Re-Energizing the Capacity
Development Program
Findings and Best Practices from the
Capacity Development Re-Energizing Workgroup
April 2011
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Office of Water (4606M)
EPA816-R-11-004
April 2011
http://water.epa. gov/drink
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Re-Energizing the Capacity Development Program
Table of Contents
Acknowledgements ii
Introduction 3
Re-Energizing the Capacity Development Program 3
The Capacity Development Re-Energizing Workgroup 4
Recognizing Differences Among Public Water Systems 4
Document Overview 5
Chapter 1: Continue to Enhance Water System Capacity 6
Recommendation 1.1: Improve assessment and measurement of managerial and financial
capacity 7
Recommendation 1.2: Implement efforts to address public water systems with continuing
non-compliance 9
Recommendation 1.3: Continue to enhance operator trainings and support 11
Chapter 2: Re-focus on Education and Outreach 12
Recommendation 2.1: Educate potential and existing public water system owners and board
members on their roles and responsibilities 13
Recommendation 2.2: Raise public awareness on the value and cost of water services 15
Recommendation 2.3: Increase awareness and access to resources and useful tools 16
Recommendation 2.4: Emphasize trainings for public water system managers, owners, and
technical staff on environmental sustainability 17
Chapter 3: Strengthen Implementation through Collaboration 18
Recommendation 3.1: Increase collaboration for all state and federal staff working on
drinking water issues 19
Recommendation 3.2: Increase coordination and communication among funding groups ... 20
Conclusion 22
Appendix A: EPA's Initiatives for Re-Energizing Capacity Development and Promoting
Sustainable Systems 23
EPA's Approach for the Equitable Consideration of Small System Customers (Small Systems
Approach) 23
2010 National Capacity Development and Operator Certification Workshop 24
Clean Water and Drinking Water Infrastructure Sustainability Policy 25
Appendix B: Detailed Case Studies 26
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Re-Energizing the Capacity Development Program
Acknowledgements
This document reflects the comments and insights contributed by a variety of individuals and
organizations. In particular, EPA would like to thank the state representatives and the
Association of State Drinking Water Administrators (ASDWA) who were part of the Capacity
Development Re-Energizing Workgroup, and whose efforts provided substantial contributions to
this document. The states represented on the Capacity Development Re-Energizing Workgroup
include: Indiana, Kansas, Nevada, New Hampshire, North Carolina, Texas, Virginia, and
Washington.
Affiliation
Indiana
Kansas
New Hampshire
Nevada
North Carolina
Texas
Virginia
Washington
EPA Region 1
EPA Region 3
EPA Region 6
EPA Region 7
EPA Headquarters
ASDWA
Name
Mary Hollingsworth
Cathy Tucker-Vogel
Sarah Pillsbury
Jennifer Carr
Julia Cavalier
Doug Holcomb
Barry Matthews
Kristin Bettridge
Jane Downing
Vicky Binetti
Blake Atkins
Mary Mindrup
Mindy Eisenberg, Sonia Brubaker,
Stephen Hogye, Maria Lopez-Carbo
Bridget O'Grady, Jim
Taft
April 2011
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Re-Energizing the Capacity Development Program
Introduction
This document is a reflection of the discussions held over the course of 2010 by the Capacity
Development Re-Energizing Workgroup, as well as a compilation of comments received during
the 2010 National Capacity Development and Operator Certification Workshop. It also includes
insights and ideas from existing strategies and policies, such as EPA's Approach for the
Equitable Consideration of Small System Customers ("Small Systems Approach"). Further
information on EPA's Small Systems Approach, the 2010 National Capacity Development and
Operator Certification Workshop, and other EPA initiatives is included in Appendix A of this
document.
This document was prepared for individuals involved in the Capacity Development and Operator
Certification Programs, including EPA Headquarters staff, EPA Regional staff, state staff, and
stakeholder groups. This document is also intended to be informative to the staff of other
programs (e.g., Drinking Water State Revolving Fund) that help public water systems (PWSs)
attain and maintain technical, managerial, and financial (TMF) capacity.
Re-Energizing the Capacity Development Program
The 1996 Safe Drinking Water Act (SDWA) Amendments emphasize a holistic approach to the
protection of public health and prevention of drinking water contamination. The Act's provisions
for Capacity Development provide a framework for EPA, states, and PWSs to work together and
ensure that PWSs attain and maintain the TMF capacity needed to achieve SDWA's objectives
for short- and long-term capacity. The SDWA Amendments recognized that states have different
needs and resources, and therefore, this framework is not prescriptive. This has led to varied
strategies and diverse implementation of state Capacity Development Programs.
Over 10 years have elapsed since EPA developed detailed guidance for the Capacity
Development Program.l Since that time, national and regional meetings have been held to
facilitate information sharing, numerous tools and resources have been developed, and many
states have identified unique approaches to addressing TMF capacity challenges. Most recently
the EPA Administrator has increased attention to supporting underserved communities,
improving community and infrastructure sustainability, and ensuring that all consumers have
access to safe drinking water. Based on these developments, EPA partnered with eight states and
1 EPA's Guidance on Implementing the Capacity Development Provisions of the 1996 SDWA Amendments (EPA
816-R-98-006) was published July 1998 and EPA's Handbook for Capacity Development: Developing Water System
Capacity under the Safe Drinking Water Act, as amended in 1996 (EPA 816-R-99-012) was published July 1999.
These documents are available on EPA's website at:
http://water.epa.gov/tvpe/drink/pws/smallsvstems/state guidance.cfm.
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Re-Energizing the Capacity Development Program
the Association of State Drinking Water Administrators (ASDWA) to form the Capacity
Development Re-energizing Workgroup to assess Capacity Development's progress thus far and
bring renewed attention to the Capacity Development Program.
The Capacity Development Re-Energizing Workgroup
The main goals of the Capacity Development Re-energizing Workgroup were to better
understand the Program's existing implementation efforts, evaluate roadblocks to building water
system capacity, and identify best practices to facilitate program implementation. Ultimately, this
re-energizing effort should help more PWSs be sustainable as a result of Capacity Development
Programs strengthened by increased knowledge sharing, particularly the sharing of
implementation best practices.
The Workgroup held monthly meetings over the course of 9 months, beginning in January 2010.
At the conclusion of these meetings, the Workgroup developed a summary of identified
challenges, recommendations, and best practices and in September 2010, took these findings to
the 2010 National Capacity Development and Operator Certification Workshop. State and EPA
Regional Workshop attendees were asked for feedback, and the Workgroup met again in October
2010 to incorporate the comments and to further summarize the findings and recommendations.
Recognizing Differences Among Public Water Systems
One of the Workgroup's first actions was to identify challenges faced by states in implementing
the program as well as PWSs that struggle with TMF capacity. Some of the challenges initially
identified by the Workgroup included:
Compliance - meeting current and future regulatory requirements.
Education - providing information to rural PWSs; increasing customer understanding of
the value of water services; expanding knowledge of water and energy efficiency
measures.
Finance - ensuring long-term financial stability to maintain the necessary infrastructure
for providing safe drinking water; ensuring affordable rates and customers' ability to pay
for delivery of safe drinking water; addressing the effects of the recent economic
downturn.
Management - improving decision maker (e.g., board member) involvement and
knowledge of their responsibilities; effectively managing assets; enhancing use of
technology.
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Re-Energizing the Capacity Development Program
Workforce - hiring/retaining certified operators; planning for an aging workforce and
associated loss of institutional knowledge.
Workgroup members acknowledged that challenges differ between community water systems
(CWSs) and noncommunity water systems (NCWSs). For example, nontransient noncommunity
water systems are less likely to employ tools such as water supply plans and capital improvement
plans. CWSs, on the other hand, are subject to more stringent requirements, and therefore, more
technical knowledge and financial resources are generally needed for these PWSs to be
successful. The Workgroup decided not to include transient noncommunity water systems in the
current scope of work due to the unique characteristics of these water systems and the allocated
timeframe for the Workgroup to develop their report.
Document Overview
The Capacity Development Re-energizing Workgroup's findings and recommendations are
organized into the three chapters of this document:
1. Continue to Enhance Water System Capacity.
2. Re-focus on Education and Outreach.
3. Strengthen Implementation through Collaboration.
Each chapter identifies common implementation challenges experienced by state Capacity
Development Programs, followed by recommendations and best practices that can be used to
address these challenges. Some of the best practices demonstrate work that state Capacity
Development Programs, EPA, or other organizations are already implementing, while other best
practices are ideas to work toward. By implementing these recommendations and best practices,
both PWSs and state Capacity Development Programs may benefit.
All of the best practices are examples only. The Workgroup acknowledges that not all best
practices will be applicable to a particular state or PWS, and that additional best practices exist
that are not described in this document. A number of current state examples, corresponding to
specific best practices, are highlighted in textboxes throughout the document. Some of these
examples, as well as additional state examples, are described in greater detail in Appendix B.
