vvEPA
               United States
               Environmental Protection
               Agency
               Office Of The Administrator
               (A-101F6)
EPA 101/F-90/038
September 1990
Mobilizing For
Safe Drinking Water:
A Blueprint For Action
#90-2506
                                                 Printed on Recycled Paper

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Mobilizing  for  Safe Drinking  Water

                A Blueprint  for Action
                       Prepared for

                    Peter Karalekas, Jr.
                Chief, Water Supply Section
                     US EPA Region I

                           by

                      Mary Ann Hill
  National Network of Environmental Management Studies Fellow
                      Summer 1990
                 US Environmental Protection Agency
                 Region 5 Library (PL-12J)
                 77 West Jackson Blvd., 12th Floor
                 Chicago, IL 60604-3590

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                           DISCLAIMER

This report  was furnished  to  the  U.S.  Environmental Protection
Agency by  the graduate student identified  on the cover page, under
a National  Network for Environmental  Management Studies
fellowship.

The  contents are  essentially as  received from the author.   The
opinions, findings,  and  conclusions expressed are those of the author
and  not necessarily those of the U.S. Environmental Protection
Agency.  Mention,  if any,  of  company, process, or product names is
not to be considered  as an endorsement by the  U.S.  Environmental
Protection  Agency.
                        ADDITIONAL COPIES

      To order additional copies of Mobilizing for  Safe  Drinking
Water: A Blueprint For Action,  please call  the National  Technical
Information  Service (NTIS) of the U.S.  Commerce Department  at
(703) 487-4650.   To order this report ask for report number
PB91-100131.  Both  paper copy and  microfiche are available.

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                                    ABSTRACT

             Mobilizing for Safe Drinking Water:  A blueprint for action

       The  1986 amendments to the Safe Drinking Water Act (SDWA),  which are being
phased in over several years, are designed to protect public  health against both the short- and
long-term effects of over 200  contaminants.  Compliance will place a tremendous strain on
state  drinking water  programs and  thousands  of public water systems, particularly small
systems serving  fewer than 3,300 people.
       Forging  cooperative  relationships  among  the  numerous  agencies and  organizations
affected by  the amendments can help ease the burden of compliance.  Such partnerships are
necessary because EPA and  state agencies alone can provide only a fraction of the technical,
managerial,  and  financial assistance needed to facilitate compliance.
       This  report describes the crisis in primacy (primary enforcement authority) that state
drinking  water program's face in light of the  SDWA amendments and the urgent need for
increased  resources necessary  to retain primacy.  Recommendations for designing  a state
Mobilization Program are presented, drawing on examples of cooperative efforts in other states.
An eighteen-month  action plan for EPA regional water supply staff is included.
       The  blueprint  should be  used by EPA  and state drinking water officials and other
individuals who  have an  interest in ensuring the continuous provision  of safe drinking water
to the nation.

       This  blueprint  was prepared by Mary Ann Hill, a National Network of Environmental
Management Studies Fellow, for Peter Karalekas, Jr., chief  of the Water Supply Branch, US
EPA Region I.   Ms. Hill is a candidate for a Masters in Public Policy degree at the John F.
Kennedy School of Government at Harvard University.

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                               Table of Contents


Mobilization:  Creating action-oriented partnerships	1

       Mobilization blueprint for Region One:  How to use this report	3

Primacy crisis:  The high cost of protecting public health	4

       The case for retaining primacy	4
       Immediate need for additional resources	5
       Building coalitions: establishing a drinking water advisory committee	6
       Alternative Funding Mechanisms (AFMs)	8

Designing a comprehensive Mobilization Program	9

       Establishing an advisory committee	10
       State Capacity	11
       Institutional Support	11
       Local Health Officials	15
       Technology and Training	16
       Non-Transient Non-Community Systems	19
       Public Education	21

Mobilization action plan for Region I (9/90 - 3/92)	23

Resource Directory	25

       Mobilization Initiative Leaders	25
       Region I Mobilization Coordinators	26
       Program Contacts in Other States	27
       Assistance Programs and Trade Associations	28

Endnotes	29

Appendices

       Appendix A:  Pennsylvania Small Water Systems Committee
       Appendix B:  Alternative Funding Mechanisms: advantages and disadvantages
       Appendix C:  Connecticut regulations for permit review and approval
       Appendix D:  Including financial review in permitting process
       Appendix E:  Maryland requirements for proposed privately-owned water systems
       Appendix F:  Sample Memoranda of Understanding (MOU):California and Connecticut
       Appendix G:  Restructuring options to overcome diseconomies of scale
       Appendix H:  Sample contract for operations and management (O&M) contracting
       Appendix I:   Case studies of O&M contracting
       Appendix J:   Case studies of mergers and acquisitions
       Appendix K:  Pennsylvania legislation on acquisition of public water systems

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Appendices (continued)

      Appendix L:  Newsletter article, "Ensuring Safe Drinking Water: New Challenges for
                   Local Health Officials"
      Appendix M: Office of Drinking Water publications
      Appendix N:   Massachusetts questionnaire for technical services network
      Appendix O:  Pennsylvania resource directory, "A Water  Utility's Guide to Financial
                   and Technical Assistance Programs"
      Appendix P:  Adopt-a-Small-System program in  Alameda County, California
      Appendix Q:   Public information fact sheets from Alaska and New Hampshire
      Appendix R:  "Summary of National  Organizations' Activities in  Support  of the
                   Mobilization  Strategy"

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Mobilization:     Creating action-oriented  partnerships

       We all  want  consistently  safe  drinking  water.   But  today's
economic and industrial  growth pose greater  threats  than ever  to our
water supplies.  The 1986 amendments to the  Safe Drinking Water Act
(SDWA) are designed to protect public health against both the short- and
long-term effects of these contaminants.
       The regulations are strict, calling for the monitoring of more than
200 chemicals by the year 2000.  Compliance will be very expensive, but
it is  an investment we must make.  In brief, the amendments call for:

o      an increase in the number of regulated contaminants to nearly 200
       by the year 2000;

o      filtration for nearly all surface water systems and disinfection for
       all surface water and many groundwater systems;

o      a ban on lead-based solder, pipe, and flux materials.

       Recognizing the  scope  and  seriousness  of  the challenge  of
compliance with the SDWA requirements, the  Environmental Protection    The  concept of Mobilization  is
Agency (EPA)  has undertaken a broad  and far reaching mobilization    £"'  expressed  by  the  ada$e,
effort » bring  the resources and talents of all groups affected  by the     Many fands mate hght worL
regulations to bear on their implementation.  The concept of Mobilization
is best expressed by the adage, "Many hands make light work."
       Forging cooperative working relationships among federal agencies,
State  drinking water programs,  business and civic groups, educational
institutions, local water systems, and industry groups can help ease the
burden of compliance. In fact, such partnerships are necessary because
EPA  and  State agencies alone  can  provide  only a fraction  of the
technical, managerial, and  financial assistance  needed to  facilitate
compliance.
       The groups involved in Mobilization include  those traditionally
associated with the water industry such  as the American Water  Works
Association, the National Rural Water Association, and the Association
of State Drinking  Water Administrators  as well  as  those  new  to the
industry  such  as  the Grocery  Manufacturers  of America  and the
Manufactured Housing Federation.
       EPA recognizes that many State programs already have established
successful  working   relationships  with  agencies  and organizations
concerned with safe drinking water and have realized  the benefits that
such cooperation can bring. EPA's Mobilization Program is an effort  to
expand  these efforts to all  States, to encourage partnerships in a more
structured and  comprehensive manner in order to yield even  greater
returns.
       Creativity,  effort,  and patience are  needed to forge  these new
partnerships.   New lines of communication and cooperation  must  be
opened  and maintained.  Relationships between organizations  must  be
redefined and expanded from the traditional regulator-regulatee mode;

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The  common  element  among
these  initiatives  is  that  each
seeks  to  achieve  its objectives
through the coordinated efforts
of   external    groups   and
associations.
any past difficulties  and "turf battles" must  be put aside  in a  spirit
cooperation and mutual self-interest.   The path will not be easy, but
potential and need for cooperation has never been greater.

      EPA and State programs must pursue three principal  objectives:

1.    Strengthen the institutional framework for water supply at b
      the State program level  and  the small  water system level,
      promoting legislation to increase  State program resources and
      promoting restructuring of small systems to ensure their viabilit

2.    Build  technical  and  managerial   capabilities  for  SD\
      implementation   by   identifying  and   promoting   appropr
      technological solutions and  by developing training  coalitions
      small system operators, local health officials,  and others.

3.    Change public attitudes by educating and garnering the suppor
      a public that views drinking water as a  valuable commodity, om
      which it is willing to invest its resources.

      The Mobilization effort serves as a coordinating umbrella fo
variety of initiatives.  The common element among these initiatives is
each seeks to achieve its objectives  through the coordinated efforts
external groups and associations - with the coordination provided by E
and State drinking water programs.    Beyond this common element,
actual  substance  of  the various initiatives  is  different, ranging  ft
increasing  State  program  resources  to  identifying  simple,   low-(
technology for small  systems.
      Six initiatives  have  been identified and developed  by  EPA
accomplish the  objectives of the  Mobilization Program:

o     State Capacity Initiative focuses on State executive and legislai
      leaders  to  gain  their  support  for  increased  resources for  S
      drinking water programs.

o     Institutional Support Initiative aims to ensure that small syste
      (those serving fewer than 3,300 people) are capable of sustained
      consistent  compliance  with  federal  and State  drinking  w;
      regulations.

o     Local Health Officials Initiative  seeks the active support  of tc
      and county health officials to  ensure that all citizens - includ
      those  with private household  wells —  enjoy the benefits of  <
      drinking water.

o     Technology and  Training  Support  Initiative focuses  on
      engineering and technical community to ensure  identification an

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       use  of appropriate low-cost technology for small systems and
       development and delivery of needed training.

o      Non-Transient  Non-Community  Systems  Initiative  aims  to
       develop awareness of SDWA regulations and facilitate compliance
       among these systems.

o      Public Education Initiative seeks  to build an understanding by
       the  general public and local officials of the importance of safe
       drinking water as a valuable resource in which we must be willing
       to invest.

Mobilization blueprint for Region One:  How to use this report

       Just as each  State's  drinking water program varies, so will its
needs,  priorities, and resources for mobilization efforts.  This report is  a
blueprint for each  State  in Region  I to use  in  designing  its  own
Mobilization  Program.   In addition, the Regional EPA Water Supply
Section can use the report as a guide in encouraging and facilitating the
States' chosen efforts.
       The blueprint is structured in four sections.  The first concentrates
on the "primacy crisis" posed by the  SDWA amendments, the critical
need of State drinking water programs for the increased resources needed
to retain primacy.  Because it is likely that appropriations from a State's
general fund will not  be  sufficient to adequately support its drinking
water  programs,  alternative funding  mechanisms   (AFMs)  must be
explored  and instituted to  supplement general  fund resources.   The
advantages and disadvantages of several AFMs are discussed along with
specific steps that a State can take to  determine which  would be most
appropriate for its needs.
       The second section of the blueprint focuses on  the key initiatives
that States  can take to  facilitate and ensure compliance with the SDWA
amendments, with  a particular concentration on  the needs  of  small
systems.  Programs  range from low-cost technical assistance efforts such
as Adopt-A-System programs  to  more  resource-intensive efforts  to
strengthen permitting regulations and improve system viability.
       The blueprint's third section is an 18-month action  plan  for
Region I,  both  EPA's  Water Supply Section and State drinking  water
programs.   The specific  actions highlighted in the plan by no means
exhaust the options available to drinking water program officials; in fact,
they  are just  the beginning.  All parties should use the action plan as  a
springboard for future Mobilization initiatives.
       A resource directory of drinking water organizations and officials
mentioned in the report is included in the  final section.
       Drinking water officials should use  this blueprint as a "menu" for
creating balanced and comprehensive Mobilization Programs throughout
Region I.   As in designing a balanced  diet, State programs should be
Drinking  water officials  should
use this^blueprint as a "menu" for
creating   balanced    and
comprehensive   Mobilization
Programs throughout  Region I.
As in designing a  balanced diet,
state programs should  be sure to
select at  least one option from
each of the six initiatives.

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      these regulations are a
        for  public   health
protection, their implementation
and enforcement threaten to bust
state drinking water programs.
sure to select at least one option from each of the six initiatives.  Wit!
each initiative there is tremendous variety, allowing for the creation o
Mobilization Program tailored to individual needs, priorities, and resourc

Primacy crisis: The high cost of protecting  public heal

      Passage of the 1986 SDWA amendments marked the dawn of a m
era in the protection  of America's  drinking water.   The  amendme
^^ increase the scope  and stringency of the national drinking wa
regulations, placing considerable emphasis on long-term health effects.
fact, the standards for regulated contaminants are set at very low levels
ensure a  lifetime of protection  against both acute and chronic  hea
effects.
      While these regulations are a boon for public health protection, th
implementation and enforcement threaten to bust  State  drinking wa
programs.   A joint report by  the Association of State  Drinking  Wa
Administrators (ASDWA) and EPA estimated that States need an additioi
$34 million per year to implement the current requirements.  In additk
implementation of the 1986 amendments will cost the States $184 milli
in one-time, upfront costs  through 1992 and will lead to an increase
$152 million  in annual costs  per year after  1992.1 Dramatic increases
federal  subsidies   are  highly  unlikely;  therefore,  States  must  bej
immediately to build support  to substantially increase their drinking wa
program budgets.

The case for retaining primacy

      Without additional resources  for  increased program costs,  Sta
could lose primary enforcement authority or "primacy."  The consequenc
of losing primacy would be  dire - increased costs to water systems  a
consumers and the loss of State control in implementation and enforcer™
of drinking water regulations.
      When it passed the  SDWA in 1974,  Congress realized  that Sta
were in a better position than EPA  to implement and  enforce drinki
water regulations and to mediate and accommodate certain  situations
conditions that might occur.   Therefore, it  provided for States to ret!
primary enforcement of the regulations.  To assume and retain  primacy
State must not only adopt drinking water regulations that are  at least
stringent as the federal  requirements but also must be able to  adminis
and enforce these regulations.
      EPA's  stated emphasis is on enforcement against those who viol
federal  regulations.    The  1986   amendments gave   EPA   increas
enforcement authority including the  ability  to levy immediate fines  a
penalties of up to $25,000 per day.  On  the other hand, the State approa
to drinking water regulations is more  concerned with  protecting  pub
health by  preventing violations before they occur.

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       Primacy involves two basic issues: money and control.  Retaining
primacy is expensive:  States must have sufficient staff to monitor and
enforce SDWA regulations.   Yet  a  recent study  by the  Virginia
Department of Health found that "while  increased State resources would
be needed to retain primacy, the final cost to the waterworks owner (and
inevitably the consumer) would increase  if primacy were returned to the
EPA."2
       By  relinquishing primacy  to  the EPA, a  State would  lose the
ability to  address its own  problems.  Loss of primacy would mean the
loss  of a  State's control  and  discretion  regarding the application  of
certain portions of the federal regulations  to the State's water systems.
For example, the Surface Water Treatment Rule (SWTR) gives primacy
States considerable discretion in addressing issues such as which sources
are surface-influenced and  evaluation  of  treatment plant performance.   If
a State loses  primacy, its  water systems would be expected to comply
with  the  EPA's  strict literal  interpretation of  the  SWTR  with  no
discretion.3
       Small systems  would be especially hard hit by a loss of primacy.
These systems, which face the most difficulty maintaining compliance
with the  new regulations,  would lose the  ability to work through their
own  special problems  with State agency staff.  In  addition, EPA does not
have the resources for the technical assistance programs so sorely needed
by small  systems.  As a result, there would be an increase in the risk of
waterborne disease outbreaks, with public health in rural areas facing the
greatest threat.

Immediate need for additional resources

       Given  the  increased scope  and  stringency  of  the  SDWA
amendments, the cost  of safe, dependable water will rise, in some cases,
dramatically.  Water system operating, monitoring, and maintenance costs
will increase as will monitoring, enforcement, and reporting costs of State
drinking water programs.  Additional resources will be needed to cover
the program costs necessary for a State  program to retain primacy.  In
addition to increased  funds needed to administer  their drinking water
programs, many States are  wrestling with the question of how to provide
financial  assistance to small systems.
       Ultimately,  these  increased  costs  will  be  borne  by  water
consumers.  The  size  of increases in household water bills will vary,
depending  on  the  system's customer base and  the  type of treatment
needed.  Not all water systems will  need  to construct new  facilities to
comply  with the new regulations.   Yet  estimates  of the  increased
resources needed for State programs to maintain primacy equal to double
the current program budgets are not uncommon.
      Most State  drinking  water programs receive  the bulk of their
funding through annual appropriations from the General Fund. However,
as pressure for the use of general fund revenue for other purposes
 "States want to  keep primacy
 because EPA does not nave the
 resources to administer programs
 sensitively and will use automatic
 penalties    and    enforcement.
 Another dimension is that  states
 have  had many   dimensions  of
 programs, for example review of
 plans   ana   specifications   in
 drinking water plants.   EPA has
 no authority for these programs."
 Mike  Cook, director  of  EPA's
 Office of  Drinking Water
 "Even if  they  wanted  to,  the
federal government cannot worry
 about specific  cases;  they must
 use a broad brush to apply  the
 regulations across the board.  A
 state  run program, on the other
 hand, can take full advantage of
 the  flexibility   built  into   the
federal regulations in order  to
 address local issues."
 Allen  Hammer, VA Department
 of Health

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State  drinking water programs
must  harness  the energy  and
resources  of drinking water's
broad-based constituencies.
State  drinking water programs
must be willing to commit staff
resources to organize, motivate.
and administer the  committees
efforts.
mounts (including competing environmental and public health  progran
States may need to investigate and secure alternative funding mechanis
(AFMs)  to provide  additional resources specifically  designated  ;
distributed  for the purpose  of retaining  primacy.   Each  State  m
investigate  the range of available  options and  determine the  mixture
funding mechanisms that is feasible and best serves its needs.
      Examples  of AFMs  include fees,  dedicated  taxes, and fines i
penalties for program administration.  Bond proceeds can be used in St
revolving funds to assist water utilities in financing infrastructure cost;

Building coalitions:  establishing a drinking water advisory  commit

      Given New England's current fiscal crunch and economic downti
State programs must work hard to develop broad-based and strong supp
for new  revenues,  most of which  will require  legislative approval.  1
only must  industry and consumers be educated about the  higher cc
associated with providing drinking water that meets standards, but they a
must be convinced to support the increased revenues needed to meet th
costs.
      State drinking water programs  can not and  should not undert
these  efforts  alone —  they must  harness  the  energy and  resources
drinking  water's broad-based constituencies.
      The  most effective way for State programs  to  build the coaliti
necessary to generate support for  increased resources for drinking  w;
programs is to form an advisory committee or task force.   In many wj
the advisory committee is a microcosm of the State's entire Mobilizat
effort.  Members of this working group should  represent  a wide range
organizations affected by the federal regulations: statewide water indu;
associations, water system owners, local governments, business and ci
organizations.
      With such a wide range of interests and  constituencies,  differen
among committee  members are  bound to surface.  However, all  par
must make the commitment to begin the process with clean slates, leav
behind past difficulties, and to work together in  a spirit of cooperation
partnership.  An excellent example of an effective advisory  committe<
Pennsylvania's Small Water System  Committee, formed in  1988  as
interagency small systems forum and network.  In addition to assisting
the passage of legislation affecting water systems, the Committee  fos
constructive working relationships among  various agencies concerned v
safe drinking water.  A list of Committee members and a sample age
from a recent meeting can  be found in Appendix A.
      State drinking  water programs  must be willing to commit s
resources to organize, motivate, and administer the committees'  effor
A volunteer committee's success and effectiveness is largely determined
the level of staff resources available to administer and implement
programs and recommendations.   The committee's staff member  she
undertake tasks such as developing briefing materials  for committee

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members, devising meeting agendas, and conducting appropriate follow-
up  activities to  ensure  the smooth and  efficient  operation  of the
committee.
       The goal of an advisory committee is to build consensus among
interested parties for increased drinking water program resources and to
turn this support into reality. State program staff should follow the steps
outlined below  to  form  a committee and ensure the realization of this
goal:

o      Identify  organizations and  contact appropriate representatives by
       an initial telephone conversation to determine interest in becoming
       a committee member;

o      Send letter to interested members, thanking them for agreeing to
       participate and outlining goals of committee.   Include a list of
       other preliminary committee members.

o      Hold initial organizational  meeting to determine action  plan for
       committee's  efforts,  including  administrative   issues such  as
       committee structure;

o      Organize regular advisory committee meetings — develop agenda,
       organize speakers and presentations, record and distribute meeting
       minutes, conduct  follow-up activities as needed

       In addition to developing  a strategy for building consensus for
increased  drinking  water  program  resources  and determining  what
combination of  General Fund and AFM revenues are most appropriate to
the program's needs, the advisory  committee can take specific actions to
voice  its support for the State program's efforts:

o      Organizations can go on public record as supporting State primacy
       by  passing resolutions, writing letters  to  legislators and  other
       industry  opinion makers, and speaking before interested groups.

o      In addition, committee members can urge the State legislature to
       take  the actions  necessary to ensure that  proper  resources are
       authorized to retain primacy and to support an AFM specifically
       dedicated to drinking water programs.

o      Committee  members should  mobilize  their own members and
       reach out to other constituencies to generate support for an  AFM
       to meet  the increased needs of the drinking water program.
Members  of a drinking  water
advisory   committee   should
represent  a  broad  range  of
constituencies, such as:

Cooperative Extension Services
Rural Community Assistance
Programs
New England Water  Works
      Association
State Water Works Association
Northeast  Rural  Water
      Association
Conservation Commissions
New England Manufactured
      Housing Association
State Association of  Health
      Boards/Officials
Public Utilities Commission
US EPA
Dept.  of Environmental
      Protection
Dept. of Public Health
Large utilities
Municipalities
State Municipal Association
League  of Women Voters
Audubon Society

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In   addition   to   building
consensus   for   increased
program revenues, a drinking
water   advisory  committee
must develop and recommend
a   package   of  funding
mechanisms that  will  best
serve the primacy  agency's
needs.
Alternative Funding Mechanisms (AFMs):

  In addition to building consensus for increased program revenues, a drinki
water advisory committee must develop and recommend a package of fundi
mechanisms that will best serve the primacy  agency's needs.  As mention
earlier, it is likely that a mixture of General Fund and AFM revenues will
the preferred funding alternative.
  In devising the best revenue package, the advisory committee must not or
consider the various types of funding mechanisms but also have some mea
by  which to measure  the effectiveness  and feasibility of  these  differe
revenue sources.  Appendix B includes  a  discussion of three AFMs (servi
fees, user fees, and fines and penalties)  and presents eight  criteria that
advisory committee can use to measure a source's effectiveness.
                                                    Water Protection Fund
                                     Because of increased jej$uiitements in its drinking water program,
                                ,the:-:-..VjtaNtt • Department o£  Sealth's  Division vo£ Water  Suppl)
                                 Eagiaeering (DWSE) realized that it could not effectively continue tc
                                 operate its; program without a  commensurate; increase in resources,
                                 By building cpafitions with associations and organizations concerned
                                 about drinking water, they were able to convince the administration
                                 and legislature of their need
                                     The BW$1 has teemed '£"one year budget increase  of nearly
                                 SoXXJtQOO which provide* an aM&oual 19 FTEs, 17 of which are
                                 designated  to tie technical and two clerical positions.   This 40%
                                 increase In staff is  expected to  strengthen the  State's capacity
                                           in the areas of enforcement and technical assistance foi
                                              non-community  systems  and small community water
                                 systems*
                             Contractor assistance available to States

                               Because it considers State  Capacity as the most important initiative of
                             Mobilization strategy, EPA's Office of Drinking  Water is making availal
                             to State  programs the services  of a  variety  of contractors and natioi
                             associations.  These contractors and organizations can assist States in th
                             efforts to implement AFMs to meet their programs' increasing needs.
                               Securing the services of a contractor is contingent upon a State progran
                             willingness to devote some of its resources to  the funding effort as pan
                             an overall Mobilization program.
                               Contractors can help  a  State program develop  an AFM proposal and c
                             ensure that the proposal is presented to key decisionmakers.  For example,  i
                             National Conference of State Legislatures can share its expertise in worki
                             with both the legislative and executive  branches.  Another example of
                                                8

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contractor assistance is  in the development of an AFM proposal for a
State drinking water program; an EPA-retained contractor can provide
the following assistance:

o      project program  revenue  needs associated  with  the SDWA
       requirements;

o      develop a clear and effective visual presentation of the need for
       an AFM  (for presentation  to industry and/or legislative groups);

o      use flexible computer models to develop revenue projections for
       a number of fee  alternatives; and

o      calculate  the annual cost of different fee alternatives to individual
       systems and consumers.

       The contractor continues to build a body of research about the fee
mechanisms considered  or implemented in  other States, drawing on the
experiences  of  both  successful  and unsuccessful proposals.   It  has
developed computer spreadsheet models  that can be readily adapted to
meet state-specific  situations ~  predicting  program  revenue  needs,
evaluating and setting fees, and accurately predicting revenue collections.
       By drawing on its research, models,  and program management
expertise, a contractor can assist States in proposing an AFM that is fair,
politically acceptable, and successful in meeting the needs of the primacy
agency.
       States that are interested in receiving contractor assistance with
their  State  Capacity initiatives  should  contact  their  regional EPA
Mobilization Coordinator, listed in the resource directory in Section  IV.

Designing a  comprehensive Mobilization Program

       Ideally,   each  State's Mobilization  Program   would  include
aggressive programs in  each  of the six initiative areas:  state capacity,
institutional support, local health officials, technology and training, non-
transient non-community systems, and public  education.  But financial
and  staff restraints  limit the development  and implementation of such
comprehensive programs.  Indeed, aU six of the Mobilization Initiatives
may not be desireable  or feasible for a  particular State  drinking water
program.   It is  important  to   remember that  the purpose  of  any
Mobilization Program is that the  State maximizes the  effectiveness of its
external relationships, drawing on the expertise and assistance of many
different organizations.
       Not all Mobilization programs  and efforts require large financial
resources; with strong coalitions  and  support  from other organizations,
States  can  go a  long way  towards  compliance with the new SDWA
requirements.
By  drawing  on  its  research,
models, and program management
expertise, a contractor can assist
States  in proposing an AFM that
is fair, politically acceptable, and
successful in meeting the needs of
the primacy agency.
The purpose of any Mobilization
Program   is   that   the   State
maximizes the effectiveness of its
external relationships, drawing on
the expertise  and assistance  of
many different organizations.

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The   absolute    minimum
Mobilization component of any
State  drinking  water program
should be an advisory committee
which   includes    individuals
whose day-to-day responsibilities
involve direct contact with water
systems at the local level.
The  time spent in  organizing
and  building a  committee and
the effort expended to maintain
these coalitions is one of the
greatest investments a  drinking
water program  can make.
This section of the blueprint details each of the six Mobilization initial
areas and the program alternatives within each that States can underu
Successful initiatives are highlighted in an effort to spark the imaginai
of primacy agency staff in other States and to serve as a catalyst for
development of similar programs in Region I.

Establishing an advisory committee

      The absolute  minimum Mobilization  component  of  any  S
drinking  water program should be  an advisory committee which inclu
individuals whose day-to-day  responsibilities involve direct contact  v
water systems  at  the local level.
      An advisory  committee  can be a  valuable  resource for progi
development, providing guidance in numerous areas, pooling the resoui
and expertise of diverse constituents, and serving as a clearinghouse
information and assistance efforts.   Specifically, an advisory committee
provide the following assistance to a primacy  agency:

o     assess a State  program's needs and resources;

o     evaluate options with an eye to resources and ability to meet spe
      needs within the State;

o     help determine which options are realistic and feasible;

o     build support for  increased resources and program activities ami
      the public,  industry representatives, and State and local governrn

o     help establish a Technical Assistance network among drinking w;
      organizations  and agencies;

o     establish mechanisms  for measuring and evaluating programs;

o     provide  feedback  on State programs  from systems and users.
                                      The time  spent in organizing and  building a  committee and
                                effort expended to  maintain  these coalitions  is  one  of the grea
                                investments  a drinking water  program can  make.  The commitment
                                drinking water program staff resources  is crucial  to  the success of
                                effort  All  of the Mobilization  efforts  outlined below  can benefit fi
                                input from a drinking water advisory committee.
                                                10

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State Capacity

       As discussed in the first section of this report, nearly every State
drinking water program has an  immediate need for increased funding;
consequently,   increasing   State  program  capacity  is  ODW's  top
Mobilization priority.
       Most  of the  New  England  States already have  expressed  an
interest in increasing  their State capacity to implement the SDWA
amendments  and  retain  primacy.   New  Hampshire's  Water Supply
Engineering Bureau  already  has gained a 50 percent increase  in  its
drinking water program staff through its Permit to  Operate fee program.

Institutional  Support

       Because small systems account for the vast majority of MCL and
M/R  violations  and because  the SDWA establishes,  as its  primary
objective, the  elimination  of  these  violations,  State  drinking  water
programs should make  special efforts to ensure small system viability.
       The "viability"  of a system refers  to  its ability  to consistently
meet  the requirements  of the SDWA amendments.  "Non-viable"  refers
to a system with technical, financial,  or managerial weaknesses that may
render jt incapable of complying with drinking water regulations.
       Small  systems account  for 93 percent of MCL violations and 94
percent of M/R violations.4   The barriers that small  systems face in
complying with the regulations include:

o      lack of financial capacity, including access to capital and other
       financing mechanisms needed to update aging and/or inadequate
       infrastructure;
o      lack of technical knowledge of State and federal requirements and
       how to meet them;
o      lack of information on  sources of assistance;
p      lack of economies of scale, leading to a high per-customer cost
       of operation;
o      lack of affordable technologies to comply with existing and new
       regulations.

       It is  important  to stress  at the outset that no  one program or
regulation will resolve  the compliance challenges faced by small public
water systems.  An integrated and comprehensive set of  policies - one
which provides not only sanctions but also incentives —  is necessary if
a State program is to continue to guarantee a continuous and adequate
supply of safe drinking water for all its residents.
       State programs  can  motivate  and assist small  communities  and
systems  to meet  the  new  standards  through a  variety of  activities
including: training, education, information,  management,  and financial
assistance.  Drinking water programs and their advisory committees
Because small  systems  account
for the vast majority of MCL and
M/R violations  ana because the
SDWA establishes, as its primary
objective, the elimination of these
violations, State drinking  water
programs  should make special
efforts  to  ensure  small  system
viability.
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Given the tremendous resources
that  will be needed by small
systems to comply with the 1986
SDWA   amendments,   it   is
imperative that State programs
consider  systematic  reviews of
the financial,  technical,   ana
managerial strength of proposed
new public water systems.
should consider the  following  initiatives  in designing their  Institutio
Support efforts:

1.    Develop  and  articulate a  policy  which  recognizes  the spec
      challenges faced by small systems.

      In a recent study of existing small systems, EPA recommends tl
States develop a policy statement acknowledging the  extra needs of sm
systems.3  Although this is a position that a drinking water agency, w
the input of its  advisory committee, must  develop  itself in  order
maintain consistency  with its remaining policies, a sample statement mij
read:

      Recognizing the special needs  and challenges faced by  small wa
      systems in meeting the regulations of the Safe  Drinking Water A
      The Agency's policies will focus on the  prevention of small syst
      failure in order to  guarantee the  continuous  provision of s
      drinking water to all people  of State.  The Agency will implem
      procedures and programs to prevent the  proliferation of new sm
      underfinanced  systems  and to  assist  existing  systems  maim
      compliance.

2.    Strengthen the approval process for new public water systems
      ensure that proposed systems can meet the operational, financi
      and  managerial standards necessary  for system viability a
      compliance with SDWA requirements.

      States should investigate efforts to ensure the viability of new, sir
water systems.  The  permitting process provides an  ideal mechanism
the review of  a potential system's  viability  and capacity to  meet  i
SDWA  regulations.  If a  State program does not have  a procedure
review or certify systems, it should consider implementing one.
      A State  that  has  a  permit  approval  process should  consii
expanding and strengthening its procedures to encourage alternatives to
creation of new systems when feasible and to require review of a propo:
system's financial, technical, and operational capacity.
      A recent  review of five State drinking water programs revealed t
all either review or have  plans to review proposed  small  water syste
through their permitting processes and use these requirements  to place
burden of proof of viability on the  proposed  systems.6  In effect, th<
States have adopted the principle  that water systems are similar to ot
public  services  (like  electric  or natural gas companies or  hospitals) t
must demonstrate a need before creating new infrastructure.
      In addition, a  State program  should consider alternatives  to
creation  of new systems.   For example, interconnection  to or satel
management  by an existing  viable system (when feasible)  could be u:
to decrease the  total number of new systems created,  thereby reducing
                                                12

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likelihood that such a system would become non-compliant
       Although definitions of feasibility vary, several States encourage
or require proposed systems to interconnect with existing systems when
feasible.  Connecticut's small system permitting process, one of the most
rigorous in the country, is intended to  "restrict the proliferation of new
small  water  systems."7   State  drinking  water regulations require a
proposed  system to connect with an  existing  system if feasible.   If
interconnection is not feasible and if other operational and managerial
alternatives have been exhausted, then the system must prove that it has
the  technical  and  financial  capacity  to  remain  in compliance.
Connecticut's  permit  approval  process is  more  fully  described  in
Appendix  C.
       An additional benefit of limiting or reducing the number of small
systems is  the decreased  staff resources needed to  track  system
compliance.  This is particularly important given the budgetary restraints
of most State programs.
       Given the tremendous resources that will be needed by small
systems to comply with the 1986 SDWA amendments, it is imperative
that  State programs  consider   systematic reviews  of  the  financial,
technical, and managerial strength of proposed new public  water systems.
Appendix  D contains a discussion of the role of the permitting process
as a mechanism for system  review, including the criteria available  to
determine  viability.

3.     Increase the State's ability to assist systems in their compliance
       efforts  through  the encouragement of  restructuring  options
       such  as satellite  management,  contracting  arrangements, or
       mergers and acquisitions of small systems.

       Preventing the establishment of new potentially non-viable water
systems is only a  piece of  the overall solution to system viability.
Implementation of the SDWA amendments will exacerbate many of the
.problems  now facing  small  systems,  particularly  lack of  technical
knowledge and financial capacity and diseconomies of scale which lead
to higher per-unit costs.  As a result, more systems will face the risk of
becoming  noncompliant and threatening  public  health.
       A recently-published EPA study focuses on restructuring initiatives
that  States can implement to help systems,  particularly small  systems,
overcome  barriers to complying with SDWA regulations.'
       Appendix G contains a discussion of three restructuring options
that  can  be used to address the problems  of diseconomies of scale:
contract operations and management (O&M), cooperatives, and  mergers
and acquisitions.  The advantages and disadvantages  of each option are
explored  along with incentives that  State programs can implement  to
encourage systems to enter into these restructuring arrangements.
Small water systems can solve
some  of the diseconomies  of
scale that they face  by utilizing
restructuring  options  such  as
operations   ana  management
contracting, cooperatives, and
mergers ana acquisitions.
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Although mobile home parks
(MHPs) only make up about
3 percent of all small systems
in New England, they account
for 12 percent of the  total
number  of   small  system
violations.
4. Build  coalitions  with  organizations  representing   small   syste
  particularly mobile home park associations.

  Mobile  home  parks  and  homeowner  associations  are  a  key  focus
Mobilization  since  they  account for approximately  40 percent  of  si
systems nationwide.   These systems  are  often neglected by their ow
because water supply is not their principal business interest and because I
lack the technical and managerial skills needed to effectively operate a  w
system.  In fact,  owners often  do  not even realize that they are opera
public  water systems.
  Recognizing that New England MHPs have not been targeted for educat
training, and technical assistance by drinking water programs,  EPA  Regi<
has begun to work with the New England Manufactured Housing Associa
(NEMHA) to help  MHP owners  and operators  understand  and  main
compliance with SDWA requirements. For example, at the NEMHA ani
meeting in October  1990,  there will  be an EPA-sponsored  Safe  Drinl
Water  exhibit.   Staff members will be  available  to answer  questions
distribute materials on drinking water regulations and available  resources.
article  on SDWA requirements will  be  published  in  NEMHA's  quart
newsletter.
  State drinking water programs can  continue these efforts with their <
statewide MHP organizations.  Maine's drinking water program has develc
an excellent relationship with the Maine Manufactured Housing  Board (MF
the State regulatory agency for MHPs. Written into its licensing agreeme
the MHB requires parks to comply with drinking water regulations.  If a \
system is in violation  of the  requirements, the MHB can direct  then:
comply or face fines or, only  in an extreme case, the suspension  of t
license to operate.  If a system has had several  violations, the MHB
encourage the park owner to seek training or  technical assistance.

Pennsylvania Mobile Home Park  Cooperative

  In a project funded by  EPA and administered by  the AWWA, a coopera
was formed of ten mobile home parks in Berks County, Pennsylvania.
pilot project was designed to enhance  compliance of these  small  \v
systems with safe drinking water regulations.
  Cooperative members met monthly to  learn about regulatory requirem
and discuss various water supply topics. A circuit rider program was initi
to provide basic  water supply  operational  services.   Efforts  to establis
cooperative arrangement for the procurement  of water treatment and  O
services were not successful, possibly  because of an absence of  motivati<
factors and financial incentives.
  Successes of the  project  include the  certification  of two MHP sys
operators.  The Pennsylvania Manufactured Housing Association is  worl
with the  State to schedule a  training  session on certification for  2!
participants.
                                                14

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Local Health Officials

       Local health officials are in an excellent position to  help ensure
safe drinking water within their communities, particularly for  private well
owners.  In fact, many already are involved in some aspect of drinking
water protection. Activities range from technical assistance for household
well owners to inspections of  public water systems.
       Local health officials can include local boards of health, county
sanitarians, and other public  health professionals.   Each  New England
state organizes its health departments  in a different way:  For example,
Rhode  Island  has  a  State   health  department  but  no local health
departments, whereas Massachusetts local  health departments are linked
to its  town governments — over 350 of them.
       State drinking water  programs should consider  the  following
initiatives in designing  a  Mobilization Program component for Local
Health Officials:

1.     Initiate outreach programs to provide local health officials with
       a greater  awareness of the new  requirements and increased
       understanding  of  the  critical role  they  can  play in  the
       successful implementation  of  the SDWA.

       Outreach efforts can include one-to-one meetings with  statewide
health organizations to establish cooperative working relationships.  For
example, local health officials can help State programs get drinking water
material to private well owners  by distributing informational pamphlets
at the time of  well inspections.
       Association newsletters  are excellent vehicles for informing health
officials of contaminant health  effects,  applicable regulatory requirements,
treatment  technology, and source  protection with  special emphasis  on
private wells.  A sample article, published in the National Environmental
Health Association's newsletter,  can be found in Appendix L.
       State programs can contact Beth Hall,  the EPA leader for the
Local Health Officials initiative, who has numerous articles available and
can "custom design" others for publication in  specific newsletters.   See
Appendix M for more information.

2.     Encourage  and  help  local health  officials in their efforts to
       assist household well owners in providing information on safe
       drinking water, providing advice  about household treatment
       devices, and educating well owners and the community about
       groundwater protection.

       Private  wells serving individual households are not subject to the
federal drinking water requirements, and in most cases, regulation occurs
only at the local level.   Local  health officials can assist private well
owners by answering questions and conducting educational programs
Local health officials  are  in an
excellent position to help ensure
safe drinking  water within their
communities,   particularly   for
private well owners.
                                                  15

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A recent study  in Pennsylvania
showed that 90 percent of small
systems can comply with  the
new   stringent   performance
requirements if they have  the
technical    and    managerial
expertise  needed  to  optimize
operational practices and install
monitoring devices.
to address  the health risks associated with drinking water contamina
These professionals can also provide technical assistance to household \
owners  with  respect to  water  sampling and analysis,  including
interpretation of laboratory results.

3.    Provide public information materials on the SDWA regulatii
      to local health officials to use in educating public water syst
      consumers about the importance of safe drinking water.

      Local health officials can play  a  critical role in their communi
by answering consumers' questions about the importance and impact of
SDWA  regulations and the public health significance of drinking  w:
contamination.  Local health officials could help generate support, ami
both the general public  and state legislators, for increased drinking  w
program resources.  State drinking water programs should work with k
health   officials   and   their   professional  organizations  to  distrit
informational pamphlets and brochures.

Technology and Training

      Because most  small systems do not have the technical capabili
to implement the extensive monitoring and treatment technologies  requ
by the 1986 amendments,  training and technical assistance (TA) progr;
will  be  needed for water system operators and  managers.  A recent st
in Pennsylvania  showed that 90 percent of small systems  can comply \
the new stringent performance requirements if they have the technical
managerial expertise needed to optimize operational practices and ins
monitoring devices.

1.    At a minimum,  States  should develop a  resource directory
      technical and financial assistance and training programs avails
      throughout the State.

      An  advisory  committee  could assist  with  the  identification
resources, including the development of a questionnaire to State, regio
and  federal assistance programs.  Massachusetts' drinking water  prog
is conducting such a survey as  part of a planned Technical Assists
Network, using  the questionnaire shown in Appendix  N.
      A resource directory can range from a simple list of phone  numl
of organizations providing technical assistance to a more comprehen
and  elaborate  publication listing detailing information  about  avail;
programs.  An excellent example of a resource  directory is Pennsylvar
guide,  A Water Utility's  Guide to Financial  and Technical Assistz
Programs,  shown in  Appendix  O.
                                                16

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       In addition to a resource directory, State programs should consider
the following initiatives in  designing  their Technology and  Training
Support efforts:

2.     Drawing on  the coalition building efforts  with the drinking
       water advisory  committee, develop a comprehensive  training
       program.

       The Office of Drinking Water has developed  a National  Training
Strategy  that identifies and targets the highest priority  training  needs of
State  drinking water program staff,  system operators,  and local health
officials.  Workshops or seminars on sampling  techniques or reporting
requirements can be productive if system  operators  are  able to attend.
However, small  system operators often work part-time or live  far from
the workshop location; as  a  result,  those systems  that  most  need
assistance are unable to get it.
       Studies demonstrate that personal contact or hands-on assistance,
rather  than  dissemination  of information through  the  mail,  is  most
effective in  helping  small systems  achieve compliance.   Two  New
England states, Maine and Rhode Island, provide one-to-one assistance to
small  systems.
       Maine's drinking water program provides a  yearly grant to  the
Maine Rural Water Association (MRWA) to provide  technical assistance
to systems.  If a system is  in violation,  the State automatically alerts  the
MRWA at the same time that  it notifies the  system operator.   As a
result,  the MRWA  circuit rider contacts the system with an  offer of
assistance to help correct the violation.  The MRWA's non-regulatory
status serves as  a buffer between the system and the  primacy  agency;
operators are often  more forthcoming  about their difficulties  with  the
circuit riders because they do not fear enforcement measures or penalties.
Vermont's primacy agency has established a similar relationship with  the
Northeast Rural  Water Association.
       In Rhode Island  state sanitarians collect nearly all required  water
samples,   visiting   every  small  water  system  at  least  quarterly.
Consequently, sanitarians are familiar with each  system and manager and
are available for consultation as needed.   Rhode Island Department of
Health officials have found this to be "an effective form of outreach that
has displaced the need for a formal technical  assistance  program  for
small  water  systems.1"

3.     Establish a technical assistance network or program, such as
       an Adopt-A-System program.

       "Adopt-A-System" programs, which link small systems with larger
utilities, are relatively low-cost  initiatives that  States can encourage to
assist   small  systems.   California's  Alameda   County  Water  District
(ACWD), which recently founded such a program, compiled a list of its
Studies demonstrate that personal
contact  or hands-on assistance.
rather  than  dissemination  of
information through the  mail, is
most  effective  in  helping  small
systems achieve  compliance.
                                                  17

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services and areas of expertise available to small systems within a 50-
100-mile radius.  Circuit riders from  the  Rural  Water Association <
Rural Community Assistance Corporation distribute the list and prbgr
information.  Small  systems can contact engineers and technicians direc
through this information clearinghouse on topics such as backflow devic
sampling  and  testing,  corrosion  control  and  leak detection.    M<
information on  the ACWD program can be found in Appendix P.
      The Massachusetts Department of Environmental Protection (DI
plans to launch a similar pilot program  in its western region.   DEP
considering  a  more formal  and  structured program than  the one
California.   Rather than simply publishing a  directory  of the "pare
system's personnel  and  their area of expertise,  DEP  envisions
development of a closer relationship between a utility and several (perh
5 or 6) small systems.
      An Adopt-A-System program can benefit the parent system as v
as the  small systems receiving assistance:

o     Corporate goodwill and public relations are boosted by participat
      in such an initiative.   Articles  in  local newspapers featuring
      parent  system  providing  assistance  to  small  systems  not  o
      illustrates the company's goodwill and community spirit but also <
      serve as a mechanism for educating the public to the importance
      safe  drinking water.

o     Cooperative purchasing arrangements can be financially beneficia
      all parties. Because large systems have the ability  to purchase
      bulk at a lower per unit cost,  they could in turn sell some of tl
      materials  to the  smaller systems at  a price higher than their c
      (so they  make a profit) and  yet  still lower than the price  the sn
      system would be paying if it purchased the  item separately (so
      small system saves money).

o     A parent system  could contract some of its services to small syste
      on a fee  basis.   In the instance where a small system may  n
      assistance that is too costly or  time-consuming for the parent sysi
      to donate, the parties could develop a contractual relationship for
      provision of the  services.  The benefits of such an arrangement
      twofold:   the small system has its work performed by a known
      trusted contractor,  and the  parent  system  charges a  fee  for
       services.

