This page left intentionally blank. 
The Honorable Lisa Jackson 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Dear Administrator Jackson: 

From the early days of the American West came the saying, “Whiskey’s for 

drinking, water’s for fighting.” Unfortunately, too many battles are still being waged 

within the water sector over resources and coordination. Your National Advisory 

Council for Environmental Policy and Technology believes the time has come to call 

a stop to the fighting and get on with the work of making America’s water 

infrastructure responsive to the needs of the 21st century. 

The attached report outlines six key strategic recommendations for achieving 

sustainability in the water sector. This advice was developed from the collective 

experience of the Council’s membership, which cuts across multiple sectors of the 

American economy, geography, and political philosophies. The Council’s work was 

led by an outstanding Work Group of its members; Work Group members were 

Howard Neukrug, Jeff Crane, Suzanne Goss, Clayton Matt, Bill Mullican, Arleen 

O’Donnell, Harrison Rue, and Dan Watts. The full Council endorses the 

recommendations in the report. 

We believe the six recommended strategies can be readily implemented by 

EPA. The most critical need is for principled and strong support of regional and 

watershed collaboration and partnerships to fulfill essential water services to the 

nation’s growing population. EPA must continue to move to watershed-based, 

regional solutions to solve the water sector’s infrastructure challenges. 

This transition, while essential, will not be simple. The water sector’s infrastructure 

system has been built over the past 150 years. It is largely fragmented among 

political jurisdictional boundaries and divided among the drinking water supply, 

wastewater, stormwater, and water storage components of the water sector. The 

structures of current environmental regulations, the water sector business, and EPA 

do not easily accommodate locally-based, holistic solutions that are needed to 

sustain the water sector and the communities that depend upon the sector. 
This report calls on EPA to move quickly and forcefully in adopting integrated 

water resource planning and watershed management as the governing framework 

for all Office of Water regulations and policies. We recommend that the Office of 

Water integrate across its own programs and work more intentionally and vigorously 

with other federal agencies to address regional water issues. We also highlight the 

need for EPA to work more directly with local and regional collaborative efforts; to 

provide new economic, regulatory, policy, and enforcement incentives for 

collaboration; and to improve technical guidance, education, and outreach in 

support of such collaborations. 

The recent American Revitalization and Recovery Act provides the Agency with 

a fresh opportunity to tackle the water infrastructure challenge. It can do so best by 

focusing on sustainable, green infrastructure strategies that consider the entire water 

cycle and are balanced with other elements of the nation’s environmental, societal, 

and economic needs. Business as usual will keep us fighting about water in the 

future as we have in the past. Channeling the substantial investment provided by 

the stimulus into sustainable, green infrastructure concepts is essential to rebuilding 

the Nation’s water infrastructure for the 21st century. 

We hope you find this report and its recommendations useful. We look forward 

to working with you on any next steps. 

Erik J. Meyers 

NACEPT Chair 
i 

Table of Contents

Executive Summary...................................................................................................... 1

I. Introduction............................................................................................................. 5

A. Purpose of this Report......................................................................................................5

Concerns about the Long-term Sustainability of Water Sector Utilities..........................5

Regional Collaborations and Partnerships are One Possible Solution............................5

Defining a Role for EPA.........................................................................................................6

B. Background.......................................................................................................................6

Today’s Funding Gap...........................................................................................................7

The EPA Response – The Sustainable Water Infrastructure Initiative...............................7

Integrated Water Resource Planning and Watershed Management ...........................8

Regional Collaboration is not Structural Consolidation ...................................................9

C. NACEPT Sustainable Water Infrastructure Workgroup .............................................10

EPA Charge to NACEPT and the Phase I Report.............................................................10

Approach Used for this Investigation ...............................................................................11

II. Key Questions Answered..................................................................................... 13

A. What is meant by regional collaborations and partnerships? ...............................13

B. Are there indicators that would help EPA identify the types of utilities that 

would benefit from such collaborations?..................................................................14

C. What do successful regional collaborations have in common? ...........................15

D. What are the barriers to collaboration?.....................................................................16

E. What can EPA do to promote, encourage, and support water integrated 

resource planning, watershed management, regional collaboration, and a 

sustainable water sector?.............................................................................................18

III. Recommendations............................................................................................... 19

Recommendation #1: Integrated Water Resource Management..............................19

Recommendation #2: Encourage the collaborative process ......................................20

Recommendation #3: Provide new economic incentives............................................22

Recommendation #4: Provide new regulatory and policy incentives........................23

Recommendation #5: Reduce internal barriers ..............................................................25

Recommendation #6: Provide better technical guidance, education, and 

outreach ..........................................................................................................................25
ii 

Appendix I: Sustainable Water Infrastructure Workgroup Members and 

Acknowledgements .........................................................................27

Appendix II: Expert Presenters ...............................................................................29

Appendix III: List of Acronyms ................................................................................31

Appendix IV: Charge to NACEPT ............................................................................33

Appendix V: References.........................................................................................39
1 

EXECUTIVE SUMMARY

One of the most critical challenges facing the nation’s water and wastewater 

systems is how to sustain its infrastructure network to ensure that the public continues 

to enjoy the environmental, health, social, and economic benefits that clean and 

safe water provide. 

The traditional business model for water sector utilities typically focuses on 

providing one or two specific services (e.g., provision of drinking water, wastewater 

collection, storm water management, water resource management, etc.) within a 

defined service area. This system works well when populations are isolated and the 

impacts of communities on their water resources are small relative to the 

abundance of the supply. 

However, this business model is ill-equipped to deal with current infrastructure, 

regulatory, ecological, political, and economic realities. Today, it is hard to make a 

clear distinction between wastewater, drinking water, and storm water issues and 

needs. It is difficult, if not impossible, to separate the long-term ability of a utility to 

deliver essential services from the planning and political realities of the surrounding 

community, or the resource limitations of the surrounding watershed. The long-term 

viability of water-sector systems needs to be examined and addressed on a more 

comprehensive basis with these interrelationships in mind. 

Further, the issues of environmental sustainability, energy management, and 

global climate change are altering the environmental landscape forever. At some 

point, environmental priorities will need to be re-examined with possible legislative 

changes in light of the shifting landscape. Until then, EPA should do everything within 

its power to shift away from an emphasis on single media and single programs 

towards recognizing and rewarding positive, collaborative, broad-based behaviors 

within the Agency and in the regulated and stakeholder communities. Across the 

country, changes are being made by water utilities to become more financially 

sustainable. It is important that utilities and stakeholders also consider the larger 

environmental context to ensure that their strategies are viable in the future. 

To meet the growing challenges of sustainable water management, EPA needs 

to think beyond a single statute’s regulatory requirements to solve problems. Today, 

watersheds are the more appropriate unit and scale of management for an 

integrated approach to managing the nation’s water resources. Applying the 

watershed approach across EPA water programs would better inform the effective 

application of regulations and resources to solve the most pressing problems. By 

recalibrating EPA’s agenda internally, a strong “lead by example” message is sent, 

lending credibility to EPA efforts to support sustainable water resources 

management and innovative approaches. 
2 

In sum, while EPA recognizes regional collaboration as an effective tool for 

improving the long-term service of water sector utilities, identifying the specific 

function that EPA could play in promoting this approach is more challenging. The 

answer is not straightforward because many of the activities needed to create 

regional cooperation and partnerships lie outside the traditional roles of EPA. 

This report identifies specific tasks that EPA can implement to strengthen the 

framework of regional or watershed-based partnerships in an effort to create 

sustainable water systems throughout the nation. These tasks include: 

1. Adopt integrated water resource planning and watershed management as the 

governing framework for all Office of Water regulations and policy. 

Integrated water resource planning and watershed management are the basic 

building blocks for a sustainable water sector. The Office of Water needs to 

revisit opportunities to integrate across its programs for: EPA to ensure that 

federal agencies provide a coordinated effort when addressing regional water 

issues; regional EPA offices to expand their watershed-based programs and 

resources to support local dialogue; and EPA to offer more support to local and 

regional collaborative efforts. 

One of the predominant themes throughout the National Advisory Council for 

Environmental Policy and Technology (NACEPT) deliberations was the need for 

EPA to “break down the walls!” NACEPT recommends a number of actions 

including revisiting the current EPA organizational structure to reduce internal 

barriers, and focus policies, activities, and resources away from single-media, 

single-issue programmatic goals. Instead, NACEPT recommends using the 

broader, more collaborative watershed approach as the unifying theme and 

ethic; this includes integration of enforcement staff to work in collaborative 

settings. 

2. Encourage the collaborative process. 

By creating a positive environment for regionally linked water sector utilities to 

work more collaboratively, EPA can help almost all utilities and their communities 

create efficiencies. EPA can encourage local and regional collaborative efforts 

by offering regional EPA office support to local groups. EPA regional offices can 

provide venues where stakeholders can meet; offer support to local groups for 

identifying and training effective, respected leaders; and help water sector 

utilities and leaders recognize their long-term sustainability interests and needs. 

In addition, EPA can foster implementation of the recommendations by 

stakeholder groups by organizing an advisory group representative of these 

involved organizations and individuals to assist in developing specific action 

plans for how best to initiate the broadened initiatives. 
3 

3. Provide new economic incentives. 

EPA can support collaborations by: (1) strengthening its public message 

regarding the gap between available, sustainable water financial resources 

and the need to address the problems successfully, whether under the banner 

of the infrastructure crisis, water system security, emerging contaminants, water 

resource planning, or water quality; (2) working to identify and establish new 

financial incentives to encourage water sector systems to pursue regional 

collaboration opportunities by leveraging existing funded programs; and (3) 

reactivating and revitalizing Section 208 as the Clean Water Act’s cornerstone of 

watershed-based infrastructure planning. 

4. Provide new regulatory and policy incentives. 

EPA can encourage collaborations by regulatory and policy incentives such as: 

(1) identifying and establishing regulatory and policy flexibility to encourage 

water sector systems to explore integrated watershed management and 

regional collaborative opportunities; and (2) working to effectively utilize 

enforcement tools, including flexibility in enforcement and permitting schedules 

to encourage collaboration. 