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Chapter 1: Continue to Enhance Water System Capacity
One of the goals of the Capacity Development Program is to assist new and existing public water
systems (PWSs) in achieving and maintaining technical, managerial, and financial (TMF)
capacity. PWSs that are able to acquire and maintain TMF capacity are more likely to achieve
long-term sustainability. There are numerous ways to enhance capacity: from correcting non-
compliance to implementing asset management programs to establishing PWS partnerships (e.g.,
equipment sharing, system consolidation). Both PWSs and states, however, may encounter
challenges associated with enhancing capacity, some of which are identified below.
States may not receive sufficient information or may find it difficult to interpret the
documentation received during the PWS proposal/application process in order to
fully assess whether a proposed PWS will have managerial and financial capacity. In
many cases, PWSs are not required to submit information on managerial or financial
capacity along with their permit application, making it difficult for states to determine if
proposed PWSs have the necessary managerial and financial capacity.
Managerial and financial capacity are not easily assessed and measured by PWSs or
states. Many states and technical assistance (TA) providers have found that managerial
and financial capacity are more difficult to define and measure than technical capacity
and, therefore, more challenging to address. Additionally, some states do not have
standard indicators or a uniform method for evaluating managerial and financial capacity.
Some PWSs struggle to obtain and retain qualified operators. A certified, dedicated
operator is essential to the capacity of a PWS. PWSs without knowledgeable operators
are at higher risk of non-compliance and other capacity issues.
States often do not have the staff or resources to conduct follow-up visits to ensure
that PWSs are implementing TMF activities. Staffing shortfalls and budgetary
constraints make it difficult for states to follow up with PWSs that have received
technical, managerial, or financial assistance. This creates opportunities for existing
PWSs to lose TMF capacity without the state's immediate knowledge.
The following recommendations and associated best practices were identified as opportunities to
address these challenges. As mentioned earlier, some of the best practices for each
recommendation are already being used, while others are ideas for the future. Furthermore, not
all best practices will be applicable to all states or PWSs.
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Re-Energizing the Capacity Development Program
Recommendation 1.1: Improve assessment and measurement of
managerial and financial capacity
To address challenges related to IMF capacity, the Workgroup identified several ways that states
can work to improve the assessment and measurement of PWS capacity and thereby identify
areas for improvement. Understanding a PWS's IMF capacity will assist the state in prioritizing
assistance resources based on identified need. While all three components of TMF capacity are
important, managerial and financial capacity are sometimes less clearly defined and oftentimes
more challenging to measure. Therefore, it is important to identify specific tools that can assess
the managerial and financial capacity of PWSs and to use these as metrics for measuring
improvement. The following best practices may aid states in implementing this recommendation.
Promote effective management by providing specific support for new PWSs.
Offering direct support over the first year or more of operation may help a PWS maintain
managerial and financial capacity. It may also allow the PWS to better understand all of
its regulatory requirements to ensure long-term compliance.
»»» During the first year of operation,
states or TA providers might
consider assisting PWSs in the
development of asset management
plans, programs, and/or standard
operating procedures (SOPs).
States and TA providers should
encourage PWSs to create dynamic
plans that will help guide
management decisions and can be
The Iowa Department of Natural Resources
promotes effective management by offering a Self-
Assessment Manual as a tool for PWSs to assess
their TMF capabilities. The Manual allows PWS
managers to carefully consider all aspects of TMF
capacity and plan for long-term capacity and
sustainability. All PWSs are encouraged to utilize the
Manual for self-evaluation.
http://www.iowadnr.gov/water/viability/manual.html
updated over the years as various changes occur.
States may want to consider developing a primer on managerial capacity that
introduces new PWS owners to available TMF tools and resources and helps them
understand how and why to use these tools.
Some states have suggested
requiring a detailed business
plan or water system
management plan for proposed
PWSs to ensure that PWSs start
off with adequate managerial
and financial capacity. Either of
these plans or a similar
Indiana currently requires potential PWSs to submit a
water system management plan. The plan allows
potential owners to learn about the full responsibilities
of owning a PWS. Additionally, the state encourages
proposed PWSs to identify existing PWSs within a 5-10
mile radius that may be suitable for connection. Refer
to Appendix B for more information.
http://www.in.gov/idem/4868.htm
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management plan could cover, among other things, the details of an infrastructure
strategy, information on the PWS owner and operator, and short- and long-term
budget plans. Water system management plans should also be designed so they can be
updated easily to facilitate adaptation to future changes and be useful to the PWS over
the course of many years.
»»» Another option for promoting effective management is for states to develop tailored,
dynamic monitoring plans for PWSs that detail all of the responsibilities and
associated costs of day-to-day activities (e.g., sampling procedures). States that
choose to develop such a plan could design a general plan for all PWSs, for any PWS
that requests such a plan, or design a tailored plan for PWSs that the state has
identified as struggling to achieve or maintain capacity.
Use surveys to collect managerial and financial information, determine which PWSs
have the greatest need, and prioritize state resources Although it may be resource
intensive, states may find it worthwhile to use surveys or questionnaires to request
information about managerial and financial capacity. States can use the submitted
information to determine which PWSs need the
most assistance and then prioritize state
resources accordingly. Follow-up surveys could
be sent (e.g., every 2 years) to track PWSs'
progress. Over time, the information may help
the state identify which PWSs are not building
managerial and financial capacity and, therefore,
require additional assistance. Another option is
for states to review managerial and financial
components during sanitary surveys. Some states
(e.g., Nebraska) have had success using sanitary
surveys for this purpose, while other states have
struggled. A common challenge for using
sanitary surveys to obtain managerial and financial information is that survey reviewers
are trained specifically to conduct sanitary surveys, not to assess TMF capacity. States
may want to consider training sanitary survey reviewers on standard procedures for
collecting TMF capacity data. Most importantly, prior to choosing an information-
collection method and starting data collection efforts, states will want to be sure that the
type and amount of information to be collected reflects the state's intended purposes and
will provide valuable insight on PWSs' managerial and financial capacity.
Kansas send outs a comprehensive
survey to community water systems
(CWSs) in the state every 3 years, which
includes questions on TMF capacity.
Kansas uses the survey to score each
CWS, determine trends (e.g., number of
CWSs not reviewing their water rates),
assess loan distribution (CWSs lacking
TMF capacity are ineligible for full
loans), and develop appropriate tools
(e.g., rate setting resources).
http://www.kdheks.gov/pws/capdev.html
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Recommendation 1.2: Implement efforts to address public water
systems with continuing non-compliance
A PWS that is regularly or continually in non-compliance poses a serious risk to public health
and requires state attention. There are numerous reasons that a PWS may be continually non-
compliant. Technical capacity may be the most apparent problem; however, managerial or
financial deficiencies may be the underlying causes of technical deficiencies. Understanding the
drivers of non-compliance will help states in their efforts to assist struggling PWSs in achieving
long-term compliance. These efforts will move these PWSs along a path towards achieving long-
term TMF capacity and sustainability, which is supported by the following best practices.
Assign a dedicated person to each non-compliant PWS. PWSs facing multiple years of
non-compliance oftentimes have a unique combination of circumstances which results in
recurring violations. The state may want to consider having a dedicated person oversee
each struggling PWS. This individual would become intimately familiar with the PWS's
characteristics and become knowledgeable
, , ., . , New Hampshire uses referrals from
about the root causes contributing to the non- , ,
enforcement and sanitary surveys to
compliance (e.g., new regulations, poor
management, artificially low or non-existent
water rates, lack of maintenance,
unwillingness to change PWS procedures,
need for infrastructure financing, etc.). PWSs
could view this person as their "go to" person
for questions and concerns since this
individual would be responsible for helping
to shepherd the system back into compliance.
Furthermore, this individual may be able to r/dwgb/capacity/index.htm
generate a "bucket list" of PWSs in need. A
primary contact or Project Manager is then
responsible for identifying each PWS's
needs and reporting progress on a regular
basis. The state keeps track of interactions
with each PWS using a task log and regular
meetings with management. Refer to
Appendix B for more information.
http://des.nh.gov/organization/divisions/wate
develop a relationship with the board members, owner, and operator, which may facilitate
information sharing and open communications between the PWS and the state. As an
additional benefit to the state, this dedicated person may be able to develop an overall
understanding of the types and underlying causes of non-compliance throughout the state.
Improve non-compliant PWSs' access to and use of technical assistance and other
resources, while balancing state resource limitations. Continually non-compliant
PWSs are typically in need of additional assistance from states. These PWSs oftentimes
have less knowledge of available resources that may help them return to compliance, or
they may have less knowledge of how to use resources. These resources may include, but
are not limited to, contact information for third-party TA providers, copies of guidance
materials, and lists of funding sources. The type of assistance that states may need to
provide will differ from one PWS to the next and may range from simply providing and
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explaining informational materials (e.g., factsheets, software) to providing one-on-one
assistance (e.g., in-person demonstration on how to do jar testing). States may be able to
allocate assistance efforts more effectively by assessing which PWSs will benefit most in
the long-run from targeted outreach and which PWSs will not make long-term changes
towards self-sufficiency and, therefore, become a drain on state resources. To make this
distinction, it is important to understand and recognize that the root causes of non-
compliance are specific to a given PWS. Most PWSs that are provided with assistance
will use those resources to build capacity. However, the state must determine how to
prioritize resources to achieve the greatest benefit while providing assistance to all
struggling PWSs.