       Before implementing an Adopt-A-System program, a State progra
legal department should review plans  to guard against possible liabi
problems.  Although ACWD has  not  experienced any such problem:
primacy agency might consider drafting  a standard agreement (such «
                 18

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Memorandum of Agreement), including an indemnification clause, to be
used by  participants  in  its program.  The  more an agency  facilitates
participation in such a  program, the more  successful  the initiative  is
likely to  be.
    PAY Technical Assistance Prop-am for Small Systems

       l?en»$yivania''$ Technical Assistance fctogram for Small Systems
    (TAPSS) was established In 1989  to *M small water systems
    comply with new SDWA ttqafoeaaefttt.  Another goal was to
    achieve a  corresponding redacttoa in violations and  improve
    operation and maintenance practices in thtte specific  areas of
    operation: ffltratkja,disinfeqdoa»andcoowiona»^oU Technical
    assistance is provided tfaroogh contracts with private consultants
    experiences in water supply treatment attd systems operations,
       Since  t98£  the Division of 'Water  Sujppl&s  ha*  Greeted
    $750.000 in State and federal monies to the oa-site training of 360
    small water systems.  Watt J&raer, of the $£*»*» Department of
    Environmental  Resoarces,  credits  TAPSS^s  success  to  the
    program's efforts  to remove the barriers to training,  "to take
    training to tfcfc ojxstRtors* door step «*d  iwodc one*o«-eRW with.
    them/       •                             '•    '
The largest barrier to compliance
that  owners  and  operators  of
NTNCWS face may  be that they
are not even aware of the SOW A
regulations  or that  they  must
comply with them.
Non-Transient Non-Community Systems

       Non-transient  non-community  water  systems (NTNCWS),  those
serving the same 25 or more people for at least six months per year, are
to a large extent a newly regulated group of public water systems.  Prior
to the 1986 SDWA amendments, the regulatory requirements for these
systems,  usually schools and businesses, were scant.  However, since the
.focus of the new requirements is on protection from the long-term health
effects of contaminants,  Congress  decided  that the  same  type  of
protection afforded  to users of community water systems  would  be
extended  to NTNCWS users.   Studies  have shown  that most people
consume nearly as much water at school or work as they do at home.
       The vast majority, more than 92 percent, of NTNCWS are very
small systems  serving fewer than 500 people.  Consequently, they face
the same  barriers  to compliance discussed  in  the section on the
Institutional Support Initiative — diseconomies of scale and lack of
technical, financial, and managerial resources.
       The largest  barrier  to compliance that owners and operators of
NTNCWS  face may be that they are not  even  aware of the  SDWA
regulations or that they must comply with them. Therefore, States must
undertake efforts  to increase  awareness  among  NTNCWS  of the
regulations and to facilitate compliance with them.
                                                 19

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Outreach  to NTNCWS  should
include not only  information
about   the    regulatory
requirements but also training,
technical or financial assistance
programs, and other options to
facilitate compliance.
      The most effective way for States to inform these systems of t
responsibilities under  the  SDWA is through established coalitions
organizations such  as  State Principals  Associations and  Chambers
Commerce.
      Unlike the general  public, which must  be  educated about  :
drinking  water, NTNCWS must comply with  the  regulations. In m
instances, compliance with the regulations will include the installation
operation of certain treatment technologies;  in  fact, about  84 perceni
NTNCWS will need to treat.  Therefore, outreach efforts should  incl
not only  information about the regulatory requirements  but also train
technical or financial assistance programs, and other options to facili
compliance (e.g.  certified operator contracting, cooperative purchasing
merger with a municipal system).
      State  programs   should   consider the   following  initiatives
establishing  their efforts to assist NTNCWS:

1.    Establish  informational outreach efforts for NTNCWS thro
      the numerous vehicles provided by organizations reaching tl
      systems.

      States can get information on drinking water regulatory requirem
and options  for compliance to NTNCWS using similar mechanisms as
Public Education Initiative described in  the following section.  The
step in  any of these initiatives is contacting an organization  wl
membership includes  significant  numbers of  NTNCWS to establis
cooperative  relationship; all it takes  is an initial telephone  call.  Spei
actions might include:

o    writing  articles  to  be  published in  trade  journals,  associa
      newsletters, or general mailings to members  (see Appendix M
      a list of generic articles  available  from EPA);

o    giving  speeches  at  membership meetings or  conferences
      associations  whose  membership  includes significant  number:
      NTNCWS;

o    setting up exhibits and distributing public information materia
      trade  shows or  conferences.

2.    Encourage capable NTNCWSs, such as large factories or sc
      districts, to establish training or technical assistance  progr
      for their personnel or for smaller systems.

      A "Big Brother" assistance program or network for NTNCWSs
be modelled on the  Adopt-A-System  programs used  by public  v
systems.  Such efforts are being considered in other parts of the  cou
For example, the Chemical Manufacturers Association,  the Grocery
                                                20

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Manufacturers of America, and the National School Boards Association
are  considering  establishment  of  a  "help  network"  of  industry
professionals to assist  schools  that  have their  own  water supplies.
During the past year, EPA worked with DuPont on the company's efforts
to offer a comprehensive 2 day SDWA training program for their facility
personnel.

Public Education

       Public  confidence, understanding,  and support  of safe  drinking
water regulations and the increased costs needed to ensure compliance is
critical to the  success of any drinking water program.   Indeed, it could
be argued  that,  without the support of a well-informed public, neither
regulators  nor  public  water systems will  be able to accomplish  the
mission of the  1986 SDWA amendments.
       State drinking water programs should work  with  their  advisory
committees to informs citizens, especially those  in  small communities,
about the SDWA requirements, the regulatory process, and the need to
support higher  water  rates or bond issuances to pay for this increased
protection.   "Public" should  be  defined  broadly to  include not only
private citizens  but also  local public officials,  business groups,  civic
organizations, and teachers.
       States should take advantage  of every available opportunity  to
educate the public.  Mechanisms for outreach are numerous and need not
consume a large portion of a drinking  water program's budget. Programs
should pursue  available free and low-cost media  such  as press  releases,
radio talk shows, public service announcements, and newsletters. Below
is  a list of specific  opportunities  and resources for  public education
efforts; it is by no means exhaustive  or comprehensive.

o      The  Safe Drinking  Water  Hotline  is a toll-free, nationwide
       information service for public water systems, local health officials,
       and the  general public.  Operators  can answer  a wide range  of
       drinking  water  questions;  for  example, How do I know if my
       town water is safe?  Do I need a filter for my kitchen tap?  How
       do I get my water tested?

o      Program  staff  and  advisory  committee members can  make
       speeches and slide  shows to  civic and business organizations and
       other interested parties  about the  importance  of  safe  drinking
       water.

o      Public opinion  leaders  (e.g.  local  elected officials  or  industry
       leaders)  should be encouraged to write op-ed pieces  supporting
      increased resources for drinking water programs  for publication in
       local newspapers.
Public   confidence,
understanding,  and support of
safe drinking water regulations
and the increased costs needed
to ensure compliance is critical
to the  success of any  drinking
water program.
                                                  21

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o Articles on SDWA can be published in agency or association newslett
  to keep staff and members informed about regulatory requirements.  £
  has  published several  generic  newsletter  articles that are available
  distribution to any State programs.  See  Appendix M  for a list of arti
  titles.

o Booths or exhibits at community events such as county fairs can be u:
  to disseminate informational materials such as pamphlets or brochures.
  travelling exhibit is available from the  Regional EPA Office.

o Alaska and New Hampshire are examples of states that have developed i
  sheets  which deliver information  on safe drinking  water in simple, n
  technical language. See Appendix Q for samples.

o The Office of Drinking Water has publications ranging from brochures
  one-page fact sheets on numerous topics related to safe drinking water.
  Appendix M for a list  of  titles and contact information for ordering.

  With the services  of an EPA contractor, a pilot project is  being launc
in  Region I  to  build  an  effective  and  comprehensive  public  educai
program.  Efforts  will include the building of coalitions with organizati
such as AWWA, National Rural Water  Association,  Cooperative  Extens
Services, League of Women Voters, and various civic associations.
                   22

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Mobilization action plan for Region I     (9/90 - 3/92)

       This action plan includes recommendations for both EPA's Water
Supply Section and State drinking  water programs  in Region I.

1.     Provide State  programs with regular  updates  on Mobilization
       Program activities  in  other States,  including examples  of  both
       successful and unsuccessful efforts  and individual contacts.

2.     Encourage and assist State primacy agencies to establish advisory
       committees  to develop statewide mobilization strategies, with a
       principal focus on  building  consensus on the need for increased
       revenues for drinking water programs.

3.     Provide support as  needed to at least three state primacy agencies
       in  their  efforts  to increase program  resources.    Facilitate
       relationship with EPA contractor.  Assist in developing a case and
       strategy for obtaining increased program revenues.

4.     Follow-up  by EPA State coordinators with State  program staff,
       including Mobilization coordinators,  after Small Systems Viability
       Conference  in  Scottsdale, AZ in  September, sharing  information
       and publications   and  encouraging contact  with  other  State
       programs.

5.     Brief Regional Administrator and Deputy Regional  Administrator
       quarterly on Mobilization activities and seek their active support
       and assistance.  Specific areas of assistance  can include  inclusion
       of  Mobilization Program activities in speeches and presentations
       and commitments to attend and speak at Regional SDWA forums
       and conferences.

6.     Develop talking points  on SDWA amendments and Mobilization
       Program activities  for  drinking  water program  staff,  Regional
       Administrator,  and Deputy Regional Administrator to include in
       all  speeches  or presentations to water industry-related groups.

7.     Conduct quarterly  meetings  of EPA and State  Mobilization
       Coordinators to facilitate sharing of information  and resources
       and to develop regional strategies  for reaching and improving
       compliance  with SDWA requirements.

8.     Meet  with  executive  director of  New England  Manufactured
       Housing Association in preparation for the organization's annual
       meeting (October 4 - 5 in Portsmouth, NH) and to discuss  how
       NEMHA can take an active role in regional mobilization activities.
                                                  23

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9.    Contact State manufactured  housing associations  and regulat
      boards to establish cooperative efforts in Mobilization Progr;
      throughout the region.  Follow-up activities should include:
      o      Publication of articles  on responsibilities of mobile  he
             parks  under SDWA regulatory  requirements  in  newsier
             of  State associations.
      o      Attendance at  associations'  annual meetings  with  SD\
             exhibit and distribution of SDWA informational material

10.   Pursue mechanisms to improve mobile home park compliance ir
      least two  states.   Possible avenues  include establishment of a p
      cooperative  similar  to  that   in Pennsylvania  and  strengthen
      licensing  requirements to include  compliance  with safe  drink
      water regulations.

11.   Work  with  at least  three states  to develop  a technical  am
      financial assistance resource directory  to  be  distributed to sysi
      owners and operators.

12.   Continue  to  provide  support, including  legislative  contra<
      assistance  if needed,   to   the   Massachusetts  Department
      Environmental Protection  in  its efforts to develop a  strategy
      improve small system viability.

13.   Work with local  health organizations in at least three states
      example,  county   sanitarians   in  Massachusetts) to  develop
      distribute  public   information  materials  on  SDWA  regulatic
      particularly to private well owners.

14.   Work  with   state  primacy agencies  and  other  water  indu
      associations  to increase attendence  at  informational forums
      conferences, particularly by small system owners and operators.

15.   Co-sponsor   conferences  such  as  Connecticut's   workshop
      September, "Safe Drinking Water:   Meeting the Challenge  of
      90s."  Provide speakers,  information,  publications,  and follow
      assistance as needed

16.   Begin   one-to-one   meetings   with  State  program  staff
      organizations representing regulated systems such as  State Princ
      Associations,  State chapters   of the League  of Women  Vot
      Chambers of Commerce to discuss Mobilization Program activii
      For  list of  organizations  to  contact, see the  EPA "Summary
      National Organizations' Activities  in support of the Mobiliza
      Strategy"  in  Appendix  R.  A list  of  the  state affiliates of tl
      organizations is being prepared by EPA and will be forwarded to
      Regional office.
                24

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Resource Directory
       Below is a list of drinking  water officials from the States and
organizations mentioned in this  report.   They  are most helpful and
willing  to share information on  their experiences and ideas  to  assist
public water systems reach and maintain  compliance with the SDWA
regulations.

                  Mobilization Initiative Leaders
Mobilization Manager
Peter E. Shanaghan
Office  of Drinking Water
State Programs Division
US EPA -- WH 550E, ET 1045
401  M Street
Washington, DC   20460
(202) 382-5813

State Capacity Initiative
James Bourne
Office  of Drinking Water
US EPA -- WH 550B, ET 1045
401  M Street
Washington, DC   20460
(202) 382-5557

Institutional Support Initiative
Jane Ephremides
Office of Drinking Water
US EPA - WH 550B, ET 1017A
401  M Street
Washington, DA   20460
(202) 382-5513

Local Health Officials Initiative
Beth Hall
Office of Drinking Water
US EPA - WH 550E, 1001A
401 M  Street
Washington, DC   20460
(202) 382-5553
Technology and Training Support
Initiative

Training Support:
Judy Lebowich
Office of Drinking Water
US EPA - WH 550E,
401 M Street
Washington, DC  20460
(202) 382-7593

Small Systems Technology:
David Schnare
Office of Drinking Water
US EPA -- WH 550B
401 M Street
Washington, DC  20460
(202) 382-5541

Non-Transient   Non-Community
Systems  Initiative
Jeff Hass
Drinking   Water/Ground    Water
Protection Branch
US EPA ~ Region m
841 Chestnut Street
Philadelphia, PA  19107
(215) 597-9873

Public Education Initiative
Charlene Shaw
Office of Drinking Water
US EPA - WH 550A, ET 1013B
401 M Street
Washington, DC  20460
(202)  382-2285
                                                25

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           Region I Mobilization Coordinators

EPA Region I                    New Hampshire
Al Wong
Water Supply Branch
US EPA -- Region I
JFK Federal Bldg, WSS 2113
Boston, MA 02203
(617) 565-3608

Connecticut

Cliff McClellan, Jr.
Water Supplies Section
Dept. of Health Services
150 Washington Street
Hartford, CT 06106
(203) 566-1253

Maine

Jeff Jenks
Drinking Water Program
Dept. of Human Services
State House Station 10
Augusta, ME 04333
(207) 289-5685

Massachusetts

George A. Zoto
Division of Water Supply
Dept. of Environmental Protection
One Winter Street, 9th floor
Boston, MA  02108
(617) 292-5966
Bernard Lucey
Water Supply Engineering Boan
Dept of Environmental Services
P.O. Box 95, Hazen Drive
Concord, NH 03301
(603) 271-3139
Rhode Island

June Swallow
Division of Drinking Water Qua.
Dept. of Health
75 Davis Street
Providence, RI  02908
(401) 277-6867

Vermont

Winslow Ladue
Division of Environmental  Heal
Dept. of Health
60 Main  Street
Burlington, VT 05401
(802) 863-7230
               26

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                         Program Contacts in Other States

ACWD's  Adopt-A-Small-System   Maryland's bonding and escrow
Program                         requirements for new systems
John Marchand
Alameda County Water District
P.O. Box 5110
43885 South Grimmer Boulevard
Fremont, CA  94537
(415) 659-1970, x522

California's  Memorandum   of
Understanding with PUC

Cliff Sharpe
Office of Drinking Water
Dept. of Health Services
714 P Street, Room 692
Sacramento, CA 95814
(916) 323-1381

Connecticut's   financial
requirements for system approval

Richard Albani
Dept. of Public Utilities Control
One  Central Park Plaza
New Britain, CT  06051
(203) 827-1553
Barry O'Brien
Water Supply Program
Dept. of the Environment
2500  Broening Highway,  Room
1122
Baltimore, MD  21224
(301) 631-3706

Shantini Senanayake
Water Supply Program
Dept. of the Environment
2500 Broening Highway
Baltimore, MD 21224
(301) 631-3712

Pennsylvania's   small  systems
program and TAPSS

Steve Schmidt
Division of Water Supplies
Dept. of Environmental Resources
P.O. Box 2357
Harrisburg, PA  17105
(717) 787-0122

Washington's  financial  review
process for operating permits

Rick Sieffert
Dept. of Social and Health Service
(206) 753-4299
                                              27

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Assistance Programs and Trade Associations
        Rural  Communities  Assistance
        Program

        John McCarthy
        218 Central Street, Box 425
        Winchendon, MA  01475
        (508) 297-1376

        Maine Rural Water Association
        84 Maine Street, Suite A
        Brunswick, ME  04011
        (207) 729-6569
        Northeast   Rural
        Association
        512 St. George Road
        Williston, VT  05495
        (802) 878-3276
Water
NJ,  CT  &   RI  Rural  Wa
Association
Branford Hill  Plaza
One Summit Place, suite 204V
Branford, CT   06405
(203) 483-4645

Maine   Manufactured  Hous
Board
David Preble, executive directoi
State House Station 35
Augusta, ME   04333
(207) 582-8723, x2312

New    England   Manufactu
Housing Association
Jim Ayotte, executive director
15 Midstate Drive, suite 212
Auburn, MA   01501
(508) 832-0642
                       28

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                                      Endnotes
1. State Costs of Implementing the 1986 Safe Drinking Water Act Amendments, a joint report
by the Association of State Drinking Water Administrators and US Environmental Protection
Agency, August 1989.

2.  "Virginia Addresses the Question of Primacy" in Meeting the Challenge: An Update on
ODW's Mobilization Effort, published by the  USEPA Office of Drinking Water, May 1990.

3. "The Impact of the Safe Drinking Water Act Amendments of  1986 on the Commonwealth
of Virginia," Report of the Department of Health to the Governor and the General Assembly
of Virginia, House document no.  30, Richmond,  1990.

4. FRDS  07 and FRDS 19A, FY 1987.

5. Improving the  viability of existing small drinking water systems. EPA 570/9-90-004, June
1990.

6.  Programs studied were Connecticut, Georgia, Maryland, Washington, and Pennsylvania.
Programs in the first four states  were  compared in "Ensuring the Viability of New, Small
Drinking  Water Systems  - A Study  of  State Programs,"  published by  EPA's  Office of
Drinking Water, April 1989.

7. Final regulations  for application procedures and criteria for issuing Certificates of Public
Convenience  and  Necessity for small  water companies. Connecticut Department  of Public
Utility Control,  September, 1987.

8. Much of this section is excerpted or summarized from this study, Improving the viability
of existing small drinking water systems. EPA 570/9-90-004, June  1990.

9.  "Technical Assistance  to Small Water Systems" description, written by the Rhode Island
Division of  Drinking  Water Quality and included  in  the  "1990 State Program Resource
Compilation" by ASDWA and AWWA.
                                          29

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                                                  Appendix A
   Pennsylvania Small Water Systems Committee
Dr. Charles Abdulla
Department of Agriculture, Economics 
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    Pennsylvania Small Water Systems CommiUee
Ms. Judy Carlson
Public Utility Commission
Office of Special Assistants
Room 115 - North Office Bldg.
P.O. Box 3265
Harrisburg, PA  17120
Dr. Beverly Cigler
Pennsylvania State University - Capitol Campus
Division of Public Affairs
Rt. 230
Middletown, PA  17057
Mr. Charles Covage
PA State Association of Boroughs
2941 North Front Street
Harrisburg, PA  17110
Ms. Jean W. Eason
Vice President/Treasurer
Eastern Gas ic Water Investment Co.
681 Moore Road
King of Prussia, PA  19406
Mr. Tom Fidler
DER
Division of State Water Plan
3600 Vartan  Way
P.O. Box 1467
Harrisburg, PA 17120
Mr. Richard Fox
Executive Director
Joint Air and Water Pollution Control
   and Conservation Committee
Box 254 Main Capitol
Harrisburg, PA  17120
Mr. David Hess
Executive Director
Senate Env. Resources and
   Energy Committee
Room 172 Main Capitol
Harrisburg, PA  17120

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                                                  Appendix
         /Ivania Small Water Systems Committee
Mr. Donald Holbrook
Water Works Operators Assn of PA
PA American Water Co.
4349 Carlisle Pike
Camp Hill, PA 17011
Mr. Dale R. Kratzer
Vice President
PSC Environmental Services
649 North Lewis Road
Limerick, PA 19464
Mr. Mark Leevan
PENNVEST
4th Floor - Keystone Building
22 South Third Street
P.O. Box  1344
Harrisburg, PA  17105
Dr. David Long
Professor of Civil Engineering
212 Sackett Building
PA State University
University Park, PA 16802
Mr. Thomas May
Vice President
BCM Engineers
1 Plymouth Meeting Mall
Plymouth Meeting,  PA 19462
Mr. Victor Miller
Department of Community Affairs
Bureau of Local Government Services
Municipal Consulting Services Division
Room 533, Forum Building
Harrisburg, PA  17120
Mr. James R. Moore
Executive Vice President
PA Manufactured Housing Assn.
P.O. Box 248
New Cumberland, PA 17070
Mr. Jerry Pillus
Pottsville DER Office
107 Brook Lane
New Philadelphia, PA  17959

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   Pennsylvania Small Water Systems Committee
Mr. Herb Pizer
Program Manager
PA Rural Water Association
Saitsburg Plaza
P.O. Box 90
Saitsburg,  PA 15681
Mr. Van Dyke Polhemus
Vice President
Greeley-Polhemus Group, Inc.
105 South High Street
West Chester, PA 19382
Mr. Ron Rams
Minority Exec-  ;e Director
Senate Environmental Resources
   and Energy Committee
Room 458  Main Capitol
Harrisburg, PA 17120
Mr. Scott Rubin
Water Coordinator
Office of Consumer Advocate
Office of Attorney General
Room 1425, Strawberry Square
Harrisburg, PA  17120
Mr. J. Stephen Schmidt
Division of Water Supplies
PA DER
P.O. Box 2357
Harrisburg, PA  17105
Mr. Robert Slatick
DER
State Board for Certification
6th Floor, Fulton Building
P.O. Box 2063
Harrisburg, PA  17120
Mr. Lawrence Stepenuck
Water Resources Specialist
Rural Water Resources, Inc.
218 Central Street
Winchendon, MA 01475

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                                                   AoDer.uix A
   Pennsylvania Small Water Systems Committee
Ms. Edith Stevens
PA League of Women Voters
R.D. #1
Cresco, PA 18326
Mr. Frederick R. Taylor
Esquire
House Conservation Committee
Room 21-C Capitol Annex
Harrisburg, PA  17120
 Mr. William Thomas
Executive Director
House Conservation Committee
Room 38E, East Wing Main Capitol
Harrisburg, PA  17120
John Williams, P.E., Community Programs
U.S. Farmers Home Administration
Suite 330
One Credit Union Place
Harrisburg, PA  17110-2996
Ms. Patti K. Wisniewski
U.S. Environmental Protection Agency
Drinking Water Section (3WM41)
814 Chestnut Building
Philadelphia, PA  19107
Mr. Robert M. Wolfel
AWWA Small Systems Committee
St. Marys Area Joint Water
479 Wolfel Avenue
St. Marys, PA 15857
Mr. Bill Woll
Executive Director
PA Municipal Authorities Assn.
2941 North Front Street
Harrisburg, PA  17110

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                                                            April 24,


                                AGENDA

              PENNSYLVANIA SMALL WATER SYSTEMS COMMITTEE


 1.  Introduction of new attendees

 2.  Minutes of January 23, 1990 meeting

 3.  Progress: extension of TAPSS; mobile home park cooperative

 4.  PENNVEST program activities

 5.  Public meetings of PA Comprehensive Water Supply Policy Plan

 6.  Lessons learned from TAPSS (Jack Ashton,  ACMSC)

 7.  Future enforcement by DER (Tom Sabatino,  DER)

 8.  Viability of New and Existing Systems (Steering  Committee)

 9.  Donation of water meters (Allen & Pizer)

10.  Input of legislative staff

11.  Report of Rate Subcommittee (Allen, Brogan,  Stan Brown,  Eason)
        - Status of H.B. 24 and 25

12.  Regulation issues:
        - Status of lead ban, Lead Contamination  Control Act,
             State Plumbing Code

13.  Education issues:
        - Improving resources for operator training
        - Reports from recent conferences and  seminars

14.  Certification issues:
        - Committee to improve small system certification (Slatick)
        - Use of national test for small systems  operators

15.  PUC initiatives (Carol Allen)

16.  Other agency/organization activities for  small water systems

17.  Other business

18.  Next meeting - Wednesday, July 18,  1990,  same  location;
     items of concern requested for agenda

19.  Ad j ournment

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                                                                 Appendix B

      Alternative Funding Mechanisms:  advantages and disadvantages

      Whatever funding mechanism(s)  it selects  and  works  to  implement,  an advisory
committee should aim for a package that provides enough revenue to  cover the full  cost of
the State's drinking water program.  A single fee-for-service will not  be sufficient to cover
a State program's  increased costs under the  new regulations.  Because legislatures  are not
receptive to programs that return every year with requests for additional funding, a State can
best use its resources by aiming high and making a strong case for a comprehensive funding
package.
      Every  government revenue source,  whether  used  for on-going operations or capital
projects, whether raised through debt or  on a current basis, has eight criteria to measure its
effectiveness and efficiency.1   No funding source  will meet all these measures fully,  but the
more measures  addressed in  a revenue source, the better it is  and more likely it is to be
supported and approved.

1.     EQUITY reflects the fairness of  the  distribution of the funding  burden  among
      individuals.  In environmental programs, equity can be approached from two directions
      — those  who create or contribute  to environmental problems should bear the  funding
      burden (the  "polluter"  pays) or those who benefit  from program activities should bear
      the funding  burden (the "beneficiary" pays).

2.     LEGISLATIVE ACCEPTABILITY reflects the political attractiveness of a financing
      mechanism.   There are  unique legislative predispositions in each State that often
      influence the  choice of  a  financing mechanism.   Establishing dedicated funds for
      drinking  water programs  may be  perceived favorably by the public but  not by State
      legislatures.   Designating fees  or  charges for specific programs creates  a direct link
      between  payment and the provision of services ~ in this case, the continuous provision
      of safe drinking  water.  However, legislatures may resist dedicating revenues because
      it decreases their flexibility in appropriating funds.

3.     PUBLIC ACCEPTABILITY reflects  the willingness of those subject  to a fee or tax
      to pay or the willingness of the public to make a particular sector pay.

4.     FEASIBILITY relates to the  legal authority to  impose a fee or  tax as well as to
      factors that  affect the  workability  of a financing mechanism.

5.     REVENUE POTENTIAL is measured by the amount of money that can be raised with
      a particular  financing mechanism and whether a mechanism provides a one-time or a
      continuing source of revenues.

6.     FLEXIBILITY  reflects  the ability  to  use revenues  from  alternative financing
      mechanisms as needed for a variety of program activities.

7.     ADMINISTRATIVE  REQUIREMENTS relate to the effort needed to implement an
      alternative financing mechanism, including start-up costs  and on-going collection  and
      management of funds.

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8.      IMPACTS relate to whether a financing mechanism creates incentives for desirable (or
       possibly undesirable) behavior and whether it places  an undue financial burden on
       industry or general taxpayers.

       The principal AFMs discussed for drinking water programs are fees,  dedicated taxes
or user charges, and fines and penalties. A recent survey conducted by the National Governor's
Association of AFM use in State environmental programs reported that 63 percent of the 431
active AFM programs were fees.2  The survey also found that fines and penalties and taxes
accounted for  16 percent and 9 percent of the total number of AFM programs, respectively.
Of the $3 billion in AFM revenues collected during the period  studied, 1988-89, 15 percent
came from taxes and 8 percent from fees; an  additional 39 percent came from bond proceeds.3

A.     Service Fees

       Fees provide a direct link between the demand for a service and the costs of providing
it. A well-structured fee, where there is a clear relationship between the demand for services
and the cost of providing them, is  the most equitable means of  matching program costs with
those responsible for or  those benefiting from program  activities.   In addition, there is  a
growing acceptance among both legislatures and the public of the concept of "fee for service"
in the provision of  public services.
       Examples of drinking water  fees include fees to conduct sanitary surveys, to review and
certify construction  plans, and to conduct laboratory analyses  of samples.
       Fees can be either fixed, where all parties pay the same amount, or variable, where the
fee is based on a rate schedule based on differences in the cost  of providing the service.  An
example of a variable fee is a  construction review fee based on the number of connections or
total cost  of the project.
       An example of a service fee used as an AFM is New Hampshire's recent Permit to
Operate Fee that will be used to  fund the  drinking water program and  maintain primacy,
allowing the primacy agency  to increase its program staff by 50 percent.   Under the fee
structure,  community systems  pay  a fixed operating permit fee of $600 per year, except that
no home  will pay  in excess  of $10  per year, this cap  avoids  undue financial burdens on
households connected to small  community systems.  Non-transient non-community systems pay
a  flat fee  of $200 annually.
       Although they can, and should, be structured to cover the full cost of providing a
service (including collection), the  drawback to fees is that  they  generally  do  not provide
adequate revenues to cover the full costs faced by a drinking  water program.  Historically,
States  and municipalities have  been reluctant to set fees high enough to recover program costs
and  have  charged only a nominal  amount for services.  Therefore, a comprehensive funding
package for increased revenues should include other  AFMs in addition to  fees.

B.    User Fees

       Historically  used most  frequently by  sewer and water utilities, user fees are structured
so that only those  who use a good or service bear its cost.  If they  are applied to a broad
base, user fees even at a low rate can generate sufficient revenues to pay for general operating
and  maintenance costs.
       The political atmosphere had a mixed effect  on the use of fees.   Some States have
opposed them because they arc considered to be "taxes in disguise," or because they felt that

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AFMs would have a negative effect on their economies.  In other States, fees have been seen
as a way to get the user of a service to pay for it.
       One of the key issues in any type of user fee is that of equity.  Because of their larger
customer base, large utilities would bear the brunt of a user fee program and so would be less
likely to support one.  In designing the fee structure, it is important that larger utilities are not
completely subsidizing smaller systems.  One idea is  a cap  on the  total amount that a large
system can be charged — as a result, their per person rates are lower than the smaller systems
even though the total amount of money generated by the fee is larger than for smaller  systems.

C.     Fines and Penalties

       Because  they are imposed for violations  of regulations,  fines and penalties do not
provide a steady stream  of revenue for drinking water programs.   However, States can
generally exercise considerable discretion in the use of these revenues.  In addition, fines are
based  on  the principle  that "the polluter  pays" and consequently, enjoy  both public and
legislative acceptability.      While States  should not  rely on  fines or  penalties as  a major
funding source  of program activities, a primacy  agency should periodically reevaluate its
penalty levels to determine if they provide water systems with  the  appropriate incentives.
1.  These measures are taken from a draft copy of "Drinking Water Mobilization Coordinators'
Handbook," published by the Office of Drinking Water, September 1989.

2.   Funding Environmental Programs: An Examination  of Alternatives,  published  by the
National Governor's Association, 1989.

3.  Much of the material on AFMS in the  following sections was excerpted from Paying for
Safe Water: Alternative Financing Mechanisms for State Drinking Water Programs, published
by EPA's Office of Drinking Water, May  1990.

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       STATE  OF  CONNECTICUT
          DEPARTMENT OF PUBLIC UTILITY CONTROL
                                                      Appendix C
       DEPARTMENT OF PUBLIC UTILITY CONTROL REGULATIONS
                             FOR
APPLICATION PROCEDURES  AND CRITERIA TOR ISSUING CERTIFICATES OF
               PUBLIC CONOTENCE AND NECESSITY
                             FOR
                     SMALL HATHl COMPANIES
                      FINAL REGULATIONS
                 EITECTIVE SEPTEMBER  28,1987
      One Central Park Piaza  •  New Britain, Connecticut 06051
                 An Equal Opportunity Employtr

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       The  Regulations 01
 Sections 16-262n»-l to 16-262n>-9, inclusive, as follows:

 Section 16-262m-l.   Definitions

 (a)  "Connunity Water  System"  or "System", as used  herein,  shall mean a system
 which  supplies to the public piped water for human  consumption,  if  such system
 has  at least  fifteen  and no more than two hundred fifty service connections or
 regularly serves an  average of  twenty-five  to one  thousand persons  daily at
 least  sixty  days out of the year,  when such water  is supplied as  part  of a
 lease  or contract.  A community water system includes  but  is not  limited to,
 (1)  any collection,  treatment,  storage,  and  distribution facilities  under
 control of an operator  of such  system and used  primarily in  connection  with
 such system,  and (2) any collection  or  pre-treatment storage  facilities not
 under  such control  which are used  primarily in  connection with  such system.
 Community  water   systems may  include,  but  are not  limited  to  service  to:
 residential sub-divisions,  cluster-housing projects,  homeowners associations,
municipalities,   tax  districts,  duplexes, townhouses,  apartment  buildings or
 complexes,  residential  and office  condominium  developments,  elderly housing
 projects,  convalescent homes,  trailer or mobile home  parks,  industrial paries,
 shopping centers or malls,  large manufacturing buildings and other commercial
 enterprises.

 (b) "Feasible Interconnections", as  used herein,  shall mean  that the extension
of  an  existing  utility's  water  mains  is  considered  feasible  to  serve  a
proposed project  with  at least  fifteen  service   connections   or  twenty-five
persons if  the  developer's  investment for  such extension,  including service
connections and  appurtenances,  is  less than,  $5,000)(construction  costs  only)
per  dwelling  or  office  unit  and  if there Yr—sufficient supply  and storage
facilities  to accommodate the  anticipated demand available from  the  existing
utility.   If  there  is  insufficient  supply and  storage  available  from the
existing utility, the cost  of  developing such facilities  may   be  included in
the water main extension proposal, as additional  items.

 (c) "Duplication of Water Facilities" as used herein,  shall mean  that  plant
and  equipment  of  a  community  water system which the  Department of  Public
Utility Control  determines  is  substantially  repetitive  to  the  plant   and
equipment   of  another  water  purveyor  or community  water  system within  one
linear  mile  of   the  proposed  project, as  measured along public  or  private
roadways.   Geological factors such  as elevation  differences, slope of the  land
and  depth   to bedrock   will   be  considered  in determining  duplication  of
facilities.

 (d) "Expansion",  as used herein,  shall mean the  following:  (l)a  five percent
increase in  the  number  of  service  connections  to be  served  by  a  community
water system, above  the  number allowed under an existing  certificate  or permit
issued  by  the  Department  of  Public Utility Control  and  the  Department  of
Health  Services*  or  (2)a five  percent  increase  in   the  number  of  service
connections to be  served by a  community water system above  the number served
as of the  effective  date of  these regulations.

 (e) "Phase I-A,  Phase I-B and Phase  II",  as  used herein, shall mean the three
parts  of   the application  and  review  procedure   for  the  construction  or
expansion of  any  community water system.

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      Phase  I-A  grants  the developer approval of his well sites and permission
 to obtain the well  drilling  permits from the appropriate  town  to proceed with
 groundwater  exploration  and development  of such wells.   The  issuance of this
 approval  means  that  the  Department  of  Public   Utility   Control  and  the
 Department  of  Health  Services have  determined  that a  main extension  to  an
 existing system  is  not  feasible (for  new water  systems  only)  and  that  there
 will  be no  duplication  of service  of other existing  water utilities  in  the
 area  when  the  project  is finished.   Phase  I-B evaluates  the  well yield  and
 water  quality  data  so  that  proper  pump  sizing, storage  and  appurtenant
 equipment and  any  required  treatment  processes  can be incorporated  into  the
 design  of  the  water system.   This approval permits  the developer  to  obtain
 building permits from the town to clear the site, lay out  the  roads, construct
 the  drainage  facilities and  dig   or  pour  the  foundations  of   the  buildings
 themselves.  Phase  II Approval,  the final  Certificate, permits  the developer
 to  go forward with the  remainder  of  the project,  i.e.  installing  the  water
 distribution system and  waterworks (storage  tanks, transfer  pumps,  meters,
 etc.) and  the  septic or sewer systems  (assuming   appropriate approvals have
already  been  obtained  from  the   Department  of  Health  Services  or  local
Directors of Health or  Department  of Environmental  Protection) for  the  septic
or sewer systems and the diversion  of water.

 (f) "Service Connection",  as  used  herein, means the service pipe  from the main
 to the curb stop, at or adjacent to the street line  or  the  customer's  property
 line.

 (g) "Customer", as  used  herein,  means  any person,  firm,  corporation,  company,
association, governmental unit, lessee  who  by the  terms  of  a written lease is
responsible for the  water bill,  or owner of  property furnished  water service
by a water company.

 (h) "Existing System", as used herein, shall mean  a regulated public service
or municipal  utility or regional  water authority  having an operating  water
system within one linear mile of the proposed project as measured along  public
and private roadways.

 (i) "Satellite  system"  as used  herein, shall mean a  non-connected community
water system of an exiating system.

 (j) "Regulated  Public Service Utility",  aa used herein,  shall  mean  a  water
company, as  defined in  Section  16-1 of  the  General Statutes of Connecticut,
 that is  under the jurisdiction of  the Department  of  Public Utility Control.

Section 16-262m-2.   Chronolottcal  Application Procedures

      The following procedures for applying  for and issuing certificates  of
 public  convenience  and  necessity  shall  be followed  by  any applicant  for  a
 certificate of  public convenience  and. necessity  in accordance  with General
 Statutes  of Connecticut Section  16-262m,  and by the  Department  of  Public
 Utility Control,  the  Department of Health Services, and any other participant
 in the proceeding on such an application:

 (a)   The Department  of  Public Utility Control  nay conduct a  pre-application
      conference with any potential applicant.

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(b)   (1)  The applicant  shall  submit  three  (3)  originals of  the  application
      for approval under  Phase  I-A,  Phase I-B, or Phase  II  to  the  Department
      of  Public   Utility  Control's   Engineering   Division   in   the   format
      prescribed by the Department of Public  Utility  Control.

      (2)  An application  fee  of  $100.00  shall  be  enclosed  with the  initial
      application when  it is submitted  to the  Department.    Checks  shall  be
      made payable  to  the Treasurer  of the  State of Connecticut.  Payment  of
      only one   (1)  fee  shall  be   required   per application,   even  if   the
      application  is  submitted  in   separate  phases.    An   applicant whose
      application is rejected or denied will be required  to pay a separate  fee
      for any application subsequently  resubaitted.   An applicant may elect  to
      submit   Phase  I-A,  Phase  I-B  and  Phase   II  data  of   the  application
      simultaneously, but  each Phase  will be  reviewed separately.

(c)   The Department of Public  Utility Control will forward  one copy  of  the
      application for approval under  Phase I-A,  Phase I-B and Phase  II to  the
      Department  of  Health  Services,  notifying   it   that   processing  and
      reviewing   should begin.    The  Department  of Health   Services   should
      conduct well site inspections  upon  receiving notice from the  Department
      of Public  Utility Control  that the Application  is considered complete
      and an  interconnection  has been found not to be feasible.

(d)   The Department of Public Utility  Control shall review each phase  of  the
      application preliminarily  for  completeness  and either  accept or  reject
      the application,   or specify  the additional information required.  The
      Department of  Public  Utility  Control  shall  notify,  in  writing,  any
      applicant  and  the  Department  of  Health Services  of  the Department  of
      Public  Utility Control's decision to  accept  or  reject the application  or
      to require  additional  information.  Upon  completion of  review of each
      phase of an application, the Department  of  Health Services  shall  forward
      its approval or  denial in  writing  to   the  Department  of Public  Utility
      Control.

(e)   (1) The Department  of Public  Utility Control and the  Department   of
      Health   Services   shall   simultaneously  review  each   phase   of  the
      application on its merits,  and  either recommend approving  or denying the
      application's request.

      (2) The  Department  of  Public  Utility Control and the  Department   of
      Health  Services may consult with each  other and with  the applicant  to
      modify  the application prior to  such approval or denial,  providing all
      modification* are confirmed  and submitted in writing by  the  applicant.

(f)   Upon the   joint   approval   of   any  phase   of   the   application  by  the
      Department  of  Public  Utility  Control  and the  Department  of   Health
      Services,  the Department of Public Utility  Control  shall issue a  letter
      of approval for that phase of  the project.

(g)   Upon the   joint   agreement  between  the Department  of  Public  Utility
      Control and  the  Department  of  Health  Services* the  two ag«aci«s shall
      issue   the  Certificate pursuant  to General   Statutes of  Connecticut
      Section 16-262m.    If  either  Department finds reason  for denial  of  a
      Certificate,  no Certificate  shall be  issued.

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 Ch)    Any  applicant issued  a certificate under  Phase  II  shall submit one  (1)
       copy  of as-built plans, certified  by  a professional engineer  registered
       in  the State  of Connecticut, each, to the Department of Public Utility
       Control,  to  the  Department of  Health Services,  to the specified owner  of
       the  water system,  and  to  the  town  in which  the   project  is located.
       These  as-built plans  shall  be  submitted  to  the respective  parties  no
       later  than ninety (90) days  from the completion of the construction.

 (i)    The Department of Public  Utility  Control  and the  Department  of  Health
       Services  shall complete its review of  each  phase of the application  in
       accordance with  the schedule set forth  below:

       (1)  Phase I-A reviews- shall be completed  within sixty  (60) days of  the
       Applicant filing  the  information specified in Section  16-262m-5 herein,
       with the Department of Public Utility Control;
       (2) Phase I-B  reviews  shall  be completed within  thirty  (30) days  of  the
       Applicant filing the information specified in Section 16-262m-6 herein,
       with the Department, of Public Utility Control;
       (3) Phase  II  reviews  Shall  be  completed  within sixty  (60) days  of  the
       Applicant  filing  the  information specified,  in   Sections   16-262n-7,
       16-262m-8 and  16-2620-9 (if  applicable) herein, with  the Department  of
       Public Utility Control;.
       (4) If  the Applicant  elects  to  submit  Phase  I-A, Phase  I-B and Phase  II
       data  of the  application  simultaneously,  each  phase will  be reviewed
       separately as indicated in paragraphs 1, 2 and 3 above.

Section 16-262m-3.    Application and Approval of Three-Phase Construction

(a)   The application  for  a new  system or for an expansion of  an existing
system which  involves  a'new water  source shall  be -submitted  and  reviewed  in
three phases, as Phase  I-A, Phase I-B and Phase II.  The same chronology and
procedures  established iriv Section  16-262m-2 •hall  be followed  sequentially
first  for  Phase  I-A  and  subsequently  for   Phase  I-B and Phase  II.  It  is
recognized that some applications for expansion may not require a  Phase  I-A or
Phase  I-B review.   In such cases only a Phase II application shall be required.

(b)    (1) The application-for Phase I-A, shall  identify   items  including,  but
      not limited  to,  the  following:   (A) The  feasibility of interconnection
       to an existing system; (B) the location and:proposed construction  of  any
      source  of  supply;  (C) the  possible  duplication of  service  and  water
      facilities caused by. the  installation of *h*'proposed system; (D)  the
      name  of an  existing regulated  or municipal water  utility  or regional
      water  authority  which  will   own,  operate  .-and   maintain  the   final
      constructed  water  supply   facilities   if  ttwy . are  to  remain  as  a
      non-connected satellite system;             '
                                                 *«r  ' '*
       (2) The  Department  of  Public  Utility Control  and  the Department  of
      Health Services  shall  determine the  issues In subparagraphs   (b)(l)(A),
       (b)(l)(B), (b)(L)(C), and (b)(l)(D) in this subsection;

       (3) If the Department of Public Utility Control.and  Department  of  Health
      Services  jointly  determine   that   the  applicant  meets  the  criteria
       reviewed  under  subdivisions  (1)  and  (2)   of  this   subsection,   the
      Department of  Public Utility  Control  snail frant approval  of  the Phase

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      I-A  application,  in  writing  to  allow  the  applicant  to  construct  the
      source  of  supply  proposed  in  the application.   The  applicant  shall
      proceed  to  construct  the  source  of   supply  in  conformance  with  the
      application and any  conditions set by  the Department of  Public  Utility
      Control and  Department of  Health  Services in  the approval.   Applicants
      proposing withdrawals  in  excess  of 50,000 gallons of  water from  one  or
      more wells joined  in a system where combined maximum withdrawal  exceeds
      50,000 gallons of water during any twenty-four  hour  period must  confer
      with the Department  of Environmental Protection to determine appropriate
      water diversion permit requirements under Section 22a-365  of  the  General
      Statutes of Connecticut;

      (A) Approval under Phase  I-A shall not  in and  of  itself  guarantee  the
      later issuance of  a certificate of  public convenience  and necessity.