5. Reduce internal barriers. 

EPA needs to do more in support of internal focus on collaborations beyond the 

significant strides it has already made. While legislative and regulatory 

mandates can inhibit the Agency’s ability to advance broader environmental, 

public health, and sustainability goals, EPA should revisit its organizational 

structure to identify and overcome any internal barriers to water system 

collaboration. One action recommended is to use the broader, collaborative 

watershed approach as the unifying theme and ethic. Additional progress 

toward collaboration could be achieved by detailing members of the 

enforcement staff to work in collaborative settings. 

6. Provide better technical guidance, education, and outreach related to 

integrated water resource planning and watershed management. 

EPA should: (1) review the Agency’s existing body of literature and programs to 

update, consolidate, and streamline the information and, if necessary, conduct 

research and gather new information; (2) partner with water sector professional 

organizations to create new, utility-focused initiatives in education, 

communication, and outreach; (3) partner with watershed stakeholder 

organizations to create a new “sustainable watershed” initiative through 

education, communication, and outreach; (4) revise its Web site, particularly 

that of the Office of Water, to align with the watershed and regional 

collaboration approach; (5) create an accessible, centralized, Web-based 

repository of tools and resources; (6) train and educate its regional offices, the 

states, and tribes on these tools and methods so that a clear and consistent 

message is communicated to the water sector and other stakeholders from 
4 

policy makers and regulators; and (7) redeploy staff to increase dialogue and 

face-to-face meetings to determine how to promote the long-term sustainability 

of systems effectively on a local or regional level. 

Where necessary and appropriate, NACEPT recommends that EPA conduct 

research and publish guidance regarding the benefits of watershed and 

regional collaborative approaches using case studies and other analyses. 

In conclusion, EPA has the opportunity to be a leader, visionary, motivator, 

catalyst, mentor, partner, financier, peer, supporter, and facilitator in strong 

support for the water sector and other stakeholders to develop sustainable 

water resource management solutions. EPA needs to assist with guidance, 

encouragement, and education; while also recognizing and rewarding those 

who are successful, thereby helping to move forward regional solutions through 

partnerships.
5 

I. INTRODUCTION

A. Purpose of this Report

The purpose of this report is to provide advice to EPA on strategies it can 

implement to promote and support water sector utility sustainability by encouraging 

regional or watershed-scale partnerships through changes in Agency policy, 

outreach, internal operations, and incentives or disincentives. 

Concerns about the Long-term 

Sustainability of Water Sector Utilities 

Water sector utilities include systems 

that provide drinking water, wastewater 

and/or storm water services, and/or are 

responsible for the protection of our 

water resources. A combination of 

forces—including population shifts, aging 

infrastructure, droughts, and economic 

constraints—impose increased stress on 

the country’s water resources and 

society’s ability to maintain or improve 

quality water sector systems. It is 

recognized that many water systems will 

witness tremendous cost pressures over 

the next several decades due to 

increasing infrastructure, operation, and 

maintenance expenses. Given current 

funding mechanisms, and existing 

infrastructure and system constraints, EPA, 

Congress, water sector organizations and 

others are concerned that a growing 

number of water systems are not 

sustainable in their current form. They 

anticipate that the number of 

unsustainable water systems will continue 

to increase as new demands and costs 

are realized. 

Regional Collaborations and Partnerships are One Possible Solution 

There are numerous management, operational, financial, and technical 

approaches, alone or combined, being used to address the looming financial, 

environmental, and sustainability issues within the water sector. This report addresses 

only one such approach; creating new regional collaborations and partnerships. By 

In May 2006, EPA requested that the 

NACEPT “Identify ways EPA can better 

advance sustainable approaches to 

water resource management and 

infrastructure to meet watershed goals.” 

The report, NACEPT’s Initial Findings and 

Recommendations on EPA’s Sustainable 

Infrastructure Watershed Pillar (July 2007), 

was submitted to EPA Administrator 

Stephen L. Johnson offering a large set of 

recommendations that fall within four 

categories of specific steps EPA should 

take: (1) lead by example; (2) educate, 

communicate, and provide information; 

(3) encourage, facilitate, and fund 

collaboration; and (4) develop, use, and 

fund specific tools. 

In August 2007, the Agency amended 

its request to NACEPT by asking that the 

Council "recommend to EPA changes in 

policy, outreach, internal operations, 

and/or incentives and disincentives to 

foster collaborative partnerships in the 

water utility sector.” This NACEPT report 

specifically addresses this amended 

request from EPA. 
6 

using this approach, water sector systems can resolve a key weakness found in 

many of our nation’s water systems – a profusion of discreet water utilities planned, 

designed, built, operated, regulated, and managed independently of each other. 

By creating a positive environment for independent, regionally-linked water 

sector utilities to work more collaboratively or in partnership, utilities and their 

communities can better identify, prioritize, and integrate a regional approach to 

long-term water system planning and infrastructure needs. This approach not only 

can reduce future water utility costs, create gains in efficiency, and limit new 

infrastructure needs, it can also provide a comprehensive approach to 

environmental and ecological improvement while expanding water utility and 

community sustainability. 

Defining a Role for EPA 

EPA recognizes regional collaboration as an effective tool for improving the 

long-term sustainability of water sector utilities. However, identifying the specific 

function that EPA could play in promoting this approach is more challenging. The 

answer is not straightforward because many of the activities needed to create 

regional cooperation and partnerships lie outside the traditional roles of EPA. 

This report identifies specific tasks that EPA can implement to strengthen the 

framework of regional or watershed based partnerships in an effort to create 

sustainable water systems throughout the nation. 

B. Background

Beginning with the creation of the National Environmental Protection Act (NEPA) 

in 1969 and EPA as an agency one year later, there has been a dramatic decrease 

in levels of pollution throughout the United States. As this “veil of pollution” lifted and 

basic understanding of environmental systems matured, the overall approach to 

meeting environmental, public health protection, and ecological mandates 

changed. Today, EPA uses a mix of regulatory, enforcement, mentoring, leadership, 

and partnering relationships to achieve these goals. 

Unfortunately, federal legislation and resulting regulation, has not kept up with 

changing environmental realities. Many of the legislated requirements have created 

inflexible mandates and organizational structures that can, at times, result in a 

compartmentalized approach to problem solving. 

EPA’s current organizational structure and programs mirror the authority 

provided the Agency under federal environmental legislation such as the Safe 

Drinking Water Act and the Clean Water Act. Similarly, states and water utilities have 

also structured their programs, functions, and organizations using the same 

categories offered by EPA and the original federal legislation. Today, the water 

sector includes four major areas: 

 Water resources management and source water protection 
7 

 Drinking water treatment and distribution 

 Wastewater collection and treatment 

 Wet weather management (storm water) 

This approach served the nation and environment well when addressing the 

large, almost insurmountable, water pollution and infrastructure challenges of the 

1970s and 1980s. Major programs targeted highly polluted rivers and streams and 

limited regulations to protect the public drinking water supply. This resulted in large, 

federally funded infrastructure programs, such as the construction grants program 

for new water pollution control plants under the Clean Water Act. 

Today’s Funding Gap 

Today, there is growing discussion of the water sector’s enormous infrastructure 

and capital investment crisis. While the primary issues of concern vary across the 

country and by water sector utility, increasing regulatory burdens, deferred 

maintenance, a “natural” convergence of aging infrastructure demands, poor 

system management, jurisdictional limitations, and new system capacity needs have 

created an estimated $1 trillion funding gap between known sources of capital and 

the anticipated future costs for maintaining and upgrading the nation’s water, 

wastewater, and storm water infrastructure systems. 

When also considering new challenges posed by global climate change, 

shifting and growing US populations, and their anticipated impacts on water 

resources—water supplies, flooding, drought, river and lake water quality, and 

changing industrial and agricultural water requirements—the future becomes even 

more ominous. 

As the problem has become better defined over the past decade, so has the 

reality that federal, state, local, and tribal governments will be largely unable (or 

unwilling) to provide the necessary funds to bridge the funding gap. Additionally, 

the traditional remedy of passing these increased costs directly onto the consumer is 

unaffordable in many urban and rural communities. 

The EPA Response – The Sustainable Water Infrastructure Initiative 

In response to growing concerns expressed by Congress, states, tribes, and 

water sector stakeholders, EPA, led by the Office of Water, established a new 

program called the Sustainable Water Infrastructure (SI) Initiative. EPA Administrator 

Johnson noted that sustainability of the water sector “is everyone’s challenge:” 

“By supporting collaborations...we are working with our utility and private sector 

partners to develop solutions for managing and sustaining our shared 

infrastructure assets.” 

SI activities are organized around four priority areas: 

 Better utility management 
8 

 Full-cost pricing of water 

 Water efficiency and conservation 

 Watershed approaches to water management 

Progress is being made on many fronts. For example, a group of utility experts 

and executives are working with EPA on a manual entitled “Effective Utility 

Management.” 1 This manual is designed to assist utility managers with improving 

their business skills, especially those skills unique to the water sector. 

In addition to these activities, the Agency is moving forward with innovative 

approaches to best utilize the remaining federal and state funds, especially those 

available through the State Revolving Fund (SRF) program support for small systems, 

including tribal set asides. For example, EPA is providing tools and technical 

assistance to small water and wastewater systems to improve technical, 

managerial, and financial capacities in a series of newly released EPA documents1

and programs: National Capacity Development Strategic Plan2, Analysis on the Use 

of Drinking Water State Revolving Fund Set-Asides: Promoting Capacity 

Development3, and The Check Up Program for Small Systems (CUPSS)4. EPA believes 

that these tools will help bridge the growing financial gap faced by small drinking 

water and wastewater systems as they repair and replace infrastructure. 