Assess, explain, and promote PWS partnerships, where appropriate. One way states
can assist struggling PWSs is by conducting initial assessments to determine whether the
PWS is a good candidate for partnerships, including restructuring or consolidation.
Forming partnerships with other PWSs is a proven approach that may provide a wide
range of options and benefits. PWS partnerships may be an effective means of changing a
PWS's operation, management, or institutional structure so that the PWS can provide
reliable drinking water services, streamline system management, and reduce costs.
Partnership options can range
from informal measures, such
as sharing equipment, to more
formal options, such as
Texas contracts with the Texas Rural Water Association to
provide consolidation assessments. The contractor discusses
consolidation with the small PWS and other surrounding
, f i- f entities and helps facilitate consolidation activities (e.g.,
transferring ownership of a
_, , , 1-1- completing paperwork or providing support at public
PWS through consolidation. > , , , . r
meetings). Texas also contracts with the University of Texas to
For example, partnerships can , . _..._ ..,..,,, .... , t , t. . ,,
r 'r r help PWSs with MCL violations understand their problems
allow PWSs to contract gnd conso|idation options (e.g., interconnections, treatment,
or relocating a source), including the financial impacts. Refer
to Appendix B for more information.
http://www.trwa.org/FMTAssistanceBrochure.pdf
http://www.beg.utexas.edu/environqlty/TCEQ_ss2004-2007.htm
management, billing, or
customer service tasks to a
neighboring PWS or an
outside business. Another
partnership option, which
may reduce administrative and operating costs, is to create a Joint Powers Agency or to
consolidate under common regional ownership or management while maintaining
separate infrastructure and treatment. Neighboring PWSs can sometimes benefit from
physically connecting their infrastructure and sharing components, such as treatment
facilities and distribution lines. States have noted that it is more cost effective and
successful in the long-run to spend money on helping PWSs with partnerships than on
maintaining failing, unsustainable PWSs. To further promote these efforts, states may
offer additional support, such as low-cost financing for various partnership activities.
Potential resistance to partnerships, especially consolidation, should be recognized and
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Re-Energizing the Capacity Development Program
earnestly addressed. This may involve employing a third-party mediator to explain the
benefits to all the parties involved.
Recommendation 1.3: Continue to enhance operator trainings and
support
It is important for states to regularly evaluate and enhance operator trainings as needed,
especially taking into account technological changes that may improve PWS operations and
innovations in management of PWSs. Other support mechanisms for operators, in addition to
traditional classroom trainings, can include periodic meetings with the state and TA providers,
site visits, and website resources such as operator "chat rooms." Below are some specific best
practices to enhance operator trainings and support.
Promote outreach, mentoring, internship, and apprenticeship programs to address
workforce challenges. Some PWSs struggle with workforce issues, whether related to
staff retirement or turnover. Hiring and retaining a certified operator is vitally important
to the success of any PWS. To
Massachusetts uses its Green Job Training and
Placement Partnership to identify, attract, and train
future PWS operators by providing them with both
classroom and field training. Trainings are offered
through vocational and technical high schools, evening
adult education classes, and state and community
colleges. An associated internship program is open to all
students who complete a training program. The state
identifies PWS operators who can mentor the training
program graduates. These mentors agree to play an
active role in the development of the individual as a
water supply professional and offer meaningful work
that exposes the student to many facets of PWS
operation. Refer to Appendix B for more information.
http://www.mass.gov/dep/water/drinking/greeniob.htm
address these workforce issues,
states may consider developing,
requiring, and/or supporting
mentoring, internship, or
apprenticeship programs that
educate the next generation of
PWS operators. States can also
promote programs that increase the
prestige associated with the
certified water profession and help
encourage more individuals to
learn about and pursue the career.
States may encourage PWS
managers and operators or industry
associations to reach out to those
who will eventually be entering the workforce. These outreach activities may include
operators visiting elementary, middle, and high schools or participating in career days. It
may also include reaching out to those currently in the workforce through adult education
or career re-training programs. The state should be sure that any outreach activities are
appropriately tailored to target the intended audience.
Encourage programs to sustain institutional knowledge. Many PWS owners,
managers, and operators have a thorough understanding of operation and maintenance of
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Re-Energizing the Capacity Development Program
their PWS because they have worked at the PWS for many years. States may want to
assist PWSs in ensuring that this institutional knowledge is gathered, preserved, and
passed on by encouraging programs that facilitate information sharing between new and
existing PWS operators. For example, states may want to require a "transitional" operator
that will observe the previous operator before his or her retirement from the PWS.
Similarly, mentoring programs, like those mentioned in the previous best practice, allow
current operators to pass on their knowledge of a particular PWS and its operation, as
well as PWS operation in general. These types of programs can help ensure that
institutional knowledge, including best practices and PWS-specific SOPs, is maintained
and shared with future owners and operators through first-hand experience.
Provide assistance to PWSs using contract operators Some PWSs benefit
substantially from using contract operators. Some states, such as Colorado, encourage the
majority of their small PWSs to utilize contract operators so that a certified operator is
consistently working at the PWS. To assist
PWSs with the process of contracting water
services, states can maintain an active list of
contract operators in the state and provide operators which is made available on its
1 i Tvn7o i 11 website. These contract operators are
guidance to PWSs on contractual language
, .,.,.. T ,,.. certified operators that are responsible for
and contractor responsibilities. In addition, , , .. . . ... , ,
the daily operational activities of three or
states may want to consider compiling a list of
The Washington Office of Drinking Water
maintains a list of approved contract
more PWSs. Contract operators must be
available 24 hours per day and are subject
to specific certification and documentation
requirements. These requirements also
apply to operators of Washington's
Satellite Management Agencies.
http://www.doh.wa.gov/ehp/dw/opcert
contractor operators that are able to assist in
the event of an emergency. It may also be a
good idea for states to monitor the number and
complexity of PWSs being run by a single
operator so that one operator does not assume
more responsibilities than he or she can
reasonably manage. Some states have
developed contractor operator materials and documents, including interview questions,
contract templates, guidelines, and more. One way states can obtain this information is
through ASDWA's CapCert Connections website
(http://www.asdwa.org/index.cfm?fuseaction=Page.viewPage&pageId=503). This
website does require individuals to register and obtain a valid username and password in
order to access the information.
Chapter 2: Re-focus on Education and Outreach
The Workgroup identified a need for further education and outreach efforts to assist PWSs and
boards, as well as to improve knowledge sharing among states related to implementation of the
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Re-Energizing the Capacity Development Program
Capacity Development Program. Several commonly experienced challenges can be tackled
through education and outreach. These challenges include:
Ensuring that PWS owners and board members understand their roles and
responsibilities. In particular, new PWS owners and board members are often unaware
of the complexity, legal responsibility, and expense of running a PWS.
Recognizing that it is often difficult to convey the value and cost of water services to
customers. The public is largely accustomed to the false notion that treated water is a
freely available public good. Some PWS customers are unaware of the complexity and
costs associated with delivering reliable, safe drinking water.
Improving awareness of available tools and resources. Many states, PWS owners and
operators, and TA providers have tools and resources that can address specific needs and
problems. Many of these resources, however, remain unknown to or underutilized by
others who can benefit from them. In addition, the tools and resources are rarely collected
in one central location, creating an obstacle to accessibility.
A number of recommendations and best practices were identified to address these challenges. As
with the previous chapter, some of the associated best practices for each recommendation are
already being used, while others are ideas for the future.
Recommendation 2.1: Educate potential and existing public water
system owners and board members on their roles and responsibilities
Many state Capacity Development Programs have created opportunities or established
requirements for new owners to learn about their responsibilities prior to state approval of a new
PWS. Such opportunities or requirements are intended to reduce the likelihood that owners will
find themselves unable or unprepared to handle the responsibilities of running a PWS. The
Workgroup identified several existing and potential best practices that state Capacity
Development Programs may use to support this recommendation.
Develop a "PWS Ownership 101" package. Some states have developed an
introductory package describing roles and responsibilities that can serve as an effective
tool for states to communicate with new or potential PWS owners. In addition to
providing these 101 packages to potential new owners, states can also provide them to
any "found" PWSs (i.e., PWSs that are identified after they are constructed). Introductory
packages can outline important roles and responsibilities, emphasizing those of owners.
