OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Evaluation Report 

Much Effort and Resources 

Needed to Help 

Small Drinking Water Systems 

Overcome Challenges 

 Report No. 2006-P-00026 

 May 30, 2006 
Report Contributors: Ira Brass 

 Anthony Chirigotis 

 Dan Engelberg 

 Frank Pelczarski 

Abbreviations 

CDC Centers for Disease Control and Prevention 

DWSRF Drinking Water State Revolving Fund 

EPA U.S. Environmental Protection Agency 

OGWDW Office of Ground Water and Drinking Water 

OIG Office of Inspector General 

RCAP Rural Community Assistance Partnership 

RWA Rural Water Association 

SDWA Safe Drinking Water Act 

Cover photo: A girl drinking glass of water from sink (United States Geological Survey photo) 
U.S. Environmental Protection Agency 2006-P-00026

Office of Inspector General May 30, 2006

At a Glance


Catalyst for Improving the Environment 

Why We Did This Review 

We conducted this review to 

examine the challenges faced 

by small drinking water 

systems in providing water 

that is safe to drink and the 

adequacy of U.S. 

Environmental Protection 

Agency (EPA) and State 

initiatives for addressing those

challenges. 

Background 

EPA classifies public water 

systems according to the 

number of people they serve, 

the source of the water, and 

whether they serve the same 

customers year-round or on an 

occasional basis. There are 

approximately 54,000 

community water systems of 

which 85 percent are small 

(501 to 3,300 people) or very 

small (25 to 500 people), 

serving 10 percent of this 

Nation’s population. 

For further information, 

contact our Office of 

Congressional and Public 

Liaison at (202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2006/ 

20060530-2006-P-00026.pdf 

Much Effort and Resources Needed to Help 

Small Drinking Water Systems Overcome Challenges

 What We Found 

The critical issues facing small drinking systems have not changed in recent years. 

Our preliminary research suggests that they have faced and still face a multitude of 

challenges that fall into two basic categories: financial/management matters and 

regulatory/compliance issues. 

Government and nongovernment organizations have attempted many different 

initiatives and approaches to assist small drinking water systems in overcoming 

their challenges. We noted several State and third party initiatives that could be 

used for best practices. While it is difficult to measure the effectiveness of 

individual EPA and State activities to assist small drinking water systems, our 

preliminary research provided indicators of success as well as limitations of these 

approaches. 

Limited data exist on the health impacts related to small drinking water systems. 

The Centers for Disease Control and Prevention maintains the data system on 

drinking water cases, but states that the information is vastly underreported. That 

is not to say that the potential for health impacts is not something to be taken 

seriously. Some data show health outbreaks related to small drinking water 

systems. 

What We Recommend 

We recommend that EPA work with States to identify successful approaches for 

working with small systems to obtain financing. We also recommend the Agency 

work closer with States to identify and compile small system best practices and 

establish a method for disseminating the information, to maximize limited 

resources to assist small systems. Our recommendations in this report, while 

necessary, will not in themselves solve small system problems in their entirety. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

May 30, 2006 

SUBJECT: Much Effort and Resources Needed to Help Small Drinking Water 

 Systems Overcome Challenges 

Report No. 2006-P-00026 

TO: Benjamin Grumbles 

 Assistant Administrator for Water 

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) 

of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe 

problems the OIG has identified and corrective actions the OIG recommends. This report 

represents the opinion of the OIG and does not necessarily represent the final EPA position. 

Final determinations on matters in this report will be made by EPA managers in accordance with 

established resolution procedures. 

On March 14, 2006, the OIG issued a draft report to EPA for review and comment. A response 

was submitted on April 20, 2006, and an exit conference was held on May 8, 2006. EPA agreed 

that many small water systems lack adequate technical, managerial, and financial capacity to 

operate in a sustainable manner and stated that its efforts have brought about improvements. 

EPA generally concurred with our recommendations, but suggested some changes to recognize 

activities that are underway. EPA also requested the deletion of one recommendation on 

regulatory approach because EPA has attempted to reduce the burden of regulations on small 

systems by providing flexibility. The OIG has incorporated these comments, as well as technical 

corrections and supplemental information provided by EPA, into the final report. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 90 calendar days. You should include a corrective actions plan for agreed upon 

actions, including milestone dates. We have no objections to the further release of this report to 

the public. This report will be available at http://www.epa.gov/oig. If you or your staff have any 

questions, please contact me at (202) 566-0847 or Dan Engelberg at (202) 566-0830. 

Sincerely, 

Bill A. Roderick 

Acting Inspector General 
Table of Contents 

At a Glance 

Chapters 

1 Introduction ........................................................................................................... 1 

Purpose .......................................................................................................... 1 

Background .................................................................................................... 1 

Scope and Methodology................................................................................. 2 

2 Small Systems Face Many Challenges ............................................................... 4 

Financial/Management Challenges ............................................................... 4 

 Regulatory/Compliance Challenges .............................................................. 10 

Conclusion...................................................................................................... 12 

 Recommendation ........................................................................................... 13 

Agency Comment and OIG Evaluation .......................................................... 13 

3 Many Approaches Undertaken to Assist Small Systems .................................. 15 

EPA Headquarters Pursues Several Approaches ......................................... 15 

EPA Regional Initiatives Address System Concerns...................................... 16 

States Take Various Approaches................................................................... 17 

Third-Party Organization Assistance a Key Piece.......................................... 19 

Conclusion...................................................................................................... 21 

 Recommendation ........................................................................................... 21 

Agency Comment and OIG Evaluation .......................................................... 21 

4 Small System Approaches Have Shown Mixed Results.................................... 23 

Smaller Systems Have Greater Noncompliance ........................................... 23 

Systems Report EPA Guidance Is Difficult to Understand ............................. 25 

Variances and Exemptions Appear Rarely Used ........................................... 25 

Regional Initiatives Have Had Mixed Results................................................. 25 

Consolidation Has Pros and Cons ................................................................ 26 

State Resource Shortages Hamper Assistance ............................................. 27 

Kansas Loan Program Is Productive.............................................................. 27 

Third-Party Organizations Seen as Beneficial to Small Systems................... 28 

One Small System Overcomes Challenges Through Own Efforts ................. 29 

Conclusion...................................................................................................... 30 

 Recommendation ........................................................................................... 30 

Agency Comment and OIG Evaluation .......................................................... 30 
5 Minimal Data on Health-Related Impacts ............................................................ 32 

Drinking Water Outbreak Data Underreported ............................................... 32 

Health Effects May Be Small-System Related ............................................... 33 

Public Health More at Risk in Small Systems................................................. 34 

Conclusion...................................................................................................... 35 

 Recommendation ........................................................................................... 36 

Agency Comment and OIG Evaluation .......................................................... 36 

Appendices 

A Organizations Visited During Preliminary Research ......................................... 37 

B Benefits and Barriers to Consolidation............................................................... 38 

C Agency Response ................................................................................................ 40 

D Distribution ........................................................................................................... 55 
Chapter 1

Introduction 

Purpose 

The EPA Strategic Plan stated that small community water systems are more likely 

than others to have difficulty complying with drinking water standards. We 

conducted preliminary research to examine the challenges faced by small drinking 

water systems in providing water that is safe to drink and the adequacy of EPA and 

State initiatives for addressing those challenges. More specifically, we directed our 

work toward the following questions: 

1. What challenges do small drinking systems face to assure that drinking water 

meets current and future Safe Drinking Water Act (SDWA) requirements? 

2. What approaches are EPA, States, and drinking water systems using to 

overcome these challenges? 

3. How effective are EPA and the States in assisting small drinking water 

systems to meet drinking water requirements? 

4. What is the impact of these efforts on the health of consumers of drinking 

water from small systems? 

Background 

EPA classifies public water systems according to the number of people they 

serve, the source of the water, and whether they serve the same customers yearround or occasionally. Public water systems provide water for human 

consumption through pipes or other constructed conveyances to at least 15 service 

connections or serve an average of at least 25 people for at least 60 days a year. 

EPA has defined three types of public water systems: 

Table 1.1: Types of Public Water Systems 

Type Description 

Community Water System Supplies water to the same population year-round. 

Non-Transient Non-Community 

Water System 

Regularly supplies water to at least 25 of the same 

people at least 6 months per year, but not yearround. Some examples are schools, factories, 

office buildings, and hospitals that have their own 

water systems. 

Transient Non-Community Water 

System 

Provides water in a place such as a gas station or 

campground where people do not remain for long 

periods. 

1
EPA also classifies water systems according to the number of people they serve: 

Table 1.2: Number of People Served by Public Water Systems 

Size of System Number of People Served 

Very small 25-500 

Small 501-3,300 

Medium 3,301-10,000 

Large 10,001-100,000 

Very large 100,001+ 

SDWA was passed by Congress to protect public health by regulating the nation’s 

public drinking water supply. SDWA authorized EPA to set national health-based 

standards for drinking water to protect against both naturally-occurring and manmade contaminants. EPA, States, and water systems then work together to make 

sure that these standards are met. 

Approximately 54,000 community water systems exist, of which 85 percent are 

small or very small, serving 10 percent of the population. 

Scope and Methodology 

We performed our evaluation in accordance with Government Auditing 

Standards, issued by the Comptroller General of the United States. We conducted 

our preliminary research from June 2005 through December 2005. Preliminary 

research is a fact-finding process to obtain operational, performance, financial, 

and other program information. Therefore, a preliminary research report (like this 

one) is not as complete or thorough as a field work one. To gain a broad 

perspective of small drinking water issues, we reviewed various agency, trade, 

industry, and academic journals, reports, and Web sites and attended the 

Association of State Drinking Water Administrators national conference. We also 

interviewed staff at EPA’s Office of Ground Water and Drinking Water 

(OGWDW) and Regions 1 and 7; State environmental and health offices in 

Maine, Massachusetts, and Kansas; 9 third party assistance organizations; and 

19 small community drinking water systems (see Appendix A). To obtain 

additional insight on our health objective, we interviewed a member of the 

National Drinking Water Advisory Council. 

We selected the States based on several factors, including (1) difference of 

approaches, (2) geographic diversity, (3) number of third party organizations, and 

(4) number and proportion of small systems. We avoided selecting States that had 

been recently visited during other Office of Inspector General drinking water 

assignments. We also avoided selecting States that were in the midst of dealing 

with hurricane-related concerns. To aid in our decision making, we sought the 

2
advice of OGWDW for State selection, and States and third party organizations 

for small system selections, because of their greater familiarity with the program. 

Our study was limited to community water systems; the majority of systems 

visited were very small ones, since they probably faced the greatest challenges. 

Although our conclusions are drawn from commonalities among participants, this 

study did not employ a statistical sampling approach. 

The OIG has not performed any previous work specifically on the small drinking 

water systems. However, the following recent reports have detailed some issues 

related to small systems: 

 Progress Report on Drinking Water Protection Efforts (2005-P-00021), 

August 22, 2005 

 Source Water Assessment and Protection Programs Show Initial Promise, 

But Obstacles Remain (2005-P-00013), March 28, 2005 

3
Chapter 2

Small Systems Face Many Challenges 

Small drinking water systems have faced and still face a multitude of challenges.1 

Our preliminary research suggests that these challenges basically fall into two 

categories: financial/management matters and regulatory/compliance issues, 

though the two categories are interrelated. EPA officials have noted that the 

critical issues facing small systems have not changed much over the past 20 years. 

Our preliminary research work through literature reviews and discussions with 

officials at all the levels corroborated that observation. 

Financial/Management Challenges 

Small drinking water systems face many challenges that fall under this category 

including lack of financial resources, insufficient revenue, aging infrastructure, 

difficulties obtaining financial assistance, cost of scale, management limitations, 

lack of long-term planning, and system operator issues. These affect the 

regulatory/compliance challenges to be discussed (see page 10). Almost half 

(9 of 19, or 47 percent) of the small systems visited mentioned financial issues as 

a challenge. 

Lack of Financial Resources 

A 1997 report by the National Academy of Sciences stated, "Small communities 

face the greatest difficulty in supplying water of adequate quality and quantity 

because they have small customer bases and therefore often lack the revenues 

needed to hire experienced managers and to maintain and upgrade their water 

supply facilities.”2

 This limited financial capacity was echoed by groups such as 

the National Drinking Water Advisory Council, the National Regulatory Research 

Institute, the National Rural Water Association, and the Universities Council on 

Water Resources. 

The lack of financial resources was brought up at each level of our site visits. For 

example, OGWDW staff members pointed out parts of the country have 

1 Congress tried to address some of these challenges with the SDWA Amendments of 1996. The Amendments 

contained provisions to help States and water systems (including small ones) improve public health protection, 

including (1) assessing water sources, (2) certifying system operators, (3) improving the technical, managerial, and 

financial capacity of water systems, (4) providing funding for infrastructure improvements, (5) providing funding to 

States, and (6) keeping the public informed. An August 2005 OIG report (Progress Report on Drinking Water 

Protection Efforts, 2005-P-0021, August 22, 2005) discussed some of the progress made as a result of the 

Amendments. 2

 National Academy of Sciences, Committee on Small Water Supply Systems, Water Science and Technology 

Board, Commission on Geosciences, Environment, and Resources, National Resource Council, Safe Water From 

Every Tap – Improving Water Services to Small Communities. 

