The U.S. Environmental Protection Agency’s Office of Water has extended the public comment period on its draft National Water Program Strategy: Response to Climate Change until June 10. The Draft Strategy represents the National Water Program’s initial effort to identify potential impacts of climate change for clean water and drinking water programs and define actions to respond to these impacts.
I was initially skeptical of this effort, launched by Assistant Administrator for Water Ben Grumbles in March 2007. The EPA under the Bush administration has shown little interest in climate change mitigation or adaptation, and is only beginning to take some modest steps under court order and threat of litigation. However, the Draft Strategy document appears to be a genuine attempt by the National Water Program (led by Deputy Assistant Administrator for Water Michael Shapiro) to prepare for the impacts of climate change and climate change mitigation efforts on the EPA’s major water programs. The Draft Strategy identifies the range of potential climate change impacts on both water quality and quantity, although it downplays the scope of these impacts. It also recognizes the opportunities for energy and water conservation in the water treatment and supply sector.
However, as detailed in a comment letter I prepared on behalf of the Great Lakes Environmental Law Center, the Draft Strategy understates the impact of climate change on the nation’s freshwater resources, especially if the United States and other countries do not take aggressive action to mitigate greenhouse gas emissions immediately. Also, the Draft Strategy does not adequately analyze the additional demands that climate change, coupled with population and economic growth, is expected to put on already stressed water resources in many regions. Finally, while the Draft Strategy discusses some opportunities and goals for water conservation, it should offer specific recommendations for policy reform to encourage water conservation in both the public and private sectors.