Cross Connection Control – A Holistic Approach
A cross connection can be defined as any actual or potential connection between the public water supply and a source of contamination or pollution. Cross connections with potable piping systems have resulted in numerous cases of illness and even death. Historically, cross connections have been one of the most serious public health threats to a drinking water supply system and many times are present in a residential water system. In order for public water systems to deal with cross connections effectively, not only must laws regarding cross connections be enforced, but customers of those systems must be educated on potential cross connections and how to neutralize those hazards.
Kentucky water utilities are required by state law to determine if or where cross connections exist and to immediately eliminate them. Kentucky RCAP has assisted rural cities with drafting cross connection control prevention program ordinances to protect the health of their water customers. An effective cross connection control prevention program ordinance should include the following:
Purpose and Authority – Clearly state the purpose of the ordinance and the authority to enforce it.
Definitions – Clearly define terms in the ordinance like cross connection, auxiliary water supply, backflow, backflow prevention assembly, contamination, residential, non-residential, etc.
Requirements – Clearly communicate the requirements that the system will implement to protect the public water system against backflow for both residential and non-residential customers.
Inspections – The customer’s water system shall be open to inspection at all reasonable times to authorized representatives to determine whether cross connections or other structural or sanitary hazards exist.
Penalties – Water services to any premises shall be discontinued if it is discovered that a backflow prevention assembly required by this ordinance has been removed, bypassed, or if an unprotected cross connection exists on the premises. Service will not be restored until such conditions or defects are corrected.
As stated earlier, enforcing cross connection laws/ordinances is just part of the equation. Water customer education is paramount for a cross connection control program to be successful. What are some examples of educational materials that can be utilized to inform water customers regarding cross connections in the home? RCAP provides system specific cross connection brochures for water systems to distribute to their customers. An effective cross connection brochure should include the following.
Definition of Terms – Customers need to know what a cross connection is, the concept of backflow, the two types of backflow (backpressure and back siphonage), and corresponding definitions.
What is Considered a Potential Hazard? – Any connection between a customer’s drinking water and another source of water that combines the two when a backflow condition occurs is a potential hazard and can cause contamination. The common household garden hose is a prime example. Customers can unknowingly create a cross connection by:
Putting an attached hose into a full bathtub;
Putting the garden hose in a swimming pool to fill it;
Putting the garden hose down the drain to flush out debris when it is backed up; or
Connecting your garden hose to a plant fertilizer or bug spray unit.
What are the Dangers of Cross Connections? – Backflows due to cross connections can cause sickness and death. If a drop in water pressure occurs, the hose could act as a siphon and backflow contaminants back up into the water supply. This makes the water unsafe for the customer, their family, and their neighbors. In fact, over half of the nation’s cross connections involve unprotected garden hoses.
Tips for Customers to Protect Their Drinking Water
Check all plumbing connections to discover water uses that may pose a hazard to the public water supply.
Never place the end of a hose where it can backflow contaminants into your drinking water.
Leave at least a one-inch air gap between the end of a tap and a source of contamination.
Attach a hose connection vacuum breaker to threaded taps to prevent contaminated water from being siphoned through a hose. Vacuum breakers are relatively inexpensive and can be found at hardware and plumbing supply stores.
In addition to brochures, Kentucky RCAP has created and provided a static “hands-on” cross connection public education display to water systems. The static display contains potential cross connection home hazards (i.e. spigots/hoses, toilet components, cattle feeders, etc.) and the devices that can be used to neutralize those hazards. The static display can be utilized in a public place or in a classroom setting.
With all the challenges that we are facing with the ongoing pandemic, it is quite evident that we are all in this together. Water systems, water customers, and RCAP must continue to work collaboratively to eliminate cross connections to protect public health.
The Story of Jo and a Private Spring in Tempe, Maine
In August 2021, RCAP Solutions received a referral from Maine Center for Disease Control for assistance regarding a confirmed cluster of illness in the rural western Maine town of Temple. Eight people had been hospitalized with intestinal illness associated with drinking water from a private spring, to include Jo, an 80-year old woman whose home has been directly supplied by the spring for over 40 years. At least a dozen other families rely on water from the spring collected at a roadside tap.
Upon meeting with Jo, RCAP learned that a sample collected at her house tested positive for total coliform bacteria, and specifically for E. coli. Jo had been stricken on her 80th birthday and endured eight days of illness. Her stool tested presumptive positive for Campylobacter bacteria.
Jo and her partner had built their home and sanctuary on a quiet dirt road in Temple over 40 years ago. It had always been gravity-fed water by a supply line from the spring on a neighboring property, to which they had deeded access. Jo loved the sweet, clear water, despite the occasional salamander that plopped out of her tap. To her knowledge, the water had never been tested prior to this incident. Now, a single woman, on a fixed income, Jo was concerned about the safety of her home’s water supply – as well as for the safety of other people of the community she knew relied on the spring. She knew there were additional unreported illnesses among the users who were reluctant to come forward, fearing they would lose access to the spring’s roadside tap.