In some cases, potential PWS owners who receive this type of information will recognize
that the responsibilities and complexities of owning a PWS are greater than they had
realized and that establishing a new PWS may not be the best option. Therefore, states
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Re-Energizing the Capacity Development Program
may want a 101 package to include alternatives to forming a new PWS (e.g., connecting
to an existing PWS). A number of states, such as North Carolina, send letters or other
materials addressing specific topics related to PWS ownership. Any "101" materials,
whether newly developed or adapted from an existing state's materials, should be
provided to potential PWS owners as early in the permitting process as possible.
Use incentives to increase PWS owner and board member attendance and
participation at trainings. Effective trainings should identify and distinguish between
the roles and responsibilities of owners, operators, and board members. Board members
play an integral role in ensuring that their PWS has capacity. Many states and
organizations offer well-developed and
effective trainings, but are looking for
innovative ways to increase attendance
and engagement. One idea for
As an incentive to increase board member/council
attendance at trainings, Kansas awards additional
DWSRF points to a PWS if 80 percent or more of the
encouraging owners or board members board/council for that pws attends a trainin§
,, . , jv. session. Additionally. PWS operators earn 5 hours of
to attend trainings is to otter
, _, . , . T,T credit if the majority of the board attends a training
incentives, such as Drinking Water _ , ,. _, . ,
session. Refer to Appendix B for more information.
http://www.kdheks.gov/pws/capdev.html
State Revolving Fund (DWSRF)
priority points. Once owners or board
members attend a training session, they may develop a deeper understanding of the
complexity of operating and maintaining a PWS. Seeing the need for and value of such
trainings may even lead these individuals to seek out additional trainings and resources
and may also make them more apt to address the PWS's needs and plan for long-term
sustainability.
Promote effective management by providing periodic training for existing PWS
owners and board members. Providing trainings on a periodic basis can support
managerial and financial capacity for PWSs and provide useful IMF capacity indicators
for states and EPA. Periodic training ensures that existing PWS owners and board
members continue to understand the managerial and financial needs of the PWS even as
changes occur over time, such as new regulatory requirements or changes in workforce
(e.g., turnover or retirement). States may want to provide training on developing and
updating a PWS business plan, calculating cash flow summaries, and understanding
profitability and basic accounting practices. Other ideas include training PWS owners and
board members in performing rate analyses and conducting water loss audits and energy
efficiency evaluations. By training these individuals on how to accurately produce this
type of information, states could benefit from being provided with useful indicators of
capacity, which can then be used to prioritize PWS assistance.
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Re-Energizing the Capacity Development Program
Recommendation 2.2: Raise public awareness on the value and cost of
water services
Community support is essential for PWSs to be sustainable. Public awareness of the value and
cost of water treatment and delivery services allows PWSs to accurately price these services.
States can help ensure a PWS's long-term capacity, particularly financial capacity, by promoting
a common understanding of the value of water services among PWSs' customers. To raise public
awareness of the value and cost of water services, a variety of best practices are available.
Support a public campaign to raise customer awareness. A public campaign to raise
awareness about the value of delivered water can change consumer expectations by
increasing awareness and understanding of the true costs of providing water. These
campaigns could aim to increase customers' appreciation for the amount of effort that is
required to reliably provide safe water and ensure that PWSs have the capacity to meet
water demands. Campaigns can be developed and implemented at the national, state,
community, or PWS level. Under the Capacity Development Program, states are able to
use DWSRF set-aside funds for public education outreach campaigns. For example,
Arkansas uses set-aside dollars to support general outreach on the importance of wellhead
and ground water protection programs. In addition to performing public outreach in their
own states, states can also support existing national or regional initiatives, such as the
American Water Works Association (AWWA) Only Tap Water Delivers grassroots and
media campaign. This AWWA campaign helps PWSs and local officials communicate to
consumers, the media, and other stakeholders about the value of tap water services.
Evaluate, assess, and communicate the value provided by PWSs by comparing
water rates with other utility rates or commodities. It is beneficial for PWSs to
evaluate their water rates on a regular basis to determine whether the current rates meet
their near- and long-term financial
needs. If an evaluation of water rates
appropriate water rate would be. When
The Environmental Finance Center and the North
indicates that current or proposed rates Carolina League of MuniciPalities collect rate
.,, , rv- . . , schedules annually from hundreds of local
will make revenue insufficient and
. government and not-for-profit utilities in North
stress the PWS s financial capacity, the _ .. _. , , , , ,
Carolina. The rate schedules are used to determine
PWS must then assess what a more , . . .... ,, . , ..
what customers are billed for water and other
services at various consumption levels. Information
a PWS determines that its water rates on rates and rate structures are then shared among
utility managers, including PWS owners.
http://www.efc.unc.edu/projects/NCWaterRates.htm
are unsustainable, one way to
communicate the importance of higher
rates to its customers is to demonstrate
that water rates are lower than other utility rates (e.g., heating) and commodities (e.g.,
bottled water). This difference in rates is often found even when water rates are increased
April 2011 Page 15
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Re-Energizing the Capacity Development Program
to sustainable levels, and PWS owners need to articulate the benefits customers are
getting for the price. Illustrating this value for cost can be especially useful for helping
customers realize how much they benefit from a sustainable PWS that provides safe,
reliable drinking water while operating with sufficient infrastructure, management,
technology, and resources.
Link water bills to water use. PWS owners, operators, and customers should be aware
of exactly how much water is being consumed. If PWSs bill according to metered
consumption, consumers may be more apt to control their water use through water
efficiency and water conservation efforts in order to save money. Additionally, providing
explanations on how water rates reflect actual costs (e.g., instead of just stating "variable
fee" or "fixed fee" on the bill) can also help customers to correctly value water services.
Recommendation 2.3: Increase awareness and access to resources and
useful tools
The Workgroup emphasized that PWSs, states, third-party TA providers, and EPA all need to
find ways to increase their awareness of existing practices and resources. The primary issue is
not a shortage of tools or best practices. Rather, resources are scattered and can be time-
consuming to collect, which can hinder the dissemination of this information. While venues for
information sharing, such as national and regional meetings, webinars, and websites, do exist,
demand for faster and easier access to resources is still high. For example, the 2010 National
Capacity Development and Operator Certification Workshop provided a meaningful opportunity
for groups and individuals working in the Capacity Development, Operator Certification, and
technical assistance fields to come together and participate in discussions (for more information
on the 2010 Workshop, refer to Appendix A of this document). The comments received during
the Workshop reinforced the notion that people are very interested in learning from one another
and sharing ideas. Based on the Capacity Development Re-Energizing Workgroup's findings and
recommendations, a number of potential best practices are available to enhance outreach and
sharing of tools and resources.
meetings at all
organizational levels
to share new and
important
information. State
workshops can be
organized to both
contribute to and build
The Mississippi Department of Health partners with a state Advisory
Committee to review, evaluate, and discuss the state's Capacity
Development Program during a regular, annual meeting. The
Advisory Committee consists of representatives from stakeholder
organizations (e.g., Mississippi Rural Water Association, Mississippi
Municipal League, Mississippi Water & Pollution Control Operators'
Association, Rural Community Assistance Partnership), as well as
selected PWS managers and operators from around the state.
http://msdh.ms.gov/msdhsite/_static/resources/2998.pdf
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Re-Energizing the Capacity Development Program
off of national or regional workshops, such as the 2010 National Capacity Development
and Operator Certification Workshop. Participants and stakeholders should be able to
contact workshop planners with relevant information and ideas, both before and after the
workshop, so that the information can be shared more broadly. It is important for
meetings to facilitate two-way information sharing - meaning participants should be
encouraged to both contribute to, and learn from the events.
Increase and encourage sharing of information, tools, and resources. States and other
organizations can collaborate to address a range of timely topics and provide examples of
recommendations and best practices by hosting webinars or other types of events. States
or EPA can also highlight interesting and innovative examples from states and PWSs,
including those that address challenges related to implementation, system capacity, and
sustainability. Furthermore, EPA's website, or
an alternate website, may be used as a discussion
board for states to share the challenges and best
practices of their programs. Capturing materials
/-^T\ TTCT-) u _i- i i u i f i TA. permitting, contact information.
on a CD or USB may be particularly helpful in ' ^ Bl
n A A i r- A- emergency planning, water conservation
allowing state programs to share information
... , . i i +- u u- u A Planning. and reporting.
with PWSs in rural locations where high-speed ,, ,
° r http://www.kdheks.gov/pws/capdev.html
internet access may not be available or
The Kansas Department of Health and
Environment developed a CD for PWSs
that includes information on requesting
affordable. Overall, the goal of any of these efforts should be to increase knowledge
sharing amongst all individuals.
Recommendation 2.4: Emphasize trainings for public water system
managers, owners, and technical staff on environmental
sustainability
Many PWSs face water availability and financial challenges. Incorporating environmental
sustainability objectives such as water and energy efficiency and long-term source water
management into operator and board member trainings can play an important role in
strengthening TMF capacity and can generate real cost savings for PWSs. To implement this
recommendation, the best practice below was identified. The Workgroup noted that some small
and very small PWSs may find the implementation of water and energy efficiency and long-term
resource management objectives to be particularly challenging and that in some cases this best
practice could conflict with the need to address existing non-compliance issues (e.g., arsenic
violations). For these reasons, some states may choose not to prioritize use of the following best
practice for some PWSs.
