On February 13, 2023, the Environmental Protection Agency (EPA) announced the availability of $2 billion in funding for U.S. states, territories, and tribes to address emerging contaminants—with an emphasis on per- and polyfluoroalkyl substances (PFAS)—in public water systems (PWSs). EPA followed its announcement by releasing state-by-state funding allocations. The funding is made available through the Emerging Contaminants in Small or Disadvantaged Communities (EC-SDC) grant program.
A brief PFAS refresher
Compared to “conventional” water contaminants, PFAS introduce a unique set of environmental challenges: complex chemistry, high mobility in water, high chemical stability, and extremely low concentrations of concern. PFAS is an umbrella term for a family comprising thousands of individual compounds, some of which are potentially harmful to human health at single-digit part-per-trillion (ppt) levels.
The PFAS characteristics that create the environmental challenges the world is dealing with today are the same characteristics that made PFAS a darling in product development and industrial applications starting in the 1940s. The widespread use of PFAS over the years has translated into widespread environmental impacts, including contaminated drinking water. One example of how PFAS can end up in drinking water originates in firefighting. PFAS have been a staple in Class-B (flammable liquid) firefighting foams since the 1960s. PFAS-containing foams are effective and have saved lives, but each time foam deploys as part of training or incident response, PFAS enters the environment. PFAS being increasingly identified in drinking water has led to the development of programs like the EC-SDC grant program.
What is the Emerging Contaminants in Small or Disadvantaged Communities Grant Program?
The Infrastructure Investments and Jobs Act (IIJA) allocated $5 billion for fiscal years 2022-2026 to the EC-SDC grant program, which focuses on providing funding to small, rural, and disadvantaged communities to implement projects that have a primary purpose of addressing emerging contaminants (e.g., PFAS) in drinking water. Subsequent to this year’s $2 billion allocation, the EC-SDC grant program plans to release $1 billion per remaining fiscal year.
What are small or disadvantaged communities?
There is no statutory definition of SDC; under the Safe Drinking Water Act (SDWA), definitions of SDC are defined at the state level. Also under SDWA, states are required to support local communities' technical, managerial, and financial (TMF) resources through Public Water System Supervision (PWSS) drinking water programs. When assessing communities for potential insufficient TMF capacity—and therefore optimal candidacy for EC-SDC grant funding—EPA suggests states may consider focusing on communities based on criteria such as being identified as disadvantaged/vulnerable, serving small populations, having limited staffing or budget, and other factors defined in the EC Grant Implementation Manual in more detail.
The EC-SDC grant program differs from programs like the WIIN Small, Underserved and Disadvantaged Communities (SUDC) grant programs in a couple notable ways: 1.) Water systems benefiting from EC-SDC funding do not have to serve underserved communities to be eligible for funding, and 2.) EC-SDC grants do not have cost-sharing or match requirements.
What kinds of projects can EC-SDC funding support?
Projects funded by EC-SDC must have a primary purpose of addressing emerging contaminants (such as PFAS) in drinking water, with “primary purpose” generally meaning that at least 50% of project costs or “level of effort” go toward addressing emerging contaminants. Notably, once EPA establishes National Primary Drinking Water Regulations (NPDWR) for a contaminant, it is no longer considered an emerging contaminant. However, with its emphasis on PFAS projects, the EC-SDC grant makes an exception to this rule for PFAS. In other words, even if EPA announces a maximum contaminant level (MCL) for PFAS, otherwise eligible PFAS projects will remain eligible for EC-SDC grant funding.
EPA provides numerous specific ideas for eligible projects, as well as examples of ineligible projects in its EC Grant Implementation Manual. Eligible project categories include research/testing, planning, design, treatment, storage, source control, household access, technical assistance, and education/outreach programs.
What’s the timeline for EC-SDC funding?
States must submit application packages by August 31st of each fiscal year cycle in which grant program funding is released.
How does EC-SDC funding correspond with ongoing testing associated with the 5th Unregulated Contaminant Monitoring Rule (UCMR5)?
UCMR is a key provision of the SDWA that helps identify unregulated contaminants in drinking water. Every five years, EPA publishes a new UCMR to address a new set of emerging contaminants. UCMR5 is being conducted between 2023 and 2025 and includes testing of nationwide PWSs for 29 PFAS compounds. Testing conducted under UCMR5 includes all water supply systems serving 3,300 or more people, as well as 800 randomly chosen PWSs serving fewer than 3,300 people.
Although UCMR5 focuses on large-scale systems, there is potential overlap for systems serving populations under 10,000. For instance, systems serving between 3,300 and 10,000 people may be tested under UCMR5 and eligible for funding for treatment systems (depending on whether the system meets other criteria, noted above). Systems serving fewer than 3,300 people, whether participating in UCMR5 or not, may be eligible for funding for select projects.
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