Temple’s Town Clerk joined RCAP and Jo on an inspection of the spring, located up a wooded trail across the road from Jo’s home. The concrete casing spring box set low in a depression, on a sloped grade. Around the spring box, the depression collected rain run-off and other organic debris. The spring box lid was not secure, which allowed contaminated water inflow and the casing did not appear to go deep enough into the ground to prevent surface water seepage infiltration. Looking inside the spring box, one could see the two lines that gravity feed Jo’s home and the roadside tap. Debris floated on the surface of the water, and roots and vegetation had grown in under the cover and penetrated the casing. There was no protection of the water from natural sources of bacteria or harmful organisms. The water was not safe to drink.
THE APPROACH & SOLUTION
RCAP worked with the Maine Drinking Water Program to obtain appropriate signage and the Town Clerk posted the roadside tap, indicating the water was non-potable and should be boiled for at least 5 minutes before consuming. Efforts were underway to locate the elderly out-of-town owner of the property to encourage the removal of the roadside tap.
At Jo’s home, it was strictly bottled water for drinking, and boiling water for other uses, such as dish washing. Jo decided she needed a reliably safe source of drinking water for her home. RCAP discussed with Jo options that included installing filtration and disinfection treatment of the spring water or obtaining a new drinking water source. Jo decided to have a well drilled on her own property. RCAP provided assistance in collecting and evaluating proposals to drill the well and exploring funding opportunities available to Jo to complete its installation and directly supply her house. At the height of summer, following two years of drought and Covid-related shortages, well drillers were in high demand and under significant backlog.
The well was finally drilled November 10, 2021. After the initial flushing and disinfecting by the well driller, RCAP conducted an on-site assessment of the well and collected water quality samples from Jo’s kitchen. The results showed elevated coliform bacteria. The water system would need to be disinfected again, with particular attention to the internal plumbing, which likely had some stubborn contamination after over 40 years of using the spring. After the second disinfection, conducted by a local plumber, the bacteria count was down from 276 colonies to 28 colonies, but the system was still not clean. RCAP noted that the pH of the water was slightly high and was likely interfering with the disinfecting chemical, and recommended an additional disinfection using a pH-buffered product.
It took a village, but on December 20th, RCAP supervised a successful buffered disinfection of the well and plumbing. This effort was made possible due to generous contributions of time and material by a local plumbing firm, a supply company, and a water treatment contractor. After a final confirmation test indicated the water source and system was free of bacteria, Jo was finally able to drink from her kitchen faucet with confidence.
RCAP issued a comprehensive assessment report to Jo, complete with recommended monitoring of the water quality and an initiated well head protection plan.
After over 40 years of drinking from a spring with unreliable water quality, and at least once being severely ill due to it, this 80-year old resident of rural Temple, Maine continues to live independently in her wooded retreat, able to drink from her kitchen tap confident that her water is safe.
At this time, the roadside tap remains “posted”. The owner has not elected to shut it down. RCAP continues to work with Temple town officials, encouraging them to stay diligent in educating and warning residents of the risks of using water from unreliable sources, and suggesting that they consider providing an alternate safe drinking water supply for public use.
RCAP continues to support rural communities and private well owners with training on using and maintaining private water sources, on-site private well and spring assessments and source water testing.
Plan to Maintain, Plan to Sustain
Is your community effectively operating profitable and sustainable water and sewer systems, or are you simply getting by? With our communities’ ever-changing dynamics, our rural drinking water and wastewater systems will need to implement new administrative strategies and management tools to adapt to the increased regulatory requirements and environmental complexities they face daily and into the future. As responsible community leaders, we must allow the systems to operate using a “business model” for long-term sustainability. Sustainability will help address new and stricter regulatory requirements, changing populations, increased service demands, limited water supplies, a highly variable climate, aging infrastructure, and limited state and federal funding.
Cost estimates for water and wastewater system needs in the rural U.S. total billions of dollars nationwide. The existing state and federal funding sources can only meet a fraction of this need, even with the new influx of infrastructure dollars through the Bipartisan Infrastructure Law (BIL). Therefore, approaches to reducing the gap between what is needed and what funds are available will need to be adopted. In addition, funders want assurance their investments in water and wastewater infrastructure will be adequately managed and maintained to ensure long-term sustainability and security. This assurance will require water and wastewater systems to present convincing evidence that they possess adequate financial, technical, and managerial capacity to maintain/sustain the infrastructure necessary to provide the service their customers expect. State and Federal funds only cover the cost of capital outlays, but not ongoing operation and maintenance over time. In addition, the new or upgraded system must remain in full compliance with the Safe Drinking Water Act (SDWA) or the Clean Water Act (CWA), and any additional state or local regulations.
