PolicyBrief
H.R. 2594
119th CongressApr 2nd 2025
To establish a Water Risk and Resilience Organization to develop risk and resilience requirements for the water sector.
IN COMMITTEE

This bill establishes a non-governmental Water Risk and Resilience Organization (WRRO) under EPA oversight to develop and enforce mandatory cybersecurity risk and resilience requirements for large public water systems.

Eric "Rick" Crawford
R

Eric "Rick" Crawford

Representative

AR-1

LEGISLATION

Water Security Bill Creates Single Private Organization to Set Cyber Rules for Large Water Systems

This bill sets up a brand new, highly specialized system to protect the nation’s largest public water systems—those serving 3,300 people or more—from cyberattacks. The core of this system is the creation of the Water Risk and Resilience Organization (WRRO). This organization will be certified by the Environmental Protection Agency (EPA) and tasked with writing the mandatory cybersecurity and resilience requirements that covered water systems must follow. Essentially, the bill delegates the complex technical rule-writing for water security to a single, non-federal expert body, while the EPA maintains oversight on fairness and process.

Who’s Guarding the Pipes: The WRRO’s Unique Power

Think of the WRRO as the new, mandatory IT security consultant for every major water utility in the country, but with regulatory teeth. The EPA Administrator has to pick only one organization to fill this role. To get the job, the WRRO must prove deep technical knowledge, have operators as members, and show they can keep sensitive security data locked down. This structure aims to bring industry expertise right into the rule-making process, ensuring that the security standards are technically sound and practical for water systems to implement. However, concentrating all this technical regulatory power into a single, private entity is a significant delegation of authority that we rarely see.

The Cost of Compliance and the $25K Fine

For the water systems themselves—the owners and operators who keep the taps flowing—this means new mandatory compliance costs and a lot of paperwork. Every covered system will have to submit an annual self-attestation confirming they are meeting the WRRO’s standards, and they’ll face an in-person assessment every five years. The sting in the tail is the WRRO’s enforcement power: they can fine systems up to $25,000 per day for continued violations after notice and a hearing. While this penalty is subject to EPA review, it means your local water utility could be paying a new regulatory body if they don't keep their digital defenses up to snuff. These costs, of course, will likely be passed down to ratepayers, meaning your water bill could eventually reflect the price of enhanced cyber defense.

Rules for the Digital Age: Where Expertise Meets Oversight

The process for setting the rules is interesting. The WRRO writes the proposed security requirements and an implementation plan outlining the deadlines. The EPA must generally approve the rule if it’s fair and non-discriminatory, and they are required to trust the WRRO’s technical expertise. If the EPA disagrees, they can’t just reject the rule; they have to send it back with specific suggestions for fixes within 90 days. This back-and-forth ensures the EPA retains the final say on the process, but the WRRO remains the technical expert in the driver’s seat. This setup is designed to ensure that the security measures are always up-to-date against evolving threats, something traditional government bureaucracy often struggles to achieve quickly. Crucially, the EPA can also force the WRRO to create a new rule if a specific threat emerges, ensuring the system can be reactive when necessary.