(c)   (1) The application  for  Phase I-B shall  identify  items  including,  but
      not limited to, the  following:
           (A) well yield  data  for each  well,  based on a  suitable yield  test
           performed by a  qualified well yield tester in  accordance with  the
           criteria  set  forth   in  section   16-262m-8   herein  and   Section
           19-13-B5KK)  of  the Regulations of Connecticut State Agencies; and

           (B) water quality data for each well as  specified by  the  Department
           of Health Services.

      (2) The  Department  of Public  Utility   Control  and  the  Department   of
      Health   Services  shall   jointly   evaluate  the  data  in  subparagraphs
      (c)(l)(A) and (c)(l)(B) in this subsection.

      (3) If  the Department  of  Public  Utility  Control  and Department of  Health
      Services determine that the applicant meets the criteria  reviewed under
      subparagraphs (c)(l)(A) and (c)(l)(B) of  this subsection,  the Department
      of  Public  Utility   Control shall grant  approval   of   the  Phase   I-B
      application,   in   writing   to  allow the  applicant  to  obtain  building
      permits to  perform the functions  specified in  section  16-262m-l(e).  The
      applicant   shall   proceed  with  construction  in conformance  with  the
      application and any conditions set  by  the Department  of  Public Utility
      Control and the Department of  Health Services in the  approval.  Approval
      under Phase I-B shall not in and of itself guarantee  the  Later issuance
      of a certificate of public convenience and  necessity for  the applicant.

(d)   (1) After receiving  approval to proceed  with  the various aspects of the
      project under  subsection  (c)  above,   an applicant shall  submit  an
      application under  Phase  II.  This  application  shall  demonstrate items
      including,  but  not limited to,  the  following:

           (A)  conformance  of  proposed  construction  with  the  Department  of
          Public  Utility   Control's  and  Department  of   Health  Services'
          engineering standards;

           (B) conformance  of proposed construction with all federal and state
          standards  on water supply;

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           (C)  the  financial,  managerial,  and  technical  resources  of  the
           applicant and ability to maintain adequate service.

      (2) The  Department of  Public  Utility Control  and Department  of  Health
      Services shall  jointly evaluate  the  issues  in  subparagraphs (d)(l)(A),
      (d)(l)(B) and (d)(l)(C) of this subsection.

      (3) If  the  Department  of  Public Utility Control and Department of Health
      Services  determine   that  the   application   meets   the  criteria   in
      subparagraphs  (d)(l)(A),  (d)(l)(B) and (d)(l)(C) of  this subsection the
      Department of  Public Utility  Control and  Department of  Health Services
      shall jointly  issue a  certificate of public convenience and necessity to
      the applicant.

      (4) The applicant  shall notify the Department of Public Utility Control,
      the Department of  Health  Services and the  specified  owner of  the  water
      sys'.em  when  the construction  of  the pumphouse,  distribution system and
      service lines  commence  so that a field inspection  can  be  scheduled to
      witness  the   installation  of  such  items  and  when  construction  is
      completed so  that a field  inspection can  be scheduled  to  inspect  the
      as-built facilities.

Section 16-262m-4.   Options When Main Extensions are not Feasible

(a)  In  the  event that the Department of Public Utility Control and Department
of Health Services determine  that a  main extension ia  not  feasible,  i.e. that
it is too  costly  to construct a main extension; and that no existing regulated
public service or municipal  utility  or regional water  authority is willing to
expand  or  own,  operate  and  maintain  the  final constructed water  supply
facilities as a non-connected satellite system,  the  applicant  may  pursue the
following options:

      (1)  If an  existing  regulated public  service  or  municipal utility  or
      regional water authority is willing  to provide  satellite ownership and
      management services,  but is unable to meet all the  criteria described in
      Sections  16-262m-8  and  16-262m-9  herein,  the  Department  of  Public
      Utility Control and the Department of Health  Services  may waive specific
      criteria  in writing,  if it is deemed  to be  in the  best  interest of the
      public affected.

      (2)  The applicant may withdraw the application  and  request  the town in
      which the project is to be constructed to determine  if  the town's zoning
      requirements   will  permit  individual  wells.    If   this  proposal  is
      acceptable  to the town,  the   developer  may change  the  configuration of
      the  project in  order  to  accommodate  individual  veils.   This  option is
      available  to  the applicant at  any  time  and  may  be  pursued  without
      obtaining a Certificate of Public. Convenience and Necessity.

      (3)  The  applicant  may   continue  forward  with   the   application  by
      sustaining  the burden  of  proof that the entity  that  will own the water
      system  has  the financial, managerial and  technical  resources to operate
      the  proposed water supply system  in a  reliable  and efficient manner and
      will  provide continuous,  adequate service  to the  proposed consumers to
      be served by the system.  The criteria  for meeting this  burden of proof
      is set  forth  in  Section 16-262m-9 of these  Regulations.

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      The above  options  must be  pursued in  Che  order presented,  i.e.  option
      three cannot be pursued until options one and two have been exhausted.

(b)   Any  party  who  is  aggrieved  such  that a  specific personal  and  legal
interest  of  said  party  has  been  specially and adversely  affected by  the
decision to approve,  reject or modify  the  application for  the issuance of  a
Certificate  may  request  a hearing  which  will   be  held  jointly before  the
Department  of  Public Utility  Control  and  the  Department of  Health  Services.
Such  appeal  will  be based  on  the  Administrative   record   compiled  by  the
Department  of  Public Utility  Control  and  the  Department  of   Health  Services
including such additional  relevant  evidence and testimony as  the  parties  may
submit.

(c)   If a  community  water  system,  as defined in  Section 16-262m-l(a) herein,
is  constructed  without  the required  Certificate  of  Public  Convenience  and
Necessity,  the  Department  of  Public  Utility Control  and  the Department  of
Health Services shall  notify the appropriate Town officials,  of  the Town  in
which  the  system  is located,  that such Town is  responsible for  the  future
operations of that  community water system, in accordance  with  Section  8-25a of
the General  Statutes  of Connecticut.

Section 16-262m-5.    Components of the Application Under Phase I-A

      Any application for Phase  I-A snail include, but not  be limited to,  the
following:

      (a) exact  legal  name,  address,  and   telephone  number of applicant  and
      name   and  title  of  contact  person;  in the  event   the  applicant  is  a
      corporation,  the  applicant  should  also provide  the names and  addresses
      of  the corporate officers;

      (b) name,  address,  telephone  number of proposed  registered  professional
      civil  engineer  who  will  have  design  and  supervision responsibility  for
      the construction of  the system;

      (c) a  check  for  $100.00  payable  to  the   Treasurer  of  the  State  of
      Connecticut;

      (d) engineering data  certified by a professional engineer registered in
      the State of  Connecticut  as  follows:

           (1)  At  a  minimum,  a  cite  plan   and  specifications for  any water
          sources  which  shall provide  for  adequate  well location,  adequate
          well construction procedure*, and proper sanitary easements for  the
          well*.   There  shall be at least  two wells  shown on the plan and  a
          reserve  site for  additional  wells, as needed.

           (2)  Plans  shoving the  relationship of  the  proposed water system to
          the  sanitary sewage and  storm drainage  facilities, and  indicating
          the  distances  from  the  proposed  wells;  wetlands and watercourses,
          observation wells;  contour  lines, customer  previses*  and  sanitary
          sewage,  storm drainage  and septic facilities;

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     (3) A minimum  8"  square location plan map showing  the  location and
     extent of service areas of  any existing  community  water system  or
     other water  purveyor within one  linear  mile of any portion  of the
     proposed system and  identifying all  adjacent  entities or  property
     owners;(use a  Scale  1"  • 2000').   The map should also  indicate any
     known  probable future  building  areas  (as   filed   with  the  Town
     Planning &  Zoning Coonission) which  might reasonably be served  by
     main extensions of the subject system;

     (4) An evaluation of the quantity of water necessary  to  provide an
     adequate supply  at  required  pressures  to existing  and  projected
     customers,  including probable future  building  areas,  during periods
     of  average  and  peak   demands   for  at  least   15  years   after
     construction;

     (5) Sanitary  survey  evaluation of  pollution  sources  (present  and
     past), such  as,  but not  limited to:  sanitary sewage,  cemeteries,
     landfills,  salt storage and commercial  and  industrial  facilities,
     which might affect the groundwater quality;

     (6) A description of the groundwater  quality  and  subsurface soils
     as  classified by  the  United  States Geological   Survey,  for  the
     project  area;

     (7) A plan for controlling  pollution sources which  might affect the
     wells;

     (8)  A   description   of  the  procedures,  methods,   schedule  and
     location, for  conducting required sampling,  testing and  reporting
     on yield testing and water quality;

     (9) A  topographical  map  showing  the relationship  and  location  of
     the proposed project to the  surrounding area;

     (10)  A  brief  description   of  the  water  system  project   and
     operational layout;

(e)  A  letter from  the   town  where the  project  is  located  indicating
whether or not  fire protection facilities arc required to be included in
the design of the water  system.   If fire  protection is  to be  required,
the letter from  the town should indicate the  number of hydrants  required
to serve  the project  as  well as  the  minimum  distance  allowed  between
hydrants;

(f)  letters  from  all  regulated  public  service  or  municipal  water
utilities or  regional  water  authorities  within one linear  mile  of the
applicant's project expressing willingness or unwillingness to  serve  as
water supplier  to the  applicant's  project.  If a water utility expressed
willingness  to  serve,  the  letter  submitted shall  include  the  proposed
manner  of  service and cost, via main extension  or satellite ownership.
The letter shall discuss the alternative of the water  utility  owning and
operating  the system  as  a  non-connected  satellite system.   The  letter

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      shall  also  include  the linear footage, size  of  pipe,  material, and cost
      of  a main  extension  including  service connections,  if  such extension
      were   required  to  be  constructed.   It  should  also   indicate  whether
      additional  supply,  storage  and  booster  facilities,  and their  related
      costs, are necessary for providing proper service;

      (g)  if  the  applicant's project is located  in an area where there  is  an
      adopted  coordinated plan,  in accordance with  Sections  25-33c  to 25-33j,
      inclusive,  of  the General  Statutes  of Connecticut,  the water  utility
      expressing  willingness  to serve  the applicant's project must do  so,  in
      conformance  with  the  established plan with  full   regard  to  exclusive
      service  areas and  satellite  ownership and management stipulations.  If a
      water  utility  coordinating  committee  has   been  convened   for  the
      appropriate  management   area,   but   does  not  yet   have   an  approved
      coordinated  plan,  the  applicant  should  furnish  a  letter  from  the
      committee indicating that the project is conceptually agreeable to  it.

Section 16-262m-6.   Components of the Application Under Phase I-B

      Any application for the  issuance of  a  certificate  of  public convenience
and  necessity  under  Phase   I-B  shall  include,  but  not  be   limited  to,  the
following:

      (a)  A copy of the well drillers completion report for each well;

      (b)  A copy  of  the yield  test  results for each well  indicating pumping
           rates,  certified  well yields and drawdown information;

      (c)  A copy  of the  water  quality  test  results  from samples  obtained
           during  the  yield  test;

      (d)  A signed agreement  between  the developer of  the  water  system and
           the existing  regulated  public service or municipal water  utility  or
           regional water   authority  indicating  that  the  final  constructed
           water supply  facilities will  be dedicated to that utility.   With  a
           regulated public  service  company such  agreement  will specify any
           refunds that  the developer may  be entitled  to  for  each  service
           connection  made to the  community water system.   The utility will  be
           expected to receive  from the developer an itemized breakdown  of the
           actual   costs  of  the  water  system  facilities  so  that  proper
           accountability and  rate-making   treatments  (if applicable)  can  be
           afforded to the utility by the Department of Public Utility Control.

      (e)  The requirements  of Section  16-262m-9 shall be addressed in  Phase
           I-B.

Section 16-262m-7.   Components  of  the Application Under  Phase II

      Engineering  data certified by  a professional engineer  registered  in the
State of Connecticut as  follows:

      (a)  Plans and  specifications  for the  project must include  but not  be
           limited  to:    transfer  pumps,  well   pumps  and   pump   curves,

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           hydropneumatic  tanks,  treatment  facilities,   distribution  system
           layout, atmospheric  storage facilities,  metering (each source  and
           customer), location of sample taps, on-site standby  power,  presence
           of emergency  alarms,  location  of pressure gauges, location  of  gate
           valves and  blow-offs,  water level  gauges on  storage  tank,  fire
           protection (if necessary), and  disinfection procedures;

      (b)  A hydraulic gradient of the proposed system;

      (c)  A  detail  of  a  typical  service  line,  service  connection,  thrust
           block installation,  hydrant installation, cross-section  of  trench
           containing pipe,  and a meter installation;
                          . ' .•
      (d)  A  plan and  profile  drawing  of  the  water  main  and all  other
           underground utilities  (sewer,  gas,  electric,   telephone  or  cable
           television);  .*•   •
                         *
      (e)  Name, address* telephone  number  and title of proposed operator with
           day-to-day responsibility for system.

Section 16-262m-8.    Design  Criteria

      All community  water  systems  proposed  for construction or expansion  in
accordance with  Section  16-262m  of  the General Statutes of  Connecticut shall
be  designed  substantially   in  accordance   with ' the   technical   standards
enumerated herein.                                  :...'

(a) For  the  purposes of -this Section  and  Sections. 16-262m-5,  16-262m-6  and
16-262m-7 inclusive,  the  following definitions shall apply:

      (1)  "Anticipated  Average Daily  Demand"  shall mean  the estimated normal
           water usage af the  system as determined for the  most representative
           24 hour period of  record not affected by unusual  demand conditions
           such  as drought.or  a significant  temporary increase in demand;

      (2)  "Peak Hour  Demand"  shall  swan  largest  hourly  volume   of  water
           consumed and shall  be considered  1/3 of the average daily demand;

      (3)  "Design Population" shall mean  the estimated number  of people  per
           service   connection,    calculated   as   fellows,   unless   specific
           circumstances  dictate otherwise:         '"•.'

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                                                     Design Population
Type of service                                          Per Service
                                                          Connection

     Single family dwelling                                  k
          (Over 3 bedrooms add 1 person
          per additional bedroom)
     Multi-dwelling (i.e. apartments, elderly
          housing, duplexes, tovnhouses and
          residential condominiums
          One bedroom unit                                  2
          Two bedroom unit                                  3
          Three bedroom unit                                4
          (over 3 bedrooms add 1 person per
          additional bedroom)
     Mobile Homes or Trailers                              2.5
     Convalescent Homes                              Use Number of beds
     All other components described in 16-262m-l(a)   Use Estimated
                                                      Population

(4)  "Safe Daily Yield  of  a Water Supply System" shall  mean  the  amount
     of water  which can be  delivered  to  the system from all  the  system
     sources at the safe yield  rate  simultaneously  in an 18  hour  period
     expressed in gallons per day;

(5)  "Safe  Yield  of  a  Well"  shall  be   calculated  as  follows:   (A)
     Unconsolidated aquifer ground water sources.  The  safe  yield shall
     be based  on  an  analysis  of  the impact  of  minimum  water  table
     elevations projected in a dry period  on the yield  of the
     well(s) and an analysis of critical impacts such as decreased
     stream flow  or induction of  pollutants.   (B)  Confined  and bedrock
     aquifer ground water sources.   Safe  yield shall  be equal to  90X of
     the hourly yield of  the well multiplied by 18 hours of  pumping per
     day except that the safe yield may be less  when utilization of  this
     yield will have unacceptable impacts or when historical  reports or
     other information  indicates  that  the  cafe  yield  is  less.   Hourly
     well  yield shall  be based on a  pump test during  which the cone of
     depression caused  by  the pumping  of the well  shall be  stabilized
     for at least  24 hours;

(6)  "Source" shall  mean  any Department of Health  Services  approved
     well, spring, reservoir  or  other location  where water is  siphoned,
     pumped, channeled  or drawn for use in a potable water supply;

(7)  "Source of  Pollution"  shall  mean any place  from which stems  or
     condition which may cause pollution  of a  ground  or surface water
     supply.  It  may  include but not be  restricted   to  a  watercourse
     including any stream,  pond*  lake or river;  privy; subsurface  sewage
     disposal  system;   cemeteries;  sanitary landfill;   sewage   lagoon;
     industrial  waste disposal location;  sanitary or  storm sewers; or  a
     buried oil  or gasoline  storage tank;

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      (8)  "Well Pump  Capacity"  shall mean  the  maximum quantity  of  water the
           well pump can supply  under normal operating  conditions.   The  pump
           capacity shall not exceed the  safe yield of  the  well;

      (9)  "Yield of a Well" shall mean the  amount  of ground water  which  can be
           withdrawn from a well as  determined, by the yield test.   The yield
           of a well is expressed as gallons per  minute (gpm);

      (10) "Service  Pipe",  as  used  herein  shall mean   the  pipe  that  runs
           between the  curb stop,  at  or adjacent  to  the  street  line or  the
           customer's property line, and  the customer's place  of consumption.

(b)   Facility location.  These  include  such items as, but  not  limited  to,
treatment plants,  pumping  stations, storage  tanks* etc.,  but  do not  include
water intakes and connecting pipelines.

      New  facilities are  to  be  located:   (1) Above the  level  of the  one
hundred year  flood and not within  the  floodway  boundary as  established  on
flood boundary  and  floodway  mapping  prepared  pursuant to  the federal  flood
insurance program;   (2) Where  chlorine gas  will  not be stored  or used  within
three hundred feet of  any  residence;  and (3) Where the  facility is not likely
to be subject to fires  or other natural or manmade  disasters.

(c)   The  following  equations  are  to  be  used  when  determining the  design
population and  water  demand  of  the   community  vater  system.   Where  unusual
circumstances exist,  the Department of  Public  Utility Control  and  Department
of Health Services will determine the  appropriateness of  these equations.

      (1) Design Population Served  •  number of service connections x number of
      people  per service;

      (2) Average Daily Demand » population served x 75  gallons per person per
      day;

      (3) Peak Hour Demand  » average daily demand x 1/3.

(d)   Water Supply requirements:

      (1)  Each  community   water  systen shall  be designed  to  furnish  and
      maintain sufficient  facilities  to provide   a  continuous  and  adequate
      supply  of  water; and there  shall be at  least  xa 151  margin  of  safety
      maintained between the system's  safe daily yield and anticipated average
      daily  demand.   Unless  other acceptable provisions  are  made  to  assure
      continuous service,  the community water system  should be able to  meet
      the anticipated  average daily demand  with it* largest well and/or  pump
      out of service;

      (2)  For a  system utilising  only  groundwater supplies,  a minimum  of  2
      well sources shall be provided;

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 (3)   All  wells  shall  be subjected to a  minimum  72-hour  yield test, by a
 qualified well yield  tester,  such  that at a constant  pumped discharge
 rate,  the drawdown level has  stabilized for at  least a 24-hour period.
 The  pump must  run continuously during  the  yield  test  for the entire  72
 hour  period  irregardless  of the  anticipated  well yield   The following
 items must  be recorded  and measured  during  the test:

      (A)  Static water level  before pumping;

      (B)  Date,  time, pump rate and drawdown  (at  least hourly);

      (C)  Time and  water levels after pump has been  shut down until well
     has  recovered;

      (D)  Each well shall have a drawdown curve  plotted  from the results
     of  the  yield  test,  with the tester's  established  safe daily yield
     at its  stabilized  drawdown certified and  printed thereon.  Suitable
     provisions  shall  be  made  in  cases  of wells  that  are  located  in
     close  proximity  to each  other and subject to  "interference."    In
     such cases a  simultaneous pumping of each well shall be required;

     (E)  Whenever possible, the pump test  shall be  performed during the
     summer  months and should  be conducted during  a time period absent
     of  precipitation  or  as  reasonably close  to non-precipitation   as
     possible;

     (F)  Suitable  provisions  including  data  from  observation  wells
     shall  be  made in cases of  wells  located  in  close  proximity  to
     wetlands, drainage ways,  or   watercourses in  order  to  quantify the
     effect  of  induced  recharge  on  flows in such wetlands, drainage ways
     or watercourses;

 (4)  All  wells,  especially deep  drilled  rock  wells,   are  subject   to
diminution  of  their  yields after  a  period of tine.    Therefore,  they
should  be  periodically  monitored  for  possible  loss  of  yield,  and
scheduled   for  an appropriate   maintenance  program   when  conditions
dictate.  When  new wells are  added  at a future date, especially  in the
vicinity  of  existing  wells,  suitable  Measures  shall  be  taken   to
ascertain potential loss of  yield fro*  the adjacent wells simultaneously
with the yield testing  of the new  wells;

 (5)  Reserve  well site property  is required  and aust  be shown on  the
final map;

 (6)  There  shall  be  a safe  yield  capacity sufficient  to  supply   75
gallons  per  person per  day  and at  least 151  additional  supply   to
maintain  an  adequate  margin  of  safety  and  be able to  accoonodate
adjacent growth in the  future.

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(e)   Source Protection:

      (1)  The following  minimum separating  distances  are required  by  Public
           Health Code Sections 19-13-B51 and 19-13-B103 (Technical Standards).

      Item                                          Minimum Distances*
                                         Under 10 gpm   10-50  gpm   Over  50 gpm

      (A)  Septic system,  buried              75'          150'         200'
           oil tanks or other
           sources of pollution
      (B)  Cast iron sewer pipe               25'           75'         100'
           or equivalent
      (C)  Surface water body                 25'           50'           50'
           or drain

      *Greater separating  distances are required for gravel wells  with pumping
      capacities  greater than  50  gpm where ledge is found at  less  than 10 feet
      and/or the  soil  percolation  rate  is faster  than 1  inch  per minute  at
      surrounding septic systems.

      (D)  Sanitary conditions within  the  radial separating distance  required
      shall  be  under  the  control  of   the  water  supply  owner  by   direct
      ownership,  easement, or  other arrangement  approved by the Department  of
      Health Services and  detailed on the as-built map.

(f)   Well Construction and Water Quality:

      (1)  Wells   shall  be constructed in accordance with Public Health  Code
           Regulation  19-13-B51  and  the  Regulations   of Connecticut   State
           Agencies   Sections   25-128-1    through    25-128-64,    inclusive
           (Regulations of the Well Drilling Industry);

      (2)  The bacterial«  physical, inorganic chemical,  organic chemical  and
           radiological quality of the source must satisfy  the requirements  of
           Public  Health  Code   Regulation   19-13-B102  and  the   Connecticut
           Department of Health Services action  levels  for organic  compounds.
           Suitable  treatment may  be  required  by  the  Department  of   Health
           Services;

      (3)  Each well  shall be equipped  with  a water level probe  for periodic
           drawdown  measurement;  and  there  shall  be  provided  suitable  low
           water   level well  pu*p  shut-off and lightning protection devices  in
           accordance  with  Section   19-13-B102(n)  of.  the   Regulations   of
           Connecticut State Agencies.

(g)   Atmospheric Storage  Tank:

      (1)  The atmospheric  storage tank  shall  be  equipped  with  a properly
      bolted entry hatch to allow access  for cleaning  and painting of the  tank
      and a  filler pipe  to  provide for water to be trucked in.  The  filler
      pipe must be capped  and  locked.  The  tank  shall also be equipped  with a
      sight glass  gauge,  a screened vent pipe and  a  high and low water level

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      signal  system.    There  shall  be  a drain  valve  at  the  bottom of  the
      accessible face of  the  tank.   Drain lines must discharge  to  the ground.
      No direct connection to a sanitary sewer will be permitted;

      (2)  Atmospheric storage tank capacity shall be at least 200  gallons  per
      residential customer or equal  to the average daily demand  of  the system,
      whichever is the  greater  number.   If commercial or industrial  customers
      are included,  additional  storage  shall  be provided based  on reasonable
      average day estimated water usage thereof;

      (3)  Hydropneumatic tank and transfer pumps:

           (A)  A hydropneumatic  tank  and transfer  pump arrangement, used  in
      tandem with the' atmospheric  tank,  shall be sized to accommodate the peak
      hour demand.   A minimum of  two  (2) transfer pumps shall be installed  to
      operate alternately,  each capable of  providing water  to  the  system  at
      the peak hour demand rate;  (B)  The transfer  pumps  shall be  installed
      between  the  atmospheric  tank  and  the  hydropneumatic tank;   (C)  The
      required  gross  volume  of  the  hydropneumatic  storage  tank  shall  be
      calculated using the following  equations:

           Usable Volume * 5 minutes  x largest transfer pump  capacity (gpm)

           Gross Volume  * 1001 x Usable Volume
                          X usable volume

      (D)   Transfer   pumps  shall  be  protected  by   low water  level  shutoff
      controls in the  storage  tank.

      (U) All waterworks  equipment  shall be  designed and  installed so  as  to
      assure safe and  easy access to  the equipment  for normal service and  for
      repairs or replacement work.

(h)    On-site Standby  Power:

      (1)  Wherever  possible, there  shall  be  included  on-site  a  permanently
      installed gasoline,  propane-fueled, diesel,  natural  gas  or  oil   fired
      generator capable  of supporting  at  least  the  largest well  pump, one
      transfer pump,  any  high   service  booster  stations  and  all  treatment
      systems simultaneously  in  the  event of  an electrical  outage.   Portable
      generators may  be considered acceptable  as an alternate  to  an on-site
      generator;

      (2)  Fuel storage  shall  be above  ground,  and provided  with a  containment
      area capable of  holding  the full  volume  of the  fuel tank.

(i)    Transmission and Distribution System:

      (1) The  transmission  pipelines,  (i.e.  that  pipe from the  source  of
      supply to  the  pumphouse or  treatment  facility or from the  source  of
      supply  to the  distribution system)  from  sources of  supply  shall  be
      designed to deliver, in combination  with  related storage facilities and
      to the  limits  of  the capacity  of those  sources of  supply,  the maximum
      requirements of  that portion of the  system  which is  dependent  upon such
      transmission pipelines;

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 (2)  The  distribution system  shall be  of adequate  size and  design to
maintain minimum nomal  operating pressures.   Minimum  distribution pipe
diameter shall be  6  inches except in cul-de-sacs where the mains are not
subject to being extended  or a* otherwise approved by  the Department of
Public  Utility  Control.    If  fire protection is  to be  provided, minimum
distribution  pipe  diameter shall  be  8  inches.  All  mains   shall  be
installed  in  the rights-of-way  of  paved  roadways  to allow  all weather
access and to facilitate repairs;

(3)  Normal operating pressures,  including peak demand conditions in the
distribution main  shall  be  between 35 psi and  125  psi  at  the service
connection;        ' .  '.--.
                      .•  •
(4)  Where  static  pressures  would  exceed 125   psi*  pressure  reducing
devices shall be provided on distribution mains;
                   *•  • •
(5)  Insofar as  practicable,  the distribution  system shall  be designed
so as  to avoid  dead  ends  in the mains.   Suitable  right-of-way easement
control shall  be .provided  to  the  proposed owner and  operator  and  his
assigns to  permit  future  such  extensions. Where a dead  end line is to
be used, an adequately,  sized blow-off shall be  installed at the  end of
the line;

(6)  Sufficient  isolation  valves shall  be provided  on  water  mains so
that inconvenience  to customers  and  sanitary hazards  will  be minimized
during  repairs  and  flushing.    At  intersections,   valves   shall   be
installed on all connecting mains;

(7)  Customer  Booster  Pumps:   No  community  water   system  shall   be
designed  to  furnish  water service  to  any customer  who  must  utilize  a
booster pump  to pump water  from  the  utility's water  main   into  the
customer's  plumbing -facilities  in order  to  maintain  a  minimum  35  psi
pressure service, except in extreme circumstances and when authorized by
the Department  of  Public  Utility Control..  The  system's gradient shall
be  designed   to  preclude  this   need  under   reasonable   foreseeable
conditions for  the ultimate service area.  Consideration shall be given
both to deteriorating pipe conditions leading  to increases  in pressure
losses  in the  maids  and  also  to  any potential hazard  which  might be
created if contamination should be introduced into the system through a
cross-connection when a negative pressure is induced  in the water main
by a customer's booster pump;                 '-.\
                                            • •  *•
(8)  Air  Relief  Valves:   At high  points  in water mains where  air  can
accumulate,  provisions   shall  be made  to .remove. the  air by  means  of
hydrants  or air relief  valves.  Suitable protection measures  shall be
included in the design to cover situation* where  flooding of  the manhole
or chamber may occur;            .          •   .

(9)  Air Relief  Valve Piping:   The open end of .an air relief  pipe from
automatic valves shall  be  extended to at  least;one  foot  above grade and
provided  with  a  screened,  downward-facing  elbow.   The  pipe  from  a
manually operated valve should be extended to the top of the pit;

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 (10)  Chamber  Drainage:   Chambers,  pita  or  manholes  containing valves,
 blow-offs, meters,  or  other such  appurtenances  to  a distribution system,
 shall  not be  connected  directly to any  sewer.   Such chambers  or pits
 shall be drained  to the surface of the ground where  they  are not subject
 to flooding by surface water, or  to absorption pits underground;

 (11) When  installing pipe,  care  must  be taken  to  keep  the  pipe clean.
 Trenches shall be kept as free of water as is possible;

 (12) When  laying of  pipe  is  interrupted overnight or  for any longer
 period  of  time,  the open end  of the pipe shall be  plugged tightly and
 the open trench covered with wood or steel covers;

 (13) Installation and  pressure testing  shall  incorporate the provisions
 of  the  American Water   Works  Association  Standards  and/corresponding
 installation procedures;

 (14) A  continuous and uniform  bedding shall be  provided in  the trench
 for all  buried  pipe.  Backfill material, free of detrimental substances,
 shall be used.   That backfill  material shall be tamped  in layers around
 the pipe and  to  a  sufficient height above the pipe to adequately support
and  protect  the  pipe.   During  pipe  laying,  stones,  boulders  and  any
other significantly detrimental materials found in  the  trench shall be
removed for a depth of at least six inches below the bottom of the pipe;

 (15) All pipe shall be provided with a minimum  earth cover  of 4.5 feet.
When rock blasting  is  necessary, ample excess depth shall  be provided to
allow for  a  suitable  depth of bedding material between  the pipe bottom
and the rock base.  Where frost can be expected to occur  deeper than 4.5
feet, additional  pipe  cover shall be provided to suit.  The mains should
have adequate cover over the  top of  the  pipe,  using  suitable backfill
material,  for  protection  against surface  loads.    For  river  or stream
crossings where the water main may be exposed to the  air,  the  water main
shall be protected against freezing by an alternate means;

(16) Whenever possible, water and sewer lines (sanitary and  storm)  shall
be located in separate trenches  at  least 10 feet apart.  Where  laid in
the same trench,  the water pipe  shall be laid  on a shelf  at  least  18
inches above  the sewer  pipe  and at  least 12 inches, but preferably 18
inches,  horizontally from the  side  of the  sewer  pipe.   The  horizontal
separating distance between a  sanitary  sever manhole  and a water  line
shall be 10 feet;

(17) Where water  and  sewer lines cross, a minisKui vertical  distance of
18 inches shall be  maintained  between  the water and  sewer line with  the
sewer at the  lower  elevation.   At crossings, pipe joints shall be spaced
as far from the crossing as possible;

(18) For force sewer lines  there  shall be no deviation  from the 10 foot
horizontal separation and the 18 inch vertical separation distances;

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      (19) When it  is  not possible  to satisfy  the  requirements in  paragraph
      (17) of  this  subsection above  one  or more of the  following  precautions
      •ay  be  approved by the  Department  of  Health  Services  as   acceptable
      alternatives:

           (A)  Sleeving  of  the sever;
           (B)  Concrete  encasement of the sewer;
           (C)  The  use of a  thicker-walled sewer pipe (pressure testing  will
                be required);
           (D)  Concrete  encasement of the water pipe;
           (E)  The  use of thicker-walled  water pipe;
           (F)  The   design  engineer  may  also  propose   other  precautionary
                measures  which will be subject  to review and approval;

      (20) The layout  plan should  provide for  suitable ownership or easement
      control  of the water supply  operator to permit further  extension  of the
      piping,  particularly where dead ends may  occur and/or where expansion of
      the water system can be  readily foreseen.
(j)   Materials:
      (1)  Metallic  and  non-metallic  materials  may  be  used  to  construct
      component  parts   of  a  water  system  including,   but  not  limited  to,
      conduits,  pipes,  couplings,  caulking  materials,  protective  linings  and
      coatings,  services,  valves,  hydrants,  pumps,  tanks  and  reservoirs;
      provided:

           (A)  The materials shall have a reasonable useful service life;

           (B)  The material shall be  capable of withstanding the internal and
           external forces to which it may be subjected  while in service;

           (C)  The  material shall  not  cause  the  water  to  become  impure,
           unwholesome,  nonpotable  or unhealthful;

           (D)  Materials and  equipment  shall be  designed and  selected with
           factors of safety  included  and installed as to  mitigate corrosion,
           electrolysis   and deterioration.   Mien  the  possibility  of  a  near
           future interconnection with another utility  exists,  some components
           such as pressure  tanks  and compressors may  be  designed for  limited
           service life;

           (E)  Us*  of  non-metallic  pipe shall require a  suitable tracer wire
           for pip* location;

           (F)  No  material shall  be allowed which does not  Met standards
           established  by  the  American  
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       system,  and the  requirements of  the  Department of  Health Services and
       the  Department  of  Public  Utility  Control.   Such  Specifications  shall
       include  the  following:

            (A)  Proper  protection shall  be  given to  metal surfaces by paints
           or other protective  coatings;

            (B)  All  paints,  liners or  coatings proposed  for use  in  a  water
           supply  system that will  come  in contact with  the potable water must
           be approved by  the Department of Health Services.   Following  final
           curing,  disinfection  and  dissipation of  the  chlorine  residual,
           water  samples  must be   collected  and  tested  in  accordance  with
           Section 19-13-B102 of  the Regulations of Connecticut State
           Agencies,   for  hydrocarbon,   organohalide,   inorganic  chemical,
           physical,  and  total  coliform  analysis   from  a  sampling   point
           approved by  the Department of Health Services. The results of  these
           analyses must be  reviewed and approved by  the  Department of Health
           Services  both  at  the time of  initial  drilling  of  the  wells and
           after  the  design  and construction  stages  but  before  using che
           facility;

           (C)  Cathodic  protection,  when  required,  must  be  designed  and
           installed by competent technically qualified personnel;

       (3)  Upon completion of  the construction  of  the community  water supply
      system,   the  well(s),   storage   tank(s),  and   appurtenances  must  be
      disinfected, in accordance with  procedures established  by the Department
      of Health Services;

      (4)  Prior  to  acceptance and  use, the design  engineer  shall  supervise
      appropriate  pressure testing  of  all  piping and  tanks  for  leakage  to
      assure specified standards are met.

(k)   Fire protection:  Whenever  fire  protection is required, the water system
shall  be  designed and  constructed  in accordance with recommendations  of the
Fire underwriter's Insurance  Services  Office,  the Departownt of Public Utility
Control and  the specified water  utility that  will  eventually  own  the  water
system.  No fire  hydrants  shall be  permitted unless the community water system
has at least 150,000 gallon* of water in atmospheric storage.

(1)   Service Pipes:

      (1)  The sice* design, material, and installations  of the  service  pipe
      shall conform  to  the reasonable requirements of .the utility  that  will
      eventually own  the water  system; provided,  however,  that  the  minimum
      size of  the pipe  shall  be  not  less  than 3/4-inch  and that  the  use of
      non-metallic pipe shall  include a.suitable tracer wire for pipe location;

      (2)  All  service   pipes  shall  be  installed below   the frost  line to
      prevent freezing;

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      (3)  Service pipes  shall  not be connected  to  hydrant branch  lines,  and
      they shall  not  cross intervening properties even with the protection of
      easements.   If  fire protection to  the  customer's property  is required,
      there  shall be a  separate service connection  and  separate  service pipe
      paralleling  the  domestic  service  pipe  to  the  customer's  place  of
      consumption;
          The service pipe shall be connected  to  a single-service corporation
     at the main, installed with a suitable gooseneck and be sufficiently
     flexible to prevent fracture from expansion or  contraction.   It shall be
     run  perpendicular  from  the  water main to  the customer  premises and be
     free from any tee, branch connection, irregularity or defect;

     (5)  The service  pipe shall  be  installed with a  suitable shutoff valve
     and  curb box  at   the  property  line.   There  shall also  be a suitable
     shutoff  valve  at  the  interior of the premises.   In  the  case of service
     pipes  dedicated  for fire  protection,  there  shall be  a  detector check
     meter installed on the pipe;

     (6)  No  physical connection  between the distribution system of a public
     water  supply and  any non-public  water  supply is  permitted  except as
     provided  for in  Section  19-13-B37 of  the   Regulations   of Connecticut
     State Agencies;

     (7)  A  separate  service connection shall be  required  for  any dwelling
     unit or  office  unit that is adaptive  to  individual ownership.  Thus, an
     application  for  a Certificate of Public Convenience and  Necessity  for
     the  following  types  of projects  must include provisions for installing  a
     separate  service  connection  for  each  dwelling  or  commercial  unit:
     residential   subdivisions,   including   homeowners   associations    and
     municipal tax districts; cluster housing  projects; duplexes; townhouses;
     residential  and  office  condominiums;  industrial  parks;  shopping centers
     or malls;  trailer or  mobile home  parks; elderly housing  projects  and
     garden  apartment  complexes.    Projects  that  may  or may  not  require
     individual service connections,  and subject  to the  Department  of Public
     Utility  Control's  judgement,   include  high  rise apartment  complexes,
     multi-storied homes, commercial  buildings and high rise condominiums;

     (8)  Each  service  connection shall be separately  mete red.   The service
     line  in each dwelling or office unit  shall  contain two ball valves  and
     an American  Water  Works Association-certified meter adaptive to a remote
     reading  device setting.  The water  utility which will eventually own  the
     water  system shall be responsible  for providing the water meters  to  each
     customer premise at its  own expense.

(•)  Pumphouse requirements:

      (1)  Well pit ari/or pumphouse construction shall  be designed to  prevent
     the  entrance of rodents and other small animals.  All facilities shall
     be  locked and  fenced  and otherwise  protected and secured to  prevent
     entrance of  unauthorized persons;

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       (2)   Adequate  drainage of all well  houses  and pits including the use  of
       floor drains  shall  be  provided as   required   in Public   Health  Code
       Regulation  19-13-fl51h;

       (3)   Necessary  electrical  controls  shall  be installed  to  enable  both
       manual  and automatic  operation of  all  pumps,  motors and  accessory
       equipment.   All  controls  must be clearly  labeled as  to  their function.
       All  electrical  wiring, controls  and appurtenances  shall  be installed  in
       conformance with the National Electrical Code;
            Flow  meters capable of  measuring  totalized  and  instantaneous flow
      shall  be installed  to  accurately measure  independently  each  source,  of
      supply  and their  installation  •hall provide  for  ease  of meter readying,
      repair  and/or removal.  Additional  meters may  be required  where  water
      treatment and/or other conditions dictate;

      (5)  Water  treatment,  when required,  shall be  installed  in accordance
      with procedures established by the Department of Health Services;

      (6)  Smooth   end   (e.g.   threadless   chrome)  sampling   taps   shall  be
      installed  on  the  discharge line  of each  well  and at a representative
      point(s)  off  the  discharge pipe(s) coming  from  the  storage  tank(s).
      Where  treatment  is  used,  taps  before and  after  treatment facilities
      shall also  be installed.   Taps  shall  be  at  least  12  inches  above the
      finished  floor  and  any  possible  high water  level.   Taps  must  point
      downward;

      (7)  Suitable over and  under  voltage protection shall be provided on the
      various electrical equipment;

      (8)  The waterworks  facilities shall be provided with suitable lighting,
      heat and ventilation.  If necessary,  a dehumidifier  shall  be used during
      summer operations;

      (9)  The  pumphouse,  wells   and  other  plant   facilities   should  be
      accessible to the various maintenance vehicles.

Section 16-262m-9.   Financial. Manaierial. sad Technical Qualifications
                     Criteria

(a)   If  the  Department of Public  Utility Control  and  Department of  Health
Services  determined that  a  main  extension is not feasible  or no  utility  is
willing to extend such main, and  that  no existing regulated  public service  or
municipal utility  or regional water authority la willing to own, operate and
maintain  the  final constructed  water  supply facilities  aa  a  non-connected,
satellite systesi,  and  if  it  is  not  feasible  to install private individual
wells,   the   applicant  may   continue  forward  with   the   application   by
satisfactorily providing the following additional information:

      j(l)  A description of  the applicant's  business  organisation  along  with
           certified copies of the executed documents  or any  authority granted
           pursuant to Section 2-20a of the General Statutes of  Connecticut;

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 (2)  Certified  copy  of most  current  12-month balance  sheet and  income
     statement  of  proposed owner  of  water system  including a statement
     of current assets and liabilities;

 (3)  Copy of  most  current  income  tax return of proposed  owner  of water
     system;

 (A)  Indicated source of  financial  resources  that would be  used to fund
     the daily operations and any needed future capital improvements;

 (5)  Describe the  financial ability  of  the proposed owner  of  the water
     system to provide a  continuous,  adequate and  pure supply  of water
     in routine and emergency situations  including a pro forma cash flow
     statement for. .one. year  starting  immediately  after construction is
     completed;     .• .  .

 (6)  Describe the annual  budget formulation process;

 (7)  Indicate the .'name,  address,  and  qualifications  of  person/company
     who  will   be   responsible   for  the   budget   preparation   and
     administration;

 (8)  Describe the  controls  that will  be   in  place  to keep  operations
     within  budget  and the  sanctions  or consequences that there will be
     for budget  overruns;                      ;

(9)  Indicate the name and  address  of person responsible  for  filing tax
     returns and annual audit reports;

(10)  Indicate the.name  and address of person(s)/company(s) who will be
     responsible for  routine operations including maintenance,  customers
     billing  and  .collections,  repairs,   emergency  service  and   daily
     management;  •

(11)  Describe the planning  process to  be  implemented  and assignment of
     responsibilities  to  provide  for  future needs  of  the   customers
     including a program for  routine  system maintenance and  the  increase
     of future supplies aa say be necessary5 . :.

(12)  Describe the  technical  background  anil experience of  the  proposed
     operator including any membership  in professional  water  industry
     organisations;  •                     .;••; ;-^..

(13)  Famish a  signed agreement or contract/.^toder which the  proposed
     operator will serve, including  guarantees of continuous  long-term
     operation;                            <~.v  •
                                           • •»• • •
(14)  Indicate the  name and  address  of person/company who will manage the
     water system if different from operator;  .

 (15)  If there will be a  business  manager, in addition to the operator,
     describe his or her  qualifications;

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 .'16)  Describe  the governing  board,  its background  in utility  business
      governance  and  the decision making process of the management entity;

 (17)  List  items  which  the  operator will  be responsible  for and  those
      which  the manager will be responsible for;

 (18)  A  plan  for  conducting  cross-connection  investigations  including
      identification    of    the    personnel   capable   of    conducting
      cross-connection inspections;

 (19)  A  plan (including the  procedures,  methods, schedule  and location)
      for conducting  required  sampling,  testing  and  reporting  regarding:
      (A)  water  quality testing;  (B)  pressure  testing;  (C)  production
      metering; (0)  customer meter  testing;  (E)  ground water  monitoring
      purusuant   to   Section   19-13-B102(n)   of   the  Regulations   of
      Connecticut State Agencies;

 (20)  A plan for maintenance of the system;

 (21)  A plan for the maintenance of required records  including at  least:

          (A) service  area maps;  (B)  water quality,  pressure,  metering
          and other  tests;  (C) emergency  procedures;  (D) metering;  (E)
          energy use; (F)  chemical  use;  (G) water levels;  (H) production
          and  consumption;  (I)   customer   complaints;  (J)  non-revenue
          water;  (K) all financial records;

(22) A plan for operator safety;

(23) A plan for leak detection;

(24) A  plan for  long range  conservation  including  supply  and  demand
     management practices;

(25) A plan  for  action and  proper notification  of authorities  in  the
     event  of an emergency;

          (A) Aa used  above,  "emergency"  means  any hurricane,  tornado,
          storm,   flood, high water*   wind-driven   water,   tidal   wave,
          tsunami,  earthquake, volcanic eruption,  landslide, mudslide,
          snowstorm,   drought   or  fire,  explosion,  electrical  outage,
          toxic spill or attack or aeries  of attacks by an enemy of  the
          United States cauaing,  or which  may cause,  substantial damage
          or injury to civilian property or persons  in the United States
          in any manner by  sabotage  r  by  the use of bombs,  shellfire or
          atomic, radiological, chemical,  bacteriological  or  biological
          means or other weapona  or processes.

(26) Estimated itemised cost  of  water  facilities  to be  constructed  or
     expanded.

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 (b)   In addition to the above  requirements,  the  Department of Public  Utility
 Control shall be furnished  the proposed  owner's plans for  the  following:

       (1)  Preparation  of adequate  rules and regulations  for providing water
            service,  including  termination  of customers  for  non-payment   of
            bills;
       (2)  Preparation  and  administration of  a proper  metered  rate schedule
            and the rates  themselves;

       (3)  A  procedure  for handling customer complaints;

       (4)  A  procedure  for meter reading and accurate billing of customers;

       (5)  A  listing in  the  local  telephone  directory  of  an  emergency  and
            general inquiry telephone number for the customers.