It is recommended that systems adopt a “business model” for managing the delivery of services. This plan should include:
A five-year financial plan with a fully allocated rate structure;
An asset management plan;
A water accounting system with full metering;
Full compliance with the Safe Drinking Water Act (SDWA) or the Clean Water Act (CWA), and your state primacy/regulatory agency requirements ;
A governance structure adequate for proper management and oversight; and
Participation in regional efforts to collaborate on long-term solutions.
A financial plan has two components: a forecast of the utility’s future financial needs (such as operating and capital needs) and an identification of how to fund those future financial needs.
A Capital Improvements Plan (CIP) is a written document that specifies and satisfies the following questions and is typically based on a utility’s asset management program:
What facility improvements will be needed in the future?
When will the improvements be needed, and when will they be undertaken?
How much will the improvements cost?
What financing options are available for the improvements?
A CIP is a multi-year planning document that identifies capital improvement needs and is usually done in 5-, 10- and even 20-year increments. This will help your utility’s board and management make informed decisions about rate setting, future debt-service requirements, and future revenue requirements. In preparing a CIP, there are several things to consider:
Will current facilities reach their design capacity soon?
What new equipment, services, or facilities are needed to meet the demand of your customers?
What current system components will require significant repair, rehabilitation, or replacement?
Will failure to upgrade existing facilities result in regulatory violations or enforcement actions?
What are the most critical improvement needs, and what is the urgency of meeting those needs?
What benefits do the improvements provide to the system and its customers?
What are the available options for financing the improvements?
Can regular resources of the systems fully fund future capital projects, and which projects will require outside financing?
How do financing options for improvements relate to the annual budgeting process?
Use the assistance of a consulting engineer to prepare cost estimates for major capital improvement projects that the community will need in the future.
RCAP and Midwest Assistance Program, Inc. (MAP), RCAP’s regional partner, assists communities by being a resource to help plan, prepare, and execute a comprehensive strategy to sustain your community’s system(s) now and into the future. To be a good steward of your infrastructure, technical, managerial, and financial responsibilities are interconnected – one cannot be sustainable without the other. As a community leader, you need to enable the community to “look around corners” to identify potential expenses and maintenance to their systems and provide a fair and equitable rate structure for the community to “invest” in the future of your most valuable resource.
RCAP’s Managerial and Financial Hub has resources on management, rate setting, applying for infrastructure funds, and regionalization.
A Guidebook of Financial Tools. USEPA, Environmental Finance Program.
The Basics of Financial Management for Small-communities Utilities. RCAP Rural Communities Assistance Partnership.
Small System Guide to Developing and Setting Water Rates, Rural Community Assistance Program, Inc.
Rate Setting and Capacity Development, the Environmental Finance Center at the University of Maryland.
“But My Water Is Fine!” — Lessons Learned in Promoting Well Test Kits to Consumers
Many contaminants that can cause both short-term and long-term health effects have no taste, odor or color. If they are present in well water, a consumer — even one who has been drinking the water for years — would never know it. The only way to find out for sure is to test the well periodically.
And yet, how many times have we heard a well owner say one of the following?
“I’ve been drinking that water my whole life, and I’m not sick.”
“My well water is so much better tasting than town water.”
“There’s nothing wrong with my water; it doesn’t need testing.”
“MY water is FINE!”
To help these consumers continue to enjoy their water safely, Delaware’s Division of Public Health (DPH) has offered a program for several years where well owners can purchase a two-bottle well test kit for $4. This allows them to sample their well water and have it tested by the state’s own lab for the most common contaminants found in the area: bacteria, nitrates, sulfur, manganese and the like.
In 2019, DPH’s Drinking Water State Revolving Fund (DWSRF) program contracted with SERCAP to provide a series of workshops for well owners and to distribute these same test kits for free to all who requested them. SERCAP held seven in-person workshops for well owners in different locations in the two lower Delaware counties. Despite best attempts, the attendance was disappointing overall, with most workshops serving less than six (6) people. SERCAP resolved to alter the program in the second year, using lessons learned from the 2019 efforts.
Part of the original intent of the program was for SERCAP to plot the water test results in order to identify any contaminant plumes. However, a disconnect with the state lab resulted in only the owners receiving the test reports, not SERCAP.
When 2020 came around, so did COVID, and the program was delayed by state-required isolation and SERCAP restrictions on staff contact from March to mid-June. Workshops were switched to a virtual format and attendance improved, with evening sessions being the most popular. Without the need to travel to on-site locations for the workshops, staff time was reduced, and budgeted funds were re-purposed to buy padded envelopes and pay postage to mail out the test kits, along with instructions for proper bacteria sampling.
