Sometimes there’s a little to say about a lot of things. Welcome back to Variable Flow.
maybee you haz teh led pipez?
It’s been a minute, I know.
Water comms: moar science!
Regular readers of this blog know that I’ve long evangelized for data-driven approaches to water sector communications. The US Water Alliance’s new Messaging Toolkit is a great example of what I've been preaching. Rather than simply compiling expert opinions about what kinds of messages are effective, the USWA team tested that advice with a series of experiments. They crafted social media posts that depicted and described water in different ways, and then deployed those posts randomly to discover which approaches prompted the greatest engagement. This approach helped identify which messaging methods are most effective and—crucially—which are ineffective.
A new EPA Working Paper reports on an even more exciting experiment aimed at promoting a lead service line identification campaign in Trenton, NJ. Researchers randomly placed door hangers with information about a self-inspection process that allowed residents to submit a photo of their service line, or else similar door hangers offering gift cards to participants. Neither proved effective: less than 1% of homes that got a door hanger ultimately participated, including those offered $100 gift cards. This is an important study, even though these treatments didn’t “work.” Door hangers are widely used by water utilities; learning that they aren’t very effective at spurring customer participation will save utilities time and money, and push them to find more effective methods.
These are encouraging efforts. Most communications guidance for water organizations is based on folk wisdom and case studies. Communication is important: we ought to demand the same kind of rigor and empirical validity for branding and messaging guidance that we expect of treatment and distribution system design. A small body of rigorous research on water comms is emerging! More, please.*
itz yer fawlt
Blame game
Two years ago, EPA’s Office of Inspector General (OIG) launched an investigation into the Jackson, Mississippi water crisis. The resulting report blasts the Mississippi State Department of Health (MSDH) for a series of regulatory failures that left the state’s capital city without functioning water and sewer systems.“The MSDH does not have implementation procedures for its compliance and enforcement program” the report states. “Consequently, the MSDH did not take formal actions to compel Jackson to comply with the Safe Drinking Water Act” (SDWA). Media coverage of the report picked up these themes, heaping scorn on MSDH.
The OIG report acknowledges that EPA could have moved faster to take enforcement action to prevent the disaster, and that Region 4 officials failed in their oversight of MSDH. “Had the EPA upheld its oversight responsibility to require the MSDH to implement enforcement procedures and had the MSDH taken enforcement actions,” the report states, “Region 4 could have been alerted sooner to the extent of Jackson’s SDWA noncompliance.” But the report even blames Mississippi for EPA’s failures, arguing that “the EPA did not have a comprehensive understanding of the extent of the management and operational issues at Jackson’s system.” That is, the OIG report concludes that EPA failed to prevent the Jackson water crisis because it didn’t realize how bad things were in the Magnolia State capital.
There’s plenty of blame to go around for Jackson’s water crisis, but the OIG report is a jaw-dropping shift of responsibility away from EPA and onto MSDH. It also beggars belief. It was obvious to anyone who was paying attention that Jackson’s water and sewer systems were deeply troubled long before the 2021 winter storm and 2022 summer floods that crippled the city’s utilities. The report only covers events beginning in 2015, but review of regulatory records show that Jackson utilities had serious SDWA and/or Clean Water Act (CWA) compliance problems on-and-off since the early 1980s. In 2013 a federal court entered a consent decree between EPA and Jackson to manage severe problems with the city’s sewer system, including deficiencies in facilities and staffing. It is incredible—literally, not credible—that in 2015 Region 4 EPA officials were blissfully unaware of the depth and breadth of Jackson’s water and sewer problems. Buried deep in the OIG report are several acknowledgements that EPA Region 4 officials could and should have taken earlier and stronger steps to address Jackson’s problems. The report also makes several procedural recommendations for Region 4 going forward. But the report’s headline findings and EPA’s summary throw MSDH directly under the bus.
Conspicuously absent from the OIG report is any culpability for the Jackson’s utility leaders or elected officials.
SDWA and CWA only work if federal and state agencies enforce these laws vigorously and local government utilities act responsibly. Failures at all three levels contributed to Jackson’s disaster. Blaming the State of Mississippi alone ignores 2/3 of the story.
Throat-clearing & hand-wringing
Speaking of chronically troubled water systems, EPA’s proposed Water System Restructuring Assessment Rule (WSRAR) would require state agencies to develop procedures for assessing “restructuring options” for water systems that repeatedly violate SDWA health regulations.
if teh horsez run two counties away, we convenez a committee to studee barn door alternitivez
The proposed rule urges primacy agencies to offer enforcement flexibility and financial support to facilitate restructuring of systems that chronically violate the SDWA. It also lays out detailed procedures to follow pursuant to restructuring. In case you were wondering, yes: “restructuring” means consolidation.
The good news here is that this rule would offer potentially significant carrots to help induce consolidation—and maybe even some sticks, too. Getting small systems on a path to sustainability and putting failing water systems into more competent hands is good public policy.
The bad news is that the proposed rule is long on red tape and short on urgency. A water system would have to fail badly and consistently in ways that threaten public health before a state agency could order an assessment of potential alternatives that might include consolidation. Any actual consolidation regionalization restructuring would happen only following lengthy studies, evaluations, public notification, meetings, comment periods, reviews, consultations, and approvals...
…all while the chronically failing water systems continue to fail. One gets the impression that this rule is more about protecting interests than protecting health.
It’s a teeny-weenie step in the right direction, I guess.
welcome to teh teem
Trump tea leaves
The once-and-future President has been moving swiftly to announce cabinet nominees, including his choice of Lee Zeldin as EPA Administrator. Zeldin’s nomination comes a bit out of left field, since the former New York congressman and gubernatorial candidate isn’t particularly well-known for his work on environmental policy.But compared with some of Mr. Trump’s more… unconventional picks, Lee Zeldin is downright orthodox.
The political rhetoric and media coverage around Zeldin’s nomination has focused almost exclusively on energy and climate. For those of us mainly interested in water, a deep dive offers a few clues about the future Administrator’s priorities. In 2021 he was one of a handful of Republicans who voted to support ongoing EPA funding and PFAS regulations for drinking water. He also very publicly boosted efforts to expand water service to Suffolk County homes with private wells contaminated by a Navy facility.
That’s not much to go on, but there is at least some reason to think that the incoming EPA Administrator supports a robust role for federal regulation of drinking water; it’s harder to perceive clean water priorities. With such a thin environmental record, much will depend on who leads the Office of Water and other sub-cabinet posts at EPA.Better late than never
The Minnesota city of Grand Rapids began chlorinating its water supply this summer following a Legionella outbreak linked to the city’s water.
These are 19th century problems, man. The introduction of chlorine to drinking water treatment in 1908 was one of the greatest health advances in the history of the world.
i can haz disinfekshen?
The continued resistance to disinfection in certain communities is puzzling. Some opponents worry about disinfection byproducts, but most resistance seems to be about the taste and smell of chlorine. Hopefully there are some smart engineers figuring out how to manage aesthetics along with THMs and HAAs.
Etc.
Flushable wipe-out in Michigan. \\ Seattle Public Utilities takes bottled water head-on and I am here for it. \\ Connecticut green-lights sale of investor-owned Aquarion to South Central Regional Water Authority, a local government agency, following Aquarion’s failed rate case last year. Prominent opponents of the deal include municipal governments, which stand to lose significant tax revenue if the private utility turns public. \\ California PUC’s utility affordability reports now include a way cool interactive map—featuring AR20 and HM values for water, electricity, gas, and telecom. \\ Physician, heal thyself.
*More on the way. Watch this space over the next couple of months.