U.S. ENVIRONMENTAL PROTECTION AGENCY
    ENVIRONMENTAL FINANCIAL ADVISORY BOARD



                                    APR  30 2002


Honorable Christine Todd Whitman
Administrator
U.S. Environmental Protection Agency
Washington, D.C. 20460-0001

Dear Administrator Whitman:

      The Environmental Financial Advisory Board (EFAB) is pleased to provide you with a
"Summary of Key Points" from a workshop on public sector initiatives to promote cost-effective
environmental management.  The Board is indebted to the Cost-Effective Environmental
Management (CEM) Workgroup, chaired by Michael Deane, Corporate Vice President, United
Water and Billy Turner, President, Columbus Water Works, who organized the workshop.

      This workshop was the second in a series that the CEM workgroup is holding to highlight
for the Agency a variety of techniques and strategies in both the public and private sectors, that
can lead to greater efficiencies and lower costs in providing public-purpose environmental and
public health protection.  The "Summary of Key Points" shows that the meeting yielded a wealth
of good information and new ideas to improve  efficiency in the public water industry.
Additionally, the workshop included a special panel on the Water Infrastructure Network's
report. The report, among other things, argues for a significant increase in long-term, reliable
federal funding of drinking water and wastewater facilities and greater State flexibility in making
grants and loans.

      We would like to take this occasion to make two broad recommendations for your
consideration:

Recommendations

1.     In general, EFAB believes that there is  as much potential to reduce the costs of
      environmental and public health protection as there is to increase the volume of
      investments in it. The Environmental Protection Agency's (EPA) Innovation Council
      would be an excellent forum to undertake a comprehensive attempt to identify cost saving
      measures and importantly, what more the Agency might do to encourage their adoption
      by the public sector.  EFAB members would be happy to meet with the Council to discuss
      how this review might take place.

2.     Over the years, EPA has done an impressive job in applying demonstration grants to the
      assessment of the public benefits of new ideas.  EFAB recommends that demonstration
      grants be expanded aggressively to identify, document, evaluate, and ultimately

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      encourage the adoption of, cost-effective management techniques and strategies. An
      excellent example is the use of demonstration grants for environmental management
      systems by the Office of Water, resulting in major advances in expanding the knowledge
      and application of EMS' in the water industry. Case studies were emphasized in the
      workshop as effective communication tools. They should be prepared for each
      demonstration project and be presented collectively on an easily accessible webpage of
      the agency. Another noteworthy example is the popular website of the Environmental
      Finance Program in the Office of the Comptroller, located at: www.epa.gov/efinpage.

Follow-Up Activities

      The CEM workgroup has held two subsequent workshops. On November 8,2001, the
workgroup hosted a workshop on the linkage between environmental management systems
(EMS) implemented by the public drinking water and wastewater utilities and financial
performance. A second workshop was held March 4,2002 on the new General Accounting
Standards Board 34 (GASB) requirements covering capital asset  inventories and management of
public utilities.  The GASB 34  requirements are controversial as they will change, in many
instances, previous practices affecting capital asset management. EFAB will be sending you
shortly specific recommendations regarding further actions EPA  should consider with respect to
EMS and GASB 34 implementation.

      We appreciate the opportunity to offer this Summary and recommendations to EPA, and
of course we are available to discuss this and other EFAB projects with you or members of your
staff.

                                 Sincerely,
             Robert O. Lenna                         A. Stanley Meiburg
             Chair, EFAB                            Executive Director, EFAB
Enclosure
cc:     Linda Combs, Chief Financial Officer
       Tracy Mehan III, Assistant Administrator, OW
       Thomas Gibson, Associate Administrator, OPEI
       Mike Ryan, Deputy Chief Financial Officer
       Joe Dillon, Comptroller

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                      Environmental
             Financial Advisory Board
EFAB
Robert Lenna
Chair

A. Stanley Meiburg
Executive Director
Members

Hon. Pete Domenici
Terry Agriss
George Brewster
George Butcher
Michael Curley
Michael Deane
Michael Finnegan
Mary Francoeur
Hon. Vincent Girardy
Steve Grossman
Evan Henry
Anne Pendergrass Hill
Mary Kelly
Stephen Mahfood
Langdon Marsh
John McCarthy
George Rafielis
Arthur Ray
Andrew Sawyers
James Smith
Sonia Toledo
Jim Tozzi
Billy Turner
Mary Ellen Whitworth
John Wise
     Public Sector Initiatives to Increase
 Efficiency and Overall Performance in the
       Water and Wastewater Industry
       "Summary Notes of Key Points"
                      FINAL
This report has not been reviewed for approval by the U.S. Environmental Protection
Agency; and hence, the views and opinions expressed in the report do not necessarily
  represent those of the Agency or any other agencies in the Federal Government.
                                         April 2002

                                    Printed on Recycled Paper

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               ENVIRONMENTAL FINANCIAL ADVISORY BOARD
      COST-EFFECTIVE ENVIRONMENTAL MANAGEMENT WORKGROUP
                        MARCH 5,2001 PUBLIC MEETING
                             NATIONAL PRESS CLUB
                                WASHINGTON, DC
                                                  •                              *

                    SUMMARY NOTES OF KEY POINTS

Morning Session 9:00 am - 12:30 pm

TOPIC:  Public Sector Initiatives to Increase Efficiency and Overall Performance in the Water
and Wastewater Industry .

Meeting brought to order by George Ames, Acting DFO

Michael Deane, CEM Workgroup Chair
•      Welcomed attendees and outlined structure and topics of the two sessions.

