west virginia capacity development strategy · 2006-10-16 · 3.0 capacity development strategy...

WEST VIRGINIA

CAPACITY DEVELOPMENT STRATEGY

Bureau for Public HealthOffice of Environmental Health Services

Environmental Engineering Division

July 31, 2000

WEST VIRGINIA CAPACITY DEVELOPMENT STRATEGY

Table of Contents

1.0 Introduction-Compliance with SDWA Requirements . . . . . . . . . . . . . . . . . . . . . . 1-11.1 SDWA Section 1420(a): State Authority for New Water Systems . . . . . . . . . . 1-11.2 SDWA Section 1420(b): Systems in Significant Noncompliance . . . . . . . . . . . 1-11.3 SDWA Section 1420(c)(2)(A): Methods or Criteria the State Will Use to Identify

and Prioritize Water Systems Most in Need of Improving Technical, Managerialand Financial Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

1.4 SDWA Section 1420(c)(2)(B): Factors that Encourage or Impair Capacity . . . 1-21.5 SDWA Section 1420(c)(2)(C): Description of How the State Will Use Its

Authorities and Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-21.5.1 Assist Public Water Systems in Complying with Regulations . . . . . . . . 1-21.5.2. Assist Public Water Systems in the

Training and Certification of Operators . . . . . . . . . . . . . . . . . . 1-21.6 SWDA Section 1420(c)(2)(D): Description of How the State Will Establish a

Baseline and Measure Improvements in Capacity . . . . . . . . . . . . . . . . . . . . . . 1-21.7 SDWA Section 1420(c)(2)(D): Description of How the State Will Establish a

Baseline and Measure Improvements in Capacity . . . . . . . . . . . . . . . . . . . . . . 1-3

2.0 Capacity Development Strategy Elements for New Water Systems . . . . . . . . . . . 2-1

3.0 Capacity Development Strategy Elements for Water Systems Seeking DWSRFAssistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

4.0 Capacity Development Strategy Elements for Existing Water Systems . . . . . . . . 4-14.1 Existing WVBPH Activities Addressing Capacity Development . . . . . . . . . . . 4-14.2 Establishment of Baseline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

4.2.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-14.2.2 Capacity Assessment Using Existing and New Information . . . . . . . . . 4-2

4.3 Prioritization of Water Systems to Receive Technical Assistance . . . . . . . . . . 4-34.3.1 DWTRF Priority Water Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-44.3.2 Referrals From Capacity Assessment Process . . . . . . . . . . . . . . . . . . . 4-44.3.3 Comprehensive Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5

4.4 On-site and Technical Assistance to Existing Water Systems . . . . . . . . . . . . . . 4-54.4.1 WVBPH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-54.4.2 Third Party Technical Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6

4.5 Measurement of Progress and Improvement in Water System Capacity . . . . . . 4-6

5.0 Stakeholder Involvement in the Development of the Strategy . . . . . . . . . . . . . . . . 5-15.1 Public Participation Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-15.2 Public Interest Groups . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-15.3 Formal Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2

5.4 Tools for Obtaining Public Input . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-25.4.1 Capacity Development Homepage . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-25.4.2 WV Rural Water Association Technical

Assistance for Small Water Systems . . . . . . . . . . . . . . . . . . . . 5-35.4.3 Public Notice and Hearing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-35.4.4 District Offices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-35.4.5 Public Participation Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-35.4.6 Distribution of Public Participation Results . . . . . . . . . . . . . . . . . . . . . 5-4

6.0 Factors Encouraging or Impairing Capacity Development . . . . . . . . . . . . . . . . . . 6-16.1 Factors Encouraging Capacity Development . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

6.1.1 WV Bureau for Public Health Regulatory Programs . . . . . . . . . . . . . . 6-16.1.2 Structural Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16.1.3 Public Service Commission of West Virginia Regulatory Programs . . . 6-26.1.4 Water System Industry Organizations, Governmental Organizations

and Local Government . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-26.2 Factors Impairing Capacity Development . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3

6.2.1 Structural Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-36.2.2 Legal and Regulatory Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-46.2.3 Economic and Demographic Factors . . . . . . . . . . . . . . . . . . . . . . . . . . 6-4

