AWWA and CFATS

The last two days have had blog posts about pro-IST lobbying campaigns that are using mass email and internet petitions to influence Congress to pass the legislation that they favor. Monday, on one of AWWA regional web sites, they urged their members to contact their Representatives and express their anti-IST views on the proposed legislation. AWWA Position The American Water Works Association is opposed to mandatory IST provisions in CFATS reauthorization and is not too happy to see that their exemption from the CFATS rules may be removed. The AWWA takes the position that ‘water treatment’ decisions (the methods and chemicals used) should be made locally. They are also concerned that there could be public health consequences “if homeland security concerns are made paramount to protecting public health”. New Information on Water Facility Provisions The web site provides some new (to me) information about how the bill being drafted in the House Energy and Commerce Committee (there is no discussion about the Homeland Security Committee’s work on the CFATS reauthorization bill) will address water treatment facilities. According to the web site: “A utility can apply for an exemption from this [IST] requirement under certain criteria to be spelled out in the bill, but the final decision will rest with EPA in Washington DC. There is no plan in this program for states to assume primacy and administer the program.” This would be a major change from the way that the CFATS reauthorization was written in HR 5577 last year. That proposed bill would have left all decisions about chemical security at water treatment facilities under the control of the Secretary of DHS. This change, if it actually appears in the committee draft of the bill, may be part of the coordination of efforts between the two committees. This would allow for more oversight by the Energy and Commerce Committee due to their coverage of the EPA. AWWA Method of Influence We looked at the two pro-IST efforts and how they intended to influence Congress. The AWWA site recommends that their members “call, fax or e-mail their members of Congress immediately” to express their views. They also note that most members of Congress will be in their district for at least a part of the Easter Recess. The site does provide a form letter that AWWA members can use. In the earlier discussion of mass mailings I made the comment that, to be effective, mass mailings needed very large number of form letters (or emails) to be delivered to be effective. The AWWA effort does intend to produce any where that large a number of mailings, but this is not really a mass mailing campaign. What they are attempting to do is to make Congress aware of how the proposed bill will affect facilities within their district. If most water treatment facilities in the district convince their Representative that the bill would have adverse effects on the efficiency or operation costs for their facility it might influence on of our fence sitters to come down on the side of the facility. The AWWA letter does not address the cost issue at all. In my opinion this is a major mistake. In the current economic environment adding costs to any publicly owned facility. AWWA had promised to provide to their members a program to evaluate the cost of changing from chlorine gas disinfection to bleach or ozone disinfection processes. Since costs of switching are not addressed I assume that the AWWA has not made this tool available. The one thing that the AWWA recommends that their members do is to invite their Representative to come and see their local facility. This would provide the water works personnel a chance to make a one-on-one appeal for avoiding the mandatory IST provisions of the CFATS reauthorization bill. This is a smart move. Providing a first hand opportunity to see the complexity of the water treatment process would make their point easier to make. The AWWA web site is not as fancy as, nor does it provide the story telling aspects of the two anti-IST programs I have already looked at. It doesn’t need to. The people that they are talking to already understand the problem and don’t need to be convinced. The one thing that is lacking is that it does not provide much in the way of tools for their members to use.