 Purpose;   The  purpose  of  these regulations  is  to  allow  the Department   of
 Public  Utility  Control  and  the Department  of  Health  Services  to implement
 jointly  the provisions  of General Statutes of Connecticut S16-262n, which was
 enacted   to  address  the  difficulties  associated  with  the   construction   or
 expansion of  small  water  systems,  such  aa   inadequate   construction  ana
 financing,  which ultimately  leads  to inadequate levels  of service provided  by
 such water companies.

      These  Regulations  are intended  to restrict  the  proliferation  of  new
 small  water systems, to  promote good public  utility practices,  to encourage
 efficiency and  economy,  to  deliver potable water in accordance with applicable
 health standards, and to  establish minimum standards to be  hereafter observed
 in  the design,  construction and  operation of  waterworks  facilities  of  new
 small water systems  and on  which existing community water systems should base
 their  future  plans   should  they  choose  to expand.   The Certificate of Public
Convenience  and  Necessity  assures  town  governments  that  community  water
 systems   will   operate   in   accordance  with  the   general   requirements  and
applicable minimum standards  of  Sections 16-11-50 through 16-11-97, inclusive
and Sections  19-13-B32, 19-13-B51. 19-13-B46, 19-13-B47 and 19-13-B102 of  the
Regulations of Connecticut State Agencies.

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                                                                  Appendix D

                    Including financial review in permitting process

       States can improve water quality  and the financial health  of communities and small
systems by providing technical  assistance during the early part of the small system planning
process. This assistance can range from informational materials about the costs of compliance
with the SDWA amendments and the importance  of full cost pricing  to development of a
standardized form for determining the financial health of a proposed system.
       Given the tremendous resources that will be needed by small systems to  comply with
the 1986 SDWA amendments, it is imperative that State programs consider systematic reviews
of the  financial, technical, and managerial strength  of proposed new public  water systems.
       Documents to be reviewed might include:

       a description of the certified operator, business manager, and bookkeeper;
       engineering plans according to State design  standards;
       an outline of the budget process;
       financial reports such as a current income statement and balance  sheet; and
       projected operation and  maintenance expenses, including  monitoring, sampling,  and
       analysis, and projected revenues.

       In addition to the  analysis of financial records, some States require proposed systems
to provide some kind of security to serve as a source of funding in case of emergency.  For
example, Maryland requires  new privately owned systems to  establish two  escrow accounts,
one each for the replacement of the highest cost treatment unit and for initial O&M costs, as
well as  a sinking fund  to  pay  for  the  replacement of the system in 20 years.   More
information on  Maryland's security requirements is located in Appendix E.

Developing criteria to determine new system  viability

       Requiring financial, technical, and managerial information is only  the  first step in
analysis  of a  proposed system's ability  to comply with the SDWA  requirements.   State
drinking water programs should  consider developing guidelines by which to evaluate the long-
term viability of proposed systems.
       Guidelines should include the evaluation of  key indicators of financial health, such as
liquidity, solvency, long-term planning, and debt retirement plans.
       EPA and its contractor,  The Cadmus Group, Inc., have published an excellent series
of four handbooks on financial  self-assessment  of water systems for privately- and publicly-
owned systems, home owners associations, and mobile home parks.1
       The mere existence of the permit review process  may cause systems to improve their
operations  and finances  voluntarily.  The  knowledge  that  they must  provide  financial
information can encourage marginal  systems to assess their capabilities  and seek alternative
arrangements without  the need for State involvement

Including the Department of Public Utilities (DPU) in the permitting process

       Several State drinking water programs have  established formal relationships with their
Department of Public Utilities (DPU) or Public Utilities Commission (PUC), agencies which
carry out financial analyses routinely as part of their rate-setting processes.

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      Formulating a Memorandum of Understanding (MOU) between the two agencies can
be a good mechanism for mutual acknowledgement of the small system problem and  the
parties' shared interest in and responsibility for devising a solution to this problem.
    Several  State drinking water  programs  are  drafting  or have  already  signed such
interagency MOUs. Officials in these States believe that the process of drafting the MOU has
been helpful in fostering a sense of shared purpose and mission regarding the provision of safe
drinking water.  Sample MOUs from California and Connecticut are included in Appendix F.

LDocument numbers  EPA 570/9-89-011 through /9-89-015.

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                                                               Appendix  E
                 MARYLAND DEPARTMENT OF' THE ENVIRONMENT
                             REQUIREMENTS
                 PROPOSED PRIVATELY-OWNED WATER SYSTEMS


     These requirements have been developed by the Maryland Department of
the Environment (MDE) as a result of our observation that,  for privately-
owned water systems,  plant operation and maintenance problems which
increase over time,  can be mitigated if the following requirements are met.
These requirements have been established to assure that,  with proper
operation and maintenance of the system, consumers enjoy  a safe and
adequate supply of drinking water,  now and in the future.

   For those water systems which a county intends to purchase and/or
operate, please send a copy of the appropriate public works agreement to
Mr. William Parrish,  Program Administrator, Water Supply  Program, Water
Management Administration, 2500 Broening Highway, Baltimore Maryland 21224.
For publicly-owned systems, some of the financial requirements may be
omitted from the public works agreement if the county believes that its
existing financial plan accommodates new systems and if sufficient funds
will  be available throughout the life of these systems to assure safe and
adequate supplies of drinking water for all consumers.

Requi rements:

   1. The project must be described and shown in the county Water and
Sewerage Plan with the appropriate service area category  designation. "

   2. A water appropriation permit must be obtained from the Water
Resources Administration  (Maryland Department of Natural  Resources) with a
copy of same submitted to the Water Supply Program (MDE).

   3. A well construction permit must be obtained from the Residential
Sanitation Division  (MDE).  Call Mr. Raymond Ludlow at (301)631-3654
regarding procedures.

   4. A financial management plan must be submitted to the Water Supply
Program. Call Mr. Barry O'Brien at (301)631-3706 regarding these procedures
for MDE review and approval.  This plan must detail estimated operating
costs and the revenues required to support these costs.

   5. An agreement must be developed and executed between the Water
Management Administration and the owner of the proposed water system.  The
agreement must provide for deposit into an escrow account of funds
sufficient to cover the repair or replacement of the highest-cost water
treatment plant unit.  In addition, a separate deposit account must be
established to provide for sufficient funds for the initial operation and
maintenance of the system.  This account will remain in effect until
operating costs are completely supported by income. Finally, the agreement
must provide for establishing an account sufficient to fund the replacement
of the system in 20 years from the date of initial operation.  This
financial assurance requirement is a condition of COMAR 26.04.03 "Water
Supply and Sewerage Systems in the Subdivision '?f Land in Maryland" and may
include such guarantees of equal protection os may be requested by the

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applicant.  Attached is a copy of such an agreement.   Mr.  O'Brien can
discuss this with you further.

   6. An operation and maintenance plan must also be  prepared and submitted
to the Division of Design Review (MDE). Call Dr.  Ta-shon Yu at (301)631-
3757 for review and approval.

   7. A State construction permit must be obtained from MDE for the
installation of the system. Call Mr.  John Stewart at  (301)631-3767
regarding procedures.

   After the State construction permit has been issued, there are two
additional requirements which  must be met prior to commencing the actual
operation of the new system:

   A. A water treatment plant  suoerintendent and operator, certified in the
appropriate classification by  tf~  Board of Waterworks and Waste System
Operators, must be employed pric  to plant sta-i-up to operate the plant.
Call Mr. Oktay Ertugrul at (301)631-3167 for details  of this program.

   B. Plans must be made for compliance with the monitoring and reporting
requirements of COMAR 26.04.01 "Quality of Drinking Water in Maryland "
before start-up of the plant.

   C. A final inspection of the system and approval to operate must be made
by MDE before the system is placed in service. Call Mr. O'Brien at
(301)631-3700 at least two weeks in advance to schedule the final inspection,

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                                                                             Appendix  E
      i HIS ACRttMENT mode  this          day of	of the year
Nineteen Hundred and  Eighty-Seven  (1987) by and between Kimberwood  Corporation,
hereinafter colled the "Developer" and  the  DEPARTMENT OF THE  ENVIRONMENT of
the State of Maryland, hereinafter  colled the "DEPARTMENT".

     WHEREAS,  the developer  is the  owner of certain property located in Queen Anne's
County, Maryland, more particularly  described by the Subdivision Plats of Bay View at
Kent Narrows, intended to be recorded among the Plat Records of Queen Anne's County,
Maryland hereinafter called the "Property"; and

     WHEREAS,  Developer is interested constructing certain structures on the Property
which  will be  served  by a community water system to be constructed on the Property,
which will be initially owned by Kimberwood Corporation, later to be owned by Bay View
at Kent Narrows  Condominium  Association, Inc., which shall be comprised  of all owners
of the Property; and

     WHEREAS,  COMAR  10.17.03.00 of the Deportment's regulations entitled Water
Supply and Sewerage Systems  in  the Subdivision  of Land  In  Maryland  requires  that
departmental approval be conditioned upon compliance with the financial and ownership
requirements  determined  to  be  necessary to assure  the  continued,  efficient,  and
effective operation of the system.

     WHEREAS,  the Department has  determined  that  the financial assurances set out In
this Agreement  and  the attached Financial Management  Plan  (Exhibit  I), which are
incorporated by reference as  if  set forth herein, are necessary to  assure compliance  with
the above regulations.

     NOW, THEREFORE, this Agreement witnesses that, the Developer in  consideration
of these  requirements and the Department's approval of  Its attendant community water
system, hereby agrees to bind itself, its heirs, successors and assigns as follows:

     I.  To construct  a  water treatment  system in accordance with the  plans and
specifications  approved  by the Department.

    2.   To properly  maintain and operate the  water  system  to  serve  the,  proposed
development in order  to protect the health,  safety and welfare of the general population
living in the area  and also the residents and guests on and  about the properly.

     3.   To properly  maintain and operate the water system In accordance with all the
applicable  regulations,  laws  and  standards of the Department  and other appropriate
agencies.

     U.   That  prior to the signing of  the proposed plots and/or recordotion of same, the
Developer will secure a bond for  $18,600.  This  bond shall be designated  as the Water
System Emergency Reserve Bond, as shown in Exhibit I, Appendix C.

      The value of the bond will be maintained so that it guarantees the equivalent cost
of  repair or  replacement of  the most  expensive  piece  of  equipment  of the Water
Treatment  System.   The replacement  costs of all major  pieces of equipment will  be
reviewed annually to  confirm that replacement costs are  guaranteed  or>d the value of the
bond  will  be adjusted to  reflect  any revised  repair/replacement  cost estimates.
Adjustments shall be made  within 60 days  of the review of replacement  costs.  In the
event  of the failure of  the Developer to repair or replace any equipment, the bond  shall
be  utilized  to perform  all  work  necessary to return the  Water Treatment System to
operating condition.  If this bond is drawn upon,  the amount drawn shall be replaced
within 90 days.

     5.   That  Water  System Emergency Reserve Bond  shall only  be  used to pay for
repairs  or  improvements  to   the  water   system  and  not for  ordinary operation
maintenance.  The Developer shall notify the Department of any use of this bond.

     6.   That prior to  placing  the water treatment system in operation, tj^e Developer
shall create an operation and maintenance bond in the amount of $4,500.00, as shown  in
Exhibit I, Appendix B.  The purpose of this bond is to insure that the  water  supply system
will hove  sufficient  minimal  funds  for  the  operation  and  maintenance  of the  water
system.
                                   Page  I  of  3

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    7. • That  prior  to approval of the development,  the  Developer shall establish  by
restrictive <-ov(»vm»«. r,,™\r*~ .uitK. tK. inr>H_ as uort of a general scheme of development,
the obligation of each owner of a condominium to pay an annual fee into the water suoply
system reserve fund.  This fund  shall  provide on amount sufficient  to replace the water
system 20 years after Initial construction.  The  annual assessments established pursuant
hereto shall constitute a lien on all  property affected.  The Developer  shall similarly
establish the obligation of each owner  to pay an annual assessment Into the water supply
system operation and maintenance fund sufficient to meet all operation and maintenance
costs.

    8.   When, as stipulated in the Bay View at Kent Narrows Condominium Association,
the obligations and rights of the Developer shall automatically transfer to Bay View at
Kent  Narrows  Condominium Association  and/or  the  Council of Unit Owners of the
condomlnium(s)) and shall be  assumed by  and  inure  to  the  benefit of such entity, the
Developer shall thereupon be discharged from further obligations under this Agreement.

    9.   If  the Developer fails to make repairs or improvements  required  for proper
maintenance and operation  of the water system, the posted bonds and/or reserve  funds
may be utilized  at  the  option of the Department arid  used  to effect such  repairs or
Improvements. The water system reserve fund  shall be restored to the original balance
within 90 days by the Developer upon any such withdrawal required to me » such repairs
or improvements.

     10.  Upon assumption of ownership of the  system by a p- ilic utility, the funds and
bonds (as established in  paragraph 4 and paragraph 7)  shall be abolished and all deposits
shall  be received by the Developer,  his  assignee, or the Bay View  at Kent r-Jprrows
Condominium Association for its use.

     II.  Nothing herein  shall be construed to limit the liability of the Developer for any
costs of repairs or improvements for  which he  is responsible by law.   Any  and all other
remedies that the Department may have at  its disposal, Including the  revocation of  any
permit  or  approval,  shall be  strictly preserved.   Any entry for inspection,  repairs or
improvements shall not be considered  trespass,  and permission to do so is hereby granted
Irrevocably.

     12.  The Department may transfer its rights and obligations under this Agreement to
any other  public agency authorized  to carry out such functions and specifically may
transfer the Agreement  to  Queen Anne's County. The Developer may  transfer Its rights
and obligations under this Agreement  to any purchaser of the Property, in the even* that
the Developer itself does not develop the property.

     )3. The Developer, its successors and assigns, shall remain subject to  all applicable
provisions of law regulating the operation and maintenance of water faci'ities.

     I ft. The Developer shall cause  this Agreement  to  be recorded among  the Land
Records of Queen Anne's County and  this  Agreement shall be noted upon the subdivision
 plots of the property.

      15. The Developer further agrees that  in addition  to Its personal liability  this
 Agreement shall run with the land and be binding on  all persons having or  acquiring any
 rights, title or interest in said property, or any part thereof.

      16. That the Developer  shall additionally  in any other Declaration of Covenanfs It
 may execute  with regard to  the proposed condominiums, Incorporate directly or by
 reference Ihe provisions of this Agreement.
                                    Page  2 of  3

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                                                           Appendix P
     17.  In the event that the requirements of any provision of
substance is not complied with, the plat approval may, at the
option of the Department, be declared null and void and the
Department may take appropriate judicial action to have saia
plat expunged from the land records.
     AS WITNESS the hands and seals of the parties herein the
date and year first about written.
                              BY:
DATE                             Jack B.Dietrich,President
                                 KIMBERWOOD CORPORATION
                              WITNESS:
DATE
                              BY:
_          _ _ _
OAT!        ~                     Richard  B.  Sellars,  Jr.,  Director
                                  Water  Management Administration  .
                                  DEPARTMENT  OF THE ENVIRONMENT
Approved as to  form  and  legal  sufficiency
this    ft/1"     day of  'vi^fe >"V i?#-.  1987
AssistanitJAttor^niy Central
               
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                                                    ADpend:i_x F
                   MEMORANDUM OF  UNDERSTANDING

                  DEPARTMENT OF HEALTH  SERVICES
                               and
                   PUBLIC UTILITIES  COMMISSION

         ON MAINTAINING SAFE AND  RELIABLE WATER  SUPPLIES
           FOR REGULATED WATER COMPANIES  IN CALIFORNIA
The Department of Health Services (DHS)  and the Public  Utilities

Commission  (?"JC)  recognize that it is their joint goal  to  ensure

-hat California water companies regulated by PUC are  economically

maintaining safe and reliable water supplies.   This Memorandum  of

Understanding (MOU)  sets forth those policies and procedures  to

which CHS and PUC commit -hemseives towards achievement  of that

goal.



                           OBJECTIVES



The common  objectives of the program, as they relate to public

water systems subject to regulation by  PUC and DHS, are as

follows:


L.   To monitor the systems  to assure that safe and reliable

     water  supplies are being maintained in accordance  with

     applicable drinking water standards.


2.   To identify contaminants and determine system improvements,

     including alternatives, necessary to provide safe and

     reliable water  supplies.

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2.    To  assure that  systen  improvement projects,  necessary  to
     upgrade supplies to neet standards,  are  selected  on  the
     basis of priority and only after reasonable  alternatives
     have been defined and -&*4- cost-effective analyses performed
     to arrive at a cost-effective solution.

4.    To establish mutually agreed upon priorities for  necessary
     system improvements.

                     PRINCIPLES OF AGREE::- .T

For the purpose of this agreement, DHS and PUC agree that their
staffs shall abide by the following principles:

I.    To the extent its resources permit, DHS  shall be
     responsible for evaluating and determining all technical
     aspects of monitoring water quality and identifying
     contaminants, and for identifying the various potential
     improvements necessary to provide safe and reliable
     water supplies.   DHS will also recommend its preferred
     solution.  P¥C shall be responsible for  evaluating  fire flow
     requirements and for making recommendations on the financial
     and rate making aspects associated with implementing the
     improvements identified by DHS  to provide safe and reliable
     water  supplies.

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2.    The staffs of the two agencies shall endeavor to keep each •
     other fully informed of their respective activities and to
     assist each agency in carrying  out its  responsibilities.

3.    Both agencies shall  exchange  all information available
     regarding water companies that are experiencing water
     quality and/or water availability  problems.  The information
     about the problems should include, but  is not limited to:

     a.    All  communications with utilities;
     b.    Orders;
     c.    Decisions;
     d.    Regulations and Policies;
     e.    Proposed new water systems;
     f.    Permits; and
     g.    Reports, investigations, etc.

4.    The PUC will notify DHS of all requests for rate increases
     from public water systems and shall routinely provide DHS
     with schedules of hearings.   DHS will provide technical
     input to PUC as necessary and appropriate  in PUC
     proceedings.  This may include  testimony before the  PUC.

5.    Identified system improvements necessary to provide  safe and
     reliable water supplies should  consider:

     a.    Protection of public health;
     b.    Short and long term benefits;

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     c.    Cost effectiveness;



     d.    Cost to customers; and



     e.    Ability of  customers to pay.





6.    Each agency shall  endeavor to provide appropriate assistance



     in necessary enforcement  actions  taken against individual



     water systems.







                     AGENCY RESPONSIBILITIES







The intent of this MOU is to identify the separate and distinct



responsibilities of  DHS and PUC.  The  following represents  a



general description  of the roles  and responsibilities of each of



the respective agencies relating  to water companies under PUC



jurisdiction.  Each  agency  agrees to adopt and  implement policies



and procedures necessary to administer its respective duties.



These policies and procedures shall be coordinated between the



agencies.





1.   DHS  shall be responsible for the following:





     a.   Evaluation of public water systems to identify public



          health deficiencies and determine compliance with the



          Safe  Drinking Water Act.





     b.   Identification of alternative cost effective corrective



          actions necessary to upgrade water supplies to meet



          standards, and recommendation  of its preferred solutic-.

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 c.    Review and approval  of  plans  and specifications and
      issuance  of domestic water  supply pernits for improvemer

d.   Inspection of  water quality  improvement projects both
     during and after construction,  and  sharing project
     status reports with  PUC.

e.   Participation at appropriate PUC public meetings with
     customers and/or evidentiary hearings where  water
     quality matters raised by DHS or any ether person  are  to
     be discussed.

PUC shall be responsible for the following:

a.   Determination of the type of rate relief needed to
     finance necessary system improvement projects for other
     than Safe Drinking Water Bond Act loan projects,  which
     by existing policy are required to be  paid  off by a
     surcharge on  customer bills.

b.   Arrange public meetings with customers and/or
     evidentiary hearings to ensure that customers are made
     aware  of the need for system improvement projects and
     the  impacts the  projects will have  on rates.

c.   Promptly  inform  DHS  of  PUC public meetings with
     customers  and/or evidentiary hearings where water
     quality problems will be discussed  so  that DHS may
     prepare  and  participate.

d.    Provide analyses of  the financial impacts,  if any, of

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          sys-em improvement projects on  both custoners and warer
          companies.

                      PROJECT COORDINATION

1.    DHS and PUC will designate project managers  for their
     respective agencies when water  quality and/or water
     availability problems exist and an improvement project is
     necessary.   The  project  managers will be the principal
     contact persons  for their agencies  on a  particular  project.

2.    whenever a potential  conflict regarding  a  specific project
     is identified,  each agency will examine  the  alternative
     solutions available for upgrading water  supplies  and then
     meet-/ to thoroughly discuss the issues  involved and attempt
     to cone to an agreement before announcing a position.  If an
     agreement can not be  reached after consultation between the
     Chief of the Sanitary Engineering Branch of  DHS and the
     Chief of the Water Utilities Branch of PUC,  DHS and PUC
     staff may advocate separate positions.   Notwithstanding such
     disagreements, this MOU shall remain in effect.

3.    There should be a complete exchange of information  between
     DHS and PUC through the project managers.   Each agency will
     set forth where and to whoa material shall be sent.   Copies
     of all correspondence Between an agency and other parties
     concerning a water system improvement project shall be sent
     to the project manager   of each agency until project
     completion.

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                                                      Apnendix F
     The  Chief  of the Sanitary Engineering Branch of DHS and the

     Chief  of the Water Utilities Branch of PUC, with designated

     members of their staff,  shall  meet as necessary but at least

     semi-annually  to review  progress of the water quality

     improvement effort in California and resolve any issues

     which have been identified  by  staff.



                           AMENDMENTS


:his KOU nay be amended by mutual agreement of DHS and PUC.  It

shall remain  in effect until- DHS and/or  PUC decide  otherwise.
Approved:
Director            '
Department of Health Services
Date:  Februarv 9,  19S7
Approved:
Executive Director
Public Utilities Commission
Date:   December  9.  1986

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                          MEMORANDUM OF UNDERSTANDING
                                     AMONG
                  THE DEPARTMENT OF ENVIRONMENTAL PROTECTION,
                                      AND
                       THE DEPARTMENT OF HEALTH SERVICES,
                                      AND
                    THE DEPARTMENT OF PUBLIC UTILITY CONTROL
                          OF THE STATE OF CONNECTICUT
PURPOSE
     This   Memorandum   of  Understanding   (MOU)  provides  a  common  set  of
     guidelines for water companies and  other  parties  who  are  required  to
     prepare  either  water  conservation plans or emergency contingency plar.s.
     The purpose of this Memorandum of Understanding is to  avoid  overlap  and
     redundancy  in  requirements  and  authority  of the signatory agencies in
     water  conservation  issues  and  emergency   contingency   plans.    This
     Memorandum  links  the  requirements  of  the  Department of Environmental
     Protection (DEP),  the  Department  of  Health  Services  (DOHS)  and  the
     Department  of  Public Utility Control  (DPUC) for these two areas of their
     responsibility under one  set  of  commonly  agreed  upon  guidelines  and
     establishes a process of coordination,  review and approval.

     As  a  result  of  a  1988 DPUC docket  on water conservation,  a program to
     retrofit state buildings with water  conservation  devices,   revisions  to
     the  State  Building  Code,  and  legislation  (Public  Act 89-327,  An Act
     Establishing  a  Water  Resources  Policy;  Public  Act  89-303,  An   Act
     Concerning  Minimum Efficiency Standards for Plumbing Fixtures; and Public
     Act 89-266, An Act Establishing a Residential Water  Saving  Program,"  the
     Governor  and  the  General  Assembly   have  established  a  clear  policy
     direction concerning the important role of  water  conservation  in  water
     management.   Pursuant  to  Public Act  89-377, an Act Establishing a Water
     Resources  Policy,  the  Bepartnent  of  Environmental   Protection,    the
     Department  of  Health  Services  and   the  Department  of  Public Utility
     Control hereby establish this Memorandum of Understanding.
APPLICATIONS
     Pursuant to Public Act 89-377 four sections  of  the  Connecticut  General
     Statutes  are  covered  by this Menorandum of Understanding.   In addition,
     three sections of th= Connecticut State Regulations are included  in  this
     Memorandum  of  Understanding  pursuant  to Section 4-8 of the Connecticut
     General Statutes.

     Statutes Included in MOU

        Sec. 16-19(a) (DPUC) - Plans for promoting water conservation required
        in conjunction with a vater company rate case;

        Sec. 16-32e(b) (DPUC) - Plans by water companies for restoring service
        which is interrupted as a result of an emergency;

        Sec. 22a-369(9) (DEP) - The long-range water conservation plan of an
        applicant for a diversion permit,  including contingency measures for
        limiting water use during seasonal or drought shortages;
                                      -i-

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        Sec. 25a-32d(b) (DOHS)- Water company water supply plans -
        vulnerability assessment and contingency procedures for public
        drinking water supply emergencies;  an analysis of the impact of water
        conservation practices and a strategy for implementing supply and
        demand management measures.

     Regulations Included in MOU

     -  Sec. 16-262m-9(a)(2A) (DPUC  & DOHS) - Long-range conservation plan,
        including supply and demand management practices required  pursuant   to
        issuing  joint     Departnent  of  Health  Services  and  Department of
        Public  Utility  Control    Certificate  of  Public   Convenience   and
        Necessity;

     -  Sec.  19-13-B102(s)  (DOTS)   -  Conservation  requirements  of the State
        Public Health Code, including a program to reduce the amount  of  water
        which cannot be accounted for;

     -  Sec.  22a-430a-3(o)  (C '?}  -  Holders of a wastewater discharge perrrit
        are to maintain practices and facilities which result  in  the  minimum
        amount  of  wastewater  discharged  utilizing  such  methods  as  water
        conservation, resource recovery, waste recycling or wastewater reuse.

INTERAGENCY  COORDINATIONCOMMITTEE  FOR  WATER   CONSERVATION   AND   EMERGENCY
CONTINGENCY PLANS

     There  is  established  an  Interagency  Coordination  Committee for Water
     Conservation  and  Emergency  Contingency  Plans  composed  of  an  agency
     representative  designated  by  the  Commissioner  of  the  Department   of
     Environmental Protection, the Commissioner of  the  Department  of  Health
     Services,  the  Chairman  of the Department of Public Utility Control,  the
     Consumer Counsel of the Office  of Consumer Counsel, and the  Secretary   of
     the  Office of Policy and Management.   The Office of Policy and Management
     shall chair the Committee. This Interagency Coordination  Committee  shall
     be  utilized  to facilitate discussion of issues which are critical to  the
     signatory agencies, to resolv*  disputes  relating  to  the  statutes  and
     regulations  within the purview of this Memorandum of Understanding and to
     monitor  and  recommend  improvements  to   the   Guidelines   and   their
     implementation.   The  goal  of  this  process  is  to have either a water
     conservation plan or an emergency contingincy plan, which is submitted   to
     one  agency and reviewed by each of the signatory agencies and through  the
     interagency review process, as described below, be acceptable  to  all   of
     the   signatory   agencies  in  any  regulatory  proceedings  under  their
     respective jurisdictions.

IMPLEMENTATION

     This Memorandum of Understanding is  implemented  through  guidelines  for
     water  conservation  plans  and emergency contingency plans which serve as
     instructions  to  water   companies,   industrial/comraercial/institutional
     water "users,  and  agricultural  water  users in the preparation of these
     plans.  Both this Memorandum  of  Understanding  and  the  Guidelines  are
     hereby   adopted  by  the  Department  of  Environmental  Protection,  the
     Department of Health  Services,  and  the  Department  of  Public  Utility
     Control.  The guidelines are divided into four separate documents:


                                      -ii-

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                                                      Appendix  ~

 -Water Conservation Plans prepared by Water Companies;
 -Emergency Contingency Plans prepared by Water Companies;
 -Water Conservation and Emergency Contingency Plans prepared by
  Industrial/Conanercial/Institutional Water Users;
 -Water Conservation and Emergency Contingency Plans prepared by
  Agricultural water users.

A  proposed  water  conservation  or  emergency  contingency  plan   (or  a
component of  an  application  which  comes  under  the  purview  of  this
Memorandum)  will  be  submitted  to  the specific state agency from which
regulatory approval is being sought.  The state agency then  will  forward
a  copy  of  the  plan  to  the  other  signatory  agencies for review and
comment.  The signatory agencies will each have 60 days from receipt of  a
plan  or  a  component  to  determine   the adequacy of the proposal and to
submit comments  to  the  regulatory  agency  for  its  consideration  for
incorporation  into  a  letter  of  deficiency.   In addition, a signatory
agency may submit minor comments to the regulatory agency  for  forwardir.g
to  the applicant for information purposes only.  If the regulatory ager.cv
finds either that as a result of its review or the  review  by  the  other
signatory  agencies  that significant deficiencies do exist in the plan or
a component of a plan, the regulatory state agency will  prepare  a  draft
letter  of  deficiency  and  will forward it to the signatory agencies for
review prior to submittal to the applicant. If no comment is  received  by
the  regulatory agency from the other signatory agencies within 15 working
days from the date  the  draft  letter  of  deficiency  was  sent  by  the
regulatory  agency,  it  vill be assumed that there is no objection to the
contents of the letter of deficiency and then it may be  issued  with  the
requirement that the applicant address  the concerns raised therein.

If  a  signatory  agency  feels  that   its  comments  were  not adequately
incorporated into the draft letter of deficiency; are within its areas  of
jurisdiction;  and  are  of  a critical nature, the commenting agency then
shall inform the regulatory agency in writing within 15 working days  fro^
the  date  that  the regulatory agency  sent the draft letter of deficiency
of its specific objections with the content of the letter of deficiency.

Staff from the regulatory agency and staff from  the  specific  commenting
agency  will  then  meet  to  come to a resolution as to the importance of
having the signatory agency's comments addressed by the applicant.   If  no
agreement  is  reached by the staffs of the agencies, the matter will then
be referred  to  the  Interagency  Coordination  Committee  to  facilitate
discussion,  if the commenting agency wishes to do so.

In  reaching  a concensus on the adequacy of a proposed plan in question,
the Interagency Coordination Committee will be  guided  by  the  following
general  areas of statutory jurisdiction.   The Department of Environmental
Protection has jurisdiction over: the conservation of water by  wastewater
discharge  permittees; providing for the prevention and abatement of water
pollution;  the amelioration of seasonal shortages of water;  and
                                 iii

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     providing  for  the  coordination  and  management  of  the  state's wste:
     resources to assure their protection,  enhancement, proper  allocation  arc
     uz  -zation.  The  Department of Health Services has jurisdiction over the
     pu  -y,  adequacy and safety of public  water supplies,  plant  and  systems;
     an.:  such  other  matters  as  may affect public health.  The Department of
     Public Utility Control has jurisdiction over investor owned water  companv
     financing,   system  operations  and  the  cost  effectiveness of plans and
     programs.  None of the signatory agencies will hold  up  another  agency's
     regulatory  process unless there is a  major outstanding issue.   The object
     of this  process is  to  have  close  coordination  between  the  signatory
     agaencies so that issues are resolved  to each agency's satisfaction.

REGULATORY APPLICATION

     Each  of  the  participating  agencies  shall  consider any approved water
     conservation and/or emergency contingency plans,  as  applicable,  in  all
     related  regulatory  activities.   Plan approval does not preclude or bind
     the outcome of specific administrative proceedings  for  permits  required
     under  the  Reflations  of  Connecticut State Agencies or the Connecticut
     General  Statutes.  A water  user  who   comes  under  the  purview  of  the
     statutes  listed  in  this Memorandum of Understanding shall implement all
     approved plans in compliance with all  applicable state  agency  regulatory
     programs and statutory requirements.

     It  is the intention of the signatory agencies that only the sections of a
     plan pertinent to  its  jurisdiction  shall  be  considered  for  official
     comment   by  it,  when  a  plan  prepared  pursuant  to this Memorandum of
     Understanding  is  utilized  to  fulfill  a  requirement  in  one  of  the
     above-referenced  statutes  or regulations.  The intent of this Memorandum
     of  Understanding  is  to  eliminate   duplication   of   effort,   reduce
     overlapping  authorities  and  ensure   regulatory consistency at the state
     level.

TIMEFRAME FOR MEMORANDUM OF UNDERSTANDING

     This Memorandum of Understanding is effective from the date of signing  by
     these  three  agencies and will remain in force for the signatory agencies
     until amended or revoked by them.   However,  any  plans  submitted  as  a
     result  of  the  above statutes and regulations during the six months from
     the signing of this Memorandum of Understanding, will not have  to  be  in
     conformance  with  their  pertinent  guidelines  during this grace period.
     The Memorandum, of Understanding may be revoked  at  any  time  by  written
     notification from any signatory to the other signatory agencies.

COORDINATION

     Any   changes   fn   statutes   which  would  affect  this  Memorandum  of
     Understanding  and/or  accompanying  Guidelines   will   be   taken   into
     consideration   by   the   three   signatory   agencies  and  through  the
     coordination of the Office of Policy and Management  will  result   in  any
     modifications  to  the  Memorandum  and/or  in  the Guidelines as would be
     appropriate.  Periodically, the Interagency  Coordination  Committee  will
     evaluate  and  recommend  improvements  to  the  review  process  and  the
     Memorandum of Understanding.


                                      -iv-

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                                                                    Appendix G

                    Restructuring options to overcome diseconomies of scale

       This section will focus on various solutions to these diseconomies of scale. As  in any
enterprise,  the cost of a good or service per unit is generally  less the  larger the size  of the
purchase.   Small  systems cannot purchase in large amounts, so they pay relatively high unit
prices.  Similarly, the larger the customer base, the lower the cost per customer of a particular
purchased item.   But by definition, small systems have a small customer base,  so  the effect
of costs on water rates is relatively higher than for larger systems.
       The three  solutions  listed below address these problems of diseconomies of scale:

       1)   Contract operation and management (O&M)
       2)   Cooperatives
       3)   Mergers and acquisitions

       By contracting out for O&M services,  a small water system may enjoy the economies
of scale already achieved by a firm that provides O&M to many clients.   In cooperatives,
several  small  systems  buy goods  or services jointly, decreasing their  per-unit costs by
increasing the size of their purchases.  In a merger or acquisition, the small system becomes
part of a larger system, taking advantage  of the economies of scale achieved by  the acquiring
entity.

Defining the terms

Contract operations and management:  A contractual arrangement  whereby a small water
system buys services from a larger entity, either another private or public system or a private
company.   No transfer of assets is  involved.  Contract O&M  is also referred to as satellite
management, third-party operator, service contract, privatization, or turn-key operation.

Cooperative: A group of small systems can join together (formally or informally) to purchase
goods or services  cooperatively (e.g. sharing a certified operator).  If the  systems create a new,
independent entity to perform this function, the entity is called a "cooperative."

Mergers and acquisitions:  A merger or acquisition occurs  when a  water system (either
publicly or privately owned)  assumes ownership of another  water  system.   Mergers  and
acquisitions do  not necessarily involve the physical interconnection of the  systems involved;
however, they do involve the transfer of assets.

A.  Contract O&M (a.k.a. satellite management)

       Many small systems lack  the  necessary trained personnel to monitor or report the
concentrations of regulated contaminants or to maintain and repair system equipment. In such
cases, professional help may be obtained by contracting for O&M assistance.  Services covered
can include:  routine maintenance, monitoring  and reporting, managerial services, or system
improvements.
       Because  their operations do not require  constant attention, small  systems  often do not
need  full-time operators. Therefore, instead of hiring full-time operators  themselves, small

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systems can contract with private  service companies to obtain certified operators  on an as-
needed basis.
       Private water service companies are the  leading providers  of O&M contracting, but
capable municipal systems should also be encouraged to provide such services.
       Contract O&M is most effective when small systems need trained operators to manage
daily operations  or perform routine monitoring and reporting functions.  Small systems  with
more severe problems should consider other options, such as mergers or acquisitions.
       States should approve the plans for satellite arrangements before they are initiated to
be sure they conform to operating permit  requirements.   During this review, the  State  can
ensure  that the satellite owner or  manager will correct small system problems in a timely
fashion.  In addition, States can promote satellite management and ownership by  providing
grants or low-interest loans to water systems that conduct satellite  planning and assessment.

Incentives for contract O&M

       States can provide several  incentives  for  systems  to enter into contract O&M
arrangements:

1.      Provide  a sample O&M  contract, with  appropriate  language,  to  facilitate  the
       establishment of such  agreements.   A sample of such an agreement can be found in
       Appendix  H.

2.      Inform and educate larger water systems of contracting opportunities. For example,
       many large municipal  systems have their  own certified microbiological  laboratories at
       which they do coliform and VOC testing.  Such labs should be encouraged to sell  their
       services to smaller systems.  Informational materials could be developed and distributed
       at the time of lab (re)certification.

3.      Maintain  a registry of qualified certified operators who can provide services to
       systems that do not need full-time operators.

4.      Modify agency policies to require an entity (such as  a hospital or school) that is part
       of  an existing  PWS  and that wants to  install its  own treatment to contract  the
       associated services  to its existing public water supplier.  The existing PWS, usually a
       municipality, would be required to charge its true, full cost of providing these services
       (treatment, monitoring, management).    Such  an  arrangement  would  avoid  the
       proliferation of new small systems, simplify compliance tracking, and be economically
       beneficial  to both parties.

       Appendix  I contains case studies of contract O&M arrangements.

Liability issues with O&M contracting

       Liability  can  present  an obstacle to  small water  systems  that seek contract O&M
services from private companies or large water utilities.  States normally hold system owners
accountable for MCL or M/R  violations;  however, if the owners have contracted for operator
services, the contract operator may  be held liable.
       States can modify their regulations to avoid liability disputes.  Oregon recently modified
its regulations to state  that  contract operators  must recommend  all necessary changes to

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maintain or bring about system compliance, thus shifting compliance responsibility back to the
systems. If a system fails to adopt the operator's recommendation, it will be responsible for
any resulting violations.  Contractor operators can be held liable if they have been negligent;
they are responsible for  the accuracy of their work, but system owners are responsible for
implementing changes to maintain compliance.
       A primacy  agency could also  recommend  that the  parties involved  in  satellite
management  arrangements incorporate an indemnification clause in their contracts to prevent
liability disputes. The sample contract in Appendix H contains such a clause.

B.  Cooperatives

       By joining together, small systems can achieve greater economies of scale and reduce
the unit  prices  of their purchases at little or no cost to  the systems or the primacy agency.
Examples of goods  and services that may be purchased more cheaply include: operation and
maintenance  services, laboratory services, chemicals, and equipment.
       In addition to the cost savings  that might  be achieved by  such  arrangements,  an
additional feature of cooperatives is the forum they create for sharing knowledge and expertise
about regulations, pricing, and solutions  to common problems.
       The simplest  type of cooperative purchasing may result from a larger system helping
a small system, to  the mutual  benefit of each.  Because large systems have the ability  to
purchase in bulk at a lower per-unit cost, they could sell some of their materials to a small
system at a price higher than their original cost (so they make a profit) and yet at a price still
lower than that which the small system  would be paying if it  purchased the  item separately
(so the small system saves money).
       Water system cooperatives are most appropriate for systems that are structurally sound.
For these systems, cooperatives  can be  an effective way of reducing costs.  However, if a
system  is  only marginally viable because of  major  technical,  financial,  or  managerial
deficiencies, then mergers and acquisitions may be a more appropriate option.
       Formation of a water  cooperative requires  that significant effort  be   devoted  to
management. If there is an informal purchasing arrangement, it will depend on the voluntary
contributions  of time from its members to get quotes from vendors, place orders,  and deliver
the goods.  Members who do not do their share  will lose their right to participate.   Small
system  owners and  operators are often independent; because of this, some  systems fear
delegating responsibility to an organization that it cannot completely control.  This may limit
the feasibility of cooperatives among some systems.

Incentives for cooperatives

       The most effective mechanism for encouraging cooperative purchasing is through the
dissemination of information about  available options and their successful  implementation  in
other areas.
       In addition,  specific cooperative  purchasing  arrangements can be encouraged.  For
example, the  tests for the new  total coliform rule are significantly cheaper when bought  in
large quantities.  As  part of its informational process for the  new total coliform rule, a State
drinking water program could encourage larger municipal and private systems to purchase extra
tests and sell them to small systems.

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C.  Mergers and acquisitions

       A merger or acquisition occurs when a publicly- or privately-owned water system
assumes ownership of another system.  The entities that are acquired or merged can be either
privately or publicly owned.    The  new systems that result have a larger  customer base,
increased access to capital, and eligibility for State grant and loan funds (usually only if the
acquiring entity is a public system). A typical example is a municipal water system acquiring
a small, privately owned system outside its  service boundaries.  Other case  studies  of  both
private and public mergers and acquisitions are located in Appendix J.
       Mergers may result from the State primacy agency's requirements, or they may result
from a system's plans  to expand its service area.  Although  the regulations vary from  state
to state,  public  mergers,  acquisitions, and the formation of new  public  systems generally
require approval by the primacy agency.
       The terms of private mergers are usually reviewed by either the primacy agency or the
State's PUC. Primacy agencies  review proposed mergers to determine whether the new system
will comply  with operating permit requirements.  Similarly,  PUCs review proposals before
granting operating permits, conducting hearings to determine if the acquisition is in the public
interest, to set rates, and to  determine whether acquisition costs should be recovered through
rate increases.
       State  regulation  of voluntary mergers can ensure that they  are an effective way of
addressing small system problems.  Voluntary private mergers and  acquisitions usually occur
when the private companies involved determine that financial restructuring is advantageous for
both companies  involved.  A recent study of voluntary private acquisitions showed that the
acquiring company is usually motivated by the wish  to expand its customer base and service
area.1  The acquired system usually wishes to get out of the  water service business.
       Sometimes voluntary action is  not enough.  There may be conditions under which the
State  must compel involuntary  mergers and acquisitions, for example,  when  a small system
is in gross violation of standards and is financially incapable of correcting the problems.
       Under existing drinking water statutes, most States do not have the authority to mandate
the takeover of  a non-compliant system.  However,  recent Connecticut legislation gives the
State  the  authority  to compel involuntary mergers or acquisitions  under  specific conditions.
Pennsylvania recently passed a  bill which gives the State PUC the authority to order a capable
public utility to  acquire a small system that the  commission has determined to be nonviable.
More information on the Pennsylvania takeover  provisions  can be found in Appendix K.

Incentives for mergers and acquisitions

       The State program should work with its advisory committee  to determine how best to
encourage  and facilitate mergers and  acquisitions. States must create financial incentives for
municipal systems to acquire smaller systems, otherwise they will  be  unable to gain support
for legislation requiring the takeover  of financially troubled systems.
       Devising an appropriate  financial incentive will require the input of numerous interested
parties.  Possible financial incentives could  include:

o     reduced interest rates from State bond authorities on bond issuances by municipalities
       whose water system agrees to acquire a troubled smaller system;

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o      State tax credits for private utilities that agree to acquire or merge with another system;

o      reduced or waived fees by the drinking water program.

       Massachusetts' Department of Environmental Protection is working on a new fee-for-
services program which, because it  exempts municipal systems,  is itself an incentive  for
smaller systems to merge with a public system.  The program's proposed fees — for example,
an annual compliance  fee of up  to $4500 per system —  may  deter smaller  systems from
remaining independent  and encourage them to merge or be  acquired by an existing municipal
system.
       If coordinated with the primacy program, reviews by  the Public Utility Commission can
help ensure  that a  merger or acquisition will alleviate the  problems the small system faced
prior to restructuring.  However, most State PUCs do not have jurisdiction over all sizes and
types of public water systems. Therefore, this type of cooperation may be limited to certain
system categories.  As mentioned in the previous section on financial viability,  State drinking
water programs may find the development of an interagency Memorandum of Understanding
with the PUC will  facilitate  this process.

1.   Patrick  Mann,  G.  Richard  Dresse,  "Commission  Regulation  of Small Water  Utilities:
Mergers and Acquisitions," NRRI, Chapter 4.

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                                                           Appendix H
                               EXHIBIT A
                         MEMORANDUM OF  AGREEMENT

This agreement  is  between Waterguard,  Inc.  (Waterguard) and


Statement Of  Intent -   It is the intent of  this agreement  for Water-
guard to provide and       to receive  the professional services of a
part time state-certified Class I water system operator (Operator).
Only the services  described in this Agreement or those later appended
by written mutual  consent are incorporated  in this Agreement. This Ag-
reement is intended to  assist       in its  basic compliance with Oregon
state laws and  regulations pertaining  to minimum operating standards
for community water systems.