Billy Turner, CEM member and organizer of the session.
•      Introduced speakers ands reviewed morning's agenda
•      Noted significant changes taking place in public sector
•      Public utilities have accepted the challenge of privatization; their culture is changing

Gary Westeroff, Malcom Pirnie:  The Changing Utility

•      Spoke via teleconference from New York, NY.
•      Covered the changing and the changed utility.
•      Identified several drivers as the "momentum for change:" Rate and cost control; political
       influences; "threat" of privatization; massive awareness and new  leadership.
•      Utilities of "every significant size" are succeeding in improving effectiveness and
       efficiency.
•      "Actions of change" include leadership commitment; focus on customers; strategic use of
       technology  (especially IT); stress on quality; and improved credibility with customers.
•      New leadership focuses  in performance and customer satisfaction and more cost-effective
       approaches.
•      Three areas of emphasis regarding technology are process control plans to improve
       productivity, control operations and monitor performance. Billy Turner strongly
       reinforced this point, especially with respect to improved technologies driving improved
       monitoring and reduced  staff requirements.
•      Widespread staff reduction underway.
       Key balance must be struck between effectiveness and efficiency, for example, reducing
       cost may come at the expense of reliability; public utilities are more conservative/better
       suited in striking this balance.
•      Briefly discussed five models from publicly owned and operated, though complete
       privatization and motivational difference between the public and private sectors.

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•      Cited several examples of public utility successes, including rising credit rating for the
       water and wastewater industry; 13:1 upgrades to downgrades.
•      Suggested a "Framework for Consideration" include ensuring fair and open evaluation of
       all alternatives; moving cautiously on privatization because of limited experience (long
       term issues vs short term savings); and if privatization is selected as an alternative the
       selection of a contractor should be an open and fair process.

Comments

•      Industry going through fundamental change in terms of the improvements  in
       effectiveness of utilities in performing their core missions and the efficiency of their
       operations.

John Huber, Louisville Water Company: A WWA/WEF QualServe Program

•      Spoke via teleconference from Louisville, KY.
•      Gave an overview of the QualServe Program developed by the AWWA and WEF for
       water/wastewater utilities
•      Program seeks continuous improvement and customer satisfaction, built around self-
       assessment, peer review and benchmarking - and quality improvement programs that have
       worked well.
•      Must accommodate organizational responsibilities - customer relations, business planning
       and management, organizational development, wastewater operation, and water supply -
       with which there are 26 business process categories.
•      Thorough preparations are essential, including support from the top, representative teams,
       credible measures of success, and access to information.
•      QualServe offers staff assistance providing help in all aspects.
•      The self assessment involves a confidential, comprehensive survey, to involve staff and
       share what they know.
•      Peer review is an objective evaluation by trained utility professionals over a 3 month
       period, with a summary report showing strengths and opportunities for improvement;
       peer reviewers are senior executives from utilities across nation; attend training; have no
       vested interest in participating utilities.
•      Benchmarking uses metrics to compare results of practices and to improve  performance;
       a clearinghouse has been established; will be fully developed by 2003; service include
       website connection to APQC services (an international benchmarking organization);
       training and workshops; performance indicators database; and best practices studies.
•      How can utilities develop goals and controls to have freedom to act?
•      To gauge and compare results the program calls for customer satisfaction surveys which
       feedback in to the self assessment, peer review, and benchmarking.
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Comments

•      It will be a challenge to develop good standards for best practices.
•      How do we maintain interest of utilities?; marketing an issue; in the original pilot 120
       utilities participated; employees got very involved - can be a cultural issue.
•      Is there any interface with the city council? Local utilities have the option of letting
       governing body know of their participation; surveys can be "scary."
•      Can the QualServe program work for all utilities? - would smaller utilities be able to take
       advantage of the tools/techniques? Attempt underway to  adapt the program to small
       systems.

Ken Rubin, PA Consultants: AMSA/AMWA Competitiveness

       First examine the cost structure of an average utility.
       25-35% capital program
       25-35% business support services
       30-40% core O&M
•      What is the competitiveness framework? A supply chain of core organizational values
       (source protection, water production, transmission, treatment, distribution, and customer
       service) that uses a wide range of organizational services, all based  on a foundation of
       capital programs management.
•      In 1998 AMSA and AMWA began a joint initiative with  case studies and regional
       workshops to train over 2000 managers in productivity improvement. Also began
       competitiveness programs in more than 150 utilities.
•      Key finding: a savings of 15-30% achievable in O&M.
       Benchmarking  an important tool with reducing costs of business support service, yielding
       up to 50 percent savings.
•      AMSA/AMWA supported similar program to capture efficiencies in provision of
       business support services, with second handbook and series of management workshops.
       Similar levels of savings are attainable.
•      Recently began project to develop an asset management handbook based on Australian
       and US experience. Also included AWWA &WEF. Bottom line of asset management is
       that, if properly implemented, it can generate significant reductions in capital replacement
       costs and also increases control over costs.
       What's been learned using competitiveness strategies?  Cited several anecdotal examples,
       including reduction of operating costs by 31% and reducing a $200 million operating
       budget by $33 million.
       Compared a burdened utility with an optimized private utility. The former's burdened
       include inefficient work practices, overstaffing, reactive maintenance, poor management
       information.
       The burden gives a cost edge ranging from 25 to 35% in controllable  O&M costs to the
       optimized private facility. However, addressing these issues, a public utility can begin to
       eliminate the burden and bring costs in line with those of private utilities.
•      Leveling the playing field allows the public utility the flexibility to  invent more in

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       training and other worthy activities and still remain competitive with a private counterpart
       that still is required to provide a return to shareholders and pay taxes & fees not paid by a
       public utility.
•      Neither model is foolproof and each depends on certain conditions being satisfied, e.g., a
       flexible civil service for the public utility and fair management contract for the private.
•      BUT main issue: how do we assure reliable, high-quality service at affordable rates?
       Competition is key to low cost and high quality [it has benefitted public utilities and
       should be a fact of life]

Comments

•      How effective has US experience been with Nessie curves (asset management) thus far?
       Not that effective so far, but will improve.
•      What cost reductions could we expect to see on the capital side (from asset
       management)? On the order of 10%.
•      Modified GASB 34 approach supports asset management.

