United States
    Environmental Protnrfio-i
 This document  introduces water efficiency for public  water systems, identifies measures to improve
 water efficiency, and provides recommendations on how water systems can get started and continue
 making water efficiency  improvements. This document is  intended for small and medium-sized water
 systems as well as technical assistance providers and state programs that support or  regulate these
Water efficiency is becoming  increasingly important to public water systems in the  United
States from a resource management and economic perspective. Increasing water efficiency can
help a water system simultaneously deal with critical  issues such as:

     Decreasing availability and quality of source waters,
     Increasing costs of treating and providing water,
     Aging infrastructure in service beyond its useful life,
     Growing demands for an improved  level of service placed on the system by customers,
     Reducing or delaying the need for expensive capital projects, and
     Important  environmental sustainability benefits,  including reduced energy use and
      reduced pressure on water resources.
 What Is Water Efficiency?
Water efficiency is the long term ethic of saving water resources through the use of water-
saving technologies and  practices. A related concept  is water conservation, which  is more
narrowly focused on reducing  water loss,  waste or use.  EPA's efforts have evolved from
emphasizing only water conservation to the more holistic framework of water efficiency. As the
volume of water lost (or wasted) is reduced, water efficiency improves. Likewise, as the volume
of water needed to satisfy customer demands is reduced, water efficiency improves.

During periods of drought and extreme summer heat, communities and water systems are very
aware of the need to conserve  their water supplies. However,  an  increasing  number of
communities and  water  systems are recognizing the value of improving water efficiency in
addition to using the short-term tools of conservation and water use restrictions during periods
of emergency. Water that  is lost unnecessarily or used inefficiently impedes the long-term
sustainability of water systems even in parts of the country without chronic water shortages.
Many water systems dealing with source water scarcity already recognize that their options are
increasingly limited and that improving water efficiency has become a necessity.

 How Can a Water System Improve Water Efficiency?
There is no one-size-fits-all approach to improving water efficiency - every water system  is
different and  will need a plan that fits its conditions and needs. The building blocks for most
water systems to get started include metering, water audits and implementation of a water loss
control program. An annual water audit can be integrated into routine business practice. Some
smaller water systems may not need a formal water audit to identify where water losses are
occurring and to prioritize projects. Strategies to improve water efficiency should also examine
how water is used and lost  on both the supply-side and  the  demand-side. This  includes
operational uses of water by the system, such as water used during treatment (filter backwash)
and water needed  to flush distribution lines, as well  as end-use by customers for everything
from brushing teeth to industrial manufacturing.

The  following  section presents several  commonly-used water efficiency  measures.  The
measures are presented in the two broad  categories of water  efficiency:  supply-side  and

Supply-Side Measures

On the supply-side, systems can often find significant efficiency gains before their water even
reaches the  customer. These measures benefit from their invisibility to  the customer  -
customers get identical (and perhaps better) service  while the system saves money  and has
more water to deliver to customers (or can withdraw less water to meet customer demand). On
the other hand, if a system chooses to promote its efforts, these measures can offer an added
benefit of good public relations that connects supply-side efficiency measures with demand-
side efficiency measures.

Measure 1: Water Metering

Metering is the most essential capability that a drinking water system needs to obtain in order
to have an  understanding  of how much water the system uses and loses. Metering allows a
system to measure the volume of water flowing into, through and  out of the system, as well as
the volume of water used by customers.

In a public water system, meters may be installed at the following locations:

      End of transmission  line
      End of treatment train
      Entry points to the distribution system
      Entry points to pressure zones or district metered areas (DMA)
      Each customer connection or consecutive system
      Other  approved connections, such as hydrants and parks

Further information on types of meter, metering points, and metering programs can be found
in Control and Mitigation of Drinking Water Losses in Distribution Systems, EPA 816-R-10-019,
November 2010, at http://water.epa.gov/type/drink/pws/smallsystems/technical help.cfm.

Meters need to be calibrated and in good repair to provide accurate data. The size and type of
meter selected is based on the flow profile for a given service connection. Age and damage to
meters can lead to deterioration and  incorrect readings, making it difficult to detect leakage.
Using the  wrong size or type of meter in an application can also result in a portion of the flow
delivered  to a service connection not being registered by the meter. Regular inspection and
calibration of meters, and replacing them as necessary, is an important part of managing water
loss. Meter inspection and maintenance frequency may depend on system specific conditions
such as water quality and the results of previous tests.

