&EPA
United States
Environmental Protection
Agency
Office of Water
(WH-550)
EPA 570/9-91-002
February 1991
Establishing Programs
To Resolve Small Drinking
Water System Viability
A Summary Of The
Federal/State Workshop
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Table of Contents
I. Introduction 1
Overview 1
Workshop Participants . 2
Workshop Agenda 2
II. Summary of Workshop Evaluations 2
III. Workshop Presentations 3
Washington 3
Connecticut 4
Maryland 6
Pennsylvania 7
The Legislative Process 8
i
IV. State Action Plan Excerpts 10
Arizona 10
Kentucky 14
Massachusetts 16
Missouri 20
Montana 22
Nevada 25
Pennsylvania 28
Utah 33
Vermont 35
V. Pennsylvania's Program 38
Introduction 38
DER's Viability Controls 38
PUC's Viability Controls 41
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I. Introduction
Overview
Currently, small water systems (those regularly serving between 25 and 3,300
people) represent 95 percent of all public water systems (PWSs) and account for over
70 percent of all drinking water regulation violations. As the Safe Drinking Water Act
(SDWA) Amendments of 1986 are implemented, small system non-compliance is
expected to increase. The States, acquiring more regulatory responsibilities as the
Amendments take effect, will bear the burden of the small systems problem. As a
result, States will need to adopt preventative strategies to reduce small system non-
compliance.
The Office of Drinking Water (ODW), with contractor support, organized a
workshop to help States develop programs to control the proliferation of new,
potentially non-viable, small water systems. The workshop was held in Scottsdale,
Arizona from September 22 to 24, 1990.
The workshop's goal was for every State to develop an "action plan" for
implementing small system viability initiatives. Each action plan identifies the program
elements needed to reduce proliferation of new small systems and discusses how the
plan will be implemented over the next two to three years. Some of the approaches
that States examined were: establishing financial and operational requirements as part
of the permitting process; encouraging interconnections; establishing water supply
plans; providing financial assistance and incentives to small systems; and strengthening
operator certification requirements. In writing their action plans States had to answer
such questions as: "What legal authority do we have?", 'Who must agree to our plan?",
'What are the obstacles to implementation?", "When can our program be operational?",
and "What will it cost?" The answers to these questions determined the types of
programs States chose. A copy of the State action plan format is included in Appendix
A of the report.
The workshop was unique in its "States helping States" approach. It was
designed to let State representatives exchange information and learn from each other's
experiences. State representatives were the "experts," trading knowledge of past
successes and failures. The workshop also allowed departments within each State to
coordinate their goals and activities.
This report summarizes the activities of the workshop. Sections on the work-
shop evaluations, the speakers' presentations, and the participant States' action plans
are included. Many States expressed interest in Pennsylvania's initiatives, so the report
also contains a section detailing Pennsylvania's strategy for ensuring small system
viability.
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Workshop Participants
Representatives from 10 States were chosen to participate in the workshop,
based on their response to an Association of State Drinking Water Administrators
(ASDWA) survey conducted in 1989. The States were: Arizona, Kentucky, Massachu-
setts, Missouri, Montana, Nevada, New Hampshire, Pennsylvania, Utah, and Vermont.
The diverse group of State representatives included: State drinking water program
staff, public utility and public service commission employees, legal representatives, and
State legislators and staffers. In addition to State participants, representatives from
Connecticut, Maryland, Pennsylvania, and Washington gave presentations on their
States' viability programs. EPA Headquarters and Regional staff and representatives
from the National Conference of State Legislatures (NCSL) and the Council of State
Governments (CSG) also attended the workshop. (A complete list of participants is
presented in Appendix B of this report.)
Workshop Agenda
The workshop was composed of three main sections: speaker presentations,
action plan development, and peer reviews. To begin the workshop, State participants
heard from representatives whose States have already implemented viability programs
and representatives who work with State governments and understand the legislative
process. On the second day, participants met in individual State workgroups to
develop their viability action plans. After States completed first drafts of the plans, they
reviewed the plans of other States. Each State workgroup analyzed between three and
five action plans. At the conclusion of the workshop, one representative from each
State presented a summary of his or her completed action plan. (A copy of the
workshop agenda is provided in Appendix C of this report.)
II. Summary of Workshop Evaluations
Before leaving the workshop, participants completed evaluation forms. The
evaluations were positive, and most participants felt that the workshop was valuable.
On the evaluation form, participants were asked to rank the following workshop
elements: State presentations, presentations on the legislative process, background
information for the action plans, and peer reviews. The average rating was four, on a
scale of one to five. The table on the following page summarizes the participants'
responses to the four workshop elements.
Participants had minor suggestions for improving the workshop. First, they felt
that too much information was presented to absorb in only three days. They would
have liked the workshop to have been longer or less rigorous. Participants also would
have liked more interaction with the speakers. They suggested that presentations
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SUMMARY OF
RATINGS FOR WORKSHOP ELEMENTS
Workshop Element
State Presentations
Legislative Presentations
Background for Action Plans
Peer Reviews
Very
5
20
13
9
8
Valuable
4
18
21
14
11
2
3
6
13
16
Not
2
0
1
2
4
Valuable
1
0
0
1
0
could have been shorter and there could have been a question and answer period
afterwards. In addition, they thought the peer review process would have been more
productive if States had reviewed fewer action plans. Some participants suggested
having groups of two or three States review and discuss each others' action plans.
III. Workshop Presentations
Representatives from four States, NCSL, and CSG gave presentations at the
workshop. The presentations featured many strategies for dealing with the small
systems problem. State speakers discussed elements of their viability programs, and
representatives from NCSL and CSG addressed how to use the legislative process to
implement viability programs. This section provides highlights from all the workshop
presentations.1
Washington
William liechty and Richard Siffert from the Department of Social and Health
Services (DSHS) and Robert Wubbena, formerly with DSHS, spoke about Washington's
small system viability program. The Office of Environmental Health Programs, located
in the DSHS, is responsible for implementing the SDWA. The Utilities and Transporta-
tion Commission sets rates for privately owned systems but does not have any viability
programs.
a more detailed examination of the programs in Connecticut, Maryland, and
Washington please see the U.S. EPA Report, "Ensuring the Viability of New, Small Drinking
Water Systems: A Study of State Programs."
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Washington has focused on water supply planning to reduce the proliferation of
new, non-viable small systems. In 1977, Washington adopted the Public Water Supply
Coordination Act (PWSCA), which created a planning process to regulate water system
development.2 The PWSCA authorizes counties to develop Coordinated Water System
Plans (CWSPs) that will: demarcate present and future water system service areas;
outline future water system development; establish procedures for authorizing new
water systems; establish shared use of facilities; and create a Satellite Support System
to provide assistance to small systems. As part of the CWSPs, all large systems, and
selected small systems, must complete individual plans to designate present and future
service areas.
Two key elements of Washington's planning approach are satellite management
and the Small System Management and Operations Program. Satellite management
enables small systems to transfer ownership or to seek assistance from larger utilities
in order to meet SDWA and State drinking water requirements. DSHS has sought to
inform all water systems that satellite management may resolve their financial, opera-
tional, and managerial problems. In addition, counties that have adopted the PWSCA
are required to assess the need for satellite management. The Small Water System
Management and Operations Program is designed for water systems that are not
required to file an individual plan. It consists of a financial program and an opera-
tions program. The financial program is intended to facilitate financing of anticipated
physical improvements required to operate a system. The operations program is
intended to ensure that systems have plans for operation and control, water quality
monitoring, emergency response, cross-connection control, and budgeting.
In addition to its planning program, Washington has strict permit regulations for
all PWSs. Chapter 248-54 of the Washington Administrative Code (WAC) sets standards
for system design, construction, monitoring, finance, operation, and management.
These regulations have been updated to expand the State's examination of proposed
systems to include tests of financial and operational viability.
The DSHS publishes many handbooks describing its programs. A list of these
publications and how they may be obtained is included as Appendix D of this report.
Connecticut
Raymond Jarema, from the Water Supplies Section of the Department of Health
Services (DHS) and Richard Albani, from the Department of Public Utility Control
(DPUC) gave presentations on Connecticut's program for ensuring small system
viability. DHS and DPUC are the two agencies with authority to restrict the creation of
2Revised Code of Washington, chapter 70.116.
4
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non-viable small water systems. In addition, the Water Resources Task Force, consist-
ing of 17 members, helped develop Connecticut's viability legislation.3
New small systems in Connecticut are limited by the Certificate of Public
Convenience and Necessity, the Connecticut Flan, and laws that mandate takeovers of
small systems. The Certificate of Public Convenience and Necessity is a joint DPUC
and DHS certificate that requires a new or expanding water system serving between 25
and 1,000 people to obtain a permit.4 A new water system is allowed to form only
when the State determines that an interconnection or a satellite arrangement is not
feasible. If such a determination is made, the system's technical, financial, and
managerial qualifications are evaluated by DHS and DPUC.
The Connecticut Plan, which is based on Washington's PWSCA, establishes an
area-wide planning program.* Water Utility Coordinating Committees (WUCCs),
composed of representatives of all utilities serving at least 25 persons, determine
future water needs and establish exclusive service area boundaries. Once existing
utilities are designated "service areas," they accept responsibility for all water systems
within their areas. CWSs serving more than 1,000 customers are required to write
individual water system plans, which outline the water sources they will use and the
area they will serve over the next 50 years.