Utility Roundtable

Alan Manning, EMA

•      Addressed "keeping a vibrant and dominant public utility sector."
•      Traditional monopoly enjoyed by public utilities provided resistence to improved
       competitiveness, in terms of cost minimization
•      Being a monopoly reinforces a bureaucratic mind set of waiting; covering and finger
       pointing.
•      But utilities have demonstrated significant cost savings are attainable.
•      Why have a dominant public utility sector?
              protect public health and the environment
              profit motive not present to generate decision conflicts
              least costly
•      Compared with an optimized public utility, a private will "always be 5-15% more
       expensive than the public-
              profit
              overheads
              performance bonds
              shareholder return
              taxes
•      Improvements made in 203 utilities through teamwork/work practices changes,
       technology, PDM &WFF.
•      Emphasized the importance of creating a real team from a working group as compared
       with pseudo teams.
•      Internal resistence can be overcome by aligning around urgency, vision, and solution.


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•      Have to involve employees in teams to get their commitment.
•      Savings beginning first year and grow rapidly with effective implementation.
       Comments
•      Private sector need not dominate but around 20% of public utilities for varying reasons
       will not be able to become competitive; these are candidates for privatization
•      What then is the role of the private sector? Design-build practices are one example;
       outsourcing some functions has good possibilities.

Myron Olstein, Black and Veatch

•      Covered trends in utility management
•      Performance and management are improving
•      Treatment performance improved significantly
             1999 AMSA survey of 119 large utilities - 95% of flows are at secondary, up from
             84% in 1993.
             24% are at tertiary.
             heavy metals down by half in past 12 years.
•      Unit staffing levels going down.
             30% decline in 9 years.
•      Between 96-99 costs to customers match inflation; debt increased by 12%.
•      Management is improving in several key ways.
             best practices being implemented [automation; workforce flexibility]
             more tools and assistance programs [asset management, competitiveness,
             benchmarking].
             development of quality improvement programs [QualServe].
             establishment of a benchmarking clearinghouse [40 members, with the American
             Productivity and Quality Center], developing common data definitions and
             benchmarking protocols; standardization.
             development of EMS guidance from EPA grant to WEF and AMSA
•      Long term operations contracts [con ops] may not be most efficient.
             more savings in capital and support services.
             operations will change due to Internet and wireless technologies.

Comments

•      Declining staff level would have been seen as a major negative until just recently when it
       has resulted from improved productivity/performance, generating major cost savings.
•      Over 60% of the sample utilities were providing some type of financial assistance to poor
       customers, such as lifeline rates.

Bill Knecht, Cincinnati Water Works

       covered the changing water utility using CWW as an example.
•      developed a strategic business plan for the period 1996-2000.

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       developed 10 core competencies all managers and supervisors are expected to possess.
       created a value statement focusing on customer service through: efficiency and cost-
       effectiveness, quality drinking water, community involvement, professionalism, and the
       environment.
       made major investment in technology which is viewed as a tool for reducing
       cost/improving customer service.
       operating and maintenance expenses remained flat for the period 1996-2000 and all
       revenue generated by rate increases was invested in the capital improvement program.
       reviewed  financial highlights of the CWW; notably revenue increases from suer fees fell
       considerably below the average rate of inflation.
       realized a AA+/Aa2 ratings on inaugural issue of revenue bonds; good management being
       a key factor.
       developing a total enterprise asset management system.
       average net income as a percent of operating revenue is 22.6%.
Barry Gullett, Charlotte-Mecklenburg Utilities

       Covered CMU competition program.
•      Competition seek best service at lowest cost.
•      CMU largest utility in Carolines with 185,000 service connections.
•      Competition program began in 1995 with yellow pages test - looking for the service that
       are offered by the private sector.
•      First generation contacts ran 1 -5 years
•      Second generation contracts run 3-10 years; now in third generation.
•      Process involved proposal from firms and from public sector employees the "City bid
       team".
•      Used an evaluation team with a privatization and competition advisory committee.
•      Disinterested parties used in bidding/evaluation process; benchmarks used in evaluations.
•      City staff can compete; blended best private practices with public sector advantages.
•      Significant cost reductions achieved; less staff, lower energy/chemicals costs and more
       efficient work practices.
•      Second generation focused on longer cost savings; balancing risk and costs and using
       larger contracts.
•      Third generation will seek competitive bids where competition is real; stress
       benchmarking and optimization; and continue to adopt private sector approaches.
•      Findings
             city employees can compete successfully;
             involve employees; give them the resources
            | break down internal bureaucracies
            '; benchmark competitors
            i
            i
Pete Dobrolski, Malcom Pirnie                                 .

•      covered the experience of Houston with optimization, using managed competition.

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•      new laws/standards have raised the community profile of public utilities, requiring them
       to invest large amounts on new technologies.
•      Houston's budgeted $556 million for water and sewer funding in 1999.
•      improved work force flexibility and training has resulted in:
             improved productivity
             higher morale
             betted educated workforce
             more efficient use of time
             Greater reliability at less cost
       a 1996 managed competition generated $12.7 savings at one plant over an earlier
       contract.
•      in 1997, Houston re-engineered itself, redesigning job classifications, streamlining
       functions Adopting skill based pay and increasing work flexibility.
•      Between 1997-99,  O&M reduced by 8% per year; personnel reduced by 15%; procedures
       streamlined; installed modem instrumentation and automation, and use cross functional
       integration.
•      Typical annual saving are $14.8 million.