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Re-Energizing the Capacity Development Program
Educate PWS managers, owners, and technical staff on the DWSRF Green Project
Reserve (GPR) and other funding sources for efficiency and environmental
sustainability. The DWSRF provides several funding opportunities to enhance IMF
capacity by implementing water efficiency (e.g., metering, leak detection), energy
efficiency (e.g., energy audits, pump system
x . ,, . The Georgia Environmental Finance
optimization), green infrastructure, and
... . . Authority uses a pre-application process for
environmentally innovative projects,
green projects requesting DWSRF funding.
The pre-application is designed to help
potential loan applicants describe proposed
green projects and environmental
improvements. The pre-application is used
to rank each GPR project and develop a
priority list of green projects.
http://www.gefa. org/lndex.aspx?page=504
particularly through the GPR. In Fiscal Year
2010, 20 percent of state DWSRF funds had
to be used to help PWSs implement GPR
projects. PWSs considering their
infrastructure needs should evaluate the costs
and benefits of GPR-eligible projects. States
can assist them in understanding the GPR
requirements, as well as requirements for
other funding sources for environmental sustainability (e.g., Department of Energy grants
for energy efficiency). For example, states can consider holding training sessions to
explain requirements or provide examples of green business cases (e.g., engineering
reports, information on water or energy audits). State programs can also use a variety of
resources to help identify PWSs with potential projects that qualify for funding based on
green or sustainable criteria. Pennsylvania, for example, contracted services for
assistance in identifying GPR-eligible projects.
Chapter 3: Strengthen Implementation through
Collaboration
Members of the Workgroup and participants of the 2010 National Capacity Development and
Operator Certification Workshop recognized that collaboration efforts are essential to addressing
many of the challenges identified by state Capacity Development Programs. Several commonly
experienced challenges related to collaboration include:
Limited communication reduces opportunities for collaboration across various
groups working on drinking water issues. Staff and managers working on drinking
water issues (in the Capacity Development, Operator Certification, DWSRF Programs,
and more) may sometimes be located in different office buildings or government
divisions, or may rarely interact on a regular basis. This communication challenge often
prevents staff from having a sound understanding of the needs, practices, and priorities of
the other individuals working on drinking water issues, resulting in limited collaboration
and missed opportunities for joint efforts.
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Re-Energizing the Capacity Development Program
A lack of coordination among different funding sources. The variations in the rules
and deadlines for funding sources can make it challenging for PWSs to acquire the funds
needed for a particular project. Navigating the numerous, different funding options can
sometimes be an overwhelming task. As a result, some PWSs do not take advantage of
the most appropriate funding sources and therefore, do not make needed long-term
planning or infrastructure investments.
The following recommendations and associated best practices were identified to address these
challenges. These best practices call attention to the fact that partnerships can occur on many
levels, including within state programs, across state programs, and between states and EPA. In
addition to the recommendations listed below, states can also explore other approaches for
effective collaboration. The most effective strategy will vary based on the specific circumstances
of the state and on the type and size of a PWS.
Recommendation 3.1: Increase collaboration for all state and federal
staff working on drinking water issues
Increasing collaboration between staff working on drinking water issues requires communication
and cooperation among members of the Operator Certification, Capacity Development, DWSRF,
Enforcement, Source Water Protection, and Regulatory Programs, among others. Collaboration
can improve the utilization of funds as well as the prioritization of PWSs or operators in need of
assistance. The most effective actions and approaches for collaboration will vary from one
organization to another. Critical to the success of such partnerships is support from both the
bottom-up (a desire for staff members to collaborate) and the top-down (encouragement and
support for collaboration from state program managers, EPA Regional staff, and EPA
Headquarters staff). The following best practices, identified by the Workgroup, are intended to
help implement this recommendation.
Participate in collective discussions about struggling PWSs and how to assist them.
Discussions among the different individuals responsible for assisting struggling or non-
compliant PWSs can
help everyone develop
Capacity Development
Program can meet
with those in the
enforcement, funding,
Washington's Capacity Development Program promotes the Small
a more comprehensive Communities lnitiative
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Re-Energizing the Capacity Development Program
and regulatory divisions to analyze why PWSs are not attaining or maintaining IMF
capacity. Staff can work together to find ways to assist struggling PWSs and ensure that
the PWSs can maintain capacity after assistance has ended. In-person meetings,
electronic correspondence, conference calls, and discussion boards are just a few
examples of forums to facilitate this information sharing.
Increase interactions between the Capacity Development and DWSRF Programs to
promote sustainable PWSs. Discussions between these programs can increase
identification of current resources within the state and ways that these resources can be
used most effectively to further promote
11 Tvnrn T 1 /-> -A The Maine Drinking Water Program uses PWS
sustainable PWSs. In particular, Capacity
Consolidation Grants to provide financial
Development staff can comment on
Intended Use Plans to provide insight into
PWS projects, such as projects for
optimization of pump systems for
increased energy efficiency. Additionally,
Capacity Development staff can help
assess the TMF capacity of DWSRF loan
applicants. This may ensure that more
loans are given to sustainable PWSs, that
set-asides are used to build TMF capacity, vices/capdev/capdev.htm
assistance to PWSs struggling with TMF
capacity. The grants of up to $100,000 are
intended to encourage these PWSs to consider
consolidation with a more viable PWS or consolidation with a neighboring, viable PWS.
The Consolidation Grants are funded using the
15 percent DWSRF Capacity Development set-
aside. Grant recipients are required to
complete an environmental review process.
Refer to Appendix B for more information.
http://www.mame.gov/dhhs/eng/water/dwp_ser
and that PWSs lacking TMF capacity are provided with the opportunity to become
sustainable by having access to conditional loans (e.g., requiring submittal of quarterly
operations and maintenance data). Capacity Development staff can then evaluate PWSs'
capacity after receiving DWSRF funding to determine if funding has led to long-term
improvements in TMF capacity.
Recommendation 3.2: Increase coordination and communication
among funding groups
States, EPA, the United States Department of Agriculture (USDA), the Department of Housing
and Urban Development (HUD), and others involved in funding drinking water infrastructure
can benefit from proactively coordinating and communicating to achieve shared goals and
enhance PWS capacity. Several existing and potential best practices to increase collaboration can
be explored at the state and federal levels.
Identify non-traditional sources of funding for PWSs. The Workgroup suggested that
by considering innovative or non-traditional funding ideas (e.g., not the DWSRF), EPA
or state Capacity Development Programs can develop a list, database, or catalog of
April 2011 Page 20
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Re-Energizing the Capacity Development Program
funding sources that extends beyond the traditional sources that are familiar to most
PWSs. States that use or discover non-traditional funding sources can also make this
information available
The California Partnership for the San Joaquin Valley is a public-
private partnership focused on improving the region's economic
vitality and quality of life. The Partnership is composed of 24 members
from state government to local governments and the private sector.
One effort undertaken by the Partnership included using a Seed (e.g.,
startup) Money grant to develop a draft integrated federal and state
regional water plan.
http://www.sivpartnership.org/wg_seed_grant.php?wg_id=10&sg_id=13
to other states, third-
party TA providers,
and PWSs. This may
help PWSs determine
which funding sources
are most applicable to
their projects and take
advantage of more
diversified funding options. Some potential non-traditional funding sources for states and
PWSs to explore include, but are not limited to: Public-Private Partnerships, Department
of Education grants (for drinking water projects at schools), the Bureau of Reclamation
Working Capital Fund, the Small Business Administration's Small Business Loans, the
Army Corps of Engineers, and the Department of Energy (grants for energy efficiency).
Increase collaboration at a national level to increase funding opportunities for all
PWSs. HUD's Community Development Block Grant Program, USDA's Rural Utilities
Service, and the DWSRF Program all have important and unique funding programs. By
taking advantage of opportunities for collaboration, these funding agencies may be able
to collectively promote worthwhile and sustainable projects, while clarifying and
increasing consistency between their different funding requirements. Some PWSs may be
more familiar with one particular funding source than others. Increased clarification of
funding objectives may aid PWSs in recognizing ways that their projects fit within the
objectives of different funding sources. Furthermore, increased consistency in funding
requirements may reduce the burden of completing funding applications for multiple
funding agencies, particularly for small PWSs.
Coordinate funding efforts among all
state funding agencies. Well-designed
funding coordination activities can help
stretch limited public dollars further and
streamline the efforts of both local
communities and funding agencies.
Coordination may take place on a
variety of levels, depending on a state's
needs or resources. One way to
coordinate funding sources is by
establishing a pre-application process.