RESPONSIBILITIES
  Waterguard -  Waterguard will provide and  supervise the services of an
Operator who possesses  a valid Class I certificate of competency issued
by the State of Oregon.  The Operator will  perform or provide for the
performance of  water system services as mutually agreed upon and
authorized under State  of Oregon Class I Water Distribution certifica-
tion.  Such services are limited to those necessary to consistently
satisfy the minimum health standards of the State of Oregon for com-
munity water systems.    The basic Operator services mutually agreed upon
as of the date  hereof are itemized in the ensuing section entitled
"Specific Services".  The services will be  provided on a mutually
agreed-upon schedule.    Additional services  may be added to this Agree-
ment from time  to  time  by written consent of Waterguard and
  	 -       as owner of the water system will provide guidance and
direction to the Operator to the extent necessary for timely decisions
and direction on any action,  expenditure or work needed to keep the
system in compliance with State health standards for community water
systems.
        agrees  to  take whatever steps are required by federal and state
law and Oregon  Health Department regulations to keep the system in
compliance with all current and future community water system minimum
standards.
        agrees  that the physical plant, assets, liabilities and legal
obligations connected  with the ownership and operation of the system
are its exclusive  responsibility and not-that of the Waterguard or
Operator.
        acknowledges that insurance coverage desired L^       in
connection with this Agreement,  including but not limited to errors and
omissions coverage, will be the responsibility of

SERVICE FEES
  Waterguard -       will pay $40.00 per hour exclusive of travel time,
for the Operator's services.   Waterguard agrees to itemize its charges
and bill        monthly  for Operator services.  Billings shall be in
one-quarter hour increments.

                                  (1)

                               Cont ir.ued

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Memorandum Of  Agreement  (continued)

                will  pay all agreed upon Waterguard billings for
Operator services within 30 days of receipt.
        will periodically review the Operator's work, reports and
recommendations and promptly advise the Operator of any changes in the
scope or nature of services it desires.

HOLD HARMLESS  AGREEMENT
  Indemnification -       will hold harmless and indemnify Waterguard,
and its officers, agents, and employees against any claim, liability,
or expense incurred by Waterguard arising out of its work under this
agreement, except to  the extent that the claim, liability or expense
arises out of  alleged negligent or intentionally wrongful actions or
failures to act of Waterguard or its officers, agents or employees.

EXCLUSIONS
  LABORATORY SERVICES - All  laboratory charges for testing, analysis or
evaluation of  the quality/qua.-.tity of the system's water will be in
addition to the fees mentioned in this Agreement.

  SYSTEM REPLACEMENT,  OPERATION AND REPAIR COSTS - all system replace-
ment,  operation and repair costs will be the responsibility of Villa.

SPECIFIC SERVICES
  The  Operator will advise       on the requirements necessary to keep
the system in compliance with all laws and regulations.   The Operator
//ill  perform or provide, consistent with reasonable and  customary
standards,  all basic community water system operational  and management
services required to keep the system in compliance with  the following
requirements as well as any  other requirements arising out of laws or
regulations hereafter  existing:
  1.    Responsibilities Of Water Supplier as required by OAR 333-61-025
       (attached);
  2.    Maximum Contaminant Levels as required by OAR 333-61-030 (at-
       tached )  ;
  3.    Sampling And Analytical Requirements as required  by OAR 331-61-
       035  (attached);
  4.    Reporting,  Public Notification And Record Keeping as
       required by OAR 333-61-040 (attached);
  5.    Construction Standards as required by OAR 333-61-050 (attached);
  6.    Plan Submission And Review Requirements as  required by OAR 333-
       61-060;
  7.    Operation And Maintenance as required by OAR 333-61-065 (at-
       tached)  ;
  8.    Cross Connection Control Requirements as required by OAR 333-61-
       070  (attached);
  9.    Fluoridation as required by OAR 333-61-085  (attached);
  10.   Product Acceptability Criteria as required  by OAR 333-61-087
       (attached).

                                  (2)

                               Continued

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                                                         AppendixH

Memorandum Of Agreement  (continued)

The OAR Chapter  333 sections listed above and any subsequent changes
made to them are by this reference included in and made a part of this
agreement.

DESIGNATION OF OPERATOR
  Waterguard hereby designates Don Weidner as the Operator to perform
the services described in this aareement.  Waterguard agrees to notify
      in writing and obtain         written agreement prior to making
any changes in its Operator designation.

ADDITIONAL SERVICES
  This Agreement may be modified, expanded or limited at any time by
the written mutual consent of both       and the Waterguard.  Notice of
a proposed change will be given by the proposing party to the other
party at  least 30 days prior to the effect of the proposed change.

OFFICIAL CORRESPONDENCE
  Waterguard and       agree to designate an official address and
telephone number to which each may send all official communications to
the other.  Both parties to this agreement will promptly advise the
other of any changes in addresses and phone numbers.

TERMINATION OF AGREEMENT
  This Agreement can be terminated by either party with 30 days written
notice to the other party.   Waterguard will be paid for all services
provided to       hereunder prior to receipt of notice of termination
or to such later date as the notice may specify.

EFFECTIVE DATE
  This agreement will be effective as of


            Signed  	
                                Title

            Signed  	
                                          Date


                           Title
                                  (3

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                                                                       Appendix  I
WATERGUARD, INC-OAM CONTRACTING
       SUMMARY:  Waterguard demonstrates how small systems in Oregon use O&M
       contracting to obtain regulatory advice, routine testing, and maintenance
       work, as wefl as financial analysis, rate-setting advice, and bookkeeping.
      To found Waterguard, die owner obtained a list of die regulated systems in Oregon,
targeted die ones serving fewer than 300 connections, and sent diem flyers announcing the
services he could offer.  A few systems responded immediately, but not until the mandatory
certification law was passed did Waterguard acquire a substantial  number of clients.
Waterguard currently has contracts with 32 systems, of which about half are mobile home
parks.  The rest include educational institutions and sub-divisions. The average size of a
mobile home park served by Waterguard is approximately 100 connections, while the
average size of a sub-division is approximately 50 connections.

      Waterguard offers a wide variety of services to small water systems.  The company
performs routine maintenance,  monitoring and reporting (for bacd and turbidity), and
system repairs.  It also provides management services such as financial analysis, rate-setting
advice, and bookkeeping.  Furthermore, Waterguard will help small systems comply with
new State drinking water regulations.  For example, die firm will  write die annual report
that State  law requires from each operator. Waterguard also provides emergency assis-
tance.

      When Waterguard is hired by a small water system, both parties sign a Memoran-
dum of Agreement.  An example of the Memorandum is provided in Appendix A.

      On average, Waterguard charges its systems $90.00 per month for routine O&M.
                                             FOR INFORMATION CONTACT:

                                     Jim Boydston, Manager
                                     Drinking Water Program, Health Division
                                     1400 S.W. 5th Avenue, Rm. 611
                                     Portland,  OR 97201
                                     903-229-6310
                                         8

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WASTEWATER SERVICES, INC.-OAM CONTRACTING
     SUMMARY:  Wastewater Services is another example of an O&M contracting
     company used by small systems to improve compliance with SDWA and State
     regulations.
      Wastewater Services was created 13 years ago by a certified operator to provide
contractual assistance to small public water systems.  Currently, Wastewater Services has 30
employees and has contracts with approximately 20 systems in western North Carolina.
Most of the contracts are with  systems that have fewer than ISO connections.

      Wastewater Services offers a w.de variety of services to small systems, but it r    ly
performs monitoring and reporting,   -astewater Services has a laboratory to provide    ting
for bacteriological and inorganic contaminants.  Additionally, if systems need infrastructure
work, the company has a construction section.  Wastewater Services does not,  however,
provide financial services such as rate-setting or bookkeeping advice.

      The fees depend on the services provided.  The average cost of a certified operator
who will be responsible for routine O&M functions is $250 per month.
                                             FOR INFORMATION CONTACT:
                                     Bob Barr
                                     Wastewater Services, Inc.
                                     P.O. Box 18029
                                     Asheville, NC 28814-0029

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                                                                       Appendix  T
CROSBY WATER AND SEWER SERVICES, INC-OftM CONTRACTING
      SUMMARY:  Crosby Water and Sewer Services is an example of how a mobile
      home park owner became a certified operator and created a business
      providing O&M services to other nearby system owners.
      Crosby Water and Sewer Services was created by a mobile home park owner who
had experienced difficulty in operating her water system. After she became certified, a few
neighboring systems informally asked her for assistance.  In 1985, she and her husband
decided to start a water and wastewater service business. Today, they assist approximately
19 wastewater and 19 water systems.  The company consists of four full-time  certified
operators who serve systems within a 35-mile radius, mainly in Wake County.  Most of
Crosby's contracts are with mobile home parks and housing developments that have an
average size of 75 service connections.

      According to Crosby, each customer has a unique set- of service requirements.  In
general, they provide monitoring, reporting,  and routine maintenance work.  There is at
least one system that they completely manage. For this  system they read meters, handle
customer billing, and perform  routine O&M  work.  Crosby also provides emergency
assistance to any system it serves.  There is a 24-hour answering service that systems may
call when a problem arises.  Before Crosby performs any major work, it makes recommen-
dations and obtains approval from the system. The firm usually is authorized to incur up
to $100 in costs without seeking approval.

      Crosby's fees depend on the services performed.  For routine O&M work, it charges
approximately $100 per month.  For a system that it completely manages, Crosby charges
$550 per month.
                                             FOR INFORMATION CONTACT:

                                       Don Williams
                                       Regional Engineer, Drinking Water Division
                                       Fayetteville, NC
                                       919-486-1191
                                         10

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SOUTHERN NEW HAMPSHIRE WATER COMPANY-SATELLITE MANAGEMENT
       SUMMARY:   Southern New Hampshire Water Company is an example of a
     large water utility providing O&M services to a small municipal water system
     through a satellite management program.
      In late 1989, Southern New Hampshire Water Company and Deny Waterworks
entered into a satellite management arrangement.  Southern New Hampshire is a large
utility that provides water to many dries in southern New Hampshire.  Deny Waterworks is
a small municipal system that wanted to contract out for O&M services.   Previously, Deny
used private service companies for O&M services.  This year, however, Southern New
Hampshire had the lowest bid for services and was awarded the contract.

      Southern New Hampshire provides Deny with operations and maintenance services.
A contract between the two companies specifies the services to be rendered. These
include: providing a certified operator, performing daily operations; reading meters;
performing sampling,  monitoring, and reporting; and implementing backflow prevention.
Deny performs all other system functions.

      Southern New Hampshire Water Company charges an hourly fee.  Information on
specific fees  is confidential.
                                            FOR INFORMATION CONTACT:

                                    Larry Gingrow
                                    Southern New Hampshire Water Company
                                    322 Nashua Rd.
                                    Londonderry, NH 03053
                                    603-882-3322
                                        12

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                                                                    Appendix i


PUBLIC UTILITY DISTRICT NO. 1 OF KTTSAP COUNTY-SATELLITE MANAGEMENT
    SUMMARY:  Public Utility District No. 1 of Kftsap County is an example of a small
    Homeowner's Association contracting widi a large public water system for a
    comprehensive  system assessment.
       Public Utility District No. 1 of Kltsap County, Washington is a public water system
which serves approximately 4/XX) people. As a PUD, the system has jurisdiction over the
entire county and is able to borrow money, contract indebtedness, issue bonds, and levy
taxes.  Currently, the PUD owns and operates a number of small water systems in the
county and has just begun to provide contract O&M services.

       The Sandy Hook Community Club, a Homeowner's Association  in Poulsbo,
Washington  recently contracted with PUD No. 1 for a comprehensive assessment of its
water system.  Sandy Hook needs assistance in determining what system improvements
should be made in order to deliver better water quality to its 75 residences.  PUD No. 1
was contracted to do die following: document above-ground problem areas; evaluate the
steel main and water services to determine approximate conditions below ground; revisit
the source and storage locations  to evaluate die physical and mechanical operations; and
prepare a report detailing findings and recommendations to reserve system deficiencies.
The contract is short-term; the services will be completed widiin 45 days of die final
signature date. Once die assessment is completed, Sandy Hook may agree to have the
PUD perform die necessary improvements.  It may also agree to have the PUD assume
long-term management of the system.

       All labor and professional  hours will be billed hourly.  All materials and equipment
that die PUD uses in executing the contract will be billed at cost plus  10 percent for
handling.  The contract stipulates diat die total cost of services cannot, however, exceed
$500.00.
                                             FOR INFORMATION CONTACT:

                                     David Siburg, Assistant Manager
                                     PUD No. 1 of Kltsap County
                                     1431 Finn Hill Road
                                     Poulsbo, WA 98370
                                     206-779-7658
                                         13

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                                                                      Appendix J



 WASHINGTON COUNTY SANITARY DISTRICT-PUBLIC ACQUISITION
      SUMMARY:  The following case study shows how a State can require a public
      merger a* a way of solving small system problems.  In this case study, a
      municipal water system extension was ordered by die primacy agent to provide
      safe drinking water to residents outside die boundary of die publicly owned
       Maryland requires each county to develop a plan of its water systems' operations,
including satellite programs and mergers.  Tbe State also haftJDft.Jta|uipry «utivxky »^ *
require a public water system to be constructed or for an nffrnsipjt ID occur.

       In 1981, residents of the Martin's Crossroads-Cearfoss  area of Washington County
experienced an outbreak of Hepatitis A due to bacteriological contamination. After
detennining that water quality problems could not be corrected by die existing systems, the
Maryland Department of Environment (MDE) ordered Washington County to develop a
feasibility study for ntrwHng water service from die dry of Hagerstown water system to
die Martin's Crossroads-Cearfoss area, to develop a construction schedule, and to imple-
ment the extension by a specified date. The Martin's Crossroads-Cearfoss area contained
218 homes at die time of die order.

       The county plan examined all options for complying with the order and determined
the most cost-effective method of meeting current and expected future water demand.
This plan was then submitted to MDE prior to system extension,   ffitiitffur rtHrfti•umisWi(\
were provided from user fees, Washington Gout* JIBUTI i iiiiiii  mil ||i(, ^iiJpBIT
f acffide* Fund.  The  area was included  In die county plan as a*sanitary subcustrict, and all
customers in die designated area were required to hookup to die water system. The cost
of water service fai die new customers  was  equivalent to diat paid by die city's original
customers.        •
                                             FOR INFORMATION CONTACT:

                                     William F. Parrish, Jr.
                                     Water Supply Program, MDE
                                     Point Breeze, Bldg. 40, Rm. 8
                                     2500 Broenlng Highway
                                     Dundalk, MD 21224
                                     301-431-3702
                                         18

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LAKEWOOD VILLAGE-FORMATION OF A PUBLIC SYSTEM
      SUMMARY": The Lakewood case shows how the formation of a publicly-owned
      water system  can allow small systems to finance needed system improvements.
      After obtaining a FmHA loan, the Lakewood system interconnected to and
      purchased water from a neighboring municipal water system.
       Lakewood Village to a subdivision containing approximately 500 single-family homes
it to located two miles south of Des Moines, Iowa. Lakewood's developer sunk a deep wt
to provide water to the community because interconnection with existing systems was not
feasible.  The water contained high levels of dissolved minerals and was corrosive.
Residents complained about staining of clothes, deterioration of plumbing fixtures, period]
water outages, and declining property values as the result of poor water quality.  Because
of high costs, die owners of the subdivision did not fully treat the water and were often
before the public utilities commission,  contesting water rate adjustments with the resident:

       In 1981, some of Lakewood's residents proposed forming a "benefited water distric
and purchasing the system from die developer. Under Iowa law a "benefited water distric
to a quasi-public entity with Its own taxing and bonding authority. As a public system,
Lakewood would be able to purchase water from the Des Moines Water Department,
eliminating die wen and, hence, the source of the problem.  After the residents submitted
petition,  the County Board of Supervisors held  hearings and formed die District without
objection.

       In a special  election, three trustees were chosen and given, by simple majority vote
the authority to incur debt on behalf of the district.  *^jfflftdg*PPl*
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                                                                       Appendix J

 NORTH LAKEPORT-FORMATION OF A NEW PUBLIC WATER SYSTEM
        SUMMARY:  North Lakeport demonstrates how a county can take the initiatf'e
        to consolidate existing small water systems by forming a. regional system.
       The North Lakeport project is located in Lake County, California, and has a
 population of fewer than 90,000 people. The county has a considerable number of small
 resorts, mobile home parks, and subdivisions that have their own water systems. Prior to
 1981, the county had a limited regulatory program for small water systems, most of which
 did little or no treatment.  The county had concerns about the quality of the finished water
 these systems provided.

       In November of 1984 and 1986 the voters of California approved the Safe Drinking
 Water Bond Laws, which provided $150 million of low-interest loans and grants for water
 system construction needed to correct public health problems. The California Department
 of Health Services identified North Lakeport as a potential area for a regional water system
 and the County Special District Office was invited to submit an application for funding.  To
 prepare the application and define die essential projects, the county hired an engineering
 firm to conduct a feasibility study, which was completed in June  of 1985.   The study •
 recommended forming a regional system that would consolidate die 41 **ri«H«fl small
 systems and individual homes which had Inadequate water quality; the Lakeside Community
 Hospital; die County's Juvenile Hall detention facility; four new residential developments;
 and die County's planned minimum-security prison for 500 prisoners.

      On  die basis of die engineering feasibility study the county's application was
 completed and the State  of California made a commitment to provide $5 million in  low-
 interest loans and a $400,000 grant.  Having the necessary funding and technical details, the
 county initiated proceedings to form an assessment district to assure diat the State loan
 could be repaid.  Several public meetings were held to discuss the details of the project
 and its costs.  The County  Health Department maintained that small systems would  need to
 make significant and cosdy improvements in order to comply widi regulations and ensure
 adequate water quality.  The voters in the county decided  that forming a regional system
was die least costly solution and die district was approved in October 1989.  The construc-
 tion of the new regional system began in January 1990.
                                              FOR INFORMATION CONTACT:
                                      B. David dark, P.E.
                                      District Engineer
                                      Office of Drinking Water
                                      Santa Rosa District Office
                                      50 D Street, Room 205
                                      Santa Rosa, CA 95404
                                      707-576-2729
                                         20

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ACQUISITION OP GREENACRES WATER SUPPLY-PRIVATE MERGERS
      SUMMARY:  The Greenacres case study shows the combined efforts of the PUC
      and primacy agency to require a takeover in order to alleviate water systems
      non-viability.
       Greenacres Water Supply had difficulty complying with a DOHS order to submit a
plan for improvements to enhance water quality and increase water supply. Greenacres'
owners did not have the resources to comply with the order and notified  DOHS that they
wanted to leave die water business.  DOHS asked DPUC to conduct a hearing about the
system. During the hearing, two water companies, Bridgeport Hydraulic Company (BHQ
and Tyler Lake Water Company, expressed interest in purchasing and operating Greenacres
as a satellite system. Although  the owners of Greenacres and Tyler Lake negotiated a
purchase price of 110,000 for the system, the Consumer Counsel  opposed the price as
excessive.  After examining the  financial records of Greenacres and considering the
improvements that  the system required, DOHS and  DPUC determined that Bridgeport
Hydraulic was a "more suitable  entity" to own and operate Greenacres.   .

       The joint decision addressed several points raised during the proceedings.  The
examination of Greenacres' financial records and the cost estimates for the system upgrade
revealed that a reasonable acquisition cost was only $617, primarily because of the large
outstanding debt that the acquirer would have to assume and the poor condition of the
system. BHC was. ordered to spread the COM
$191,000) among its 96,000 customers in order Ib fCttftrtf" ih< tuamM UmJLH?ofthe-»
upgrade on the Greenacres customent The approved acquisition costs, not including the
original net cost of the plant, was required  to be charged to a deferred debits account for
amortization over four years. DOHS and DPUC decided to allow BHC to include unamor-
tizcd acquisition costs in its rate base, as the company had requested.

      DOHS and DPUC ruled that Greenacres customers should be billed at  their old rate
until all the residences had been metered.  Then BHC could bill them at the  same rate as
its other customers in the area.  BHC was also given a schedule for system improvements
and was required to submit certain financial information to DPUC.  The company was also
required to notify the Greenacres customers of its ownership.

      Connecticut's takeover legislation allowed the State to facilitate acquisition by a
privately owned utility to correct the problems of a non-viable system.  The State acquisi-
tion hearing on Greenacres determined the following: who should take over the failing
system; the acquisition cost; what system improvements  must be undertaken by the
acquiring system; and what rates the customers of the acquired system should be charged.
                                             FOR INFORMATION CONTACT:

                                      Richard Albani
                                      DPUC, Water Section
                                      One Central Park Plaza
                                      New Britain, CT 06051
                                      203-827-1553
                                         23

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                                                                      Appendix  j

ACQUISITION OF HELMS, INC.-PRIVATE MERCERS
       SUMMARY: The acquisition of Helms, Inc., a small privately-owned water system,
     by Connecticut Water Company (CWC) shows how the State primacy agent and
     the PUC can jointly order water systems to act as receivers, to implement specific
     system improvements on a time schedule, and to acquire other water systems.
       Under Connecticut General Statutes 16-262, the Department of Health Services
(DOHS) and the Department of Public Utility Control (DPUC) called a hearing to find a
suitable water company to acquire the two divisions of Helms, Inc., Nathan Hale and
Lakeview in Coventry, Connecticut.  These two water systems had a history of repeated
outages, and the owners of Helms,  Inc. had failed to comply with seven Administrative
Orders from DPUC and DOHS.  These systems had severe engineering deficiencies, and
had an old, poorly maintained system in need of reconstruction. No corrective  action was
being taken by the owners.

       Helms, Inc. provided water to  169 unmetered residential customers and  10 seasonal
customers.  There were no treatment  facilities at either Nathan Hale or Lakeview.  The
owners had difficulty maintaining contracts with licensed pump companies, resulting in
periods during which no maintenance took place.

      A temporary receiver had previously been appointed under  CGS 16-2621, who
incurred liabilities for the maintenance of the system. DPUC and DOHS subsequently
recommended that the CWC acquire Helm, Inc. CWC was required to pay the  receiver an
amount equal to his liabilities; this amount was added to the cost of acquisition that CWC
was allowed to recover through  its rates.

      Two years after the Joint Hearing, the former Helms customers were being charged
a flat rate of 1307.80 per year as stipulated in the Decision.  When system upgrades are
completed, customers will be metered and charged the same rate as all other CWC
customers, which in 1988 was $315 per 72,000 gallons of water per household.
                                             FOR INFORMATION CONTACT:
                                     Richard Albani
                                     DPUC, Water Section
                                     One Central Park Plaza
                                     New Britain, CT 06051
                                     203-827-1553
                                        24

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                                                              Appendix Y
                                                  PRINTER'S NO. 27
                  THE GENERAL ASSEMBLY OF PENNSYLVANIA
                    HOUSE  BILL
                     NO.  25
Session of
  1989
    INTRODUCED BY LLOYD,  BATTISTO, D. R. WRIGHT,  NOYE, HALUSKA,
       GIGLIOTTI, VEON, HASAY, STABACK, KOSINSKI,  G. SNYDER,
       E.  Z. TAYLOR, KUKOVICH, BELFANTI, TIGUE,  CAWLEY, STUBAN,
       ITKIN AND COLAIZ20,  JANUARY 18, 1989
    REFERRED TO COMMITTEE ON CONSUMER AFFAIRS, JANUARY 18, 1989
                               AN ACT
 1  Amending Title 66 (Public Utilities) of the  Pennsylvania
 2     Consolidated Statutes, providing for the  commission to order
 3     the acquisition of  small water and sewer  utilities.
 4     The General Assembly  of the Commonwealth  of Pennsylvania
 5  hereby enacts as follows:
 6     Section 1.  Title 66  of the Pennsylvania  Consolidated
 7  Statutes is amended by adding a section to read:
 8  §  529.  Power of commission to order acquisition of small  water
 9            and sewer utilities.
10     (a)  General rul«*—The commission may order a capable  public
11  utility to acquire a aaall water or sewer utility if the
12  commission, after notice and an opportunity  to be heard,
13  determines;
14        (1)  that the small water or sewer utility is in
15     violation of statutory or regulatory standards which affect
16     the safety, adequacy, efficiency or reasonableness of the
17     service provided by the small water or sewer utility;

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  1          (2)  that the small water or sewer  utility  has  fai'ed  •
  2      comply, within a  -?asonable period of time,  wj;.-.  anv  -rder
  3      the  Department of Environmental Resources or  the  commissicr
  4      concerning the safety, adequacy, efficiency  or  reasonabler.e
  5      of service, including, but not limited  to, the  availability
  6      of water, the potability of water, the  palatability of  vate
  7      or the provision of water at adequate volume  and  pressure;
  8          (3)  that the small water or sewer  utility  cannot
  9      reasonably be expected to furnish and maintain  adequate,
10      efficient,  safe and reasonable service  and facilities in tt
11      future;
12          (4)  that alternatives to acquit  .on have  been
13      considered in accordance with subsect.on (b)  and  have been
14      determined by the commission to be impractical  or not
15      economically feasible; and
16          (5)  that the rates charged by the acquiring  capable
17     public utility to its preacquisition customers will not
18      increase unreasonably because of the acquisition.
19      (b)   Alternatives to acquisition.—Before the commission ma
20  order the acquisition of a small water or sewer  utility in
21  accordance with subsection (a),  the commission shall  discuss
22  with the small water or sewer utility, and shall give such
23  utility a reasonable opportunity to investigate, alternatives
24  acquisition,  including, but  not  limited to;
25         (1)  The reorganization of the  small water or  sewer
26     utility under  new management.
27         (2)  The entering of  a contract with another public
28     utility or  a management or service  company to operate  the
29     small water  or sewer utility.
30         (3)  Th   appointment  of a  receiver to assure the
                                 - 2  -

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                                                                Appendix  v
  I     provision of adequate, efficient, 5a:e and reasonable service
  2     and facilities to the public.
  3         (4)  The merger of the small water or sewer utility with
  4     one or more other public utilities.
  5         (5)  The acquisition of the small water or sewer utility
  6     by a municipality, a municipal authority or a cooperative.
  7     (c)  Factors to be considered.—In making a determination
  8  pursuant to subsection (a), the commission shall consider:
  9         (1)  The financial, managerial and technical ability of
10     the small water or sewer utility.
11         (2)  The financial, managerial and technical ability of
12     all proximate public utilities providing the same type of
13     service.
14         (3)  The expenditures which may be necessary to make
15     improvements to the small water or sewer utility to assure
16     compliance with applicable statutory or regulatory standards
17     concerning the adequacy, efficiency, safety or reasonableness
18     of utility service.
19         (4)  The expansion of the franchise area of the acquiring
20     capable public utility so as to include the service area of
21     the small water or sewer utility to be acquired.
22         (5)  Any other matters which may be relevant.
23     (d)  Order of the commission.—Subsequent to the
24  determinations required by subsection (a), the commission shall
25  issue an  order for the  acquisition of the small water or sewer
26  utility by a capable public utility.  Such order shall provide
27  for the extension of the  service  area of the acquiring public
28  utility.
29     (e) Acquisition  prict.—The price for the acquisition of the
30  small water or sewer utility shall be determined by agreement
                                 - 3  -

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 1  between the small  water  or  sewer utility and the acquiring
 2  capable public utility,  subject So a determination by the
 3  conunissior  -hat the  price is reasonable. If the small water or
 4  sewer util^sy and  the acquiring capable public utility are
 5  unable to agree on the acquisition price or the commission
 6  disapproves the acquisition price on which the utilities have
 7  agreed, the commission shall issue an order directing the
 8  acquiring capable  public utility to acquire the small water or
 9  sewer utility by exercising the power of eminent domain pursuant
10  to the act  of June 22, 1964 (Sp.Sess.,  P.L.84, No.6), known as
11  the Eminent Domain Code.
12     (f)  Separate t  .ffs.—The ccmnission may, in its discretion
13  and for a reasonable period of tir.e after the date of
14  acquisition,  allow the acquiring capable public utility to
15  charge and  collect rates from the customers of the acquired
16  small water or sewer utility pursuant to a separate tariff.
17     (g)  Appointment  of receiver.—The commission may, in its
18  discretion, appoint  a receiver to protect the interests of the
19  customers of the small water or sewer utility. Any such
20  appointment shall  be by  order of the commission, whic- order
21  shall specify the  duties and responsibilities of the  :ceive
22     (h)  Notice.—The notice required by subsection (a; or any
23  other provision of this  section shall be served upon the small
24  water or sewer utility affected, the Office of Consumer
25  Advocate, the Office of  Trial Staff/ the Department of
26  Environmental Resources, all proximate public utilities
27  providing the same type  of  service as the small water or sewer
28  utility, all proximate municipalities and municipal authorities
29  providing the same type  of  service as the small water or sewer
30  utility, and the municipalities served by the small water or
                                 - 4 -

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                                                                 Aooer.dix
  1   sewer utility. The commission shall order the affected small
  2   water or sewer utility to provide notice to  its customers of the
  3   initiation of proceedings under this section in the same manner
  4   in which the utility is required to notify its customers of
  5   proposed general rate increases.
  6     (i)  Burden of proof.—The Law Bureau shall have the burden
  7   of establishing a prima facie case that the  acquisition of the
  8   small water or sewer utility would be in the public interest and
  9   in compliance with the provisions of this section. Once the
10   commission determines that a prima facie case has been
11   established;
12         (1)  the small water or sewer utility shall have the
13     burden of proving its ability to render adequate, efficient,
14     safe and reasonable service at just and reasonable rates; and
15         (2)  a proximate public utility providing the same type
16     of service as the small water or sewer utility shall have the
17     opportunity and burden of proving its financial, managerial
18     or technical inability to acquire and operate the small water
19     or sewer utility.
20     (j)  Plan for improvements.—Any capable public utility
21  ordered by the commission to acquire a small water or sewer
22  utility shall, prior to acquisition, submit to the commission
23  for approval a plan, including a timetable, for bringing the
24  small water or sewer utility into compliance with applicable
25  statutory or regulatory standards.  The capable public utility
26  shall also provide a copy of the plan to the Department of
27  Environmental Resources and such other State or local agency as
28  the commission may direct. The reasonably and prudently incurred
29  costs of  each improvement shall be recoverable in rates only
30  after that improvement becomes used and useful in the public
                                 - 5 -

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 1  service.
 2     (k)  Limitations on .lability.—Upon approval by the
 3  commission of a plan for  improvements submitted pursuant to
 4  subsection (j)  and the acquisition o£ a small water or sewer
 5  utility by a capable public utility,  the acquiring capable
 6  public utility shall not  be subject to any enforcement actions
 7  by State or local  agencies which had notice of the plan and
 8  shall not be liable for any damages beyond the aggregate amount
 9  of $50,OOP, including a maximum amount of $5,000 per incident,
10  if the cause of those damages or the basis of such enforcement
11  action is proximately related to identified violations of
12  applicable statutes or regulations by the small water or sewer
13  utility. This subsection  shall not apply;
14         (1)  beyond the end of the timetable in the plan for
15     improvements;
16         (2)  whenever the  acquiring capable public utility is not
17     in compliance with the plan for improvements; or
18         (3)  i£> within 30 days of having received notice of the
19     proposed plan for improvements, the Department of
20     Environmental Resources submitted written objections to the
21     commission and  those objections have not subsequently been
22     withdrawn.
23     (1)  Definitions.—As  used in this section, the following
24  words and phrases  shall have the meanings given to them in this
25  subsection;
26     "Capable public utility."  A public utility which regularly
27  provides the same  type of service as the small water utility or
28  the small sewer utility to 4,000 or more customer connections,
29  which is not an affiliated interest of the small water utility
30  or the small sewer utility, and which provides adequate,
                                 - 6 -

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                                                               Aoper.dix
  L  efficier.:, safe and  reasonaole  service.
  2     "Small sewer utility."  A oublic  utility  which  regularly
  3  provides sewer service  to  1,000  or  fewer  customer  connections.
  4     "Small water utility."  A public  utility  which  regularly
  5  provides water service  to  1,000  or  fewer  customer  connections.
  6     Section 2.  This  act  shall take  effect in 60  days.
L15L66JRW/19890H0025B0027        - 7  -

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                                                                    Appendix T,
NEHA
Environmental   Healthjrencls  Report
    Volume 3, Number 4
                                  Fall Quarter 1989
                  Ensuring   Safe   Drinking  Water
                 New Challenges for  Local  Health  Officials
    Passage of the 1986 Safe Drink-
    ing Water Act (SDWA)  Amend-
    ments marked the dawn of a new
    era in the protection of America's
    drinking water. The amendments
    mandate a sweeping and compre-
    hensive regulatory program to
    ensure the uniform safety of drink-
    ing water for all Americans served
    by public water systems, at home,
    at school, at work, or on the road.

      The U.S. EPA Office of Drinking
    Water (ODW) recognizes the seri-
    ousness of the challenge it faces in
    turning the 1986 amendments into
    reality. To meet the challenge,
    ODW has undertaken a broad and
    far-reaching "Mobilization" effort.
    The basic concept behind Mobili-
    zation is expressed  by the adage
    "Many hands make light work."
    Through Mobilization, ODWhopes
    to bring the talents and resources
    of all groups and organizations
    impacted by the drinking water
    requirements to bear on their im-
    plementation.
       Local health officials are a key
    focus of the Mobilization effort,
    since they are in.an excellent posi-
    tion to contribute to the implem-
    entation of the new drinking wa-
    ter requirements. In fact, local
    health officials are critical to the
    successful implementation of
    SDWA. This article is intended to
provide local health officials with
an increased awareness of the new
drinking requirements, and  an
understanding of how they can
best contribute to  successful im-
plementation.
Background

History of the National Drink-
ing Water Program. Prior to
1974, the federal  government
possessed very limited regulatory
authority, and most drinking
water standards and practices
were established by individual
sfates. The first federal drinking
water standards were adopted in
1914, but regulated only those
suppliers serving interstate carri-
ers, for example, passenger trains.
  Because the nature and enforce-
ment of state standards varied
greatly, the U.S. Congress passed
the original 1974 SDWA and es-
tablished the federal Public Wa-
ter Supply (PWS) Program. Ad-
ministered by the U.S. Environ-
mental Protection Agency Office
of Drinking Water, the program
regulates the quality of drinking
water provided by the nation's
public water systems. As shown in
Figure 1,85% of all Americans re-
ceive their drinking water from
water systems subject to regula-
tion under SDWA. The remaining
15% of the population are largely
served by individual, private wells.
 A major goal of the 1974 act was
to provide uniformity and consis-
tency to state regulatory efforts.
Under a management system
known as primacy, states are re-
sponsible for implementing and
enforcing the PWS Program.
 To achieve primacy, each state
must adopt regulatory require-
ments at least as stringentas those
promulgated by EPA and must
have  adequate authority to  en-
force  the requirements.  States
may establish siting, design, con-
struction, and operation require-
ments. Presently, the only states
without primacy are Wyoming,
Indiana, Indian Lands, and  the

Figure 1.
U.S. population served by
SDWA-regulated and non-
regulated systems.
            2«4 M men

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NEHA
 District of Columbia.  The U.S.
 EPA is responsible for implemen-
 tation  and enforcement in non-
 primacy States.

 The nature of the regulated
 community. There are approxi-
 mately 200,000 public water sys-
 tems  (PWSs) regulated  under
 SDWA. A public water system is
 defined as any system providing
 piped water for human consump-
 tion, and serving 25 or more people
 or 15 or more service connections
 for at at least 60 days per year. As
 shown in Figure 2, there are three
 major categories of public water
 supply systems: community water
 systems; non-transient, non com-
 munity water systems; and tran-
 sient non-community systems.
 Figure 2.
 Regulated universe of Public
 Water Systems.

 Totol PiiXk WcMf eyMBn* « 301442
                        10%
   A  community  water  system
 (CWS) provides water to the same
 people on  a year-round basis.
 CWSs range in nature from large
 urban water systems  to mobile
 home parks and nursing homes
 having their own supply source.
 Two-hundred  and  .twenty-one
 million people receive their house-
 hold drinking water from CWSs.
   As shown in Figure 3, the vast
 majority of the U.S. population is
 served by a relatively small n ..Ti-
 ber of large CWSs, and  these -ys-
 tems are capable of compliance
 without great difficulty.  On the
 other hand,  a minority (11 per-
Figure 3.
Community water systems size
distribution.
 PERCENT
 100
! Percent of Total Public Water Systems
; Percentage of Total Population Served
       Very Small    Small
                                                             Medium     Large   Very Large
                                                          SIZE CATEGORY
cent) of the population is served by
a large  number of small  water
systems. These small systems ac-
count for over 90 percent  of the
violations of current drinking
water requirements.
  Small  and  very  small  CWSs
(those serving fewer than 3,300
persons^, with their smaller and
less dense  service populations,
have difficulty consistently deliv-
ering safe drinking water at af-
fordable prices. These systems are
characterized by low revenues,
high user rates, poor financial

 Figure 4.
 Regulated universe of Community
 Water Systems.
 capabilities,  poor  business  and
 technical management, and a lack
 of engineering/planning  knowl-
 edge.  As shown in Figure 4, ap-
 proximately 40 percent of small
 and very small CWSs are mobile
 home park and homeowner asso-
 ciation systems. These two cate-
 gories  are particularly  trouble-
 some.  Mobile home park systems
 are often neglected by park own-
 ers because water supply is not
 their principal business interest.
 Homeowner association  systems
 are created for water supply provi-
 sion  when  residential develop-
 ments are isolated from larger
 CWSs. Unfortunately, homeowner
 associations lack the technical and
 managerial skills needed to effec-
 tively operate a water system
   A non-transient, non-commun-
 ity water system (NTNCWS), un-
 like a CWS, does not serve a year-
 round population. Rather, it serves
 a daily average of at least 25 of the
 same  individuals for at least six
 months out of the year. The most
 common types of NTNCWSs are
 factories and rural schools having
 their  own well  or other supply

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                                                                           AoDer.cix
source.  Historically, NTNCWSs
were required to meet only those
standards (nitrates and bacteria)
required to prevent short-term
health problems. As discussed in
more  detail later, these systems
are now required to meet the same
standards  as CWSs since their
service populations consist of long-
term users.
  A  transient non-community
water system (TNCWS), like  a
NTNCWS, does not serve a year-
round  community population.
Unlike  a  NTNCWS, it serves  a
transient population of at least 25
individuals daily, that is, the sys-
tem does not serve the same 25 or
more  individuals on a long-term
basis  as do schools and factories.
The   most  common  kinds  of
TNCWSs  include rest stops, res-
taurants, gasoline service stations,
campgrounds, and park facilities.
Unlike  CWSs  and NTNCWSs,
TNCWSs are required to meet only
those standards designed to pre-
vent short-term health problems.
Roles and responsibilities in
the current PWS program. The
ultimate goal of the drinking wa-
ter program is to prevent endan-
germent to human health result-
ing from  the contamination of
drinking  water supplies.  This
'mission requires intense coopera-
tion among U.S. EPA, state pri-
macy agencies, and the regulated
community. Each has a well-de-
fined  and  vital role in the regula-
tory process.
   EPA is responsible for  estab-
lishing regulations'and policy for
national   program oversight.
States are responsible for imple-
menting and enforcing the national
regulations as well as carrying out
their  own programs of plan re-
view,  technical  assistance, and
operator certification.
  Local water suppliers  are
responsible for constructing, oper-
Figure 5.
State shortfall of funds
necessary to implement the
Public Water Supply Program.
          Funding for
     Current PWS Program
                                  Funding for Current and
                                     New Requirements
     [Total • $129 million par year)
                       Currant PWS
                     Program Shortfall
                       $34 Million
            Currant PWS
               n Fund
               Million

              (34%)
                                  {Total • $281 million p«r year)

                              •For th» TWW rtqutrtfnamt, and addtonal $1 BO
                              mikon doflan In orw-tm* eotu i* il«o n*c*tsary.
ating,  and  maintaining  public
water systems capable of compli-
ance with all federal, state 'and
local regulations.
The  State  Drinking  Water
Program capacity problem. As
will be discussed in the next sec-
tion, EPA is developing numerous
new regulations in response to the
mandate  of the  1986  SDWA
Amendments. To retain primacy,
states will have to adopt and en-
force these new regulations. State
Drinking Water Program budgets
must more than double to support
this new work.

 States currently spend about $95
million per year. Of that amount,
states contribute two-thirds and
federal grant dollars constitute the
remainder. Figure 5 indicates that
states need an additional $34 mil-
lion per year just to implement the
current requirements. In addition,
implementation  of the  1986
Amendments will cost the states
$180  million in one-time costs
through 1992, and will lead to an
increase in annual costs of $150
million per year after 1992. Dra-
matic increases in federal subsi-
dies are unlikely, thus states must
build support to substantially in-
crease  their  drinking  water
budgets.
Is the public's drinking water
safe? Recently, EPA's enforcement
of drinking  water requirements
has been  criticized  by some as
insufficient Such allegations have

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Figure 6.
Drinking Water Regulatory Development Schedule.
    Con tmmlnin t/Ptqulnmin t
Final flute"
E/feef/v» D»tff
    Fluonde

    Lead Ban (SOWA 1417)

    Phase 1 Volatile Organics

    Public Notification

    Lead Ban Policy Guidance

    Surface Water Treatment Rule

    Total Coliform Rule

    Lead/Copper

    Phase M 38 Contaminants

    Phase III Radionuclides

    Phase IV Disinfection

    Phase V 25 Contaminants

    Phase VMst list
                     c
    2nd list
         4/86

         6/86

         6/87

        10/87

         9/88

         6/89

         6/89

         1990

        12/90

         1991

         1992

         1991

         1991

         1994
        10/87

         6/86

         1/89

         4/89

         3/89

        12/90,

        12/90

         1991

         6/92

         1993

         1994

         1992

         1993

         1996
    • As of June 1989
    - All dates after January 1990 am estimated.
    — EPA Rules are generally effective 18 months after being finalized.
       Stats rules are required to be adopted by the EPA effective date.
received considerable media cov-
erage over the past year. As a
result, citizens have confronted
their water suppliers and local
health departments to determine
whether  such problems  exist
locally.
  EPA's compliance data (the same
data upon which the negative alle-
gations are based) indicates that
America's drinking water is very
safe. In 1987 and 1988,75 percent
of the 60,000 CWSs met all drink-
ing water regulations all of the
time. More than 180 million Ameri-
cans  received  their water from
systems in full compliance. Of the
41  million people  whose CWSs
violated the regulations  at least
once, only about 10 percent were
served  by systems with signifi-
The New Program

Since the passage of the original
Safe Drinking Water Act (SDWA)
in 1974, and up through 1985,
U.S. EPA adopted National Pri-
mary Drinking Water Regulations
(NPDWRs) for 26 contaminants.
In 1986, SDWA was comprehen-
sively amended to greatly increase
the scope and stringency of the
PWS Program and the national
drinking water regulations. Fig-
ure 6 displays the  schedule for
regulatory changes r   .liredbythe
1986 Amendments.    brief, U.S.
EPA is required to rr.ake the fol-
lowing changes to the PWS Pro-
gram and the NPDWRs:

• Increase to nearly 200 by the
  year 2000, the number of regu-
  lated contaminants (see Figure
  7).

• Require water systems to moni-
  tor over 100 yet  unregulated
  contaminants.

• Require filtration for nearly all
  surface water systems, and dis-
  infection for all surface wate-
  and many g~5undwater system
  cant compliance problems. Most
  systems that experienced compli-
  ance problems, corrected those
  problems within one month. In
  most cases, they simply failed to
  test their water for contaminants,
  and were not in direct violation of
  a health standard. For large sys-
  tems that must test hundreds of
  samples each month, missing even
  a single sample is recorded as a
  violation.
   Small and very small systems
  are the most frequent violators. In
  1988, small system violators out-
  numbered larger violators by 11 to
  1. Also, the greatest percentage of
  violators are not  located in the
  continental U.S., but are located
  in Guam, the Virgin Islands, and
  other Territories.
                    • Ensure th.
                      based mo.
                      materials
                      men ted.
              ». new ban on lea
                pipe, and  fl -
             j properly  imple-
                    • Take action in response to bol-
                      stered enforcement powers.
                      Furthermore, in 1988 Congress
                    passed the Lead Contamination
                    Control Act which requires U.S.
                    EPA to maintain an updated list
                    of water coolers with lead-based
                    components, and to develop guid-
                    ance for controlling the lead con-
                    tamination  of  school drinking
                    water.
                    The health basis for drinking
                    water requirements. SDWA re-
                    quires all NPDWR standards to be
                    health-based, and establishes the
                    rationale that EPA must use when
                    developing  those standards. A

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                                                                           Appendix  L
                                                                                 Trends
health-based standard must be
adopted for each regulated  con-
taminant and must consist of ei-
ther a Maximum Contaminant
Level (MCL), or a treatment tech-
nique requirement. An MCL is the
contaminant concentration level
that legally cannot be exceeded in
treated drinking water. If it is not
feasible to detect the contaminant
in drinking water, a treatment
technique requirement is  estab-
lished in lieu of an MCL.

  In establishing an MCL, EPA
must first develop an MCL Goal or
MCLG. The MCLG reflects  the
concentration level at which there
is no  known or anticipated  ad-
verse health effect, based upon a
lifetime consumption of drinking
water at the MCLG, concentration.
The MCL is then set as close to the
MCLG as feasible. Feasible means
the treated  water concentration
that can  be achieved using  the
best treatment technology (taking
cost into consideration) available.
It is important to note that much
emphasis  is being placed upon
long-term health effects. In fact,
the standards for regulated  con-
taminants are being set at very
low levels in order to ensure a
lifetime of protection against both
acute and chronic health effects.
Figure 7.
Contaminant; regulated pursuant
to the Public Water Supply
Program.
Roles for Local  Officials     owners in the following ways:
Local health  officials  are in an
excellent position to fulfill  key
roles in ensuring safe drinking
water within  their communities.
As a part of their existing activi-
ties  and responsibilities, many
local health officials are already .
involved in some aspect of drink-
ing water protection. The existing
roles of local health officials range
from  technical  assistance  for
household well owners to formal
involvement in the Public Water
Supply (PWS) Program, such as
carrying out inspections of public
water systems.