Connecticut's takeover laws grant DPUC and DHS the authority to order a
solvent water company or municipality to take over a failing small water system.6 A
takeover may be ordered only after a system fails to comply with an Administrative
Order from either DHS or DPUC. Once a system is designated for acquisition, a joint
agency hearing is held to determine the most appropriate action. DPUC and DHS may
order the acquisition of the system by the most suitable public or private entity. If
acquisition is ordered, the acquiring company must make the necessary improvements
to the failing system, but is allowed to recover reasonable costs.
3The Task Force was formed as a result of Special Act 82-28, "An Act Concerning a
Study of State Agency Authority in the Management of Water Resources for Public Water
Supplies."
Connecticut General Statutes 16-262m.
'Public Act 85-535, "An Act Concerning a Connecticut Plan for Public Water Supply
Coordination," Incorporated into statutes as Connecticut General Statutes 25-32d and 25-
33 e-j.
'Connecticut General Statutes 16-2621 (n)-(q).
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Maryland
William Parrish, from the Water Supply Program in the Maryland Department of
'the Environment (MDE), spoke on Maryland's approach to small system viability. The
Water Supply Program has primacy over drinking water regulation and oversees water
system compliance and enforcement Other groups involved in regulating small water
systems include: the Comprehensive Planning section of MDE; counties; local govern-
ments; and the Public Service Commission (which regulates only 35 water and
wastewater utilities).
Maryland discourages the creation of new, non-viable water systems through a
county water supply planning program and a stringent permit process. Since 1969,
Maryland has required county governments to submit a comprehensive water plan to
MDE every two years.7 The plan must define which areas will require water service
from publicly owned utilities in the next 10 years and describe how proposed water
systems will finance construction and maintenance. A county water plan must be
consistent with all State and local comprehensive development plans, and it must
integrate all subsidiary water supply plans developed by local, private, State, or Federal
agencies within county boundaries. In developing a water plan, a county may require
a proposed facility to interconnect with an existing system. To enforce the county plan
requirement, MDE may withhold a construction permit for a water facility in a county
that has not completed a plan. This halts any development and puts pressure on the
county to submit a plan. MDE may also withhold a construction permit for a facility
not included in the county plan.
In addition to the comprehensive water plan, Maryland also has permit require-
ments that prevent the creation of new, non-viable water systems. Maryland's broad
statutory authority has allowed MDE to adopt extensive rules governing PWS permits.ฎ
To obtain a construction permit, a proposed community water system must submit a
financial plan and an operation and maintenance (O&M) plan. These plans outline the
proposed system's construction and maintenance costs and the expected revenues. An
MDE accountant reviews the plans, and if they are approved, an agreement is drawn
up between the owner, the MDE, and the county.
Privately owned systems must execute financial agreements, which include a
provision to establish three escrow accounts. The first is an initial O&M account used
to support the system until construction is finished and the systems becomes self-
supporting. The second is a repair/replacement account used to cover the repair or
7Title 9 of the Health-Environmental Code in the Annotated Code of Maryland outlines
'MDE's-statutory.authority. .... ,
8Maryland is trying to pass viability legislation to strengthen its regulations.
6
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replacement of the highest-cost treatment plant unit. The third is a sinking fund used
for system replacement. This account must be sufficient to replace the system 20 years
after construction. Revenue for the sinking fund is provided within a system's rate
structure.
Pennsylvania
Pennsylvania was the only State at the workshop whose representatives func-
tioned as speakers and participants. Steven Schmidt and Walter Harner, from the
Department of Environmental Resources (DER), Judith Koch Carlson, a Public Utility
Commission (PUC) rate analyst, and John Cromwell, a contractor for DER, gave
presentations on Pennsylvania's approach to ensuring small system viability. The
Division of Water Supplies in DER regulates all PWSs, and the PUC regulates all
investor-owned systems and municipal systems operating outside their boundaries
(approximately 15 percent of all CWSs).
Pennsylvania has initiated efforts to improve the viability of small systems
through DER and through PUC. DER already has established several viability pro-
grams, including: the Technical Assistance Program for Small Systems (TAPSS), which
offers on-site technical assistance and training to small systems; the Pennsylvania Small
Water Systems Committee, which functions as a clearinghouse and information center
for organisations providing small systems services; the Pennsylvania Infrastructure
Investment Authority Act (PENNVEST), which provides low interests loans and limited
grants for water and wastewater improvements; and the Mobile Home Park Coopera-
tive, which improves small systems' ability to obtain supplies and services by increas-
ing their economies of scale. These programs are discussed in detail in section V.
DER also is studying many new viability options. A major part of this effort
focuses on the permit process. The State would like to develop a viability screening
method which would be incorporated into the permit application. Applicants request-
ing construction permits will have to demonstrate that no better alternative means of
providing water are available, and they will need to provide detailed estimates of the
total capital cost, the total O&M cost, and the amount required in reserve to provide
for eventual system replacement. In addition, they will need to prepare a business
plan that includes pro forma balance sheets and income statements projecting five
years into the future.
Other options DER is considering are: providing incentives for large systems to
acquire non-viable small systems; passing legislation or regulations to order the
acquisition of small systems; developing regional planning; encouraging the formation
of multi-community water systems; and conducting public outreach and operator
training. These options are described more fully in section IV.
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PUC also has initiated efforts to ensure small system viability. The two pieces of
legislation that address viability are Act 24 and proposed House Bill 25. Act 24, which
passed in April 1990, encourages large systems to acquire non-viable small systems,
and House Bill 25 would allow PUC to order the takeover of a small system. (More
information on these are presented in section V.) Additionally, PUC has passed a .
water conservation policy and a universal metering order that applies to all utilities
under PUC jurisdiction. These programs require each utility to submit a plan for
metering all sources and customers.
The Legislative Process
State legislatures will play an increasingly important role in ensuring that water
systems comply with the SDWA Amendments. Many State regulatory agencies will
require additional legal authority to regulate the formation of small water systems that
may lack the technical, financial, and managerial capacity to protect public health.
Larry Morandi from NCSL and Steve Brown from CSG gave brief presentations on the
legislative process.
Passing legislation is difficult, but there are some guidelines State agencies and
drinking water programs may follow (see Exhibit 1). First, States must identify
whether legislation is necessary to implement a program. Historically, drinking water
issues have not been a priority with legislators. Because it may be difficult to generate
legislative interest, States must determine whether changes in regulations issued under
existing statutory authority will be sufficient to accomplish their objectives.
If legislation is necessary, State agencies must determine whether they need a
change in policy or just money to implement their program. This will determine
which committees will be involved. Next, agencies must learn the relationship of
policy committees to fiscal committees. For example, they should know whether a
policy committee acts before a fiscal committee and whether policy committee
members serve as fiscal subcommittee members in the drinking water area. State
agencies also need to decide whether they should request that an interim legislative
committee be established to study the issue and develop recommendations prior to the
session. To determine what bills may compete for legislative attention, agencies and
drinking water programs should know the status of other legislative proposals that
may relate to water quality. Finally, States should consider whether the governor or
the legislature is primarily responsible for drawing up the State budget.
To gain support for legislation, States must spark interest in drinking water
issues, actively involve all relevant parties, and gain a consensus on proposed solu-
tions. First, drinking water issues must achieve higher visibility. Generally, the issues
with the greatest costs gain legislative attention. Therefore, drinking water policies
should be tied to larger issues, such as growth management or infrastructure finance.
State agencies also should involve legislators as advocates of drinking water programs.
8
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Prc-Scssion
STATE LEGISLATIVE PROCESS
Session
N A I Ml N A I. C,' 11 N
Interim
Committee
Formation
*
Committee
Heanngs
\
/
Oonvnhtee
Recommendations
Opportunity for state drinking water agency input.
lla
11
If not. back
to initial
House
X
^
If passed
in same
form, to
Governor
lie
If disagreement,
to conference
committee
\
X
Final vote
in each
House
\
First Reading
and
Committee
Assignment
Committee
Hearings
Refenml to
Fiscal
Committee
X
s.
Committee
Recommendation
Conuniiioc
Recommendation
o
Referral to
other House -
Repeat 5-9
Second Reading -
Floor Amendments
Third Reading -
Final Vote
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To win support for legislation, agencies need to work with the Governor's office,
legislative leadership, and the relevant committee chairperson. In addition, State
agencies must form a consensus on the need for the proposed legislation and present
a united front at legislative committee meetings.. The final piece of advice, offered by a
Utah State Senator to Larry Morandi, is: "Don't ever write a one page bill: it might get
read."
IV. State Action Plan Excerpts
During the workshop, each State completed a draft action plan that outlines the
viability initiatives it will implement over the next two to three years. This section
presents excerpts from States' action plans, providing information on such programs
as water supply planning, permitting, and review, assistance to small systems, and
certification and licensing. The excerpts also summarize States' planned activities and
give a schedule for the activities' completion. Each synopsis provides a comprehensive
description of the State's viability program as it will be when all of the program
components are implemented. New Hampshire's action plan is not included because
the State requested no distribution at this time. Complete action plans may be
obtained by calling Penny Barles, at U.S. EPA, Office of Drinking Water, (202) 382-
5517.
