AWIA Round II – What Drinking Water Suppliers Should Consider When Revisiting Risk and Resilience Assessments and Emergency Response Plans

Round II of America’s Water Infrastructure Act of 2018 (AWIA) requires public water systems to update and recertify both Risk and Resilience Assessments (RRAs) and Emergency Response Plans (ERPs). Public water systems are required to revisit and plan for risks associated with natural and malevolent threats.

Risks associated with natural disasters continually test our resilience and emergency response systems. From devastating flooding to the deadly combination of dry vegetation and high winds, these natural disasters underscore the pressing need for enhanced preparedness and resilience in the face of increasingly frequent and severe natural disasters. While many of these incidents continue to be unprecedented in nature, we need to continue to ask ourselves: What if that happened in my community? With Round II of the AWIA upon us, now is the time to build resilience and emergency preparedness into drinking water utility infrastructure planning and operations. But what does recertification look like? Let’s dive in.

What do U.S. water utilities need to do?

First, let’s recap the requirements for Risk and Resilience Assessments (RRAs) and Emergency Response Plans (ERPs) The America’s Water Infrastructure Act (AWIA) of 2018 mandates that community water systems serving more than 3,300 people conduct comprehensive RRAs and develop or update ERPs. Initial RRAs and ERPs were due in compliance with AWIA beginning in March 2020, with the due dates staggered depending on the populations served by the water system.

An RRA evaluates the risks to critical water infrastructure, including the consequence of failure, physical security vulnerabilities, cybersecurity risks, and resilience to natural hazards. Following the assessment, water systems were required to develop or update an existing ERP to outline specific strategies and procedures to mitigate risks, maintain operations during emergencies, and restore services promptly.

While the initial RRAs and ERPs have been certified, 2025 brings Round II of AWIA with deadlines beginning this year for larger water utilities:

 

AWIA Round II Certification Deadlines 

Population Served	Previous RRA Deadline	Next 5-Year Submission Cycle RRA Deadline
≥100,000	March 31, 2020	March 31, 2025
50,000-99,999	December 31, 2020	December 31, 2025
3,301-49,999	June 30, 2021	June 30, 2026

 

Population Served	Previous ERP Deadline*	Next 5-Year Submission Cycle ERP Deadline*
≥100,000	September 30, 2020	September 30, 2025
50,000-99,999	June 30, 2021	June 30, 2026
3,301-49,999	December 31, 2021	December 31, 2026

*ERP certifications are due six months from the date of the RRA certification. The dates shown above are certification dates based on a utility submitting a RRA on the final due date.

Incorporating Resilience and Emergency Preparedness into AWIA Round II

While the requirements for RRAs and ERPs have not changed since the first round of AWIA, the challenges and threats that community water systems face continue to evolve. When reevaluating the risks or updating emergency response plans, water systems should consider:

• How has the water system changed since the initial RRA and ERP? Changes to infrastructure or system operation may have mitigated previous threats, but also could add new ones. Has the water system replaced a pump station or added emergency power at a new location? Has the condition of certain assets declined, creating new risks? Water systems should revisit critical assets and evaluate threats.
• How have the risks changed since the initial RRA and ERP? Water systems are urged to update RRAs and ERPs based on our latest understanding of emerging and continuing threats. EPA’s Water Resilience Website maintains current information on evolving threats. Does your ERP outline incident response protocols in the event of a critical supply chain issue?
• What new resources are available to assist in ERP updates? In the five years since the initial AWIA RRA and ERP submissions, a variety of resources continue to be developed that can assist water utilities. For example, the Water Research Foundation’s Project No. 5106 for Concept of Operations (CONOPS) Plan for Water Distribution System Testing and Recovery was published in 2024. It was created due to the lack of guidance for public water system staff facing wildfire attacks of their distribution systems. Water systems should identify what new resources exist to bolster ERPs and better prepare for emergency response.
• How can we learn from the successes and challenges of our peers? A myriad of lessons learned come in the aftermath of disasters and crises. How can you incorporate some of the protocols that worked best for our peers into ERPs? How can you proactively incorporate response protocols that address some of the challenges that others faced?
• Have you demonstrated the monetary risk of certain scenarios? While AWIA does not require water systems to conduct the quantitative risk assessment, doing so estimates the total risk (in dollars) of specific scenarios. Utilizing this along with the estimated mitigation measure cost can help illustrate the benefits of mitigation projects and help you obtain necessary buy-in to move projects forward.
• Does your risk assessment align with funding opportunities? Certain funding opportunities require specific assessments be completed to be eligible for consideration. In updating AWIA RRAs and ERPs, public water systems should evaluate adjacent funding opportunities to ensure that they maximize the effort of their updates and that the risk assessment and emergency preparedness aspects are in line with requirements that could limit eligibility.

Depending on the size of your water system, Round II of AWIA requires updates and recertification of RRAs and ERPs beginning now, in March 2025. Public water systems shouldn’t wait to dive in. Not sure where to start for RRA and ERP updates for AWIA compliance? Contact me.