Perspective on the 2010s
A few months ago, we republished an Aqua Talk article I authored in late 2009 entitled “Perspectives on a New Decade.” It looked back on what happened in the 2000s and attempted to look forward to what might happen in the 2010s. This article will briefly look back on what actually happened in the 2010s. Next time we will look forward to the 2020s after this messed up initial year known as 2020. The late 2009 article asked a few questions, so let’s answer those.
Question: Will we be able to effectively implement the regulations adopted in the late 2000s?
Answer: Yes, with challenges. Implementing the Long Term 2 Enhanced Surface Water Treatment Rule (LT2), Stage 2 Disinfectants and Disinfection Byproducts Rule (Stage 2), has gone relatively well largely due to the investment in training and early implementation efforts of the mid- to late-2000s. Fortunately, very few public drinking water systems in Colorado fell outside of Bin 1 for LT2. Stage 2 has been considerably more challenging for water systems to comply with and CDPHE to implement. Watershed changes associated with climate change or wildfires still trigger new maximum contaminant level violations and these can be difficult to address.
Question: What new regulations will be promulgated by EPA before 2020?
Answer: Colorado completed adoption and began implementing the groundwater rule in about 2010 and the Revised Total Coliform Rule (RTCR) in 2016. These regulations were impactful, especially with respect to monitoring and repeat sampling requirements. Complying with some of the details remains challenging today. But overall Colorado’s long-standing disinfection rules prepared us pretty well to avoid water safety problems associated with these rules. For example, we have had to conduct very few Level 2 assessments under RTCR.
Question: What progress will be made in understanding and dealing with unregulated contaminants?
Answer: See below for more information, but from a full-fledged regulatory perspective little changed. EPA went back and forth a couple of times on whether or not to regulate perchlorate and their present position is not to move forward with developing a final rule for that contaminant.
Question: What additional precautions will water utilities need to take to as part of our nation’s efforts to protect the homeland?
Answer: Since its launch in 2008, membership in the Colorado Water and Wastewater Area Response Network (CO-WARN) increased dramatically. CO-WARN has helped many water systems in times of need, like the 2013 floods. About 270 utilities in Colorado are CO-WARN members and have signed the mutual aid agreement. CO-WARN strongly supports utility resiliency and helps the state’s overall capacity to respond to emergencies. Unfortunately, in 2020 we have seen an uptick in vandalism and cyberattacks perpetrated against water utilities. America’s Water Infrastructure Act of 2018 requires that community water systems serving more than 3,300 people update risk assessments and emergency response plans.
Question: What about climate change?
Answer: We have certainly seen impacts from climate change with prolonged dryness and large wildfires in numerous locations throughout the state during the 2010s culminating in the terrible year of 2020. We will be dealing with its aftermath for years to come and there is no end in sight. We will be working to foster safe potable reuse over the next decade, which will improve climate resiliency.
In addition, over the last ten years we adopted and implemented new or revised rules (mostly in 2016) regarding disinfection waivers, storage tanks, backflow prevention and cross connection control, disinfectant residual in distribution, hand pumps, and water haulers. The number of disinfection waivers was about 126 in 2009 and stands at about six today. Overall, no waterborne disease outbreaks have occurred at a regulated public drinking water system since 2008, and E. coli violations were reduced by 70% in the 2010s as compared to the 1990s. Since 2014 these violations have been exceedingly rare (only one) at regulated drinking water systems. But outbreaks and E. coli violations continue to occur at water systems that went undetected over the years and were not regulated. This suite of rules continues to be challenging for water systems and CDPHE to implement, but the positive results are astounding! Other states cannot believe that a state the size of Colorado has essentially eliminated E. coli violations in drinking water.
In 2009, I stated that surely new challenges would arise as well. Boy, did they! Lead and PFAS. Water systems and CDPHE undertook Herculean efforts after the Flint crisis in 2015-16 to improve Lead and Copper Rule (LCR) implementation. Our approach to nearly every aspect of the rule from materials identification to sampling requirements and optimum corrosion control treatment was reinvigorated or overhauled. Since LCR is the most complicated rule, it was a painful process. We were successful in working with Denver Water and EPA to obtain the first-of-its-kind variance from the LCR allowing for lead service line removal and supplying filters to the public instead of adding orthophosphate. This was a supreme challenge but represented real wins for public health, the environment, health equity and cost effectiveness. While all that was going on, Colorado became the number one state in terms of its population consuming drinking water close to or above EPA’s revised health advisory for PFAS compounds after it was revised downward by nearly an order of magnitude in May 2016. That is a list no one wants to be on top of! Through partnerships with impacted water systems, EPA, local health departments and potentially responsible parties, these situations all received considerable attention and effort. Today, no one in Colorado served by a public drinking water system is known to consume tap water above or near EPA’s health advisory.
Lastly, in 2009 I projected that resource issues were likely to remain a challenge for water systems and CDPHE as well. That played out beyond expectation for the Safe Drinking Water Program. We began projecting financial difficulties in about 2014. By 2017 the problem was severe. To avoid a crisis, we were forced to abolish 11 technical positions representing about 15% of our direct program workforce. That was a painful time. Fortunately, increased federal funding helped us get back on the right track, but we are still struggling to fill positions and adequately implement the 2016 rules. Without more funding, we are not in a strong position to adopt and fully implement the expected revisions to the LCR.
Overall, the 2010s were a wilder ride than expected but we can all be proud that tap water today in Colorado is undeniably safer than ever before! In my next program manager message, we’ll look ahead to the 2020s. Thanks again for all you do to protect public health by keeping drinking water safe.
➽ Ron Falco, P.E. Safe Drinking Water Program Manager