Arizona
Arizona has four viability program objectives: to define the term "viability"; to
prevent the creation of new non-viable systems; to help existing systems become viable;
and to encourage the elimination of non-viable systems whose problems cannot be
corrected. To achieve these objectives, the State is considering many programs. One.
important program is to develop financial requirements that will test the viability of
new and existing systems. New systems would be required to develop business plans,
demonstrating that they have adequate financial, operational, and management
capabilities and that they have evaluated all other water supply options. Some other
programs the State is considering are: providing incentives for, or requiring, small
system takeovers; requiring financial assurances, such as bonds, from investor-owned
systems; promoting regional planning; attaching operator certification requirements to
permitting and local planning; and coordinating the permitting process between the
three agencies involved. These programs and others are outlined below. Any
questions about Arizona's action plan should be directed to the State lead contact:
Mr. Robert L. Munari, Manager
Field Services Section, Office of Water Quality
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Department of Environmental Quality
2655 E. Magnolia Street
Phoenix, Arizona 85034
(602) 392-4002
Viability Measures
Water Supply Planning, Permitting, and Review
Water Supply Planning:
- require PWS to track current users and undeveloped lots in approved
subdivisions it has committed to serve;
require PWS to manage water resources and plan source development,
system improvements, and extensions; and
- require continued compliance with the Arizona Ground Water Manage-
ment Act.
Business Plan for New PWSs:
- management requirements;
- operation requirements;
- financial requirements;
- full cost analysis; and
- evaluation of options.
Encourage Interconnections
Provide Takeover Mechanisms:
- eliminate obstacles to takeovers;
- provide incentives for takeovers;
- provide disincentives to current owners to fight takeovers;
- provide authority for mandatory takeovers;
- encourage quasi-public entity to run water systems; and
- provide emergency hauling.
Require financial assurances (primarily for investor-owned PWSs):
- require bonding mechanism to guarantee completion of construction;
- require guarantor to ensure proper operation; and
- -- --require sinking fund set aside for major equipment replacement.
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Inter-Agency Coordination:
- Water Systems Coordinating Council (statutory);
- Private Water System Advisory Committee (ad hoc-Department of Water
Resources);
- Rural Infrastructure Committee (ad hoc-Dept of Commerce);
- Councils of Government (statutory, ad hoc involvement); and
- Omnibus Drinking Water Legislation Development Committee (envi-
sioned; WSCC, RIG, Legislature).
Regional Planning:
- use 208-type plan as a vehicle for restricting development of new free-
standing water systems;
- encourage regional water service districts; and
- establish role in land use planning and non-point source management.
Assistance to Small PWSs
Financial Assistance:
- develop a state revolving loan fund to provide capital funding for small
water systems.
Certification and Licensing
Operating Certification:
- strengthen certification requirements;
- increase certification fees; and
- tie permitting, certification, 100-year assured supply (Dept. of Water
Resources), local planing and zoning, County Health Department license
requirements, and Certificate of Convenience and Necessity concepts into
a single process.
Other Measures
Emergency Operations:
- contamination;
- outages;
- interruptions; and
--*>* hauling (mandate in Certificate of Convenience and Necessity).
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link Agency Requirements for New Wells:
- well drilling permits (Dept. of Water Resources);
- plan and specification review (Dept. of Environmental Quality); and
- public service corporation adjudication (AZ Corporation Commission).
Violation Prevention:
- reminders prior to due dates;
reminders shortly after due dates but before formal enforcement actions
are taken; and
annual compliance status reports.
Planned Activities
Legislation Development
Identify what must go to the legislature:
ratification of program;
additional authorities;
- clarification of existing authorities; and
- authorization of dedicated funds and deposition of fees to support state
and county programs.
10/90 - 4/91 Option development:
- strategy and strawman legislation.
6/91 Workshop:
- implementation under current authorities and
- need for new legislation.
7/91 - 1/92 Develop legislation for 1992 Legislature:
- educate legislators and interest groups.
Regulation Development
Identify current authorities and what can be done under current authorities
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6/91 - 12/92 Rule development (for items that need rule changes but can
be done under current authorities)
Kentucky
Kentucky has three viability program objectives: to educate the general assem-
bly on the importance of ensuring small system viability; to define more clearly the
responsibilities of State authorities; and to expand and clarify legislation that grants
authority to agencies regulating PWSs. To reach its goals, the Drinking Water Branch
is considering several viability programs. One is an operating permit to ensure that
systems meet financial and managerial requirements. Presently, systems must meet
only technical criteria before they are issued a permit. Kentucky also is considering
the following programs: escrow account requirements for systems regulated by the
Public Service Commission (PSC); financial reviews of all small systems; satellite
management requirements for small systems; and technical assistance for systems
during construction. These programs and others are summarized below. Any
questions about Kentucky's action plan should be directed to:
Mr. John Smither, Branch Manager
Drinking Water Branch
Division of Water
Department of Environmental Protection
18 Reilly Road, Fort Boone Plaza
Frankfort, Kentucky 40601
(502) 564-3410
Viability Measures
Water Supply Planning, Permitting, and Review
Both the PSC and KyDEP have permitting authority to ensure that minimum
design, construction and operating requirements are met before construc-
tion.
The PSC conducts financial reviews to determine affordability and financial
requirements, such as system escrow accounts for the 210 regulated utilities,
The PSC authorizes new system interconnections with existing viable systems
for the 210 regulated utilities.
The PSC authorizes satellite management/ownership.
14
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The PSC grants exclusive service areas to districts. A system-wide planning
process needs to be implemented for all water systems.
KyDEP may need to regulate systems not regulated by PSC for financial
review, satellite management/ownership and service areas.
Assistance to Small PWSs
Technical assistance needs to be given before construction, to resolve any
design and construction problems needs to be developed.
Develop a program to certify system managers for all systems.
The PSC provides limited technical assistance for all regulated systems.
KyDEP is developing a program for State funding for water supply planning.
Certification and Licensing
KyDEP certifies water plant operators.
Ucensing of pump installers, well drillers, and plumbers is handled by other
departments.
Other Measures
Coordinate grants and loans by other intra-State agencies to incorporate
viability issues during decision-making process.
Planned Activities
Legislation Development
1990 - 1991 Work with the governor's office, legislative leaders and commit-
tee chairman to educate decision makers on viability issues of drinking water
systems
1991 Prepare appropriate legislation for introduction in the 1992 Legislative
Session
Regulation Development
"*- '1990 - 1991 ป Develop regulations which can be implemented without new
legislation no later than the 1992 Legislative Session
15
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Other Milestones
1990-1991 Develop- intra-agency agreements which can be implemented
without new legislation no later than the 1992 Legislative Session
Massachusetts
Massachusetts wants to limit the creation of new non-viable systems and
encourage the expansion of existing viable systems. To do mis, the State has planned
several viability initiatives. One of the most important is financial accountability
requirements for new systems. To obtain a construction permit, a system would need
to demonstrate that it has considered all available alternatives, and it must submit a
financial management plan. Other initiatives Massachusetts is considering include:
conducting financial reviews of existing systems; providing business management
assistance to newly formed systems; and expanding operator certification requirements
to very small systems. These options, as well as others, are described in the excerpts
below. More information on Massachusetts' action plan can be obtained from:
Ms. Yvette dePeiza, Program Manager
Division of Water Supply
Department of Environmental Protection
One Winter Street, 9th Floor
Boston, Massachusetts 02108
(617) 292-5857
Viability Measures
Water Supply Planning, Permitting, and Review
New Systems
New system approval regulations; permitting process to ensure that mini-
mum design, construction, and operating requirements are met before
construction:
- investigation of all available alternatives during the application process,
including interconnecting with an existing system;
- new system interconnection with existing viable systems;
- satellite management/ownership;
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- consolidating management with another existing system, etc.;
- review of financial management plan to assess viability, such as Letters of
Credit, bonds, escrow accounts, etc. can be considered;
- certified operator requirements must be met prior to operation;
- operation and maintenance manual required;
- emergency response plan required;
- engineer's certification of new systems before and after construction; and
- notice of cost to prospective purchasers at each point of sale or .
transfer/guidance to be developed.
Changes to original approved status:
- information required on any changes to original;
- transfer of permits approval required; and
- transfer of assets approval required.
Existing systems in compliance
Identification
Sanitary survey
Financial audit (worksheet to be developed with DPU)
Use of third-party groups to provide technical assistance
Existing systems in non-compliance
Municipal
Non-municipal
- DPU regulated and
- Non-DPU regulated
Identification
Sanitary survey
Enforcement action (orders, civil penalties)
All options for resolving the problem are considered including the following;
- revenue enhancements;
17
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- loans or grants;
- rate increases;
- takeovers;
- mergers; and
- abandonment
Assistance to Small PWSs
Provide technical assistance, before construction, to resolve any design and
construction problems.
Provide business management assistance to newly forming systems/third
party involvement, RCAP, NERWA, AWWA, NEWW.
Provide Financial assistance such as State funding for water supply planning
(to be investigated).
Hold training programs and seminars.
Promote the NERWA circuit rider program.
Certification and Licensing
Develop certified operator requirements for systems (VSS).
Promote shared certified operators for systems.
Develop a licensing program for well drillers, plumbers, and cross-connec-..
tion device testers.
Other Measures -
Outside task force on small water system issues:
- NERWA/Cadmus initiative for small systems (part of larger water supply
review program).
Safe Drinking Water Act Advisory Committee:
- small system issues workgroup.
Small system issues (1 FTE presently devoted).
Outreach activities:
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- "In the Main" newsletter.
Legislative initiative to bring Board of Certified Operators under DEP
jurisdiction
Special Measures of DEP
Linkage of all environmental data bases .for compliance determination.
Administrative penalties and orders:
- up to $25,000/day per violation.
Annual compliance fees and permit fees dedicated to DEP program.
Planned Activities
Legislation Development
No later than fiscal year 1993:
- obtain authority to order temporary supply interconnections in emergen-
cies and
investigate takeover alternatives.