Technological advances have yielded much more powerful tools for water systems to monitor
water use and loss than the traditional manual-read meters. Automated meter reading (AMR)
allows  water systems to measure water use per connection  remotely and in real  time, which
not only  allows for more accurate and frequent billing (itself  a measure to improve water
efficiency) but also is an  important tool for detecting changes that might  indicate significant
water loss. This technology offers the added benefit of optimizing the volume of water billings
issued by the water system.

Measure 2: Water Audits

Systems can use metering and other monitoring data to establish a baseline understanding of
how much water the system uses and loses. This is typically accomplished with a water audit.
The water audit is an assessment of the  distribution, metering, and accounting operations of
the water utility and uses accounting principles to determine how much water is being lost and
where. Many federal and state agencies offer information to help systems plan  for a water
audit and, in  some cases, to pay for a comprehensive  water audit. For more information on
conducting a water  audit,  see EPA's Control and Mitigation  of Drinking Water Losses in
Distribution    Systems   guidance   document.   This    document    is   available   at
http://water.epa.gov/tvpe/drink/pws/smallsystems/technical help.cfm.

Through water audits and ongoing water accounting, systems can learn how much water is
being lost or wasted in  the system  from source-to-tap and  pinpoint problem areas so that
operation improvements and maintenance  can  be   properly prioritized  and targeted to
maximize  water  efficiency.  Further,  as  they  implement  water  efficiency projects  and
operational changes, systems can use their baseline water audit to evaluate the effectiveness of
the changes and to measure the increases in water efficiency.

Measure 3: Water Loss Control

Every public water system relies  either directly  or indirectly on withdrawing water from  a
ground water source (typically a well) or a surface water source (typically a lake, reservoir or
river). Not all of this water reaches a beneficial end use. Some of this water is lost along the
source-to-tap pathway. Zero loss is not considered realistic given the number of pipes, valves,
connections, tanks, treatment devices, meters and  fixtures  associated with even the  least
complicated public water system. A  key part  of any effort  to  improve water  efficiency,
therefore, is  to identify sources  of water loss  throughout  the system and  to implement
measures to reduce this waste.

Real water losses (leakage) in the  distribution system require more water to be pumped and
treated, which  requires  additional energy and chemical usage, resulting  in wasted resources
and excess pumping capacity. Apparent water losses due  to customer metering inaccuracies,
unauthorized  consumption and  billing  errors can result in lost revenue. A well implemented
water loss control program can reduce water and revenue loss and can also protect public
health by reducing the threat of sanitary defects such as backflow or infiltration that may allow
microbial or other contaminants to enter the finished water. A water loss control program
should be flexible and tailored  to the specific  needs and characteristics of a public water
system. There are three major components to an effective program:

    1. Water Audit
    2. Intervention
    3. Evaluation

EPA has  published  a guidance  document on water loss  control,  Control and Mitigation of
Drinking  Water Losses in Distribution Systems, EPA 816-R-10-019, November 2010, available at
http://water.epa.gov/type/drink/pws/smallsystems/technical help.cfm that provides detailed
information on how systems can account for their water and establish a leak detection and
repair strategy. The central focus of such a strategy is to identify "non-revenue water." Non-
revenue  water is  water that is not producing revenue and generally not producing value to
customers. Systems  without  a  comprehensive water  loss control   program  still   have
opportunities  to  reduce  lost water  by addressing  leaking  pipes and storage, replacing
inaccurate and  malfunctioning meters,  and eliminating  unauthorized use.  Many systems know
about some of the leaks  in their distribution system, which  is an easy  way to get  started.
Technological  advances in metering, such  as automated sensors and  telemetry, can  help
systems  gain  a more complete and sophisticated picture of water loss, which  might  help
systems prioritize  leak repairs.