When Senator Tom Carper visited the SERCAP office in Frankford, he gave the program a tremendous boost because the event was covered by all the local TV stations. This helped spread the message that the free sample kits were available to the public. Between the news broadcasts in late November and the end of the grant in December, SERCAP’s Delaware office handed out 184 well test kits.
The plan for a future grant round is to use the 2019 mailing list to survey recipients on whether they actually used their kits, and to ask if they will share a copy of their results with SERCAP for the purposes of mapping results and identifying potential problem areas.
Well experts recommend testing private wells every year for bacteria and pH, and every year or two for nitrate — especially in agricultural areas or places where nitrogen might be more prevalent. Private labs can charge upwards of $100 for the same array of tests that the Delaware private well kits cover, so the $4 test kits are a bargain any time of the year. Still, advertising that a $4 test was available for free apparently made a big difference in people’s willingness to test their well water.
Not all states have robust, subsidized programs as is the case with Delaware. Because of this, RCAP has developed a national private well program to help educate and serve the more than 23 million well owners across America. The program, funded by the Environmental Protection Agency, provides outreach, education, and technical assistance to well owners, private well professionals and key stakeholders. Because most well owners have no idea what is in their water, in 2020, RCAP added a free well test kit addition to our existing programming based on feedback around homeowner demand. For more information on this program and to find out who to contact for private well support in your state, please check out our private well webpage: https://www.rcap.org/environmental-programs/private-wells/.
Beyond Flint: Updated Lead and Copper Guidance for Public Water Systems
Over the last 50 years, a variety of rules have impacted the amount of lead in drinking water, in addition to monitoring requirements imposed on public water systems (PWS). One might ask, “Why is so much emphasis placed on monitoring and controlling lead levels in drinking water?”
The answer is simple: Lead can negatively affect almost every organ and system in your body. This issue entered into the national spotlight more recently with lead seepage into the drinking water in Flint, Michigan causing a major public health emergency. The Flint water crisis revealed dangerous levels of lead in the drinking water, further propelling the conversations around the dangers of lead. Flint is just one of thousands of communities facing similar challenges.
Lead exposure is especially harmful to young children, pregnant women, and those with compromised immune systems. The Environmental Protection Agency (EPA) has not identified any safe blood lead levels in children, and it can cause impaired mental development, IQ deficits, shorter attention spans, and low birth weights. Lead exposure can also cause increased blood pressure in adults. The degree of harm done to one’s body from lead exposure depends on several factors. A few determining factors to consider are the frequency and dose amount of the exposure, age, and an individual’s susceptibility factors as a whole. Lead is not only found in drinking water, but is also present in the air, dust, soil, and foods we consume, as well as in the paint in homes
The Safe Drinking Water Act (SDWA) of 1974 set a lead maximum contaminant level (MCL) of 50 parts per billion (ppb). In 1986, the Lead Ban amendment took effect, requiring PWS to use “lead-free” pipe, solder, and flux to install or repair any public water supply lines. This Lead Ban included “lead-free” materials in residential homes or commercial facilities connected to a public water supply. Before this ban, solders used for water pipe joints typically contained about 50 percent lead. In 1991, EPA implemented the first Lead and Copper Rule or (LCR) requiring utilities or PWS to monitor for lead contamination in drinking water and to provide corrosion control treatment if lead levels exceed an action level of 15 ppb.
Since 1991, there have been several revisions to the LCR that impose greater responsibilities on utility operators. Why are we talking about this now? Recent actions by the EPA and current administration are accelerating the push to more effectively remove lead from the nation’s drinking water. The reduction of lead levels found in drinking water is at the forefront of the EPA’s current initiative to ensure all Americans receive safe potable drinking water straight from the tap. A Lead and Copper Rule Revision (LCRR) has been in the works for a few years now, changing the roles and responsibilities of utility operators and PWS. On January 15, 2021, the EPA published a regulatory revision to the National Primary Drinking Water Regulation for lead and copper under the authority of the SDWA. A summary of the revision states:
These revised requirements provide greater and more effective protection of public health by reducing exposure to lead and copper in drinking water. The rule will better identify high levels of lead, improve the reliability of lead tap sampling results, strengthen corrosion control treatment requirements, expand consumer awareness and improve risk communication.
For the first time, the summary goes on to state that public water systems will be required to test for lead levels in water at schools and childcare facilities.
Later in January 2021, President Biden issued “Executive Order 13990,” placing a ‘freeze’ on the LCRR published by EPA pending a 60-day review by the Biden Administration. On March 12, 2021, EPA published revisions to the LCRR after the ‘freeze’, which extended the effective date and compliance dates for PWS nationally. If you are not familiar with the Lead and Copper Rule Long-Term Revision, you can find additional information here.