Robert Danhauser, Charleston CPW

•      Covered the adoption of an EMS under ISO 14001 guidelines at the Charleston
       Department of Public Works.
•      Why change is needed - aging infrastructure, tighter requirements, threat of competition,
       limited resources; customer issues.
•      ISO 14001 provides a business framework to utilities, beginning with the evaluation of
       current procedures using processes to identify potential strengths and weaknesses and
       assisting the organization in developing long term business and environmental strategies.
•      Using ISO guidelines a process was developed to evaluate performance against
       established objectives and to review and adjust performance.
•      In two years - CPW has:
              established a planning process
              developed a structured process to implement improvements
              developed a process to implement waste minimization and pollution prevention
              measures.
       ISO 14001, through the EMS concept, has
              provided a planning and management framework for improvement
              reduced exposures to risk and liability
              reduced O&M costs
              increased staff skills
       CPW is the first certified utility under ISO 14001.
•      Liability issues and customer concerns will promote greater use of EMS by public
       utilities.
•      80 utilities are considering EMS.
•      But concrete incentives are needed.

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•      EPA's Office of Water providing grant assistance to the development of EMS guidelines
       for the wastewater industry.

Comments on Roundtable

•      How do we get the word out to smaller utilities - how do we penetrate this market - get
       broader application below say the top 500 utilities?
•      There is no mechanism to do this - but smaller utilities will be easier to change than
       larger ones.
•      Make greater use of rural networks, such as the Rural Water Associations; political inertia
       a big problem.
•      Improvements in instrumentation have played a major role in achieving greater
       efficiencies in, for example, reducing staff required to conduct routine operations.

Ed Means, McGuire Environmental Consultants, Inc. - Strategies for the Future

•      Genesis of work: public water leadership —AWWA
•      Effort involved trends papers and workshops to id. scenarios and strategies
•      The final product later this year will be a Water Utility Futures Book
•      General findings:  change will be driven, but costs will grow
•      About 60 trends were identified via the approach

Ten Most Important Trends
1.
2.
3.
4.
5.
6.
       large rate increases will be needed to replace infrastructure
       many water utilities will have funding difficulties
       the services that water utility must supply will grow
       regulations and economics will drive consolidation of small utilities
       raw water supplies will be curbed by environmental concerns
u.     small treatment units and point-of-delivery devices will be important
7.     economic pressures wilt drive utilities to continuous improvements
8.     conservation and water recycling must and will increase
9.     traditional utility management approaches will change
10.    mergers of water and wastewater utilities with electric and gas utilities will be common

Other Findings and Observations

•      U.S. population will double by 2100 increasing pressure on water supplies.
•      Customers will demand more service and information of water providers.
•      Consumer confidence has declined and may continue to do so.
•      Water infrastructure spending and household costs will grow.
•      Water utility options will shrink as demands grow.
•      Technology will help in alleviating future water problems especially as computers
       become relatively cheaper and more powerful.

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•     But, finding technical staff will be more difficult and more costly.
•     Outsourcing will grow driven by local economics and politics.

Possible future scenarios

1.    Business as usual                        2.     Rise of the oligopoly
3.    Consumers rule                          4.     Empire strikes back

Promising strategies (appear applicable to addressing all scenarios)

•     Practice good management — quantify and articulate needs and maintain flexible
      approach (be willing to do what works)
•     Maintain good stakeholder relations and stress customer service
•     Increase community involvement and develop partnerships
•     Remove impediments to efficiency
•     Transform work environment via emphasis on improved recruitment, training, incentives,
      and pay
•     Apply best available technology:
              install automation to reduce labor and save energy
              integrate information systems
              use the internet to gain administrative efficiencies
              invest in research and development to foster innovation
•     Adopt total watershed  management approach using such tools as demand management,
      conservation, reuse programs, and rate-based incentives to manage water supply needs
•     In short, water utilities must operate as a business

Afternoon Session 2:00 pm - 4:00 pm

TOPIC: A panel discussion of the findings and recommendations of the "Water Infrastructure
Now (WIN) Report" by experts  representing a range of viewpoints

•     Michael Deane welcomed and introduced the panel
•     Ken Kirk, Executive Director of the Association of Metropolitan Sewage Agencies,
      reviewed the principle findings and recommendations of the WIN Report
•     Each panelist briefly outlined the position of their respective organization(s) with respect
      to the WIN Report.

PANELISTS PRESENTATIONS

Ken Kirk, Association of Metropolitan Sewage Agencies

•     A new federal-state-local partnership is needed and within this relationship there is a need
      for federal government to play a bigger role.
•     The WIN coalition held series of four facilitated discussions on addressing the issue of

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       water infrastructure financing needs.
•      WIN conclusions and suggestions:
              1.     Need long-term reliable funding source — $57 billion over five years
                    equally split between drinking water and wastewater
              2.     Want a commission to look into long-term solutions to funding problems
              3.     Give funding flexibility to the state; let them determine the grant/loan mix
       Other WIN thoughts
              1.     expect 25-50 per cent to be eligible for grants
              2.     expect 10-15 per cent subsidized loans
              3.     let the state decide the mix/set priorities/area of focus
              4.     establish consolidated state water agencies as successors to srfs
              5.     lift caps on private activity bonds
              6.     restrict eligibilities to core infrastructure needs
              7.     establish an EPA Office of Water Infrastructure Financing
              8.     commit $250 million a year for new technologies and management
                    practices R&D
              9.     fund expanded technical assistance of $25 million per year (EPA and Ag)
•      WIN initiative only means that the federal share would be 8% of total costs.
•      There have been 29 signatories to the WIN report so far.

Peter Cook, National Association of Water Companies

•      The cost estimates for water infrastructure needs vary widely from report to report.
       However, all parties agree that the costs will be large.
•      A realistic expectation of federal assistance provided over the five year period described
       in the WIN report might be in the range of $5-6 billion.
•      The best place to invest any federal dollars would be in the  replacement of existing
       facilities.
•      The industry question, "What is affordable?", is important and must get more attention.
•      Many large systems simply do not need help, but many small systems and large ones with
       many poor users probably do.
•      Strongly supports the idea of using a variety of financing mechanisms.
•      However, grants should be used very judiciously and a strict cap/lid should be placed on
       their use.
•      The U.S. Department of Agriculture's Rural Utilities Service (RUS) does great
       affordability work.
•      The quality of such work done by U.S. EPA is less impressive.
•      The country must not give subsidies to systems that do not need them and must encourage
       the efficient use of the limited subsidies that are or become available.