Measure 4: Pressure Management

Managing water pressure is another  way that systems can  improve water efficiency and
manage water losses. Pressure differences may occur across a system for many reasons; the
simplest  reason is  variance in  elevation differential between  water sources and  end users.
Reducing excess pressure can:

       Reduce the  volume of leaks and decrease flow through open taps or faucets.
       Limit future losses by reducing stresses on  pipes and joints, limiting the risk of new

To identify potential areas within a system for pressure  reduction, hydraulic models and field
studies may be needed. Maintaining adequate pressure is critical to maintaining adequate fire
flow, protecting against  backflow and  intrusion, and  maintaining water quality. All  pressure
reductions should be consistent with any applicable state or local regulations. In some cases,
fire suppression systems or hot water heating systems on customer  premises may  have to be
upgraded to continue to function if water pressure is lowered, especially if these systems have
been damaged by corrosion or other wear.1

Improved  pressure control often requires the installation of new equipment. Two common
options are 1) pressure reducing values that can be  installed in either water mains or directly
into buildings, and 2) flow restrictors. Utilities  may also wish to offer individualized consultation
with large-volume users to offer additional pressure management advice.

Measure 5: Water  Use In Treatment Processes

Utilities' treatment  processes consume water. In particular, backwashing of sand filters must be
done frequently and requires large volumes. In optimizing backwash practices, utilities should
consider ways to minimize water  use while maintaining effective cleaning of the filters. This
may involve fine  tuning the  frequency  and  duration of  backwashing.  Overly frequent
backwashing may consume water unnecessarily, although not backwashing frequently enough
hinders performance. Monitoring head loss or the turbidity of the effluent from the filter may
provide more flexibility than a fixed schedule. Water use may also be reduced by altering the
backwash rate. The use of an air scour system can drop the rate from 15 gpm/ft2 to  8 gpm/ft2."
A simultaneous air/water backwash system has also been shown to  reduce water rates while
providing sufficient cleaning.1"

Demand-Side Measures

Although water systems  can implement water efficiency improvements on the supply-side of
the equation, the long-term factor driving water use is customer demand. The measures that
water systems can use  to shape customer  demand fall along a  spectrum from voluntary
approaches to mandatory conditions of water service and include:

      Water use audits
      Rebate and Incentive programs
      Water recycling and reuse (on-site reuse of process water, use of treated wastewater
       for non-potable reuse, or indirect potable reuse)
      Water pricing
      Water use regulations

Measure 6: Education

Information and education measures can indirectly result in water  savings by encouraging
customers to change  inefficient  water  use habits and  to  support the  water system's
conservation planning goals. Water bills can identify volume of usage, rates and charges to help
customers understand their water usage. Systems can also include inserts in bills with  tips for
home water consumption. School  programs can provide information on water conservation
practices to students  and  their families. Additional information  and  resources  are available
from EPA's WaterSense Program at http://www.epa.gov/watersense/.

Communicating the value of the water  the system supplies is an  important element of
educating customers. Systems can explain that the public water supply is not free because of
the testing and treatment needed  to  ensure its safety  as well as the  need to maintain
infrastructure to deliver the water to every building throughout the community (the consumer
is often unaware of the pipe  network because it is out of sight). In  terms of service, water
systems can emphasize that they provide safe water 24 hours a day and personnel are expected
to be available even during emergencies and  severe storms that often knock-out other utility
service, such  as electricity  and phone. The system's team  of highly trained professionals and
certified operators provide  the best assurance  that water is there when people need it at home,
at their business, or for fighting fires. Customers that understand the  number of samples and
tests, the miles of pipe, the impending capital needs, the number of staff and the volume of
water treated may be more receptive to water efficiency efforts  and  to future  rate increases
when necessary.

Measure 7: Water Use Audits

Some water systems  have found  success  in  offering free water audits to their  large  volume
users, both residential and commercial. The auditor can identify ways the customers can reduce
their water footprints, saving money for  the customers and improving the  system's overall
water efficiency. Systems might find customers more willing to undergo an audit prior to an
increase in water rates.

Measure 8: Rebate and Incentive Programs

Rebates and incentives can be used to encourage homeowners, businesses and institutions to
replace  less water efficient appliances and  fixtures, as well as to install  water efficient
technologies.  Utilities  can design  incentive rebate  programs  that  are  targeted to  the
nonresidential  and residential sectors, and to indoor and outdoor uses. A program to accelerate
replacements or retrofits can yield substantial water savings for the system and cost savings for
the customer. Also, demonstrations and pilot programs can be  used to introduce and promote
new water efficient technologies.

