BC Compliance News: August 2022 environmental regulations
Interior Dept. announces urgent actions to protect Colorado River, hydroelectric dams amid drought
Poles show the water level in a reservoir.
The drought ravaging the West is making an impact in the world of compliance and regulations. On Aug. 16, the Department of the Interior announced urgent actions to protect the Colorado River System from the prolonged effects of the drought.
The announcement highlighted the mounting concern regarding not only drinking water and irrigation, but also the level of water in reservoirs that are vital to nearby hydroelectric dams generating power. In addition to a reduction in downstream releases from Glen Canyon and Hoover Dams, there is a call for basin-wide conservation in an effort to avoid catastrophic collapse of the river
We will continue to follow this story as it affects many of our clients in both the public and private sectors.
In other environmental updates, we highlight the following in our Compliance News:
Ask an Expert: Climate risk and readiness
From cascading and compounding risks to questions you can ask yourself now, BC’s Karri Ving shares insight into climate risk and readiness. Read “Ask an Expert”
PFAS regulatory updates persist
In July, the EPA published a final rule adding five PFAS to the toxic chemicals list that must be reported.
General duty clause
While the EPA’s Risk Management Program (RMP) applicability is reasonably clear, some facilities with chemicals in amounts less than the RMP thresholds are finding themselves in trouble with the EPA because they are overlooking EPA’s General Duty Clause.
About the Expert
Meghan Krishnayya, Indianapolis, is the Director of Technical Practices for Brown and Caldwell, with 25 years of experience in municipal and industrial markets. She guides strategies to deliver client value through differentiated technical solutions and expertise, with a personal passion around compliance; permitting; and Environmental, Social, and Governance (ESG) goals.
National Regulatory Dates
Dec. 21, 2025
Compliance deadline for state eElectronic NPDES reporting
For utilities and businesses, a focus on the climate and how private and public sectors prepare for and react to climate transition is the “new normal” that will continue to grow and evolve.
Taking a look at climate risk
Many clients tend to think of climate risk in the traditional sense: the likelihood of a hazard’s occurrence multiplied by the consequences. In this changing climate, it is important to look at risk and impact through a different lens. Clients are often good at planning for climate risks in isolation such as floods, wildfires, or extreme precipitation. However, many often overlook:
Cascading risk: One event sets off a series of other events. Example: A flash flood causes electrical grid failure, which disrupts electricity for a pump station, which causes the pump station not to function, which then leads to increased flooding.
Compounding risk: Scenarios that involve multiple risks at one time. Example: A wildfire during a chronic drought.
In addition, clients are now also facing business and reputational risks associated with climate transition preparedness. In a few short years, it will no longer be acceptable not to have a climate policy and committed actions. For both private and public sector clients, interested parties like ratepayers, investors, and insurers are going to review the qualitative commitment that each organization is making on climate and investigate how commitments translate into progress. Credit worthiness, insurance premiums, and risk profiles will also be tied to climate-related disclosures, risks, opportunities, management processes, targets, and goals.
Assessing climate readiness
It may feel like a daunting task to begin to approach your organization’s climate readiness. Before diving into complex models and commitments, you can begin by developing scenario planning and looking at your level of service, then ask these questions:
Given the information you have about climate transition in your geography, what is your confidence level around being able to continue to deliver, perform, and/or operate at current levels through a climate transition, whether it is chronic (a longer-term condition or trend such as a drought) or acute (an extreme weather event such as a hurricane)?
Was your response to a recent nature-based event or catastrophe sufficient? What steps can you take to address vulnerabilities?
How are you working outside of your bubble to understand and manage risk more effectively? For instance, researching available national and local risk mapping related to flooding, drought, heat island effect, and disproportionate impacts of climate change to your most vulnerable communities.
Adapting to change
As Heraclitus said, change is the only constant in life. This is especially true as you navigate climate risk and readiness. Assessments used today may not work as sea levels rise, temperatures increase, or storms become more intense. Reporting requirements will continue to evolve. Levels of service expectations and supply chain resiliency may change as well. Whether you operate in the private or public sector, the ability to pivot and adjust will be key.
About the experts
Meghan Krishnayya, Indianapolis, is the Director of Technical Practices for Brown and Caldwell, with 25 years of experience in municipal and industrial markets. She guides strategies to deliver client value through differentiated technical solutions and expertise, with a personal passion around compliance; permitting; and Environmental, Social, and Governance (ESG) goals.
Karri Ving is Brown and Caldwell’s Managing Principal, Business & Consulting & ESG, and has over 25 years of experience in the public, private, and nonprofit sectors. Karri works on immediate and long-term challenges and opportunities, with a focus on Environmental, Social, and Governance (ESG) topics.
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