AWIA Section 2013 risk and resilience assessments
Community water systems serving more than 3,300 people must assess risk from malevolent acts and natural hazards across named parts of the system, and review that assessment at least every five years.
- Status
- in force
- Authority
- EPA, under Safe Drinking Water Act Section 1433 as amended by AWIA Section 2013
- Applies to
- Community water systems serving more than 3,300 people, which must complete a risk and resilience assessment and an emergency response plan and review both at least every five years.
Key points
- AWIA Section 2013 amended Section 1433 of the Safe Drinking Water Act, requiring community water systems serving more than 3,300 people to develop or update a risk and resilience assessment and an emergency response plan.
- The assessment must address the risk from malevolent acts as well as natural hazards.
- The statute names the elements to be covered, including physical barriers, source water, water collection and intake, pretreatment, treatment, storage and distribution facilities, and the electronic and automated systems the utility uses.
- Both the assessment and the emergency response plan must be reviewed at least once every five years to determine whether they need revising.
- The requirement does not name any technology, so aerial exposure is an input to the assessment rather than a mandate to deploy detection.
The requirement
AWIA Section 2013 amended Section 1433 of the Safe Drinking Water Act. It requires community water systems serving more than 3,300 people to develop or update a risk and resilience assessment, and an emergency response plan, and to review both at least once every five years.
The assessment must address the risk to the system from malevolent acts as well as from natural hazards. The statute is specific about the elements to be covered: physical barriers, source water, water collection and intake, pretreatment, treatment, storage and distribution facilities, and the electronic, computer and other automated systems the utility uses.
Why it matters for aerial exposure
Most facility types have no standing obligation to assess physical security risk. Water systems above the threshold do, it recurs, and the elements it names are exactly the ones visible from above.
That has a practical consequence. An analysis of what a drone can observe at a treatment works, an intake, a pumping station or a chemical store is an input to a document the utility must produce in any case. It does not need its own business case.
It is worth being clear about the limit of that point. The statute requires assessment and planning. It does not require detection equipment, and reading it as a technology mandate goes further than the text supports.
What the assessment usefully covers
Three areas tend to matter more than the rest at a water utility.
Bulk chemical storage is the acute hazard already present on site, and its location, containment and access routes are what overflight reveals. Control buildings and automated systems are named in the statute and are a reasonable focus. Source water, reservoirs and open basins are the most visible assets from the air and also the ones physical protection cannot cover, so an honest assessment should say where exposure cannot be reduced and concentrate effort where it can.
The review cycle
The five-year review is the practical entry point for most utilities. A system that completed its assessment some years ago is due to revisit it, and considerations that were not addressed the first time can be brought in then.
For public agencies there is a funding point worth noting. Assessment and planning are named allowable cost categories under the FEMA C-UAS Grant Program, so for eligible applicants this work may be fundable. Eligibility is determined by the funding notice and by the administering state.
FAQ
▸Does AWIA require water utilities to address drones?
Not specifically. It requires an assessment of risk from malevolent acts and natural hazards across the parts of the system the statute names, including physical barriers, source water, intake, treatment, storage and distribution. Aerial observation is one route by which a malevolent act becomes feasible, so it reasonably belongs within that assessment.
▸Does it require us to buy detection equipment?
No. AWIA requires assessment and planning. Anyone presenting it as a mandate for drone detection is overstating it, and the statute governs rather than any description of it.
▸We are a small system. Does this apply to us?
The threshold is a community water system serving more than 3,300 people. Below that, the Section 1433 requirements do not apply, although a utility may still choose to assess risk. Systems close to the threshold should confirm their position rather than estimate it.
▸What does the five-year review mean in practice?
That this is a recurring obligation rather than a one-off submission. A utility that completed an assessment several years ago is due to revisit it, and new considerations such as aerial exposure can be addressed within that cycle rather than as a separate exercise.