EPA's WaterSense Program  has developed  water efficiency  standards  for  many  common
appliances and fixtures including  water efficient  toilets,  shower heads  and  faucets. Water
systems can encourage customers to invest in these water-conserving devices. Federal, state
and local incentives can be combined to promote WaterSense technologies. Energy utilities
might also be willing to participate  in order to lower the peak electrical demand from the water
system during extended periods of high temperature.

Measure 9: Water Reuse and Recycling

Water reuse and  recycling can reduce production  demands on the utility. Such programs are
particularly suited for:

      Industrial settings. Water utilities can work with non-residential customers to identify
       potential areas for  reuse or recycling. Some industries  can substantially reduce water
       demand through water reuse (or multiple  use) in  manufacturing  processes.  Recycled
       wastewater can be used for some industrial  and agricultural purposes.
      Large-volume irrigation applications. Reuse and recycling can be encouraged for large
      volume irrigation.
      Selective residential applications. In some areas, recycled  water can  be used in
       residential applications. Water systems will need to  check with local plumbing codes
       and ordinances for possible conditions and restrictions.

Measure 10: Water Pricing

One of the most  fundamental tools water  systems can use to improve water efficiency  is to
ensure that  customers receive a cost signal by putting a volume price  on the  water used.
Costing and  pricing convey the true value of water and water  delivery services to customers.
Using cost-of-service accounting, user charges are  established  and metered rates are used so
that the customer's water bill corresponds to their usage. New automated, remote  metering
technology makes it easier for water systems to send out more frequent bills (such as monthly
rather than annual or  biannual bills),  which helps customers better understand their personal
water usage and potentially give then more control over future water usage. Moving to more
frequent billing can also soften the 'sticker shock'  that customers may experience when rates
are raised.

A cost analysis may be useful to understand what types of usage drive system costs. In this
analysis,  systems  consider  whether  their current  rate structures  promote  water  usage
(declining block rates) or conservation (increasing block rates) and what the effects might be of
introducing a new rate structure on revenues.  More advanced  pricing  methods  generally
allocate costs  by customer  class (e.g. industrial or residential)  and/or type of water use.
Advanced pricing might also  consider seasonal variations or other methods for pricing indoor
and outdoor usage  based on differing contributions to system peaks.

Measure 11: Water-use Regulations

Some water systems use water-use regulations for managing water demand during droughts or
other water-supply emergencies. They may also  be  used for promoting conservation during
non-emergency situations. A few examples of water-use regulations are:

      Restrictions on non-essential uses,  such as lawn watering, car washing and washing
       sidewalks and driveways
      Restrictions on commercial car washes, nurseries, hotels and restaurants.
      Restrictions on once-through cooling
      Restrictions on non-recirculating car washes, laundries and decorative fountains
      Standards for water-using fixtures and appliances
      Standards on new developments' landscaping, drainage and irrigation practices
 State Role
States can play a significant supporting role in helping water systems understand the need for
water efficiency, design a program that will work for their situation and reach out to customers
to promote the program. Most state tools are voluntary, although some states have enacted
regulations that require  water  efficiency activities and  more than half of the  states  have
established water loss standards that range from 7.5 percent to 20 percent. Examples of state
tools include requirements for water systems to  have a water conservation or water efficiency
plan and programs to recognize and  reward water systems that voluntarily implement a water
efficiency program as part of good management.

States can use Drinking Water State Revolving Fund (DWSRF) set-aside resources to educate
certified  operators, system  staff, and  community boards  about the importance of water
efficiency. These set-asides can pay for water audits, leak detection efforts, designing new rates
and funding rebate/incentive programs. States can also promote water efficiency directly to the
public statewide and provide outreach and education materials to water systems to use in
educating their customers.

Another powerful way states can apply their DWSRF program is to create incentives for systems
to implement water efficiency measures. Some states give systems applying for a  DWSRF loan


bonus points for water efficiency efforts, while other states make a water efficiency plan  a
condition of receiving assistance.

States can incorporate a review of water efficiency as part of their regular sanitary surveys and
during engineering plan review processes for initial water system design or modifications.