Integrated Water Resource Planning and Watershed Management 

Integrated Water Resource Planning (IWRP) is the management of water 

resources over an entire watershed, providing integrated solutions to meet drinking 

water, water supply, wastewater, and storm water needs and requirements. IWRP 

allows communities to collaborate as they identify, prioritize, and balance resource 

needs within a watershed. IWRP can be a catalyst to bring about cooperation 

among the officials responsible for managing water sector systems. 

The importance of IWRP was alluded to in the first NACEPT report on Sustainable 

Water Infrastructure which emphasized the importance of this approach to EPA: 

 “...build upon and leverage its existing partnerships and alliances to promote 

collaboration among water, wastewater, and storm water utilities, and industries 

in a given watershed area. This would give them a more effective voice with 

local decision makers and stakeholders. EPA, tribes, states, and utilities should 

elucidate the benefits of working together to the many different types of 

organizations that might participate in the watershed approach.” 

 

1 http://yosemite.epa.gov/water/owrccatalog.nsf/HomePage?OpenForm&CartID=8189-102727

2 EPA# 816K07003

3 EPA# 816R06004

4 http://www.epa.gov/safewater/cupss/index.html
9 

NACEPT recognizes that it is difficult to 

communicate among people, agencies, 

utilities, and other stakeholders when there is 

no venue to articulate one’s needs and 

interests. IWRP, as well as utility collaboration 

and partnerships, can be difficult to organize 

and make successful. As stated in the first 

NACEPT report on Sustainable Water 

Infrastructure: 

“Promotion of this type of collaboration will require clear demonstration in the 

local context of advantage. Without that, natural resistance to the uncertainties 

of change will interfere with movement to collaboration.” 

Even so, as described in the next section of this report, regional collaboration 

holds significant promise as a tool to remedy some of the water sector’s issues of 

sustainability. 

Regional Collaboration is not Structural Consolidation 

A word of caution is in order – regional collaboration is not the same as regional 

facilities. Expanding regional facilities into new areas can promote sprawl and 

encourage development in exurbia/rural areas instead of redeveloping brownfields 

and other developed areas. From the first NACEPT report on Sustainable Water 

Infrastructure: 

“When the authors of this report speak about regional collaboration, 

regionalization, partnerships, etc, we are speaking about a functional, 

operational, communicative, supportive arrangement among stakeholders and 

not necessarily are we promoting structural or infrastructure consolidation.” 

The primary recommendation of 

this NACEPT report is for EPA to reinvigorate its active support and 

participation in IWRP, and for the 

Agency to use Watershed-Based 

Management as its organizational 

foundation for supporting regional 

collaboration and partnerships 

throughout the United States.

The Infrastructure Action Group of Southeastern Pennsylvania First Suburbs Project

An example of the new way of approaching water sector sustainability is being 

attempted in the Philadelphia suburbs by a group of citizens, academicians, political 

leaders, and clergy. They have worked to identify the biggest issues in these first-ring 

suburbs and narrowed their focus to affordable housing, education, social services, and 

water infrastructure. The Infrastructure Action Group of Southeastern Pennsylvania First 

Suburbs Project prescribes that the goals of system regionalization and sound infrastructure 

investment involve the following five principals: 

 Efficiency – fix existing infrastructure before building new facilities and systems 

 Fiscal Sustainability – adopt full-cost pricing policies that build future maintenance and 

renewal costs into current rate structures 

 Environmental Sustainability – encourage a comprehensive approach to water 

management that protects water quality, conserves ground water, prevents 

ecologically harmful withdrawals from rivers and streams, and coordinates infrastructure 

investments with sound land use management 

 Equity – water flows across municipal boundaries, therefore the cost of water needs to 

be shared among all in the watershed 

 Coordination – new investments should be accompanied by new institutional 

arrangements for improved coordination and more efficient service delivery 
10 

C. NACEPT Sustainable Water Infrastructure Workgroup 

EPA Charge to NACEPT and the Phase I Report 

EPA asked NACEPT to assist the Agency in advancing cost-effective and 

sustainable approaches to water resource management and infrastructure to meet 

water quality goals. A workgroup, a subset of the Council, was established to assist 

NACEPT to respond to the charge. The full charge and additional background 

material are contained in Appendix IV. 

Specifically, in May 2006, EPA requested that NACEPT: 

“(I) Identify ways that the EPA can better advance sustainable approaches to 

water resource management and infrastructure to meet watershed goals, and 

(II) Analyze the primary and secondary benefits of non-traditional, or alternative, 

approaches to water infrastructure management.” 

The report NACEPT’s Initial Findings and Recommendations on EPA’s Sustainable 

Infrastructure Watershed Pillar (July 2007), also known as Phase I of the charge, was 

submitted to EPA Administrator Johnson offering a large set of recommendations 

that fall within four categories of specific steps EPA should take. These steps include: 

 Lead by example 

 Educate, communicate, and 

provide information 

 Encourage, facilitate, and fund 

collaboration 

 Develop, use, and fund specific 

tools 

In October 2007, EPA amended the charge to NACEPT, requesting that the 

group focus on the current issue. Specific recommendations include: 

“(II) Recommend to EPA changes in policy, outreach, internal operations, 

and/or incentives and disincentives to foster collaborative partnerships in the 

water utility sector.” 

This is in direct support of a recommendation in the first NACEPT report: 

“Another opportunity is for EPA to build upon and leverage its existing 

partnerships and alliances to promote collaboration among water, wastewater, 

and storm water utilities, and industries in a given watershed area. This would 

give them a more effective voice with local decision makers and stakeholders. 

EPA, tribes, states, and utilities should elucidate the benefits of working together 

to the many different types of organizations that might participate in the 

watershed approach.” 
11 

This report deals specifically with this amended charge. However, this current 

effort recommends that EPA prepare a progress report regarding actions taken in 

response to the Phase I report and other actions taken or underway to move these 

approaches forward within the Agency. Moreover, periodic reporting of measures of 

collaborative effort success would help focus EPA headquarters and regional efforts 

to support collaboration at all levels. 

Approach Used for this Investigation 

The NACEPT Sustainable Water Infrastructure Workgroup held a number of 

meetings and conference calls to gain an initial understanding of the charge from 

EPA, as well as to understand current approaches and activities within the Agency. 

It also met with stakeholders from professional water organizations, private 

consultants, and utility mangers to learn about perceptions, activities, and plans. In 

addition, one-on-one interviews were held with various state, tribal, local, non-profit, 

and private groups from around the country. Significant reference resources 

became available to the group from various sources. This information was used to 

inform the Workgroup during its reflections, deliberations, and writing of these 

recommendations. Appendix II lists the experts brought in to speak with the 

Workgroup and Appendix V provides the list of references. 
12 

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13 

II. KEY QUESTIONS ANSWERED

This section uses a question and answer format to address some of the issues 

raised during the NACEPT Sustainable Water Infrastructure Workgroup investigation 

on regional collaboration and the role EPA plays. 

A. What is meant by regional collaborations and partnerships?

NACEPT met with experts involved with inter-organizational partnership, utility 

management, and regulatory compliance and reviewed many case studies and 

examples of successful regional utility collaborations. 

In its most simplistic form, regional collaborations are a partnership between two 

or more utilities to form cost-sharing agreements in order to more effectively provide 

services. Many utilities today utilize some form of these partnerships or agreements. 

Examples include: 

 Purchase equipment, chemicals, office supplies, etc. 

 Contract services for engineering, operations, billing, call center 

management, meter reading, training, etc. 

 Provide mutual aid in case of drought, flood, terrorism, or other emergencies 

 Consolidate infrastructure by constructing physical interconnects 

 Consolidate and centralize management 

These cost-sharing agreements can be very effective tools, especially for small 

water sector utilities. However, this form of partnership does not address the 

structural sustainability issues described earlier. That is, for water sector utilities to 

become sustainable, they must operate within the context of a sustainable system. 

This can only be accomplished when the collaborative approach is used within the 

context of Integrated Water Resource Planning or a watershed management 

approach. Under this definition of regional collaboration, water sector utilities would 

be working with regional stakeholders to: 

 Develop comprehensive, regional assessments and plans to tackle the 

infrastructure, ecological, and economic needs within the watershed or 

region 

 Address regional issues of water resources, environmental regulations, and 

community sustainability 

 Influence policy, legislation, regulation, and financial aid on federal, state, 

tribal, and regional levels 

 Provide broad education, communication, and/or outreach efforts 

 Prioritize environmental projects on a regional basis 

Conclusion: EPA should restructure and align its programs to more effectively promote 

Integrated Water Resource Planning and watershed management as the key building blocks 

that communities can use to ensure the sustainability of the nation’s water infrastructure. 
14 

B. Are there indicators that would help EPA identify the types of 

utilities that would benefit from such collaborations?

NACEPT was asked if there were any specific utility characteristics or indicators 

that would help EPA identify utilities that could benefit from collaborative, regional 

efforts. In particular, it was hypothesized that small systems would be especially 

good candidates for regionalization for demographic, resource, and financial 

reasons. While results indicate that small systems represent an important subset of 

utilities that would benefit from the regional collaborative approach, NACEPT found 

the applicability of this approach to be significantly broader. 

NACEPT also found that there are many reasons why a utility may want to 

consider a collaborative, regional approach to watershed management, and that 

multiple categories of utilities may be well served by a partnering relationship. 