6.3 Mechanisms to Address Capacity Impairment . . . . . . . . . . . . . . . . . . . . . . . . . 6-56.4 Ongoing Determination of Factors Impairing and Enhancing Capacity . . . . . . 6-6

7.0 Implementation Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-17.1 Implementation Within the Agency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-17.2 Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-17.3 Action Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1

7.3.1 Action Plan for Evaluating New Water Systems . . . . . . . . . . . . . . . . . 7-17.3.2 Action Plan for Evaluating Existing Water Systems . . . . . . . . . . . . . . . 7-1

8.0 Communication Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-18.1 Governmental Agency Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-18.2 Water Systems Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-1

Tables

4-1 Existing WVBPH Activity and the Relationship to 1996 SDWA Amendments

7-1 1996 SDWA Capacity Development Reporting Requirements

7-2 Capacity Development Strategy - Timeline for Action

Figures

4-1 WVBPH Existing Water System Capacity Development Baseline Assessment and Referral System

4-2 General Process and Use of Water System Assessment Information

4-3 Process for Referral for On-Site Assistance

4-4 Comprehensive Needs Assessment

Appendices

A Documentation of State Authority for New Water Systems

B WVBPH Water System Permit Application Process

C Financial Capacity Guidance Document for Small Systems

D June 8, 2000 Stakeholders Meeting Participants

E Schedule of Public Participation Activities

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1.0 Introduction-Compliance with SDWA Requirements

The 1996 Safe Drinking Water Act (SDWA) Amendments include requirements for states to: (1)obtain authority to prevent the creation of new nonviable Community Water Systems (CWSs) andNontransient Noncommunity Water Systems (NTNCWSs); (2) to develop a strategy to address thecapacity of all existing water systems; and, (3) to ensure potential Drinking Water State RevolvingFund (DWSRF) recipients have sufficient, technical, managerial, and financial capacity (TMFC) priorto receiving funds (or the DWSRF funds will allow them to develop the capacity they require).

The West Virginia Bureau for Public Health (WVBPH), the State Primacy Agency, has developeda comprehensive Capacity Development Strategy including all of the SDWA-required elements. Thisintroduction highlights the overall WVBPH program or activity related to the stated element. It isnot meant to describe the program or activity in great detail. The details may be found in Sections2 through 8.

1.1 SDWA Section 1420(a): State Authority for New Water Systems

The WV Code, §§16-9(a) and 16-13C-3(a), contains sufficient authority for the WVBPH to regulatewater systems technical, financial, managerial, and operational capacity (comprehensive businessplan). The WV Attorney General certified on November 30, 1998, that West Virginia had adequateauthority to implement SDWA requirements. The US Environmental Protection Agency (EPA)determined on April 19, 1999, the WV program met EPA guidance and statutory requirements.Copies of the Attorney General’s letter and EPA’s letter are provided in Appendix A. The PublicWater Systems Regulations were adopted under the provisions of the state code. The WVBPHWater System Permit Application Process is provided in Appendix B.

1.2 SDWA Section 1420(b): Systems in Significant Noncompliance

In conjunction with the US EPA, the WVBPH developed a list of water systems with a history ofsignificant noncompliance with the SDWA. The list was compiled and submitted to the US EPAprior to August 6, 1997, as required by Section 1420(b)(1). The list of water systems with a historyof significant noncompliance will be updated and submitted to EPA by August 6, 2000.

The WVBPH will prepare and submit to the EPA administrator a report on the success ofenforcement actions and initial Capacity Development efforts. This report will be completed andsubmitted on or before August 6, 2001.

1.3 SDWA Section 1420(c)(2)(A): Methods or Criteria the State Will Use toIdentify and Prioritize Water Systems Most in Need of ImprovingTechnical, Managerial and Financial Capacity

WVBPH has adopted two methodologies for water systems to be prioritized and receive assistance.Assistance will be provided by WVBPH staff or referred to a third party. First, public water systems

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targeted to receive Drinking Water Treatment Revolving Fund (DWTRF) funding will be assessedby WVBPH DWTRF staff to determine if the water system has sufficient technical, managerial, andfinancial capacity. Systems without sufficient technical, managerial, or financial capacity will beprioritized to receive assistance from the WVBPH or third party in preparing a ComprehensiveBusiness Plan (CBP). Water systems will be addressed in the order they appear on the DWTRFpriority list. Secondly, existing water systems will be routinely assessed for technical, managerial,and financial capacity. Water systems needing assistance will be identified and prioritized to receivescheduled assistance. Section 4.3 describes the identification and prioritization of water systems forassistance.