4
communities that are losing population; this loss reduces the fee or rate base of 

the utility. The Chief, Drinking Water Management Branch, Region 7, stated that 

financial capabilities top the list of small drinking water system challenges. She 

further noted that no revenue base for small systems exists. State of Maine 

officials cited a lack of money to install treatment systems as an issue facing small 

systems. The Massachusetts Rural Community Assistance Partnership (RCAP) 

indicated that many systems lack adequate capacity and do not have the funding. 

The Massachusetts Water Works Association said it was more difficult for small 

systems to address issues when more money is needed and financial assistance is 

unavailable. Eight of the 19 systems we visited mentioned a need for funding to 

address problems. A Massachusetts water district superintendent stated that his 

greatest concern was money for plant operations and debt payment. The customer 

base had diminished with large industry moving away. All five Kansas systems 

visited were poor communities with very poor financial bases. 

Insufficient Revenue 

One factor contributing to the strain of financial resources is receiving adequate 

revenue from users. The need to increase water rates can be affected by political 

concerns and weak financial bases. In May 2004, a group of international experts 

meeting on small water systems reported3 balancing system needs with costs as a 

challenge faced by system managers. The experts indicated that board members 

and elected officials may be reluctant to raise rates, or have conflicting priorities 

when it came to distributing funds. Articles in National Rural Water Association 

and University of Council of Water Resources publications have highlighted 

avoidance or infrequent rate increases as difficulties faced by water managers. 

One author stated that many systems have never analyzed their rates and almost 

none do it annually. He further stated that elected boards tend to believe their role 

is to keep rates low. 

An article4

 by an Environmental Finance Center official stated that another factor 

contributing to the problem of sustaining financial capacity is customer perception 

of the cost of service. Even if water is under-priced, customers will react to any 

increase in charges or costs regardless of their legitimacy. Customers react with 

“sticker shock” to rapid or significant price increases necessary to compensate for 

delays in system improvements or failures to properly reserve resources for future 

capital improvements. 

Our visits and interviews found examples of rate increase resistance. Maine 

RCAP officials spoke of very small systems being leery of rate increases. Also, 

5 of the 19 small systems visited discussed the difficulty of getting a rate increase 

as a problem. A Massachusetts water system had not had a rate increase in 

3

 Tim Ford, Gretchen Rupp, Phillip Butterfield, and Anne Camper, compilers, Protecting Public Health in Small 

Water Systems, Report of International Colloquium, January 2005. 4

 William Jarocki, Funding the Future: Meeting the Costs of Capital Replacement, Journal of Contemporary Water,

pp. 21-26.

5
approximately 15 years because town approval was not likely. A Kansas system 

pointed to a majority of the town’s population being elderly or below the poverty 

level as the reason for low rate increases. 

Aging Infrastructure 

One of the biggest costs facing drinking water systems is maintaining and 

replacing infrastructure. The most recent report to Congress on drinking water 

infrastructure needs5

 (June 2005) shows that small system needs are estimated at 

$34.2 billion. Aging infrastructure needs to be replaced to assure water quality 

and compliance with drinking water regulations. 

The challenge of aging infrastructure has been addressed by many reports and 

publications. A 2000 Midwest Technology Assistance Center study on economic 

and managerial capacity for small systems

6

 found that the main topic for most 

small systems was a need to replace antiquated and inadequate infrastructure. 

Over a 5- year period of financial capacity reviews, the Environmental Finance 

Center at Boise State University7 found that 78 percent of Idaho systems 

presented no evidence that future infrastructure needs had been identified 

Third-party organizations we visited described infrastructure concerns. 

According to the Executive Director of the Maine Rural Water Association 

(RWA), water systems are reaching their natural life expectancy of 50 to 80 years 

and fewer dollars and grant monies are available for infrastructure than in prior 

years. The Executive Director of the Massachusetts Water Works Association 

stated that small systems have a continuing larger infrastructure need while 

operating day-to-day. Small systems, she said, will have to wait until new 

requirements are in place before they can consider any infrastructure 

improvements, since they do not want to chance spending money on proposals 

that may not occur. 

Seven of the small systems we visited mentioned aging infrastructure as a 

challenge. A Massachusetts water district indicated that as water leaks occur, 

replacement work is done. No money exists for capital improvements. One 

Maine system described needing $1.5 million to make its water system safe from 

a potentially dangerous health hazard, as its system infrastructure has water lines 

directly below septic systems. Several of the Kansas systems have been unable to 

comply with recently enacted drinking water regulations and cannot afford the 

necessary system upgrades to bring them into compliance. 

5

 U.S. Environmental Protection Agency, Drinking Water Infrastructure Needs Survey and Assessment, Third 

Report to Congress, EPA-816-R-05-001, June 2005. 6

 Jarocki, pp. 21-26. 7

 Ibid. 

6
Difficulties Obtaining Financial Assistance 

Small water systems found it more difficult to obtain necessary funding to address 

financial needs. Both the 2000 National Drinking Water Advisory Council 

report8 and an article in the 2004 Universities Council on Water Resources 

Journal9 identify the availability and affordability of financing as a small system 

challenge. 

Both regions we interviewed indicated that the ability of small systems to obtain 

loans, especially from the Drinking Water State Revolving Fund (DWSRF), is an 

impediment. States and third parties also raised concern. Massachusetts officials 

stated that there is a lot of paper work for systems to apply for loans. Generally, 

if an amount is less than $100,000 it is not cost-efficient for a small system to 

complete a DWSRF loan application. Massachusetts RCAP stated that less 

DWSRF funding was going to communities and small systems have little capacity 

to obtain funds. The Massachusetts Water Works Association said that the 

DWSRF loan application process for small systems is both cumbersome and 

costly. In some cases, it is cost-prohibitive for the amount of loan money sought. 

Only 1 of the 19 small systems we visited received a loan/grant from the DWSRF. 

Four systems obtained loans from the U.S. Department of Agriculture and one got 

a commercial loan (EPA is only one of several Federal agencies that provides 

funding for drinking water needs). Maine mobile home park owners had to sell 

some of their other properties to cover $50,000 in drinking water related costs. 

Only a few of the visited systems commented on the DWSRF process. Three 

systems indicated they did not qualify or were rejected, while one system said it 

stayed away from government loans and would rather pay cash. 

Cost of Scale 

It is more difficult for small systems to spread costs among their customers to 

operate and maintain their systems. The 2001 drinking water needs report to 

Congress10 stated that project costs for small systems are modest to larger ones; 

however, costs per household are significantly higher than those associated with 

the larger systems. This disparity results in many of the challenges we discuss. 

Several 2004 Universities Council of Water Resources articles address this topic. 

One states11 that economies of size are significant in water system operation and 

have a profound effect on system management. These smallest systems are at a 

8

 U.S. Environmental Protection Agency, Report of the National Drinking Water Advisory Council Small Systems

Implementation Work Group, EPA-816-R-00-012, April 2000. 9

 Universities Council on Water Resources, Journal of Contemporary Water Research & Education, Issue 128, June 

2004. 10 U.S. Environmental Protection Agency, Drinking Water Infrastructure Needs Survey and Assessment, Second 

Report to Congress, EPA-816-R-01-004, February 2001. 11 Ben Dziegielewski and Tom Bik, Technical Assistance Needs and Research Priorities for Small Community 

Water Systems, Journal of Contemporary Water, pp. 13-20.

7
distinct economic disadvantage. A second states12 that small systems, lacking 

economies of scale, are frequently poorly funded. They commonly operate at a 

loss on an operating cost basis. A third states13 that a distinction is made with 

very small systems since they are the systems most likely to be lacking technical, 

financial, and management capacity. An economy of scale exists for the number 

of users that water systems must have to be sustainable and very small systems 

typically fall below it. Both the Massachusetts Department of Environmental 

Protection and Massachusetts RCAP specifically brought up the challenge of 

economy of scale. 

Management Limitations 

Managerial capacity has been recognized for some time as a key component to 

successful operation. Small systems are acutely affected because their 

management many times is in the hands of a few individuals for whom a drinking 

water operation is not their sole occupation. 

Many reports and articles have addressed this theme. Two University of Illinois 

authors writing about the importance of water system management stated14 that 

many small communities are hard-pressed to evaluate needed improvements, raise 

funds, and manage the more sophisticated systems required to meet new drinking 

water standards. Most have part-time officials and few staff members to plan, 

oversee, and manage infrastructure improvements. The 2000 Midwest 

Technology Assistance Center study noted that poor water system management 

often reflected poor community management. 

The Region 7 Drinking Water Management Branch Chief said that two of the 

most difficult challenges facing small systems were the stability of a water system 

to maintain staff members that have the technical knowledge, and the ability and 

know-how to manage on a day-to-day basis. 

The third-party organizations we visited identified poor management as a 

concern. For example, according to Massachusetts RCAP, many systems lack 

adequate capacity and do not have the leadership. Maine RCAP stated that the 

overall strength or weakness of a system lies in its water boards and the overall 

strength is lacking. Massachusetts RWA discussed the absence of management at 

small systems. The Executive Director of the Massachusetts Water Works 

Association talked about the constant change of small system ownership, which 

negatively impacts implementing rules. 

12 Carl E. Brown, Making Small Water Systems Strong, Journal of Contemporary Water, pp. 27-30. 13 Jim Maras, Economic and Financial Capacity of Small Water Systems, Journal of Contemporary Water,

pp. 31-34. 14 John B. Braden and Philip C. Mankin, Ecnomic and Financial Management of Small Water Systems: Issue 

Introduction, Journal of Contemporary Water, pp. 1-5. 

8
Obviously, the systems we visited did not identify poor management as a current 

concern because it might reflect on them. However, we were told several times 

that people did not have enough time to understand the regulations or complete 

necessary paperwork. One Massachusetts system discussed the neglect of the 

previous water board that had mired the system in noncompliance issues. One 

operator described the water system’s commissioners as “not too smart” and not 

taking advantage of any provided training. We heard of system managers who 

were only part-timers (e.g., school bus driver, volunteer) or had until recently 

performed other professions (e.g., nursing technician). 

Lack of Long-Term Planning 

One aspect of poor management that carries over to some of the other challenges 

is planning deficiencies. The challenge of long-term planning was cited in 

National Drinking Water Advisory Council, International Colloquium, and the 

Universities Council on Water Resources articles and reports. One third-party 

organization commented on this topic. Maine RCAP stated that water systems do 

no planning and do not look to the future. 

Most systems visited did not discuss long-term planning, since they were mainly 

focused on current issues. For example, four of the systems were not even aware 

of how new pending regulations might affect them. However, one Massachusetts 

water district indicated that a challenge for the future will be infrastructure needs 

and no planning has occurred for future work. 

System Operator Issues 

Water system operators are key players in assuring the safe drinking water is 

provided to the public. While the challenges discussed so far reflect managerial 

and financial capacity concerns, operator issues reflect water system technical 

capacity concerns. Many challenges involve or face operators, which reflect the 

microcosm of challenges that confront small systems (financial/management, 

regulatory/compliance). 

The January 2005 International Colloquium report15 listed many of the specific 

challenges faced by small system operators: 

 Multiplicity of regulations, which can be confusing. Not always obvious 

to operator responsible for compliance why regulations exist or whether 

they apply to all systems. 

 Older operators may have difficulty understanding new technologies 

(insufficient training opportunities, poor reading skills). 

 When older operators retire, there is limited ability or opportunity to pass 

on historical operation knowledge to new operators. 

 Part-time or volunteer operators. 

15 Tim Ford et al. 

9
 Lack of available training, or few incentives to take training. 

 Inability to attend training because of lack of backup operators. 

 Shortage of new people to replace retiring operators (exacerbated by poor 

pay and low status of job). 

 Operators may not have influence to take protective health measures that 

are in conflict with other financial demands on system or community. 

The entities we visited discussed many of these same issues. Maine officials 

emphasized the high turnover rate of water system operators; very small system 

operators do not have the time to keep current with additional training. The New 

England Interstate Water Pollution Control Commission, Maine RCAP, Maine 

RWA, and Massachusetts RWA noted that keeping qualified system operators 

was a problem. Massachusetts RWA officials further stated the technology 

required of operators was “too large” for them. The New England Interstate 

Water Pollution Control Commission and Massachusetts RWA said that being an 

operator is not viewed as a profession by the public and thus these positions are 

not adequately funded or funded at all. Maine RWA emphasized this point by 

stating that a trained and licensed operator can go work at Wal-Mart® and get 

more pay and fringe benefits, with much less responsibility and liability. 

Only one small system from Massachusetts specifically discussed overall operator 

issues. The Director of Public Works for the town said a major problem for 

systems is low pay, retention of qualified operators, and difficulty in getting 

people to step up and be responsible. Most other systems visited noted 

regulations issues (see below) or assistance and training received (see Chapters 3 

and 4). 

Regulatory/Compliance Challenges 

Small drinking water systems face challenges of a regulatory/compliance nature: 

difficult to understand and burdensome regulations, compliance with current 

regulations, and compliance with future regulations. Many of these are as a result 

of the challenges described in the financial/management section. Of the 19 small 

systems we visited, 13 (68 percent) mentioned regulatory issues as a challenge. 

Regulations Burdensome or Difficult to Understand 

A July 2001 National Rural Water Association white paper16 concluded that 

regulations have steadily increased since 1974 in both number and complexity 

and small water systems face a compounding effect. That is, compliance with one 

particular regulation may be much more difficult as result of one or more prior 

16 F. W. Pontius, Compounding Effect of Drinking Water Regulations on Small Water Systems, Rural Water 

Parnership White Paper (Duncan, Oklahoma: National Rural Water Association, July 4, 2001). 