In December 2021, the White House launched the Lead Pipe and Paint Action Plan to deliver clean drinking water through the replacement of lead pipes. The President’s action plan allocates the EPA $15 billion over five years through the Drinking Water State Revolving Funds authorized in the Bipartisan Infrastructure Law for lead service line replacement.
RCAP provides training and technical assistance on these issues. You can reach out to our regional partners for further assistance. If we all work together, we can continue to better protect our youth and community members from the risks of harmful lead exposure!
The Road to Arsenic Free Drinking Water for Arvin, California
If you’ve ever driven through California’s Central Valley, odds are you may have missed a pretty resilient small town tucked away in Kern County. Located just a few miles Southwest of Bakersfield, the town of Arvin, CA has often found itself in the news due to being on the wrong side of a long uphill battle to get into drinking water compliance. Then one day, Arvin Community Services District (CSD) general manager, Raul Barraza, sent out an email to a group of Arvin residents and leaders in early October 2021 to share some big news about the Arvin Arsenic Mitigation Project. Imagine my excitement when I heard that after 13 years, the water in Arvin had finally been deemed safe to drink in accordance with Safe Drinking Water Act Standards!
Raul also asked me to speak at the announcement ceremony event, to which I gladly agreed. But when I got down to writing my speech, I started to reflect on what the Arsenic Mitigation Project has meant to me, not only professionally, but on a personal level as well. I knew I couldn’t simply write down what it meant, so I decided to wing it and go on stage and just speak from the heart. In hindsight, maybe that wasn’t the greatest idea.
For me, the story of Arvin’s arsenic woes goes back way before my time with Rural Community Assistance Corporation (RCAC). My family moved to Arvin way back in 1994, when I was only three-years-old. Back then there was only one traffic light in the whole 13,000 population town! Arvin has since boomed into a three traffic light town with a population of 21,000 people, but it is still very much ignored and lacks many resources. My parents were farm workers that became fairly involved with local grassroots organizations, like the Committee for a Better Arvin, during my middle school and high school years. The big issue back then was a county dump site just a few miles out of town that would emit foul odors that the residents were not thrilled about. We would go to strikes and demonstrations to get the county government to relocate the dump. The effort was a success, and this really started shaping my worldview – to care about environmental justice issues affecting small towns that often go ignored.
Then in 2008, the Environmental Protection Agency (EPA) lowered the threshold of the Arsenic maximum contaminant level (MCL) from 50 to 10 parts per billion (ppb), which made Arvin completely fall out of compliance. There had always been water quality issues so we never drank the tap water, mostly due to taste and turbidity, but the arsenic violations were intermittent as the arsenic levels fluctuated between 30-60ppb. Arvin would only occasionally be out of compliance under the original 50ppb MCL. That was just the way of life out there. We drank out of water bottles or the refillable 5-gallon jugs – never the tap. I just thought that’s the way it was everywhere.
But then I left for college in the Bay Area and everyone out there drank and refilled their reusable bottles straight from the tap. It was a huge culture shock. And I was like, “Wait a minute, we’ve been deliberately told not to do this back home for as long as I can remember! Then again, we don’t have the luxury of having pristine Hetch Hetchy water coming out of our taps.” I also remember my first year at UC Berkeley(Cal), taking an Introduction to Environmental Science course. This course touched on a lot of environmental issues from climate change to eutrophication, to air and water quality depletion all over the country. I also very distinctly remember South Kern County, and specifically Arvin, being presented as a case study during a lecture for bad air quality caused by smog from major transportation and commerce arteries such as I-5 and CA-99 and particulate matter pollution from all the agricultural activity in the Central Valley. That just felt crummy. Here I am in a class with people from all over the world from places like San Francisco, Hong Kong, Singapore, Seoul – you name it! While their cities were lauded as examples of forward thinking and progress, their first exposure to where I’m from was through this case study pointing out how terrible the air quality was there. It felt bad seeing that as our claim to fame. I sunk into my seat that day. But that day also made me want to do something – anything – to help change that perception.
