Baseline Information on Malevolent Acts for Community Water Systems: July 2019 U.S. Environmental Protection Agency Guidance Document

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The United States Environmental Protection Agency (Office of Water) (“EPA”) released a July 2019 guidance document titled:

Baseline Information on Malevolent Acts for Community Water Systems (“Guidance”)

See EPA 817-K-19-001.

The Guidance is intended to provide baseline information that a community water system (“CWS”) can use to comply with Section 2013(a) of federal legislation – America’s Water Infrastructure Act (“AWIA”).

EPA states that the Guidance can “identify malevolent Acts and take steps to reduce the risk that a specific system will experience if one occurs or potentially deter a threat from occurring.”

The agency believes that by “assessing threats” that CWSs can:

. . . identify, prepare for and manage any risks they may have by adopting an “all-hazards” approach that:

  • Identifies, deters, detects, and prepares for these threats
  • Reduces vulnerabilities of critical assets
  • Mitigates the potential consequences of incidents that do occur

A disclaimer is noted with a statement that the Guidance is not a threat analysis for a specific system. As a result, the agency does not believe it should be used in such a manner. Instead, it is stated to be a starting point for CWSs to use when estimating the threat likelihood of malevolent acts when undertaking a risk in a resilience assessment.

The Guidance includes the following sections:

  • Section 1: AWIA Requirements – Provides an overview of AWIA requirements pertaining to Risk and Resilience Assessments, Emergency Response Plans (ERPs), and baseline threat information.
  • Section 2: Assessing Risk and Resilience – Describes the basic elements of Risk and Resilience Assessments for CWSs.
  • Section 3: Asset Categories – Defines physical and cyber elements that CWSs are required to evaluate in conducting Risk and Resilience Assessments under AWIA.
  • Section 4: Threat Categories and Likelihoods for Malevolent Acts – Describes threat categories of relevance to CWSs.
  • Section 5: Resources for Additional Information – Contains a listing of other sources of information on malevolent acts relevant to CWSs.

A link to the Guidance can be found here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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