Characteristics of utilities that would particularly benefit from collaborative 

approaches include: 

 Customer Demographics 

− Water systems serving small customer bases 

− Systems anticipating or experiencing significant growth/decline in 

population

− Affordability, driven by a low per capita income

 System Revenues 

− Systems with revenues unable to support adequate staffing 

− Utilities unable to recover operations, maintenance, and capital 

expenditures 

 Regulatory Program Burdens 

− Combined Sewer Overflow/Sanitary Sewer Overflow (CSO/SSO) 

communities limited by affordability considerations 

− Phase II Municipal Separate Storm Sewer System (MS4) (i.e., a separate 

storm sewer system) without sufficient resource capacity for its 

management structure or revenue base 

− Wastewater systems experiencing compliance concerns due to permit or 

consent order restrictions; or that are discharging to impaired water 

bodies where Total Maximum Daily Loads (TMDLs) are required 

− Water systems experiencing compliance concerns such as: 

x Arsenic, trihalomethanes (THMs), chlorination, lead, cryptosporidium 

 Resource Limitations 

− Insufficient water supply, resources, or impairments

x Repeated or prolonged droughts, system reliability, water quality, 

vulnerable supplies, competition, environmental restrictions, climate 

change, increased flooding, or significant population shifts

− Growing communities with septic systems or other decentralized systems 

without sufficient infrastructure or management support 
15 

 Jurisdictional and Geographic Constraints 

− Systems that are limited by political, geographic, or infrastructure 

constraints may be great candidates for collaborative efforts if these 

limitations can be addressed and overcome 

− Systems that are impacted by out-of-jurisdiction upstream 

activities/development/ water withdrawals 

Conclusion: By creating a positive environment for regionally linked water sector utilities to work 

more collaboratively, EPA can help utilities and their communities create efficiencies and 

integrated systems that are more sustainable and benefit the community in multiple ways. 

C. What do successful regional collaborations have in common?

NACEPT found that successful regional collaborations typically exhibit four 

common attributes:

 There is a leader who recognizes that some critical needs, issues, or challenges 

are beyond the community’s or utility’s ability to control or resolve 

independently. 

− Typical drivers include utility-specific problems or larger regional problems 

such as population growth, growing infrastructure costs, transportation 

needs, environmental protection, education, or community development. 

− Awareness of these issues may have been generated within the utility (by 

management or board members) or externally (by local government 

officials or policy makers). 

− In rural watersheds, with smaller utilities and limited staff, an outside agent 

(e.g., local, regional, or non-profit) was often instrumental in initiating 

awareness and organizing partnerships. 

 There is some motivating factor—such as a financial incentive, compliance 

penalty, drought, or flood—that encourages the utility to consider solutions 

outside its traditional boundaries. 

− Existing funding sources are unable to meet system needs and new 

increases in revenues are unacceptable or unaffordable to the 

community. 

− There are new incentives in the form of federal, state, tribal, and local 

grants, matching funds, new revenues, profits, or other monetary 

incentives that reward the collaborative approach. 

x Even relatively small dollar amounts available for planning beyond 

immediate system needs help encourage collaborative efforts. 

− Regulatory requirements or enforcement actions, when used with 

innovative direction, can encourage regional collaboration. However, if 

not used carefully, they can also inhibit broader discussions and regional 

solutions. 

− Drought, other natural or manmade resource challenges, or other crises, 

provide a short-term opportunity to open discussions among regional 

players. 

− Longer-term issues that are on the minds of citizens such as climate 

change, water security, aging infrastructure, sprawl, energy, population 

growth, or affordability concerns can help motivate localities to consider 

collaborative options.
16 

 There is a safe, neutral venue where regional stakeholders can congregate, 

discuss shared regional visions and goals, and explore solutions that address all 

potential issues, costs, and benefits. 

− There is typically a strong leading partner, whether a utility manager or 

board member, an elected local policymaker or administrator, or 

community leader who can champion regional solutions among the 

stakeholders. 

− There is typically recognition among the stakeholders that they share a 

common resource and that the use of this resource affects others. 

− There is either a history of, or a desire for, working across political 

jurisdictions, between government, business, and non-profits, and across a 

wide range of issues. 

 The collaboration process should ultimately result in a written agreement. 

− For the collaborative process to work it must ultimately result in a written 

agreement, which can take time. 

− If there are EPA or state impending enforcement actions, inflexible 

regulatory timeframes, or mounting penalties, water sector systems 

typically make quick, bad investment decisions to reduce overall costs 

and risks. This may inhibit innovation and outside-the-box thinking that 

could result in better and more cost effective solutions. 

Conclusion: EPA can encourage the collaborative process by: (1) helping utility and 

community leaders recognize their long-term local needs; (2) providing incentives to motivate 

groups to work together; (3) creating a safe, neutral venue where EPA can act as a credible 

convener of stakeholders; and (4) allowing some regulatory flexibility in schedules and penalties 

to accommodate collaborative partnerships that lead to better or equivalent environmental 

results. 

D. What are the barriers to collaboration?

NACEPT identified several significant barriers at the federal, state, tribal, local, 

and utility level that may inhibit or prevent water sector systems from moving 

forward with collaborative partnerships. 

 Individual and Organizational Barriers 

− Unaware of potential advantages. In the absence of a perceived benefit, 

collaborative opportunities are not pursued. 

− No perceived need for change. Operations, reliability, and costs may 

present no current issues; longer-term capacity and sustainability 

concerns may be left unaddressed. Alternatively, line management may 

be so intently focused on current issues and operational problems, that 

there may be little capacity to consider utility sustainability. 

− Budget cycles. Budget cycles and planning horizons may inhibit or 

discourage collaborative approaches which often are time consuming 

and on different timeframes than local government political and 

budgetary cycles. 

− Concerns over loss of local control. Unknown risks, costs, and a perceived 

(or real) loss of independence, influence, oversight, or control over 

policies, budgeting, hiring, decision making, risk management, and rates 
17 

may deter utility managers or the local community from considering 

collaborative options. 

 Regional and Jurisdictional Issues 

− Water rights. There may be concern that collaborative partnerships may 

lead to a forced sharing of water rights and potential shortfalls of 

available water for one system to the benefit of another. 

− States’ Board of Public Utilities. Many states have utility boards that 

regulate pricing for non-municipal water sector utilities. The political, 

technical, and economic complexities of some collaborative agreements 

can make bringing such matters before a state utilities board daunting. 

The state board may become a barrier to even exploring the idea of 

collaboration without a clear understanding of the process and a clear 

concept of the benefits that might result. 

− Regional dynamics. Neighboring jurisdictions—whether they are states, 

counties, municipalities, or school districts—often have political, 

demographic, historical, economic, or community-based rivalries (i.e., 

sports) that make it difficult to develop trust and equity among parties. 

− Using water as a regional planning tool. The availability of water to 

promote or limit growth is an unfortunate reality in many communities. 

Without the availability of alternate community planning mechanisms, 

water is often a political tool that inhibits the formation of regional 

collaborations due to competing local interests and the lack of clear 

understanding of the benefits of collaborative approaches. 

 Lack of Enterprise Funding 

− The true cost of water service is a fundamental component of sustainable 

water resource systems. Many communities rely on a portion of water 

sector revenues as financial support for other municipal services, or for 

their general fund. In other instances, such as storm water management, 

the cost of water sector services is hidden in the general real estate tax 

base. Lack of an enterprise fund based on the true cost of service 

confounds collaborations that involve cost or revenue sharing. In addition, 

potable water is heavily subsidized and consumers do not pay the full 

costs of supply and delivery, which reduces revenues and in some cases 

negatively affects management approaches and potential collaborative 

efforts to promote conservation and efficient management approaches. 

− Similarly, apprehension about agreements with existing bondholders and 

solutions for handling unequal debt, particularly if the debt is municipal, 

may hinder the exploration of collaboration. 

 Limited Ability of Regional Stakeholders to Take a Holistic View 

− Success in establishing collaborative partnerships depends on individuals 

who can imagine the advantages of regional sharing of service 

responsibilities and the benefits reaped because of the partnership. 

Conclusion: Many barriers to regional collaboration are outside the boundaries of traditional 

EPA approaches to resolution. For EPA to be effective in this arena, the Agency will need to 

consider significant new organizational directions such as those described in the NACEPT 

Report, Everyone’s Business: Working Towards Sustainability Through Environmental Stewardship 

and Collaboration5. Key recommendations include that EPA should: (1) reframe its mission with 

 

5 http://www.epa.gov/ocem/nacept/reports/pdf/2008-0328-everyones-business-final.pdf 
18 

stewardship as the unifying theme and ethic; (2) strive to become the world’s premier 

stewardship model and catalyst by integrating regulatory programs, grants, voluntary 

partnerships, information, in-house operations, and other tools into a common framework; (3) 

foster stewardship by providing leadership in collaborative governance and participating in 

partnerships organized by others; (4) systematically invest in the skills and competencies 

necessary for the Agency’s domestic and global leadership in environmental stewardship; and 

(5) drive the ethic and practice of stewardship deep into the culture of the Agency. 

E. What can EPA do to promote, encourage, and support water 

integrated resource planning, watershed management, 

regional collaboration, and a sustainable water sector?

EPA needs to take a broader perspective on how water sector utilities are 

planned, managed, and regulated. EPA needs to connect and, in many cases, 

reconnect with grassroots organizations to support collaborative efforts by 

communities to consolidate resources and thereby improve the benefits and cost 

effectiveness of integrated approaches to managing drinking water, wastewater, 

and storm water resources. To accomplish this collaboration, EPA should take 

advantage of the opportunities provided by other federal, state, tribal, regional, 

and local agencies, as well as non-governmental organizations (NGOs), to break 

down parochial barriers and build consensus within neighboring communities. 

Conclusion: EPA needs to be a leader, visionary, motivator, catalyst, mentor, partner, financier, 

peer, supporter, and facilitator in strong support for the water sector and other stakeholders to 

use an integrated, watershed-based approach that explores regional collaborative 

opportunities to develop sustainable, water resource management solutions. EPA needs to 

assist with guidance, encouragement, and education; recognizing and rewarding those who 

are successful, and help to move forward regional partnerships. 
19 

III. RECOMMENDATIONS

The National Advisory Council for Environmental Policy and Technology 

(NACEPT) recommends the following. 

