What EPA’s New Drinking Water Checklist Asks State Regulators to Do

The U.S. Environmental Protection Agency has published a voluntary Systemic Issues Checklist designed to help state drinking water regulators identify problems at public water systems before they become service failures or public health threats. The guidance, released under the Trump EPA’s Powering the Great American Comeback Initiative, targets so-called systemic issues: source water supplies nearing capacity, treatment equipment that is malfunctioning, and recurring water main breaks.

The checklist is intended to supplement existing state sanitary survey programs rather than replace them. EPA says state agencies can use the new checklists to document and track issues found during routine assessments, and to follow through on long-term resolutions. The agency described the tool as voluntary and said it is designed not to create new processes or additional administrative burden.

The announcement was backed by state regulators. Anthony DeRosa, executive director of the Association of State Drinking Water Administrators, said the checklist was developed in partnership with states and EPA and would help primacy agencies identify and address challenges before they become risks to service reliability or public health. EPA Assistant Administrator for Water Jess Kramer framed the document as part of the agency’s work with state co-regulators under the Safe Drinking Water Act.

EPA also used the release to highlight financing available for water infrastructure. The agency said it announced more than $6.5 billion this year through the Drinking Water State Revolving Fund and has roughly $11 billion in flexible financing through the Water Infrastructure Finance and Innovation Act loan program, which can cover up to 80 percent of project costs in small and rural communities.

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Why a Voluntary Checklist Matters for State Primacy Agencies and Water Utilities

What the checklist actually changes for state primacy agencies

This is not a new federal mandate. Under the Safe Drinking Water Act, states with primacy are the front-line regulators, and the checklist reinforces that role by giving them a shared template for documentation. The practical value lies in making systemic issues visible over time: a water main break becomes a recurring pattern, source water demand trends toward capacity limits, treatment equipment problems are logged rather than treated as one-off events. Because the guidance is voluntary and explicitly designed not to add new processes, EPA appears to be aiming for adoption through usefulness rather than enforcement pressure.

How the $17.5 billion funding context fits in

The checklist’s value depends on what happens after a problem is identified, and that is where EPA’s financing tools matter. The DWSRF is state-run and already the main federal-state channel for drinking water projects. WIFIA adds flexible financing, with the 80 percent project-cost coverage for small and rural communities particularly relevant to systems that may lack rate bases large enough to support conventional borrowing. The release connects identification of systemic issues to available capital, even if it stops short of creating a new funding stream or priority rule.

The political framing around plain-language co-regulation

EPA is presenting the checklist as part of a broader effort to communicate simply and to strengthen, rather than bypass, state authority. That matters because drinking water enforcement has often been politically sensitive, especially when federal mandates require costly local upgrades. A voluntary, state-partnered checklist lets the administration show action on drinking water reliability while avoiding a prescriptive federal burden—though it also means the guidance’s impact will depend on how many states choose to integrate it.

Next Steps for States and Public Water Systems Using the New Checklist

For state agencies and public water system operators, the new guidance translates into a few concrete steps:

  • Download the checklist from EPA’s sanitary survey page or the SDWA capacity development state resources webpage and compare it against your current sanitary survey documentation.
  • Add the three named systemic issue categories—source water nearing capacity, malfunctioning treatment equipment, and frequent water main breaks—to routine survey review checklists, especially where they are not already tracked.
  • Keep the integration lightweight. EPA designed the checklist as a supplement to existing sanitary survey programs, so states should use it to improve documentation without duplicating workflows.
  • Move identified issues into a funding path. For capital fixes, coordinate with your state’s DWSRF allocation; small and rural systems should evaluate WIFIA, which can finance up to 80 percent of project costs.
  • Use Real Water TA for hands-on assistance on infrastructure or funding needs if a systemic issue cannot be resolved through existing state processes.

Risk & Opportunity Assessment

Commercial RiskLowThe guidance is voluntary and explicitly designed not to create new processes or additional burden, so it does not immediately change water systems’ operating costs or revenue.
Competitive RiskLowNo market or competitive shift is created; the checklist is a shared documentation tool for utilities of all sizes rather than a differentiator.
Regulatory RiskMediumAlthough the checklist is voluntary, unresolved systemic issues such as frequent water main breaks or source water nearing capacity can eventually lead to Safe Drinking Water Act compliance problems and public health enforcement action.
Reputation RiskLowThe initiative offers a framework to prevent service disruptions, but the document itself does not create new reputational exposure.
Technology DisruptionLowThe guidance supplements existing sanitary surveys with documentation checklists; it does not introduce new technology or require systems to replace equipment.
Commercial OpportunityMediumEPA paired the checklist with funding tools—over $6.5 billion in DWSRF funds and about $11 billion in WIFIA financing, including up to 80 percent project-cost coverage for small and rural communities—creating a practical path from risk identification to infrastructure investment.