The Nevada Water and Wastewater Review
Committee (NWWRC) brings together state and
federal funders to assist communities in navigating
multiple agencies' application processes. NWWRC
created a pre-application to help small
communities begin the application process and to
provide consistent information to all of the
funding agencies. The committee recommends the
most appropriate funding for the applicant. Refer
to Appendix B for more information.
http://ndep.nv.gov/bffwp/nwwpa.htm
April 2011
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Re-Energizing the Capacity Development Program
Another coordination method is to hold regular (e.g., quarterly) meetings among funding
agencies or create a funding committee with representatives from each agency.
Conclusion
The Workgroup hopes that sharing the recommendations and best practices described in this
document will help spread awareness about available tools and opportunities, inspire new
initiatives and ideas, and re-energize state Capacity Development Programs. Measuring the
progress of Capacity Development Programs can be difficult, but is a worthwhile endeavor,
particularly in light of declining state resources and the need for PWSs to be sustainable.
At the conclusion of the 2010 National Capacity Development and Operator Certification
Workshop, participants identified the three most important topics to address over the next few
years. Many participants agreed to help tackle these issues by forming workgroups that would
promote discussion of challenges and sharing of best practices. The three workgroups address the
following topics identified at the Workshop: 1) managerial capacity; 2) collaboration; and, 3)
workforce. At the time of this document's publication, these workgroups have already started to
meet. These workgroups will continue to meet and hope to share the information learned with all
individuals involved in the Capacity Development Program. In addition, the Capacity
Development Re-energizing Workgroup agreed to continue meeting on an ad hoc basis to
discuss any timely issues or new best practices. Any individuals interested in staying up-to-date
with EPA's and the states' current activities on these topics can obtain information through the
new CapCert blog on ASDWA's CapCert Connections website
(http://www.asdwa.org/index.cfm?fuseaction=Page.viewPage&pageId=503). This website does
require individuals to register and obtain a valid username and password in order to access the
information.
Overall, information sharing within the Capacity Development Program is moving forward and
improved communication methods are being evaluated and tested. The Workgroup encourages
EPA to continue working closely with states in addressing new and existing challenges, and
identifying new and innovative best practices for the Capacity Development Program. The
culmination of actions by states, EPA, and other stakeholders will continue to help PWSs
improve capacity and continue along a path towards achieving long-term sustainability.
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Re-Energizing the Capacity Development Program
Appendix A: EPA's Initiatives for Re-Energizing Capacity
Development and Promoting Sustainable Systems
EPA's Approach for the Equitable Consideration of Small System
Customers (Small Systems Approach)
The United States Environmental Protection Agency (EPA) prepared the Approach for the
Equitable Consideration of Small System Customers ("Small Systems Approach") in 2009 to
improve public water system (PWS) sustainability and public health protection for persons
served by small PWSs, and to fulfill the commitment in the Fiscal Year (FY) 2010 President's
Budget2 which states:
In conjunction with the dramatic increase in Federal funding for local water
infrastructure needs, the Administration will pursue program reforms that will put
resources for these ongoing needs on a firmer foundation... The 2010 Budget also
proposes to work with State and local governments to address Federal drinking
water policy in order to provide equitable consideration of small system
customers.
In working with these stakeholders and reviewing available data, EPA confirmed that: 1) some
small PWSs (also referred to as small systems) face challenges to providing water in compliance
with drinking water standards; and, 2) there is no single solution to small system challenges, and
therefore, a variety of strategies needs to be employed. The principles and key components of
EPA's Small Systems Approach, incorporating the input EPA received through outreach efforts,
are provided below.
Principles of the Approach
1. Access to safe drinking water should not be based on ability to pay. Every person served
by a PWS should receive safe drinking water.
2. Small systems should be provided a hand-up not a hand-out.
3. A variety of strategies should be employed to address the full spectrum of needs.
4. The long-term sustainability of small systems should be ensured.
5. Better targeted assistance should be provided to those small systems that are most in
need.
2 U.S. EPA. Office of the Chief Financial Officer. Budget Homepage, http://www.epa.gov/budget/.
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Re-Energizing the Capacity Development Program
Key Components of the Approach
1. EPA will work with the state Drinking Water State Revolving Fund (DWSRF) Loan
Fund and the United States Department of Agriculture (USD A) Rural Utilities Service to
strengthen and target financial support to small systems.
2. EPA will support strengthening Capacity Development Programs and tools.
3. EPA will promote partnerships/restructuring of non-sustainable systems.
EPA believes that the Safe Drinking Water Act (SDWA) currently allows for the development
and implementation of many of the tools and programs necessary to assist these systems in
reaching EPA's public health objectives, and to move PWSs down the path toward long-term
sustainability. The robust use of these tools will promote protection of public health while
providing for the equitable consideration of small system customers.
2010 National Capacity Development and Operator Certification
Workshop
In recognition of a need for greater input and involvement nationwide, EPA partnered with the
states to plan the first ever joint National Capacity Development and Operator Certification
Workshop. This workshop was held in September 2010 in Dallas, Texas. The goals of the
workshop were to promote greater cohesion and communication between state programs and
among stakeholders (e.g., states, EPA, and technical assistance [TA] providers), and to discuss
challenges and identify best practices that states can apply to their individual programs. The
workshop was attended by 35 states, EPA Headquarters and Regions, the Rural Community
Assistance Program, the Environmental Finance Centers, the National Rural Water Association,
the American Water Works Association, Small System Technical Assistance Centers, the
Association of State Drinking Water Administrators, and the USDA Rural Development.
Participants at the workshop expressed great interest in moving forward with implementation of
approaches and practices that address the key PWS challenges identified. For this reason, the
participants suggested forming three ongoing workgroups to address the following topics: 1)
challenges with managerial capacity; 2) workforce; and, 3) improving coordination among
drinking water programs. These workgroups, in addition to the Re-Energizing Capacity
Development Workgroup, will assist EPA in implementing the Small Systems Approach and
moving the Capacity Development Program forward.
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Re-Energizing the Capacity Development Program
Clean Water and Drinking Water Infrastructure Sustainability Policy
EPA issued its Clean Water and Drinking Water Infrastructure Sustainability Policy in October
2010 as part of its efforts to promote sustainable infrastructure within the water sector.
Sustainable management of our water infrastructure is one of the most substantial challenges
facing the water sector and is essential to protecting human health and the environment and
realizing the goals of clean and safe water. Communities across the country face challenges with
their water infrastructureoften related to aging systems in need of significant upgrade and
repair. The investments made now in water sector infrastructure can have profound impacts on
long-term community Sustainability. Through the Clean Water and Drinking Water Infrastructure
Sustainability Policy, EPA is helping to ensure that federal investments, policies, and actions
support water infrastructure in efficient and sustainable locations to best aid existing
communities, enhance economic competitiveness, and promote affordable neighborhoods.
The Policy was released in response to a request in the FY 2010 President's Budget. In
developing the Policy, EPA reached out to federal, state, and local officials to obtain input.
These stakeholders provided a number of key insights on water and wastewater infrastructure
Sustainability that EPA took into consideration.
The Clean Water and Drinking Water Infrastructure Sustainability Policy emphasizes the need to
build on existing efforts to promote sustainable water infrastructure, working with states and
PWSs to employ robust, comprehensive planning processes to deliver projects that are cost
effective over their life cycle, resource efficient, and consistent with community Sustainability
goals. The Policy encourages communities to develop sustainable systems that employ effective
management practices to build and maintain the level of technical, managerial, and financial
(TMF) capacity necessary to ensure long-term Sustainability.
This Policy represents a collaborative effort between EPA and its federal, state, and local
partners. Working with these partners, EPA will develop guidance, provide TA, and target
federal-state revolving fund capitalization funds and other relevant federal financial assistance to
increase the Sustainability of our water infrastructure.
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Re-Energizing the Capacity Development Program
Appendix B: Detailed Case Studies
COLORADO WATER QUALITY CONTROL DIVISION:
FACILITY OPERATORS PROGRAM
The Colorado Water Quality Control Division's Water and Wastewater Facility Operators
Certification Board has a Facility Operators Program for the certification of operators for water
treatment plants, water distribution systems, and other water related systems.
While basic operator responsibilities include physical operation of the PWS and chemical dosing, the
Facility Operator Program encourages operators to go above and beyond their basic duties and to
hold themselves to a higher level of professionalism. Colorado recently enhanced the Facility
Operator Program by implementing the Certified Water Professional (CWP) credential. The goal of
this new credential is to establish a higher level of operator qualification and recognize those
individuals who perform above and beyond their basic responsibilities. The CWP credential is
intended to enhance an operator's professional status by encouraging operators to achieve the
highest applicable certification level and to participate in education beyond the minimum required
training units. The designation as a CWP would appear after an operator's name, similar to a
professional engineer (P.E.) designation. The state also wants to use the CWP credential to highlight
individuals who display additional professionalism, ethics, competence, and pride in their system
and community. For example, the state is interested in highlighting individuals who mentor new
operators, visit local schools to promote the water system operator profession, or respond to
emergency situations.
