Root Causes of Municipal Noncompliance Project

The Office of Compliance is building a national, evidence-based program designed to achieve higher levels of compliance and improve our environment through EPA’s compliance and enforcement activities.

To accomplish these goals, OECA is developing a Compliance Learning Agenda, which will identify the most pressing, unanswered environmental compliance questions, and establish an evaluation plan with a series of research projects intended to answer those questions.

In June 2021, OECA convened a workgroup of volunteers from EPA, states, tribes, and academia to work together to draft the first CLA where we determined that identifying the immediate and underlying causes of noncompliance at small municipal systems was a key unanswered question.

Through this project, we hope to gain clarity about the root causes that underlie municipal noncompliance and that can also render agency interventions (enforcement, technical assistance, etc.) unsuccessful in returning systems to compliance by answering the following research questions:

• What are the root causes of municipal Wastewater Treatment Plant and Drinking Water system Clean Water Act/Safe Drinking Water Act noncompliance that can render EPA and State enforcement and technical/financial assistance efforts unsuccessful?
  • Considering the factors that affect municipal compliance, what are the impediments to compliance that prevent technical assistance/financial assistance/enforcement tools from being effective in producing compliance?

* We anticipate that the answers to these questions will involve multiple research efforts given the range root causes of noncompliance that will need to be assessed. The details of the research question(s) and project opportunity are not set in stone; discussion and refinement are likely.