Action Please By:
May 12, 2008

EPA’s Office of Water released a public review draft of its National Water Program Strategy: Response to Climate Change on March 28.  The Draft Strategy identifies potential impacts of climate change on water resources and water programs, and proposes five broad goals for the National Water Program and 46 specific actions that EPA can initiate in the current or next fiscal year to respond to climate change.

NACWA’s review of the Draft Strategy indicates that the information contained in the document about potential impacts of climate change is already familiar to the Association and its members.  The Draft Strategy does not establish any major changes in policy or direction for the Office of Water.  Most of the actions proposed in the Draft Strategy only represent some consideration of climate change in existing EPA programs.  EPA points out in the Draft Strategy that climate change challenges do not always fit into existing Office of Water programs, and that many elements of a watershed approach will increase the sustainability and resiliency of aquatic systems facing climate change impacts.  In the Draft Strategy, however, EPA does not propose any changes that will create a more holistic, watershed-based approach to water quality and climate change issues.

This Regulatory Alert seeks to summarize the 101-page EPA draft, focusing on the parts of the Strategy that deal with climate change concerns that could impact the clean water community, and seeks member input on the content of the Strategy.  NACWA plans to submit comments on the Draft Strategy by the May 27, 2008 deadline.  Members are asked to contact Cynthia Finley at 202/296-9836 or This e-mail address is being protected from spambots. You need JavaScript enabled to view it with their input by Monday, May 12 for inclusion in NACWA’s comments.

Significant Impacts from Climate Change Possible for Clean Water Programs

The Draft Strategy describes how climate change can affect water resources and water programs, and identifies air and water temperature increases, changes in levels and distribution of precipitation, increases in storm intensity, sea level rise, and changes in energy generation as having possible impacts on clean water programs.  Warmer air temperatures, for example, may lead to warmer water temperatures, resulting in higher dissolved oxygen levels and higher concentrations of some pollutants, such as phosphorus.  As a result, more waters may be listed as impaired and require development of total maximum daily loads (TMDLs), and National Pollutant Discharge Elimination System (NPDES) permits may need adjustment.  Similarly, it may become more important to change nonpoint source pollution control programs to adjust to climate change effects.

One of the most significant impacts cited in the strategy is the expected change in precipitation patterns.  The changes in levels, distribution, and intensity of precipitation will vary in different regions of the U.S., with the northeast expected to receive more precipitation and the southwest expected to receive less.  Areas with more precipitation and higher intensity storms will face more stormwater management challenges due to increased pollution and sedimentation from runoff and more sanitary sewer overflows (SSOs) and combined sewer overflows (CSOs).  Areas with less precipitation may have lower streamflow and groundwater recharge, making it more difficult to meet water quality goals.  As stated in the Draft Strategy, “additional investments in water infrastructure may be needed to manage both decreases in rainfall…and increases in rainfall.”  Prioritization of infrastructure projects may change as the public sees the effects of more overflows and other water quality impacts.

Other impacts include rising sea levels due to climate change, which may force coastal clean water agencies to relocate treatment facilities and discharge outlets.  The increased demand for biofuels made from agricultural products as an alternative to fossil fuels could increase water usage for irrigation and fuel production, and runoff of sediments, nutrients, and pesticides may become even more of a water quality problem.  This will make nonpoint source control programs more vital to maintaining and improving water quality.

EPA Outlines Five Goals to Respond to Climate Change Impacts

EPA lists five major goals for the National Water Program in responding to climate change:  use core water programs to improve mitigation of greenhouse gases, adapt the implementation of core water programs to improve their effectiveness in the context of climate change, strengthen links between EPA water programs and climate change research, educate EPA staff and other stakeholders on climate change impacts on water resources and Agency programs, and establish the management capability within the National Water Program at EPA for sustained engagement of climate change challenges.  For each of these goals, “Key Actions” were identified that the National Water Program could implement within the next two years.  The principles used to develop the Key Actions were to define areas of uncertainty, evaluate proactive and reactive actions in response to the consequences of climate change, and guard against unintended consequences of actions to address climate change.  Most of the Key Actions expand current EPA efforts to better address climate change, while some are new actions that would specifically focus on climate change issues.  All of these Key Actions are identified with the assumption that funding for the Office of Water will remain level and no new funds will be available for specific climate change actions.