The Facility Operators Program is strengthened through several partnerships. For example, the
Water Quality Control Division (WQCD) works closely with the state's Capacity Development
Program. This collaboration allows the WQCD to better inform water systems and communities of
information related to upcoming trainings. The Capacity Development Program also supports the
WQCD's Facility Operator Program by allocating Local Assistance set-aside funds to support a
coaching program. The coaching program enables certified operators with a high level of knowledge
and experience to assist small systems lacking TMF capacity using a non-enforcement and non-
regulatory approach. ERG funds are also used to reimburse small system operators for renewal
certifications. In addition, the WQCD funds hands-on distribution system training at low or no cost.
These programs and trainings are offered as a direct result of collaboration between the Capacity
Development Program and the Facility Operator Program.
For more information: http://www.cdi3he.state.co.us/oi3/ocb/index.html
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Re-Energizing the Capacity Development Program
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT:
WATER SYSTEM PLAN FOR PROPOSED SYSTEMS
The Indiana Department of Environmental Management (IDEM) has established several new system
requirements, including a water system plan. The goals of these requirements are to help the IDEM
assess TMF capacity of potential PWSs and to ensure that potential owners have an understanding
of the effort it takes to run a PWS and of the quality and quantity of their proposed water source.
Since 1999, Indiana has had 7 or 8 PWSs halt their request for a permit because the prospective
applicant realized that establishing and running a system would be too expensive. The water system
plan and other new system requirements also help expedite the permitting process and limit the
need for enforcement activities by the state since non-viable systems will not receive a permit.
PWSs must submit a water system plan prior to the submission of a construction permit. The plan is
required to have not only descriptions of the technical aspects of the systems but also include
financial information, including details on an infrastructure replacement plan and both a 5 year and
10 year budget. Managerial information required in the water system plan includes information on
the owner and operator, a description of risks and how the PWS would respond to an emergency,
and an assessment of authority and responsibility. The IDEM provides an Information Handbook for
Preparing a Water System Management Plan on their website to ensure that potential owners know
how to create the water system plan and why each component is important to a PWS's capacity.
For more information: http://www.in.gov/idem/4868.htm
KANSAS CAPACITY DEVELOPMENT PROGRAM:
RURAL WATER DISTRICT BOARD AND CITY COUNCIL EDUCATION PROGRAM
The Kansas Capacity, or KanCap, Education Program was developed by the Kansas Capacity
Development Program to train water district board and city council members in rural areas. The
KanCap Education Program utilizes a handbook and an interactive CD. Board or council members
can use these as a learning tool and also as a reference guide once the training course is completed.
As an incentive to increase attendance, Kansas awards additional "points" towards a PWS's ranking
for DWSRF loans if 80 percent or more of the board or council for that PWS attends a training
session. Additionally, PWS operators earn 5 hours of educational credit if the majority of the board
attends. This educational outreach effort has been highly successful, with 112 PWSs (229 people)
participating in the training in state fiscal year 2010.
The Kansas Rural Water Association was contracted to develop training materials and conduct the
trainings. The purpose of the 8-hour training sessions is to provide board and council members with
information they need to make decisions that protect public health, with an emphasis on their
managerial and financial responsibilities. The training program is voluntary and flexible, with a
minimum of 12 training sessions conducted during each state fiscal year. Learning options range
from on-site discussions with TA providers to a self study option. There is no cost for materials if
participants attend either classroom training or engage in on-site discussions; materials for self
study are available for a fee. Available training materials include video clips, interactive quizzes, and
other activities that provide information on maintaining compliance with drinking water regulations.
For more information: http://www.kdheks.Qov/pws/capdev.html
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MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION:
GREEN JOBS TRAINING AND PLACEMENT PARTNERSHIP
To address the challenge of an aging and retiring workforce, the Massachusetts Department of
Environmental Protection (MassDEP) created the Green Jobs Training and Placement Partnership
(GJPP). GJPP is a targeted initiative that aims to identify, attract, and train future water system
professionals by providing them with both classroom and field training. This program focuses on, but
is not limited to, EPA-designated environmental justice (EJ) areas.
MassDEP partners with various groups, including EPA Region 1, drinking water trade associations and
service providers, water systems, vocational technical high schools, adult education programs, and
state and community colleges in order to provide a complete and well-rounded experience to
potential water system operators. These partners assist in providing operator trainings and
internships, examination preparation and review, and career counseling.
GJPP is comprised of four components:
1. Training for students at vocational and technical high schools. MassDEP works with vocational
and technical high schools to expose students to drinking water operations and educate them on
a career as a water system professional. MassDEP and its partners work together to offer
classroom instruction including use of reading/reference materials, guest lecturers, and field trips.
2. Training for adult students through evening adult education classes. MassDEP partners with an
existing adult education program to provide a 15-hour course on operator training for very small
systems. The evening classes attract ready-to-work individuals and introduce them to the water
supply field and the responsibilities of certified operators. Adult education students receive
reference materials, lectures from water supply professionals, networking opportunities, field
trips to drinking water systems, and reimbursements for the Operator Certification exam.
3. Training for students at state and community colleges. MassDEP partners with four community
colleges (all located in EJ areas) to offer an 18-hour classroom training course. The course
provides students with an understanding of professional opportunities in the drinking water field
and helps attract students to existing environmental programs in the colleges' networks. Students
participating in this training are eligible to receive college credit for the course.
4. On-site field trainings (i.e., internships) for all trainees. MassDEP provides interactive field
training experience for students who complete any of the above trainings. MassDEP identifies
operators that will act as mentors for the training program graduates. These mentors agree to
play an active role in the individual's development as a water supply professional and offer
meaningful work that exposes the student to many facets of water system operation. One of
MassDEP's partners identifies PWSsto host interns, processes applications from interested
students, and sets up interviews with prospective PWSs. Interns are reimbursed $10 per hour for
up to 300 hours of work and must submit a project at the conclusion of the internship. MassDEP
funds these internships through EPA Operator Expense Reimbursement Grants.
A total of 240 students (115 in the community college program, 66 in the adult education program,
and 59 in the vocational high school program) participated in the first year of GJPP. At the conclusion
of the first year, more than 12 operator licenses were issued and four students were hired by PWSs.
For more information: http://www.mass.gov/dep/water/drinkina/areenjob.htm
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MAINE DRINKING WATER PROGRAM:
FUNDING MECHANISMS TO ASSIST WATER SYSTEMS IN ACHIEVING IMF CAPACITY
The Maine Drinking Water Program (DWP) assists water systems in achieving IMF capacity by
increasing PWS access to funding mechanisms, including the Public Water System Consolidation
Grants and the Very Small Water System Compliance Loan Fund.
Public Water System Consolidation Grants
The Public Water System Consolidation Grant Program was started in 2008 and provides financial
assistance to PWSs struggling with IMF capacity. The grants are intended to encourage PWSs with
capacity issues to consider consolidation with a neighboring, viable PWS. PWSs are eligible for a
grant of up to $100,000. The grant funds up to 50 percent of consolidation costs for for-profit PWSs
and up to 75 percent of costs for non-profit PWSs. Qualifying costs include, but are not limited to:
planning and design, environmental review, income survey, and construction and abandonment of
sources. Currently, the state allocates $500,000 annually to the Grant Program through the use of
the 15 percent DWSRF Capacity Development set-aside.
To qualify for a Consolidation Grant, the following criteria must be met:
The applying PWS must have a TMF capacity issue that will be addressed by consolidation with
the more viable PWS and applying PWS must report a median household income of less than
$35,178.
The receiving PWS must have sufficient TMF capacity, and the consolidation must not reduce
the receiving PWS's capacity.
Plans and specifications for the consolidation must be reviewed and approved by DWP.
The PWS must complete the environmental review process that is currently part of the DWSRF
construction loan program.
Since 2008, 13 water systems have received Consolidation Grants, totaling $720,000. Overall,
approximately 1,600 customers have been impacted. Due to the popularity of the Program, the
state is planning to implement a ranking process and will use certain criteria to evaluate
applications, including risk to public health, timeframe for completion, and timing of the application
submission.
Very Small Water System Compliance Loan Fund
The Very Small Water System Compliance Loan Fund was created in 2010 to help very small water
systems achieve compliance with new and current standards of the SDWA, excluding the Total
Coliform Rule. The Fund puts aside $500,000 of construction funds for use by very small PWSs,
enabling community water systems (CWSs) serving 100 or fewer customers or any non-profit,
nontransient noncommunity water systems (NTNCWSs) to receive a loan of up to $50,000 to
address compliance issues. The loans are provided at 100 percent principal forgiveness, have no
application period, and overhead costs are rolled into the loan. The state has identified eight
potential projects; seven with arsenic compliance issues and one with a uranium compliance issue.
To date, three water systems have applied for a Very Small System Compliance Loan.