I chose to forego a research job up in Napa and Sonoma County vineyards to look for something in the environmental justice realm closer to home instead. I had trouble finding work back home, even with a bachelor’s degree from Cal, but I was determined to stay and help. Months went by and no luck. I could see why the massive brain drain trend happens in places like the Central Valley. Young people don’t have many options or opportunities, so when they leave for college they tend to leave for good. My first gig ended up being as a warehouse worker at a cold storage facility packing and packaging grapes for export. It took a bit of swallowing my pride, but I ended up having a great time and meeting many inspiring, hard working people there.Arvin CSD’s Project Site for the Arvin Arsenic Mitigation Project
Fortunately, I found out about an open position at the Community Water Center (CWC), a nonprofit dedicated to ensuring all Californianas have access to safe and affordable drinking water. A large portion of my work was organizing, advocacy and Agua4All outreach work. Agua4All is a program The California Endowment started in collaboration with RCAC, CWC and Pueblo Unido Community Development Corporation to increase access to and consumption of safe drinking water in schools and communities through the installation of bottle filling stations, provision of reusable water bottles and interim treatment solutions where necessary. The pilot project launched in Arvin. I worked closely with RCAC during the Agua4All work so I eventually made the jump from CWC to RCAC. I worked with Lee Schegg, Randy Vessels, Dave Wallis, and Sarah Buck to get the Arvin Interim Solutions project off the ground. We ran pilot tests, installed arsenic removal filters and protective cabinets for the first phase of the interim solutions project. We also developed the manual that was used to operate the units up until this year! I eventually took over the data management and quality assurance role and made sure all the lab tests were negative and that the filters were running effectively. All in all, we managed over 170 filters at multiple sites all over Arvin including all of the schools, the parks, health clinics and more for several years. It was a very rewarding position as I got to visit the sites and build an even closer bond with my community. I even had to run around and sample the filters for 1,2,3-TCP. 1,2,3-TCP, at the time, was an unregulated contaminant, an agricultural byproduct that was known to cause cancer and other negative health impacts. The data was used in establishing the 1,2,3-TCP thresholds for the filters used to remove arsenic that had already been installed.I spoke in front of the CA State Water Resource Control Board (SWRCB), CA’s regulatory agency, during the TCP MCL setting process, again citing my work with the Arvin Arsenic Mitigation project. The project has had a huge impact on not only my life, but thousands of people’s lives as well.Arvin CSD’s board members receive their compliance letter from EPA.
But now here we are in 2021, with the EPA Compliance letter in hand. Arvin did it. They got the job done. After years of interim solutions, in the end they succeeded in drilling six new production wells, built a new million-gallon water tank, and brought thousands of feet of new pipelines online, implementing a long term solution to provide safe water to the entire community.
With all this in mind, I headed over to the announcement ceremony on Oct. 12 with some general ideas of what I wanted to say. I was greeted by many big names in the water regulatory world from the federal, state, and local levels. I shared the stage with Joaquin Esquivel (SWRCB Chairman), Deborah Jordan (EPA Regional Administrator), Dee Jaspar (lead engineer for the project), the Arvin CSD Board and their General Manager, representatives from Congressmen Rudy Salas’ and David Valadao’s offices and State Senator Melissa Hurtado herself. They all spoke eloquently about the project, the funding details, the technical ups and downs, and even touched on the interim solutions projects RCAC helped implement.Arvin CSD’s board being recognized by State Senator Melissa Hurtado.
By the time it was my turn to speak, there wasn’t much for me to add on the project itself. So I ended up sharing this story, My Story. And I ended up getting emotional up there on the podium reflecting on all of it,thinking about how my friends and family, many of whom still live in Arvin, no longer need to worry about the water. Being able to help ensure that peace of mind for them felt very, very rewarding. Seeing the local Arvin CSD board members receive accolade upon accolade that night from state and federal leaders also instilled a great sense of pride in my hometown. The evening was a huge success. Raul Barraza and Joaquin Esquivel even came over to have a celebratory dinner at my parent’s place!
I hope that this whole 13-year, $20 million project not only restores the people’s faith in the drinking water, but also restores their faith in the democratic process. The system gets a lot of flak for ineffectiveness. But this small town proved that with a lot of hard-work, patience, and teamwork, good things are still very much possible. It just takes having the right people and attitude in place. This was a unified effort from the bottom up for the community. The community, local water board, state and federal regulators, and numerous technical assistance providers all came together to make it happen.
And who knows, maybe now some intro-level environmental science courses out there will start sharing this Arvin case study instead!
Drinking Water Systems and the Consumer Confidence Report
In America, every state and territory is home to a regulatory agency with oversight and administrative authority over public drinking water systems. These state agencies are held to standards set by the federal government and charged with enforcement through the United States Environmental Protection Agency (EPA).
Consumers see their water purveyors as a trusted authority and rely on their utility companies to provide reliable, affordable services. Unfortunately, utility providers are not always in sync with their customer base. In order to secure their consumer’s confidence, utility providers need to consider the specific needs of their communities, gauge challenges, and incorporate best practices to meet customer satisfaction.
According to the EPA, more than 97% of the nation’s over 148,000 public water systems are small systems, meaning they serve 10,000 or fewer people. A public water system (PWS) is a system that provides potable water for consumption to at least 25 people or 15 service connections for at least 60 days a year. These water systems include municipalities, special districts, homeowner associations, campgrounds , and other kinds of facilities. Access to clean and safe water does not always come easily or affordably. Infrastructure is an expensive investment. Small water systems face unique challenges including the need for economic capital to sustainably provide safe drinking water. This has become evident through a number of high-profile water crisis issues such as Flint, Michigan , and other cases where hydraulic fracking fluid is contaminating drinking water wells.
