Infrastructure Resilience Briefing — AWIA 2025 emergency response certification

Executive briefing: Community water systems serving 3,301–49,999 people must certify to the U.S. Environmental Protection Agency by December 31, 2025 that their emergency response plans reflect the most recent risk and resilience assessment completed under America’s Water Infrastructure Act (AWIA) Section 2013. Utilities that miss the deadline risk civil penalties and referral to state primacy agencies. Operators need coordinated cybersecurity, physical security, and incident communications procedures documented, exercised, and approved so filings meet statutory requirements.

Key infrastructure signals

Statutory deadline. EPA guidance confirms the final AWIA deadline applies to systems serving between 3,301 and 49,999 residents, following earlier compliance windows for larger utilities.
Certification mechanics. Utilities must submit electronic certification through EPA’s CDX portal within six months of finishing their risk assessment update, retaining supporting documentation for onsite audits.
Penalty exposure. Failure to certify can trigger EPA administrative orders, $25,000-per-day civil penalties, and potential loss of Drinking Water State Revolving Fund access.

Control alignment

AWWA G430/G440. Map AWIA emergency response plan elements to industry standards covering security practices, incident management, and mutual aid coordination.
NIST CSF 2.0. Capture cybersecurity controls for operational technology (OT) assets—network segmentation, incident response, and monitoring—to demonstrate comprehensive risk coverage.
EPA enforcement. Document board approvals and executive certifications to prove governance oversight of AWIA deliverables.

Detection and response priorities

Instrument telemetry for chemical feed, SCADA, and remote access systems so operators can evidence cyber-physical situational awareness in their emergency plans.
Track tabletop exercises, after-action items, and mutual aid agreements to show response capabilities are tested and current.

Enablement moves

Establish AWIA program management offices to coordinate engineering, cybersecurity, compliance, and legal teams through the certification timeline.
Leverage EPA’s Water Utility Response On-The-Go (Water Utility Emergency Response Plan) templates to standardize documentation and expedite updates.
Integrate AWIA artefacts with capital planning so resilience investments tie directly to identified vulnerabilities.

Sources

Zeph Tech helps water utilities operationalise AWIA—closing cyber-physical gaps, documenting emergency playbooks, and managing the certification process ahead of EPA enforcement.