For more information: http://www.maine.ciov/dhhs/enci/water/dwp_services/capdev/capdev.htm
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NEVADA DIVISION OF ENVIRONMENTAL PROTECTION:
NEVADA WATER AND WASTEWATER REVIEW COMMITTEE
The Nevada Water and Wastewater Review Committee (NWWRC) brings together state and federal
funders to assist communities in navigating the application processes of multiple agencies. The
committee includes representatives from the United States Department of Agriculture, the
Community Development Building Group, and the Nevada Division of Environmental Protection
(DEP). These groups collaborate to assist potential PWS loan and grant applicants in determining the
best approach to funding their projects.
The NWWRC also has a particular focus on small, rural communities since these communities often
face difficulties with meeting both the administrative and financial requirements of individual (or in
some cases, multiple) funding agencies. The NWWRC created a pre-application to help communities
begin the funding application process and to provide consistent information to all of the funding
agencies. The NWWRC's committee meets within 3-4 weeks of receiving a pre-application and
provides detailed correspondence to recommend the most appropriate funding for the applicant.
Applicants can then complete the funding applications for individual agencies.
The Nevada DEP has found the creation of the NWWRC to be very beneficial. The NWWRC helps
small communities by identifying funding opportunities and helping to navigate the application
process. The NWWRC has also been beneficial in allowing Nevada's funding agencies to craft
funding packages that combine various loans and grants. Additionally, project applicants know that
the various funding agencies are communicating, which reduces "answer shopping" by applicants.
This also allows the funding agencies to receive consistent explanations of funding proposals
because all agencies have read the basic project information on the pre-application.
For more information: http://ndep.nv.gov/bffwp/nwwpa.htm
NEW HAMPSHIRE CAPACITY DEVELOPMENT PROGRAM:
TECHNICAL ASSISTANCE AND ENFORCEMENT
The New Hampshire Capacity Development Program identifies PWSs in need (i.e., "the bucket list")
based on referrals primarily from enforcement and sanitary survey inspections. This Capacity
Development list is cross-checked quarterly with EPA's Enforcement Targeting Tool (previously the
Significant Non-Complier [SNC] and Historical SNC lists) to ensure outreach has been exhausted for
all higher level enforcement cases as well.
In January 2008, one new outreach position was created and other technical staff members were
assigned outreach duties to shepherd each PWS on the bucket list back to compliance. An active
work log for each PWS is maintained and is accessible internally to all staff of the Drinking Water
and Groundwater Bureau (DWGB) for recording and review of information on outreach activities.
The current status of non-compliant PWSs is discussed at weekly meetings of the Capacity
Development staff, and quarterly meetings with the Bureau Administrator and all technical and
survey staff. When necessary, the Administrator personally attends membership meetings and
conference calls with PWS commissioners or board members to review deficiencies and come to an
agreement on a suitable work plan and timeline for resolution. The work plan log is closed when the
PWS returns to compliance, and a copy of the chronological log is maintained in the PWS file.
For more information: http://des.nh.aov/oraanization/divisions/water/dwgb/capacitv/index.htm
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NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES:
WATER SYSTEM MANAGEMENT PLAN REQUIREMENT
The North Carolina Department of Environment and Natural Resources (DENR) requires a water
system management plan (WSMP) to document that new PWS owners have the ability to finance,
operate, and manage their PWS. A WSMP is a useful tool for any owner, and especially new owners,
and is required by state regulation for all CWSs and NTNCWSs intending to construct, alter, or
expand their PWS. To assess the capacity of new PWSs, the state reviews WSMPs to verify that
PWSs have both managerial and financial capacity. DENR has the authority to review WSMPs at any
time and to require existing PWSs to address any management and ownership issues.
The WSMPs must include details on the managerial and financial capacity of the PWS. The WSMP
specifically discusses: system organization; ownership; management qualifications; management
training; internal PWS policies; monitoring, reporting, and record keeping procedures; and financial
plans. Once construction, alteration, or expansion activities are finalized, the PWS must submit an
engineer's certification that the project has been constructed in accordance with the approved
WSMP and specifications. When DENR encounters difficulty with a PWS, it may review the WSMP
and require that the PWS submit an engineer's report on how it is addressing the problem.
For more information: http://www.deh.enr.state.nc.us/t3ws/Cat3Dev/Cat3DevForms.htm
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY:
SYSTEM RESTRUCTURING
The Texas Commission on Environmental Quality (TCEQ) offers consolidation assessments for PWS
owners who are considering getting out of the water business by consolidating their PWS. In these
circumstances, TCEQ contracts with the Texas Rural Water Association (TRWA) to provide
consolidation assessments. If consolidation is determined to be feasible and recommended, the
TWRA discusses consolidation with the PWS owner and other affected parties and helps to facilitate
the process (e.g., complete paperwork and applications, provide support at public meetings) until
completion. PWSs currently in enforcement proceedings or in the process of being referred to
enforcement for violations are not eligible for assistance without the approval and involvement of
the TCEQ Enforcement Division and Regional Field Operations Office. Projects that will result in PWS
consolidation can receive additional priority points in the state's DWSRF Intended Use Plan.
TCEQ also contracts with the University of Texas to help PWSs with Maximum Contaminant Level
violations understand the issues and related consolidation options (e.g., interconnections,
treatment, relocating a source). Financial impacts are also discussed, so that the PWS understands
the costs per customer for different options. TCEQ funds this high-level technical assistance to small
PWSs using the DWSRF Small Systems Technical Assistance (2%) set-aside.
For more information: http://www.trwa.orci/FMTAssistanceBrochure.pdf and
http://www.beg. utexas.edu/environqlty/TCEQ ss2004-2007.htm
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VIRGINIA OFFICE OF DRINKING WATER:
SOURCE WATER ASSESSMENTS AND SOURCE WATER PROTECTION
Virginia's Office of Drinking Water (ODW) staff work collaboratively with PWSs to help them comply
with regulations by using a programmatic and financial assistance approach. As part of the state's
Capacity Development Strategy, ODW promotes sustainability and encourages PWSs to develop
IMF capacity by utilizing ODWs source water assessments and engaging PWSs in the development
of source water protection (SWP) plans.
In 2003, ODW completed a focused effort to perform Source Water Assessment Reviews on all
active public water supplies. These assessments were designed to reveal PWSs' potential
vulnerabilities to manmade contamination and serve as a tool for water supply resource planning.
ODW continues to perform assessments on new PWSs and to update historical assessments using
field observations made during sanitary surveys.
ODW also has a Source Water Protection Program for small ground water CWSs. This Program
utilizes a contractor to provide technical support to small PWSs. The resulting SWP plans enable
participating PWSs to take steps to safeguard their drinking water sources by managing and
controlling activities in the vicinity of the source that could compromise water quality and quantity.
As of August 2010: 89 CWSs (46% of population, 9% of CWSs) have achieved substantial
implementation of their SWP plans; 255 CWSs (26% of CWSs) have a SWP strategy in place; and, 166
CWSs have completed a SWP plan which addresses one or more aspect of their protection strategy.
Additionally, ODW, in conjunction with the Department of Environmental Quality, solicits proposals
for Wellhead Protection Plan Development from PWSs. This funding source helps PWSs implement
activities in their SWP plans (e.g., installing fencing around wellheads, adding signs, removing
underground storage tanks).
For more information: http://www.vdh.state.va.us/clrinkinQwater/Owners/strateQV.htm
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WASHINGTON STATE DEPARTMENT OF HEALTH, OFFICE OF DRINKING WATER:
THIRD-PARTY TECHNICAL ASSISTANCE AND PLANNING PROGRAM
The State of Washington Department of Health (DOH) collaboratively engages with their TA
providers to provide PWSs with Capacity Development assistance. The state's regional staff
members make referrals to TA providers based on a PWS's needs. This assistance can include board
training, asset management, budgeting, rate setting, loan preparation, and other activities that
improve the PWS's viability. The TA providers complete summary reports of services provided and
consult with the state's contract manager and regional staff to discuss progress, concerns,
remaining technical assistance needs, and how best to address unresolved issues.
DOH also proactively engages with PWSs through their planning program. By regulation, all CWSs
and NCWSs must demonstrate their TMF capacity through a comprehensive planning document.
CWSs that serve 1,000 or more connections or that are expanding in size must receive DOH approval
of their water system plan. These PWSs evaluate and document their operational and management
structure, future capital improvements, budget, current and estimated future demand, and ability to
meet the demand. The remaining PWSs must develop and implement a smaller comprehensive plan
that evaluates system capacity, but does not anticipate future growth. PWSs work with local
planning agencies, emergency responders, officials, and neighboring PWSs throughout their plan
development process. DOH regional planners and engineers use the plan approval process to
oversee PWSs' capacity to serve their current and future customers. Regional staff members also
help small PWSs develop appropriate plans for their future by providing direct technical assistance
and outreach or referrals to TA providers.
For more information: http://www.doh.wa.qov/ehp/clw/Procirams/capacitv.htm
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