  Of course, the  future roles as-
sumed by local health officials will
vary from place to place and  de-
pend upon many factors, includ-
ing most importantly  1) the re-
sources available to local health
departments,  2) the nature of in-
dividual state PWS programs, 3)
the presence oflegal barriers which
prevent state PWS programs from
delegating drinking water authori-
ties to local governments, and 4)
thtfnterest of local health officials
themselves. The EPA Office of
Drinking Water has  identified
three general areas of activity
where local health  officials can
take on key roles.

Working with household well
owners. Most local health offi-
cials are already involved with
private well owners. Private wells
serving individual households are
not subject to  the federal drinking
water requirements, and in most
cases, regulation occurs only at
the local level. Nonetheless, EPA
is concerned about the welfare of
household well  owners,  and de-
sires to be certain that they bene-
fit from the agency's understand-
ing of health  risks related to the
consumption  of contaminated
drinking water. Local health offi-
cials can  assist houshold  well
• By answering questions and
  conducting proactive education
  programs addressing the health
  risks associated with drinking
  water contaminants, especially
  those common to the local area.
• By providing information and
  technical assistance to  well
  owners with respect to water
  sampling and analysis, includ-
  ing the interpretation of labora-
  tory results.

• By providing advice with re spe ct
  to- what type(s)  of  household
  treatment devices can be used to
  prevent the consumption of con-
  taminated water.

• By educating well owners and
  the community at large about
  groundwater protection (a form
  of pollution prevention).   And
  also by providing local residents
  with a better understanding of
  the impacts  on  groundwater
  caused by septic tank placement
  and maintenance, and various
  forms of land use such as agri-
  cultural and livestock,  under-
  ground  storage  of  petroleum
  products and other  chemicals,
  and the improper handling and
  disposal ofhousehold chemicals.
Informing Public Water  Sys-
tem consumers  As  previously
discussed, most of our  nation's
population—about  85 percent—
receives household drinking wa-
ter  from public water systems.
Most of the water that is consumed
away from the home—at school, at
work, or in public places such as
restaurants and parks—is also
provided by public water systems.
Each new rule and regulation that
appb'es to public water systems
will directly affect the  average
citizen. As a result, public water
system consumers will have more
questions and concerns about their
drinking water.

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NEHA
                                                    Irene
  Local health officials can play a
 critical role in their communities
 by answering consumers' questions
 about the importance and impact
 of the new regulations, about the
 public health significance of drink-
 ingwater contamination, and what
 steps,  if any,  area  consumers
 should be taking.

   More  specifically, local health
 officials  can provide such assis-
 tance to customers of public water
 systems  by conducting proactive
 public education programs—in co-
 ordination with area water utili-
 ties and the state PWS program—
 addressing 1) the significance and
 health effects of drinking water
 contamination, 2) the protection
 of drinking water at  the supply
 source, 3) the techniques for con-
 serving drinking water,and 4) the
 need for higher water ra&s in order
 to pay for protection  from long-
 term health effects.
 Assuming a Formal Role In the
 Public Water Supply Program
 As discussed  above,  one  of the
 unfortunate realities confronting
 state PWS programs is a signifi-
 cant lack of funding.
  Local health officials can help
the states with their financial woes
in numerous ways. Most immedi-
ately and importantly, localhealth
officials could help generate sup-
port, amongboth the general public
and state legislators, for increased
state  PWS program resources.
Once the state program secures
additional resources, local health
officials can enter into  formal
agreements with the state. These
agreements would   enable local
health officials to assume certain
state PWS program respc- abili-
ties, such as sampling, insp-   ons,
and some enforcement act:  -.ties.
In brief, the following are various
ways  in which local health offi-
cials can become  more  involved
with the state PWS program:

• By supporting all efforts to in-
  crease the capacity of the state
  PWS Program.

•  By actively  encouraging both
  elected and appointed decision-
  makers  to  support  increased
  resources for their state PWS
  program, and by explaining to
  the public the importance of a
  strongvstate PWS program.
• By supporting state PWS pro-
  gram efforts to resolve small
  water system problems, espe-
  cially the promotion of manage-
  rial consolidation among nearby
  small systems, and helping small
  systems with  understanding
  monitoring  requirements  and
  interpreting monitoring results.

  To conclude, drinking water
program  requirements are now
expanding to an unprecedented
degree. The successful implemen-
tation of these requirements will
involve  the  utmost  cooperation
from all affected parties. Both U.S.
EPA and state PWS programs are
now relying upon local health offi-
cials, as never before, to expand
and apply their knowledge, exper-
tise, and assistance, especially in
light of the close relationships they
enjoy with the local public.
Prepared  for  NEHA  by Peter
Shanaghan, Mobilization Coordi-
nator, Office of Drinking Water,
U.S. EPA. For further informa-
tion, please call the U.S. EPA Safe
Drinking Water Hotline at 1-800
426-4791; 382-5533 in the Wash-
ington, D.C., metro area.
      National Environmental Health Association
      720 S. Colorado Blvd.
      Suite 970, South Tower
      Denver, CO 80222
                                                 Non-Profit Org.
                                                  U.S. Postage
                                                    PAID
                                                  Denver, CO
                                                  Permit *618

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                                                                         Appendix M

                                      ODW Publications

Brochures and Pamphlets

Is Your Drinking Water Safe?

A pamphlet that provides  an  overview  of the regulatory requirements  of  the SDWA
amendments.  Written in simple, non-technical terms, the pamphlet is a good source of basic
information on EPA's public  water supply program.

Bottled Water

Household Water Treatment

SDWA for State  and Local Officials

Radon

Compliance/Enforcement

Your Drinking Water:  From Source to Tap

Lead and Your Drinking Water

Reports and Studies

Paving for Safe Water: Alternative Financing Mechanisms for State Drinking Water Programs
A  handbook that discusses methods that  State drinking water programs  can  use  to  raise
revenues to finance the costs associated with implementation of the SDWA amendments.

Ensuring the Viability  of New. Small Drinking Water Systems: A Study of State Programs

A  study of four State programs aimed at controlling the creation of non-viable small  drinking
water systems.   Programs in Connecticut, Georgia, Maryland,  and Washington are evaluated.
(EPA document number 570/9-89-004, April 1989)

Improving the Viability of  Existing Small Drinking Water Systems

A  study of State initiatives used  to address the problems of small drinking water  systems,
including restructuring options such as O&M contracting and acquisition of non-viable  systems.
Case studies of  successful programs and names and telephone numbers of persons to contact
for additional information are included. (EPA document number 570-9-90-004, June 1990)

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Newsletter Articles

The following articles arc available from Beth Hall who is coordinating the development of
the generic articles; her phone number is (202)  382-5553.

Drinking Water Regulations Expand for School  and Business Operated Systems

A 3  1/2-page article that reviews current drinking water  requirements for NTNCWSs and
provides a brief overview of forthcoming requirements.

Teachers and Safe  Drinking Water

This  2-page article  discusses the role that teachers play in preparing their communities for the
new  requirements.  Emphasis is placed on local involvement and public education.

Small Communities and Drinking Water

This  3  1/2-page article discusses the role that community leaders and decision makers can play
in preparing their communities for the new requirements. Emphasis is placed on understanding
the new regulatory requirements, identifying sources  of assistance,  and considering all the
options for compliance.

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                                                                                                    Appe
                      Massachusetts  Department  of  Environmental  Protection
                      QUESTIONNAIRE ON TECHNICAL SERVICES AND PUBLIC OUTREACH
                                          FOR SAFE DRINKING WATER
1.  ORGANIZATION

2.  MAILING ADDRESS
                 TOWN	STATE	ZIP CODE_

3.  TELEPHONE NO.  (	)	-	

4.  CONTACT PERSON:   	
                 TITLE

                 ADDRESS
                 TOWN                                      STATE             ZIP CODE
5  STATUS OF ORGANIZATION:  Profit 	  Nonprofit 501 C3	  Government Agency	(circle type below)
                                                                       federal   state   county   local

6.  ORGANIZATION CATEGORY DESCRIPTION:

         a. Water Supply  b. Environmental Consulting c. Legal  d. Planning  e. Financial  f. Library  g. Public Education

         h. Other	(please specify)
IN WHICH OF THE FOLLOWING SERVICES AND ACnVTTES IS YOUR ORGANIZATION INVOLVED?
Please answer all that apply, and please be as specific as possible.

A.  TECHNICAL ASSISTANCE

         a.   On-Site Inspections/Maintenance/Management of	 (i.e.  water
             supply distribution systems, water supply sanitary surveys, soils, etc.)
             for	(grve purpose)

         b.   Accept Telephone Inquiries on 	(give subject areas)

         c.   Grant Proposal Development  (state/federal/pnvate S sources) for
             (i.e. financial assistance  to conduct studies, construct facilities, purchase equipment and supplies, etc.)

         d.   Training/Education 	
             Certification/Degrees offered (if any)

         e.   Legal Assistance	
         f.    Planning Assistance
        g.   Other	(please specify)


3. OUTREACH/EDUCATION

        a.   Publication Types (i.e. fact sheets, pamphlets, newsletters, etc.)	

             Topics of Publications	

        b.   Technical Library	
        c.   Computer Ncrwork/Bulletm Board

        d.   Audio Visual Resources
        e.   Mass Media (i.e. outreach through T.V., billboards, etc.)

        f.   Workshops/Semmars/Classes
             Certification/Degrees offered (if any)

        g.   Other	
                                                                                            (continued next page)

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 C.  LOBB-iING



         a.    Federal/Sute/Local Lobbying



         b.    Grassroots Lobbying 	



D.  FUNDING SOURCE 	




E.  OTHER
WHAT SEGMENT OF THE PUBLIC DOES YOUR ORGANIZATION ADDRESS?



(i.e. general public; water suppliers; local, state or federal government, etc.)

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                                   Appendix Q
   EIMIMVEST
  PENNSYLVANIA INFRASTRUCTURE INVESTMENT AUTHORITY
   22 South Third Street Harnsburg, Pennsylvania 17101
A water utility's Guide To
 Financial and Technical
  Assistance Programs
             issued By The

 Pennsylvania Infrastructure Investment Authority
      Commonwealth of Pennsylvania
          Governor Robert P Casey.
              Chairman
             January 1990

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                        COMMONWEALTH or PENNSYLVANIA
                           Orricc or THE GOVERNOR
                                HAHHISBURO
THE GOVERNOR
           We are committed  to improving the quality  of life for
      Pennsylvania families by helping supply  the  clean water for our
      communities.  The Pennsylvania Infrastructure Investment
      Authority ~  or PENNVEST ~ has become the vital  source  of
      funding for these desperately needed infrastructure
      improvements.

           For too  long our Commonwealth's  smaller communities found it
      almost  impossible  to finance the kind of  capital investment  so vital
      to a healthy  environment and a robust economy.  We established
      PENNVEST in 1988 to help provide more than $2.5 billion for
      improvements in Pennsylvania's drinking water and sewer systems.

           There are about 2,400 local water systems  in Pennsylvania,
      more than any other state in the nation.   Some 2,100 of  them
      serve fewer than 3,300 customers,  frequently in communities with
      a narrow or shrinking tax base.   The burden of millions of
      dollars of improvements in these systems —  which average  only
      478 customers each —  could  result in enormous rate  increases.
      Instead,  PENNVEST's low-interest loans,  along with the other
      assistance plans described in this  booklet, can  keep down  the
      costs to our  consumers and create jobs in our communities.

           This "Water  Utility's Guide to Financial and T-   nical
      Assistance Programs" provides a list of agencies tha. are ready to
      provide the environmental infrastructure we need tc  .eave  our
      children  and grandchildren.  They have  a right to clean drinking
      water,  and through PENNVEST, we are  now making that right
      into a  reality.
                                             Robert P. Casey
                                             Governor

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                                                                      Appendix 0
   Pennsylvania infrastructure investment Authority

 program
 PENNVEST

 Types of Assistance
 Low interest loans and supplemental grants for drinking water  and wastewater
 including industrial wastewater systems

 who is Eligible
 Any owner  or operator of any wastewater or drinking water system The owner or
 operator may be either a public or private entity, including any person, corporation
 partnership, association, cooperative, municipal authority or governmental unit

 program use
 Financial assistance is available for construction, improvement, expansion, extension,
 acquisition,  repair or rehabilitation of all or any part of any facility or system, whether
 publicly or privately owned, for the collection, treatment or disposal of wastewater
 including industrial wastewater, or for the supply, treatment, storage or distribution of
 drinking water Eligible costs may include, but are not limited to, construction, project
 design and engineering, administration, permit fees, legal fees, acquisition of property
 rights and equipment that are preliminary to or a necessary part of the project and
 interest during construction

 Activity and Amount of Funds Available
 PENNVEST is able to finance up to  100% of eligible project costs, subject to the
 following limits  There is an overall project cap of S11 million per project. This cap is
 increased to S20 million if more than one municipality is served and can be exceeded
 with Authority approval if four or  more communities are served The Authority may
 require the applicant to participate in financing a project when it determines that the
 applicant has the financial capability to do so and that such participation is desirable

 PENNVEST financial assistance will primarily consist of low interest loans with some
 supplemental grant funds available for economically distressed communities, interest
 rates vary based, in part, on the cost of funds to the Commonwealth. Once a PENNVEST
 loan is approved, interest is fixed for the term of the loan, it is anticipated that most of
 the loans will have a term of 20 years  and carry interest rates ranging from 1% to
 approximately 6% There are no application, loan  origination, or service fees. There are
 no pre-payment penalties on loans. Loan applicants are eligible for an expedited rate
 review process established by the PUC to facilitate debt service repayment.

 Application procedure
 Contact the Pennsylvania infrastructure  Investment Authority  and request an
 application form for publicly-owned wastewater, publicly-owned drinking water, non-
 governmental  wastewater,  or non-governmental drinking water  systems, as
 appropriate The  fundamental objectives that will guide project evaluation and
 selection  are improvements to public health, public safety and the environment.
 Performance on other criteria, including improvements to economic development,
 compliance with State and Federal  requirements, social impact, and improvements to
 adequacy and efficiency are also considered Meetings are held on a quarterly basis
 Special meetings can be held on emergency situations.

Where to Apply
 Pennsylvania infrastructure investment Authority
 22 South Third Street
 Harnsburg, PA 17101
(717)787-8137

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  Pennsylvania infrastructure investment Authority
Program
PENNVEST Advanced F-unding Program

Types of Assistance
LOW interest loans and possibly supplemental grants are available for feasibility studies
arid the design and engineering of drinking water systems The design and engineer ing
of wastewater systems may also be funded  Feasibility studies of wastewater systems
may be funded by Act 537 as administered by DER

Who Is Eligible
Any current or prospective owner or operator of  any drinking water 01 wastewater
system  This may be either a public or a private organisation, including any person.
corporation, partnership,  association,  cooperative, municipal authority, or
governmental unit

Program DM
The intent of the Advanced Funding Program is to aid providers and prospective
pioviders of water and wastewater service who cannot  	i to locally finance the
costs of the preliminary tasks required in order to apply foi a pfcNNVEST construction
loan Loans are made available for a term of five years
The approval of an advance  funding application is not a guarantee of construction
funding, nor is it a requirement to use PENNVEST to fund construe tion  The applicant
will be obliged to implement any project receiving advance funding if construction
funding is later approved, the advance funding loan can be made a part of the
construction loan
The great majority of advance funding will  be made available in the form of low
interest loans  Grants are possible but will be very limited In most cases any grant
funds provided will be combined with loan funds interest rates are determined in the
same way as is done for construction projects

Application Procedure
 The application procedure is similar to that used  for the construction loan projects
Application forms can be obtained from the PENNVEST  office  All applicants are
 required to conduct a preliminary planning consultation with DER in order  to assure
 maximum coordination

 Where to Apply
 Pennsylvania Infrastructure Investment Authority
 22 South Third Street
 HarnsburgPA17101
 (71717878137
       Pennsylvania Department of Environmental
                              Resources

Program
Technical Assistance Program foi Small Systems (TAI'SSi

Types of Assistance
On site technical assistance and training

who Is Eligible
This progiam focuses on small publicly diul privately owned drinking water systems
serving 2b or more people  DER is offering this technical assistance and training to
small water system opei ators in Pennsylvania

Program Use
DER is contracting with consultants highly experienced in effective  operation of
drinking watei treatment facilities to go to small water systems and provide technical
assistance and training to the operators The progi jin (overs proper operation and
maintenance of facilities for filtration disinfeition 01 c or region control  Evaluation of
the effectiveness of the treatment, including performaiue samples will be provided
Training to meet both noimal and emergency operating conditions will  be given Hie
goal is to improve the quality of the drinking water as much as possible with the
existing facilities and meet  the i equii ements of the Pennsylvania S.if e Di inking Watei
Act TAPSS will also provide information on funding sources. Such as  PtNNVtSf to
assist  in upgrading treatment facilities

Activity and Amount of Funds
The training will be provided on site at eat h opt-i ati>r s water system jnu dm HUJ hours
convenient to the operator including evenings Hie cost ot tecMnic Jl assistance and
training will be borne solely by DtR The system owner or operator will not be (haiged
for any services provided through this program

Application Procedure
Contact the  l'< ,•  t Manager  listed  below Priority is based on the minimi/aiion of
violations oi UK  ii..)ny new  drinking water  requirements and the  likelihood uf
improved drinkn iy water quality as a result of the technical assistance and training'

where to Apply
Walt Harner. Proiec t Manager Pennsylvania Depar I merit ot t nvironmer it al Kesour ces
Bureau of Community Environmental Control Division of Water Supplies
PO Box2557
Harnsburg. PA 171?0
(71717875017

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o
x
c
OJ
p,
       Pennsylvania Department of Environmental
                              Resources

Program
lUnfMuof W.KPt PPSOUI r or> Maruiqpmpnt
W.itrr ( onspr vn( lonATpr hni< -il ASMM.VH r Program

Types of Assistance
lot hnir jl ,is<;iM anrp is provider) (o smnll (1 OOO or fewpr service connections) publicly 01
privately owner) community drinking water systems through  on site visits hy OEP
personnel

who Is Eligible
Any owner/operator of a small community water system with 1.000 or fewer service
connections Municipalities municipal authorities, corporations, partnerships.
proprietorships associations and institutions are eligible

Program use
The following services are available through the program leak detection, water meter
management, rate scheduling and drought contingency planning Leak detection
equipment and training  in the proper care and handling of available equipment is
provided free of charge

Activity and Amount of Funds Available
Technical assistance is  provided free of cost No charge will be made to the system
owner/operator

Application Procedure
Contact the Bureau of Water Resources Management and request assistance Eligibility
and priority will be determined by the Bureau based on public health and safety issues
and compliance with State and Federal standards

Where to Apply
Tom F idler Chief
Water f onservat ion Technical Services Sect ion
State Water Plan Bureau of Water Resources Management
Department of Environmental Resources
Evangelic al Press Building
Third and Reily Streets
Harnsburg PA 17170
17171 7R7B7SO
                                                                                                                           Pennsylvania Department of Commerce
Community Facilities Grant
Type* of Assistance
Supplemental financial assistance (proiect grantsi for needed public facilities to
strengthen income producing capability, improve health and safety and alleviate
financial hardship of the community

Wtio Is BNgJWe
Any Pennsylvania borough, township, city, municipality or county authority with a
population of 12.000 or fewer people Authorities serving multiple communities with a
combined population of 12.000 or more people are ineligible

Program live
Construction, rehabilitation, alteration, expansion or improvement of water facilities.
pumping stations, distribution and treatment  facilities, reservoir rehabilitation
projects and access roads

Activity and Amount of Funds Available
Grants are limited to protects of S2.qpO,000 or less Grants may be awarded for up to
S50.000 or 50% of eligible project cost, whichever is less Eligible costs include
construction, project design, engineering and legal costs (relating to construction)
Eligible  municipalities and certain economically distressed communities within
counties having annual average unemployment rates more than 30% higher than the
statewide average are eligible for maximum grants of up to 575.000 or 75% of total
eligible project cost, whichever is less

Application Procedure
Send letter of intent to Bureau of Business Financing by April 15th File application by
May 1st The application will be  evaluated on the basis of order of importance
improvement of health and safety, degree of economic distress, economic impact
project readiness and cost effectiveness Funding decisions will be reached by July
51st

Where to Apply
Mary McGlmchey. Chief. Division of Grants and Loans
Bureau of Business Financing
PA Department of Commerce
Room 194. Forum Building
Harnsburg. PA 17120
(717)787 7120

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          Pennsylvania Department of Commerce
          Pennsylvania Department of Commerce
Program
Site Development Grant

Types of Assistance
Project grams to  increase industrial employment  Dy encouraging the industrial
growth of the Commonwealth

wnolsEHglMe
Any Pennsylvania municipality (township, borough, cityl, nonprofit  industrial
development agency or state agency which will ser ve an industrial or tourist site

Program Use
installation of water facilities, pumping stations, distribution and tieatmem facilities
sanitary sewage lines, channel realignment and access roads Sewage treatment and
storm sewer protects are ineligible for funding

Activity and Amount of Funds
Maximum grants may be for S50.000 or 50% of eligible project costs whichever is less
bligible costs include construction, project design, engineering and legal costs (relating
to construction) Eligible municipalities and certain  distressed communities within
counties having annual average unemployment rates more than 30% higher than the
statewide average  are eligible for maximum grants of up to 5100.000 or 50% of total
eligible project cost, whichever is less

Application Procedure
Send letter of intent to Bureau of Business Financing by April 1st File application by
May 1st  Applications will  be evaluated based on the following ilisted in order of
importance) degree  of economic distress, economic impact of  project  project
readiness, improvement of healt h and safety and cost effectiveness

where to Apply
Mary McClinchey. Chief Division of Grants and Loans
Bureau of Business Financing
PA Department of Commerce
Room 494. Forum Building
Harnsburg, PA17120
(717)787 7120
Program
business Inf r asti ucture Development 1'iogr Jin (BID!

Types of Assistance
Grants or loans lo local sponsors in order to install specific  inlr astruc lure
improvements  necessaiy to complement industrial investment by private
companies which increase Pennsylvania s snare of demesne and international
commerce and create new lobs

Who Is Eligible
Eligible sponsors include local governments (boroughs  townships cmesi councils of
governments municipal authorities and redevelopment authorities  Eligible private
businesses include agricultural industrial and manufactuunij businesses ana research
development enterprises

Program Use
Construction expansion  improvement and rehabilitation is limited to  drainage
systems, energy facilitu'., die ind safety facilities  transpoitation facilities  water
systems and waste disposal facilities lo be eligible all infrastructure improvement
projects must be necessary tor (he operation of an eligible business 01 busmev i   .'
specific job generating site The infrastructure improvement must net one
time job (at the specific job sitel within three years for every SIS000
granted The private business must be providing 52 in investment for every •,< i\\ u\U
funding

Activity and Amount of Funds Available
Individual grants ,uid loans may not exceed 51 SOOOOO  Interest rales and loan trims
will be detei mined by the Department of Commerce  Maximum loan term sluil be no
greater than  20  years Eligible costs include construction site clearance demolition
engineering and design  expenses, legal costs and administrative expenses intviied to
effectively administer BID grants or loans)

Application Procedures
Eligible sponsor provides letter of application lequesl  along with a letter of intent
from the private business to Pennsylvania Department of comment' if pmjeit is
determined eligible apphr anon material will then be sent Completed applu ations will
be processed within thirty days of then receipt
                                                                                      Where to Apply
                                                                                      Mary McClinchey. Chief Divi1.
                                                                                      Bureau of Business F m.n.
                                                                                      PA Depart merit of Con)	
                                                                                      Room4M .1    nt,      i
                                                                                      Marrisburg i
                                                                                      1/17)78/7120
                            if Grant sand loans
                                                                             I

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o
 X
•H
•d
 ex
          Pennsylvania Department of Commerce

Program
App.ilarhian Ppqinnal nrvplnpmrnt Supplpmental Grant

Types of Assistance
Supplemental- grants to rommunities within the Appalachian Loral Development
districts (see Apppncjix  A (or listing! to aid construction protects vital to regional
growth

wnolsHlglble
Municipalities municipal authorities sewer authorities, school districts planning
commissions ot public or private non profit organizations There are no size or income
restrictions

Program Use
Construction of watpr systems, sewer systems  and treatment plants  Eligible costs
include construction  project design and engineering costs and  all legal and
administrative fees

Activity and Amount of Funds Available
Thr bulk of funds available to Pennsylvania recipients are used to support enterprise
development in Pennsylvania s seven Appalachian local Development Districts

Application Procedures
Contact the Office of Enterprise Development or the Appalachian local Development
District serving the county in which t he protect is loc ated (See Appendix A) The project
will be assessed based on the seventy of the problem and number of people affected

Where to Apply
Katherme Wilson Chief
Office of Enterprise Development
PA Department of Commerce
Room 404. Forum Building
Harnsburg PA 17170
                                                                                                                     Pennsylvania Department of Community Affairs
Bureau of Housing and Development. Small Communities Division Community
Development Block Grants/Small Municipalities Entitlement and Competitive Grant
Program

Types of Assistance
Grants to provide the Federal non entitlement municipalities of Pennsylvania with
funding needed to address local community development needs in the areas of
housing, community facilities, economic development and public services including
community drinking water systems

wno Is HIglDW
General purpose units of local government not designated as  Federal entitlement
counties or municipalities (see Appendix 8 for a listing of Federal entitlement
governments which are ineligible for DCA money! Applicants must demonstrate that
no less than 51% of funding to be received will principally benefit persons of low/
moderate income The municipality may apply through its county or directly apply
itself
                                                                                                                 Acquisition, construction, reconstruction or installation of water and sewage facilities

                                                                                                                 Activities and Amount of Funds Available
                                                                                                                 Entitlement funding is allocated to eligible municipalities and counties on a formula
                                                                                                                 basis Selected projects must meet specific program regulations and requirements to
                                                                                                                 be approved bv DCA Competitive funding is specific project funding which is
                                                                                                                 competitively awarded by OCA to eligible municipalities based on specific project
                                                                                                                 proposals DCA determines priority based on community need, project scope impact
                                                                                                                 on low/moderate income residents and other factors

                                                                                                                 Eligible costs include engineering and construction costs Ineligible costs include
                                                                                                                 construction equipment  purchases, operating and maintenance costs and staff
                                                                                                                 salaries
                                                                                                                 For competitive grants, contact DC As Small Communities Division and request an
                                                                                                                 application For entitlement grants, contact the local county planning office or apply
                                                                                                                 directly to DCA's Small Communities Division Applications will be evaluated on the basis
                                                                                                                 of the following  community need, seriousness of the problem, resolution  to the
                                                                                                                 problem,  benefit to low/moderate income residents and timeliness of project
                                                                                                                 completion

                                                                                                                 Wnere to Apply
                                                                                                                 RileyStoy. Chief
                                                                                                                 Small Communities Program Division
                                                                                                                 Department of Community Affairs
                                                                                                                 Room 515. Forum Building
                                                                                                                 Harnsburg. PA 17120
                                                                                                                 17171783 3910

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	Pennsylvania Department of Health	

Program
Division of Health Promotion   Fluondation Program for Community Di inking Water
Systems

Types of Assistance
Financial assistance (grants)  to initiate community drinking water fluondation
Technical information on the  benefits, safety and economy of fluctuation is also
offered

who Is Eligible
Any publn (municipality or municipal authority) or any private nonprofit (association)
owner of a community drinking water system The governing entity must have taken
formal action authorizing the addition of fluoride to the water Engineering plans must
be approved by the Department of Environmental Resources

Program UM
Grants are provided through the Department of Health to community drinking water
systems in order that fluondation may be included in the  drinking water system
Fluondation is one of the most efficient and practical means for preventing and
suppressing tooth decay and dental disease The  Department of Health will contract
with eligible entities to provide fluondation Up to 100% of the costs of fluoridating
may be reimbursed depending upon the availability of funds Reimbursable items
include cost of engineering plans, purchasing and installation of equipment, testing
equipment and supplies, training of operators) and the first year s supply of fluoride
chemical The Department of Health also provides technical information on the value
of community drinking water fluondation

Activity and Amount of Funds Available
Funds for reimbursement of costs of fluoridating are allocated  annually from the
Preventive Health and Health Services Block Grant The amount of assistance available
depends upon allocations  and requests received  Fluondation information and
educational materials are available free of charge

Application procedure
Submit a copy of the formal action to fluoridate taken by  the governing entity a
narrative description of  the water system  and the population and geogiaphic area
served together with an itemized proposed budget From this information, a proposed
contract for services will be prepared and returned for review and signature

Where to Apply
Pennsylvania Department of Health
Division of Health Promotion
Room 912 A
Health and Welfare Building
P 0 Box 90
Harnsburg PA 17108
(717)7876967
                                   10
	Farmers Home Administration (FmHA)	

Program
Wdter and Waste Disposal Grants and t uans (Program #104181

Types of Assistance
Grants and dire* t i     > n water and waste disposal facilities in rural areas and towns
of10000orfe«.n >,, ,,,,k

Who Is Eligible
Public entities such as municipalities  municipal authorities counties  nonprofit
organisations and community action agencies Population restr it lion is 10.000 people
per community Priority will be given to rural communities with populations of 5.000 or
fewer people

Program use
Acquisition of a water supply construe Honor improvement of water supply reservoirs
pipelines  wells pumping plants water and sewage filtration and treatment facilities
Eligible costs include legal and administrative fees, engineering fees, equipment costs
relating to the project (as deemed appropriate by FmHA) and all construction costs

Activity and Amount of Funds Available
FmHA is primarily a loan agency with supplemental gr.jnt money used at the discretion
of FmHA to maintain  the water and sewer rates charged to the system users a(
reasonable  levels  Interest  rates  are determined by  the median  income ot  the
community and arc classified as poverty intermediate 01 market rates  Poveity
classification is based on median income of 512.918 or less pel home for  I98/

Application Procedure
Contact the FmHA District  Oftice for your  county to submit an application and tile
FoimADb21 Priority will be given to public entities in areas ot bOOOurlewei people
with consider ation given to median income, severity of the problem and  availabihty of
other credit

where to Apply
See Appendix C
FmHA District Offices

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 o
 y
•H
"H
 S.
 ex
           Farmers Home Administration (FmHA)

Program
HompOwnershiploansiPmqram »r>0? anrt fSCMI

Typ«s of Assistance
low interest loans and interest subsidies to provide water supply and sewage disposal
Who Is Eligible
Individuals of low to moderate income living in FmHA served areas who need housing
rehabilitation hut are unable to obtain affordable credit elsewhere

Program use
Building or rehabilitation of a dwelling by providing a water supply and/or sewage
disposal facility  This could  include constructing or modernizing kitchens or
bathrooms developing a drinking water well or connecting with community water
systems

Activity and Amount of Funds Available
Eligible costs include water or sewer connection fees
Application Pr
                 •dure
Contact the FmHA County Office in your county for an interview  The county
supervisor will arrange an inspection of the property Loans will be awarded based on
the supervisors inspection report

MFftere to Apply
See Appendix D
FmHA County Offices
      Economic Development Administration (EDA)

Program
Public Works and Development Facilities Program
Types of
Grants and loans for water and sewer projects which primarily serve industrial and
commercial users to assist in the construction of public facilities needed to initiate and
encourage the creation and retention of lobs in the private sector
who to i
States, cities, counties, political subdivisions and private or public  non profit
organizations
Acquisition, construction, rehabilitation, expansion or improvement of water and
sewage facilities and access roads Protect must enhance economic development of its
industrial and commercial users or stimulate community growth by creating iocs.
reducing unemployment and raising family incomes

Activity and Amount of Funds Available
Eligible projects may receive grants of up to 50% of total project cost

Application PioceUure
Contact  your local Economic Development District to establish a pre application
conference  An EDA representative will then determine if further processing is
necessary Priority will be determined by project economic impact, community needs.
availability of funds and the nature of the protect

wiiei e to Apply
See Appendix E
EDA District Offices
                                   12
                                                                                                                       13

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               National Rural water Association
Program
Pennsylvania Rural Water Association
Training and Technical Assistance Program

Types of Assistance
Technical assistance provided by certified water plant opeiatois dlung with naming
sessions whose purpose is to supply a community water system owner/operator with
educational training in operational daily work areas in order that the system may be
better able to comply with the Pennsylvania Safe Drinking Water Ac t

wholsfHglbto
Any community drinking water system in Pennsylvania with a resident population of
mnoo or less is eligible System types include municipalities municipal authorities
 i     ii ions, corporations,  institutions, partnerships,  proprietorships and mobile
hoi ne parks

Program use
Technical assistance includes an on site visit to provide extensive water system training
in water loss, leak detection, chlormation. metering, rate structuring proper record
keeping, and day to day operation and maintenance Training sessions are offered
throughout Pennsylvania Topics discussed include  filtration, distribution.
maintenance and public education Pennsylvania Rural Water Association s Training
Program has been  accepted  as credit experience for water system operator
certification

Activity and Amount of Funds AvaHaMe
Technical assistance  and training sessions are provided free  to community water
systems  The cost of the program is borne solely by the National Rural Water
Association On average. 720 site visits and 14  to 16 training sessions are held on an
annual basis Pennsylvania Rural Water Association s  Training Program has been
accepted as credit experience for water system operator certification

Application Procedure
Contact the Pennsylvania Chapter of the National Rural water Association and request
a meeting

where to Apply
Herb Pizer. Program Manager
Pennsylvania Rural Water Association
Saltsburg Plaza
PO Box 90
Saltsburg. PA 15681
(412) 6595246
                                    14
               Rural Housing improvement, inc.
Program
Rural Watei K'esouices ik'Wki foimerly the Rural Community Assistance Program
(RCAPI

Types of Assistance
Ie
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o

X
•H
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o
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-Tl
             American Water Works Association

Program
Small System Program

Program Use
I he new Small System Program will provide technical assistance to small community
drinking water system owners and operators through instruction and training packets
along with public education seminars The goal of the program is to help small system
owners and operators develop  expertise in daily system operations  water system
management and fmanre water related legislation and regulations Specific program
tonics may include iron and manganese removal wells,  pumps  hydrants filters.
cor rosion and t ross connect ions

AWWA also cochairs with DER a Committee on Small Drinking Water System Issues
which includes representation from many private and governmental organizations
concerned with small drinking water systems This committee can serve as a clearing
house for information and assistance desired by a small drinking water system owner
or operator

Where to Apply
For more information on AWWAs Small System Program, contact
DaleKratzer
PSC Environmental Services Inc
700 North Warner Road
Suite 300
King of Prussia PA 19406
l?1S> 557 5060
                                                                                                                            Pennsylvania Public Utilities Commission
Public Utility Technical Assistance

TypMof AssManra
The Commission can supply water providers with assistance and information on
general operations, rate structures, compliance with regulations, and customer
relations, including billing and  collection procedures Assistance with filing for rate
increases can also be made available
Special expedient rate considerations can be allowed under certain circumstances

WftO M RNQlDW
Any regulated utility may receive technical assistance, although it is most often used
by utilities with less than S200.000 in annual revenues
Expedient rate considerations can be granted in either of two special circumstances as
discussed below

pioomnUM
The  two types of expedient  rate considerations are short  form filings and pass
through filings
Short form filings are for small utilities, generally identified as those generating less
than S200.000 annually Short form filings require less time for consideration than the
more complex regular filings
Pass through filings are those that request rate increases solely for the purpose of
defraying  the expenses associated with the repayment of  a PENNVEST loan, the
purchase of water from another provider or the purchase  of electricity Since these
rate increases involve only the passing through of costs to the utility, the Commission
is able to process them more quickly

AppBotlon PF ooiiuf>
There is no formal application procedure to obtain technical assistance It  is
recommended  that utilities requiring such assistance  write or telephone the
Commission at the address below
Forms for short form and pass through rate increase filings can be obtained from the
commission at the address below

wim • to Apply
 Attention Judy Carlson
 Pennsylvania Public Utilities Commission
 PO Box 3265
 Harnsburg. PA 17120
 (71717835590
                                                                 16
                                                                                                                                                        17

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                            Appendix A
	Pennsylvania Department of Commerce
local Appalachian Region Development Districts
SEDA  Council of Governments
TimberhavenRD f1
lewisburg PA 17857
(7171 5244491
Counties served  Centre. Clinton. Columbia Juni.ua  tycoming, Mitfhn. Montour,
                Northumberland. Perry, Snyder and Union
Southwestern Pennsylvania Economic Development District
110 Market Street
Pittsburgh. PA 15222
(4121391 1240
Counties served  Allegheny. Armstrong  Beaver Butler Fayette  Greene Indiana
                Huntmgton and Westmoreland
North Central Pennsylvania Regional Planning and Developmeni Commission
651 Mom moreno Avenue
PO Box 488
Ridgway. PA 1585S
1814)7733162
Counties served  Cameron, Clearfield. Elk. Jefferson. McKean and Potter

Southern Alleghenies Planning and Development Commission
Suite 100
Southern Alleghenies Pla^a
1506 Eleventh Avenue
Altoona PA 16601
(81419461641
Counties served  Bedford Blair. Cambria Fulton. Huntingdon and Somerset
Northern Iiei Regional Planning and Development Commission
SO/Main Street
Towanda. PA 18848
(7171265910$
Counties served  Bradford, Sullivan. Susquehanna Tioga and Wyoming

Eronomic Development Council of Northeastern Pennsylvania
1151 Oak Street
Pittston, PA 18640 5795
(717)6555581
Counties served  Carbon, Lackawanna luzerne Monroe Pike Schuylkill and Wayne

Northwest Pennsylvania Regional Planning and Development Commission
Suite 406
Biery Building
Franklin PA 16523
(8141437 3024
Counties served  Clarion. Crawford, Erie. Forest Lawrence. Mercer  venjngo arid
                Warren
                                   18
                            Appendix B
             Department of Community Affairs
                                                                                    Federal entitlement governments which are ineligible for OCA grant money are as
                                                                                    follows
         Entitlement
           Counties
         All.
         B,....
         Beiks
         Bucks
         Chester
         Delaware
         Lancaster
         lu/erne
         Montgomery
         WjsliirKji.iii
         Westmoreland
         York
          Federal
       Entitlement
      Municipalities
     Allentowiiitehighl
     Altoona (Blair)
     Bethlehem (Northampton)
     Carlisle (Cumberland)
     Easton (Northampton)
     trieitnei
     Han isbui y iDauphin)
     Johnstown (Cambria)
     Lebanon (I ebanoni
     Pit tsbur yh (Allegheny)
     Philadelphia (Philadelphia)
     Sc ranton (l a< kawanna)
     ShaioruMercerl
     St jt e College (Cei \ 11 ei
     Williamsport ilyconunyi
                                                                                    Hie following communities have  opted out  of Urban County Pioyrams jnd aie
                                                                                    eligible for OCA administered( DBG grant funds
Bradford Woods Horouyh (Allegheny)
Fllwood City Borough IBeaven
Potter lownship (Beaver)
West Pikeland Township(Chester)
West Bradford Township (Chester)
West Goshen Township (Chester)
Nanticoke City (Lucerne*
PittstonCity (Lucerne)
Conshohocken Horouyh (Montgomeiyi
tirnerick Township(Montgumeiyi
Arnold City (Westrnorelandi
Jeannette City (Westmoreland)
Monessen City (Westmoreland)
New Kensington City (Weslrin.i eland)
Scottsdale Borough iwestriiui eland)
                                                                                                                      19

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O
 X
•T-\
•a
                     Appendix C
Farmers Home Administration District Offices
District Office
Mpjnviiir



Ipwisniitq







Allpnfnwn






M.irs






Chambprsburg







County Office
Brookville
ClrarfieM
Franklin

Bfllefonte
Bloomsburg
I ewisburg
Mifflmtown
Montrose
Towanda
Wellsboro
Williamsport
Allentown
Cleona
Doylpstown
Honesdale
Iresport
N.inticokp
WPS( Chester
Butler
Fbensburg
Greensburg
Kit tanning
Somerset
Uniontown
Washington
Bedford
Carlisle
Chambersburg
Gettysburg
Hollid.ivsbiirg
Hunfingrjon
lanrastpr
York
Address and Phone
Ed Kau Building
101 2 Water Street
Meadville.PA 16555
(814)5566155
P O Box 252
Room 405 Federal Building
Lewisburg. PA17857
(717)5244450




850 North 5th Street
Allentown. PA 18 102
(215)7764296




Mars Prof essional Building
PO Box 422
Pittsburgh Street
Mars PA 16046
(412)6255174


501 Lortz Avenue
Chambersburg PA 17201
(717)7652728





           Appendix D
Farmers Home Administration
         County Offices
                                                                                                        County Office
                                                                                                        Allentown
                                                                                                        Bedford
                                                                                                        Bellefonte
                                                                                                        Bloomsburg
                                                                                                        Brook vtlle
                                                                                                        Butler
                                                                                                        Carlisle
                                                                                                        Chambersburg
                                                                                                        Clearfield
                                                                                                        fleona
                                                                                                County Served
                                                                                                Lehigh
                                                                                                Carbon
                                                                                                Monroe
                                                                                                Northampton

                                                                                                Bedford
                                                                                                Fulton
                                                                                                                              Centre
                                                                                                Columbia
                                                                                                Montour
                                                                                                Northumberland
                                                                                                                              Jefferson
                                                                                                                              Clarion
                                                                                                                              Elk
                                                                                                                              Butler
                                                                                                                              Beaver
                                                                                                                              Cumberland
                                                                                                                              Perry
                                                                                                                              Franklin
                                                                                                                              Clearfield
                                                                                                                              Lebanon
                                                                                                                              Dauphin
                             Address and Phone

                             Suite »112
                             5405 Airport Road
                             Allentown. PA 1810 5
                             (2151 2669-188

                             Barclay Building
                             PO Box 121
                             Bedford. PA 15522
                             (814)6259077

                             R D  »5. PO Box 58
                             Bellefonte. PA 16825
                             (814)5551555

                             PO  BOX806
                             1127 Old Berwick Road
                             Bloomsburg PA 17815
                             (717)7849055

                             Jefferson County Service
                             Center
                             RD  *5
                             Brookville. PA 15825
                             1814)8492521

                             106 Thompson Road
                             Butler. PA 15825
                             (412)2824450

                             Melmar Suite
                             45 Brookwood Avenue
                             Carlisle. PA 17015
                             (717)2496506

                             550 Cleveland Avenue
                             Chambersburg. PA 17201
                             (717)264 5442

                             Agricultural Service Center
                             650 Leonard Street
                             Clearfield. PA 168 50
                             (814)7655516

                             528 East Penn Avenue
                             Cleona.PA!7042
                             (717)2742879
                                                          70
                                                                                                                                        21

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                                                                              I
County Office
Doylestown
Ebensburg
Franklin
Gettysburg
Greensburg
 Hollidaysburg
 Honesdale
 Huntingdon
 Kittanmng
 Lancaster
County Served
Bucks
Montgomery
Philadelphia
                        Cambria
                        Venango
                        Forest
                        Adams
                        Westmoreland
                        Blair
                         Wayne
                         Latkawanna
                         Pike

                         Huntingdon
 Armstrong
 Indiana
                         Lancaster
Address and Phone
4 2 59 Swan ip Road
Doylestown PA 18901
(215) 548 I1b6
PO Box 194
tbensbuicj PA 159 51
(814)4725500

R 0 H"\ Box 665
Franklin PA 16525
(814)457 5642

44Sourl)FianklinStieet
Gettysburg PA 17525
(717)5549251

958 St  flan Way
Route 50
Creensbuig PA 15601
(412)8540596

1407Blan Street
Holhdaysburg PA 16648
(814)6959875

4 /O Sunt ise Avenue
Honesdale PA 18451
(71712551570

 902 Pennsylvania Avenue
 Huntingdon PA 16652
 (814164 5 6 720

 PO Box 921
 Armsdale Admin  Bldg
 Kitianning PA 16201
 (4121548 5458

 1585 Arcadia Road
 Lancaster, PA 17601
 17171 5954760
county Office
Mejdville
                                                                                     Meiter
                                                                                     MtfHlMIGWM
                                                                                     Mont rose
                                                                                     Nanticoke
                                                                                     Sniethport
                                                             Someiset
                                                                                     lowanda
                                                                                     Umonlown
County Served
Crawford
                                                                                                             Mercer
                                                                                                             Lawrence
                                                                                                             lumata
                                                                                                             Mitflin
                                                                                                             Susquehanna
                                                                                                             Wyoming
                                                                                                             luzerne
                                                                                                             McKean
                                                                                                             C ameron
                                                                                                             Potter
                                                                                     Somerset
                                                                                                             Bradford
                                                                                                             Sullivan
                                                                                                             Fayette
Address and Phone
t a Kau Building
Wairen 1012 Water Street
Meadville PA 16555
(814)7248117
                                                                                                             41 i (.,1 et-nville Road
                                                                                                             Meicer PA 16157
                                                                                                             (412)6624080

