Potable Reuse Rulemaking
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Letter of Support
The Arizona Section of the WateReuse Association will be submitting a letter to the Arizona Department of Environmental Quality in support of updating rules for Arizona’s Administrative Code on Purified Water for Potable Use. We invite our members to sign onto the following letter to demonstrate widespread support for updating these rules with the recommendations of the Recycled Water Work Group, along with ADEQ’s incorporation of best practices from the water reuse industry.
The support letter, including the names of all of the organizations that signed onto it, will be submitted to Trevor Baggiore, Water Quality Division Director, at the Arizona Department of Quality.
Dear Mr. Baggiore,
Our organizations express support of updating rules for Arizona’s Administrative Code on Purified Water for Potable Use. We recognize the value that Purified Water represents as a new source of water for Arizona communities and consider it essential to have robust and comprehensive rules for protection of public health. The existing rule, A.A.C. R18-9-E701, was a first step toward allowing potable reuse projects to be permitted but did not include many of the details to allow full-scale projects to be executed, which was recommended from the ADEQ Recycled Water Work Groups Final Report dated January 15, 2018.
There is a real possibility that many utilities will be impacted by continued drought or other water management challenges that distinguish wastewater effluent as a vital source of drinking water. Cuts to water deliveries through Central Arizona Project are looming, triggering the Department of Water Resources to explore small- and large-scale supply alternatives for all of Arizona. In many areas, existing groundwater levels are declining, and groundwater quality is deteriorating. Some communities are having challenges recharging aquifers with reclaimed water due to saturated soils, impacts from nearby contaminated groundwater, or poor infiltration rates. Purified water offers communities a local solution to address these challenges and support their continued economic development and job growth.
In closing, our organizations encourage updating these rules with the recommendations of the Recycled Water Work Group, along with ADEQ’s incorporation of best practices from the water reuse industry. We look to the Recycled Water Work Group to recommend rules that will secure public trust that these new sources of water are safe and reliable. A new rule provides an avenue for utilities to consider Purified Water as a drinking water source and we do not see that new rules will pose additional burdens on existing utilities and businesses. The use of purified water as a new source for drinking water supplies is a voluntary option for enhancing water resource portfolios.