10
regulations. A later June 2004 white paper17 noted the increasingly stringent 

regulatory requirements and the associated cost and technical complexity of 

compliance. 

Massachusetts staff indicated that a major problem was that systems do not 

understand the rules which results in a need for technical assistance. They also 

stated that small systems have too much paperwork. Maine staff indicated that 

from a small system’s perspective, the existing requirements, the reporting, and 

the impact of the new regulations will be burdensome. 

Small systems we visited also weighed in on these issues. A Maine mobile home 

park operator stated that his greatest concern was the time to do necessary 

paperwork. He claimed to understand the regulations, but not why certain tests 

were needed. Another Maine mobile home owner expressed frustration with 

burdensome requirements and their impact on his system. He said he did not 

know what he would do, but “maybe just walk away from the system.” A 

Massachusetts water district operator stated that too much time was required of 

systems to comply with regulations and the town could not pay someone to do all 

the work. 

Compliance with Current Regulations 

Several of the systems we visited in Massachusetts and Maine had been issued or 

were on enforcement documents and hence current compliance was not a 

challenge. Kansas staff discussed problems its small systems were having 

complying with the Stage 1 Disinfectant/Disinfection By-Products Rule. The 

challenge for systems with surface water as the source is infrastructure changes 

needed to comply with the maximum contaminant level requirements for Total 

Trihalomethanes and Five Haloacetic Acids. All five Kansas systems we visited 

faced this problem. 

Compliance with Future Regulations 

Many of the EPA regions, States, third parties, and small systems we visited 

mentioned future regulations as a challenge. These groups were concerned 

because EPA will be issuing new drinking water regulations soon, and their effect 

on small systems’ operations and finances is uncertain. 

According to the Chief of the Drinking Water Branch, Region 1, compliance with 

the Arsenic Rule will have the greatest impact on small systems; those systems 

without disinfection will be affected by the Ground Water Rule. Those States that 

have not monitored under Stage 1 will be quite heavily affected in implementing 

Stage 2 of the Disinfection By-Products Rule. According to Region 7, the 

17 Robert Raucher, Megan Harrod, and Marca Hagenstad, Consolidation of Small Water Systems: What Are the 

Pros and Cons, Rural Water Partnership White Paper (Duncan, Oklahoma, National Rural Water Association, June 

29, 2004). 

11
Radionuclides Rule and compliance will be an issue for some States and systems 

on a case-by-case basis, with many systems being in noncompliance. Region 7 

has found that many systems with radionuclide problems also have arsenic ones. 

Massachusetts’ Chief, Drinking Water Program, said the Ground Water Rule will 

be a problem for most of the small systems because 90 percent of those that use 

ground water do not disinfect—maybe an especially costly situation because new 

equipment may be needed to comply with the rule. A major problem, according 

to Massachusetts staff, was that systems do not understand the rules, resulting in a 

need for technical assistance. Maine staff concurred with the impact this rule will 

have on its small systems. 

Third-party organizations described future compliance issues faced by small 

systems. For example, the New England Interstate Water Pollution Control 

Commission is concerned with the revised Arsenic Rule and not sure how much 

EPA consideration was given to the burden placed on small systems – in 

particular the disposal of what is produced from the waste stream. Massachusetts 

RWA said the Ground Water, Disinfectant By-Products, and Arsenic Rules will 

impact the small systems; in particular those with ground water sources. In 

Massachusetts, the State’s proposed maximum contaminant levels for perchlorate 

is creating concerns among system operators. The Executive Director of the 

Massachusetts Water Works Association said that the new regulations will be 

overwhelming to the very small systems. She added that EPA’s concept of 

writing the rules as “one size fits all” does not fit all. Consideration should be 

given to personalizing or regionalizing a rule. Maine RWA indicated that while 

some small systems have recently spent money to upgrade their water filtration 

systems, they will have problems complying with the new regulations. Kansas 

RWA stated that the monitoring costs to test for Cryptosporidium and Giardia 

under the Long Term 2 Enhanced Surface Water Treatment Rule could be 

additionally imposing to the small systems. 

Ten of the 19 small systems we visited also brought up future regulations as items 

of possible concern. One Maine water department operator stated that if EPA’s 

rules become more stringent, many small systems will not be able to cope. This 

possible situation is due in part to the lack of experience, finances, technology, 

and the time to address the additional requirements. Several systems stated that 

they were not sure what the impact of future regulations would be on their 

systems. 

Conclusion 

Small drinking water systems face myriad challenges to assure good water quality 

and protect public health now and into the future. These challenges, whether they 

are financial/management or regulatory/compliance, are interrelated, have existed 

for some time, and will continue. 

12
Recommendation 

We recommend that the Assistant Administrator for Water: 

2-1 Direct EPA work with States to identify successful approaches for 

working with small systems in the DWSRF program. 

Agency Comment and OIG Evaluation 

In its April 20, 2006 response, EPA stated that while it establishes the basic 

requirements of the DWSRF program, individual States implement them, thus 

there are actually 51 programs. EPA agreed that States should review their own 

processes to simplify and streamline them. The response stated that the law 

requires that 15 percent of DWSRF funds be provided to small systems serving 

fewer than 10,000, and national figures show that 39 percent of funding went to 

those entities. Statistics were provided showing that over half of the loans made 

since the program began were provided to small systems (serving 3,300 people or 

less). In response to Recommendation 2-1 the Agency stated it “will continue to 

work with states to identify best practices and share them with other states that are 

still facing challenges in funding small systems." 

The ability to obtain necessary funding is a challenge that small systems face. We 

recognize that within the DWSRF process, it is the States that have primary 

responsibility for the program. Some States have been more successful than 

others in assisting small systems. The identification and sharing of this 

information can be beneficial to other States and we believe EPA, with its 

national influence, can facilitate that exchange. We have revised our 

recommendation to reflect EPA’s role in the process. 

The response also suggested that draft Recommendation 2-2 be dropped. The 

recommendation had asked EPA to determine whether a “one size fits all” 

regulatory approach could be changed to a “regionalized” one. EPA stated that 

while potential occurrence and related exposure to a contaminant may vary by 

region, the health effects do not. EPA develops regulations to protect the public 

from potential health risks due to drinking water, regardless of where they are or 

the size of the system. In doing so, regulations are established that are risk-based, 

as opposed to a "one size fits all" approach. Examples were provided relative to 

Long-Term 2 Enhanced Surface Water Treatment and Arsenic Rules as they 

relate to small systems. To reduce burden on small systems, EPA varies 

schedules and monitoring requirements by system size (and relative population 

served). In addition, to reduce monitoring costs for small filtered systems, more 

expensive monitoring is only required if specified trigger values are exceeded. 

With regard to arsenic, small systems were provided an additional two years to 

comply with the standard. Additionally, where warranted, States have the 

flexibility to provide eligible systems with exemptions that can provide an 

additional nine years to meet the standard. 

13
The information provided in EPA’s response is consistent with the flexible 

approach we were advocating in our draft recommendation. We believe small 

systems sometimes need to be dealt with differently than larger systems because 

of the specific challenges they face. Therefore, based on the EPA response, we 

are deleting the draft recommendation. 

14
Chapter 3

Many Approaches Undertaken to Assist 

Small Systems 

Many activities are being utilized to assist small drinking water systems in 

overcoming their challenges. EPA Headquarters, EPA regions, and States have 

all attempted different initiatives, several utilizing third-party organizations. 

Some address specific issues, while others cover a broad spectrum. Headquarters 

pursued a capacity development strategy and revised variance and exemption 

regulations. Region 1 used many of the Headquarters tools as part of its initiative; 

both Regions 1 and 7 had more directed initiatives for small systems concerning 

arsenic. 

We noted during our preliminary research several State and third-party initiatives 

that could be used for best practices. Massachusetts extensively used a coalition 

of third-party organizations, while Kansas’ initiatives sought to develop tools and 

programs that help water systems achieve and maintain financial and managerial 

capacity. Third-party efforts included a Massachusetts Water Works Association 

mentoring program, Maine RCAP working with several systems to establish a 

joint rate payer base, and Kansas RWA documents to aid water board/town 

council members. 

This chapter details the approaches taken. The effectiveness of the approaches is 

discussed in Chapter 4. 

EPA Headquarters Pursues Several Approaches 

Headquarters’ strategy for small systems, Capacity Development, is pursued with 

all drinking water systems. This strategy continues the approach advocated in the 

SDWA Amendments to ensure that water systems have adequate technical, 

management, and financial capacity. Headquarters has been focusing mainly on 

guidance documents and working through funds given to the Technical Assistance 

Centers and Environmental Finance Centers. A number of Simple Tools for 

Effective Performance documents and “targeted” quick reference guides have 

been issued to assist small systems. Regions have utilized these for their own 

initiatives (see Region 1 below). The Technical Assistance Centers are working 

on materials for board member training and security basics (additional details on 

Technical Assistance Center activities are provided at the end of this chapter). 

The Environmental Finance Centers are currently working on financial training 

for board members. 

15
EPA also revised its variances and exemptions regulations on August 14, 1998, to 

create a new affordability-based small systems variance. Variances under SDWA 

allow a public water system to deviate from the maximum contaminant level of a 

national primary drinking water regulation under certain conditions when 

exceptionally poor source water conditions prevent compliance with that 

regulation. Exemptions under SDWA allow a public water system extra time to 

comply with a new national primary drinking water regulation. When operating 

under variances or exemptions, water systems must still provide drinking water 

that protects public health. 

EPA Regional Initiatives Address System Concerns 

Both the EPA regions we visited had their own initiatives to assist small drinking 

water systems address both categories of challenges presented in Chapter 2. 

Region 1 indicated that it utilized many of the Headquarters tools to assist small 

systems. For example, the region utilized the asset management tool developed 

by OGWDW: “Asset Management - A Handbook for Small Systems – One of the 

Simple Tools for Effective Performance (STEP) Series.” In 2004, the Region 

provided funds to RCAP to design and conduct asset management training for key 

regional and State contacts throughout New England. The asset management 

“Train the Trainers” workshops were developed to train about budgets, capital 

improvement plans, life cycle costs, operation and maintenance costs, and proper 

rate structure. 

The June 2004 Pocket Sampling Guide for Small Water Systems was developed 

by the New England Water Works Association, under an Assistance Agreement 

with Region 1. This sampling tool was modeled after two older versions 

produced by OGWDW. The region supported the effort to update the pocket 

guide to address noncompliance issues due to monitoring and reporting violations, 

advance the knowledge of new and existing regulations, and meet the needs of 

small systems for user friendly compliance assistance tools. 

Other Region 1 initiatives included the following: 

 The “Got Computer” Project was funded on a grant to the New England 

Rural Water Association. This pilot project was an attempt to meet the 

needs of some small systems in accessing the Internet, by providing water 

utilities with used and donated EPA computers. 

 The Technology List Server was developed to give water system owners 

and operators an opportunity to ask questions, share experiences, and post 

information informally. 

 The Technology Advisory Board was established in 2001 to serve as a 

regional forum for information exchange, technical discussion, and 

16
priority setting about treatment and emerging technologies relating to 

water systems. 

 An Arsenic Initiative was developed to assist small systems address this 

water quality concern. This initiative included data compilation, GIS 

(Geographic Information System) mapping, an arsenic costing tool, 

information transfers, circuit riders, and various meetings. 

Region 7 also has an arsenic initiative for small systems. The regional staff's 

emphasis is on systems’ use of EPA’s Office of Research and Development grants 

and finding low cost treatment technologies for the systems to utilize (grants have 

been given to the University of Nebraska). 

The Region's implementation plan (1) emphasizes regulatory flexibility to States 

and utilities, (2) identifies appropriate and affordable arsenic removal strategies 

for small systems, (3) identifies and promotes use of affordable funding options, 

(4) provides appropriate treatment technologies for water systems, and 

(5) implements an aggressive research to identify new affordable technologies. 

States Take Various Approaches 

The States we visited took different approaches to assist small systems. Some of 

these initiatives we believe can serve as best practices and should be shared with 

other States. 

Massachusetts 

Massachusetts extensively used a coalition of third-party assistance organizations. 

It provided its full 2-percent DWSRF set-aside to the Massachusetts Coalition for 

Small System Assistance, which was made up of the New England Water Works 

Association, Massachusetts Water Works Association, Massachusetts Rural 

Water Association, and RCAP. 

Free Massachusetts Coalition for Small System Assistance services to public 

water system personnel were in the following areas: seminar series on diverse 

topics, one-on-one site visits, regional mentoring cooperatives, operator 

reimbursement training, and public awareness. 

Massachusetts found it helpful to put systems on a compliance schedule. The 

State uses compliance measures as the method of determining if information is 

being communicated correctly to the systems or if they understand what they need 

to do. This allows the assistance organizations to provide the aid systems need to 

comply. Third-party assistance organizations are considered to wear the “white 

hats” by water systems because they are not responsible for enforcement, which is 

the State role. Therefore, these assistance organizations are better accepted and 

can provide the needed assistance. 

17
Maine 

Maine also worked closely with its third party organizations. The State partnered 

with such groups as Maine RWA and Maine RCAP to fund circuit riders and 

provide training to small systems. 

Kansas 

Kansas has taken a number of initiatives to assist small systems. Since 2002, the 

State has been involved with developing tools and programs that help water 

systems achieve and maintain financial and managerial capacity. These programs 

and tools are listed below. 