In order to guarantee that the drinking water being consumed is safe, the EPA developed a tool called the Consumer Confidence Report (CCR) Rule, 63 FR 44511. This report requires mandatory annual reporting to be completed by every public drinking water system and distributed to their customers by the first of July. The CCR also referred to as an annual water quality report, is an integral part of a purveyor’s delivery of information to the consumer.
A CCR will contain water system information including:
contact information for questions regarding the report,
the source of the drinking water,
definitions including perceptible contaminant levels, information on monitoring radon and other contaminants if detected, and
explanations of violations and corrective action steps. Exceptions and variances granted by the EPA will also be detailed.
The CCR Rule normally requires each water system to mail or directly deliver one copy of its CCR to each customer. In addition, the facility must try to reach customers not individually billed, for example, non-metered customers or apartment dwellers. A utility may also publish the CCR in a local newspaper. Much the same as mailing a copy of the CCR, electronic (e-mailed) delivery must furnish the CCR in a manner that bears the effort of being direct. The EPA translates this CCR Rule requirement to mean that water systems may use a billing statement with a prominently displayed banner and a website address (or URL) directed to the CCR, to meet the CCR delivery requirement. The water purveyor must also, annually, provide a contact name and phone number for a customer to request a paper copy of the CCR. For more information regarding the CCR requirements, please refer to the EPA’s website.
Rate Setting – The Small System Challenge
Small water and wastewater utilities face many challenges in structuring user rates that are fair and equitable to the customer and provide sufficient revenue for the utilities’ operations and future needs. Government and quasi-government owned systems are particularly prone to setting rates based on political expediency rather than on the real cost of operation, often subsidizing a utility fund with the general fund, usually tax-derived dollars. Private systems, while not immune to these same pressures, are more apt to have a systematically designed rate structure because they don’t usually have a general fund to tap into and have no choice but to run the utility as a business enterprise.
Utility rates that are not designed to include adequate cost of present service will eventually threaten the system’s ability to sustain itself. Lack of sufficient revenue often prohibits sound management activities that are necessary to the utility’s long-term health and stability. Activities such as planned equipment maintenance or replacement, system improvements that could increase efficiency or treatment quality, and increases in staff compensation to stay competitive in the hiring market are some examples of sound utility management practices. Lack of ability to perform these activities can lead to equipment failure, process failure, treatment standards violations, and lack of continuity of operations due to staff turnover.
Utility rates that are not designed to include adequate costs of future service through sound planning and forecasting can also threaten a system’s ability to sustain itself. If new rate structures are imposed in order to pay for major repairs, it often means that present customers are paying for the cost of serving future customers. Conversely, the present customers may really be paying for the actual cost of having served past customers who were not paying rates sufficient to cover maintenance and/or replacement of the system’s components in the last few decades.
Small utilities, both public and private, seldom have the resources themselves to conduct a full-fledged, cost-of-service rate study. The cost of having an outside consultant perform such a study is usually prohibitive, so that detailed rate studies, if they are done at all by small systems, are only done every few years. Decision-makers are then left to set rates based on whatever they have been for the last several years or on what surrounding communities charge for the same type of service. The problem with both of these methods is that they do not reflect the true cost of providing service, and neither is based on data that is defensible or “saleable” to the consumer. Most people do not want to pay more for anything than they have to, especially not for public water supply. Rate setting procedures that include objective rate analysis methodologies prepare officials and staff to present rate proposals in an understandable fashion that can foster public understanding and improve acceptance of proposed changes.
Many utilities make the mistake of assuming what is budgeted reflects the total cost of operation. This can overlook reserves as a genuine cost of operating the system, since it is not a current year cash expense. Contributions to any reserve fund, whether it be for replacement, debt service, emergencies or capital improvement activities, should be reflected in the rate design. Current users should be covering at least a portion of the costs of the system’s wear and tear that their use is causing, and this cost should be considered in structuring rates.
All governing bodies must perform a balancing act with virtually every decision they make. That is never more evident than in system rate setting. All in all, system decision-makers need to remember that rate increases alone are no substitute for good overall financial management practices. Proper planning, adequate reserves, preventive maintenance, and strategic asset management can go a long way to ensure that a utility is sustainable over time. Costs of operation must be offset by adequate, equitable user fees that, along with non-rate revenue, fully recover the costs of operating the system now and in the future. RCAP TAPs in each region can perform this analysis and can help a governing body or board explain and defend their proposed rate structure to their utility customers and to the taxpaying public.
Exploring Water, Health Infrastructure, Resilience and Learning (WHIRL)
Editor’s note: McElmurry is a contributing author for Drop of Knowledge and leader of a collaborative research project exploring the intersection of drinking water and public health. RCAP is working with the researchers on this project to provide the rural perspective. RCAP has provided feedback on the researchers’ survey instrument.