Regulation Development
No later than fiscal year 1993:
- develop financial management plan requirements and
- develop notice of service cost for prospective purchasers
Other Milestones
No later than fiscal year 1993:
- create training school similar to existing waste water training facility;
- formalize relationship between DEP and DPU;
- develop guidelines for determining whether service to an existing system
is feasible;
- - develop field worksheet for collection of financial-data during sanitary
surveys;
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- develop operation and maintenance manual;
- develop responsibilities of certified operators (ongoing); and
- mobilize third party support.
Missouri
Missouri's goal is to prevent the formation of non-viable systems and to ensure
the viability of existing systems. To accomplish this goal, Missouri is developing such.
viability initiatives as: developing a permitting program that will guarantee technical,
financial, and continuing authority capabilities; developing financial requirements;
encouraging comprehensive water system planning; and improving operator certifica-
tion and training requirements. The excerpts below provide more detail on these
programs and others. The lead contact in Missouri is:
Mr. Jerry Lane, Director
Public Drinking Water Program
Department of Water Resources
Division of Environmental Quality
205 Jefferson Street
P.O. Box 176
Jefferson City, Missouri 65102
(314) 751-0535
Viability Measures
Water Supply Planning, Permitting, and Review
Modify permitting process to ensure that minimum design, construction, and
operating requirements are met before construction. This would include:
- requirement to provide certified as-built by PE;
- definition and establishment of continuing utility management and
operating authority requirements;
- requirement to have certified operators; and
- requirement to meet financial viability criteria.
Require financial review to determine affordability and financial require-
ments:
- establish financial ability criteria.
Require -water "supply plans for water-systems-every -5-10 years**.*.
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Establish hierarchy for continuing utility management and operating authori-
ty, which may include the following:
- new system interconnection with existing viable systems;
- satellite management/ownership;
- management O & M contracting; and
- receiverships.
County and regional review to specify each system's present and future
service areas and system improvements and expansion plans.
Assistance to Small PWSs
Develop management, operation, and maintenance manual (consider pub-
lic/private partnerships).
Modify state funding criteria to promote consolidation of management,
operation, and maintenance of water systems.
Develop tax free bond funding program for privately owned water and
sewer systems.
Certification and Licensing
Modify state regulations to require certified operators at all community water
systems.
Modify state regulations to require certified operators at all non-community,
water systems.
Planned Activities
Legislation Development
12/90 Request additional funds from Legislature
6/91 Clarify water quantity issues
6/91 Develop administrative authority and penalties
6/92 Expand permitting authority to include financial requirements
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6/92 Establish and define continuing authority requirements to ensure long-
term system ownership
6/92 Develop authority to appoint receiverships
Regulation Development
7/91 Identify existing regulatory authorities among state and local agencies
7/91 Develop a fee system
6/91 Operator certification regulations for community water systems
6/93 Operator certification regulations for non-community water systems
Other Milestones
7/91 Delegate some permit reviews to regional offices
7/91 Explore county cooperative efforts
7/91 Hire individual or contractor for planning
7/91 Provide assistance to water supplies
6/92 Modify permitting process
7/92 Develop MOUs or public/private partnerships
7/93 Hire additional staff to implement program
Montana
Montana wants to establish a viability program designed to limit the prolifera-
tion of new water systems and ensure the viability of existing systems. Montana
currently is drafting legislation that would require small systems to submit financial,
operational, and management information during the construction permit process. In
addition, the Department of Health and Environmental Services (DOHES) is consider-
ing a provision that would order small systems to maintain escrow accounts to ensure
future viability. Other viability initiatives include: developing an annual financial
reporting requirement; encouraging satellite management/ownership; providing
financial management assistance; and establishing operator certification requirements
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for non-transient, non-community system operators. The excerpts below describe
these programs and others. The lead contact for Montana is:
Mr. Dan L. Fraser, Chief
Water Quality Bureau
Department of Health and Environmental Sciences
Cogswell Building Room A206
Helena, Montana 59620
(406) 444-2406
Viability Measures
Water Supply Planning, Permitting, and Review
Develop permitting process to ensure that minimum design and construction
requirements are met before construction commences (existing).
Conduct construction inspections to ensure construction is in accordance
with Department of Health approval and follow-up inspections.
Review long-term financial viability.
Institute bonding provision to ensure capital improvements are made.
Develop an annual financial reporting requirement.
Establish more complete rules regarding minimum operating requirements
including pressure and service (application of 10 State standards).
Encourage new system interconnection with existing viable system (satellite
management/ownership).
Assistance to Small PWSs
Provide technical assistance to give operating and maintenance guidance.
Provide assistance for administration and financial management.
Adopt comprehensive performance evaluation/composite correction pro-
gram process to small ground water systems.
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Certification and Licensing
Mandatory certification for all community systems.
Require certification of non-transient non-community operators.
Require continuing education for community systems serving less than 100
and non-transient non-community system operators.
Strengthen training program.
Contract with rural water and rural community action committee to provide
training and technical assistance.
Provide more training for system administrators.
Other Measures
Formal Memorandum of Agreement between PSC and DHES to coordinate
efforts related to adequacy of facilities, service, and financial considerations
of small water systems.
Enforcement
Administrative Orders,
- Administrative penalties, and
- Civil penalties.
Planned Activities
Legislation Development
10/90 Draft legislation
Task force activities (ongoing)
10/90 Complete task force report
Prior to legislative session: Brief Director, Governor's Office, and key
legislators
10/91 Draft rules:
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- viability review standards;
- fees;
- administrative enforcement; and
- operator certification.
1991-1992 Reconvene task force
8/92 Develop recommendations for 1993 Legislature
Other Milestones
11/91 PSC/DHESMOU
1991-1992 Develop comprehensive performance evaluation process for
small systems
Nevada
Nevada's goal is to develop and enact State legislation that will provide the
financial, administrative, and institutional support needed to ensure the viability of new
small water systems. The State is particularly interested in increasing resources for
State program administration and providing financial and technical assistance to small
PWSs. Other viability initiatives being developed are: requiring new systems that will
not be operated by a governmental agency to post a performance bond; developing
more stringent operator certification requirements; and imposing administrative fines.
Excerpts from Nevada's action plan are provided below. More information about
Nevada's initiatives may be obtained from:
Mr. Jeffrey Fontaine, Supervisor
Public Health Engineering
Nevada Division of Health
Bureau of Regulatory Health Services
505 East King Street, Room 103
Carson City, Nevada 89710
(702) 885-4750
Viability Measures
Water Supply Planning, Permitting, and Review
i Any new public water system that will not be operated and maintained by a
governmental agency must post a performance bond, using some financial
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viability model, with the county for operation and maintenance for a period
of 5 years.
Assistance to Small PWSs
Enact legislation which provides financial support for small water systems in
meeting the existing and future requirements of the federal SDWA. Systems
must submit, prior to receipt of any financial support, a plan approved by,
the State Board to Finance Water Projects, that ensures viability.
Provide additional funds through existing programs such as Community
Development Block Grants and Section 501 of Tide V of the Federal Disaster
Assistance Act of 1989.
Establish a matching grant program administered by the State Board to
Finance Water Projects to provide financial assistance for capital improve-
ments required of non-investor-owned community and non-transient public
water systems.
Establish a revolving loan fund administrated by the State Board to Finance
Water Projects to provide low-interest loans for capital improvements
required of community water systems.
Appoint the Administrator of Nevada's Health Division, or his/her designee,
as a nonvoting advisory member of the State Board to Finance Water Pro-
jects.
Certification and Licensing
Require certification of operators of [community] all public water systems
which are designated surface water systems [or] and community water
systems serving 100 or more persons. Program is to be administered
through the Nevada Division of Health.
Establish an advisory board appointed by the Governor which consists of
water system operators to advise the Health Division concerning the proce-
dures and process of an operator certification program.
Operator certification program will encompass continuing education and
training.
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Other Measures
Urge by resolution the establishment of well-head protection zones to
protect the quality of community drinking water sources through planning
and zoning authorities as provided in NRS 278.020, NRS 278.150, MRS
278.160 and NRS 278.250.
Enact legislation which emphasizes the maintenance of primary enforcement
responsibility (primacy) at the State level for the drinking water program.
Increase resources for the administration of the State program.
Enact new provisions which state that willful violation of a regulation
pursuant to NRS 445.381 subjects a supplier to a civil penalty of not more
than $5000 per day as provided in NRS 445.397.
Authorize the State Board of Health to impose an administrative fine of not
more than $5,000 per day for the willful violations listed in NRS 445.397.
Appropriation of $300,000 to the Health Division for the preparation of an
inventory of the quality of Nevada's 440 community public water systems to
include an assessment of projected needs necessary to the comply with
current and future SDWA requirements.
Require approval of the State Health Division, the Division of Environmental
Protection, and the Division of Water Resources for parcel maps not within
the service area of a water system created as a general improvement district,
owned or created by a county or city, or regulated by the PSCN.
Specify that no supplier of water or sewer services which is subject to
regulation by the PSCN may dispose of or encumber any of its property
which is necessary or useful in the performance of its duties to the public
without first securing from the PSCN an order authorizing it to do so; and
declare that any such action made other than in accordance with the order is
void.
Issues to be resolved
Proliferation of individual wells in areas mat could best be served by a water
system. Water rights are a problem.
State authority to regulated quasi-water systems (those serving 2 to 14
- connections) that serve more than the individual household or complex of
buildings on a piece of property.
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Investigate existing authority to prohibit/deny construction of new water
systems with inadequate water supply potential.
What satellite management incentives the State Health Division can offer to
existing utilities.
Ability to review the entire operation and maintenance/revenue .package,and
approve/deny construction of new water systems.