1.4 SDWA Section 1420(c)(2)(B): Factors that Encourage or ImpairCapacity

The WVBPH has many programs already in place to enhance water system capacity. Additionalprograms will be added as part of the Capacity Development Strategy to further enhance capacity.The existing WVBPH programs enhancing capacity are discussed in Section 4.1.

Impairments to capacity development may be classified as structural, legal and regulatory, andeconomic and demographic. There are specific impairments to capacity under each of thesecategories. The impairments and potential strategic factors to address the impairments are inSection 6.0.

1.5 SDWA Section 1420(c)(2)(C): Description of How the State Will Use ItsAuthorities and Resources

1.5.1 Assist Public Water Systems in Complying with Regulations

WVBPH has many existing programs/activities designed to assist water systems in complying withregulations. Existing programs/activities are contained in Section 4.1. Through the use of theDWSRF set-aside funds, WVBPH will be expanding and improving its programs to provide moreassistance. The types of assistance are described in Section 4.4.

1.5.2. Assist Public Water Systems in the Training and Certification of Operators

The WVBPH programs addressing assistance with training and certification are described in Section4.1. Also, as part of the on-site technical assistance contract, a third party may assist a water systemin obtaining the proper training and attaining necessary certification.

1.6 SWDA Section 1420(c)(2)(D): Description of How the State WillEstablish a Baseline and Measure Improvements in Capacity

The WVBPH will use data generated from a National Rural Water Association (NRWA) water

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system capacity survey, existing WVBPH and Public Service Commission (PSC) compliance data,sanitary survey data, and managerial and financial capacity information related to the TMFC of allwater systems to develop an initial baseline. Indicators of TMFC have been selected and criteriaestablished. Recipients of capacity development assistance will be monitored and reassessed todetermine if assistance has resulted in the water system achieving the necessary capacity. All watersystems will be reassessed after five (5) years to measure program improvement over time. TheWVBPH will also obtain information on systems receiving on-site technical assistance and theimprovements those water systems have made. Section 4.0 describes the baseline and measures ofimprovement process.

1.7 SDWA Section 1420(c)(2)(D): Description of How the State Will Establish a Baselineand Measure Improvements in Capacity

WVBPH has an on-going association with a diverse group of stakeholders. Individuals wereprovided opportunities for input into the strategy development process and may be consultedregarding implementation. Stakeholder involvement is discussed in Section 5.0.

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2.0 Capacity Development Strategy Elements for New Water Systems

The Safe Drinking Water Act Amendments of 1996 (the Amendments) adopted significant changesin the Safe Drinking Water Act (SDWA). Of particular importance here, the Amendments requireStates to adopt and implement programs to ensure water systems have the capability to comply withexisting and anticipated drinking water regulations. These new provisions, known as CapacityDevelopment, mark the first time the Federal government has explicitly required States to take actionsto ensure water systems will have the financial, technical and managerial resources required toprovide safe and reliable water service to the public. Essentially, this capacity or capability will helpassure better infrastructure stewardship.

Section 1420(a) of the SDWA requires each state to obtain: “...the legal authority or other means toensure that all new community water systems and new non-transient non-community water systemscommencing operation after October 1, 1999, demonstrate technical, managerial, and financialcapacity with respect to each national primary drinking water regulation in effect, or likely to be ineffect, on the date of commencement of operations”. In other words, this section of the SDWArequires West Virginia to have the ability to prevent new water systems from beginning operationunless they have the technical, managerial, and financial capacity to provide safe and reliable service.This provision applies to both CWSs and NTNCWSs.

In West Virginia, all proposals to create a new water system must meet certain statutory andregulatory requirements. Section 16-1-9 of the West Virginia Code states: “No person, firm,company, corporation, institution, or association, whether public or private, county or municipal,shall install or establish any system or method of ...water supply, ...without first obtaining a writtenpermit to install or establish such system or method from the commissioner of the bureau of publichealth...” The WVBPH implements this section through issuance of a permit to construct.