Kancap. Under contract with Kansas RWA, an interactive CD and 

handbook (available on the disk) were developed that water system and 

governing board members can use as an educational tool as well as a 

reference guide, once training is completed. Many topics are on the disk, 

with an emphasis on managerial and financial responsibilities. 

Financial Planning Tools and Assistance (In Process). Kansas contracted 

with the Environmental Finance Center at Boise State University to develop 

a Kansas-specific rate-setting and financial planning tool to be made 

available via the Internet to all water systems. The software was to be ready 

by the end of 2005. 

Kansas contracted with a consulting firm to provide on-site financial 

planning assistance, including rate setting, budget review, and capital 

improvement planning. A report is provided to the systems with 

recommendations to help them achieve and maintain financial capacity. 

Regional Public Water Supply Planning Grant Program. This program 

provides 50-percent matching funds for preliminary engineering studies that 

evaluate regional solutions to address system needs and challenges. Kansas 

uses a portion of the drinking water loan fund set-aside to provide up to 

$12,500 to match funding provided by project sponsors for the studies. It 

started in fiscal 2004; to date, three studies have been funded. Those studies 

have the potential to benefit a total of 19 public water supply systems. 

Kansas Public Water Supply Loan Fund Program. The revolving fund 

provides financial assistance in the form of loans to municipalities at below 

market interest rates, for constructing public water supply system 

infrastructure. The loan fund is made possible by receiving capitalization 

grants from EPA. As new regulations are implemented, it is the State’s 

intent that loans help systems meet challenges faced in achieving 

compliance. The State contracts with the Kansas Rural Water Finance 

Authority to conduct financial reviews of all systems applying for a loan. 

18
Kansas Public Water Supply Loan Fund: Small System Technical 

Assistance 2 Percent Set-Aside. Technical assistance is provided to 

systems serving less than 10,000 through a contract with Kansas RWA. 

Kansas RWA will provide technical help to small systems to help comply 

with rules, develop and maintain proper operation and maintenance 

procedures, and develop appropriate management procedures and provide 

technical assistance to systems using surface water as their source of supply. 

Kansas RWA provides a minimum of 420 hours of onsite technical 

assistance. 

Kansas is also focused on regionalizing (or consolidating) systems. This is 

not a forced program but can be mandated depending on case-by-case 

issues. Nonetheless, it is encouraged as small systems get into difficulty. 

Regionalizing systems is more common in the central and western parts of 

the State. (Consolidation is detailed more fully in Chapter 4.) 

Third-Party Organization Assistance a Key Piece 

Third-party organizations are active in assisting small systems, both as partners 

with EPA and States and on their own. They are a key player in the small system 

assistance process. Besides the approaches already described above (including 

the coordinated Massachusetts Coalition for Small System Assistance activity), 

some additional ones include the following. 

Maine RCAP 

RCAP's role is to aid systems in finding funding for improvements. Major 

problems for very small systems, especially with populations with low incomes, 

are they cannot keep up with plant improvements or they have an insufficient rate 

structure or user rate. An example of its efforts is its activity in Addison, Maine. 

The town has 65 households (200 people) with a ground water system and zero 

capacity development. A Maine RCAP official said many systems are like this in 

the State. RCAP is attempting to establish five systems on the same rate payer 

base with one operator. The overall benefit for the systems is that they would 

have an operator available to them for reporting, compliance, testing results, and 

any other pertinent issues. They also would share in the economy of scale for 

infrastructure issues. Both the State of Maine and Rural Development (at the U.S. 

Department of Agriculture) are supporting this initiative. Maine RCAP was able 

to get a local accounting firm to review the books pro bono and make corrections 

for the Addison water system. Massachusetts RCAP provided assistance to solve 

the technical problems. To date no operator has been hired. 

Massachusetts Water Works Association 

The Massachusetts Water Works Association independently provides 12 training 

sessions annually, in addition to the 20 to 25 training sessions that it does through 

19
the Massachusetts Coalition for Small System Assistance contract. The 

Massachusetts Water Works Association provides very low cost training to water 

system operators while training provided under the coalition contract is free. The 

organization also does training sessions at vocational schools to identify job 

opportunities in the drinking water field. It addresses boards of health, day care 

centers, etc., to identify that, given the specifics, certain entities are in fact public 

water systems and are required to abide by the SDWA regulations. Some 

problems have occurred with local public health officials who are not fully aware 

of all water requirements. 

The Massachusetts Water Works Association also performs mentoring. The 

mentoring sessions were designed to provide pertinent information to assist small 

water systems maintain regulatory compliance. An additional benefit was that the 

sessions provided an opportunity for small water system owners and operators to 

meet experienced water works professionals and develop a network of resources 

and contacts for obtaining additional information. A key component of the 

mentoring program is the corps of volunteers who serve as “mentors” at the 

mentoring sessions. The corps of volunteers consists of experienced water works 

professionals, including consultants, engineers, and specialized staff from larger 

water systems. The volunteers serve as presenters and facilitators at the 

mentoring sessions. As “mentors,” they share their knowledge and skills with the 

attendees. The mentoring program was promoted through the regional water 

works associations, boards of health associations, and other organizations. 

Kansas RWA 

Kansas RWA has five circuit riders; three are funded by Kansas/EPA monies and 

the remaining two are funded by the National Rural Water Association. The 

organization provides training to water system operators and board members. To 

aid water board/council members and utility employees in the running of their 

water systems, Kansas RWA produced between 1993 and 2000 the seven-volume 

Water Board Bible series. 

EPA Technical Assistance Centers 

We visited the EPA Technical Assistance Center at the University of New 

Hampshire. This Center has worked with the New England Interstate Water 

Pollution Control Commission and the New England Water Works Association 

with respect to small systems treatment needs. For example, a pilot study is in 

place in Newbury, Vermont; the Center will be coordinating similar small system 

sand filtration systems with Maine RWA and the State of Maine. 

Typically, a $4 million appropriation for the eight Technical Assistance Centers is 

divided equally amongst them. However, there can be separate riders or other 

appropriations. Each of the centers has specialties. For example: 

20
• Montana State University. Maintains the national Web site and is 

nationally focused. It provides basic training material for operators in the 

form of CDs, on-line training, and books: 13 hours of training material. It 

has distributed thousands of CDs. The center has a $40,000 grant for 

research. 

• University of Missouri, Columbia. This center focuses more on 

technology than training. 

• Mississippi State University. This center works with Rural Water 

Associations and addresses small drinking water systems’ existing and 

emerging needs. 

• Pennsylvania State, Harrisburg. This Center provide training for 

persons involved with instruction and training of small public water 

system operators. 

• University of Alaska, Sitka. This Center provides training and technical 

assistance. It trains operators to use a laboratory testing kit. 

Conclusion 

EPA, States, and third-party organizations are using many different approaches to 

assist small systems to overcome the various challenges they face. Some of these 

are in partnership and others are self-initiated. We found several of these to be 

better practices and worthy of sharing with other States and organizations. 

Recommendation 

We recommend that the Assistant Administrator for Water: 

3-1 Direct OGWDW to work closer with States to identify and compile small 

system best practices and establish a method for disseminating the 

information so that limited resources to assist small systems can be 

maximized. 

Agency Comment and OIG Evaluation 

EPA concurred with our recommendation and agreed that it is important that 

successful tactics be shared to ensure the maximization of resources. The Office 

of Water has had many efforts underway and cited successes such as regional and 

national capacity development workshops, meetings with Technical Assistance 

Center grant recipients and providers, and the Capacity Development Program 

Tool. The Office of Water is also assessing approaches to get feedback directly 

from small systems on both the usefulness of the tools developed and the 

additional tools needed. Finally, one of the Office of Water’s goals is to develop 

an improved Internet site to provide information it has developed to support small 

systems and links to other third-party providers. 

21
We encourage Office of Water to continue to find ways to compile and 

disseminate best practice information to assist small systems to maximize their 

limited resources. 

22
Chapter 4

Small System Approaches Have Shown 

Mixed Results 

The effectiveness of efforts to overcome small drinking water challenges has been 

mixed. Statistics over the last 13 years show that system size correlates with 

noncompliance with drinking water regulations.18 The smaller the system, the 

greater the possibility of noncompliance. The approaches that EPA, States, and 

third parties have tried to use to assist small systems (see Chapter 3) have run the 

spectrum of success. We list the effectiveness of several of these approaches in 

this chapter. 

Smaller Systems Have Greater Noncompliance 

EPA statistics have shown over the years that noncompliance with drinking water 

regulations has increased as the size of the system decreases. For example, the 

1997 Report by the National Academy of Sciences, Safe Water From Every Tap--

Improving Water Services to Small Communities, reviewed EPA data and found 

the following: 

. . . [the] number of community water systems that violated the 

maximum contaminant level (MCL) for total coliforms by size of 

community and water source (ground or surface) for the 27-month 

period October 1, 1992, through December 31, 1994. Most of the 

systems in violation were in ground water systems serving 500 or 

fewer people, presumably because many of these systems do not 

disinfect their water. The violation rate for systems with fewer 

than 500 customers is more than twice the rate for systems serving 

larger populations: a violation of the MCL for total coliforms was 

reported by 29.5 percent of the systems serving fewer than 500 

people as compared to less than 14.5 percent of the systems 

serving larger communities. 

The report also provided some other data for that time from the Federal Reporting 

Data System, as shown in Table 4.1. 

18 Meeting drinking water standards is most difficult for water systems in small communities. Small communities 

often cannot afford the equipment and qualified operators necessary to ensure compliance with safe drinking water 

standards. Increases in both the number of drinking water regulations and the number of small community water 

systems over the past three decades have compounded the problem of providing safe drinking water to small 

communities. 

23
Table 4.1: Violations of Drinking Water Standards for Chemical Contamination by 

Size of Water System 

Size of Population Served 

500 and 

under 501-3,300 3,301-10,000 >10,000 

Total number of 

systems with violations 531 162 25 15 

Percentage of systems 

with violations 1.5 1.1 0.61 0.44 

A June 2004 Journal of Contemporary Water Research & Education article19 cited 

statistics on 2002 SDWA violations in the United States. The proportion of total 

violations for the very small size category was much larger than the proportion of 

systems in this category (73 percent vs. 57 percent). Monitoring and Reporting 

violations dominated all size categories (nearly 60 percent of all violations) and 

more than 80 percent of Monitoring and Reporting violations are accounted for by 

very small systems. EPA considers maximum contaminant levels and treatment 

technique violations to be the most serious and classifies these as health-based 

violations. Very small systems had almost 60 percent of all the health-based 

violations; small systems accounted for another 24 percent. 

Data20 from 2 years later also support the system size difference: 

Table 4.2: Number of Community Water Systems in Violation 

System Size 

Maximum 

Contaminant 

Level Violations 

Maximum Residual 

Disinfectant Level and 

Other Violations 

Treatment 

Technique 

Violations 

Very small 2,032 6,218 808 

Small 806 2,003 365 

Medium 324 438 107 

EPA data also show that small system noncompliance rates have remained 

relatively unchanged in recent years. For example, maximum contaminant level 

small system violation rates have ranged between 5.48 and 6.98 percent for the 

years 1998 to 2004. For the same period, treatment technique violation rates have 

ranged from 1.78 to 3.01 percent. These and other types of violations have varied 

up or down depending on the year. 

19Dziegielewski and Bik, Technical Assistance Needs. 20 U.S. Environmental Protection Agency, FACTOIDS: Drinking Water and Ground Water Statistics for 2004, EPA

816-K-05-001, May 2005. 

24
Systems Report EPA Guidance Is Difficult to Understand 

One way EPA communicates drinking water requirements is through guidance 

documents. We found that many small systems thought this guidance difficult, 

complicated, and too technically written. Small systems had to depend on third 

party organizations to help them understand the documents. Since considerable 

time was spent on this endeavor, other worthwhile activities to assist small 

systems had to be sacrificed. 

For example, the Massachusetts Drinking Water Program Chief said that guidance 

documents, which are to explain and identify implementation of a rule, are too 

technical. A “plain English” version is needed. 

Four of the third-party organizations we visited also provided comments. On 

whether communicating material or guidance is reaching the small systems, 

Massachusetts RCAP believed it was achieved in an indirect manner--not directly 

from the regulatory agencies. It stated communication is generally a result of a 

system having a problem which results in their awareness of something--“a 

reaction thing.” Massachusetts RWA staff indicated that communication to water 

systems was okay, but the material sent to systems is too overwhelming. Systems 

feel guidance or any material is too complex (written by engineers for engineers), 

too overwhelming, and too burdensome. Maine RWA advised that the EPA 

regulations are burdensome to small systems. Its field staff spent a majority of 

their time explaining regulations to systems or reacting and explaining problems 

that occurred. Maine RWA stated that part of the problem is the amount of 

regulations and part is how EPA and States communicate to the water systems. 

Massachusetts RWA stated that guidance is complicated and presented in a 

confusing manner as opposed to hard technical jargon. 

Variances and Exemptions Appear Rarely Used 

None of the entities we visited brought up the use of variances or exemptions. 

EPA had established these tools to assist small systems who cannot afford to 

comply with drinking water regulations. Since we identified compliance with 

future regulations as a small system challenge, we had expected more active use 

of this approach. 

Regional Initiatives Have Had Mixed Results 

Several of the Region 1 initiatives described in Chapter 3 have had mixed results. 