Water systems and public health systems grew up together and are interdependent in complex, and not always clearly, visible ways. A research program, Water, Health Infrastructure Resilience and Learning (WHIRL) funded by the National Science Foundation is exploring these interdependencies and will soon be distributing a survey to both water and public health professionals.
In 1914, the United States Public Health Service (PHS) adopted the first drinking water guidelines targeting microbial (coliform bacteria) and chemical (arsenic) contaminants (US Treasury, 1914). This led to the advent of centralized municipal drinking water systems that are credited with reducing nearly half of the total mortality, and three-quarters of the infant mortality, in major U.S. cities during the first half of the twentieth century (Cutler & Miller, 2005). In the 100+ years since the development of drinking water guidelines, these interdependent systems have developed through separate federal regulatory agencies (i.e., Environmental Protection Agency, Department of Health and Human Services), management frameworks, and even different professional and educational disciplines. As a result, many drinking water and public health systems are now highly disconnected (Levitt & March, 1988).
Disconnects between water and health systems are confounded by practices put in place after September 11, 2001. Many post 9/11 practices were designed to isolate water systems and restrict the flow of information, with the goal of protecting systems and facilities from potential terrorist attacks. However, these restrictions had the unintended consequence of making it more difficult to share information with key stakeholders, such as public health officials and the public. This may have contributed to a public that is largely not engaged, unaware and uninformed about how drinking water systems work and the importance of investing in their upkeep (Bipartisan Policy Center, 2017).
Both highly visible / public and “under the radar” events emphasize the growing need for a stronger connection between public health and drinking water. Day-to-day events (e.g., faulty, aging infrastructure that affects water quality) and disruptive weather (e.g., hurricanes, floods and droughts) that can lead to infectious disease outbreaks or human-induced disasters (e.g., chemical spills, contamination) are failures that can shut down drinking water services and have substantial adverse impacts on public health. Risks, hazards, and disruptions, even minor events that often go unnoticed, may illuminate interdependencies between drinking water and public health systems. If these interdependencies are critical, identifying these connections and strengthening them may enhance resilience.This is particularly true during periods immediately following events, when there are opportunities to learn, change and enhance system resilience (Sitkin, 1992; Turner 1976; May, 1992; Birkland, 2004).
In 2018, the National Science Foundation (NSF) funded a 4-year study to examine how drinking water and public health systems interact, with a focus on reducing risks of future disasters and enhancing the resilience of these two critical infrastructure systems. The project, entitled Water and Health Infrastructure Resilience and Learning (WHIRL), also aims to understand how these systems learn about and adapt to changes and how the public engages with these systems. The research is a collaboration between academics from Wayne State University, the University of Michigan, and Indiana University and the American Water Works Association, the Water Research Foundation, the Association of State Drinking Water Administrators, the Rural Community Assistance Partnership (RCAP), and the National Association of County and City Health Officials.
In collaboration with these partners, the WHIRL team has developed a survey questionnaire that will be distributed to water and health professionals over the coming weeks to collect information about how water systems and public health systems interact, both formally and informally. The survey includes questions about information exchange, communication, routine and non-routine interactions and the ways these groups learn from crises and disasters among other issues. The goal is to generate understanding about how drinking water-related hazards and disruptions unfold in ways that affect both drinking water and public health systems that can help in the construction of tools to detect undesirable events. In addition, the project will create new capacity to learn from the disruptions that will inevitably occur.
The WHIRL survey is available here. Broad participation from the water community is necessary to insure representative and reliable results. Summaries of results from this survey will be reported at conferences and in future editions of the Drop of Knowledge.
Bipartisan Policy Center (2017). Defeating Terrorists, Not Terrorism: Assessing U.S. Counterterrorism Policy from 9/11 to ISIS. Task force on terrorism and Ideology. Washington, D.C., Bipartisan Policy Center.
Birkland, T. A. (2004). Learning and policy improvement after disaster: The case of aviation security. American Behavioral Scientist, 48(3), 341-364.
Cutler, D., & Miller, G. (2005). The role of public health improvements in health advances: The twentieth-century United States. Demography, 42(1), 1-22. doi: 10.1353/dem.2005.0002
Levitt, B., & March, J. G. (1988). Organizational learning. Annual Review of Sociology, 14(1), 319-338.
Sitkin, S. B. (1992). Learning through failure: The strategy of small losses. Research in Organizational Behavior, 14, 231-266.
Turner, B. A. (1976). The organizational and inter-organizational development of disasters. Administrative Science Quarterly, 21(3), 378-397.
U.S. Treasury Department. (1914).
The bacteriological standard for drinking water. Public Health Rep. 29:2959-2966.