EPA Office of Water Offers 46 “Key Actions” in Response to Climate Change

EPA proposes mitigating greenhouse gas emissions related to water through water conservation and energy efficiency measures.  For wastewater utilities, most of the energy is used for aeration, pumping, and solids processing, with advanced treatment, particularly denitrification and membrane filtration, also requiring significant energy use.  EPA’s Key Action #1 (page 27 of the Draft Strategy) is to improve energy efficiency at utilities, including the installation of Combined Heat and Power systems for biogas reuse.  With Key Action #4 (page 29), EPA seeks to decrease the volume of water to be treated, and therefore decrease energy use, by promoting technologies to detect infiltration and inflow into wastewater collection systems.  EPA also commits to reducing the volume of water requiring collection and treatment through Key Action #5 (page 30), promoting water conservation, reuse, and recycling at industrial facilities, and through Key Action #7 (page 31), promoting green building and green infrastructure practices for managing stormwater.

To help water programs adapt to climate change, EPA identifies Key Actions for reviewing water quality criteria, including sedimentation and velocity (Key Action #14, page 41), and biological indicators (Key Action #15, page 42) that may be affected by changes in precipitation.  Key Actions #17 and #18 (page 43) deal with effluent limitation guidelines.  New industry sectors (e.g., biofuels) and existing categories associated with alternative energy source development and other climate change actions will be evaluated, and existing effluent guidelines will be reviewed for industrial production or treatment modifications related to climate change.  Recognizing that many water quality issues are watershed issues, EPA states in Key Action #19 (page 44) that the Office of Wetlands, Oceans and Watersheds (OWOW) will develop a Climate Change Policy memo that promotes the incorporation of climate change responses into their core programs.  The NPDES permit programs will need to be adapted to respond to climate change, as described in Key Action #26 (page 49), which may include changes to low flow and other flow condition values and the promotion of watershed-based permitting.

Key Actions regarding climate change considerations in CSO long-term control plans and in management of SSOs were also defined by EPA.  In Key Action #27 (page 50), EPA plans to evaluate opportunities to address wet weather and climate change impacts at municipal and industrial treatment works, including identification of best practices for characterizing design storms that account for climate change.  The promotion of green infrastructure and sustainable infrastructure as part of wet weather management and permitting is also part of this Key Action.  EPA will develop a sustainability/vulnerability analysis handbook for climate change impacts for Key Action #30 (page 53) for use in making long-term decisions about infrastructure needs.

As part of its goal to strengthen the links between research and water program actions, EPA identifies Key Action #35 (page 61) to monitor the water-related research conducted by the U.S. Climate Change Science Program (CCSP), an interagency program that coordinates and integrates scientific research on climate change.  The Office of Water will name a representative to join the EPA Office of Research and Development (ORD) representative on the CCSP Water Cycle Working Group, and as stated in Key Action #36 (page 63), will also work with ORD in the development of research related to water impacts of climate change.

To help educate water program staff and stakeholders on climate change impacts, the Office of Water established Key Action #38 (page 65) to set up a clearinghouse website and listserv, in cooperation with other EPA offices, with documents and research related to climate change.  The Office of Water will also publish a reference document, Background Papers:  A Climate Change Primer for Water Professionals, to provide information about climate change impacts on water programs (Key Action #41, page 66).

EPA plans to maintain the National Water Program Climate Change workgroup that was responsible for writing the Strategy (Key Action #43, page 67) and to provide annual updates on the Strategy (Key Action #39, page 65), ensuring the Program’s long-term management of climate change challenges.

NACWA Seeks Member Input for Comments on the Draft Strategy

NACWA plans to submit comments to EPA about the Draft Strategy by the May 27 deadline.  Although EPA mentions the watershed approach as a cross-cutting theme, the Strategy does little to promote a watershed approach for improving water quality and responding to the challenges of climate change.  NACWA’s comments will draw upon the work of the Association’s Strategic Watershed Task Force, including the recommendations contained in the Task Force’s 2007 report, Recommendations for a Viable and Vital 21st Century Clean Water Policy.   The need for government and the public to recognize that “water is water,” as discussed in both the Task Force report and at the 2007 Water Sector Forum on Climate Change, will also be a focus of NACWA’s comments.  In considering climate change impacts, some of the controls and mandates of the Clean Water Act may not be logical, and analysis of the net environmental benefits of water treatment options may become necessary.

NACWA will also recommend other areas of research that were discussed at the Water Sector Forum on Climate Change, including temperature effects on treatment processes and removal of emerging contaminants, which will help improve water reuse and biosolids management options.  The Office of Water could also assist with providing data for refining the greenhouse gas emissions estimates for wastewater treatment made in EPA’s Inventory of Greenhouse Gas Emissions and Sinks.  NACWA has been working with EPA’s Climate Change Division to modify the emissions estimates, but more data will likely be necessary for changes to be made.

Members with input on these or any other climate change issues should contact Cynthia Finley at 202/296-9836 or This e-mail address is being protected from spambots. You need JavaScript enabled to view it by May 12 with comments or questions.  Members that submit their own comments to EPA regarding the Draft Strategy are also encouraged to send their comments to NACWA.