The WVBPH requires a Comprehensive Business Plan (CBP) for:

• Development of a new water system.• Transfer of ownership of an existing water system regulated by the Public Service

Commission.

Details of the application process are provided in Appendix B.

In addition, prior to receiving a permit to construct, the plans and specifications must meet WVBPH’sexisting Design Standards for Public Water Supply Systems to ensure the new systems are properlydesigned. The application process for a permit to construct also includes an assessment of thefinancial and managerial capacity of a water system. Adequate financial and managerial capacity toensure facilities will be operated and maintained is required for a water system to receive a permit toconstruct.

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3.0 Capacity Development Strategy Elements for Water Systems Seeking DWSRFAssistance

The SDWA Amendments of 1996 included a provision for the federal government to providecapitalization grants to each state to initiate a DWSRF program dedicated to funding drinking waterprojects. The DWTRF program has been established in West Virginia to administer DWSRFassistance. The DWTRF program is required to ensure water systems receiving DWSRF funds havesufficient TMFC.

• SDWA in 1452(a)(3)(A) states: “... no assistance shall be provided to a public water systemthat - (I) does not have the technical, managerial and financial capacity to ensure compliancewith the requirements of this title; or (ii) is in significant noncompliance with any requirementof the national primary drinking water regulations or variance”. However, a water systemowner may receive assistance if use of the funds will ensure compliance or if the systemowner agrees to undertake appropriate changes in operations (including ownership,management, accounting, rates, maintenance, consolidation, alternative water supply, or otherprocedures) to assure compliance.

• Systems targeted to receive DWTRF monies will be assessed by the WVBPH’s DWTRF staffto determine if the system has sufficient TMFC. Systems not having sufficient TMFC will berequired to complete an acceptable Comprehensive Business Plan. The plan will be reviewedand approved by DWTRF staff prior to funding. System owners needing assistance indeveloping a plan will be referred to a third party for assistance in the order they appear onthe DWTRF priority list. Any system on the Significant Noncompliance (SNC) List will notreceive assistance unless the assistance will enable the water system to return to compliance.

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4.0 Capacity Development Strategy Elements for Existing Water Systems

4.1 Existing WVBPH Activities Addressing Capacity Development

Prior to the 1996 SDWA Amendment requirements WVBPH already conducted many activitiesrelating to water system capacity development. These activities were not typically considered“capacity building” activities and were not packaged together as part of an overall capacitydevelopment program. In the preparation of the Capacity Development Strategy, it was importantto determine the current activities related to capacity development, how they impacted TMFC, andhow WVBPH coordinates these activities.

Table 4-1 presents activities dealing with water system capacity development and how those activitiesrelate to the new SDWA capacity development requirements. This is not meant as an exhaustive listof all of the activities within WVBPH, but rather those activities relating in some manner to capacitydevelopment.

As Table 4-1 illustrates, WVBPH conducts many activities encouraging water system capacity andassisting in the identification and prioritization of water systems needing TMFC assistance. WVBPHalso conducts many activities generating data needed to establish a baseline and measure progress.

4.2 Establishment of Baseline

4.2.1 General

As part of the process of determining the basic capacity needs of water system, prioritizing the watersystem for technical assistance, and measuring improvement over time, a baseline assessment mustbe completed and baseline capacity of all existing water systems established. The baseline capacityof all water systems will be established using existing information and new information the State willobtain/develop as a part of this capacity development strategy.

The primary source of new information will be a self-assessment survey developed by the NRWA.In July, 2000 the self-assessment survey was sent to all water systems by the WVRWA. The surveyconsists of relatively simple, generally yes/no questions to be answered by water system personneland returned to WVRWA. Where necessary, WVRWA and WVBPH personnel will provideassistance to water systems to ensure proper completion of the survey. The survey includes questionsfocusing on all aspects of water system capacity, technical, managerial and financial. The NRWAsurvey information, in conjunction with existing WVBPH and PSC compliance data, sanitary surveydata, and managerial and financial capacity information will be used by WVBPH to establish the initialbaseline. The baseline assessment for CWSs and NTNCWSs will be accomplished by August 6,2002.