                                                                                                             22 North 4th Street
                                                                                                             Mifflmtown. PA 17059
                                                                                                             (717)4568951

                                                                                                             R D #5 Box27F
                                                                                                             Mont rose PA 18801
                                                                                                             (7171278 5781

                                                                                                             71 North Market sii..
                                                                                                             PO Bo* 148
                                                                                                             Nanticoke PA 18654
                                                                                                             (717) 7558700
                                                                                                             Marvin Street Lxteiision
                                                                                                             R 0 #1
                                                                                                             bmeihpmt PA IL741J
                                                                                                             (814)8875686
                                                                                                             R D »') Box 559A
                                                                                                             Somerset PA 15501
                                                                                                             (81414458914
                                                K D *5 Box 105
                                                TowjnJ.i PA 18848
                                                (717)2656165
                                                                                                             P 0 Box 2004 Greene
                                                                                                             255 South Mt Vernon
                                                                                                               Avenue
                                                                                                             umontown PA 15401
                                                                                                             (412)4572708
 Leesport
 Berks
 Schuylkill
 P' i fiox 520
 Leesport. PA 19555
 (21515724686
                                                                                     Was/iington
                        Washington
                        Allegheny
                        5 > Highland Avenue
                        Washington PA 15501
                        (412)2225060
 Lewisburg
 Union
 Snyder
 R D *2 P 0 Box 60
 Lewisburg. PA 17857
 (717)5244429
                                                                                     Waterford
                                                                                                             Erie
                                                R D »5 Rt 19
                                                Waterford PA 16441
                                                (814)7966781
                                    22
                                                                                                                        25

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o

X
H
 g.
 CX
-Tl
county Office

WHKIxirn
                       county Served
                          Wtlli.imf-port
                       Chpstpr
                       [lpl.iw.irp
                                                 lyrnminq
                                                 fhnton
                                                  York
Address and Phone

Putnam Building
ri East Avenue
wellsboro. PA 16101
in?) 7244812

1 North New Strppt
West Chester. PA 19 WO
(215I4369541

P 0 Box 68
Federal Building 240
?<10West Third Street
Williamsport PA 1770?
(7171 J?6 55S7

1 ?4 Plpasant Acres Poad
York PA 17402
(7171 757 7655
                            Appendix E
          Economic Development Administration
                         District Of flees
North Central PA Regional Planning and Development Commission
651 Montmorenci Avenue
Box 488
Ridgway. PA 15853
(814)7733162
Counties served  Cameron. Clearfield. Elk. Jefferson. McKean and Potter
                                                                                      Northwest PA Regional Planning and Development Commission
                                                                                      Suite 406 Biery Building
                                                                                      Franklin. PA 16323
                                                                                      (814)4373024
                                                                                      Counties served  Clarion. Crawford. Erie. Forest. Lawrence. Mercer, venango and
                                                                                                     Warren

                                                                                      Southern Alleghenies Planning and Development Commission
                                                                                      Suite 100 Southern Allegheny Plaza
                                                                                      1506 Eleventh Avenue
                                                                                      Altoona. PA 16601
                                                                                      (814)9461641
                                                                                      Counties served Bedford. Blair Cambria. Fulton. Huntingdon and Somerset
                                                                                                                Southwestern PA Economic Development District
                                                                                                                110 Market Street
                                                                                                                Pittsburgh PA 15222
                                                                                                                (412)591 1240
                                                                                                                Counties served Allegheny. Armstrong, Beaver. Fayette. Greene. Indiana. Washington
                                                                                                                              and Westmoreland
                                                                                                                SE DA Council of Governments
                                                                                                                Route »1
                                                                                                                lewisburg. PA 17837
                                                                                                                (717)5244491
                                                                                                                Counties served Centre. Clinton. Columbia. Juniata Lycoming. Mifflr  Montour.
                                                                                                                               Northumberland. Perry. Snyder and Union
                                                                                                                Northern Tier Regional Planning and Development Commission
                                                                                                                507 Main Street
                                                                                                                Towanda. PA 18845
                                                                                                                (717)2659103
                                                                                                                Counties served  Bradford. Sullivan. Susguehanna. Tioga and Wyoming

                                                                                                                Economic Development Council of Northeastern Pennsylvania
                                                                                                                1151 Oak Street
                                                                                                                Pittston. PA 18640
                                                                                                                1717)6555581
                                                                                                                Counties served  Carbon. Lackawanna. Luzerne. Monroe, Pike. Schuylkill &  I Wayne
                                                             ?4
                                                                                                                                                  25
                                                                                                       r

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                                                                               .Appendix  ?
                                       Meeting the Challenge
                           "Adopt-a-Small-System"
          California, long the bea-
          con of fresh attitudes and
          ideas, is the home of a new
          program which is putting
           the Mobilization con-
             cept   into   action.
              Alameda County
               Water   District
                (ACWD)   has
                founded     an
                "Adopt-a-Small-
               System" program
which is an inspirational example of
how water suppliers  can work  to-
gether to protect their public.
  "Adopt-a-Small-System" is the
brain child of an interagency small
systems outreach committee created
to address the unique problems of
small systems. Through the program,
small systems can draw on the  re-
sources available at  larger facilities.
The first step was compilation of a list
of services available from ACWD to
small systems within a 50-100 mile
radius. The list is a sampling of pos-
sibleservicesavailable with the phone
numbers of ACWD employees with
expertise in specific areas of water
systems management. The small
systems can pick up the phone and
talk to real live engineers and techni-
cians through an information clear-
inghouse on topics such as: sampling
and  testing, monitoring,  backflow
devices, meters, emergency operat-
ing procedures,  water main specs,
plant operation, training and safety,
hazardous materials, wells,corrosion
control, leaks, computer systems and
setting water rates.  Distribution of
this list and information about the
program is handled by circuit riders
from RWA and RCAC, who  have
established personal  relationships
with the small systems owners or
operators.
  A big part of the program is not just
offering to answer call-in questions,
but to educate the operators so they
can ask the right questions.  Since
many of the small systems have part-
time or volunteer operators, they may
not know enough about a problem to
aska good question, where to turn for
help, or even what the 1986 SOW A
Amendments require of them.
  Funds don't allow for ACWD
employees to travel to the small sys-
tems sites, but in addition to provid-
ing over-the-phone assistance, lim-
ited training at ACWD*s own  loca-
tions would be available. Small sys-
tems owners or operators  are wel-
come and  encouraged to  visit the
facilities and meet one-on-one with
the technicians and engineers there.
  The Bay Area Resource Council
(BARC) is being told of the genesis
and progress of the "Adopt-a-Small-
System" in hopes that neighboring
 utilities will follow in suit and estab-
 lish a help network throughout The
 Bay Area. At the April meeting of the
 California chapter of  the AWWA,
 ACWD presented its program effort.
   The wheels are in motion and all
 "Adopt-a-Small-System" needs now
 are some phone calls  from anyone
 with questions, advice or who just
 wants to touch base. No question is
 too small or large. If ACWD cannot
 help, they can at least steer the in-
 luirer in the right direction..
   For more information on "Adopt-
I a-Small-System"  or for a list of the
javailable services call John Marchand
I of ACWD at (415) 659-1970 ext. 522.
             Congressional  Legislation
     Legislation presently being considered by Congress which
                 may affect small water systems.
 Small Community Environmental Assistance Act of 1990-Sen. Bau-
 cus (D-MT>—This bill was introduced in February 1990 and would direct
 states to create revolving loan programs to help small communities con-
 struct wastewater treatment works, public water systems, and solid waste
 facilities.
 Rural Economic Development Act of 1989-Reps.  English (D-OK),
 Coleman (R-MO), and Gunderson (R-WI)—The bill would authorize $60
 million for grants and loans to be made available to small water and waste
 disposal facilities whose communitiesface "significant" health risks. (Status:
 in the Agriculture Committee).     -;x
 Rural Partnership Act of 1989-Sen. ILeehy (D-VT>—The bill would call for
 the Rural Electrification Administpatjorltomake loans to local governments
 to provide water, sewar and wasillScility. services.  (Status: good for
 passage {MsiS^nr^oFSa^                      •••••V.^Y-	
 Rural YtMr^^]^*\»^^j^^9^^^^fd^ jp.iJD}--The
 bill would-'*c>c^s;.tha;pro                                      to
 small, sparsely:pbpulated, rural communities.  It would creafe'a single-pur-
 pose revolving fund  to incure appropriate water quality and quantity.
 (Status: in the Environment and Public Works Committee).
 National Infrastructure Council Act of  1990-Sens. Burdick (D-ND),
 Moynlhan (D-NY), Baucus (D-MT), Lautenberg (D-NJ), Warner (R-VA),
 Mitchell (D-ME), Bentsen (D-TX), Reid (D-NV), Lieberman (D-CT) and
 Breaux (D-LA)—The bill would establish a Council to coordinate technical
 assistance to communities needing advice on infrastructure issues and
 serve as a clearinghouse of information. (Status: in the Environment and
 Public Works Committee).
 Environmental Infrastructure Act of 1989-Sens. Domenlcl (R-NM), and
 Boren  (D-OK>—The bill is designed to  restore some of the tax-exempt
 status previously enjoyed by government bonds prior to the passage of the
 Tax Reform Act of 1986. (Status: in the  Senate Finance Committee).
                                                                                        May 1990

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                                                                                   l),.!,,i> ',
 (. I Af<«. W  R'
            ALAMEDA COUNTY WATER DISTRICT                 INTER-OFFICE MEMORANDUM


            TO:        BARRAP,  n£ir CH - RCAC              DATE:   JUNF  9,  5989


            FROM:      JOHN MARCHANU - LABORATORY

            SUBJECT:   ADOPT-A-SMALL SYSTEM PROGRAM ASSISTANCE
            The  attached is a  list  of advice and Information  services which the
            Alampda  County Water  District could provide  to  small  systems through
            the   Adopt-A-Sma11-System   Program   proposed   by   RCAC.   While  the
            District could  not provide routine, on-site  assistance,  small  system
            operators and staff would  be welcome to tour our facilities and meet
            with our technicians  and  advisors.  The District  could  also provide
            limited  training at our  facilities  in  the  areas  indicated  on the
            attached  sheet.   While   this   is,  of  course,   not  for  general
            distribution to all 10,800 small systems in our  state,  it could serve
            and  a guideline of  the  types of services which other larger systems
            and  utilities could  provide  to  smaller  systems.  Please  keep  me
            posted on the progress of the program.

            Later this month, the Bay Area Resource Council, a  group  of thp other
            large Bay Area water  systems,  will  he m«etinp here at  A.C.W.D.  At
            that time, I will  ask  what  services  they  could  provide to small
            systems.  I will keep you informed as to the  results of the meeting.
            c.c.  Jim Beard, General Manager, A.C.W.O.
                 Phil Utic, Operations Manager
                 Doug Chun, Operations Superintendent

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                                                                 Apcer.c:_:<  ?
AlAMEOA COUNTY WATER DISTRICT                INTER-OFFICE MEMORANDUM


TO:       ADOPT-A-SMAU. SYSTEM PARTICIPANTS  DATE:  FEBRUARY ?, 1990


FROM:     JOHN MARCHAND - LABORATORY

SUBJECT:  AOOPT-A-SMALL SYSTFM PROGRAM
In  August,  19R9,  the  Alameda  County  Water  District  agreed  to
participate  in  an  experimental  program  called  the Adopt-a-Small
System  Program.   The   basic  idea  is  to  provide  over-the-phonp
technical  assistance  or  limited  on-site  orientation  at A.C.W.D.
locations for operators of small water systems.

Since this is  a  new  and  experimental  program, there is no way to
predict the volume  of  inquiries  which we may receive.  Even thouqh
the list, was  first  circulated  in August, 1989, to my knowledge, no
one on the list  has  hepn  contacted.  I have included a copy of the
resource list for  your  information.  This memo may he a reminder to
some and may he the first notification to others about this program.

If you should  receive  a call from someone identifying themselves as
being from a  small  system,  please  give  them  the benefit of your
r-xpertisp.  Many of  these  operators may not know enough about their
water systems to  ask  a  decent question.  The District is taking it
upon itself to at. least turn them in the right direction.  If you are
contacted by anyone,  or have any questions about the program, please
contact me.

Thank you.

Attachment

C.c. Attached list
     0. Beard
     P. Ut1c
     r. Hill

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                     A1.AMEDA  COUNTY  WATER  PI STRICT
           fall  list, for  technical assistance 1-(415) 659-J970
Laboratory sampling nr  t.estinq  procedures  -  John Marchand  - ext.. :,
Monitoring rf?q;il ronifrits - Michael  Lanier  - ext,  0?0
Bockflow drvicp  testing and itMintpnancp -  Mikp. Rranco - cxt.579
      infori'iation and repair  -  Ed  litnon -  cxt. OQO
     rncy Operation Procedures  - Orry  Nottingham - cxt. D70
Nr-y; water main specificoHons and  standards  -  Gary McGhip - pxt. 410
Waler Trpatnipfit  Plant Opf?ration -  Rico Rossi  - ext. 511
Training and safety films and videos - Bon Arington - pxt.
Hazardous Materials - Jill Duoriq  -  sxt. 440
Operations and maintenance: - Clark Armstrong  - ext.573
Wflls, nenpral maintenance - Jim Edwards - ext.  D17
Cnomical handling and safety -  Orry  Nottingham - ext. 570
Corrosion Control - Torti  lyons  - ext 480
     rrp.iirs - Hank fscohar - pxt. 540
       " systems and telemetry  - Sam Yee  - ext.  571
Srtt-   water rates - Aftity W .njMUji  -  ext. ext 3Q>

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Steve Cowper
  Governor

Dennis Kelso
  Commissioner

AmtfKyle
  Deputy Commissioner

Larry Dietrick
  Director. Environmental
  Quality

Deena Henklns
  Chief, Wastewater and
  Water Treatment

Charier* Dengs, PhD
  Manager. Drinking
  Water Program
                                                                            Appendix Q
                                     DRINKING WATER PROGRAM
                                                   FACT SHEET
                            Goal
                            To protect the health of all Alaskans by ensuring that drinking water from
                            public water systems is safe.
Program Background

In 1974. the U.S. Congress passed the Safe Drinking Water Act which
established minimum standards for all public water supply systems in the
United States.  The U.S. Environmental Protection Agency (EPA) was put in
charge of this program and given the authority to delegate the responsibility
to the individual states, so programs could be more responsive to the needs
of individual states.

In Alaska, the Department of Environmental Conservation's (DEC) Drinking
Water Program administers the program through the state Drinking Water
Regulations. Various amendments to the original act and state regulations
have since been added, as more Is learned about how to do a better job of
protecting the health of the public.
Issue

Many people assume that an environment which looks pristine means
uncontamlnated drinking water. This is not necessarily true!  Even in
unpopulated areas, disease-causing organisms such as Glardla lamblia
from beavers or muskrats may contaminate the water, making it unsafe to
drink without treatment Other possible diseases caused by microorgan-
isms or viruses In drinking water include salmonellosis. cholera, gastroen-
teritis,  dysentery, hepatitis A, and typhoid fever.

High concentrations of minerals, such as lead and arsenic, or chemicals
from agriculture. Industry, mining, military operations,  homes, or Institu-
tions can also contaminate untreated water. Since 1974. many chemicals
have been linked to cancer, genetic mutations, and birth defects. In Alaska.
contamination of underground drinking water sources by petroleum prod-
uct leaks and spills is a particular problem.
                            Major Features

                            The major features of the Alaska Drinking Water Program include:
                                   Responding to water contamination emergencies
                                   Special-purpose sampling to identify and resolve contamination
                                   problems
                                          ADEC DRINKING WATER PROGRAM
                                                       . i .

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Major Features (continued)

'     Technical assistance to water system operators so they may do a better Job In producing and
      delivering safe drinking water
      Sanitary surveys of public water systems to Identify possible health problems
      Standards for new construction and operation
      Standards for public notification of problems/concerns with the water systems
      Maximum Contaminant Levels (MCLs) for Inorganic chemicals
      MCLs for organic chemicals such as pesticides, volatile organlcs such as petroleum
      products, and the by-products produced when organic compounds are disinfected along
      with the microbiological contaminants
*     MCLs for physical contaminants such as turbidity
•     MCLs for microbiological contaminants such as coliform bacteria
*     MCLs for radioactive contaminants
*     Minimum separation distances between water sources and potential sources of
      contamination such as sewage treatment systems and fuel tanks
•     Use of "lead-free" pipe, solder, and flux In water systems.


Progress to Date

•     Implementation of 18 AAC 80 - State of Alaska Drinking Water Regulations.
*     1989 proposed revision of the Drinking Water Regulations to include Volatile Organic
      Chemicals (VOCs) and enhance public notification procedures.
*     Implementation of a ban of lead pipe and solder in repairs and new construction of drinking
      water systems that connect to public water supplies.


Activities in 1989 to 1990

Upcoming revisions to the Drinking Water Regulations to includet

      Surface water treatment regulations
      Increased coliform bacteria monitoring requirements
      Requirements for the disinfection of all public water supplies
      Increased monitoring for inorganic and organic contaminants
      Increased monitoring for lead In drinking water.


Program Beneflts

The beneflts of both the DEC and EPA Drinking Water programs are that they improve the public
health and reduce the Incidence of waterborne diseases of all Alaskans regardless of whether they
live in the Bush or in town.
                               ADEC DRINKING WATER PROGRAM

                                           -2-

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                                                                                Appendix  Q
                              DRINKING WATER PROGRAM STAFF
                           CENTRAL OFFICE (JUNEAU) 3 465-2656

                           Charlene Denys
                           Drinking Water Program Manager

                           Kerry Llndley
                           Environmental Engineer
                           Rural Water Systems Coordinator
Steve Cowper
  Governor

Dennis Kelso
  Commissioner

Amy Kyle
  Deputy Commissioner

Larry Dietrlck
  Director,  Environmental
  Quality

DeenaHenktns
  Chief. Wastewater and
  Water Treatment

Chanene-Denys. PhD
  Manager, Drinking
  Water Program
NORTHERN REGIONAL OFFICE (FAIRBANKS) S 452-1714

Stan Justice
Environmental Engineer
NRO Drinking Water Program Manager

Linda Hendershot
Environmental Field Officer

Plan review is performed at the Interior. Tok. Nome, and North Slope district
offices. All other activity is conducted at the regional office.
SOUTHCENTRAL REGIONAL OFFICE (ANCHORAGE)  B 563-6529

Art Ronimus
Environmental Engineer
SCRO Drinking Water Program Manager

Lynette Dean
Environmental Field Officer

Plan review is performed at the Anchorage Western. Mat-Su. Kenai. and
Prince William Sound district offices. Other activity is conducted at either
the district or regional offices, depending on which district is involved.
                           SOUTHEAST REGIONAL OFFICE (JUNEAU)  8789-3151

                           RonFlinn
                           Environmental Field Officer
                           SERO Drinking Water Program Manager

                           Plan review is performed at the Juneau. Sitka. and Ketchlkan district
                           offices. Other activity is conducted at either the district or regional offices.
                           depending on which district is involved.
                                         ADEC DRINKING WATER PROGRAM

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Steve Cowper
  Governor

Dennis Keiso
  Commissioner

Amy Kyle
  Deputy Commissioner

Larry Dlf trick
  Director. Environmental
Deenn Henkins
 Chief, Waste water and
 Water Treatment
Charierte Dengs,
  Manager. Drinking
  Water Program
                                                                               Appendix Q
                                 TEN MOST FREQUENTLY ASKED
                            QUESTIONS ABOUT DRINKING WATER
                           1.
      WHERE DOES BIT DRINKING WATER COME FROM?
                           There are two possible sources for drinking water  surface water or ground
                           water. Lakes, reservoirs, streams, and rivers are "surface" water sources.
                           Ground water is surface water that has percolated through the soil into
                           underground aquifers. Ground water is the source of well water.
                           2.
      HOW DO I KNOW THAT MY WATER IS SAFE?
The DEC Drinking Water Program requires regular water testing of all water
systems that regularly serve 25 or more people.  Testing for bacteria is
required monthly: testing for chemicals is required less frequently. State
regulations require that all public water systems inform their customers of
any failures to either perform the required testing or "pass" the test.

As a consumer, you are entitled to information regarding your water sys-
tem: its test procedures, schedule, and performance record. Call your local
water supply or DEC office for Information.

Two groups of systems are not required to test their water on a regular
basis: private systems (i.e.. a well or a surface water source that serves only
one single-family residence), and small systems that serve less than 25
people (for example, a  4-plex apartment building that has its own water
source). There are no  regulations to ensure that the water from these types
of systems is tested regularly, or that consumers are Informed of any exist-
ing hazards.

3.    ON A DAILY BASIS. WHO MAKES SURE MY DRINKING WATER IS
      SAFE?

Your local water system operator ensures that your water is safe to drink.
He or she makes sure  the water plant is running correctly, applies whatever
kind of treatment the water requires, samples the water on a regular basis.
maintains test records, and notifies the public when a problem arises.

4.    WHAT HAPPENS TO MY DRINKING WATER BEFORE IT GETS TO
      ME?

If you have a well, the  water is most likely pumped directly from the well
Into your home or other watering point For small surface systems, water is
often piped to a holding tank, where chlorine or some other disinfectant is
added to kill bacteria and other microorganisms that are commonly found in
surface water. Larger systems may have more complex treatment: the
water may be strained to remove debris, like branches and rocks, and
treated with a coagulant to help make small particles settle to the bottom of
a sedimentation tank.  The water then may go through beds of gravel and
sand for final filtering. The final step of treatment Is to disinfect the water
before it goes into the  distribution system.
                                         ADEC DRDVKBVG WATER PROGRAM

                                                     • I •

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4.     WHAT HAPPENS TO MY DRINKING WATER?... (continued)

State regulations require that your water system regularly test the water provided to consumers to
make sure it is safe.


5.     HOW CAN DRINKING WATER BECOME CONTAMINATED?

Drinking water contamination can come from many sources, which is why most drinking water is
treated before it gets to the consumer.

Contamination before treatment can come from natural minerals and salts and human and animal
organic waste. (Even though they are natural, some minerals and salts can be dangerous if con-
sumed.) Leaking or corroded underground storage tanks, leaching landfills, agricultural runoff (con
talnlng fertilizers and pesticides), surface run-off (overflowing storm sewers, rainwater from oil-slick
or salt-treated roads), or improperly  disposed chemicals are among the more common pollutants of
drinking water.

Water can also sometimes be contaminated after treatment. For example, corrosion of certain pipir
materials can cause contamination with lead or asbestos.  Also, bacteria and dirt can get into the
water through leaking pipes.

6.    WHAT ARE THE MOST COMMON DRINKING WATER CONTAMINANTS IN ALASKA?

Primary - (Health hazard) Coliform bacteria, turbidity. Giardia. arsenic, volatile organic chemical
Secondary - (Aesthetics) Iron, manganese, calcium, color

7.    WHERE DO THE DRINKING WATER REGULATIONS COME PROM?

Congress passed the Safe Drinking Water Act in 1974. The Act required the U.S. Environmental
Protection Agency (EPA) to set drinking water standards (called Maximum Contaminant Levels, or
MCLs) for any contaminant that "may have an adverse effect on human health." In 1986. Congress
amended the Act to lengthen the list of contaminants to be regulated to protect public health.

The Act also allowed the federal government to delegate the responsibility for operating the drinking
water program to individual states.

The program was delegated to DEC in 1978. That means that  every time the federal government sets
standards, the state must set standards that are at least as strict as the federal standards and must
enforce those standards. DEC is in the process of revising the state drinking water regulations to
incorporate the new federal standards. The  revision process Is expected to continue for several more
years, as new federal regulations come into effect.

8.     WHO PATS TO KEEP DRINKING WATER SAFE?

The cost of keeping drinking water safe is ultimately paid by the consumer, through utility bills and.
in some cases,  taxes. Water system bills defray the cost of running the water plant, testing to make
sure the water is safe, and the purchase of new equipment to solve contamination problems. In some
areas, taxes help pay for building new water systems and modifying older ones to meet drinking wate
standards.

The state also pays for part of the operation  of the state Drinking Water Program. (About half of the
state Drinking Water Program is paid for by a grant from the U.S. Environmental Protection Agency.)

Currently, the average cost of drinking water in Alaska is a great value: one penny buys 80 8-ounce
glasses of treated drinking water.

                               ADEC DRINKING WATER PROGRAM

                                            -2-

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                                                                         Appendix  O

9.    WHAT ROLE DOES DEC PLAT IN KEEPING ALASKA'S DRINKING WATER
      SAFE?

DEC Drinking Water Program personnel review plans for new or modified water plants to ensure the
water system is properly engineered and will be capable of serving safe water they assist water sys-
tem operators and owners In meeting the requirements of the regulations: and they ensure that sys-
tems test their water as they should, and that the results are acceptable. If test results indicate there
is a problem. DEC works with the system operator to solve the problem. DEC also enforces its regula
Uons to make sure that drinking water is kept safe for all consumers.

10.   IF MY WATER IS FILTERED AND DISINFECTED AT THE TREATMENT PLANT, WILL
      AN ADDITIONAL FILTER ON MY TAP MAKE MY WATER EVEN SAFER?

Tap water from Class A or Class B public water systems should be safe from primary, health-threat-
ening, contaminants. Although secondary contaminants, those that affect the color, odor, or taste of
treated drinking water, do not pose a health risk, the consumer may wish to remove them prior to
consumption. Chlorine is one of the most common substances that consumers commonly prefer to
remove at the tap. While the smell and taste of chlorine assures the consumer that the water has
been treated to remove pathogens, a granular activated-carbon (GAC) filter attached to the tap is a re-
liable means of removing the smell and taste  of chlorine. A word of caution about GAC and other
"point of uae filter*:" Any filter must be regularly maintained to ensure proper operation and
cleaned to remove bacterial growth that actually can increase bacteria levels in the water as it comes
from the tap.
                              ADEC DRINKING WATER PROGRAM

                                           -3-

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Steve Cowper
  Governor

Dennis Kelso
  Commissioner

Amy Kyle
  Deputy Commissioner

Lorry Dfetrick
  Director. Environmental
  Quality

Oeena Henkins
  Chfe/ Wastewater arvi
  Water Treatment

Charlene Denys. PhD
  Marager. Drtnlrfn0
  Water Program
                                                       Appendix Q


                      GLOSSARY OF

            DRINKING WATER TERMS

Acute Exposure:  A single exposure to a toxic substance which results in
severe biological harm or death.  Acute exposures are usually characterized
as lasting no longer than a day.

Acute Toxiclty: The ability of a substance to cause poisonous effects
resulting in severe biological harm or death soon after a single exposure or
dose. Also, any severe poisonous effect resulting from a single short-term
exposure to a toxic substance.

Algae:  Simple rootless plants that grow in sunlit waters in relative propor-
tion to the amounts of nutrients available. They can affect water quality
adversely by lowering the dissolved oxygen in the water. They are food for
fish and small aquatic animals.

Background Level: In toxic substances monitoring, the average presence in
the environment, originally referring to naturally occurring phenomena.

Bacteria: (Singular  bacterium) Microscopic living organisms which can
aid In pollution control by consuming or breaking down organic matter in
sewage, or by similarly acting on oil spills or other water pollutants. Bacte-
ria in soil, water or air can also cause human, animal and plant health
problems.

Carcinogen:  Any substance that can cause  or contribute to the production
of cancer.

Carcinogenic:  Cancer-producing.

Chlorlnation: The application of chlorine to drinking water, sewage, or
Industrial waste to disinfect or to oxidize undesirable compounds.

Chlorlnator. A device that adds chlorine, in gas or liquid form, to water or
sewage to kill infectious bacteria.

Chlorine-Contact Chamber That part of a water treatment plant where
effluent is disinfected by chlorine.

Coliform Organism:  Microorganisms found in the  Intestinal tract of hu-
mans and animals. Their presence In water  indicates fecal pollution and
potentially dangerous bacterial contamination by disease-causing microor-
ganisms.

Community Water System: A public water system which serves at least 15
service connections used by year-round residents or regularly serves at
least 25 year-round residents.

Confined Aquifer: An aquifer in which ground water is confined under
pressure which Is significantly greater than atmospheric pressure.
                                           ADEC DRINKING WATER PROGRAM

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Contaminant: Any physical, chemical, biological, or radiological substance or matter that has an
adverse effect on air. water, or soil.                                                  •

Disinfectant: A chemical or physical process that kills pathogenic organisms in water. Chlorine is
often used to disinfect sewage treatment effluent, water supplies, wells, and swimming pools.

Epidemic:  Widespread outbreak of a disease, or a large number of cases of a disease in a single
community or relatively small area.

Fecal Colifonn Bacteria: Bacteria found in the intestinal tracts of mammals. Their presence In
water or sludge is an indicator of pollution and possible contamination by pathogens.

First Draw:  The water that immediately comes out when a tap is first opened. This water is likely to
have the highest level of lead contamination from plumbing materials.

Fluorosls: An abnormal condition caused by excessive intake of fluorine, characterized chiefly by
mottling of the teeth.

Flush: 1. To open a cold-water tap to clear out all the water which may have been sitting for a long
time in the pipes. In new homes, to flush a system means to send large volumes of water gushing
through the  unused pipes to remove loose particles of solder and flux.  2. To force large amounts of
water through liquid to clean out piping or tubing, storage or process tanks.

Fresh Water Water that generally contains less than 1.000 milllgrams-per-llter of dissolved solids.

Ground Water: The supply of fresh water found beneath the Earth's surface, usually in aquifers.
which is often used for supplying wells and springs. Because ground water is a major  source of
drinking water there is growing concern over areas where leaching agricultural or industrial pollut-
ants or substances from leaking underground storage tanks are contaminating ground water.

Hard Water Alkaline water containing dissolved salts that interfere with some Industrial processes
and prevent soap from lathering.

Heary Metals:  Metallic elements with high atomic weights, e.g.. mercury, chromium, cadmium.
arsenic, and lead. They can damage living things at low concentrations and tend to accumulate in th
food chain.

Hydrogeology: The geology of ground water, with particular emphasis on the chemistry and move-
ment of water.

Hydrology:  The science dealing with the properties, distribution, and circulation of water.

Infiltration: The penetration of water through the ground surface into sub-surface soil or the pene-
tration of water from the soil into sewer or other pipes through defective Joints, connections, or man-
hole walls.

Influent:  Water, wastewater. or other liquid flowing into a reservoir, basin, or treatment plant.

Interstate Carrier Water Supply: A source of water for drinking and sanitary use on  planes.'tmses.
trains, and ships operating in more than one state.  These sources are federally regulated.   *i<

Leachate: A liquid that results from water collecting contaminants as it trickles through wastes, agri
cultural pesticides or fertilizers. Leaching may occur in farming areas, feedlots. and landfills, and ma
result in hazardous substances entering surface water, ground water, or soil.
                                ADEC DRDVKDW3 WATER PROGRAM

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                                                                            Appendix Q

Lead (Pb): A heavy metal that Is hazardous to health if breathed or swallowed.  Its use in gasoline.
paints, and plumbing compounds has been sharply restricted or eliminated by federal laws and
regulations.  (See:  heavy metals.)

Million-gallon* Per Day (MGD): A measure of water flow.

Microorganism: Living organisms so small that Individually they can usually only be seen through a
microscope.

Multiple Use:  Use of land for more than one purpose; i.e.. grazing of livestock, wildlife production.
recreation, watershed, and timber production.  Could also apply to use of bodies of water for recrea-
tional purposes, fishing, and water supply.

Non-Community Water System:  A public water system that is not a community water system: e.g..
the water supply at a camp site or national park, school, factory or restaurant.

Non-ConTentional Pollutant: Any pollutant which Is not a statutortly listed or which Is poorly
understood by the scientific community.

Non-Point Source: Pollution sources which are diffuse and do not have a single point of origin or are
not introduced into a receiving stream from a specific outlet.  The pollutants are generally carried off
the land by stormwater runoff.  The commonly used categories for non-point sources are: agriculture.
forestry, urban, mining, construction, dams and channels, land disposal, and saltwater intrusion.

Organism:  Any living thing.

Pathogens:  Microorganisms that can cause disease in other organisms or in humans, animals and
plants. They may be  bacteria, viruses, or parasites and are found in sewage, in runoff from animal
farms or rural areas populated with domestic and/or wild animals, and in water used for swimming.
Fish and shellfish contaminated by pathogens, or the contaminated water itself, can cause serious
Illnesses.

Percolation: The movement of water downward and radially through the sub-surface soil layers.
usually continuing downward to the ground water.

Point Source: A stationery location or fixed facility from which pollutants are discharged or emitted.
Also, any single identifiable source of pollution, e.g.. a pipe, ditch, ship, ore pit. factory smokestack.

Pollutant:  Generally, any substance introduced Into the environment that adversely aflects the
usefulness of a resource.

Pollution: Generally, the presence of matter or energy whose nature, location or quantity produces
undeslred environmental effects. Under the Clean Water Act. for example, the term is defined as the
man-made or man-induced alteration of the physical, biological, and radiological integrity of water.

Potable Water: Water that is safe for drinking and cooking.

Pumping Station:  Mechanical devices installed in sewer or water systems or other liquid-carrying
pipelines that move the liquids to a higher level.

Reservoir:  Any natural or artificial holding area used to store, regulate, or control water.

Riparian Rights: Entitlement of a land owner to the water on or bordering his property, including
the right to prevent diversion or misuse of upstream waters.  Generally, a matter of state law.
                                ADEC DRINKING WATER PROGRAM
                                             -3-

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Run-Off: That part of precipitation, snow melt, or Irrigation water that runs off the land into streams
or other surface water. It can carry pollutants from the air and land Into the receiving waters.

Salinity: The degree of salt in water.

Sand Filters: Devices that remove some suspended solids from sewage.  Air and bacteria decompose
additional wastes filtering through the sand so that cleaner water drains  from the bed.

Maximum Contaminant Level: Maximum permissible level of a contaminant in water which is
delivered to the free flowing outlet of the ultimate user of a water supply, the consumer or of contami-
nation resulting from corrosion of piping and plumbing caused by water quality.

Semi-Confined Aquifer: An  aquifer that is partially confined by a soil layer (or layers) of low permea-
bility through which recharge and discharge can occur.

Soft Water:  Any water that is not "hard." i.e.. does not contain a significant amount of dissolved
minerals such as salts containing calcium or magnesium.

Solder:  A metallic compound used to seal the joints between pipes. Until recently, most solder
contained 50 percent lead.  The use of lead solder is now prohibited for pipes carrying potable water.

Sole Source Aquifer: An aquifer that supplies 50 percent or more of the drinking water of an area.

Surface Pump:  A mechanism for removing water or wastewater from a sump or wet well.

Surface Water:  All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, im-
poundments, seas, estuaries, etc.) and all springs, wells, or other collectors which are directly influ-
enced by surface water.

Toxic: Harmful to living organisms.

Toxic Pollutants:  Materials  contaminating the  environment that cause death, disease, birth defects
in organisms that ingest or absorb them.  The quantities and length of exposure  necessary to cause
these effects can vary widely.

Toxic Substance:  A chemical or mixture that may represent an unreasonable risk of injury to health
or the environment.

Toxicant: A poisonous agent that kills or injures animal or plant life.

Toxicity: The degree of danger posed by a substance to animal or plant life. (See:  acute tcodcity.)

Toxicology: The science and study of poisons control.

Trihalomethane (THM): One of a family of organic compounds, named as derivatives of methane.
THMs are generally the by-product from chlortnatlon of drinking water that contains organic material.

Turbidimeter: A device that measures the amount of suspended solids  in a liquid.

Turbidity:  1.  Haziness in air caused by the presence of particles and pollutants. 2. A similar cloudy
condition in water due to suspended silt or organic matter.

Urban Runoff:  Stormwater from city streets and adjacent domestic or commercial properties that may
cany pollutants of various kinds into the sewer systems and/or receiving waters.
                                ADEC DRINKING WATER PROGRAM

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                                                                              Appendix Q

Vims: The smallest form of microorganisms capable of causing disease.

Watershed: The land area that drains Into a stream.

Water Supplier A person who owns or operates a public water system.

Water Supply System: The collection, treatment, storage, and distribution of potable water from
source to consumer.

Water Solubility:  The maximum concentration of a chemical compound which can result when it is
dissolved in water.  If a substance is water soluble, it can very readily disperse through the environ-
ment.

Water Table: The level of ground water.

Well:  A bored, drilled,  or driven shaft, or a dug hole, whose depth is greater than the largest surface
dimension and whose purpose is to reach underground water supplies or oil. or to store or bury fluids
bdow ground.

Well Monitoring:  The measurement, by on-slte Instruments or laboratory methods, of the quality of
water in a well.

Well Plug: A watertight and gastight seal installed in a bore hole or well to prevent movement of
fluids.
                               ADEC DRINKING WATER PROGRAM

                                           -5-

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                                                                                     Appendix Q
                                                     HEPATITIS A
Steve Cowper
  Governor

Dennis Kelso
  Commissioner

Amy Kyle
  Deputy Commissioner

Larry Dietrtok
  Director, Environmental
  Quality

Drena Hentclns
  Chief. Wastf water and
  Water Treatment

Chaiiene Denys. PKD
  Manager. Drinking
  Water Program
Hepatitis A. previously known as "Infectious hepatitis." is a viral disease
that has been and continues to be a problem in Alaska.

Hepatitis A may spread In epidemic fashion by drinking contaminated water
or by Inadequate hand washing by food handlers or by eating raw shellfish
which were raised In water polluted by sewage. Improper handling of
drinking water in areas without piped distribution systems can be a major
contributing factor in those communities.

In Alaska, hepatitis A often occurs in a cyclic pattern.  It begins when a
population experiences on outbreak, after which it is immune to further
outbreaks. No new cases occur for five or 10 years -- until there Is a new
generation (mostly children) which has not previously been exposed. An-
other outbreak occurs and that new generation becomes immune. Every five
to 10 years, the pattern repeats itself.

There Is no treatment for hepatitis A. Immune globulin, if given immediately
after exposure, can sometimes prevent Illness in contacts. It is not fully
protective. The only real protection against hepatitis A is good personal
hygiene, proper treatment and handling of drinking water, and proper
disposal of human wastes.

Once a person has the disease, he or she is immune to reinfection. Work is
ongoing to develop a vaccine, but none is ready yet.

Hepatitis A should not be confused with hepatitis B (formerly serum hepati-
tis). This  type is usually spread through blood products or bodily fluids and
Is usually much more serious. Fortunately a preventatlve vaccine has been
developed for hepatitis B.

Symptons of hepatlts A Include nausea, vomiting, muscles aches and
jaundice which occurs approximately  15 to  45 days after exposure.  This
long Incubation period makes It difficult to relate the illness to the con-
sumption of contaminated water.
                                           AOEC DRINKING WATER PROGRAM

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Steve Cowper
  Gouerrior

Dennis Kelso
  Commissioner

Amy Kyi*
  Deputy Commissioner

lorry Dletrkk
  Director. Environmental
  Quality

Oeena HenJcirvs
  Chief. Wastewater and
  Water Treatment

Chariene Denys. PhD
  Manager. Drinking
  Water Program
                                                         C  ARDIA
Glardla lamblia is the single-celled animal (protozoan) which causes the
disease gtardlasls. or "beaver fever".  This organism is carried by warm-
blooded animals and has become the most common waterbome disease
the U.S.

In Alaska. DEC is very concerned about the possibility that this disease i
be spread by public water systems that use surface water sources.  The <
currence of this organism In the animals that live  n the watersheds of
public drinking water supplies, particularly beav-r and  muskrat. is ct
particular concern. Adequate treatment of this water is  the only protectic
trom infection since there are no preventative medicines or vaccines for t
disease.

This organism can exist In both the free-swimming (trophozoite) form wh
lives in the intestines of warm-blooded animals, or in the cyst or dorman
form. The cyst form is very resistant and can survive outside of an infect
animal for a long time. Drinking untreated water contaminated with as f
as one to ten cysts is enough to cause infection. The cyst form is the ma
concern of water treatment plants since the free-swimming form cannot
survive for  long outside of a carrier on its own.

The new EPA surface water treatment rules will require filtration for mosi
surface water systems and specific disinfectant concentrations and coma
times to treat surface waters for Giardla.  (Under the previous standards.
chlorine concentrations and contact times were established for bacteria.:
single-celled animals.) After much research, new standards and treatmei
techniques have been devised to protect against Giardla cysts.

Glardlasis may also spread through direct person-to-person contact. The
spread of the disease among children at day-care centers is fairly commoi
In such cases, cleanliness and proper hand washing is  the key to prevent
infection.

Symptoms of giardlasis usually occur from one to four weeks after infectii
and include explosive, watery, foul-smelling diarrhea, gas in the stomach
intestines,  nausea, and loss of appetite. Giardiasis is treated by one or
more of the four commonly prescribed drugs available in the U.S. Becausi
there are no drugs that can prevent the disease, water treatment is the or
means of preventing It.  Boiling water for 20 minutes is an effective mean*
killing the giardia organism in small  quantities of water.
                                            ADEC DRINKING WATER PROGRAM

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                                                                                     Append.x 0
Steve Cowper
  Governor

Dennis Kelso
  Commissioner

Amy Kyle
  Deputy Commissioner

Lorry Dietrfck
  Director, Environmental
Deeno. Henklna
  Chief. Wostewoter and
  Water Treatment

Charlene Denys. PhD
  Manager. Drinking
  Water Program
                                              CRYPTOSPORIDIUM
Cryptosporidium has been called the "new super-bug" of the water treat-
ment industry.  It. like Glardla lamblla. is a single-celled protozoan that
resists chlorinatlon.

Almost any animal found in a watershed may serve as a host to this organ-
ism, including birds, fish, and reptiles. In a rural setting, cattle seem to be
the most common animal-to-human carrier. In urban settings, bacterial
contamination from day-care centers, sexual activities, food-handling, and
water storage and handling are common sources.

As with Giardia. Cryptosporidium exists in either the free-swimming, tro-
phozolte  form or the dormant oocyst form.  One oocyst is enough to cause
an infection and the symptoms include diarrhea, stomach cramps, nausea,
dehydration, and headaches.

Presently, there is no cure for cryptosportdiosis. but the disease is self-
limiting in individuals with healthy immune systems. However, once in-
fected, the host is a life-time carrier and subject to relapses. Among people
with suppressed immune systems,  such as those Infected with acquired
immune  deficiency syndrome (AIDS), the disease is life-threatening and is.
in fact, a major cause of death among AIDS patients.

Water  treatment for Cryptosporidium must rely on properly designed and
operated filtration systems. Chlorine disinfection of the organism Is ineffec-
tive. One study has shown that the oocyst can withstand pure bleach
(50.000 parts-pcr-mlllion chlorine)  for 24 hours and still cause an infection!
Boiling water for as little as one minute,  however, will kill the organism.

So far there have only been two confirmed outbreaks of cryptosportdiosis in
the U.S.  There have probably been more. but. until recently, both crypto-
sportdiosls and glardlasls have been diagnosed as acute gastroenteritis.
                                           ADEC DRINKING WATER PROGRAM

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Steve Cowper
  Governor

Dennis Kelso
  Commissioner

Amy Kyle
  Deputy Commissioner

Larry Dtetrtck
  Director, EniAronmental
  Quality

Deena Henktns
  Chief. Wastewater and
  Water Treatment

Charier* Denys. PhD
  Manager. Drinking
  Water Program
                                                OTHER  DISEASES
Of all the reported cases of waterbome diseases in the U.S.  from 1920 to
1980, only 56% of them could be traced to an identifiable cause.  The
remaining 44% were classified as "acute gastroenteritis." characterized b?
symptoms of abdominai -amps, nausea, vomiting, and diarrh  ;  occurrtr
from 12 to 48 hours afu   msuming contaminated water. In   .ny of the
cases, the search for the   use of the outbreak was either linn jd to thos<
organisms that are easily -entified. or a qualified specimen was either nc
taken or not taken in a timer/ manner.

Despite advances in laboratory techniques, water sampling techniques, a
knowledge of newly recognized and Identifiable disease agents, causes of
outbreaks frequently cannot be determined. The challenge of supplying s,
water continues.

In the interim, the best means of assuring that drinking water from a sur
face source is safe is to employ the old standbys: chlorlnatlon and fllt.rat.lc
or boiling.
                                           ADEC DRINKING WATER PROGRAM

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                                                                                                      Augu»t 1990
 DEPARTMENT OF ENVIRONMENTAL SERVICES
 State of New Hampshire
 P.O. Box 95, Hazen Drive
 Concord, NH 03301-6628
 603-271-3445/3446
         Radon  Facts
        Does your household water come from a well? If so,
you may have radon gas in your water.
        Radon  gas  is  normally found  in  all  wells  but
particularly in bedrock (sometimes called "drilled" or
"artesian") wells. If you obtain your water from such a source,
you may want to know to what degree radon gas is present in
your water. Every well has some radon. The  important question
is how much.