Diane Van De Hei, Association of Metropolitan Water Agencies

•      It is very important to begin to address the water infrastructure funding/financing problem
       now.

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•      While it is true that different reports have identified different absolute levels of needs,
       they all agree that the financing challenge is large.
•      The reason for the differences is that each of the reports have focused on different things,
       so comparing them is like comparing apples and oranges
•      Affordability,  if examined and considered, must take into account not just the costs of
       providing water and wastewater services, but also the cost of providing other public
       services.
•      Most affordability arguments are just a smokescreen to avoid providing federal assistance
       to large systems.
•      The small systems affordability issue is a red herring to divert government money away
       from where it will do the most good for the most people -- the large systems.
•      Government should look at and adopt a new model of affordability that factors in (gives
       credit for) a water and wastewater system's existing efficiency and viability.
•      Government should direct its resources to areas and systems in which they will do the
       most good.
•      Non-viable and inefficient systems (i.e., many small systems)  should not be supported
       with government subsidies.

Rick Norment, National Council  for Public-Private Partnerships

•      The Council supports much of the WIN report findings, particularly the recommendations
       concerning private activity bonds.
•      It agrees with the WIN report that the nation faces a large financing challenge in meeting
       its significant water and wastewater infrastructure needs.
•      The Council believes that an expansion in the use of private activity bonds would be of
       great help in meeting these  environmental infrastructure needs.
•      However, it does not agree with the magnitude of the grant program proposed in the WIN
       report.
•      The Council believes that there needs to be incentives for greater efficiencies by the
       nation's water and wastewater systems.  Grants are frequently not a good incentive, if not
       an outright disincentive for full cost accounting.
•      Further, if significant grants were made available to the admirable state revolving loan
       fund programs they would use the grants extensively in lieu of loans.
•      Competition drives improvements in efficiencies and grants, which will not be made
       available to the private sector, will make them uncompetitive.

Tim Williams, Water Environment Federation

       The Water Environment Federation's (WEF) is an organization comprised of different
       types of members who hold a variety of views on the WIN report.
•      However, the WEF signed on to the WIN report because it highlights serious needs and
       makes realistic suggestions for meeting them.
•      The WIN report is also very good because it clearly identifies  the need for the federal role
       in water and wastewater infrastructure financing  to grow.

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•      Mr. Williams expressed considerable disappointment in those who did not sign on to the
       WIN report.
•      Since there is a budget surplus and considerable Congressional support exists for
       financing environmental infrastructure, the timing is right to get new and expanded
       federal grant assistance.
•      The WIN proposal for $57 billion in federal assistance over five years is actually a very
      • modest one.

Dawn Kristof, Water and Wastewater Equipment Manufacturers Association

•      While her association chose not to endorse the WIN report, they agree on the seriousness
       of the problems/needs.
•      The association and its members strongly believe that a healthy marketplace is absolutely
       necessary for them to help provide cost-effective solutions.
•      The demand for water and wastewater infrastructure technology is driven by
       environmental regulations and enforcement.
•      Depending on uncertain, year-to-year, federal funding often results in a lot of undesirable
       stop and go activity by local utilities.
•      Government subsidy programs may stifle the desire of client utilities for innovation
       because such funding is often accompanied by intended and unintended restrictions to
       innovations.
       The association greatly doubts that federal  grant funds would come with no restrictions
       and remembers the problems that existed in this regard with the construction grants
       program.
•      Any grants provided by the federal government should also be strictly and closely tied to
       affordability.

Steve Allbee, U.S. EPA, Office of Water

•      Capital spending on water and wastewater systems maintenance has  not been, and is not,
       adequate.  Such spending is flat.
•      Water and wastewater systems are facing increasing affordability problems.
•      The country (and the industry) are not investing enough in research.  More dollars are
       needed for both research and investment.

•      A major pathway decision on the approach to addressing the infrastructure challenge must
       be made soon.
•      There is a need for a fiscal partnership as no single party can adequately address the
       challenge.
•      Improved asset management must be an important part of the answer as federal  support
       will be limited.
•      Efficiency improvements are needed and can be achieved.
•      This problem calls for an approach that incorporates business-like sustainability and
       permanent federal support.

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•     There does not see a return to the construction grants mentality.
•     There is a serious weakness in the fragmentation of information on the infrastructure
      financing problem.

Meeting adjourned by George Ames

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                        MAY 31  2002
                                                                             OFFICE OF
                                                                              WATER
 Mr. A. Stanley Meiburg
 Executive Director, EFAB
 Environmental Protection Agency - Region 4
 61 Forsyth Street, SW.
 Atlanta, GA 30303-8960

 Dear Mr. Meiburg:

       Thank you for your letter of April 30,2002, to Administrator Christine Todd Whitman,
 transmitting the Environmental Financial Advisory Board's (EFAB) recommendations from the
 Cost-Effective Environmental Workgroup's recent meeting.  Your letter contained two broad
 recommendations for our consideration.

       First, EFAB recommended that the Environmental Protection Agency's (EPA)
 Innovation Council take up the issues of improving efficiency in the water and wastewater
'industry. We have been in touch with staff in the Office of Policy, Economics and Innovation
 (OPEI) regarding their Innovation Action Council (1AC), and as you may know, the IAC recently
 released a 60 page innovation strategy for EPA entitled Innovating for Better Environmental
 Results (www.epa.gov/opei/strategv/).  EPA's program offices and regions will soon be
 implementing the commitments set forth in the strategy. Clearly, improving efficiency in the
 public water and wastewater industry is consistent with the Office of Water's stated objective to
 "employ innovative management mechanisms to reduce the lifecycle costs of infrastructure and
 utilize more flexible financial mechanisms to fund improvements." To advance this objective,
 we believe it would be fruitful for OPEI to meet with EFAB and discuss some of the Board's
 recommended improvements in procurement practices and other cost-effective initiatives
 recommended in your June 2001 report. Our staff in the Office of Wastewater Management
 (OWM) would be happy to work with OCFO to set up a three-way meeting so that OWM,
 OCFO and OPEI can jointly consider issues of efficiency in the water and wastewater industry.

