UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                                                                     WSG13
                                                                     Date Signed: August 1978
MEMORANDUM

SUBJECT:    Grant Allocation

FROM:       Alan Levin, Director (signed by Alan Levin)
              State Programs Division, ODW (WH-550)

TO:           Regional Water Supply Representatives, I-X
       It has been brought to my attention that there is some question in regard to the definition of a
public water system for use in the grant allocation formula. Specifically, the question is, "If a primacy
State has authority to cover community water systems below 15 service connection or 25 individuals,
can the State include those systems in their inventory for the purpose of receiving additional grant
funds?"

       While it can be argued that the State is providing additional resources to cover smaller systems
and consequently ensuring the delivery of safe water to a larger population, we feel that we must be
consistent in the allocation of the grant funds. Accordingly, only those systems serving 15 service
connections or 25  individuals will be used in the grant allocation irrespective of the State definition.

       This decision is based upon two primary factors:

       (1)    The funds allotted under the Safe Drinking Water Act should be utilized to implement
              the mandates (and limitations) of the Act.

       (2)    Most States assumed that the grant funds would be distributed on the 15/25 basis and
              any change in that implied policy would be disruptive with respect to State coverage,
              laws, and regulation if they attempted to maintain their percentage  share of the national
              authorization.

       In summary, we will continue to only count those community systems serving 15 service
connections or 25  individuals or larger for the purpose of determining the grant allocation.

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