Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Waterworks Operation Fee [12 VAC 5 ‑ 600]
Action Amend and Update the Waterworks Operation Fee Regulations
Comment Period Ended on 3/2/2022
Back to List of Comments
3/2/22  5:09 pm
Commenter: Sarah Holland, Virginia Health Catalyst

Supports or the prioritization of equity and environmental justice in amendments

Dear Mr. Roadcap,


I write to you on behalf of Virginia Health Catalyst (Catalyst) staff, board, and partners. Catalyst is a statewide advocacy nonprofit committed to ensuring all Virginians have equitable access to safe, trusted, affordable, fluoridated drinking water – and that it’s Virginian’s beverage of choice.


Thank you for the opportunity to provide comment on the Notice of Intended Regulatory Action to consider amending 12VAC5-600, Waterworks Operation Fee. Catalyst supports the prioritization of equity and environmental justice in any amendments to be made.


Communities of color, rural populations, and low-wealth individuals experience more barriers to accessing clean water than privileged communities.


  • Black, Hispanic and Native American residents are more likely to live in environmentally disadvantaged neighborhoods, with exposure to water that violates quality standards. (1)
  • Black and Hispanic children and adults are two to three times more likely to report not drinking their tap water than members of white households. In 2017-2018, roughly 3 out of 10 Black adults and children and nearly 4 of 10 Hispanic adults and children didn’t drink their tap water. (2)
  • Small and rural community water systems are more likely to serve marginalized communities and face unique challenges compared with large and urban systems, and are found to have more compliance violations than urban systems. (3)


In order for all Virginians to have equitable access to safe, affordable, trusted drinking water, equity must remain a priority and emphasis in all of our work. Catalyst is currently convening a taskforce (Water Equity Taskforce) comprised of water stakeholders from across the commonwealth to develop recommendations to improve equitable access to water, and we are pleased to partner with the Office of Drinking Water staff in this effort. We commend the Office of Drinking Water staff for their hard work to keep Virginia’s water safe, and to appropriately assess the needs of communities by prioritizing  a better understanding of equity and environmental injustice.


If you have any questions, please do not hesitate to contact me at


Thank you,


Sarah Holland

Chief Executive Officer, Virginia Health Catalyst



  1. Jill Baumgartner, Judith Rodriguez, Frans Berkhout, Yvonne Doyle, Majid Ezzati, George Owuso, Zahidul Quayyum, Bethlehem Solomon, Meghan Winters, Gary Adamkiewicz, Brian E. Robinson, Synthesizing the links between secure housing tenure and health for more equitable cities, Wellcome Open Research, 10.12688/wellcomeopenres.17244.1, 7, (18), (2022).
  2. Rosinger, A. Y., Patel, A. I., & Weaks, F. (2021). Examining recent trends in the racial disparity gap in tap water consumption: Nhanes 2011–2018. Public Health Nutrition, 1–7.
  3. Marcillo, C. E. & Krometis, L. A. H. Small towns, big challenges: does rurality influence Safe Drinking Water Act compliance? AWWA Water Sci. 1, e1120 (2019).
CommentID: 120518