       Second, EFAB recommended that EPA expand its demonstration grants for cost-effective
 management strategies, most particularly, environmental management systems (EMS), and that
                              Internet Address (URL) • http://www.epa.gov
            Rocyelod/Rocyclablo • Printed with Vagstablo Oil Based Inks on Recycled Paper (Minimum 20% Postconsumer)

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.demonstration projects be presented collectively on an Agency webpage.  We are moving to
 implement both of these suggestions. Under Section 104 (b)(3) of the Clean Water Act, we
 support a number of projects to promote EMS adoption. We will soon issue a Notice of Request
 for Initial Proposals in the Federal Register that again includes EMS as a distinct project area.
 Over the past five years we have assisted 23 local and state agencies as they developed EMSs for
 their operations. Last year, we funded a new EMS project designed to assist local governments
 called the Public Entity Environmental Management System Resource Center (PEER). The
 PEER Center f www.peercenter.net/) is a national clearinghouse of EMS information designed
 primarily for local governments. The PEER center will soon include a series of Local Resource
 Centers around the country to provide technical assistance on EMS to local, county and state
 governments. EPA will provide funding and technical assistance to these Centers so that they
 may better serve the EMS needs of local and state agencies. All these activities support EPA's
 overall policy of promoting EMS adoption in key sectors, as part of our recently released
 innovations strategy.

       Finally, we in the Office of Water look forward to building a stronger relationship with
 the EFAB on a variety of issues. The enclosed fact sheet details the potential use of the Clean
 Water State Revolving Fund for EMS projects.  As I am sure you know, George Ames, Chief,
 State Revolving Fund (SRF) Branch, brings his expertise and institutional knowledge to the
 OWM and will continue serving EFAB as an expert witness. In addition, George has asked Holly
. Stallworth, an economist in the SRF Branch, to serve as liaison to EFAB.

       Thank you for your work on cost-effective environmental management. If you have any
 further questions, please feel free to contact George Ames (202-564-0661) or Richard Kuhlman,
 Director, Municipal Support Division (202-564-0696).

                                               Sincerely,
                                               G. Tracy Mehan, Til
                                               Assistant Administrator
 Enclosure

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&EPA
                             United States
                             Environmental Protection
                             Agency
Office of Water
(4204 M)
Washington, DC 20460
EPA832-F-00-075
November 2001
                        Environmental   Management Systems and   the  Clean
                       Water State Revolving Fund
                                                       Several publicly owned treatment works (POTWs) have been or will
                                                       shortly be certified to ISO 14001. These include San Diego, CA.
                                                       Lowell, MA, Charleston. SC, Eugene. OR and Gastonia. NC. Other,
                                                       more tailored EMS programsareaJsoundcrdcvelopmerrt. Forexample,
                                                       under the National Biosolids Partnership (NBP), the EPA's Office of
                                                       Water, along with lite Water Environmental Federation (WEF) and the
                                                       Association ofMclropolitan Sewerage Agcncics(AMSA), is helping to
                                                       develop and implement an EMS program tailored to the biosolids
                                                       industry. EPA, AMSA and WEF are also beginning a project to analyze
                                                       the feasibility of developing a utility-wide EMS template that would
                                                       integrate  the  use of other utility  management  tools  like  asset
                                                       management. More infortnation about theNBP's EMS program can be
                                                       found on their web site at www.hicMiolids.orB.
 The Problem

 Public and private enterprises face an increasingly heavy burden of
 responsibility  for  the  future  condition  of our environment.
 Waste-water treatment systems in particular are getting more complex
 and face numerous environmental challenges, requiring dynamic,  top
 quality environmental management  A systematic method  for
 addressing environmental consequences is often needed - not only for
 current issues of legal compliance  but also to address additional
 community and environmental concerns. One method of managing
 environmental impacts has been codified into a series of protocols:
 environmental management systems (EMS). The EMS method holds
 particular promise as an information-rich and  inclusive framework for
 addressing environmental issues.
 This fact sheet will briefly discuss the method of an environmental
 management  system (EMS)  and how the Clean Water State
 'Revolving Fund may be tapped to establish an EMS program.
••:.-
 \Vlfat is an EMS?

 An EMS is a formal set of procedures and policies that define how on
 organization will manage and reduce its impacts on the environment.
 The basic elements of an EMS include;

         •  reviewing the organization's goals;
         •   analyzing  its  environmental   impacts  and legal
         requirements;
         • setting environmental objectives and targets;
         • establishing programs to meet objectives and targets;
         • monitoring and measuring progress;
         •  ensuring  employee environmental  awareness   and
         competence;
         •  reviewing progress  of the EMS  and  making
         improvements.

 As an iniegrative process, EMS is a continual cycle that involves
 planning,  implementing, reviewing and improving  so  that iin
 organization can reduce its environmental impacts.