Implementing the “Got Computer” Project pilot identified barriers to success due 

to the nature and age of the donated computers. The New England Regional 

Water Association distributed used computers (5 years old) to nine small water 

systems. As for the Technology List Server, about 60 representatives of water 

utilities, technical assistance providers, State drinking water programs, and EPA 

signed up for the list server. Region 1 utilized this mechanism to post information 

25
on upcoming training and provide announcements of the availability of fact sheets 

and other guidance. However, over the long term the overall success of this 

project was spotty with respect to engaging water utilities to ask questions and 

share experiences. The Technology Advisory Board has proved more successful 

and continues today on an informal and as-needed basis. 

Consolidation Has Pros and Cons 

Consolidation (sometimes referred to as regionalization) is one approach that has 

been proposed as a way for many small systems to address some of the challenges 

they face. Some States are strong proponents of this method (Alabama, 

Connecticut, Kansas, Kentucky, and North Carolina), while others (Maine and 

Massachusetts) are not. This approach is not a cure-all and has many advantages 

and challenges. Consolidation was brought up in several of the articles we 

reviewed and was an active approach in one of the States we visited (Kansas). 

Water system consolidation is defined as one community water system being 

absorbed into, combined with, or served by other utilities to gain the resources 

they otherwise lack. There are numerous forms of consolidation; some entail 

actual physical interconnection or other structural approaches, and some forms 

involve nonstructural approaches such as shared management arrangements. 

Utilities can enter into mergers or other cooperative agreements with other 

(usually larger) systems, or transfer management and/or ownership to another 

entity. 

The benefits to consolidation include economies of scale, increased financial 

opportunities, elimination of duplicative services, increased reliability, increased 

flexibility, enhanced protection of public health, skill improvements, and service 

efficiency. Conversely, a number of barriers exist, including loss of power and 

community independence, differing management goals, conflicting regulations, 

cost and benefit inequities, workforce reduction, equipment reduction, public 

confusion, and debt. Appendix B provides more details on benefits and barriers. 

Of the three States visited, only Kansas was actively pursuing consolidation. 

Kansas officials noted the challenges small systems faced and said the State 

proposes to systems that "regionalization" of systems may be an alternative. 

Massachusetts officials said they cannot have a "Consolidation Policy," while 

Maine officials noted that there were not any options for consolidation of small 

systems. All five small systems we visited in Kansas had dealt with 

regionalization; two have gone through with it, while the other three are still 

trying to decide what to do. Four of the five faced noncompliance with the Stage 

1 Disinfectant/Disinfection By-Products Rule that became effective in January 

2004. The other system had water supply problems. Challenges that these 

systems face or still face include poor economic bases (including many low 

income and elderly residents), fear of increased costs, loss of autonomy, and loss 

of revenue. 

26
State Resource Shortages Hamper Assistance 

State resource shortages are affecting the State agency's ability to serve the needs 

of small systems. We found shortages in two of the three States we visited. The 

shortages have caused States to cut back on their activities and depend more on 

third-party organizations to fill the void. 

• Maine does not have enough staff to do all the work it needs. Staffing (32 

people) has been the same since 2000. In fact, one person oversees over 

1,000 systems in one part of the State. In 2001, the State completed a selfassessment tool and identified that 62 State staff were needed for its 

drinking water program. The future of the whole program has been in 

jeopardy because the needed matching State funds have been an annual 

issue. In 2005, a $3.5 million bond was drafted through a special 

legislative session and was approved by the voters in November 2005. In 

2004, the State had no matching funds nor was a bond provided. In 2003, 

the State match was cut from $1.8 million to $1.2 million. At least one of 

the small systems visited stated that due to cutbacks the State had not been 

helpful. 

• Massachusetts had a “budget meltdown” 4 years ago which resulted in a 

25-percent staff reduction. The drinking water program was supported 

through funding that was approximately 25 percent EPA, 25 percent from 

the State budget, and the balance from an assessment to water systems 

(enacted through State legislation) that is .085 cents per thousand gallons 

of water used by systems. The State bills the water systems and this 

amount annually is approximately $2.2 million. At least one small system 

commented that it had to rely on third-party assistance because of the staff 

reductions. 

Kansas Loan Program Is Productive 

Kansas’ Public Water Supply Loan Fund Program has been able to address water 

system needs. As noted in Chapter 3, the loan fund is made possible by receipt of 

capitalization grants from EPA. Between fiscal years 1997 and 2004, Kansas 

received a total of $84,376,600 from EPA in grants. Since inception in 1997, 

127 loans have been closed for a total of $290,457,701. One of the program goals 

is to provide loans to small systems. SDWA requires that 15 percent of the loan 

assistance must be to systems serving less than 10,000 people. Kansas takes this 

one step further and requires that 20 percent of loan funds go to systems with a 

population less than 5,000. Small systems have received 88 of the 127 loans 

made since the program began amounting to $103,174,812, or approximately 

35 percent of the total dollar of loans closed. 

27
Third-Party Organizations Seen as Beneficial to Small Systems 

Third parties have been a bright spot, providing the hands-on attention that small 

systems need. In a climate of limited governmental resources, third-party 

assistance organizations fill a void. In partnership with States, they provide 

necessary training, technical assistance, guidance, and financial and management 

tools to small systems. Fourteen of the 19 systems we visited spoke positively 

(none were negative) of these organizations. 

States are making use of these organizations to the benefit of small systems. For 

example, as noted in Chapter 3, Massachusetts made extensive use of the fourorganization Massachusetts Coalition for Small System Assistance. This coalition 

was able contribute much needed assistance. For the period July 1, 2002, through 

June 30, 2004, the coalition reported the following milestones: 

• All 41 group training sessions have been completed. 

• All 276 one-on-one site visits have been completed. 

• All 30 mentoring sessions have been completed. 

• The Drinking Water Fair in the Western Region was conducted on 

November 20, 2002, and November 18, 2003, both with a good turnout. 

• The National Theatre for Children performed at various schools in the 

State during “Drinking Water Week,” May 5-9, 2003, and May 3-7, 2004. 

• The Small Systems Outreach Web Site continues to operate and is updated 

on a regular basis. 

Massachusetts officials said they were pleased with the work done and assistance 

by each of the organizations. They said there is no overlap of services provided 

by each. In fact, they are put in the same room to identify projects and 

coordination. 

While the other two States visited did not make as extensive use of its third-party 

organizations as did Massachusetts, small systems did benefit from the 

State/third-party partnerships. 

Maine identified a very good working relationship with the Maine RWA and 

Maine Utilities. Cooperation includes matching funds and sharing work. The 

State also identified its successful contact with third-party organizations such as 

RCAP and quarterly meetings with the New England Interstate Water Pollution 

Control Commission. The face-to-face meetings are successful. The State has 

used the Technical Assistance Center and has handed out Technical Assistance 

Center training CDs to water systems. 

Concerning its operator certification requirements, Maine contracted with Maine 

RWA to put on pre-exam training at 30 different sessions throughout the State. 

Maine specifically targeted systems that did not have certified operators and 

provided training at four strategic locations with 20 to 25 candidates each. 

28
Training brochures were mailed out over a 4-year period through five to six 

mailings from Maine RWA. Maine states that it has 98-percent operator 

certification compliance. However, it emphasized that it has a high turnover of 

water system operators and that very small system operators do not have the time 

to keep abreast with additional training. Nonetheless, Maine continues to 

maintain its outreach for educational training. 

The measure of an approach is the perception of its user--in this case, the small 

systems themselves. We found the small systems we visited appreciated very 

much the assistance provided by third-party organizations. Here is just a 

sampling of their comments: 

• A Massachusetts director of public works said that without the assistance 

from assistance organizations, the water system would have great 

difficulties. 

• A Massachusetts water district treasurer said that if they did not have these 

resources (third parties) available to him, he would not know what to do. 

• A Maine system operator relied on a third-party organization to help 

define and translate the regulations. With hands-on assistance, the system 

is now in compliance. 

• A Maine water system operator stated, “I would stagger under the 

regulations without Maine Rural Water.” 

• Kansas town officials advised that a third-party organization was a great 

help to their community. 

One Small System Overcomes Challenges Through Own Efforts 

Small systems are able to right their own ship in some cases. East Chelmsford, 

Massachusetts, was able to get out of noncompliance and improve its operation by 

its own actions. A town commissioner said the best thing for the system was the 

State Consent Order issued in 1999 because it forced change. This Order cited 42 

infractions since 1990 with no action taken to resolve and 19 additional new 

violations. The system was fined $5,000 and shut down from February to July 

1999. During this time, the State told the town to consider consolidation with 

another system. The commissioner said the townspeople rejected this 

recommendation. The Board of Commissioners had resigned. 

The big problem in 1999 was that the system had very little money. During the 

first 4 months under the new staff, the system was unable to pay bills and could 

only meet payroll. With a complete change in staff and board, the system doubled 

water rates in 1999, which Massachusetts had advised in prior years but not done. 

These rates were increased 5 percent per year for the next 3 years. Only in the 

last 3 years have rates not increased. Rate increases enabled the system to begin 

much needed improvements neglected under the prior administration. The system 

is now solvent and operates on $2 million per year with rates that have allowed 

improvements with excess of $1 million spent on upgrades over the past 6 years. 

29
Today the system is a success story--but it is due to the diligent efforts of the 

current Board and the water system staff, in response to State enforcement action. 

EPA and Massachusetts have held sanitary survey classes using the town's 

success as an example. 

Conclusion 

While it is difficult to measure the effectiveness of individual EPA and State 

activities to assist small drinking water systems, our preliminary research 

provided indicators of both successes and limitations in the approaches. An 

important aspect of the EPA drinking water program is its regulations and the 

guidance provided to assure compliance with them. We heard many times that 

they were difficult for small systems to understand. Regions and States tried 

many approaches; some worked better than others. Consolidation was one the 

approaches on the forefront, but because it has advantages and disadvantages, it is 

not a panacea. States are also facing resource shortages affecting their ability to 

assist small systems. Yet, States like Kansas have been able to provide loans 

funds to these systems. Because of limited resources, States have had to depend 

more on their partnerships with third-party organizations, and these have been 

able to fill the need. Several highly successful activities have taken place and 

small systems have acknowledged the benefits they receive. 

Recommendation 

We recommend that the Assistant Administrator for Water: 

4-1 Develop and implement approaches to improve communication with small 

systems so that targeted guidance is received and understood. 

Agency Comment and OIG Evaluation 

EPA indicated that it was difficult to respond to this recommendation without a 

better understanding of the specific documents to which the interviewees were 

referring. EPA has been making a greater effort in the past several years to 

develop guidance that is targeted to small systems. As an example, a six-page 

summary of recent and upcoming products for small systems was attached as part 

of the April 20, 2006 response. The Agency response stated that while EPA will 

continue to work to develop guidance geared to small systems, it knows it needs 

to do a better job of ensuring the delivery of these products. It is clear that some 

small systems are unaware of specific products and tools and EPA believes the 

improved Web site and interactions with States and technical assistance providers 

will help get the word out, identify needs, and refine existing information to make 

it more useful. 

30
We found the difficulty of understanding the complicated and technically written 

drinking water guidance was a concern that was prominently voiced by officials 

of small systems and the States and third-party organizations that assisted them. 

This was raised to us as a general complaint and hence we cannot provide the 

specificity EPA requests. We note that the Office of Water has recently been 

putting more effort in addressing this problem. We have revised the 

recommendation to more accurately reflect our concern that EPA guidance is not 

reaching the small systems for which it is intended. We encourage the Office of 

Water to continue to try to better communicate technical and regulatory 

information to small systems. 

31
Chapter 5

Minimal Data on Health-Related Impacts 

Limited data exists on the health impacts related to small drinking water systems. 

The Centers for Disease Control and Prevention (CDC) maintains a data system 

of drinking water cases, but the information received is voluntary; CDC officials 

state that the information is vastly underreported. Examples of drinking water 

cases have occurred, as well as State boil orders, but they are not numerous; only 

some can be attributed to small community water systems. 

The potential for health impacts needs to be taken seriously. Health effects may 

be related to small systems: experts have stated that health problems are more 

likely to arise from exposure to "disinfectable pathogens" in smaller systems with 

limited resources than in larger ones. 

Drinking Water Outbreak Data Underreported 

Most of the data on drinking water health issues come from the CDC. The CDC 

maintains a Waterborne Outbreak Surveillance System, which is voluntary, 

passive, paper-based, and unfunded. Because of these conditions, according to 

the Chief of CDC’s Environmental Health Services Branch, outbreaks are vastly 

underreported. She gave the example of the Milwaukee outbreak that involved 

approximately 400,000 cases, yet only 20 were reported. Some data are available 

from the CDC, but no specific breakdown exists of health-related cases relative to 

small community drinking water systems. 

For example, the above CDC official stated that from 1971 to 2002, 758 

outbreaks were reported, most caused by individual or non-community systems. 

Of that, CDC data for 1991 to 2000 indicated 155 outbreaks: 

Table 5.1: Waterborne Outbreaks (1991-2000) 

Outbreaks Cases 

Community Water Systems 57 422,364 

Non-community Water Systems 64 8,934 

Individual Water Systems 34 548 

All Systems 155 431,846 

Of all the cases in Table 5.1 above, 403,000 of them related to the one outbreak in 

Milwaukee involving Cryptosporidium in 1993. The etiological agents that 

caused these other outbreaks included: Giardia, Cryptosporidium, 

Campylobacter, Salmonella, Escherichia coli (E. coli), Shigella, Plasiomonas 

shigelloides, non-O1 Vibrio cholerae, hepatitis A virus, Norwalk-like viruses, 

small, round-structured virus, chemical, and undetermined. 