Explore responsibility and authority for the management of failed systems.
Planned Activities
Legislation Development
1/91 Recommendations of the legislative committee on Water and Waste-
water Resources introduced as bill drafts to the 1991 Legislature
Ongoing: Coalition of cities, counties, private utilities, interested parties and
state government formed to assist passage of the proposed legislation in the
1991 Legislature
1/91 - 6/91 Coalition to resolve outstanding issues during the 1991 Legisla-
ture
Pennsylvania
Pennsylvania's goal is to control the proliferation of new non-viable water
systems and improve the viability of existing systems. Currently, the State is conduct-
ing a study that develops a viability screening method that will be incorporated into the
permit process. Eventually, this method will be applied to existing systems. (For
more information on this study, please see section III of this report.) The State also is
considering such viability measures as: providing financial assistance for water supply
planning and satellite management; improving operator certification requirements; and
directing training programs to small system needs. Excerpts from Pennsylvania's
program are provided below. The State's lead contact is:
Mr. Steve Schmidt, Chief, Program Development
and Evaluation, Division of Water Supplies
PA Department of Environmental Resources
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P.O. Box 2357
Harrisburg, Pennsylvania 17105
(717) 787-0122
Viability Measures
Screening Methodology for New Small Systems
Step 1: The Preliminary Engineering Conference presently called for in the PWS
Manual will be expanded. An early initial meeting will provide potential applicants .,
with a "pre-feasibility" analysis. The objective is to educate potential applicants
regarding full costs at as early a point as possible. In this meeting, DER engineers will
utilize a new cost model being developed by Gannett Fleming as part of this project.
The cost model is designed to provide a rough order-of-magnitude assessment of
capital, operation and maintenance, and replacement costs. The model will compute
total capital requirements and the total annual cost per connection from a fundamental
set of input assumptions provided by the potential applicant. Many potential appli-
cants will use the full cost "price signal" thus provided by DER as a basis for compari-
son shopping to see if they cannot find a more economically attractive alternative to
new system development.
Step 2: For applicants who choose to pursue new system development, the ^
scope of die Engineer's Report presently required to accompany the permit application
will be expanded in two respects:
The consideration of alternatives will be expanded to require a discussion of
the rationale for proceeding with new system development instead of
choosing an alternative means of providing water service, such as intercon-
nection to an existing system.
The proposed system design must be accompanied by a detailed cost
estimate, presenting estimates of:
- the total capital cost;
- the total annual O&M cost; and
- a prudent annual reserve requirement to provide for eventual system.
replacement.
Step 3: The O&M Plan requirement will be expanded to include a requirement
for a "business plan." The business plan will include the following components:
" < " -"Information to disclose more fully the ownership of the proposed system to
identify the parties responsible for its effective management.
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A pro forma balance sheet, projected 5 years into the future, to provide
assurance of adequate capitalization of the system.
A pro forma income statement, projected 5 years into the future and demon-
strating a positive cash flow, to assure revenues sufficient to cover the full
costs of the system.
Any additional guarantees that the system developer wishes to offer to assure
DER of the success of the business plan, such as:
- letters of credit confirming the commitment of capital to the project;
- a commitment of funds in escrow, a performance bond, or another form
of insurance;
- a commitment to hire a credible contract O&M company; and
- a commitment from a guarantor to take responsibility for the system if
the business plan fails. (Guarantors could include: nearby water systems
capable of extending service; local governments; county authorities;
private water companies; private contract O&M firms; and other credible
entities.)
Step 4: Conformance with the business plan will become a condition of the
permit. The annual operating report requirement will be expanded to require an
annual financial report sufficient to allow a clear comparison of actual versus planned^
financial performance.
To complement and reinforce the incentives implicit in the modified permit
process, DER will undertake programs of public education to assure that the general
public as well as targeted groups such as consumers, homebuyers, mortgage lenders,.
and local government officials are apprised of the business risks inherent in small
water system development and are aware of the information available in the business
plans submitted to DER. *
Modification of the permit application process will ensure that all parties
involved in the development of new water systems are made fully aware of the full
costs of providing a proper water supply. This correction in the "price signal" can be
made to function as a "credible deterrent" that will redirect many potential applicants
to other-eventually less expensive-means of providing water service. -,
Assuming the modifications in the DER permit process are successful in
encouraging some comparison shopping by potential new system developers, what
measures could be proposed to remove existing barriers toor, enhance the incentives
for-alternative solutions such as extensions of service, interconnections, absorp-
L w- titsrC/Sateilite'management by nearby -larger -systemsr and innovative^bnns of commer-
cial involvement by the private sector? This may include a wide range of proposed
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statutory, regulatory and institutional changes that bear on the problem of providing
water service. There are a number of barriers inherent in the present legal/regulato-
ry/institutional framework as well as a number of places where incentives to larger
scale provision of water service can be enhanced.
Review of Existing System Mobility
Apply viability screening to existing small systems, perhaps through DER or
PUC regulatory/enforcement proceedings or through PENNVEST loan
application procedures. This may include a requirement for the same plan
components:
- Facility Plan-detail replacement, rehab, and upgrade needs;
- O&M Plan-following format already developed in the DER water supply
manual; and
- Management and Financial Plan-same components as for new systems;
balance sheet to show adequate capitalization, income statement to
document revenue sufficiency; full disclosure of ownership.
Initiate regional/local planning involvement in the review of viability plans of
existing small systems. Attempt to attract "a few good counties/townships" tp
lead the way. Encourage this involvement by investigating the use of
PENNVEST funds-or other sources of funding-for local planning efforts.
Charge the local/regional planners with addressing the natural geographic
relationships between small systems within an area-possibilities for
regionalization, franchising, interconnection, satellite management, big
brother arrangements, mergers/acquisitions. How can the viability status of
individual systems within the same region be enhanced through mutual
arrangements?
Build on recent consensus process undertaken in development of the
PENNVEST Comprehensive Water Facilities Plan to build momentum for
legislation to mandate statewide regional/local planning initiatives. Obtain
"ratification" and extension of initiatives already started. Obtain a suitable
appropriation to implement this initiative.
Assistance to Small PWSs
DER will continue reviewing and offering assistance during the technical
review of plans and specifications.
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The cost estimates and management checklist derived from the cost model
will assist newly forming systems to understand the good business require-
ments.
DER will work with PENNVEST staff to consider the possibility of using
PENNVEST funds for water supply planning at a regional level in efforts to
consolidate nonviable systems rather man simply prop-up nonviable systems
with grants or low interest loans.
Certification and licensing
DER will strive to improve and enhance the operator certification training
and examination process for small system operators.
Training programs will be directed to small system needs.
PLANNED ACTIVITIES
10/90 Establish a Viability Advisory Committee to guide the current studies
of new and existing systems and to assure practical steps are developed
7/91 Complete the Viability Study of both new and existing systems
4/91 Develop a MOU with the PUC to utilize the viability process
4/91 Obtain DER/PUC executive staff approval of viability concepts and
process
6/91 Train DER/PUC staff in implementation of viability screening method
and cost model
6-9/91 Prepare a request for additional staff and budget to carry out the
program
6-9/91 Execute a contract for financial service agency to perform viability
reviews
7/91 Develop a formal plan and agreements with funding agencies
7/91 Develop a communications strategy for the entire viability effort,
including targeting of groups to achieve education about viability issues, and
developing implementation methods
7/92 Recruit, hire, and orient new staff to begin full viability screening
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1992-96 Phase in all existing small water systems
1991- Maintain viability by reviewing annual financial reports for consisten-
cy with viability plans.
Utah
Utah's primary objective is to create incentives for regionalization and coopera-
tive agreements. To achieve this objective, the State would like to develop financial
and managerial requirements for proposed systems and promote area-wide planning.
Other initiatives being considered are: providing technical assistance to systems before
construction; establishing more stringent operator certification requirements; and
developing a more extensive licensing program. Excerpts from Utah's action plan are
provided below. The lead contact for the State is:
Mr. Ken Bousfield
Bureau of Drinking Water
Utah Department of Health
P.O. Box 16690
Salt Lake City, Utah 84116-0690
(801) 538-6159
Viability Measures
Water Supply Planning, Permitting, and Review
Permitting process to ensure that minimum design, construction, and
operating requirements are met before construction:
- review of engineering plans and specifications to ensure they meet
regulations and common industry standards;
- submittal of certified as-build plans (by inspector or certified system
operator);
- inspection by a State-certified local jurisdictional inspector to ensure
compliance with engineering plans and specifications;
- submittal of proposed managerial organization and operations of the
small drinking water system to include the services of a State certified
drinking water operator of the proper discipline and grade level as
required by the Utah Operator Certification Regulations;
- review projected fixed operational costs and ensure adequate reserves
for unforseen operational and maintenance expenses, and any capital
expenditures;
- adequacy of pre-purchase disclosure;
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- demonstration of why regionalization or formation of a cooperative is not
viable, if they are not used; and
- conformity with the area-wide plan as provided by AOG/COG.
Financial review to determine affordability and financial requirements.
- analysis to ensure that the small drinking water system is economically
feasible for construction, operations, and maintenance with viability . ...
ensured by the posting of an adequate performance bond until the
system is economically self-sustaining.
Assistance to Small PWSs
Technical assistance, before construction, to resolve any design and con-
struction problems (many agencies available for consultation).
Financial assistance is available for non-profit small drinking water systems
through existing State agencies.
Certification and Licensing
Operator certification will be required for all small drinking water systems
under proposed legislative changes.
