AWIA of 2018: EPA Releases Aug. 1 Baseline Threat Guidance

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Trey Shanks

Environmental Scientist

Note: This is the fourth part in a series about the AWIA of 2018. Read the first here, second here and third here.

On Aug. 1, the U.S. EPA released additional information related to the American Water Infrastructure Act of 2018 Section 2013 Risk and Resilience and Emergency Response Plan requirements. In addition to an updated web tool, the EPA provided guidance for baseline threats, an emergency response plan template and an online portal for certification of the compliance requirements.

Compliance deadlines begin in March 2020 for water utilities to assess infrastructure risks from natural and man-made hazards and to develop plans for improved resilience and emergency response against those risks.

Baseline Threat Information for Risk and Resilience Assessment

The EPA released a guidance document containing baseline threat information for malevolent acts, categorized by EPA into the following threat categories :

  • Assault on Utility – Physical
  • Contamination of Finished Water – Accidental*
  • Contamination of Finished Water – Intentional
  • Theft or Diversion – Physical
  • Cyber Attack on Business Enterprise Systems
  • Cyber Attack on Process Control Systems
  • Sabotage – Physical
  • Contamination of Source Water – Accidental*
  • Contamination of Source Water – Intentional

Note that EPA has included several accidental threats because the potential consequences are similar to malevolent acts. Each threat category contains a number of scenarios.

Emergency Response Plan Template

The EPA has issued a template for utilities to have as a reference for developing an emergency response plan specifically to meet the AWIA Section 2013 requirements to incorporate the findings of the risk and resilience assessment.  It’s important to note that utilities are not required to develop a new or separate emergency response plan if one is already in place, but the existing pan may need to be updated to address AWIA requirements.

AWIA Certification

The EPA strongly recommends online certification of the Risk and Resilience Assessment and the Emergency Response Plan. This can be achieved through an online portal on EPA’s web site. Alternative certification options remain but are not recommended by EPA.

How Freese and Nichols Can Help You

Freese and Nichols’ approach can help you go beyond compliance to get the best value for your water-infrastructure assets. Our team of water and wastewater engineers has extensive experience developing Vulnerability Assessments, Risk Management Plans and Evaluations, and Resilience Programs for many water utilities from less than 3,000 to more than a million. Our team can help you successfully complete your Risk and Resilience Assessment and develop or update your Emergency Response Plan.


Our team will be happy to help if you have any further questions. Here’s who you can reach out to.

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Trey Shanks, CFM, IAM, leads Freese and Nichols’ Asset Management services. He is a Principal in our Fort Worth office.