Recommendation #1: Integrated Water Resource Management

Action: EPA needs to more fully adopt Integrated Water Resource Planning and 

Watershed Management as the governing framework for Office of Water (OW) 

regulations and policy. Increased demands on the nation’s water resources—

whether due to population growth, pollution, regulations, recreational and fish and 

wildlife concerns, competing water needs from energy, agriculture or industry, or 

climate change—will continue to place pressure on the water sector to find new, 

more sustainable business strategies. Since most of these issues involve stakeholders 

and resources outside the control of the local water sector utility and its local pipe 

network, a collaborative, watershed-based approach to problem solving will be 

necessary. 

This situation is complicated by a community of water systems not well 

configured to address multi-media environmental concerns, or even issues involving 

the entire water cycle within its jurisdiction. 

In order for EPA to support the sustainability of the water infrastructure system, 

whether through regional collaboration or other methods, the Agency will need to 

move fully and quickly to a new water resource management strategy. This resource 

management strategy should endorse, encourage, and ultimately require water 

sector stakeholders to take advantage of all opportunities for coordinated regional 

or watershed-based collaboration, planning, operations, and management. 

Action: The EPA Office of Water should revisit opportunities to integrate across its 

programs. There are tremendous opportunities for the water sector to begin to work 

across its four segments – drinking water, water resources, wastewater 

management, and storm water management. Examples include: 

 Integrating drinking water source protection rules for contaminants such as 

cryptosporidium with water quality standards and controls under the Clean 

Water Act. 

 Expanding the “green infrastructure” strategy, which has great potential and 

enormous support for storm water management, into other aspects of water 

resources management such as wastewater, CSOs, Storm water Phase I and II 

programs and Capacity, Management, Operations, and Maintenance 

(CMOM). 

 Reintroducing Section 208 of the Clean Water Act, redesigning the program 

for watershed-based Integrated Water Resource Planning, and creating 

financial (e.g., SRF) incentives for collaborative watershed based planning 

and infrastructure funding. 
20 

Action: EPA should ensure that federal agencies provide a coordinated effort 

when addressing major regional water issues. EPA should work to ensure clear 

communication and coordination with other federal agencies that have 

programmatic responsibilities that may impact the water sector (e.g., the US Forest 

Service, US Army Corps of Engineers, Bureau of Land Management, National Park 

Service, Fish and Wildlife, Federal Highways, Department of Defense, and Natural 

Resources Conservation Service). Where possible, the Agency should assume a 

leadership role. 

Action: Regional EPA offices should expand their watershed-based programs 

and resources to support local dialogue. Each of the ten regional offices should 

increase its capacity to support local and regional dialogue and facilitation, thereby 

encouraging stakeholders to meet, discuss, and solve common environmental and 

infrastructure sustainability issues. Where this is not immediately possible due to 

resource or political concerns, EPA should enlist the support of local foundations or 

non-profit organizations to fill this void. 

EPA needs to return to its original central tenet for water sector policy: Comprehensive Planning 

for Total Water Management. During the 1970s and 1980s, EPA focused many of its efforts on 

improving the water environment by requiring the development of Clean Water Act Section 

208 Regional Water Quality Management Plans. These plans encouraged citizen-group 

participation and comprehensive watershed planning to assist federal, state, tribal, regional, 

and local decision makers to focus on priority water quality issues, and provide local input and 

guidance to overall water quality programs. 

At that time, the Section 208 process had three significant shortcomings: (1) it was developed 

prior to the emergence of citizen-based watershed groups and therefore generally did not 

include significant stakeholder input; (2) although the process allowed for the identification of 

all sources of pollution, the process was generally limited to EPA’s primary concerns – point 

source dischargers; and (3) there was neither a mandate nor long-term funding for 

implementation of the Section 208 plans. 

Today, the stakeholder partnerships imagined decades ago under Section 208 have come to 

fruition in the form of hundreds of watershed groups across the nation. In addition, the total 

water management concepts of Section 208 fit well with today’s focus on a collaborative 

watershed approach to comprehensive total water management. Section 208 deserves serious 

consideration as a viable mechanism that could be reinvigorated based on today’s 

challenges to foster collaborative watershed-based infrastructure planning. 

Recommendation #2: Encourage the collaborative process

Action: EPA needs to offer more support to local and regional collaborative 

efforts. Often, the best role for EPA is supportive, not directive. EPA needs to get 

more involved in regional planning issues, especially identifying where there is 

crossover between community issues and water sector needs. 

In Southeastern Pennsylvania, the Resource Conservation and Development Council (RC&D) is 

seeking funds from EPA and others to assist six municipalities with a pilot cooperative program 

to develop economically feasible options for dealing with storm water management issues, 

including current MS4 and upcoming TMDL requirements. These municipalities are highly 

urbanized, and relatively small. They have severe technical and economic constraints when 
21 

dealing with storm water related regulatory requirements and other activities identified in 

regional watershed plans. The total cost for this project is $2 million dollars. Clearly, federal 

support from EPA is needed to implement technical transfer and provide regulatory flexibility. 

This pilot program provides significant examples of collaborative strategies for communities in 

similar circumstances. 

Action: EPA regional offices should offer local groups support with identifying 

and procuring safe, neutral venues where stakeholders can meet. Strong 

collaborative efforts often start at the grassroots level. These individuals or 

organizations require a safe, attractive, and neutral venue that encourages 

stakeholders to attend meetings and hold open and honest dialogue. EPA should 

recognize and embrace this basic requirement of collaboration by facilitating 

logistical and other resource support for states, tribes, NGOs, and local groups to 

meet. 

Action: EPA regional offices should offer local groups support for identifying and 

training effective, respected leaders. Every collaborative effort requires effective, 

respected leadership. Identifying an individual or organization that is highly 

regarded in the community who can broker, facilitate, organize, and direct the 

collaborative process is critical when building successful collaborations. EPA should 

recognize and embrace this basic requirement of collaboration, and provide the 

capacity and resources to reach out to local groups as well as provide leadership 

training using effective practices gleaned from successful partnering examples. 

Action: EPA should help water sector utilities and leaders to recognize their longterm sustainability interests and needs. Strong leadership is required to ensure that 

EPA program managers are encouraged to maintain a collaborative facilitator role. 

Good recent examples of water sector utilities and stakeholders working together for 

long-term sustainability include the Chesapeake Bay Program6 (Region 3), the 

Schuylkill Action Network7 (Region 3), and the Mystic River Workshop8 (Region 1). 

For example, a major effort is underway to improve the Schuylkill River and its 

tributaries by the Schuylkill Action Network (SAN), a national leader in collaborative 

watershed protection. The SAN is a group of more than 60 government, business, 

and non-profit partners convened by EPA to tackle the challenges in restoring the 

river. With guidance from EPA Region 3 and the Philadelphia Water Department, the 

SAN has grown from four members in 2003 to over 200 members today – 

representing government agencies, local watershed organizations and land 

conservation organizations, businesses, universities, water suppliers, and citizens. SAN 

members use the network to coordinate activities, pool resources, promote policy 

changes, and implement priority projects that protect and improve the water 

resources of the Schuylkill River – a source of drinking water for over 1.5 million 

people in Southeastern Pennsylvania. 

 

6 http://www.chesapeakebay.net 7 http://www.schuylkillactionnetwork.org 

8http://www.epa.gov/region1/mysticriver/basicinformation.html 
22 

The SAN provides an effective means of exchanging new information among a 

diverse and large audience. It promotes efficient implementation of measures 

intended to protect and improve the Schuylkill watershed. For these reasons, the 

SAN is good model of how EPA can support water utilities and other leaders in 

recognizing, and addressing, their long-term sustainability interests and needs. 

EPA should strengthen its position as a partnering agency for purposes of 

enhancing all of its programs, both regulatory and non-regulatory. More effective 

partnering is particularly important for non-regulatory programs where voluntary 

action, based on trust, assistance, and persuasion is fundamental. This 

recommendation is from the National Academy of Public Administration for EPA, 

April, 2007: Taking Environmental Protection to the Next Level9. 

Action: EPA should establish a Sustainable Water Resources Stakeholder 

Advisory Group to assist EPA in the planning and the implementation of the 

recommendations in this report. This could be done through NACEPT. EPA would 

benefit from a forum of stakeholders that would be able to provide perspective and 

feedback about the recommendations contained in this report and others. An 

important activity that could be carried out with the assistance of such a group 

would be the development of an action plan and a schedule of implementation. 

Participation by respected stakeholders in this level of planning could be expected 

to enhance credibility and acceptability to the activities that emerge from the 

process, thereby increasing the probability of widespread participation. The impacts 

of implementation of the recommendations will increase significantly with the 

support of key stakeholders, such as business and environmental leaders and 

government officials who are integrally involved in land-use policies and programs. 

The nature and longevity of the advisory group would depend on EPA procedures 

and the confirmed value of the advice provided. 

Recommendation #3: Provide new economic incentives 

Action: EPA needs to strengthen its public message on the need for additional 

federal funding for water sector initiatives, whether under the banner of the 

infrastructure crisis, water system security, research and development, water 

resource planning, or water quality. In an effort to reverse the trend of declining 

federal financial support for the water environment, EPA needs to work with the 

water sector professional organizations to explain the coming crisis in water 

infrastructure sustainability. 

Financial incentives are on the decline. In the past decade, Community Based Environmental 

Protection Watershed Teams have been eliminated from EPA regional offices. Smaller funding 

programs and other incentives used by local groups such as the Regional Geographic 

Initiatives and 104(b)(3) grants have also been eliminated. Larger Targeted Watershed Grants 

have replaced smaller watershed programs better suited for local collaborative efforts with 

watershed groups. In 2007, ten Targeted Watershed grants were awarded, but only two last 

year. 

 

9 http://www.napawash.org/pc_management_studies/EPA_Summary_Report_5-17-07.pdf 
23 

Action: EPA should work to identify and establish new financial incentives to 

encourage water sector systems to investigate regional collaboration opportunities. 

Although there are very limited funds available for existing financial incentive 

programs such as the Drinking Water State Revolving Fund (DWSRF) and the Clean 

Watersheds State Revolving Fund (CWSRF), there may still be opportunities to 

leverage these funds to encourage collaboration. Opportunities include: 

 Provide technical assistance to states and tribes based on accessing the 15 

percent DWSRF or tribal set-asides to support regional collaboration efforts. For 

the CWSRF regional facility planning grants, EPA should work to provide a 

similar dedicated funding stream. 