CWSs and NTNCWSs are of immediate concern because of the continuous, long term exposure ofusers to many contaminants with the potential to cause chronic illness or disease. Therefore, transient

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noncommunity water systems (TNCWSs) will not be included in the initial baseline assessment. Thiswill enable the WVBPH to focus its limited resources on the CWSs and NTNCWSs. Capacity issueswith TNCWSs will initially be addressed on an as needed basis. In the future, as capacity problemswith CWSs and NTNCWSs are resolved and more resources become available, additional emphasison TNCWSs is anticipated.

4.2.2 Capacity Assessment Using Existing and New Information

The capacity assessment process will be used to obtain data and updates on water systems. It is anapproach linking NRWA survey capacity assessment data, compliance monitoring data and sanitarysurvey data to determine general TMFC. The information obtained from this type of comprehensiveassessment is multi-purposed. It is intended to:

• Establish a baseline.• Provide a means of monitoring improvement over time.• Establish a prioritized list of water systems needing TMFC assistance.• Enable WVBPH to direct personnel and money where they are most needed and effective.

The baseline assessment takes into account four factors:

• The water system compliance factor.• The water system condition factor.• The water system managerial and financial capacity factor.• The future regulation impact factor.

This approach is described by the following equation and illustrated Figure 4-1.

A + B + C + D = Overall Capacity Assessment

Where: A = Water System Compliance Factor

B = Water System Condition Factor

C = Water System Managerial and Financial Capacity Factor

D = Future Regulation Impact Factor

The sum of the four factors represents the Overall Capacity Assessment and will be used to catagorizewater systems as high, moderate, or low priority. The basic type of information and the source ofinformation for each factor are described below. Figure 4-2 illustrates the general process and useof the water system capacity assessment.

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4.2.2.1 Compliance Factor (“A”)

The Water System Compliance Factor is the water system’s ability to meet current SDWArequirements, both in terms of actual maximum contaminant level (MCL) and microbial violations andmonitoring/reporting violations. This information provides some insight into the water systems abilityto consistently protect public health and comply with regulations.

Data for this component will come from the NRWA survey and the existing PWS database. Thisdatabase contains basic water system information and the compliance history. Currently data is easilyaccessible for all water systems. The Water System’s Compliance Factor inherently addresses somecomponents of the managerial, technical and operational capacity factors.

4.2.2.2 Condition Factor (“B”)

The condition factor is the physical condition of the water system infrastructure used to treat anddistribute water to the system’s customers. Data for this component will come from the NRWAsurvey and WVBPH Sanitary Surveys. Sanitary Surveys are currently performed periodically on allwater systems. The surveys contain basic information regarding the system condition, includingoperation and maintenance data.

4.2.2.3 Managerial and Financial Capacity Factor (“C”)

The managerial and financial capacity factor is the water systems administrative capability (e.g.,adequacy of staffing and organization, ownership accountability, etc.) and the adequacy of systemfunds for achieving and maintaining compliance. Data for this component will come from the NRWAsurvey and data currently collected by WVBPH. Information collected by the WV Public ServiceCommission (PSC) will also be valuable for assessing this capacity factor (for facilities regulated bythe PSC). However, in order to fully evaluate water systems adequately for managerial and financialcapacity, new information may have to be obtained through a sanitary survey.

4.2.2.4 Future Regulation Impact Factor (“D”)

The future regulation impact factor is the water systems capacity to meet selected new regulations.Data for this component will come from the NRWA survey and WVBPH staff. The followingproposed regulations will be evaluated: Operator Certification, Interim Enhanced Surface WaterTreatment Rule (IESWTR), Stage 1 Disinfection/Disinfection By-Products Rule and the GroundWater Rule.

4.3 Prioritization of Water Systems to Receive Technical Assistance

Water systems will be prioritized for targeted on-site assistance using a two-component approach.The two components are: (1) DWTRF Priority System, and (2) Water systems referred through thecapacity assessment process. The lists developed by DWTRF and referred from the capacity

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assessment process will funnel into the WVBPH Infrastructure/Capacity Development Section(ICDS) to determine the need for, and type of, on-site assistance. A diagram illustrating prioritizationis provided in Figure 4-3, Process for Referral for On-Site Assistance. A description of each of thecomponents is provided in the following subsections.