Here are some examples of how states encourage or require public water systems to improve
their water efficiency:

     Florida has created  a  voluntary certification  program for residential and commercial
      developments that encourage water efficiency through the use of efficient appliances,
      fixtures, and landscaping. In addition, the state uses DWSRF set-asides to provide water
      audits and leak detection services to small systems.
     Washington  has  a  comprehensive  water efficiency  program  based  on  its  Water
      Efficiency Rule requiring metering,  data  collection,  distribution system leakage of 10
      percent or less and other requirements.
     Colorado  requires water systems that provide over 2,000 acre feet of water per year to
      have a water efficiency plan in  place to receive DWSRF funding. In addition, smaller
      systems can get bonus points for implementing  water efficiency plans. The state has
      made grant money  available to water systems to develop a water  efficiency  plan,
      implement the plan and provide public outreach and education.
     Kansas requires DWSRF applicants to implement a water efficiency plan that has  been
      approved  by the state.
     Pennsylvania has funded a leak detection program for small systems using a DWSRF set-
      aside; the program has saved  over 1.4 billion gallons to date.
     Nebraska systems must either have metered all connections or the project must include
      meter installation to  receive a DWSRF loan.
     Nevada uses DWSRF set-asides to fund technical assistance efforts to water systems to
      prepare comprehensive water conservation programs.
     Texas requires comprehensive regional water conservation plans of most drinking water

 Integrated Resource Management
Water efficiency can be accomplished by instituting operating practices such as automation
methods and strategic use of storage, as well as source water protection strategies and land-
use management methods aimed at conserving water. Water efficiency can be accomplished
jointly with the conservation of other resources, such as energy and treatment chemicals. In
addition, water and wastewater utilities can jointly plan and implement conservation programs
to realize savings and share in the benefits.

Integrative practices can also be accomplished on the demand side. Water and energy utilities
can conduct comprehensive end-use audits and jointly promote conservation practices by end-
users. Large-volume users can work with utilities to make adjustments to processes that reduce
water  and energy usage and wastewater flows, while  saving other resources. Utilities that
provide wholesale water can work with  wholesale customers to design  a  water efficiency
program that will be mutually beneficial.
 Case Studies
Metropolitan Georgia North Water Planning District (MGNWPD)

In 2003, the Metropolitan Georgia North Water Planning District (MGNWPD) adopted a water
supply and water conservation management plan that focused heavily on promoting water
efficiency from both producers and  users to ensure  a safe and sufficient supply of water to
more than 6 million people in and around  the  Atlanta area. The creation of the  regional
MGNWPD,  two years earlier, was driven by concerns raised by rapid population growth (> 1
million people  between 2000-2008), by uncertainty over the potential impacts of climate
change on  a  primarily surface water regional water supply, and  by the need to coordinate
efficiency  and conservation initiatives  among  the more  than 50 public and  private water
entities supplying the region.

MGNWPD developed the plan  by examining the 30-year outlook for supply-side and demand-
side trends. They evaluated  potential water conservation and efficiency measures based on the
maturity  of the technologies,  service  area applicability,  and the  likelihood  of  consumer
acceptance. Measures that were adopted  include tiered  water conservation  rates, fixture
retrofits, legislation to mandate irrigation rain sensors, residential and commercial water audits
and sub-metering for multi-family buildings.  A  public education component was included to
improve public participation. Progress has been made in achieving plan objectives, including a
20 percent reduction in water demand. Since the adoption  of the plan, the average daily water
use within  the district has  decreased from  168 gallons per day(baseline) to 151 gallons per

The severe regional 2007-2008 drought, caused by the driest weather in 75 years, stressed
drinking  water supplies and  underscored the  timeliness of  conservation and efficiency
measures to the greater Atlanta area.lv

Gallitzin Water Authority (GWA), Pennsylvania

Water efficiency and conservation measures taken by the Gallitzin Water Authority (GWA) in
Cambria County, Pennsylvania,  highlight the significant energy, materials and other savings that
can be realized through improved water efficiency. This is the case even when the systems
involved  are  small  (the GWA serves  approximately  2,000 people through  roughly  1,000

In the early  1990s, the  system was experiencing high  operating  costs,  low pressure, and
extreme water loss; more than 309,929 gallons per day (70 percent) was estimated to be lost
through leakage. To solve these problems,  in 1994 GWA instituted a water efficiency plan.  As
part of the plan, GWA created  production and distribution records and mapped system leaks,
eventually isolating 95  percent of the leaks. Once the leaks were identified, a leak repair and
corrosion control program was developed and implemented.