 Encourage states to use a system similar to the Texas Intended Use Plan (IUP) 

Program to create collaborative incentives. 

Texas uses the EPA IUP ranking process to award infrastructure projects additional “ranking 

points” for regionalization and consolidation. This can be a very powerful incentive, especially 

since the CWSRF and DWSRF are currently oversubscribed and underfunded. However, these 

projects are typically offered to the SRF boards for ranking near the completion of the design 

process and not during the concept/planning period. 

Action: EPA should renew Section 208 grant funding. The Section 208 process 

appears particularly well-suited to re-join the EPA toolbox of financial and regulatory 

incentives to encourage the watershed approach. 

Section 208 Plans. EPA should reinvest in comprehensive watershed management planning 

and foster collaborative partnerships between utilities and all other stakeholder groups in the 

watershed as initially envisioned by Section 208. Non-profit citizen watershed groups in 

partnerships with utilities have demonstrated a greater potential to leverage dollars from a 

multitude of sources and use the watershed planning process as a means to develop wide 

consensus within communities. The implementation of these plans will result in healthier 

watersheds and lower costs for water and wastewater utilities over the long term. 

Recommendation #4: Provide new regulatory and policy incentives 

The use of consent orders, penalties, and other enforcement actions often shuts 

down communication and collaboration. As a result, reactive investment decisions 

can be made by water sector system administrators that are not sustainable in the 

long run. Care must be taken by EPA to provide the time to engage the regional 

stakeholders and determine if alternative watershed-based solutions exist. 

Action: EPA should work to identify and establish regulatory and policy flexibility, 

which would encourage water sector systems to explore integrated watershed 

management and regional collaborative opportunities. 

 An excellent example of EPA following this approach is the March 5, 2007 

memorandum from Ben Grumbles to EPA Regional Administrators on using 

Green Infrastructure to Protect Water Quality in Storm Water, CSO, Non-point 

Source, and other water programs. 

 Provide regulatory flexibility and relief to utilities that provide a mentorship 

program to other systems in the same watershed. 
24 

Colorado proposes a utility mentorship program. Colorado is proposing an Environmental 

Results Program (ERP) for the National Pollution Discharge Elimination System (NPDES) municipal 

wastewater dischargers. In exchange for a less expensive and less difficult permitting, 

compliance, and inspection process, a large utility system can establish a mentorship program 

with a small system. The ERP elements require that: (1) the state develops baseline compliance 

and establishes performance metrics; (2) the facility self-certifies compliance; (3) the 

enforcement agency conducts statistically-based, random audits/inspections to evaluate 

overall compliance for the sector, and takes enforcement actions as necessary to address 

compliance issues; and (4) the large facility provides mentoring to at least one NPDES minor 

wastewater discharger to help it improve compliance. 

Action: Use enforcement tools to encourage collaboration. EPA should explore 

regulatory and policy changes that can “legitimize” integrated watershed 

programs. EPA should create an opportunity for utilities to gain deference—or 

primacy—from regulatory programs in both permitting and enforcement activities if 

they are pursuing a strong, collaborative, watershed approach to regional problem 

solving. 

EPA should investigate the creation of a certification process which gives the 

Agency “reasonable confidence” that a utility’s planning and investment objectives 

are recognized as delivering multiple environmental and community benefits. These 

benefits transcend narrow compliance objectives over limited timeframes. 

Action: Provide flexibility in enforcement and permitting schedules. EPA should 

reward rather than inhibit communities that are moving forward with regional 

collaborative solutions. 

 Provide the time and support necessary for communities to achieve their 

broad environmental and sustainability goals. 

 Recognize that the standard 5-year permit cycles, 15-year consent orders, 

and drinking water Maximum Contaminant Level (MCL) schedules may not 

provide sufficient time to invest fully in collaborative approaches to problem 

solving. 

 Pursue regulatory and voluntary approaches that use adaptive management 

principles coupled with the necessary evaluation and assessment processes to 

ensure that progress is occurring. 

 Provide flexibility for municipalities facing storm water Phase II regulations to 

form regional storm water utilities (perhaps in collaboration with local water 

and/or wastewater utilities) in order to share costs and implement 

comprehensive storm water management planning. 

 Synchronize monitoring, reporting, and permitting schedules to facilitate a 

watershed-based program delivery. Many states have already moved in this 

direction. EPA should convene a workgroup to assess how these programs are 

working, how to institutionalize watershed-based practices, and how to 

develop incentives for state and tribal participation. 
25 

Recommendation #5: Reduce internal barriers

Action: Re-visit EPA’s organizational structure to reduce internal barriers. EPA is to 

be commended for the significant strides it has already made in support of 

watershed management and system collaboration, but much more is needed. Part 

of the challenge for EPA has been that its legislative and regulatory mandates inhibit 

its organizational, resource, and bureaucratic abilities to focus on its broader 

environmental, public health, and sustainability goals. 

Action: Focus policies, activities, and resources away from single-media, singleissue programmatic goals. Instead, use the broader, more collaborative watershed 

approach as the unifying theme and ethic. 

 Reaffirm, to staff and the public, the Agency’s top-down policy commitment 

to collaborative watershed management through memos, speeches, policy 

statements, directives, activities, resource allocations, and actions. 

 Regularly and systematically grow collaborative partnership activities and 

programs. As a benchmark, each regional office should initiate five new 

collaborative processes each year. 

 Re-direct human and financial resources to encourage and support regional 

collaborations. Such collaborations should become the Agency standard 

rather than an exception. 

 Replicate existing models and programs that have successfully integrated 

regulatory programs, grants, voluntary partnerships, information, technology, 

and other tools. 

 Create new pilot programs that integrate various EPA programs and 

encourage watershed stakeholders to work together to solve environmental, 

ecological, and sustainability goals. 

Action: Detail enforcement staff to work in collaborative settings. Assign 

additional Office of Enforcement and Compliance Assurance (OECA) staff to a nonenforcement role in regional collaboration initiatives. EPA can increase the cross 

training of staff in this vital activity. Enforcement personnel have a lot of knowledge 

and experience to offer stakeholders. 

Recommendation #6: Provide better technical guidance, 

education, and outreach

Action: Review the existing body of literature and programs. Update, 

consolidate, and streamline the information. If necessary, conduct research and 

gather new information. There appears to be no significant level of effort, within 

EPA, to summarize, publicize, or promote existing information on regional 

collaboration approaches to water sustainability even though there is an 

abundance of information and educational tools (i.e., reference documents, 

training materials, webcasts, etc.). Many of the existing collateral tools were 

developed through funding or participation by EPA. NACEPT recommends that any 

necessary research focus on determining the energy-related benefits of integrated 
26 

water resource planning, watershed, regional, and green infrastructure approaches, 

including the energy related benefits of regional and integrated approaches as 

they relate to infrastructure design, the use of decentralized systems, regional water 

supply management, materials selection, operation and maintenance and pollution 

prevention strategies. 

Action: Partner with water sector professional organizations to create new, utilityfocused initiatives in education, communication, and outreach. 

 Develop peer-based water sector utility workshops that promote the use of 

tools currently available that demonstrate regional collaborative solutions and 

provide detailed examples of successes in regionalization. 

 Develop a utility decision-making “toolbox” to evaluate the opportunities and 

challenges of regional solutions. 

 Create new tools specifically designed for small systems, including model 

agreements/arrangements to spur discussion and illustrate the possibilities. 

Action: Partner with watershed stakeholder organizations to create a new 

“sustainable watershed” initiative through education, communication, and 

outreach. Like the water sector utility, in order for other stakeholders to get involved 

in regional collaborative discussions and agreements, local politicians, homeowners, 

institutions, planners, farmers, industry, and other stakeholders need to understand, 

“What is in it for me?” EPA should educate and demonstrate to these stakeholders 

that the political, economic, and social barriers are worth overcoming in order to 

create a more financially and environmentally sustainable community. 

Action: EPA should revise its Web site to align with the watershed and regional 

collaboration approach. EPA should revise its Web site to align with the watershed 

and regional collaboration approach. During this revision, the Web site design needs 

to be more user-friendly and easier to navigate. 

Action: Create an accessible, centralized, Web-based repository of tools and 

resources. EPA should cross-reference available tools (including the incorporation of 

the aforementioned “toolbox”) and categorize them by media type, file format, 

interactive functionality, etc. Access needs to be simple and flexible to maximize its 

use. EPA should incorporate links to external sites that provide additional tools from 

other key stakeholders. 

Action: EPA should train and educate its regional offices, states, and tribes on 

these tools and methods so that a clear and consistent message is communicated 

to the water sector and other stakeholders from policy makers and regulators. 

Action: EPA should re-deploy staff to increase dialogue and face-to-face meetings to 

determine how to promote the long-term sustainability of systems effectively on a local level. 
27 

APPENDIX I: SUSTAINABLE WATER INFRASTRUCTURE WORKGROUP

MEMBERS AND ACKNOWLEDGEMENTS

Workgroup Members 

Mr. Jeff Crane

Executive Director

Colorado Watershed Assembly 

Hotchkiss, CO 

Mr. Clayton Matt

Department Head

Natural Resource Department 

Confederated Salish and Kootenai Tribes 

Pablo, MT 

Mr. William Mullican

Deputy Executive Administrator 

Texas Water Development Board 

Austin, TX 

Mr. Howard Neukrug 

(NACEPT Workgroup Chair) 

Director

Office of Watersheds 

Philadelphia Water 

Philadelphia, PA 

Ms. Arleen O’Donnell 

Board of Directors 

Massachusetts Environmental Trust 

Boston, MA 

Mr. Harrison Rue 

Executive Director 

Thomas Jefferson Planning District 

Commission & Charlottesville-Albemarle 

Metropolitan Planning Organization 

Charlottesville, VA 

Dr. Dan Watts 

Executive Director

New Jersey Institute of Technology 

University Heights 

York Center for Environmental Engineering 

and Science 

Newark, NJ 

Supplemental Workgroup Member 

Ms. Suzanne Goss

Government Relations

JEA (electric, water, sewer) 

Jacksonville, FL 

EPA Office of Water Liaisons 

Mr. Andrew Crossland 

Office of Water 

U.S. Environmental Protection Agency 

Mr. Robert Goo 

Office of Water 

U.S. Environmental Protection Agency 

NACEPT Chair 

Mr. John L. Howard, Jr. 