Licensing of pump installers, well drillers, and plumbers currently required
by other State agencies.
Planned Activities
Legislation Development
1991 Session: Propose legislation for extension of operator certification to
all public drinking water systems
1992 Session: Propose legislation for levying administrative penalties by the
Bureau of Drinking Water
Regulation Development
1/92 Revise existing regulations for extension of operator certification to all
public drinking water systems
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Other Milestones
. Develop guidelines for an AOG/COG area-wide planning process
Develop a program with the PSC to allow economic incentives for continuing
operation of non-compliant small drinking water systems by other entities,
expanding receivership which currently exists through the Safe Drinking
Water Committee.
Vermont
Vermont's objective is to ensure the viability of new and existing PWSs, with .
particular emphasis on privately owned systems. Some of the initiatives the State is
considering are: requiring systems to develop 10-year financial plans; requiring
proposed systems to explore alternatives such as interconnection; proposing legislation
that would create incentives for consolidation of small systems and satellite manage-
ment; and improving technical assistance to small system operators. These initiatives
and others are described below. More information on Vermont's action plan may be
obtained from:
Mr. Winslow Ladue, Drinking Water Program Chief
Environmental Health Division
Vermont Department of Health
60 Main Street, P. O. Box 70
Burlington, Vermont 05402
(802) 863-7234
Viability Measures
Water Supply Planning, Permitting, and Review
Evaluate viability as part of reviews of new investor-owned water systems.
Determine whether alternatives such as system interconnections or denial of
a Certificate of Public Good by the Public Service Board would better serve
the public interest. (Estimated caseload 1 to 2 per month.)
Require new and existing non-investor-owned water systems to develop 10-
year financial plans, with updates every five years. These plans should
include all costs affecting viability and should establish reasonable sinking
funds for equipment replacement.
---->-**"-For the creation of a new sub-town municipal water-district, propose
legislation that would establish a concurrent approval requirement by local
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Boards of Selectmen and the State Water Supply Program, with advice from
the Department of Public Service. Approval would be withheld if the new
system has not adequately considered interconnection or if the rates will not
ensure viability.
Review viability of existing small systems over next 3 years. Schedule
reviews in order of decreasing public health risk factors. Use existing
sanitary surveys to perform analysis.
Propose legislation to create incentives for the consolidation of small sys-
tems, as well as satellite operation and management
- add financial incentives through rate-making for the takeover of small
systems by nearby investor-owned utilities and
- authorize State Treasurer to grant lower interest loans to municipal
utilities which accept "dogs."
Strengthen the role of regional planning in water system planning. This will
involve training and better communicating system locations and limitations.
It also may involve increasing PRC responsibility for coordinating municipal
water system service areas.
- propose a bill that explicitly states that regional plans will include a
public water system inventory and plan.
Add a water system viability evaluation in the current state land use permit-
ting process (Act 250) for subdivisions and new development.
Revise the process for PSB approval (Certificate of Public Good) of new
small investor-owned systems:
shorten the review period and reduce case preparation costs and
- use application forms jointly prepared by PSB and Water Supply Pro-
gram.
Clarify PSB jurisdiction over cooperatives and mobile home parks.
Develop joint database regarding public and investor-owned water systems
that is interactively accessible to Water Supply Program, Dept of Health
Epidemiology Division and PSB and Department of Public Service.
Assistance to Small PWSs
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Improve technical assistance to small system operators. Use as a model the
current program for technical assistance to municipal sewage systems.
Improve small system access to private capital sources. Develop explanatory
handbook on how to acquire loan capital from banks and how to obtain rate
increases to meet bank prudential concerns. Clarify FSB policy on rate
increase timing. Answer these questions:
- will FSB allow rate increase (based on loaned amount) before asset
becomes "used and useful?" and
- can rates be conditioned upon installation of improvements?
Other Measures
Improve enforcement activities:
expand existing authority to use administrative penalties for drinking
water violations and
- use receivership and revocation of Certificates of Public Good as means
of promoting change in investor-owned non-viable systems.
Increase revenues for water supply program. Propose legislation to:
- raise fees for water quality analysis, permits, operator certification, and
laboratory certification and
- increase the water company gross receipts tax on investor-owned sys-
tems. (Revenues to go to technical support of small systems.)
Planned Activities
Legislation Development
10/90 Meet with small system operators and other stakeholders; Develop
advisory group and refine overall strategy
11/90 Develop MOUs to implement interim strategy of interagency coopera-
tion; Develop legislation (simple and non-controversial); Circulate first draft
within government of redraft of PSB rule on drinking water systems
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Regulation Development
3/91 Adopt new drinking water rules
6/91 Adopt new PSB rules
ซ
V. Pennsylvania's Program
Introduction
The Pennsylvania Department of Environmental Resources (DER), Division of
Water Supplies (DWS), is responsible for regulating the State's public drinking water
systems. DER regulates approximately 10,700 PWSs: 2,400 are community systems
and 8,300 are non-community systems. Approximately 87 percent of all Pennsylvania's
PWSs are small systems, which are responsible for more than 90 percent of the State's
drinking water violations. The Pennsylvania Public Utility Commission (PUC) regulates
privately owned systems and municipal water systems that operate outside their
municipal boundaries. There are approximately 365 such systems, representing 15
percent of the State's CWSs. Over half have annual operating revenues of less than
$100,000. The table below presents Pennsylvania's water system inventory.
Pennsylvania's
Water System Inventory
Number of Individuals Public Water Percent of Community Percent of
Served by a System Systems all PWSs Water Systems all CWSs
0 < 500 9,338 87.1 1,551 63.9
501-3,300 1,023 9.5 551 22.7
3301 - 10,000 204 1.9 175 7.2
> 10,000 155 1.5 151 6.2
DER's Viability Controls
DER has developed many viability initiatives. Some are directed toward new
systems, while others affect existing systems. The initiatives discussed in this section
' include: "the permit process; the Small -Water Systems Committee; .the Technical
Assistance Program for Small Systems; the Pennsylvania Infrastructure Investment
38
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Authority Act; and the Mobile Home Park Cooperative. All of these initiatives were
implemented within the last two years, so information about them is limited.
Permit Process:' DER attempts to ensure the viability of new small systems
through its permit process. DER requires a system to submit engineering designs and
specification plans to qualify for a design and construction permit. In addition, it
requires the system owner or operator to obtain an operating permit. Tide 35,
Chapter 5, section 721.7 of the Pennsylvania Statutes grants DER the authority to .
"include in each permit general and specific conditions to ensure the proper operation
of the public water system and the furnishing of an adequate, safe, and potable supply
of water." DER is considering the inclusion of financial and managerial requirements
in the permit process.
Pennsylvania Small Water System Committee (SWSC): Formed in 1988, the
SWSC is a forum for exchanging information about small water systems. The Commit-
tee has members from agencies and organizations such as: the Department of
Community Affairs; the PA Water Works Operators Association; the Joint Air and Water
Pollution Control and Conservation Committee; the Senate Environmental Resources
and Energy Committee; the PA Rural Water Association, and the PA League of Women
Voters. Members meet quarterly to discuss small water system issues and to help
coordinate resources and prevent an overlap of efforts. They also assist in building
support for State drinking water legislation. For example, the Committee supported
the passage of Act 24, which encourages small system takeovers by large water
systems.
Technical Assistance Program for Small Systems (TAPSS): TAPSS was
designed to improve the technical, operational, and managerial capabilities of small
water systems through on-site technical assistance and training. The program was
established in 1989 and was financed with State and Federal funds. The program's
primary goal was to help small water systems comply with new and existing drinking
water regulations, focusing on filtration, disinfection, and corrosion control. TAPPS
has aided approximately 360 small water systems.
DER hired contractors to conduct the on-site technical assistance and training
programs for small systems. The contractors trained 113 small water system owners
and operators in corrosion control principles, 50 systems in operations and mainte-
nance of filtration plants, and 194 systems in disinfection practices. The corrosion ...
control contractors made videotapes of the corrosion control seminars, which were
edited to three half-hour topic areas: "Corrosion Principles," "Chemicals and Chemical
Feed," and "Operational Considerations." In addition, contractors conducted training
seminars for all DER field staff.
'- -The Pennsylvania Infrastructure Investment Authority Act (PENNVEST):
PENNVEST is an initiative that has provided small water and sewage system owners
39
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with financial assistance. In 1989, $560 million was available through the program and
approximately 60 percent was directed towards small system capital improvements.
The program is designed to provide $2.5 billion in assistance to water and sewage
systems over the next 25 years.
Any owner or operator of a drinking water system is eligible to participate in
the program. It may be a public or private entity, including any person, corporation,
partnership, association, cooperative, municipal authority, or governmental unit.
PENNVEST grants financial assistance for construction, improvement, expansion,
extension, acquisition, repair, or rehabilitation of any drinking water system.
PENNVEST is able to finance up to 100 percent of eligible project costs, subject
to some limits. There is an overall cap of $11 million per project. This cap is
increased to $20 million if more than one municipality is served and may be exceeded
with Authority approval if more than four communities are served.
PENNVEST assistance primarily consists of low interest loans with some
supplemental grants for economically distressed communities. Interest rates vary, but
once a loan is approved, interest is fixed for the term of the loan. Most of the loans
have a term of 20 years and carry interest rates ranging from one to six percent.