32 
Health Effects May Be Small-System Related 

Other examples of health effects may be related to small systems, but these are 

either specific outbreaks or evidence of problems in relatively small numbers and, 

as can be seen, they are not only caused by small community systems. 

• During the summer of 1998, an outbreak of E. coli occurred in Alpine, 

Wyoming, sickening 157 people from 15 States. The investigators 

concluded that surface water containing deer and elk feces seeped into the 

aquifer that provided the town's water. The outbreak surfaced when 

physicians noted an increase in bloody diarrhea among town residents. 

• A University of Minnesota article21 noted that 5 of the 18 waterborne 

outbreaks of E. coli reported to the CDC between 1982 and 1998 stemmed 

from contaminated drinking water, and all 5 involved small water systems 

or wells supplying rural townships or camps. 

• A 2002 CDC article22 states in its summary paragraph that "Contamination 

of small unprotected water systems may be an increasing public health 

risk." This article cites other statistics on E. coli outbreaks. It states that 

the first reported drinking water outbreak of E. coli occurred in 1989 in 

rural Missouri and subsequently six more had been associated with 

drinking water. Three were small and occurred in a camp, a recreational 

vehicle park, and a well. The three more highly publicized recent ones 

occurred in Wyoming (see above), New York, and Canada. The New York 

one occurred in September 1999 at the Washington County Fair. In that 

outbreak, the drinking water was likely contaminated when cow manure 

seeped into a shallow, unchlorinated well after a large rainstorm. There 

were 921 cases of diarrhea and possibly 2 deaths. The authors of the 

article state that because of underreporting and underdiagnosis, 

reported outbreaks probably represent a small fraction of the true number 

of E. coli outbreaks associated with drinking water in the United States. 

The article concludes: 

Small drinking water systems may be less likely to be 

adequately chlorinated and to routinely monitor for 

contaminants. The outbreak reported here confirms the 

potential of these small, unprotected and unchlorinated 

water systems to be an important source of infection with 

E. coli O157:H7 and other pathogens. Stronger 

enforcement of existing regulations and perhaps 

21 Wyoming E. coli O 157:H7 outbreak showed hazards in small water system (University of Minnesota: Center for 

Infection Disease Research and Policy), April 3, 2002. 22 Sonja J. Olsen, Gayle Miller, Thomas Breuer, Melinda Kennedy, Charles Higgins, Jim Walford, Gary McKee, 

Kim Fox, Wililam Bibb, and Paul Mead, A waterborne outbreak of Escherichia coli O157:H7 infections and

hemolytic uremic syndrome: implications for rural water systems, Emerging Infectious Diseases, April 2002. 

33
broadening of current regulations, such as the proposed 

ground water rule designed to prevent illness from drinking 

water from ground water sources through disinfection, are 

needed to protect rural drinking water systems in the 

United States. 

• From July 23 to September 12, 2004, an outbreak occurred on Bass Island, 

Ohio, that involved 1,450 cases (mainly Giardia). Though the specific 

cause of the outbreak was not determined, the problems occurred basically 

relative to transient public water systems. 

• As of September 26, 2005, 13 active boil water orders occurred in the 

State of Maine for the following reasons: 

Table 5.2: Reasons for Maine Boil Water Order 

Reason Number Percent 

E. coli positive 9 69% 

Non-functioning disinfection system 2 15% 

Chronic total coliform 1 8% 

System without water 1 8% 

The longest boil water order was in effect for 25 months, while four 

systems had orders in effect less than a month. The average age of these 

orders was 4.5 months. Of the 13 small water systems, 3 are small 

community water systems, 5 systems are Non-Transient NonCommunities, and 5 systems are Transients. 

• During calendar year 2004, 16 boil water orders were issued in Kansas--15 

of these were for systems serving less than 3,300 people (5 of these were 

for systems less than 500). 

Public Health More at Risk in Small Systems 

A group of 46 international experts from the United States and other countries 

met in May 2004 to discuss small water systems. They agreed on four principal 

problems affecting small systems, including the incomplete understanding of 

public health risks. In the report on the international colloquium (issued January 

2005), the Executive Summary stated: 

Public health risks associated with small water systems can be 

incurred at any point in the water treatment and transmission 

process, encompassing both acute and chronic diseases due to 

microbial or chemical contamination ... Colloquium participants 

concurred that system stakeholders must become far more aware 

of these potential health risks. 

34
The report also noted that relative to public health risks, small systems can be 

more at risk: 

• As distribution systems age and deteriorate, the burden of replacement is 

far 

greater for small systems and the per-household costs are very high. 

• Financial limitations and relative lack of access to laboratories and 

technical 

expertise may lead to inadequate monitoring and poorly trained personnel. 

• Cumulative risks may be greater for customers of small systems. 

• Small systems are more susceptible to acts of terrorism. 

• An alarming rise of E. coli contamination has occurred over the past 30 

years. 

• Increasing links exist between heavy rainfall and waterborne disease 

outbreaks. 

Similar comments were provided by a professor from Tufts University we met 

with, who is a member of the public health subcommittee of the National 

Drinking Water Advisory Council and on the water panel of EPA's Science 

Advisory Committee. He noted the following: 

• Small drinking water systems frequently do not have the expertise to do 

testing, the economics to maintain the systems, nor the population base to 

successfully support the system. 

• With regard to small community drinking water systems issues, there were 

challenges associated with flooding at various times of the year on a caseby-case basis. He stated that these challenges were true to the risks (e.g., 

bacteria, Crypto, E. coli, Giardia, turbidity, and water quality in general) 

and that basically people were not protected from the risks under these 

conditions. 

• Although larger water systems were, in general, better, small drinking 

water systems were more at risk because of depopulation and the decrease 

in the tax base and thus not able to cope economically and address risk. 

Conclusion 

Not much data exists on the health impacts relative to small drinking water 

systems. The CDC, which maintains the data system, has stated that information 

is vastly underreported. This data system relies on voluntary reports. Outbreaks 

can be directly related to small systems, but they are not of any great magnitude. 

Experts say, however, that small systems can be more at risk for public health 

incidents. 

35
Recommendation 

We recommend that the Assistant Administrator for Water: 

5-1 Continue the collaborative effort with the CDC to improve the system of 

identifying drinking water related health outbreaks. 

Agency Comment and OIG Evaluation 

EPA did not believe that it is possible to draw sound conclusions regarding the 

magnitude of outbreaks based on data from the current outbreak surveillance 

system. The response noted that CDC statistics only represent a portion of the 

burden of illness associated with drinking water exposure, the system only 

pertains to outbreaks of waterborne illness, and our report noted that studies have 

not been performed to assess the sensitivity of the reporting system. 

However, EPA appreciated the recommendation. The Office of Water has been 

working with the Office of Research and Development and CDC counterparts on 

efforts to improve the surveillance system and other activities to improve the 

investigation and reporting of outbreaks. 

We were pleased that EPA is working collaboratively with the CDC to improve 

the surveillance system so that there are better data on the effects of drinking 

water on the public health. We have slightly revised our recommendation to 

recognize the current EPA activity. 

36
Appendix A 

Organizations Visited During 

Preliminary Research 

EPA 

Office of Ground Water and Drinking Water 

Region 1 

Region 7 

States 

Kansas Department of Health and Environment 

Maine Department of Health and Human Services 

Massachusetts Department of Environmental Protection 

Third Party Organizations 

Kansas Rural Water Association 

Maine Rural Community Assistance Partnership 

Maine Rural Water Association 

Massachusetts Rural Community Assistance Partnership 

Massachusetts Rural Water Association 

Massachusetts Water Works Association 

New England Interstate Water Pollution Control Commission 

New England Water Works Association 

Technical Assistance Center at the University of New Hampshire 

Drinking Water Systems 

Kansas Maine Massachusetts 

Altoona 

Elk City 

Harveyville 

Toronto 

Williamsburg 

Begin Trailer Park 

Buckfield Water Department 

Hebron Water Company 

Northern Springs Mobile Home Park 

Port Clyde Water District 

Topsham Mobile Home Park 

East Chelmsford Water District 

Elm Hill Water District 

Leino Park Water District 

Nanatomqua Mobile Home Park 

Palmer Water District 

Wagon Wheel Mobile Home Park 

West Brookfield Water District 

Westminister Water District 

37
Appendix B 

Benefits and Barriers to Consolidation 

Benefits to Consolidation 

Economies of Scale: Spreading fixed capital, operation, and maintenance costs over a 

larger population could lead to lower per unit costs and subsequent lower customer rates, 

and additional efficiencies by having lower total costs from combined financial, 

administrative, personnel, and equipment resources. 

Increased Financial Opportunities: More revenues and assets, larger tax base, and 

access to regional programs (States give priority to regional efforts when disbursing 

grants/financial support). 

Elimination of Duplicative Services: Greater efficiencies can be experienced by 

eliminating any services at one facility if another facility has a greater capability. 

Increased Reliability: Meeting water supply needs with one large source instead of 

numerous small ones. 

Increased Flexibility: New management possibilities - with more opportunities available, 

communities can develop strategies tailored to their specific needs and concerns. 

Enhanced Protection of Public Health: With benefits of economies of scale and potential 

greater access to state-of-the-art technologies, public health and environmental protection 

can be enhanced. 

Skill Improvements: Being able to offer higher salaries could attract better, more 

qualified employees. 

Service Efficiency: While data show that consolidation improves efficiency in other 

services, it is not known what efficiencies might be experienced in the water utility 

service. 

Barriers to Consolidation 

Loss of Power and Community Independence: This is a primary concern of communities 

considering consolidation. Some smaller jurisdictions might have less influence on or 

supervision of a consolidated agency than their larger neighbors. 

Differing Management Goals: While neighboring communities share many common 

needs and concerns, disparities in population, geography, or other characteristics may 

make it difficult for communities to agree on specific regional projects. 

38
Conflicting Regulations: Multistate or multicounty regional programs can face varying 

regulations. 

Cost and Benefit Inequities: Some communities may bear a disproportionate share of 

costs relative to the benefits derived when compared to communities with whom they 

might consolidate services. 

Workforce Reduction: Consolidation often entails employee layoffs, and it may be 

difficult to get support from officials or citizens. Also, difficulties may arise when 

personnel from one utility are tasked with increasing service to a larger population. 

Equipment Reduction: Consolidation might entail disposal of facilities and equipment, 

which often creates resistance from officials, especially where resources might be shared 

across local service agencies (e.g., periodical use of water utility backhoe by town road 

department). 

Public Confusion: Short-term confusion that may arise over service delivery areas or 

service providers. 

Debt: It may take many years before a consolidation is able to pay off all pre-existing 

debts, or at least slow their increase. Communities may not support consolidation if it 

does not immediately bring about tax savings or fee reductions. 

39
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

APR 2 0 2006 

OFFICE OF 

WATER 

MEMORANDUM 

SUBJECT : Much Effort and Resources Needed to Help Small Drinking Water Systems 

Overcome Challenges, Assignment No. 2005-0001358, Draft Report 

FROM: Benjamin H. Grumble, 

Assistant Adminis 

TO: Dan Engelberg 

Director of Program Evaluation 

Office of Inspector General 

Thank you for the opportunity to comment on your Office's draft report, Much Effort and 

Resources Needed to Help Small Drinking Water Systems Overcome Challenges. I will respond 

briefly to the overall findings, with more detailed responses to your recommendations and 

technical comments attached . 

The report reconfirms the finding that many small drinking water systems lack adequate 

technical, managerial, and financial capacity to operate in a sustainable manner. Over the past 

several years, the Environmental Protection Agency (EPA) has been working to implement 

programs from the 1996 Amendments to the Safe Drinking Water Act that were intended to help 

strengthen the ability of these systems to reliably supply safe drinking water. We believe that 

improvements have occurred as a result of efforts at the national, state and local levels . 

EPA has attempted to reduce the burden of regulations on small systems by providing 

flexibility that is available through the law. However, for some systems, challenges will always 

be there because they lack an adequate rate base across which to spread costs . Given that one of 

EPA's primary missions is to protect public health, restructuring the industry to address these 

systems is preferable to changing our public health protection framework in such a way as to 

increase the public's exposure to risk. 

Additionally, many of the financial stresses that water systems have faced and will face in 

the future are unrelated to regulatory requirements . EPA's assessments of drinking water 

infrastructure needs have demonstrated that most of the identified needs are those that a system 

would have to address irrespective of drinking water regulations . As water infrastructure ages, 

systems will need to address the basic infrastructure which allows them to deliver water to 

Internet Address (URL) e http://www.epa .gov 

Recycled/Recyclable 9 Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 

Appendix C
customers. EPA is emphasizing the importance of addressing our nation's water infrastructure 

through the Sustainable Infrastructure Initiative (www .epa .gov/ow. As part of its Better 

Management pillar to the initiative, we will continue to promote restructuring, whether physical 

or managerial, as a strategy to reduce costs and the commensurate burden on ratepayers. 

Thank you again for the opportunity to comment on the draft report . If you have 

questions regarding our comments, please contact Cynthia C. Dougherty, Director, Office of 

Ground Water and Drinking Water, at (202) 564-3750. 

Attachments 
EPA Resaonse to Recommendations 

Recommendation 2-1 : Review the DWSRF process and determine if there are ways to 

simplify it so that small systems have a better opportunity to obtain financing from the Fund. 