NACEPT Chair, Jan. 2006-Jan. 2009

Partner 

Vinson & Elkins, LLP 

Erik Meyers 

NACEPT Interim Chair 

Vice President 

Sustainable Programs 

The Conservation Fund

NACEPT Designated Federal Officer 

Ms. Sonia Altieri

U.S. Environmental Protection Agency (1601M) 

Office of Cooperative Environmental 

Management (OCEM) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Tel. (202) 564-0243 

altieri.sonia@epa.gov 
28 

 Acknowledgements

NACEPT thanks the members of the Sustainable Water Infrastructure Workgroup, 

especially Howard Neukrug who devoted many hours as the Workgroup Chair. We 

would also like to express our gratitude to experts from the water sector --including 

Ralph Jones, Bruce Tobey, Dominick DiGangi, Normand Labbe, Jackie LeClair, Peter 

Shanaghan, John Cromwell, Ken Kirk, Tom Curtis, and Dave Clark -- who provided 

invaluable perspectives relevant to our charge. And we thank Andy Crossland and 

Robert Goo from EPA’s Office of Water for guiding the Workgroup throughout this 

effort. NACEPT acknowledges the outstanding support we received from Rafael 

DeLeon, the Director of the Office of Cooperative Environmental Management 

(OCEM) and his staff, including Megan Moreau, and especially the Council’s 

Designated Federal Officer (DFO), Sonia Altieri. 
29 

APPENDIX II: EXPERT PRESENTERS

Name Organization Web site 

Ralph Jones The Cadmus Group www.cadmusgroup.com 

Bruce Tobey Massachusetts Municipal Association www.mma.org 

Dominick 

DiGangi 

Greater New Haven Water Pollution 

Control Authority 

www.gnhwpca.org 

Normand Labbe Southern Maine Regional Water Council 

Jackie LeClair EPA Region 1 www.epa.gov/region01/ 

Peter 

Shanaghan 

EPA Office of Ground Water and Drinking 

Water 

www.epa.gov/safewater/ 

John Cromwell Stratus Consulting www.stratusconsulting.com 

Ken Kirk National Association of Clean Water 

Agencies (NACWA) 

www.amsa-cleanwater.org/ 

Tom Curtis American Water Works Association 

(AWWA) 

www.awwa.org/ 

Dave Clark Rural Community Assistance Partnership 

(RCAP) 

www.rcap.org/ 
30 

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31 

APPENDIX III: LIST OF ACRONYMS

AWWA American Water Works Association 

CMOM Capacity, Management, Operations and Maintenance 

CSO/SSO Combined Sewer Overflow / Sanitary Sewer Overflow 

CUPSS Check Up Program for Small Systems 

CWA Clean Water Act 

CWSRF Clean Water State Revolving Fund 

DWSRF Drinking Water State Revolving Fund 

EPA US Environmental Protection Agency 

ERP Environmental Results Program 

IUP Intended Use Plan 

MCL Maximum Contaminant Level 

MS4 Municipal Separate Storm Sewer System 

NACEPT National Advisory Council for Environmental Policy and 

Technology 

NACWA National Association of Clean Water Agencies 

NEPA National Environmental Protection Act 

NGO Non-Governmental Organization 

NPDES National Pollution Discharge Elimination System 

OECA Office of Enforcement and Compliance Assurance 

OW EPA Office of Water 

RC&D Resource Conservation and Development Council 

RCAP Rural Community Assistance Partnership 

SDWA Safe Drinking Water Act 

SI Sustainable Water Infrastructure 

THMs Trihalomethanes 

TMDL Total Maximum Daily Load 

WRDA Water Resources and Development Act 
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33 

APPENDIX IV: CHARGE TO NACEPT

National Advisory Council for Environmental Policy and Technology

Charge for Developing Recommendations on U.S. EPA’s 

Sustainable Infrastructure Watershed Pillar

Background 

The EPA Administrator has identified Sustainable Water Infrastructure (hereafter 

referred to as Sustainable Infrastructure (SI)) as one of the Agency’s highest priority 

initiatives. In January 2003, the Administrator convened a Forum – Closing the Gap: 

Innovative Responses for Sustainable Water. At this Forum, the Assistant Administrator 

for Water highlighted the “Four Pillars of Sustainable Infrastructure”-- Better 

Management, Full-Cost Pricing, Water Efficiency, and Watershed Approaches to 

Protection (hereafter referred as the Watershed Pillar). The SI initiative aims to 

decrease the gap between growing infrastructure (drinking water plants, piping, 

etc.) needs and spending, by promoting sustainable infrastructure through the four 

Pillars. 

This charge is being developed to address the challenges specific to the 

Sustainable Infrastructure (SI) Watershed Pillar. The goal of the Watershed Pillar is to 

enable utilities (i.e., drinking water and wastewater) and other stakeholders (e.g., 

local and State agencies, Tribal Governments, local planning and ordinance 

organizations, environmental advocacy groups, watershed decision makers) to take 

advantage of opportunities offered by watershed approaches to minimize 

infrastructure cost and/or operating and maintenance expenses to achieve water 

quality and quantity and human health protection goals. 

One of the most critical challenges facing the Nation is how to sustain our water 

and wastewater infrastructure to ensure that the public can continue to enjoy the 

environmental, health, social, and economic benefits that clean and safe water 

provide. 

Our wastewater and drinking water systems are aging, with some system 

components older than 100 years. Our growing and shifting population requires 

investment for new infrastructure and maintenance of existing infrastructure. Current 

treatment strategies and technologies may not be adequate to address emerging 

issues, investment in research and development has declined, and the prospects for 

continued large federal investment are limited. 

EPA’s Clean Water and Drinking Water Infrastructure Gap Analysis (2002) 

estimated that if capital investment and operations and maintenance remained at 

current levels, the potential gap in funding between 2000 and 2019 would be 

approximately $270 billion for wastewater infrastructure and $263 billion for drinking 

water infrastructure. 
34 

Meeting these challenges requires a multi-faceted approach to managing and 

sustaining our infrastructure assets. The Nation must change the way we manage, 

view, value, and invest in our water infrastructure. This can only come about if all 

parties embrace a collaborative approach that encourages new and innovative 

solutions to the challenges we all face. All levels of government and the private 

sector have a shared responsibility for seeking effective, efficient, and fair solutions 

for sustaining our precious water infrastructure. 

Through collaboration with all key stakeholders, the use of effective and 

innovative approaches and technologies, and a commitment to long-term 

stewardship of our water infrastructure, we can make better use of our resources, 

potentially reduce the funding gap and move the Nation’s water infrastructure 

down a pathway toward sustainability over the next fifteen years. For example, 

more than 4,000 local watershed organizations are at work in the United States. They 

are advocating watershed restoration, source water protection, improved site 

design, erosion control, land conservation, and storm water management -- to 

name just a few activities. 

The watershed approach is generally invoked to mean broad stakeholder 

involvement, hydrologically defined boundaries, and coordinated management 

across all aspects of policy that affect water. “Source water protection” is the 

watershed approach’s analog under the Safe Drinking Water Act. The watershed 

approach and source water protection are grounded in science and allow for 

prioritization and cost-effective interventions, as appropriate. 

The EPA Office of Water’s 2003 guidance on watershed-based permitting and 

water quality trading allow for strategic, cost-effective actions to meet water quality 

standards. Watershed goals and the impact of multiple pollutant sources and 

stressors, including nonpoint sources, are considered when National Pollutant 

Discharge Elimination System (NPDES) permits are written for multiple sources in a 

watershed. The goal of this approach is to issue permits that take into account the 

conditions of the entire watershed and address diverse pollution sources, not just 

individual point sources. Often, such permits carry a trading component. A current 

example of a successful watershed-based permit with trading can be found along 

Long Island Sound, where nitrogen trading among dozens of publicly owned 

treatment works in Connecticut is expected to save more than $200 million in control 

costs. 

Source water protection, targeted to protect current and future sources of 

drinking water, also holds the promise of substantial benefits. EPA has determined 

that preventing contamination can be up to 40 times more cost effective than 

remediation of a drinking water source or finding a new one. 

Development decisions are another important approach to the watershed 

paradigm. Development decisions are generally made at the local level. While local 

governments have direct authority over land use and development decisions, many 

states play important roles in setting statewide approaches to planning for growth. 
35 

The EPA cannot and should not be a national or regional development board, but 

the federal government can help states, Tribes and municipalities better understand 

the impacts of development patterns. The Source Water Collaborative’s10 recent 

Vision Statement notes that drinking water protection should be integrated into 

land-use planning and stewardship; road, sewer and water projects; farming, 

industry and development practices; waste disposal methods; watershed planning, 

protection and clean-up; and the routine decisions Americans make every day. EPA 

is working to help states and communities (and should be working to help Tribes) 

realize the economic, community, and environmental benefits of smart growth by: 

1) providing information, model programs, and analytical tools to inform 

communities about growth and development; 2) working to remove federal barriers 

that may hinder smarter community growth; and 3) creating new resources and 

incentives for states and communities pursuing smart growth. 

A key objective the Agency wishes to advance under the sustainable 

infrastructure effort is the merger of watershed management principles into utility 

management, so that key decision makers consider the watershed approach 

alongside the traditional treatment technology investments. As part of this effort, the 

Agency needs information regarding whether: 1) a bias exists in favor of 

technological investments due to existing governmental policies, institutional 

structures, scientific uncertainties, or problems in valuing the benefits of using a 

watershed approach; and 2) if such a bias exists, how can this bias be eliminated? 