There are no application or service fees and there are no pre-payment penalties.9
One of the largest projects PENNVEST approved was a $5.2 million water
system improvement for the Columbia Water Company in Lancaster County. The
Columbia system has suffered with giardia contamination, rusty water, and inadequate
pressure for fire fighting. The PENNVEST loan will be used to renovate the water
treatment plant and distribution system, to build a new pump station, and to install a
2-million-gallon water tank.10
The Mobile Home Park Cooperative: This initiative began in 1989 to address
compliance problems with the State's estimated 800 mobile home parks. The goal of
the program is to provide operations expertise to mobile home park owners in order
to improve their compliance with drinking water regulations. Eleven mobile home
parks in Berks County were selected to receive assistance through the program. A
"circuit rider" from an engineering contractor trained system owners and operators,
assisted in developing operations and emergency plans, and helped operators become
State certified. The pilot program also developed a guidebook for coalition building ..
Information on PENNVEST was taken from "A Water Utility's Guide to Financial and
Technical Assistance Programs," Pennsylvania Infrastructure Investment Authority,
ปGommonwealth~of .Pennsylvania, .January 1990. , .............
"Commonwealth of Pennsylvania, PENNVEST, News Release, September 26, 1990.
40
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which provides the program's history and a guide explaining how to organize such
efforts. Preliminary results indicate that mobile home park owners are not as finan-
cially constrained as was initially thought.
PUC's Viability Controls
The major PUC viability initiatives are Act 24 and proposed House Bill 25. Both
initiatives, described below, encourage the acquisition of non-viable small systems by
larger, viable systems.
Act 24: Signed into law in April 1990, this initiative provides an incentive for
large water utilities to acquire failing small systems. When a public utility acquires a
small system at a cost which exceeds the depreciated original cost, that excess, or any
portion deemed reasonable by the commission, may be included in the acquiring
utility's rate base.11 To spread acquisition costs over its rate base, a utility must prove
several points, including: that the system purchased is useful in providing water
service; that the system purchased had 1,200 or fewer customer connections; that at
the time of purchase, the system was not furnishing and maintaining adequate,
efficient, safe, and reasonable service; that the purchase price is reasonable; and that
the rates charged to pre-acquisition customers will not increase unreasonably.
House Bill 25: This bill, which is currently before the legislature, would give
the PUC authority to require the acquisition of non-viable, small systems by large
systems. The bill allows the PUC to order a capable public utility to acquire a small
water utility if it determines that: the small system has violated statutory or regulatory
standards which affect the safety, adequacy, efficiency, or reasonableness of the service
provided; the system has failed to comply, within a reasonable period of time, with any
PUC or DER order; that the system cannot furnish and maintain adequate, efficient,
safe, and reasonable service in the future; that alternatives to acquisition have been
considered and rejected; and that the rates charged by the acquiring utility to its pre-
acquisition customers will not increase unreasonably.
"The acquired small system may be owned by a public utility, a municipal
corporation, or an individual.
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APPENDIX A
STATE ACTION PLAN
ENSURING THE VIABILITY OF NEW
SMALL DRINKING WATER SYSTEMS BEFORE CREATION
I. STATE PROFILE
- Background
- Definitions
- Small System Characteristics
- Current Small System Program
- Future Viability Issues
II. MISSION STATEMENT AND OBJECTIVES
Viability Program Mission:
- Concise statement identifying the purpose and mission of the State's viability program.
Viability Program Objectives:
- Translate the general mission statement into specific measurable results -- identifying
what is to be accomplished through the program's activities.
III. DESCRIPTION OF STATE'S PROPOSED VIABILITY PROGRAM
- Each State will develop individual action plans tailored to address its specific and
unique small systems needs. This section should be used to describe in detail
necessary program authority, program administration and viability activities the State
envisions will comprise its viability program (i.e. the big picture). This should be a
comprehensive description including any current viability activities the State is
implementing. The basic elements that should be considered in formulating a viability
program are listed below.
Authority:
- Statutory and regulatory (current and under development)
- Identification of organizations involved and responsibility and authority of each
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Program Administration:
- Appropriated funds or other resources to carry out the program
- Program planning, management and evaluation
- Staff hiring and training
- Partnerships with third parties for resource sharing and cooperation to achieve the
program's mission
Viability Program Activities:
Water Supply Planning. Permitting and Review
- Permitting process to ensure that minimum design, construction and operating
requirements are met before construction.
- Financial review to determine affordability and financial requirements, such as system
escrow accounts.
- New system interconnection with existing viable systems.
- Satellite management/ownership.
- Are-wide planning to specify each system's present and future exclusive service area,
system improvements and expansion plans; may include satellite management plans.
Assistance to small PWSs
- Technical assistance, before construction, to resolve any design and construction
problems.
- Business management assistance to newly forming systems.
- Financial assistance such as State funding for water supply planning.
Certification and Licensing
- Certified operator requirements for new systems.
- Licensing of pump installers, well drillers, and plumbers.
Other Measures
IV. VIABILITY PROGRAM IMPLEMENTATION
- From the detailed description in Section III identify specific tasks (those things that
must be done in order to put a viability measure in place and reach implementation)
and establish milestones (dates targeting expected accomplishment of the task or
portions of the task).
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APPENDIX B
Small System Viability Workshop
Participant List
ARIZONA:
Mr. Robert L Munari, Manager
Field Services Section, Office of Water Quality
Department of Environmental Quality
2655 E. Magnolia Street
Phoenix, AZ 85034
(602) 392-4002
Fax: (602) 392-4017
Mr. Jon Dahl, Manager,
Drinking Water Compliance Unit
Department of Environmental Quality
2005 North Central Avenue
Phoenix, AZ 85004
(602) 257-2201
Fax: (602) 257-6948
Mr. Paul Storms
Consumer Service Specialist
Arizona Corporation Commission
1200 West Washington
Phoenix, AZ 85007
(602) 542-4251
Mr. Steve Jenkins
Department of Water Resources
15 South 15th Avenue
Phoenix, AZ 85007
(602) 542-1546
Mr. Hugh Holub
177 North Church Street
Suite 200
Tucson, AZ 85701
(602) 792-1488
Ms. Irene Hallett Weller
Department of Environmental Quality
2005 North Central Avenue
Phoenix, AZ 85004
(602) 257-6950
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Mr. Steve Burg
Arizona Corporation Commission
1200 West Washington
Phoenix, AZ 85007
KENTUCKY:
Mr. George Schureck
Division of Water
Department of Environmental Protection
18 Reilly Road, Fort Boone Plaza
Frankfort, KY 40601
(502) 564-3410 Ext. 549
Mr. Ralph Schiefferle
Department of Environmental Protection
18 Reilly Road, Fort Boone Plaza
Frankfort, KY 40601
Mr. Claude Rhorer, Director
Engineering and Services
Kentucky Public Service Commission
730 Schenkle Lane
P.O. Box 615
Frankfort, KY 40602
(502) 564-7488
Representative Clarence Noland
P.O. Box 364
Irvine, KY 40336
MASSACHUSETTS:
Ms. Yvette dePeiza, Program Manager
Division of Water Supply
Department of Envionmental Protection
One Winter Street, 9th Floor
Boston, MA 02108
(617) 292-5857
Fax: (617) 556-1049
Mr. Robert Brown
Office of General Counsel
Department of Environmental Protection
One Winter Street, 3rd Floor
Boston, MA 02108
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Mr. Paul E. Osbome
Utility Accountant
Massachusetts Department of Public Utility Control
100 Cambridge Street
Boston, MA 02202
(617) 727-3545
Ms. Heidi Feusi, Training Coordinator
Division of Water Supply
Department of Environmental Protection
One Winter Street, 9th Floor
Boston, MA 02108
(617) 292-5857
Fax: (617) 556-1049
MISSOURI:
Mr. Jerry L. Lane, Director
Public Drinking Water Program
Department of Water Resources
Division of Environmental Quality
205 Jefferson Street
P.O. Box 176
Jefferson City, MO 65102
Mr. Breck Summerford, Chief, Engineering and Compliance
Department of Water Resources
Division of Environmental Quality
205 Jefferson Street
P.O. Box 176
Jefferson City, MO 65102
(314) 751-1127
Mr. Bill Sankpill
Missouri Public Service Commission
Treeman Building
P.O. Box 360
Jefferson City, MO 65102
(314) 751-7074
Fax: (314) 751-1847
Mr. Joe Bindbeutel, Assistant A.G.
Office of the Attorney General
P.O. Box 360
Jefferson City, MO 65102
-(314) 7-51-8805
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MONTANA:
Mr. Dan L. Fraser, Chief
Water Quality Bureau
Department of Health and
Environmental Sciences
Cogswell Building, Room A206
Helena, MT 59620
(406) 444-2406
Mr. Bob Thompson, Atty.
Water Quality Bureau
Department of Health and
Environmental Sciences
Cogswell Building, Room A206
Helena, MT 59620
(406) 444-2406
Mr. Ron Woods, Rate Analyst
Montana Public Service Commission
2701 Prospect Avenue
Helena, MT 59620
(404) 444-6188
Ms. Denise Peterson
Montana Public Service Commission
2701 Prospect Avenue
Helena, MT 59620
NEW HAMPSHIRE:
Mr. Bernard B. Lucey, P.E.
Administrator of Water .Supply
Engineering Bureau
Department of Environmental Services
P.O. Box 95, Hazen Drive
Concord, NH 03302-0095
(603) 271-3139
Mr. Edward Schmidt, Director
Water Supply Pollution Control Division
Department of Environmental Services
P.O. Box 95, Hazen Drive
Concord, NH 03302-0095
(603) 271-3139
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Mr. Eugene Sullivan, Esq.