 EMSs arc increasingly being developed  in  conformancc with the
 voluntary International Organization for Standardization (ISO) 14001
''standard for EMSs. Over 1300 organizations  in the US. arc attracted
 to the ISO EMS because it provides a documented, externally
 verifiable system.  Firms adopting an ISO  14001-based EMS can
 demonstrate due diligence  in regulatory compliance, a  positive
 statement of environmental philosophy, and a competitive advantage
 in public, customer, and business partner relationships. EPA has
 Established a policy of promoting the development of EMSs in key
 sectors, including wastewatcr, because the EMS method can help
 improve overall environmental performance,  reduce costs, and bring
 about improved facility management in many  other ways. A  number
 of states arc also promoting EMS adoption by various sectors.
                                                       The Clean Water State Revolving Fund

                                                       The CWSRF programs,  in every stale and Puerto Rico, work like
                                                       banks. Federal and state contributions arc used to capitalize or set up
                                                       the programs. These assets, in turn, are used to make low or no-interest
                                                       loans for important water quality projects.  Funds arc repaid to the
                                                       CWSRFs over terms as long as twenty years.  Repaid funds arc then
                                                       recycled to fund other water quality projects. Nationally, the CWSRF
                                                       has in excess of $34 billion in assets (includes loans already made and
                                                       funds available to make loans). The CWSRF is funding water quality
                                                       projects at a rate of more than S3 billion per year.

                                                       Potential incentives for funding CWSRF EMS projects include special
                                                       recognition, such as acknowledgment on EPA'swcb site, opportunities
                                                       to be featured in EPA publications, and participation in information
                                                       exchanges such as EMS practitioner forums.

                                                       Benefits in Using Environmental Management Systems
                                                       for CWSRF Projects

                                                       EMS can help local government entities address their regulatory and
                                                       non-regulatory issues in a systematic and cost-effective manner. This
                                                       proactive approach can help reduce the risk of non-compliance and
                                                       improve health and safety practices for employees and the public. The
                                                       EMS can also help address  non-regulatory  issues such  as odor
                                                       management and energy conservation.  Implementation of EMS can
                                                       result in significant energy savings. The EMS can promote stronger
                                                       operational control and employee stewardship.  Local government
                                                       unlitius ure also using EMSs to manage growth. In addition to the
                                                       advantages available  for local governments, state agencies benefit by
                                                       extending the coverage of their CWSRF by making more efficient and
                                                       ttlTcclivu use of their loan funds in achieving water quality benefits.

                                                       Eligibility for Funding

                                                       The EPA is pursuing a policy of actively promoting the adoption of
                                                       EMSs. The Clean Water State Revolving Fund can be  used for
                                                       developing an EMS, provided it is  part of the construction,

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 modification or expansion of a POTW. While CWSRF loan
 funds can be used to help establish an EMS program in the context of
 waste-water treatment, CWSRF funds may not be used to maintain or
 operate the EMS. However, research shows that EMS development
"tests usually exceed the costs of implementing the EMS. Again, only
 EMS development costs arc eligible and only those costs can only be
 funded as part or the construction, modification, or expansion of a
 POTW.  EMS projects are not eligible for loans  as a stand alone
 activity.
 /     v
 Learning by Example

 While CWSRF funds were not used to develop and set up the
 following EMS projects, these projects would have been eligible for
 funding as part of a POTW construction, expansion or modification.
 The City of Lowell, Massachusetts, Lowell Waslcwatcr Utility
 was selected as a project participant  in the USEPA EMS Pilot
 Program for Local Government Entities. The Utility is an activated
 sludge wastewater treatment facility providing primary and secondary
 treatment to 170,000 users in five communities. The EMS focused on
 waste stream  management,  chemical use management, energy
 reduction, odor control, and industrial notification. Energy reduction
 alone resulted in a savings of 57,000 over a 10-month period. Other
 benefits  include  improved  communication at all  levels  of the
 Organization, greater participation in decision making, more creative
 solutions,  employee  empowerment,  and  increased  operation
 efFjciencics'arid belter service  to customers. These improvements
 resulted from a rather modest expenditure of about 542,000. For more
 information  contact  Mark   Young,   (978)  970-4248,  e-mail:
• myoung@ci.lowell.rna.us.

 The Wastewater Division within the City of Eugene, Oregon is
 devclopinganBMSforn49 million-gallon-pcr-day regional secondary
 wastcwntcr treatment plant, a  biosolids processing facility, a land
 application site for irrigation using vegetable cannery wastewater, and
 49; local  sewage pumping  stations.   The EMS  centers  on the
 Wastewater Division's core responsibilities of protecting health and
 environment, and clarifies guiding policies, ensures integration of the
 different functional components of the regional wastewater program to
 optimize environmental benefits, and helps to establish and maintain
 an effective documentation  system.  The EMS objectives  target
 reductions in natural resources consumption, power consumption,
 non- recyclable wastes, and improvement of die quality of treated
 wastewater. For more information, contact Peter Ruflicr at (541) 682-
 8606'or via e-mail at Petcr.J.RUFFlER@ci.eiigene.or.us
North City Reclamation Plant, and reductions of over 8% and 30%,
respectively, of their normalized process chemical use for the Point
Loma Wastewater Treatment Plant and the Metro Biosolids Center.
The EMS has also prepared the Division to effectively respond to other
regulatory and wastcwalcr industry standards, like  the US EPA's
Capacity,  Monitoring, Operations,  and Maintenance (CMOM)
Program requirements and the National Biosolids Partnership's EMS
for Biosolids Initiative.  For more information contact Chris Torn at
(858)654-4265,
e-mail: CJT@sdcity.sanncl.gov.

Challenges Ahead

EPA has been encouraging the states to open their CWSRFs to the
widest variety of water quality projects, while addressing high priority
projects in targeted watersheds.  Those interested in  establishing an
EMS (in conjunction with the construction, expansion or upgrade of a
wastcwater treatment plant) should contact their state for information
on the CWSRF application process.
For more information on Environmental Management Systems,
please contact:
The EMS web s'llef http://ena.BOV/mvmimtH/ems.him'> or Jim Home at
(202) 564-0571 or through email at
home.inmes6?cpa.pov.