The SI now seeks to develop more robust information, data, case studies, and 

lessons-learned with respect to the use of watershed approaches to avoid or reduce 

current or future infrastructure costs and/or operating and maintenance expenses. 

EPA is specifically interested in gathering data on the cost savings and ecological 

and public health benefits that the use of such an approach may accrue while still 

achieving compliance with the requirements of the Clean Water Act and Safe 

Drinking Water Act. 

Charge to the NACEPT Water Infrastructure Workgroup 

The Water Infrastructure Workgroup of the National Advisory Council for 

Environmental Policy and Technology (NACEPT) is asked to assist the Agency in 

advancing cost-effective and sustainable approaches to water resource 

management and infrastructure to meet watershed goals. It is the Agency’s position 

that the watershed approach is critical to protecting and restoring the nation’s 

waters. The Agency furthermore suspects that in order for the benefits of the 

watershed approach to be fully realized it must be integrated into the 

comprehensive planning processes at the state, regional and local levels. 

 

10 The Source Water Collaborative consists of a broad set of constituencies that include the U.S. EPA and 13 

national premier organizations (representing state agencies, water utilities and environmental groups) that 

have agreed to combine their efforts to protect drinking water sources. 
36 

There are several areas where NACEPT can assist the Agency in determining 

how to best use its expertise and resources to promote the watershed approach, as 

it specifically applies to Sustainable Infrastructure, and its integration into state, 

regional and local comprehensive planning processes. 

Overall Goals: 

A. Promote the development of sustainable infrastructure by elevating water 

resource and infrastructure protection and management as a state, regional 

and local government priority in the comprehensive planning process on a 

par with transportation planning, public safety and schools. 

B. Encourage widespread adoption of an integrated planning approach 

focused on water resource and infrastructure protection and management. 

C. Provide information, data, tools and tools necessary for state and local 

governments and their communities to adopt these approaches. 

Research and Recommendations 

The Charge encompasses two distinct focus areas. Consequently, the Office of 

Water is proposing that NACEPT adopt a phased approach for addressing the 

charge over a two-year period. 

A. Phase 1: Comprehensive Planning and Decision-Making 

No later than May, 2007 NACEPT would identify incentives, drivers, barriers, and 

other factors that encourage or inhibit the prioritization of water resource 

infrastructure and management into the comprehensive state, regional and 

municipal planning frameworks and decision making processes. 

Also no later than May, 2007 NACEPT would provide recommendations to the 

Agency on: 

1. Actions the Agency can take to help states and local governments 

overcome the barriers and impediments that prevent the full integration 

of water resource management as a priority in their respective planning 

and decision making processes. For example: 

a. How can the Agency more effectively promote increased collaboration 

among drinking water, wastewater and storm water utilities, local 

governments, planning boards and other stakeholders that result in 

collective water infrastructure priority setting under a watershed 

management context through education and other means? 

b. How can municipalities and other local government/regional planning 

entities build support for promoting a watershed approach to water 

infrastructure planning? 

c. Using relevant examples from the recent Cooperation Conservation 

Conference, what are the ways in which “cooperative conservation” or 

“coordinated resource management” has been or can be used to 

overcome barriers to promoting a watershed approach to water 

infrastructure planning? 
37 

d. How can EPA, States, or others influence various community stakeholders to 

adopt and promote such an approach? 

e. What are the specific barriers embodied in existing EPA and state policies or 

practices that need to be remedied to help EPA and states further 

encourage and assist entities to consider and implement alternative and 

integrated approaches for water infrastructure planning and management? 

Phase 2: Benefits of Traditional versus Alternative Approaches to Water Resource 

Infrastructure and Management 

No later than May, 2008 NACEPT would identify, analyze and report on the 

actual or potential benefits that accrue to local governments and utilities that 

use alternative and integrated approaches to manage wastewater, drinking 

water, and storm water, and the factors that affect whether alternative or 

traditional approaches are more cost-effective. Examples of these alternative 

approaches include centralized management of decentralized technologies 

and systems, soft path technologies, conservation designs, smart growth 

strategies, water conservation and reuse policies and low impact development 

approaches. 

In doing so, NACEPT would examine specific examples and associated factors 

from communities where centralized approaches are predominant and those 

where alternative approaches have been used, along with the key factors that 

caused these communities to adopt these approaches. 

In addition, NACEPT would identify, analyze and report on the actual or 

potential incentives for local governments and utilities to use alternative and 

integrated approaches to manage wastewater, drinking water, and storm 

water. 

Also no later than May, 2008 NACEPT would provide recommendations to the 

Agency on: 

1. Specific actions (e.g., policy, guidance, technical and programmatic tools, 

research) that the Agency can take to encourage and promote the 

investigation of alternative approaches that could meet water quality and 

service objectives at lower life-cycle cost than traditional approaches. For 

example, assist EPA in identifying mechanisms for promoting consideration of 

centralized management and oversight of decentralized systems as a costeffective alternative to physical consolidation of infrastructure. 

Potential Future Work 

EPA would be open to identifying additional research areas, upon completion 

of the current charge, to further improve the understanding of sustainable 

infrastructure issues. The additional research topics may include new areas or may 

build upon the results of the current research charge. 
38 

 NACEPT Charge Addendum (Phase II): August 15, 2007

This Addendum is intended to clarify and refine Part II of the charge. Part II deals 

primarily with the benefits and cost effectiveness of integrated approaches to 

managing drinking water, wastewater and storm water. With the progress achieved 

in some areas since the charge was written, EPA believes it would receive the 

greatest benefit from the workgroup focusing on collaborative opportunities or 

partnerships (COoP) between utilities (water, wastewater and/or storm water) 

and/or other stakeholders within a watershed or region. 

EPA would like to better understand the barriers and incentives to achieving 

cost efficiencies and economies of scale that result from COoPs and reduce the 

infrastructure gap and enhance sustainability. 

Examples include outsourcing of certain functions; circuit rider programs; pooled 

purchasing arrangements; central management of decentralized water and 

wastewater systems; physical connection and merging of systems; watershed 

partnerships, etc. 

NACEPT will talk with experts in the field and study key examples to determine 

what COoPs are most effective in achieving efficiencies. 

NACEPT will consider whether there are characteristics (e.g. size, growth rates 

etc.) that prevent a utility from being cost effective without entering into some form 

of COoP. 

NACEPT would consider barriers and actual or potential incentives that exist (at 

the Federal, State, Tribal and Local level) to foster successful COoP. 

NACEPT would identify specific stakeholder (utilities, States, tribal and local 

governments, citizen groups, etc) actions that could be taken and recommend to 

EPA changes in policy, outreach, internal operations, and/or incentives and 

disincentives to foster COoPs. 
39 

APPENDIX V: REFERENCES

Theriault, B. [March 21, 2005] “Small and Large Water Utilities Will Benefit from a Bill 

that Creates Regional Councils.” Column in Portland Press Herald. [Southern 

Maine Regional Water Coalition] 

Southern Maine Regional Water Council. [October 25, 2006] Mutual Aid Agreement 

for the Southern Maine Regional Water Council. 

U.S. Environmental Protection Agency, Office of Water. 2008. “Factoids: Drinking 

Water and Ground Water Statistics for 2007.” EPA document 816-K-07-004. 

March 2008. Online at: www.epa.gov/safewater/data. 

Massachusetts Coalition for Water Resources Stewardship. 2007. “The Case for 

Environmental Regulatory Reform: Clean Water Act NPDES Permitting.” White 

paper, November 14, 2007. 

Raucher, B. 2007. “Sustainability: What Does it Really Mean and How Do Water 

Utilities Get There?” PowerPoint presentation. Prepared for the American Water 

Works Association, Annual Conference and Exhibition, Toronto, Ontario. June 27, 

2007. 

U.S. Environmental Protection Agency, Office of Water. 2002. System partnership 

solutions to improve public health protection. EPA Document 816-R-02-022. 

September 2002. 

U.S. Environmental Protection Agency, Office of Water. System partnership solutions 

to improve public health protection: Volume 2. EPA Document 816-R-06-005. 

U.S. Environmental Protection Agency, Office of Water. 2001. “Building water system 

capacity: A guide for tribal administrators.” EPA document 816-K-01-08. July 

2001. 

[Water Environment Federation] 2007. “Case studies addressing innovative utility 

approaches to watershed management.” August 8, 2007. Draft #5. 

Yeager, T., R. Ehrhard, and J. Murphy. 2006. Business attributes of successful 

responsible management entities. 

Western Governors’ Association. 2006. “Water needs and strategies for a sustainable 

future.” June 2006. 

U.S. Environmental Protection Agency, Office of Water. 2007. Restructuring and 

consolidation of small drinking water systems: A compendium of state 

authorities, statutes, and regulations. EPA Document 816-B-07-001. October 

2007. 
40 

U.S. Environmental Protection Agency, Office of Water. 2008. National capacity 

development strategic plan. EPA Document 816-K-07-003. January 2008. 

U.S. Environmental Protection Agency, Office of Water. 2000. Report of the National 

Drinking Water Advisory Council, Small Systems Implementation Working Group. 

EPA Document 816-R-00-012. 

Raucher, R.S. et al. 2006. Regional solutions to water supply provision. Report 

prepared for: AWWA Research Foundation and U.S. Environmental Protection 

Agency. Under Cooperative Agreement R829679-01. Document 1P-3.5C-91146-

10/06-NH. 

NACEPT. 2008. “Everyone’s Business: Working Towards Sustainability Through 

Environmental Stewardship and Collaboration.” EPA Document 130-K-08-001. 

March 2008. 

Cadmus Group et al. 2002. Selections from: A study of best practices in the water 

and wastewater sector for the Ontario Superbuild Corporation. Final report. April 

1, 2002. 
1