Response: When discussing the DWSRF program, it is important to understand that, while the 

national program establishes basic requirements, state programs are in charge of implementing their own programs . Therefore, when looking at processes, there are actually 51 distinct 

programs. EPA agrees that states should review their own processes to simplify and streamline 

them, to the extent possible (given overriding federal requirements) . The law requires that a 

minimum of 15% of DWSRF funds be provided to small systems serving fewer than 10,000 . At 

a national level, the program has far exceeded this level, with 39% of funding going to small 

systems. Because the costs of projects for small systems tend to be smaller, it is also useful to 

look at the percentage of loans going to small systems, since it better reflects the impact of the 

program. Through June 30, 2005, 73% of 4,200 loans made since the program began have been 

provided to small systems . Breaking it down further, 19% of loans have gone to systems serving fewer than 500, 34% to systems serving 501-3,300 and 18% to systems serving 3,301 to 10,000 . 

Looking at those states visited by the IG, 77% of loans in Kansas (45% of funds) and 92% of 

loans in Maine (80% of funds) went to small systems . Massachusetts, however, provided only 28% of its loans to small systems (14% of funds) . While the DWSRF may not be "broken" at the 

national level, it may be appropriate for Massachusetts to reassess its program to determine 

whether it can increase participation of small systems in the program. The Agency will continue 

to work with states to identify best practices and share them with other states that are still facing 

challenges in funding small systems. 

If maintained, we suggest that the recommendation be redrafted to ask EPA to work with states 

to identify successful approaches for working with small systems in the DWSRF program. 

Recommendation 2-2: Determine whether a "one size fits all" approach could be changed to a "regionalized" one. 

Response : While potential occurrence and related exposure to a contaminant may vary by region 

(e .g ., arsenic), the health effects from a contaminant do not. EPA develops regulations to protect the public from potential public health risks due to drinking water, regardless of where they are 

in the country or the size of the system from which they receive service. In doing so, we establish 

regulations that are risk-targeted (as compared to a "one size fits all" approach) . For example, 

the Long-Term 2 Enhanced Surface Water Treatment Rule (LT2) establishes risk-targeted 

treatment techniques requirements to control Cryptosporidium in public water systems using 

surface water or ground water under the direct influence of surface water. Rather than require all 

systems to meet more stringent treatment requirements, the LT2 regulation targets additional 

treatment requirements to those systems that are identified as being at a greater risk of having 

Cryptosporidium . 

42
To reduce burden on small systems, EPA varies schedules and monitoring requirements by the 

system size (and relative population served) . For example, the date for public water systems to 

begin LT2 monitoring is staggered by size, with small systems starting at a later time than larger systems . In addition, to reduce monitoring costs, small filtered systems initially monitor for E. coli for one year as a screening analysis and are only required to carry out more costly 

Cyptosporidium monitoring if their E. Coli levels exceed specified trigger values . 

For the revised arsenic standard, which affects smaller systems to a greater degree than larger systems, the Agency provided all systems with an additional two years to comply with the 

standard (the 2001 rule became effective on January 23, 2006). Additionally, where warranted, 

states have the flexibility to provide eligible systems with exemptions that can provide an 

additional nine years to meet the standard so that they have time to obtain funding to address 

capital needs. 

We suggest that the IG drop this recommendation . 

Recommendation 3-1 : Direct OGWDW to work closer with states to identify and compile 

small system best practices and establish a method for disseminating the information so 

that limited resources to assist small systems can be maximized. 

Response: EPA agrees that states and technical assistance providers are using a variety of 

approaches to reach small systems and that it is important to share successful tactics to ensure 

that we all maximize our resources. Over the past few years, EPA has convened regional and 

national capacity development workshops which bring together EPA staff, state personnel and 

technical assistance providers to share their experiences in working with small systems. We have 

found these to be successful and well-regarded by attendees as a mechanism for sharing 

information . We have also found success in convening annual meetings of recipients of EPA's 

Small System Technical Assistance Center (TAC) grants and other technical assistance providers 

to share information about EPA's priorities and the activities carried out at each TAC. 

Looking forward, we are incorporating a section on innovations and best management practices 

into our Capacity Development Program Evaluation Tool. We are also assessing approaches by 

which we could get feedback directly from small systems on both the usefulness of the tools we 

have developed and what additional tools they need. Finally, one of our goals is to develop an 

improved Internet site that will provide information developed by EPA to support small systems 

and links to other third party providers who also assist small systems. 

We can concur with this recommendation because it reflects efforts the program already has 

underway. 

Recommendation 4-1 : Develop guidance documents directed at small systems in easier to 

understand language. 

43
Response: It is difficult to respond to this recommendation without a better understanding of the 

specific documents to which interviewees were referring. EPA has been making a greater effort 

in the past several years to develop guidance that is targeted to small systems . We have 

developed Quick Reference Guides which provide overviews of each rule and a number of 

documents for our Simple Tools for Effective Performance series . While we will continue to 

work to develop guidance that is geared to small systems, we know that we need to do a better 

job of ensuring the delivery of these products to small systems . In discussions with states, 

systems, and technical assistance providers, it is clear that some are unaware of specific products 

and tools that have been developed by EPA and its grantees . We believe our improved web site 

and interactions with states and technical assistance providers will help us to get the word out on 

existing tools, identify needs, and refine existing information to make it more useful to the 

regulated community. For your reference, we have attached a summary of recent and upcoming 

products for small systems that was provided to state drinking water administrators at a March 

2006 meeting in Alexandria, Virginia . 

If maintained, this recommendation would be more useful if it was more specific . For example, 

it would be helpful if the IG could provide examples of specific guidance that EPA has 

developed for small systems that is not easy to understand . Alternatively, it would be helpful if 

the IG could provide examples of guidance developed by third parties that small systems have 

identified as easy to understand . 

Recommendation 5-1 : Seek ways to work jointly with the CDC to improve the system of 

identifying drinking water related health outbreaks. 

Response: The IG's conclusion notes that "outbreaks can be directly related to small systems, 

but they are not of any great magnitude" . We do not believe it is possible to draw sound 

conclusions regarding the magnitude of outbreaks based on data from the current outbreak 

surveillance system. The CDC's outbreak surveillance summary for 2001-2002 noted that their 

statistics represent only a portion of the burden of illness associated with drinking water 

exposure . As discussed in the IG report and interviews with experts, not all outbreaks are 

recognized, investigated, or reported to CDC or EPA, and studies have not been performed to 

assess the sensitivity of the reporting system. Additionally, the current surveillance system 

pertains only to outbreaks of waterborne illness and therefore might not reflect or correspond 

with trends associated with endemic waterborne illness . 

However, we appreciate the recommendation that EPA work with CDC to improve reporting of 

drinking water related outbreaks. EPA's Office of Water has been working with our EPA Office 

of Research and Development and CDC counterparts on efforts to improve the Waterborne 

Disease Surveillance Systems and other activities to improve the investigation and reporting of 

outbreaks. Specific activities being planned by CDC that EPA has been involved with include: 

transitioning from a paper-based to electronic outbreak reporting system, providing training on 

outbreak investigations, and implementing an Environmental Health Specialist Network pilot for 

drinking water. 

44
If maintained, we suggest that this recommendation be redrafted to recognize that EPA is already 

working with CDC and encourage that those collaborative efforts continue. 

45
Specific Comments on Draft Report 

Abbreviations 

" The text for "MCL" should read "Maximum Contaminant Level". 

Chapter 2 

" Page 5, under Aging Infrastructure, 3rd paragraph, 2°d sentence . The text notes that 

"fewer and fewer grant dollars are available for infrastructure than in prior years" . It is 

unclear to what grant dollars the speaker is referring. EPA had no formal funding 

mechanism for drinking water infrastructure prior to the 1996 SDWA Amendments . If 

the speaker is referring the funds made available through the U.S . Department of 

Agriculture's Rural Development or other state and federal programs, it would be 

appropriate to clarify and verify that fact . 

Page 6. 3`d paragraph under Difficulties in Obtaining Financial Assistance . In considering 

the availability of funding, it is important to remember that there are close to 50,000 

community water systems in the country that serve fewer than 10,000 people . No one 

federal funding program can or should address the needs of all of these systems. Each 

federal program must focus its limited resources on the highest priorities of that program. 

For the DWSRF program, these are projects needed to protect public health and ensure 

compliance with the Safe Drinking Water Act. If the IG did not consider the priorities of 

the funding programs in selecting small systems to interview, then it is not surprising the 

systems visited had not applied for or received assistance . 

" Page 9.1s` paragraph and heading under Regulatory/Compliance Challenges . The heading 

"understanding and burdensome regulations" is somewhat confusing because it appears 

there are either missing words or an extra "and" in the clause . We recommend changing 

it to read "Concerns about Burdensome Regulations" since this seems to capture the 

issues raised in the section. With respect to these concerns, the focus on burden implies 

that there is no underlying public health benefit to drinking water regulations. EPA issues 

regulations to address public health concerns, not for the sole purpose of creating more 

burden for systems . 

" Page 10, Is' paragraph under Compliance with Current Regulations. The I 't sentence 

does not make sense. For the 3`d sentence, the text should read "maximum contaminant 

levels", not "maximum combined loadings". 

" Page 10, 3rd paragraph under Compliance with Future Regulations . This paragraph is 

unclear. If a ground water system does not disinfect, the Stage 2 Disinfection Byproducts 

rule would not be a problem. Should the reference instead be to the "Ground Water 

Rule", which could result in some systems having to disinfect and thus install equipment? 

" Page 11, 2°d paragraph beginning "Third-party organizations described. . ." . The second 

sentence indicates that NEIWPCC is concerned with the new Ground Water Rule because 

7 

46
of disposal issues associated with the resulting effluent. Is the reference supposed to be 

to the "revised Arsenic Rule"? The only "waste stream" that would be associated with 

the Ground Water Rule would be disinfected water, whereas treatment to meet the 

Arsenic Rule could result in a residual that systems would have to manage. 

" Same paragraph . With respect to the comment about "EPA's concept of writing the rules 

as one size fits all", as noted in the response to recommendation 2-2, EPA is working to 

develop regulations that target risks and tailor requirements according to the identified 

risk. It would appear that the speaker is comparing the requirements that small systems 

must meet to "doing nothing at all" instead of comparing the requirements to those that 

larger systems must meet. 

" Same paragraph. In the last sentence, the reference should be to "monitoring", not 

"capital" costs, and to the "Long Term 2 Enhanced Surface Water Treatment Rule (LT2 

Rule)", not the "Stage 2 Rule" . Further, the statement fails to recognize the flexibility 

provided in the LT2 rule which allows small systems to conduct an initial screen of 

monitoring for E. coli . Systems would only have to carry out more expensive testing for 

Cryptosporidium if they exceed a trigger value for E. coli . 

Chapter 4 

" Page 19 . We are not sure of the usefulness of including compliance data from 1992-1994 

in the report unless it is for the purpose of showing trends between that time period (pre1996 SDWA amendments) and the present. 

" Page 20. Tables 4-1 and 4-2 should indicate the years covered by the data. 

" Page 20. lst paragraph under Table 4-1 . Text refers to "maximum levels of contaminants 

(MCL)". It should refer to "maximum contaminant levels" . 

" Same paragraph, last sentence. Given the fact that small systems make up a greater 

percentage of all systems, it is not surprising that they account for more violations . It is 

more useful to look at the systems in violation as a percentage of total systems in a 

specific size class . For example, Table 4-2 shows the number of systems with violations 

of health-based standards by size class. The table below shows the percent of CWS in 

2004 with violations of any health based standard (e.g ., MCL, MRDL, TT, other) by size, 

after correcting for double counting systems that may have a violation of more than one 

contaminant (e .g ., one system may have a violation of the MCL for the Total Coliform 

Rule and a violation of the TT for the Surface Water Treatment Rule) . While individual 

small systems may have a violation of more than one rule, a review of this table would 

seem to indicate that the overall percentage of systems with violations is not so different 

from medium or large systems. 

47
% 

Population 

Population % CWS Served by CWS with Served by CWS Total Population with CWS with FY CWS Size Violations a Violation with Violation Total CWS Served b CWS Violation violation 

2004 1 Very-Small 4,249 2,757 445,449 30,006 4,957,131 9.2% 9.0% 

2 -Small 1,820 1,123 1,601,133 14,212 20,137,604 7.9% 8.0% 

3-Medium 676 410 2,407,717 4,707 27,346,264 8 .7% 8.8% 

4 -Large 709 359 8,745,641 3,541 99,808,668 10.1% 8.8% 

5 -Very-Large 60 28 14,113,921 372 120,246,010 7 .5% 11 .7% 

" Page 20-21 . With respect to text under the section EPA Guidance Hard to Understand, it 

would have been useful to have a better understanding as to whether the speakers were 

referring to products that have been specifically developed for small systems. 

" Page 22 . Last paragraph under Consolidation has Pros and Cons. The first sentence should 

clarify that it is referring to the "Stage 1" Disinfectant/Disinfection Byproducts Rule. 

" Page 25. Last paragraph under Small Systems Overcome Challenges Themselves . In the first 

paragraph, the text indicates that the town commissioner said "the best thing for the system 

was the State Consent Order issued in 1999 because it forced change" . Given this, it would 

seem that the last paragraph should also speak to the diligent efforts of the State drinking 

water program (in addition to the Board and water system staff) . While unfortunate, it seems 

that, in some cases, state oversight and enforcement actions must serve as the driver for 

change. Had the state backed down, it is unlikely the system would have been able to gain 

support for rate increases that are allowing them to upgrade services for the community. 