For  more Information  on  the  CWSRF or,for  a program
representative in your stale, please contact:
The Clean Water Slate Revolving Fund Branch
U.S. Environmental Protection Agency
EPA East
1201 Constitution Avenue, NW
(Mail Code 4204M)
Washington ,D.C. 20004
Phone: (202) 564-0752 Fax: (202) 501 -2403
Internet: hfrn:y/\v\v\v.cna.iiov/ovvm/finnn.hlm
 City of  San  Diego, California Metropolitan Waslewaler
 Department's Operations  and  Maintenance Division.   The
 Department manages a regional sewer system service area of 4,560
 sguare miles serving a population of two million people. Utilizing the
 ISO 14001 standard, the Division developed and implemented the first
 ISO-certified EMS for POTWs within the United States.  The EMS
 established four system-wide environmental programs focusing on
 inductions in  energy consumption, chemical usage, solid waste
 disposal, and potable water use.  Successful implementation of the
 EMSresulted in a reduction of 10% in normalized electrical use by the

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SEPA
                            United States
                            Environmental Protection
                            Agency
Office of Water
(4204 M)
Washington, DC 20460
EPA832-F-00-075
November 2001
                       Environmental   Management  Systems  and   the  Clean
                      Water State Revolving Fund
                                                     Several publidy owned treatment works (POTWs) have been or will
                                                     shortly be certified to ISO 14001,  These include San Diego, CA,
                                                     Lowell, MA, Charleston, SC, Eugene, OR and Gastonia, NC. Other,
                                                     moretailoredEMSprogramsarealsoundcrdevelopment Forexample,
                                                     under the National Biosolids Partnership (NBPX the EPA's Office of
                                                     Water, along with the Water Environmental Federation (WEF) and the
                                                     Association ofMetropolitan Sewerage Agencies (AMSA), is helping to
                                                     develop and implement an EMS program tailored to die biosolids
                                                     industry .EPA, AMSA and WEF are also beginning a project to analyze
                                                     the feasibility of developing a utility-wide EMS template that would
                                                     integrate the use of other utility management  tools  like asset
                                                     management. More information about IheNBP's EMS program can be
The Problem

Public and private enterprises face an increasingly heavy burden of
responsibility  for the future  condition  of our  environment
Wastewater treatment systems in particular are getting more complex
and face numerous environmental challenges, requiring dynamic, top
quality environmental management  A systematic method for
addressingenvironmental consequences is often needed- not only fen-
current issues of legal compliance but also to address additional
community and environmental concerns. One method of managing
environmental impacts has been codified into a series of protocols:
environmental management systems (EMS).  The EMS method holds
particular promise as an information-rich and inclusive framework for
addressing environmental issues.
This fact sheet will briefly discuss the method of an environmental
management  system  (EMS) and how  the Clean Water State
Revolving Fund may be lapped to establish an EMS program.

What is an EMS?

Ah EMS is a formal set of procedures and policies that define how an
organization will manage and reduce its impacts on the environment.
The basic elements of an EMS include:

        •  reviewing the organization's goals;
        •   analyzing  its environmental impacts  and  legal
        requirements;
        • setting environmental objectives and targets;
        • establishing programs to meet objectives and targets;
        • monitoring and measuring piogress,"
        •  ensuring employee environmental   awareness and
        competence;
        •  reviewing progress of the EMS and making
        improvements.

As an integrative process, EMS is a continual cycle that involves
planning,  implementing, reviewing and improving  so  that an
organization can reduce its environmental impacts.
              •
EMSs are increasingly being developed  in conformance with the
voluntary International Organization for Standardization (ISO) 14001
standard for EMSs. Over 1300 organizations in the US. are attracted
to the ISO EMS because it provides a documented, externally
verifiable system. Firms adopting an ISO  14001-based EMS can
demonstrate due diligence in  regulatory compliance,  a positive
statement of environmental philosophy, and a competitive advantage
in public, customer, and business partner relationships.  EPA has
established a policy of promoting the development of EMSs in key
sectors, including wastewater, because the EMS method can help
improve overall environmental performance, reduce costs, and bring
abbirt improved facility management in many other ways, A number
of states are also promoting EMS adoption by various sectors.
                                                     found on their web site at www.biosolids.org.

                                                     The Clean Water State Revolving Fund

                                                     The CWSRF programs, in every state and Puerto Rico, work like
                                                     banks. Federal and state contributions are used to capitalize or set up
                                                     (he programs. These assets, in turn, are used to make low orno-interesl
                                                     loans for important water quality projects. Funds are repaid to the
                                                     CWSRFs over terms as long as twenty years.  Repaid funds are then
                                                     recycled to fund other water quality projects. Nationally, the CWSRF
                                                     has in excess of $34 billion in assets (includes loans already made and
                                                     funds available to make loans).  The CWSRF is funding water quality
                                                     projects at a rate of more than S3 billion per year.

                                                     Potential incentives for funding CWSRF EMS projects include special
                                                     recognition, such as acknowledgment on EPA's website, opportunities
                                                     to be featured in EPA publications, and participation in information
                                                     exchanges such as EMS practitioner forums.

                                                     Benefits in Using Environmental Management Systems
                                                    for CWSRF Projects

                                                     EMS can help local government entities address their regulatoiy and
                                                     non-regulatory issues in a systematic and cost-effective manner. This
                                                     proactive approach can help reduce the risk of non-compliance and
                                                     improve health and safety practices for employees and the public. The
                                                     EMS can  also help address non-regulatory issues such  as  odor
                                                     management and energy conservation. Implementation of EMS can
                                                     result in significant energy savings. The EMS can promote stronger
                                                     operational control and employee stewardship.  Local government
                                                     entities are also using EMSs to manage growth.  In addition to the
                                                     advantages available for local governments, state agencies benefit by
                                                     extending die coverage of their CWSRF by making more efficient and
                                                     effective use of their loan funds in achieving water qualify benefits.

                                                     Eligibility for Funding

                                                     The EPA is pursuing a policy of actively promoting the adoption of
                                                     EMSs. The Clean Water State Revolving Fund can be used for
                                                     developing an EMS, provided it is part of the construction,

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