The results of the water efficiency program have been impressive; four years after the start of
the program  GWA had logged  a  59 percent decrease in water production and an 87 percent
decrease in non-revenue water. This has resulted in an annual $20,000 savings in energy costs
and an annual $5,000 savings in chemical costs. It has also extended the life of the system's
    The Drinking Water State Revolving Fund (DWSRF)  can  provide low-interest loans for a
   variety of energy efficiency and water efficiency projects. States are encouraged to continue
   to use their DWSRF capitalization grant to fund green drinking water projects to address
   green infrastructure, water and energy efficiency improvements and other environmentally
   innovative activities. In FY2010 and FY2011, states were required to use a minimum of 20
   percent of their capitalization grant for green projects (also known as the Green Project
   Reserve or GPR).  For the FY2012 capitalization grant, designating green  projects  is at the
   discretion of  the  state.  Examples  of fundable  green  projects include energy audits,
   equipment upgrades, leak detection equipment, water meter installation and  installation of
   water efficient devices.  Other  improvements, which in FY2010 and FY2011  required the
   development of a business case to be designated for GPR, include retrofit or replacement of
   pumps and motors with high efficiency motors, replacement or rehabilitation of distribution
   lines  or  installing Supervisory Control and  Data Acquisition  (SCADA) systems. These
   improvements may also still  be eligible for funding even if  they are not designated  for GPR.


Drinking water systems should contact their state DWSRF programs to find out more about
the state's priorities and funding options.

Eligible water efficiency projects may include the following:

   Installing  and  retrofitting water  efficient  devices  such as  plumbing  fixtures  and
   Installing water meters on previously unmetered connections and replacing broken or
    malfunctioning meters
   Adding Automated Meter Reading capabilities or leak detection equipment to existing
   Conducting  water audits,  leak detection studies  and water  use efficiency  baseline
   Developing conservation plans*
   Recycling and water reuse projects
   Retrofitting or replacement of existing landscape irrigation systems with more efficient
    systems that include moisture and rain sensing controllers
   Projects that result from a water efficiency related assessment
   Distribution  system leak detection equipment
   Automatic flushing systems
   Pressure reducing valves
   Internal plant water reuse (such as backwash water  recycling)
   Distribution  pipe replacement or rehab**
   Storage tank replacement or rehab**
   New water efficient landscape  irrigation system**

* that are reasonably expected to result in  a capital project or in  reduction in demand to
alleviate the need for additional capital investment
** requires approved business case

Reducing water loss and  improving  water  efficiency  do  not have to be daunting tasks.
Beginning with the basic ideas and principles outlined in this fact sheet, water systems can
limit their water losses and improve their water efficiency. Additional resources available to
assist water systems in promoting water efficiency, both at your facilities and with your
customers, include:

   The Alliance for Water Efficiency, http://www.allianceforwaterefficiency.org
   American  Water Works Association, http://www.awwa.org/waterwiser/
   US EPA WaterSense Program, http://www.epa.gov/watersense/
    Water Efficiency: The Journal for Water Resource Management.
   The Association of Metropolitan Water Agencies.
    http://www.amwa.net/cs/water  efficiency/information

Additional ideas for water saving measures come from Australia and the United Kingdom:

      The savewater! Alliance (Australia), http://www.savewater.com.au/
      Waterwise (a not-for-profit, non-governmental organization) in the UK focused on
       decreasing water consumption), http://www.waterwise.org.uk/
1 Sydney Water. 2006. Water Pressure Management Program: Improving the reliability of our water
supply. http://aim.prepared-fp7.eu/viewer/doc.aspx?id=48
" Satterfield, A., 2005. Filter Backwashing. Tech Brief, Vol. 5, Issue 3. National Environmental Services
111  Amirtharajah et al., 1991. Optimum Backwash of dual Media Filters and GAC Filter-Adsorbers with Air
Scour. American Water Works Association Research Foundation Report.
iv  Metropolitan Georgia North Water Planning District (MGNWPD). 2011. Water Supply and Water
Conservation Management Plan, http://www.northgeorgiawater.com/plans/water-resources-plans
v Maryland Department of the Environment. 2003. Developing and implementing a water conservation
Plan: Guidance for Maryland Public Water Systems on Best Management Practices for Improving Water
Conservation and Water Use Efficiency, page D-2.
http://www.mde.state.md.us/assets/document/water cons/wcp guidance2003.pdf
Office of Water (4606M)                  EPA 816-F-13-003                  July 2013