Developing A Better Understanding of Drinking Water Technology Approval: WINSSS Center Project B1

When EPA in 2014 chose to fund the National Centers for Innovation in Small Drinking Water Systems, their vision for the Centers was much more than developing new drinking water technologies; they asked them to also consider facilitating acceptance of both new and existing technologies, improving relationships between stakeholders, fostering dialogue among regulators, and facilitating the development of uniform data collection approaches for new technologies. All of the non-treatment pieces of the vision have been incorporated into the WINSSS Center’s Project B1.

Project B1 has three objectives:

1. Conduct a survey of the states to determine the barriers and data needs for technology acceptance.
2. Develop a states workgroup and use the survey results as a starting point to discuss how to overcome those barriers and develop a set of uniform data needs.
3. Take the workgroup results and apply them to the New England states to work toward multi-state acceptance.

The first objective has been completed, and the workgroup called for in the second has been meeting every other month since December.

Recognizing the importance of state buy-in to the project, the PI’s proposed to include the Association of State Drinking Water Administrators (ASDWA) as a partner in the survey implementation at the proposal stage. They have been a great partner, and the success of this project is a reflection of their involvement. It was also clear early on  that both Centers had proposed work related to developing a better understanding of acceptance of technologies, so we joined forces. It proved instrumental in the development of the questions, and there were at least eight participants from WINSSS, ASDWA, and DeRISK, that had a hand in the question development.

The survey included 16 questions asking states about their approach to technology acceptance, their experiences with new technologies, barriers to getting these technologies to small systems, data needs for acceptance of any new technology, and their interest in participating in our effort. Forty  states responded, again thanks to ASDWA’s involvement, and the data were telling. We learned that many states don’t consider new technologies for small systems because of cost and risk and that states generally struggle with having the staff and technical expertise to understand and approve new technologies. The most common barriers were a lack of staff and staff time to approve technologies, adequate performance data from vendors, funding for testing/evaluation, and training for state staff.

We asked the states to tell us what questions they needed answered to approve a technology, and over half of the states listed performance data to support the technology, pilot data from multiple locations or water qualities, residuals produced, third party certification and understanding of where technology is appropriate, and understanding the operator skills needed to operate the technology. They also listed the data deficiencies they see most often. These included range of water qualities tested, length of pilot testing, scale of pilot testing, and operating costs, among others.

The good news is that 11 of 14 “emerging” technologies provided to the states in the survey have already been implemented in at least 10 states. This suggests that more technologies are in use than we initially believed and for some technologies, better sharing and communication mechanisms between states are the most immediate needs.

We also asked states how they used the data from EPA’s Environmental Technology Verification Program (ETV) and Arsenic Demonstration Program in accepting new technologies. Nineteen states said they rely on ETV certification or testing protocols as part of their process. Fifteen states said that the Arsenic Demo Program influenced their decisions related to the tested technologies. These programs no longer exist, but they provide valuable insight into how we might consider developing a new program to support the states for sharing data and communicating technology approval information.

The last part of the survey focused on technology acceptance and asked the states if they would be interested in sharing data, developing common standards with neighboring states, or partnering with nearby states to coordinate technology approval. Six states did not answer this question, but 33 of the 34 who did were at least somewhat interested in developing a data sharing network. Twenty-eight states were also interested in developing common standards with nearby states, and 23 were interested in developing partnerships with nearby states to approve technologies. These are very encouraging results.

The survey data were shared with the states, and a workgroup of Centers, ASDWA, and state staffs was formed. The first meeting was in December 2015, and much progress has been made since. The workgroup has developed a draft framework for an entity that would support a shared data repository. They are currently developing a plan/proposal to share with the Interstate Technology & Regulatory Council board (ITRC) to consider how this entity might work with or within the existing ITRC framework. No decisions on this have been made and the workgroup is evaluating options. An open call to all industry stakeholders is planned for late July or early August to share progress to date and to get feedback.

There are no illusions that this can all be accomplished in a short time; the issues and barriers related to technology acceptance have been discussed within the industry for more than 25 years. But this project has created buzz within the industry, as well as with the states and USEPA. It has momentum, and the idea of developing a consensus approach for sharing data and fostering cooperation among all stakeholders that both supports the states need to protect public health and makes it easier for technologies to be accepted by states is now being discussed among all of the relevant players.