What is Radon?
       Radon is a radioactive gas produced through the decay
of naturally occurring radioactive minerals in soil and rocks. It
is colorless, odorless, and tasteless. Radon gas  can  dissolve in
water and  later be released into the air during such normal
household activities as showering. Radon gas can also enter a
home directly from the soil  beneath and around the building.
When trapped in  an enclosed space (such as indoors), radon gas
can accumulate and pose a significant health risk.

Health Effects
       Radon  gas  is unusual  among drinking water
contaminants in that it is not normally harmful when consumed.
The  primary risk  from exposure to radon gas is through
breathing. Studies show that  high levels of radon gas in the air
increase the risk of lung cancer.

How Much is Too Much?
       Radon  gas  in air  or  in water  is  measured
in pCi/L. Generally, a radon gas concentration of 10,000 pCi/L
in water can be expected to increase the radon level of the air by
IpCi/L.
       The U.S. Environmental Protection Agency (EPA) has
set a radon "action level" of 4 pCi/L for radon gas in indoor air.
While not a health standard,  this level is a guideline for people
10 use in assessing the seriousness of their exposure. Above this
level, a homeowner should consider some  remedial action to
reduce  the radon p.esent in  the air. Appropriate actions could
include water treatment and/or remedial construction actions
such as basement venting or sealing.
       EPA is currently considering options for a new federal
drinking water standard between 200 and 2,000 pCi/L for radon.
We expect that up to eO% of the  bedrock  wells in N^w
Hampshire would fail suv.n a  future EPA standard.

Testing
        Because breathing radon gas is considered to be a
greater health risk than drinking water containing radon gas,
testing your air for radon gas is usually more important than
testing your water. However, if the level of radon in the air of
your home is high, you should  find out the level of radon in
your water, since its removal may be an effective means of
reducing the airborne levels in your home.
       Air:  Test kits may be obtained from Hutu Tnm  iig
the NH Department of Health and Human Services/£T271-
4674. A number of commercial laboratories also perform air
tests  for radon gas and kits are available from many hardware
and discount stores, toe cost can be from SIS to $40 per test
       Water:   A  test for radon gas in your drinking water
requires approximately three weeks for processing and costs
S15. A container for the radon water test may be obtained from
the DES Water Laboratory by calling 271-3445/3446.

Other Radionudides
       In addition to radon gas, other minerals such as radium
and uranium may produce dissolved radioactivity in your
drinking water. A test of your drinking water for radon gas does
not necessarily indicate the presence or absence of any other
mineral radionuclides,  nor does a positive test  for these
dissolved minerals imply  the presence of excessive amounts of
radon gas.  In other words, it will take two laboratory tests of
your  drinking water, one for dissolved radioactivity, the other
for radon gas, to address the radioactivity potential of your
water. For  more information, we recommend that you contact
the NH Dept. of  Health and Human Services, Radiological
Health Program, at 217-4585.

Treatment
       In most cases, removal of radon from indoor air is the
most effective means of reducing one's risk from exposure to
radon. The most commonly used reduction method for radon
gas in air is soil gas ventilation or suction, which works by
drawing away radon gas under and around the house.
Preventive measures such as sealing off potential radon gas
entry routes into the house (cracks in floors and walb) are also
effective. In new construction, the problem of radon gas entry
from the soil may  be avoided by  providing escape routes for the
gas so that  it does not  build up in the soil and enter the house.
       For more information on treatment removal methods
for radon in water, contact the DES Water Quality Er.£uv~ring
Bureau at  271-3139. For information about radon reduction
methods in your home's air, contact DHHS, 271-4674.

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 DEPARTMENT OF ENVIRONMENTAL SERVICES
 State of New Hampshire
 P.O. Box 96, Hazen Drive
 Concord, NH 03301-6528
 603-271-3445/3446
                                                                                                        Augu»t
  Arsenic     Fad
        Does your household water come from underground
water supplies? If so, you may have arsenic in your water.

        Arsenic is frequently found in  bedrock wells
(sometimes called "drilled" or "artesian" wells). Many wells
have some arsenic. The important question is how much.

Where Does Arsenic Come From?

        Arsenic occurs naturally in wells throughout the
United States. Geological reports dating back to the late
1890's testify to the presence of arsenic in NH bedrock. Other
sources of arsenic in the environment include meats,  fish,
shellfish, wines, cigarettes, and leafy vegetables.

Health Effects

       Some studies  suggest that  arsenic  may be a
carcinogen when inhaled or ingestetfJYxher studies indicate
that trace amounts of arsenic may be essential for metabolism.
Elevated levels of arsenic in water, however, have been
associated with chronic gastro-intestinal upset, diarrhea,
liver damage, nervous system changes, Mood unbalance, and
skin changes. There is  no need to treat water used for
bathing, toilet, washing, or other non-consumption uses.

       If you have specific questions about arsenic's effect
on you or your family,  you should contact your personal
physician. For more general information on arsenic's health
effects, contact the  Environmental Hcaiiit Risk Assessment
Unit of the Division of Public Health Services (271-4664).

How Much is Too Much?

       The U.S. Environmental Protection Agency (EPA)
has established a Maximum Contaminant Level for arsenic in
public drinking water supplies of .05mg/L. This figure  may
also be expressed as parts per billion (ppb) or parts per million
(ppm) [.OS mg/L = .OS parts per million » SO parts per billion].
EPA's health standard is based on the consumption, by a
normal adult male, of two liters  (appr* .imately 2 quarts) of
water per day for a lifetime (70 years).

       Within  the  next year, EPA is expected to propose a
revised standard for arsenic that will be more stringent than
the current standard.

       If the water in your well has an arst..ic concentration
over .OS mg/L, the U.S. standard, we recommend that you use
an alternate supply of water  for drinking and cooking, or
install a device to treat your drinking water.
Testing

        Because arsenic concentrations in well water \
with the seasons, we recommend that several tests of the w
be taken over a pehod of months to determine the true avca
arsenic concentration. The NH Department of Environme
Services Laboratory (271-3445) will test your water
arsenic for a S10 charge. A number of private laboratory
the state also test for arsenic.
Corrective Action
                                   \ to con
        There are two basic options: 1) )6 construct a :
and possibly different type of well, or 2) install a cream
system for your existing well-V
New well:

        Substitution of a shallow dug well may reduce
arsenic in your water, but such a well may also be affectec
backyard activities or surface water runoff.

        It is possible that a new bedrock well in a diffe
location will provide water with lower levels of arsenic. If
have a large lot, this may be an option. However, you she
check First to see if the arsenic levels  of all neighbor
bedrock wells are low before investing in a new bedrock wi

Treatment Devices:
       Our  experience over the past decade indicates i
the simplest and most cost-effective treatment to  remi
arsenic from drinking water is activated alumina. Only a I
gallons of water need to be treated per day.  (Typically
gallons per day will provide enough water for drinking
cooking purposes.) Water passes through the  cartridge
activated alumina into a small storage tank which holds
arsenic-free water until needed.
       This device installs easily under the sink ant
relatively inexpensive. You  must be sure  to replace
cartridge regularly, as arsenic levels will begin  to rise w
die capacity of the cartridge is exceeded. The old canri
may be disposed  of along with your houselv :: trash. Oi
treatment options include reverse osmosis and jcionizatkxi

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                                Ki ...•-.:•.    ,. •   -••'•vo'.vV "":'i>^d
                                -»^..-,;; -,  :-.-.• .«• • -  - • .-:^-^!*?,•:; •^•'<;'^
                                |S - ^-J' :l &*•' '^'' •  *:'; ^^vt4a;:|l
Summary of National Organizations1 Activities in Support
                of the Mobilization Strategy
                  Part 1 - Major Associations
»
JUN 1 2 1990

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
American Water Works Association (AWWA)

AWWA is an international, non-profit,
scientific, and educational association
dedicated to safe drinking water.  It was formed
to promote public health, safety, and welfare
through the improvement of the quality and
quantity of water delivered to the public and
the development of public understanding of the
industry.  The association has nearly 50,000
members including water utility managers,
superintendents, engineers, chemists,
bacteriologists, and others interested in public
water supply; municipal and investor owned water
departments; boards of health; manufacturers of
waterworks equipment; government officials and
consultants interested in water supply.

666 W. Quincy Avenue
Denver, CO  80235
(303) 794-7711
John Mannion, Executive Director

1010 Vermont Avenue, N.W.
Washington, D.C.  20005
Jack Sullivan, Washington Representative
(202) 628-8303

Trudie Lay, Small Systems Coordinator
(303) 794-7711, ext. 2309
o     Working through its sections, AWWA is
      providing valuable support for State
      drinking water program capacity building
      efforts in a number of States.
o     Serving on the Steering Committee for the
      National Training Strategy.
o     Collaboration on National Drinking Water
      Week.
o     Participating in the Low-Cost Small System
      treatment technology initiative.
o     AWWA's small systems effort is closely
      coordinating with and expressing strong
      public support for the Mobilization
      strategy.
o     Received Grant to develop 11 outreach
      strategies for use by outreach providers
o     Managing P3 grant for PA Mobile Home Park
      Cooperative.
o     Received Grant from Region 8 for
      Mobilization to communicate the impact of
      radionuclide contaminants on  small drinking
      water systems in Wyoming.
o     Regularly receives Updates on status of
      National Pesticide Survey.
o     Briefed one-on-one by NPS staff.

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
Association of Metropolitan Water Agencies
(AMWA1

AHWA represents the interests and concerns of
the nation's largest water supply agencies.

1717 K Street, N.W., Suite 1006
Washington, D.C.   20036
Diane Van de Hei, Executive Director
(202) 331-2820
o     Collaboration on National Drinking Water
      Week.
o     Through its member systems, support the
      State capacity initiative.
o     Some member systems are providing outreach
      and technical assistance to small systems
      located near their own operating area.
o     Regularly receives Updates and health
      effects materials from National Pesticide
      Survey.
Association of State Drinking Water
Administrators fASDWAl

ASDWA is the professional association that
represents the collective interests of State
drinking water programs.  Members of the
association are the drinking water program
administrators in the States and territories.
Other State and local drinking water personnel
may be associate members.  ASDWA works to meet
communication and coordination needs of state
drinking water program managers; facilitates the
exchange of information and experience among
state drinking water agencies and serves as a
liaison with Congress and U.S. EPA.
o

o

o
Received a grant to assist with the State
drinking water program capacity building
initiative.  Providing consultation and
advise to selected States.  Tracking State
program capacity building efforts
nationwide.
Collaborated with ODW in reviewing State
Compliance Assurance Plan grant proposals.
Serving on the steering committee for the
National Training Strategy
Participating in the Low-Cost Small System
Treatment Technology Initiative.

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                                                                        MOBILIZATION INVOLVEMENT
1911 N. Fort Myer Drive, Suite 1100
Arlington, VA   22209
(703) 524-2428
G. Wade Miller, Executive Director
Lori O'Toole (703) 524-2428
o     Collaboration on National Drinking Water
      Week.
o     Regularly receives Updates on status of
      National Pesticide Survey and health effects
      materials.
o     Received a grant to facilitate state
      participation in National Pesticide Survey
      pilot program.
Association of State and Territorial Health
Officials  fASTHOl

Executive officers of state and territorial
health departments.  Represents state and
territorial health officers on matters of
federal health, legislation, and policies; aids
public or private agencies dealing with human
health, especially in interstate and federal
relationships.

6728 Old McLean Village Drive
McLean, Virginia   22101
(703) 556-9222
George Degnon, Executive Director
Joy Silver  (703) 556-9222
o     Briefed several times on the State Capacity
      Initiative - ASTHO has indicated an interest
      in supporting our efforts - we are currently
      discussing possible specific actions with
      them.
o     Participated in review of National Pesticide
      Survey public information materials.
o     Briefed one-on-one by NFS staff.
o     Regularly receives NPS Update and health
      effects materials.
                                              f
                                              a

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
Association of State and Territorial Public
Health Laboratory Directors  fASTPHLDl

ASTPHLD facilitates the sharing of information
and techniqn      diagnostic and analytical
profession.* i  	-/ratory work.  Its membership is
comprised oi  une laboratory  directors in the
States and territories.
      The Health Effects Branch is working with
      the association to facilitate information
      transfer to the laboratory directors.
      The association has been briefed on
      Mobilization and has expressed an interest
      in maintaining a dialogue with us.
Chemical Manufacturers .Association  (CMA1

Manufacturers of basic chemicals who sell a
substantial portion of their production to
others.  Administers research  in areas of broad
import to chemical manufacturing, such as air
and water pollution control, and other special
research programs.  Conducts committee studies,
workshops, and technical  symposia.  Promotes in-
plant safety through incentive programs and
annual awards.

2501 M Street, N.W.
Washington, D.C.  20037
(202) 887-1100
Dr. Brenda Cuccherini
o     Association provided with information on the
      requirements for non-transient non-community
      systems.
o     Mat with Jeff Hass  5/90 to discuss possible
      Mobilizaiton activities.
o     DuPont has conducted a Safe Drinking Water
      Workshop that Jeff  Hass spoke at discussing
      NTNC systems.
o     CMA is interested in working with DuPont and
      other members to develop a big brother help
      networks.

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                                                                       MOBILIZATION  INVOLVEMENT
National Bank for Cooperatives  fCoBank)

A $12 million financial institution,
(cooperative bank) specializing in agricultural
and utility financing.  CoBank is a
consolidation of 11 strong banks for
cooperatives that joined efforts in January,
1989.
Conducting demonstration project in
cooperation with RCAC on financing and
outreach for small water and wastewater
systems.  P3 funding through OMPC.
P.O. Box 5110
Denver, Colorado 80217

Street location:
5500 South Quebec Street
Englewood, CO   80111
(303) 740-4000
W. M. Harding

Cooperative Extension Service  (CESi

Informal non-classroom educational system on
agricultural, home economics,  natural resources
and youth programs.  Affiliated with land grant
colleges and universities and  in partnership
with county, state, and federal governments for
funding and program development.
CES has been briefed on the Mobilization
Initiative and we have continued the
dialogue.  We have agreed to meet regularly
to discuss possible cooperative efforts.
CES has provided the Regional Mobilization^
Coordinators with guidance and information^
on working with State extension programs.

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                                                                        MOBILIZATION INVOLVEMENT
USDA Cooperative Extension  Service
Room 3347 South
14th & Independence Ave., SW
Washington, D.C.  20250-0900
Fred Swader
(202) 250-0900
Cynthia Garman-Squier
(202) 447-5245
Cathy Burwell
(202) 447-4682
o     State extension programs make information on
      safe drinking water available to consumers.
o     CES is interested in forming  a joint effort
      to provide training to small  communities on
      drinking water issues.  On the steering
      committee for the National Training
      Strategy.
o     Collaboration on National Drinking Water
      Week.
o     Promoted Meeting the Challenge on their
      electronic nail system to State CES Water
      Quality Coordinators.  Coordinators in KB,
      NC and Headquaters have requested additional
      copies.
Council of Infrastructure Financing
AuthoritiesfCIFAl

The purposes of CIFA are to:  educate
infrastructure financing agencies, other public
officials and the general public concerning the
sources, methods and needs for financing public
infrastructures in the U.S.; engage in research
and policy analyses; represent infrastructure
financing authorities before public bodies and
officials.

300 Metropolitan Square
655 Fifteenth Street, NW
Washington, D.C.   20005
(202) 347-6333
      CIFA has been briefed on Mobilization and
      strongly supports the effort.  Several joint
      conferences have been held on issues related
      to financing drinking water infrastructure
      in small systems.
      CIFA has published an article on the
      Mobilization effort in their  newsletter.

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                                SUMMARY OF  MOBILIZATION ORGANIZATIONS
     ASSOCIATION
           MOBILIZATION INVOLVEMENT
Council of State Governments

Joint agency of all state governments. Works to
strengthen state governments by: improving
administrative and managerial capability and
performance, promoting intergovernmental
cooperation; collecting, processing, generating,
and disseminating information needed by states,
assisting states in solving specific problems of
policy formulation and operations; serving as a
catalyst on issues and opportunities affecting
the states.

Iron Works Pike
Box 11910
Lexington, KY  40578
(606) 252-2291
Steven Brown, Dir., Center for the Environment
and Natural Resources
Presently applying for grant to work with
National Conference of State Legislatures in
addressing problems of small systems.
Edison Electric  Institute  fEEIl

Investor-owned electric utility companies
operating  in the U.S. Has  affiliate members in
North, Central,  and  South  America.

1111  19th  St., NW
Washington, DC   20036
William Fang  (202) 778-6617
C. Richard Bozek (202) 778-6641
Institute has been briefed on requirements
for non-transient non-community systems and
is interested in follow-up activities.
Mat with Jeff Haas 5/90 to discuss possible
cooperative efforts.
                                                                                                      a

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
Farmers Home Administration  fFmHA)

The (FmHA) is authorized to  provide financial
assistance for water and waste disposal
facilities in rural areas and towns of up to
10,000 people.  FmHA funds are allocated among
the States based on rural population and poverty
level.
o     FmHA has been briefed on Mobilization.
o     Engaged in an ongoing dialogue.
Grocery Manufacturers of America  (GMA)

Manufacturers of food and non-food products sold
through grocery trade.  Promotes high standards
in the manufacture and distribution of grocery
products.

1010 Wisconsin Avenue, N.W., Suite 800
Washington, D.C.   20007
(202) 337-9400
George Koch, President
Marsha McNeil (202) 337-9400

Paul Bruns, Ph.D.
Nabisco Brands Inc.
200 DeForest Ave.
P.O. Box 1944
East Hanover, NJ  07936-1944
(201) 503-4186
      Association has been briefed on the
      requirements for non-transient
      non-communities and is interested in
      supporting State Capacity and Public
      Education activities.
      Their Environmental Task Force »et with Jeff
      Hass and Peter Shanaghan 5/90 to discuss
      possible cooperative efforts.
      Has offered to print and distribute some of
      our public education materials. We have sent
      them samples of our publications.
      Interested in developing big brother help
      networks.

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                                SUMMARY  OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
League of Women Voters Education Fund (LWVEF)

Educational arm of the League of Women Voters of
the United States.  Conducts a variety of
research and educational activities related to
public policy issues.  Activities include:
developing objective information on important
national issues, sponsoring regional community
seminars on issues such as election systems,
land use, national security, and techniques for
more effective citizen participation in
government.

1730 M Street, N.W., Suite 1000
Washington, D.C.   20036
(202) 429-1965
Grant Thompson, Executive Director
Elizabeth Kraft, Director of Natural Resources
X266
Valerie Strauss, Agricultural Chemicals
o     Has received a grant to produce public
      education video.
o     Variety of activities in the public
      education area.
o     Participated in focus group on public
      attitudes toward drinking water and
      pesticides.
o     Participated in early planning discussions
      for National Pesticide Survey.
o     Reviewed public information materials for
      NPS.
o     Participated in focus group on public
      attitudes toward drinking water and
      pesticides.
o     Regularly receives Updates on status of NPS.

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
National Assoc Lation of County Health Officials
fNACHO)

Organization of county health officials.
Purposes are to:  stimulate and contribute to
the improvement of county health programs and
public health practices throughout the U.S.;
disseminate information on county health
programs and practices; participates in the
formulation and advancement of the policies of
the National Association of Counties.

440 First Street, N.W., Suite 500
Washington, D.C.   20062
(202) 783-5550
Nancy Rawding, Executive Director
o     Has established a formal agreement with the
      Local Health Officials Initiative.
o     Co-sponsored focus group for Local Health
      Officials to review information products at
      National Meeting.
o     Regularly publishes drinking water related
      articles in their newsletter.
o     Collaborating on National Drinking Water
      Week.
o     Represented on National Pesticide Survey's
      Regional/State/County Workgroups.
o     Reviewed public information NPS materials.
o     Regularly receives Updates on NPS status.
o     Frequent one-on-one breifings by NPS staff.
National Association of Towns and Townships
fNATaTl

Federation of state organizations and individual
communities.  To provide technical assistance,
educational services, and  public policy support
to local government officials of small
communities across the country.  Conducts
research and develops public policy
      Maintaining an open dialogue.  NaTAT has
      expressed an interest in publishing drinking
      water related articles.
                                                  10

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                                SUMMARY  OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
           MOBILIZATION INVOLVEMENT
recommendations to help improve the quality of
life for people living in small communities.
Sponsors educational conferences and training
workshops.

1522 K Street, N.W., Suite 730
Washington, D.C.   20005
(202) 737-5200
Jeffrey H. Schiff, Executive Director
National Association of Water Companies  fNAWCl

Privately and commercially owned and operated
water companies; associate members are
individuals with an engineering, scientific, or
other professionals interested in the
association.  Conducts research and informs
members of economic, legal and regulatory
developments; encourages communication between
investor-owned water companies and regulatory
agencies.

1725 K Street, N.W., Suite 1212
Washington, D.C.   20006
(202) 833-8383
James Graff, Executive Director
Elaine Krawiec  (202) 833-8383
Collaborating on National Drinking Water
Week.
Regularly receives Updates on National
Pesticide Survey.
                                                   11

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
National Conference of State Legislatures  (NCSL)

National organization of state legislators or
legislative staff.  Aims are:  to improve the
quality and effectiveness of state legislatures,
to ensure states a strong, cohesive voice in the
federal decision-making process; to foster
interstate communication and cooperation.
Provides training and development and service on
current issues.  Maintains Office of
State-Federal Relations in Washington, D.C. to
monitor federal legislation.

1050 17th Street, Suite 2100
Denver, CO  80265
(303) 623-7800
William Pound, Executive Director

National Education Association fNEAl

Professional organization and union of
elementary and secondary school teachers,
college and university professors,
administrators, principals, counselors, and
others concerned with education.

1201 16th Street, N.W.
Washington, D.C.   20036
Don Cameron, Executive Director
Joel Packer  (202) 822-7329
TEMPORARY LOCATION:Coyne Building
                   1156 15th St., NW
o

o


o

o
o

o

o
Have received a grant to prepare a guide for
State legislators on the impacts of the Safe
Drinking Water Act.
Working to support State Capacity and
Institutional Support Initiatives.
Have received a grant to provide direct
technical assistance to selected State
legislatures.
Regularly receives Updates on status of
National Pesticide Survey.
Reviewed NPS public information materials.
Association has been briefed on the
requirements for non-transient non-community
(NTNC) systems.
Have expressed an interest in publishing
public education articles on drinking water.
Mat with Jeff Hass 5/90  to discuss possible
cooperative efforts.
Looking into the possibility of providing
then with a listing from FRD8 of schools
which are NTNC systems  in answer to their
request for a state-by-state inventory of
affected public schools .
                                                   12

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                                                                       MOBILIZATION INVOLVEMENT
National Environmental Health Association (NEHA)

Professional society of persons engaged in
environmental health for governmental public
health agencies, public health and environmental
protection education, industry, colleges, and
universities.  Conducts national professional
registration program and continuing education
program.  Provides self-paced learning modules
for field professionals.

720 S. Colorado Blvd.
Suite 970, South Tower'
Denver, CO 80222
(303) 756-9090
Nelson Fabian, Executive Director
o     Actively support Local Health Officials
      Initiative.
o     Published special newsletter on the Safe
      Drinking Water Act and the local health
      official's role.
o     Have received a grant to  prepare a guide to
      agreements between State primacy agencies
      and local health departments.
o     Participating on the steering committee for
      the National Training Strategy.
o     Collaboration on National Drinking Water
      Week.
o     Regularly receives Updates on status of
      National Pesticide Survey.
National Governors Association  (NGA)

Governors of the 50 states, Guam, American
Samoa, the Virgin Islands, the Northern Mariana
Islands, and Puerto Rico.  Serves as a vehicle
through which governors influence the
development and implementation of national
policy and apply creative leadership to state
problems.  Keeps the federal establishment
informed of the needs and perceptions of states.
o
o
Provides support to State Capacity
Initiative as part of OW agreement with
OCEM.
Arranged briefings on National Pesticide
Survey for governors' representatives in
Washington.
Reviewed NPS public information materials.
One-on-one advance briefing on plans for NPS
final report.
                                                                                                      a
                                                  13

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
444 N. Capitol Street, Suite 250
Washington, DC 20001  •
(202)624-5300
Raymond Scheppach, Executive Director
Jim Solyst (202) 624-7739
Tom Curtis, Dir. Energy and Environment
Committee 624-5389
           MOBILIZATION INVOLVEMENT
Regularly receives Updates on NFS status.
National Manufactured Housing Federation

A group of associations of manufacturers and
owners of manufactured housing created to
represent their members before Federal and State
governments.
Mr. Dan Gilligan
1701 K Street, N.W. Suite 400
Washington, D.C.  20006
(202) 822-6470
Inviting EPA participation in their
conferences.
Involved in demonstration projects in TX and
PA.
Assisting in information transfer to a
number of small systems to facilitate
compliance.
                                                  14

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
National Restaurant Association  (NRA1

Restaurants, cafeterias, clubs,  contract food-
service management, drive-ins, caterers,
institutional food services, and other members
of the food service industry; also represents
establishments belonging to non-affiliated state
and local restaurant associations in
governmental affairs.
1200 17th Street, N.W.
Washington, DC  20036
William P. Fisher, Executive V.P.
Robert Harrington, Asst. Dir. of Tech. Service
(202) 331-5900

National Rural Water Association (NRWA)

NRWA's mission is improving the  quality of life
in rural and small towns.
NRWA's members are small publicly owned water
systems.

P.O. Box 1428
Duncan, Oklahoma  73534
(405) 252-0629
Sam Wade, Executive Director
John Trax  (202) 333-8830
      Association has been provided with
      information on the requirements for non-
      transient non-community systems.
o     Received a grant to provide training and
      technical assistance to small water systems.
o     Collaborate on National Drinking Water Week.
o     On the steering committee for the National
      Training Strategy.
o     Conduct demonstration projects in support of
      Mobilization objectives.
o     Regularly receives Updates on status of
      National Pesticide Survey.
o     Requested 50 additional copies of Meeting
      the Challenge to distribute to States. (Sent
      out by Roger Barnes)
                                                   15

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                                                       MOBILIZATION  INVOLVEMENT
National School Boards Association  fNSBA)

Federation of state school  boards associations,
and the boards of education in the  District of
Columbia and the Virgin  Islands. Provides
information on topics such  as curriculum
development and legislation and court decisions
affecting education and  school policy.
1680 Duke St.
Alexandria, VA  22314
(703) 838-6722
Kate Herber  (703) 838-6727
                                      o     Association has been briefed on the
                                            requirements for non-transient non-community
                                            systems.
                                      o     Met with Jeff Haas 5/90 to discuss possible
                                            Mobilization activities.
                                      o     Has offered to identify schools in LA and TX
                                            which would benefit from a big brother help
                                            network.
                                      o     Regularly receives Updates on status of
                                            National Pesticide Survey.
National Soft Drink Association  (NSDA)

Active members are manufacturers of soft drinks;
associate members are suppliers of materials and
services. Objectives include government affairs
on the national and state  levels; discussion of
industry problems; general improvement of
operating procedures.

1101 16th St. NW
Washington, DC  20036
(202) 463-6732
Dwight C. Reed
Michael Redman
President
Technical Director
                                      o     Association has been briefed on the
                                            requirements for non-transient non-community
                                            systems.
                                      o     Met with Jeff Hass 5/90 to discuss possible
                                            Mobilisation activities.
                                      o     They have a well established  network at the
                                            States level and has offered to possibly
                                            help with our State Capacity Initiative.
                                      o     Have been briefed on the possiblity of
                                            establishing a big brother help network.
(202) 463-6750
                                                  16

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                                SUMMARY  OF  MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                 MOBILIZATION INVOLVEMENT
National Water Alliance fNWAl

Corporations, nonprofit organizations, trade
associations, state and local governments, and
interested individuals.  Seeks to influence
national policies regarding water resources and
educate the public about problems affecting the
nation's water supply.  Disseminates information
on water pollution and conservation; presents
position papers to the U.S. Congress.

1225 I St., N.W., Suite 300
Washington, DC  20005
(202) 646-0917
Ron Linton, President

Rural Community Assistance Program  fRCAP)

RCAP is a national network of nonprofit
organizations dedicated to better rural health,
increased rural development, and enhanced
quality of rural life.  RCAP works  to improve
the delivery of water supply, waste disposal,
and related services to rural, low-income
residents.

602 s. King Street, Suite 402
Leesburg, Virginia  22075
Edwin Cobb, Executive Director
(703) 478-8652
o     Collaborate on National Drinking Water Week.
o     Regularly receives Update on status of
      National Pesticide Survey.
      Received a grant to provide technical
      assistance to small systems.
      Serve on the steering committee for the
      National Training Strategy.
      Conduct a wide variety of demonstration
      projects which support the Mobilization
      objectives.
                                                   17

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                                                                       MOBILIZATION INVOLVEMENT
Water Wastewater Equipment Manufacturers
Association  fWWEMA)

Manufacturers of equipment for water works,
wastewater, and industrial wastes disposal
plants; manufacturers1 representatives and
distributors.  Sponsors public relations, public
affairs, and marketing programs.
                        o
                        o
Collaborate in National Drinking Water Week,
Participate in the Low-Cost Small System
Treatment Technology Initiative.
P.O. Box 17402
Dulles International Airport
(703) 661-8011
Dawn Kristof, President
20041
                                                   18

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                                  ADDITIONAL ORGANIZATIONS WITH A POSSIBLE ROLE

                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION	MOBILIZATION' S INVOLVEMENT

American Association of School
Administrators  (AASA)

Professional association of administrators       o  Association  has  been provided with information on the
and executives  of school systems and               requirements for non-transient non-community systems.
educational service agencies; school
district superintendents; central, building,
and service unit administrators; presidents
of colleges, deans, and professors of
educational administration; placement
officers; executive directors and
administrators  of education associations;
heads of private schools.

1801 N. Moore St.
Arlington, VA   22209
(703) 528-0700
Richard D. Miller, Executive Director
Virginia Vertiz
Bruce Hunter
                                                                                                      "8

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                                     MOBILIZATION'S INVOLVEMENT

American Bankers Association  (ABA)

Commercial banks and trust companies;           o Association has been provided with information on th.
combined assets of members represent about      requirements for non-transient  non-communities and is
95% of the industry.  Serves banking            interested in follow-up activities.
industry through banker committee structure
in areas of banking professions, banking
organizations, communications, education,
government relations, and memberships and
administrative services.

1120 Connecticut Ave., N.W.
Washington, DC  2003d
(202) 663-5000
Don Ogilvie, Executive V.P.

American Council on Education (ACE)

A council of colleges and universities,         o Association has been provided with information on the
educational organizations, and affiliates.        requirements for non-transient non-communities and is
Represents accredited post-secondary              interested in follow-up activities.
institutions directly or through national
and regional higher education associations;
advocates on their behalf before Congress,
the federal government, and federal and
state courts.

One Dupont Circle, N.W., Suite 800
Washington, DC  20036
(202) 939-9300
Robert H. Atwell, President
Mr. Shelly Steinback (202) 939-9355

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION	MOBILIZATION'S INVOLVEMENT


American Federation of Teachers (AFT|

Works with teachers and other educational       o Association has been provided with information on the
employees at the state and local level in         requirements for non-transient non-communities and is
organizing, collective bargaining, research,      interested in follow-up activities.
educational issues, and public relations.
Conducts research in areas such as
educational reform, bilingual education,
teacher certification, and evaluation.
Represents members' concerns through
legislative action; offers technical
assistance.

555 New Jersey Ave., N.W.
Washington, DC  20001
(202) 879-4400
Albert Shanker, President
Gregory Humphrey (202) 879-4400

American Mining Congress (AMC)

Domestic producers of coal, metals, and         o Association has been provided with information on the
minerals; manufacturers of mining equipment;      requirements for non-transient non-communities and is
engineering, consulting, constructing, and        interested in follow-up activities.
leasing companies; financial institutions
that serve the mining industry.

1920 N St. N.W., Suite 300                                                                          &
Washington, DC  20036                                                                                ffi
(202) 861-2800                                                                                       p
John Knebel, President

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                                SUMMARY OF  MOBILIZATION ORGANIZATIONS

     ASSOCIATION	MOBILIZATION'S INVOLVEMENT

American Paper Institute

U.S. manufacturers of pulp, paper, and          o Institute has been provided with information on the
paperboard.  Gathers, compiles, and               requirements for non-transient non-community systems
disseminates information; conducts research       and is interested in follow-up activities.
on scientific and technical problems;
represents members in industry matters
before governmental, transportation,
industrial, and other agencies.

260 Madison Ave.
New York, NY 10016
(212) 340-0600
Red Cavaney, President
1250 Connecticut Avenue, NW, Suite 210
Washington, DC  20036
Marilyn Haugen (202) 463-2591
American Petroleum Institute

Producers, refiners, marketers, and             o Institute has been briefed on requirements for
transporters of petroleum and allied              non-transient non-communities and is interested in
products such as crude oil, lubricating oil,      follow-up activities.
gasoline, and natural gas.  Seeks to
maintain cooperation between government and
industry on all matters of national concern;
fosters foreign and domestic trade in
American petroleum products; promotes the
interests of the petroleum industry;

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION	MOBILIZATION'S INVOLVEMENT

encourages the mutual improvement of
members.

1220 L St. N.W.
Washington, DC  20005
(202) 682-8000
Charles DiBona, President
Stephanie Meadows, Senior Regulatory
 Analyst  (202) 682-8475


American Society of Agricultural Engineers
fASAEl

Professional and technical organization of      o Society has been provided with information on the
individuals interested in engineering and         requirements for non-transient non-community systems.
technology for agriculture.  Develops
engineering standards used in agriculture.

2950 Niles Road
St. Joseph, MI   49085-9659
(616) 429-0300
Roger Castensen, Executive Vice-President

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                                     MOBILIZATION'S INVOLVEMENT
American Textile Manufacturers Institute
fATMIl

Textile mill firms operating machinery for      o Institute has been briefed on the requirements for
manufacturing .md processing cotton,              non-transient non  .-mmunity systems and is interested
man-made, wool, and silk textile products;        in follow-up activities.
includes spinning, weaving, bleaching,
finishing, knitting, and allied plants; does
not include manufacturers of hosiery or
firms that produce man-made fibers and yarns
by a chemical process.  Operates public
relations program for the industry,
government relations program, textile market
program, and statistical and economic
information service.

1801 K St. N.W., Suite 900
Washington, DC  20006
(202) 862-0500
Carlos Moore, Executive V.P.
Nancy Weinberg  (202) 862-0580

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                     MOBILIZATION * 8 INVOLVEMENT
Association of Physical Plant Administrators
of Universities and Colleges (APPAUC)

Represents administrators in colleges and
universities; members in other categories
are school districts, governmental
installations, etc.  Individuals who have
responsibilities for buildings and grounds
of the institutions.

1446 Duke Street
Alexandria, VA   22314^-3492
Wayne Leroy, Associate Vice President
(703) 684-1446
o Association has been provided information on the
  requirements for non-transient non-community systems.
Council for American Private Education
(CAPE)

Coalition of national organizations serving
the interests of private schools  (K-12).
Weeks to promote understanding and
cooperation between private schools, public
schools, and the government at all levels;
to encourage the sharing of resources among
member organizations and their schools; to
stimulate the creation and effectiveness of
o Council has been provided information on the
  requirements for non-transient non-community systems.


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                                SUMMARY  OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                                     MOBILIZATION'S INVOLVEMENT
state and local private school groups; to
formulate and disseminate public policy
concerning private schools at the national,
state, and local levels.
1625 I St., NW, Suite 412
Washington, DC  20006
(202) 659-0016
Robert L. Smith, Executive Director
Carol Ruple (202) 659-00016
Council of Chief State School Officers

The 50 chief state school officers (state       o Association has been provided with  information on the
superintendents and commissioners of              requirements for non-transient non-community systems.
education) and the heads of education
agencies in the D. C., Guam, American Samoa,
Puerto Rico, the Virgin Islands, and the
Northern Mariana Islands.  Expresses
members' views on educational issues before
civic and professional organizations,
federal agencies, Congress, and the public.

379 Hall of States
400 N. Capitol St., N.W.
Washington, DC  20001-1511
Gordon M. Ambach, Executive Director
Carnie Hayes  (202) 393-8161

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                                SUMMARY  OF  MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                     MOBILIZATION'S INVOLVEMENT
Independent Petroleum Association of America
(IPAA)

Independent oil and gas operators, royalty
owners, and others (suppliers, drilling
contractors, bankers, oil attorneys,
trucking contractors, and rig building
contractors) interested in the production of
crude oil and natural gas.  Represents small
oil and natural gas producers in legislative
and regulatory areas at the federal level.

1101 16th St., N.W.
Washington, DC  20036
(202) 857-4722
H.B. Scoggins, Jr., President
Mr. Jim Groninger  (202) 857-4722

National Association of Conservation
Districts

A nonprofit organization serving as the
national instrument of its membership -
3,000 local districts and 54 states and
territorial associations. Conservation
districts, local subdivisions of state
government, work to promote the
o Association has been briefed on the requirements for
  non-transient non-community systems.
o The association has been briefed on Mobilization and
  has expressed an interest in maintaining a dialogue
  with us.
o Met with National Pesticide Survey's director to
  discuss contents and framework of NPS final report.
o Regularly receives Updates on NPS status.

                                                    I
                                                    a.

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                     MOBILIZATION'S INVOLVEMENT
conservation, wise use and orderly
development of land, water,  forests,
wildlife, and related natural resources,

509 Capitol t..ijurt, NE
Washington, DC  20002
(202) 547-6223
Eugene Lamb
o Offered to distribute materials for Mobilization.
National Association of Counties
                       *
Only national organization  in US
representing county governments. Purpose  is
to improve county government, act as liason
with other levels of government, act a voice
of county government and  advance public
understanding of rate  of  counties.

440 1st St., NW
Washington, DC  20001
(202) 393-6226
o The association has been briefed on Mobilization and
  has expressed an interest in maintaining a dialogue
  with us.
o Reviewed National Pesticide Survey's public education
  materials including health effects information.
o Represented on NPS regional/State/County workgroup.
o Met with NPS director to discuss contents and framework
  of final report.
o Briefed one-on-one by NPS staff when appropriate.
o Regularly receives Update on status of Survey.
                                                   10

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                                     MOBILIZATION'S INVOLVEMENT

National Association of Elementary School
Principals (NAESP)

Professional association of principals          o Association has been briefed on the requirements for
engaged in administration and supervision of      non-transient non-community systems.
schools with elementary grades, including
teaching principals, assistant or vice
principals, and supervising principals;
persons engaged in educational research and
in the professional education of elementary
school administrators

1615 Duke St.
Alexandria, VA  22314-3483
(703) 684-3345
Samuel G. Sava, Executive Director
Edward Keller  (703) 684-3345
National Association of Independent Schools
fNAISl

Independent elementary and secondary school     o Association has been briefed on requirements for non-
members; regional associations of                 transient non-community systems.
independent schools and related
associations.  Provides curricular and                                                              ^

                                                                                                    f
                                                  11                                                a
                                                                                                    x

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION	MOBILIZATION'S INVOLVEMENT

administrative research and services;
conducts seminars.  Offers computerized
services.

75 Federal Street
Boston, MA  02110
(617) 451-2444
John C. Esty, Jr., President
11 Dupont Circle, NW, Suite 210
Washington, DC  20036
Kellen Canavan (202) 462-3886



National Association of Manufacturers (NAM)

Manufacturers cooperating are non-              o Association has been provided with information on the
manufacturers having a direct interest in or      requirements for non-transient non-community systems.
relationship to manufacturing.  Represents
industry's views  on national and
international problems to government.
Maintains public  relations program.  Reviews
current and proposed legislation,
administrative rulings, and interpretations,
judicial decisions, and legal matters
affecting industry.

1331 Pennsylvania Ave., N.W.,
Suite  1500 N.
Washington, DC 20004
(202)  637-3000
Alexander B. Trowbridge, President


                                                  12

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                                SUMMARY  OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                                     MOBILIZATION'S INVOLVEMENT
National Association of Private Schools for
Exceptional Children fNAPSECl

Is concerned with the needs of private          o Association has been brief on requirements for
schools that work with exceptional children.      non-transient non-community systems.
Provides a forum for exchange among
facilities serving exceptional students and
acts as a national voice for these
facilities.  Informs parents and the public
of special services available to exceptional
students, in an effort to match the student
with the program best fitting his or her
needs.

1522 K Street, NW, Suite 1032
Washington, DC  20005
(202) 408-3338
Kenneth C. Terrell, Executive Director


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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                                     MOBILIZATION'S INVOLVEMENT

National Rural Electric Cooperative
Association

Rural electric cooperative systems, public
power districts, and public utility
districts in 46 states. Activities include:
management institutes, professional
conferences; training and consulting
services; legal representation; energy
efficiency and conservation campaigns.

1800 Massachusetts Ave., NW
Washington, DC  20036
(202) 857-9500
Bob Bergland Exec. V.P.

National Association of Secondary School
Principals (NASSP1

Secondary school principals and assistant       o Association has been brief on requirements for
principals; other persons engaged in              non-transient non-community systems.
secondary school administration and/or
supervision; college professors teaching
courses in secondary education.  Sponsors
National Association of Student Councils,
National Honor Society, and National Junior
Honor Society.

1904 Association Dr.
Reston, VA  22091
(703) 860-0200
Scott D. Thompson, Exec. Dir.


                                                  14

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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                                     MOBILIZATION'S INVOLVEMENT
National Coal Association  (NCA)

Producers and sellers of coal, equipment        o Have provided information on the requirements for
suppliers, other energy suppliers,                non-transient non-community water systems.
consultants, and coal transporters.  Serves
as liaison between the industry and federal
branches and agencies of government.  Keeps
members informed of legislative and
administrative actions concerning taxation.
Works with industry, consumers, and
government agencies to•control air
pollution.  Seeks improved conditions for
export of steam and metallurgical coal.

1130 17th St., N.W.
Washington, DC  20036
(202) 463-2625
Richard L. Lawson, President
David Branard (202) 463-2625
                                                                                                    a
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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION	MOBILIZATION' B INVOLVEMENT

National Licensed Beverage Association
(NLBA1

Bars, taverns, restaurants, cocktail            o Association has been provided with information on the
lounges, and hotels selling alcoholic             requirements for non-transient non-community systems.
beverages for on-premises consumption in
states where such sales are legal.  Conducts
server education programs.  Initiated
promotion of May as National Tavern Month,
an industry wide campaign.

4214 King St., W.
Alexandria, VA  22302
(703) 671-7575
Gerald E. Murphy, Executive Director
Kevin Kilgren (202) 638-6400
John Chwat (202) 638-6400

National Parent Teachers Association fNPTA)

6.6 million member association focusing on      o Association has been briefed on the requirements for
the concerns of children and youth.               non-transient non-community systems.

1201 16th Street, NW, Suite 619
Washington, D.C.  20036
Carolyn Henrich, Governmental Affairs
 Representative
(202) 822-7878
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                                SUMMARY OF MOBILIZATION ORGANIZATIONS
     ASSOCIATION
                     MOBILIZATION'S INVOLVEMENT
National Petroleum Refiners Association NPRA

Petroleum, petrochemical, and refining
companies.

1899 L St., N.W., Suite 1000
Washington, DC  20036
(202) 457-0480
Urvan R. Sternfels, President
Maurice McBride, Government Affairs
 Representative
(202) 457-0480
o Association has been provided with information on the
  requirements for non-transient non-community systems.
Pharmaceutical Manufacturers Association
fPMA)

Manufacturers of ethical pharmaceutical and
biological products that are distributed
under their own labels.  Encourages high
standards for quality control and good
manufacturing practices; research toward
development of new and better medical
products; enactment of uniform and
reasonable drug legislation for the
protection of public health.  Disseminates
information on governmental regulations and
policies, but does not maintain or supply
information on specific products, prices,
o Association has been provided with information on the
  requirements for non-transient non-community systems.
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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION	MOBILIZATION'S INVOLVEMENT

distribution, promotion, or sales policies
of its individual members.

1100 15th St., N.W.
Washington, DC  20005
(202) 835-3400
Gerald J. Mossinghoff, President
Tom White, Regulatory Affairs Representative
(202) 835-355
U.S. Catholic Conference  (USCC)

Civil entity of the American Catholic           o Conference has been briefed on the requirements for
Bishops "assisting them in  their service to      non-transient non-community systems.
the church in this country by uniting the       o Requested 400 additional copies of Meeting the
people of God where voluntary, collective         challenge to distribute to their school administrators
action on a broad diocesan level is needed."      and facilities managers.

3211 4th Street, NE
Washington, DC  20017
(202) 541-3000
Rev. Msgr. Daniel  Hoye, General Secretary
Richard E. Duffy (202) 541-3000
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                                SUMMARY OF MOBILIZATION ORGANIZATIONS

     ASSOCIATION                                 	MOBILIZATION'S INVOLVEMENT

U.S. Department of Education  (USDOE) -
Office of Private Education

Office responsible for advocacy and liaison     o USDOE has been provided with  information on the
for National non-public schools and               requirements for non-transient non-community systems.
religious schools.

400 Maryland Avenue, S.W., Rm 4137
Washington, D.C.   20202
Dr. Charles O'Malley (202) 401-1365
                      FTS  441-1365
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