New Hampshire Public Utility Commission
8 Old Suncook Road, Bldg. No. 1
Concord, NH 03301-5185
(603) 271-6011
NEVADA:
Mr. Jeffrey Fontaine, Supervisor
Public Health Engineering
Nevada Division of Health
Bureau of Regulatory Health Services
505 East King Street, Rm 103
Carson City, NV 89710
(702) 885-4750
Mr. Bob Hadfield
Executive Director of Nevada
Association of Counties.,
308 North Cuny Street
Carson City, NV 89703
(702) 883-7863
Mr. Ron Lange, Deputy Administrator
Nevada Division of Health
Bureau of Regulatory Health Services
505 East King Street, Room 103
Carson City, NV 89710
(702) 687-4740
PENNSYLVANIA:
Mr. Steve Schmidt, Chief, .Program Development
and Evaluation, Division of Water Supplies
Pennsylvania Department of Environmental Resources
P.O. Box 2357
Harrisburg, PA 17105
(717) 787-0122
Fax: (717) 772-3249
Mr. Walter L. Harner, Sanitary Engineer
Division of Water Supplies
Pennsylvania Department of Environmental Resources
P.O. Box 2357
Harrisburg, PA 17105
(717) 787-0122
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Ms. Judy Carlson, Rate Analyst
Pennsylvania Public Utilty Commission
Room 200, North Office Building
P.O. Box 3265
Harrisburg, PA 17120
(717) 783-5392
VERMONT:
Winslow Ladue, Drinking Water Program Chief
Environmental Health Division
Vermont Department of Health
60 Main Street, P.O. Box 70
Burlington, VT 05402
(802) 863-7234
Mr. Peter Bluhm
Vermont Public Service Board
89 Main Street
Montpelier, VT 05602
(802) 828-2358
Ms. Suzanne Rude, Board Member
Public Service Board
89 Main Street
Montpelier, VT 05602
(802) 828-2358
Mr. William Brierly, Director
Public Facilities Division
Department of Environmental Conservation
103 South Main Street
Waterbury, VT 05676
(802) 244-8755
Ms. Susan Martin, Utilities Rate Analyst
VT Dept. of Public Service
120 State Street
Montpelier, VT 05602
UTAH:
Mr.Gayle Smith, P.E. Director
Bureau of Drinking Water/Sanitation
Utah Department of Health
P.O.-Box 16690
Salt Lake City, Utah 84116-0690
(801) 538-6159
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Mr. Travis Black, Environmental Health Scientist
Compliance Section, Bureau of Drinking Water/Sanitation
Utah Department of Health
P.O. Box 16690
Salt Lake City, UT 84116-0690
(801) 538-6159
Mr. Darrell S. Hanson, Manager,
Gas and Water Division of Public Utilities
Utah Department of Commerce
160 E. 300 South, P.O. Box 45802
Salt Lake City, UT 84145-0802
(801) 530-6655
Mr. Grant Bagley
Assistant Attorney General
Utah Attorney General's Office
Physical Resources Division
State Capitol Building
Salt Lake City, UT 84114
(801) 538-1017
Fax: (801) 538-3442
Mayor Carole Scott
P.O. Box 188
Manila, UT 84046
(801) 784-3143
Mr. Ken Orton, Circuit Rider
Utah Rural Water Association
P.O. Box 661
Spanish Fork, UT 84662
(801) 798-3518
STATE SPEAKERS
CONNECTICUT:
Mr. Richard Albani
Connecticut Department of Public Utility Control
1 Central Park Plaza
New Britain, CT 06051
(203) 827-1553 or
(203) 827-2600
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Mr. Raymond Jarema, P.E., Chief Engineer
Water Supplies Section
Connecticut Department of Health Services
150 Washington Street
Hartford, CT 06106
(203) 566-1251
MARYLAND:
Mr. William F. Parrish, Jr.
Program Administrator
Water Supply Program
Maryland Department of the Environment
Point Breeze Building 40, Room 8-L
2500 Broening Highway
Dundalk, MD 21224
(301) 631-3702
WASHINGTON:
Mr. Richard Siffert, Planning Program Supervisor
Drinking Water Program
Department of Social and Health Services
Mail Stop LD-11, Building 3
Airdustrial Park
Olympia, WA 98504
(206) 753-4299
Mr. D. William Liechty, Acting Director
Drinking Water Program
Department of Social and Health Services
Mail Stop LD-11, Building 3
Airdustrial Park
Olympia, WA 98504
(206) 753-5953
Mr. Bob Wubbena, President
Economic and Engineering Services
P.O. Box 976
626 Columbia Street, NW
Suite 2A
Olympia, WA 98507
(206) 352-5090
Honorable Louise Miller
-414 Legislative Building
AS-33
Olympia, WA 98504
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Honorable Ken Madsen
P.O. Box 370
Roy, WA 98580
Mr. David Monthie
Energy and Utilities Joint Select
Committee on Water Resources Policy
Room 404, QW-11
Olympia,WA 98504
OTHER SPEAKERS
Mr. Larry Morandi
Program Director, Natural Resources
National Conference of State Legislatures
1050 17th Street, Suite 2100
Denver, CO 80265
(303) 830-2200
Mr. Steve Brown
Council of State Governments
Iron Works Pike
P.O. Box 11910
Lexington, KY 40578-9989
(606) 231-1939
REGION I (617) 565-3610
Boston, MA
Kevin Reilly
Chris Ryan
Mark Sceery
REGION IV (404) 347-4727
Atlanta, GA
Wayne Aronson
REGION Vin (303) 293-1603
Denver, CO
Doris Sanders
David Schmidt
REGION IX (415) 744-1817
-San Francisco, CA
Marvin Young
CorineLi
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EPA HEADQUARTERS (202) 382-5543
Office of Drinking Water
Washington, D.C.
Michael B. Cook, Director, ODW
Jane T. Ephremides, PDED, ODW
Larry Graham, SPD, ODW
Penny Barles, PDED, ODW
Robert Blanco, SPD, ODW
THE CADMUS GROUP, INC. (617) 894-9830
Mr. Ralph Jones
135 Beaver Street
Waltham, MA 02154
Mr. Ken Mayo
135 Beaver Street
Waltham, MA 02154
Ms. Dayna Scott
135 Beaver street
Waltham, MA 02154
ASDWA
Ms. Vanessa Lieby
Wade Miller Associates
1911 North Fort Myer Drive
Suite 400
Arlington, VA 22209
(703) 524-1888
Mr. John Cromwell
Wade Miller Associates
1911 North Fort Myer Drive
Suite 400
Arlington, VA 22209
(703) 524-1888
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APPENDIX C '
VIABILITY WORKSHOP
AGENDA
Saturday. September 22. 1990
8:00 am Registration
8:30 am ASDWA Welcome
- Dan Fraser, National Vice President
Association of State Drinking Water Administrators
8:45 am Introduction Exercise
9:00 am EPA Opening Remarks
- Michael B. Cook, Director, Office of Drinking Water
Environmental Protection Agency
9:30 am Washington State Viability Program
- Mr. Richard Siffert, Planning Program Supervisor
Drinking Water Program, Dept. of Social & Health Services
- Mr. William Liechty, Acting Director
Drinking Water Program, Dept. of Social & Health Services
- Mr. Bob Wubbena, President
Economic and Engineering Services
10:45 am Break
11:00 am Connecticut State Viability Program
- Mr. Raymond Jarema, P.E., Chief Engineer
Water Supplies Section, Conn. Dept. of Health Services
- Mr. Richard Albani
Connecticut Department of Public Utility Control
12:30 pm Lunch
1:30 pm Maryland State Viability Program
- Mr. William Parrish, Jr., Program Administrator
Water Supply Program, Maryland Dept. of the Environment
2:30 pm Break
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2:45 pm Pennsylvania State Viability Program
- Mr. Steve Schmidt, Chief
Program Development & Evaluation, Division of Water Supply
PA Department of Environmental Resources
- Mr. Walt Harner, Sanitary Engineer
Division of Water Supplies, PA Dept of Environmental Resources
- Ms. Judy Carlson, Rate Analyst
Pennsylvania Public Utility Commission
- Mr. John Cromwell, Project Coordinator
Wade Miller Associates, Inc.
3:45 pm The Legislative Process
- Mr. Larry Morandi, Program Director
Natural Resources, National Conference of State Legislatures
- Mr. Steve Brown
Council of State Governments
5:00 pm Feedback
5:15 pm END
7:30 pm Evening Sessions
- Informal meeting with workshop speakers
9:30 pm END
Sunday. September 23. 1990
8:30 am General Session to Review Workshop Process Schedule
- Discussion on how groups will be working, approach to
completing the action plan, and review the elements of the action
plan
9:00 am State Workgroup Session
- State Action Plan is developed. Before lunch, PC disk is turned
in for hard copy production
12:30 pm Lunch
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2:00 pm General Session to Describe Peer Review Process
- Each State to review and provide written comments on 5 States'
Action Plans
2:15 pm State Workgroup Session
4:15 pm Break
- Review completed and hand written comments turned in for
photocopying
5:15 pm General Session to Handout Peer Reviews
- Brief discussion of Monday's activities
6:15 pm END
Monday. September 24. 1990
9:00 am State Workgroup Session to Review Comments and Incorporate
Changes
10:15 am General Session
- Chairman of each Workgroup Reports on State Viability Action
Plan
1:00 pm Lunch
2:00 pm Improving the Viability of Existing Small Drinking Water Systems
- Ralph Jones, The Cadmus Group, Inc.
2:30 pm Administrative Penalty Authority
- Penny Baries, Office of Drinking Water, EPA
3:00 pm Closure and Evaluation
- Final Action Plans Distributed
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