48
Attachment referenced in response to Recommendation 4-1 

Drinking Water Utilities Team Products to Assist States and Small Systems 

March 2006 Update 

I. STEP Guides (Simple Tools for Effective Performance) 

Setting Small Drinking Water System Rates for a Sustainable Future (December 2005) : As 

part of its on-going efforts to promote sustainable water infrastructure, EPA has released a new 

document to help water utilities consider whether their rate structures sufficiently address the 

costs of ensuring safe and clean water. This document is for owners and operators of small 

community drinking water systems. It is designed to help these owners and operators understand 

the full costs of providing a safe and adequate supply of drinking water to their customers, and to 

guide them in setting water rates that will support these costs . Systems that will find this guide 

useful are small publicly or privately owned entities whose primary business is providing 

drinking water, as well as homeowner associations and manufactured housing communities. 

Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 800-426-

4791 . Please reference EPA Document # 816-R-05-006 . Copies of this document can also be 

obtained from the EPA website at: 

http://www.ena.2ov/safewater/smallsys/ndfs/guide smallsystems final ratesetting ug ide pdf 

Taking Stock of Your Water System: A Simple Asset Inventory Guide for Very Small 

Drinking Water Systems (October 2004) : EPA has developed a STEP Guide to assist very 

small systems in conducting a simple inventory of infrastructure for capital planning purposes . 

This STEP Guide is essential in keeping these types of water systems running properly and 

making sure that the drinking water produced by these systems is reliable, safe and affordable. 

Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 800-426-

4791 . Please reference EPA Document # 816-K-03-002. Copies of this document can also be 

obtained from the EPA website at : 

http ://www.epa.gov/safewater/smalls ys/pdfs/final asset inventory for small s stems pdf 

~ Small Systems Guide to Safe Drinking Water Act (SDWA) Regulations (September 2003) : 

EPA has developed a STEP Guide that explains how current and future SDWA regulations relate 

to each other to achieve public health protection. This workbook focuses on why compliance is 

important, what knowledge is needed in order to comply, and when compliance is required. 

Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-

426-4791 . Please reference EPA Document # 816-R-03-017 . Copies of this document can also 

be obtained from the EPA website at: 

http://www.epa.aov/safewater/smalls ys/pdfs/,izuide smallsystems sdwa pdf 

Asset Management: A Handbook for Small Water Systems (September 2003): EPA has 

developed a STEP Guide that emphasizes how effective asset management is a key element of small 

system sustainability . Various sample worksheets are provided to help small systems organize data 

10 

49
and determine the best approach to maintenance and replacement of major physical assets . Copies 

of this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791 . 

Please reference EPA Document # 816-R-03-016. Copies of this document can also be obtained 

from the EPA website at : 

http ://www.epa.gov/safewater/smallsys/pdfs/guide smallsystems_asset mgmnt.pdf 

Strategic Planning: A Handbook for Small Water Systems (September 2003): EPA has 

developed a STEP Guide to assist small systems in strategic planning. The STEP Guide provides 

worksheets and related tools to help systems organize data and systematically assess their strengths, 

weaknesses, challenges, and opportunities . This Guide is based on the strategic planning 

workshops held around the country in 2000. Copies of this document can be obtained from the EPA 

Safe Drinking Water Hotline at 800-426-4791 . Please reference EPA Document # 816-R-03-015. 

Copies of this document can also be obtained from the EPA website at : 

http ://www .epa .gov/safewater/smallsys/pdfs/guide smallsystems stratplan.pdf. 

Complying With the Revised Drinking Water Standard for Arsenic: Small Entity Compliance 

Guide (One of the Simple Tools for Effective Performance (STEP) Guide Series) (December 

2002) : EPA has developed a guide that is designed to help small drinking water systems understand 

and achieve compliance with the revised Arsenic Rule. The STEP Guide provides information for 

small drinking water systems to help in their selection of appropriate arsenic compliance options. 

Worksheets are also provided along with step-by-step instructions on how to complete them and 

interpret monitoring results . Additional blank worksheets can be requested separately. Copies of 

this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791 . 

Please reference EPA Document # 816-R-02-008A for the STEP Guide and EPA Document # 816-

R-02-008B for additional blank worksheets. Copies of this document can also be obtained from the 

EPA website at : http ://www.epa.gov/safewater/ars/pdfs/regguide/ars final app f.pdf 

Sources of Financial and Technical Assistance for Small Systems (July 2002) : EPA has 

developed a guide that identifies major sources of technical and financial assistance specifically 

targeted at small drinking water systems. Each source listed in this document contains a description 

about the source's mission, types of assistance that can be provided, and contact information. 

Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-

4791 . Please reference EPA document # 816-K-02-005. Copies of this document can also be 

obtained from the EPA website at : http ://www.epa.gov/safewater/smallsys/pdfs/tfa sdws .pdf 

A Small System Guide to the Total Coliform Rule: Monitoring Drinking Water Systems to 

Protect Public Health (June 2001) : EPA has developed a guide that describes the need for 

coliform monitoring and how the Total Coliform Rule (TCR) applies to small community drinking 

water systems serving 3,300 people or less . Worksheets are provided along with step-by-step 

instructions on how to complete them and interpret the results of TCR monitoring. Additional 

blank monitoring worksheets can be requested separately . Copies of these products can be 

obtained by calling the Safe Drinking Water Hotline at 1-800-426-4791 . Please reference EPA 

Document # 816-R-O1-017A for the STEP guide and EPA Document # 816-R-O1-017B for 

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50
additional blank monitoring worksheets. Copies of this document can also be obtained from the 

EPA website at: http://www.epa.gov/safewater/smallsys/small-tcr.t)df 

Coming Soon! 

Stage 1 Disinfection Byproducts (DBP) STEP Guide: EPA is currently developing a STEP 

Guide to guide small systems in achieving compliance with the Stage 1 Disinfectants and 

Disinfection By-Products rule . The STEP Guide will include worksheets and other tabular and 

graphical tools to help systems organize their data and think through compliance options. EPA is 

expecting to have this workbook completed in Spring 2006. 

Restructuring Workbook for Small Water Systems: EPA is currently developing a simple 

workbook to help small drinking water systems with restructuring. The workbook shall include 

worksheets and related tools to assist small systems in their restructuring efforts. Emphasis should 

be place on management and physical consolidation options. Restructuring opportunities in the 

public and private sectors will also be explored. EPA is expecting to have this product completed 

by Spring 2006. 

Total Coliform Rule STEP Guide for Non-Community Water Systems: EPA is developing a 

workbook to help small non-community drinking water systems comply with the Total Coliform 

Rule. EPA is expecting to have this document completed by Spring 2006. 

11. Reports and Manuals 

Arsenic Treatment Technology Evaluation Handbook for Small Systems (July 2003): This 

manual addresses state-of-the-art arsenic treatment for small systems and includes discussion of 

process theory, design parameters, cost estimation, compatibility with existing treatment processes, 

necessary pre- and post-treatment, residual disposal, and process operation and maintenance. 

Detailed example design calculations will be provided. The manual is intended for use by 

consulting engineers, state engineers, and technical assistance providers . Copies of this document 

can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791 . Please reference 

EPA Document # 816-R-03-014. Copies of this document can also be obtained from the EPA 

website at : http ://www.epa .gov/safewater/smallsys/arsenic treatment handbook lo pdf 

Coming Soon! 

Summary of State Operator Certification Programs: EPA is currently developing a 

comprehensive summary document of state Operator Certification programs. The summary will be 

organized to address the key components of EPA's Operator Certification Guidelines . EPA is 

expecting to have this document completed by Summer 2006. 

Compendium of Restructuring Statutes, Regulations, and Policies Report: EPA is currently 

developing a compendium of statutes, regulations, and policies on restructuring . EPA is expecting 

to have this compendium completed by Summer 2006. 

12 

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III. Drinking Water Academy Courses 

Drinking Water Academy Courses on Capacity Development: EPA has developed four courses 

in conjunction with the Drinking Water Academy: Introduction to Capacity Development (February 

2003) ; Developing Technical Capacity (February 2003); Developing Managerial Capacity (July 

2002), and Developing Financial Capacity (July 2002). Copies of these courses are available at : 

http ://www .epa.gov/safewater/dwa/electronic/ematerials html#PWS 

Comins Soon! 

"Introduction to Restructuring for Small Systems" Drinking Water Academy Course: EPA is 

developing a one-day course to help small drinking water systems with restructuring . Emphasis will 

be placed on management and physical consolidation options . Restructuring opportunities in the 

public and private sectors will also be explored in the course. The course will discuss available 

tools to assist small systems in their restructuring efforts . EPA is expecting to have this course 

completed by Spring 2006. 

"Introduction to the Multiple Barrier Approach" Drinking Water Academy Course: EPA is 

developing a one-day course to help all water system personnel understand the barriers to 

contamination: source water protection ; treatment; distribution system integrity ; and public 

awareness. The course will discuss available tools to systems in their important efforts to protect 

public health through safe drinking water. EPA is expecting to have this course completed by 

Spring 2006. 

IV. Quick Reference Guides and Brochures 

Quick Reference Guide for Variances and Exemptions: EPA has developed a Quick Reference 

Guides for Variances and Exemptions Rule. Copies of this document can be obtained from the EPA 

Safe Drinking Water Hotline at 1-800-426-4791 . Please reference EPA Document # 816-F-04-005 . 

Copies of this document can also be obtained from the EPA website at : 

http ://www.epa.gov/safewater/smallsys/pdfs/qrauide smallsystems variance-exemptions .pdf 

Coming Soon! 

Promotional Materials for Best Management Practices: EPA is developing a brochure (4 pages) 

highlighting the capacity building benefits of system performance and optimization initiatives 

through Environmental Management Systems. EPA is expecting to have this document completed 

by Summer 2006. 

"Targeted" Quick Reference Guides: EPA is developing a series of 2-4 page Quick Reference 

Guides for small water systems, including: Distribution Systems and Cross Connections; Roles and 

Responsibilities of Operators; Roles and Responsibilities of Owners; Timing Basics ; Reporting and 

Recordkeeping. EPA is expecting to have these documents completed by Summer 2006. 

V. Tools 

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Preventive Maintenance Tool for Small Ground Water Systems (Card File): EPA has 

developed a simple preventive maintenance tool for small ground water systems. The tool consists 

of index cards that give preventive maintenance tasks to be accomplished on a daily, weekly, and 

monthly basis . The tool also incorporates security-related tasks that could be accomplished in 

conjunction with the maintenance tasks. Copies of this document can be obtained from the EPA 

Safe Drinking Water Hotline at 1-800-426-4791 . Please reference EPA Document # 816-B-04-002 . 

Copies of this document can also be obtained from the EPA website at: 

http://www.epa.gov/safewater/smalls ~Ls/pdfs/logcards smallsvstems preventivemaintainance .pdf (log cards) 

and http://www.epa.gov/safewater/smallsys/pdfs/booket smallsystems preventivemaintainance .pdf (guide 

booklet) 

Coming Soon! 

Interactive Sampling CD for Small Systems: This Interactive CD-Rom tool is being 

developed to provide small system operators with video instruction for sample collection, 

storage, and shipment of contaminants such as: VOC's, IOC's, SOC's, Coliform bacteria, 

Radiological, TTHM/HAA5, and Lead/Copper. PowerPoint slides will also be available for 

trainers . The CD will contain Case Studies (7 short video clips highlighting small systems that 

have had detections of some of these contaminants and their story on how they dealt with each 

situation); the Rule Wizard (allows the user to input system size, source, and treatment type to 

generate the Federal SDWA sampling requirements) ; and a Contaminant List. EPA is 

expecting to have these documents completed by Summer 2006. 

VI. Case Studies 

Case Studies of Sustainable Water and Wastewater Pricing (December 2005): As part of its 

on-going efforts to promote sustainable water infrastructure, EPA has released a new document 

to help water utilities consider whether their rate structures sufficiently address the costs of 

ensuring safe and clean water. This document provides case studies describing how eight 

drinking water systems across the U.S . have approached water pricing. Each case study provides 

background on the system and describes how they are allocating costs and what rates should be 

charged to their customers. EPA collected this information to respond to the increasing 

challenges systems face with maintaining our nation's water infrastructure. This document will 

be made available to water and wastewater utility staff, state regulators, and technical and 

financial assistance providers in order to give new perspectives, and possibly valuable insight, on 

ways to develop and implement sustainable pricing practices. Copies of this document can be 

obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791 . Please reference EPA 

document # 816-R-05-007 . Copies of this document can also be obtained from the EPA website 

at : 

http ://www.epa.,izov/safewater/smallsys/pdfs/guide smallsystems fullcost pricing case studies. 

Small System Partnership Solutions (September 2002) : EPA has developed a product that 

provides an overview of steps that promote partnerships between systems. The product provides 

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examples of successful case studies of systems that have partnered with each other as a solution 

to achieving capacity . Copies of this document can be obtained from the EPA Safe Drinking Water Hotline at 1-800-426-4791 . Please reference EPA document # 816-R-02-022. Copies of 

this document can also be obtained from the EPA website at : 

http ://www.epa.gov/safewater/smallsys/ dfs/capacitydevelopstudyvl5 Rdf 

54
Appendix D 

Distribution 

Office of the Administrator 

Assistant Administrator, Office of Water 

Director, Office of Ground Water and Drinking Water 

Agency Followup Official (the CFO) 

Agency Followup Coordinator 

Audit Liaison, Office of Water 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

General Counsel 

Acting Inspector General 

55