4.3.1 DWTRF Priority Water Systems

Prior to receiving DWTRF money, the water system must demonstrate they have sufficient TMFCor they must demonstrate the DWTRF money will enable them to develop sufficient capacity. Theprocess of assessing whether systems have sufficient capacity was described previously in Section 3.0.The water systems targeted annually for DWTRF funding will be assessed by DWTRF staff.Based on the assessment of the DWTRF targeted systems, the water systems needing assistance willbe referred to the ICDS to be added to the list of water systems needing on-site assistance. This listwill be prioritized in the order the water systems fall on the DWTRF priority list. In addition toreviewing the list of annually targeted water systems, the Inventory and Assessment Report compiledby the WV IJDC will be reviewed. This report is prepared every three years to inform the governorand legislature of infrastructure needs in the state.

4.3.2 Referrals From Capacity Assessment Process

Based on the capacity assessment process described in Section 4.2, systems will be assessed forcapacity. A list of systems requiring assistance will be prepared and prioritized by ICDS. Theassistance may be related to technical, managerial, or financial capacity deficiencies. ICDS willsubdivide the list of water systems into two categories, those with site specific capacity developmentdeficiencies and those with global capacity development deficiencies. This subdivision will ensurelimited capacity development assistance resources are used in an effective and efficient manner.

4.3.2.1 Site Specific Capacity Development Deficiencies

Site specific capacity development deficiencies are those associated with a single water system. Sitespecific deficiencies will be addressed by targeting systems by the ICDS. The ICDS will have thediscretion of altering the order of the initial priority list, if there are circumstances justifying themovement of one system ahead of another. Following identification of a water system for site specificassistance, ICDS will determine if the water system is willing to accept capacity developmentassistance, further define the needs of the water system and match assistance tools and assistanceproviders to address the identified needs. The District Office will be consulted prior to any referralto a third party.

4.3.2.2 Global Capacity Development Deficiencies

Global capacity development deficiencies are those associated with drinking water systemsthroughout the state, in a specific geographic region, or sharing a common deficiency best addressedas a group rather than on a system by system basis. During the referral assessment process, ICDS

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will identify water systems with global capacity development deficiencies. These systems will bereferred to the WVBPH Oversight Committee. The Oversight Committee will consist of themanagers of the four sections of the Office of Environmental Health Services, EnvironmentalEngineering Division (EED): Source Water Protection Section manager; ICDS managers; DistrictOffice Coordination manager; and, Regulatory Development and Compliance manager. Dependingon the nature of the global deficiencies needing addressed, the Oversight Committee may solicit theinput from numerous other sources having an interest in solving, or tools potentially helpful forresolving, the identified global deficiency. Global deficiencies will be addressed by prioritizing andtargeting groups of water systems with global deficiencies by the Oversight Committee.

4.3.3 Comprehensive Evaluation

The ICDS, with the cooperation of the District Office staff, will arrange for a comprehensive needsassessment of each drinking water system with a high priority designation. This assessment willidentify all the technical, managerial and financial issues for each system. The initial part of theneeds assessment is an evaluation to verify existing data is accurate. This confirms the system is ahigh priority for capacity development assistance. Once completed, the designated support staffcomplete the needs assessment process. Figure 4-4 illustrates the comprehensive needs assessmentprocess.

4.4 On-site and Technical Assistance to Existing Water Systems

On-site and technical assistance may be provided to the system by WVBPH or a third party. TheWVBPH assistance is a continuation of existing, ongoing assistance services WVBPH provides towater systems. Third party assistance is provided through existing contractual agreements or otherstate, federal or non profit entities. Third party assistance provides addition resources for a greaternumber of visits and more services. The systems receiving on-site assistance from a third party willbe selected by the ICDS from the prioritized list, as described above, and must be willing to acceptthe assistance. In this section, a distinction is made between technical assistance (including technical,managerial, and financial aspects) provided without actually visiting a system and on-site assistance.The majority, if not all, of the assistance provided by a third party will be on-site assistance, while theWVBPH assistance is a mixture of both types.

4.4.1 WVBPH

Currently WVBPH provides on-site and technical assistance in many ways. Assistance may comefrom the District Office personnel or the Central Office personnel. The assistance may be simple(e.g., answering a question over the phone) or involved assistance, such as providing informationneeded to complete a Comprehensive Business Plan. The assistance includes all of the factors,technical, managerial, and financial. WVBPH may become aware of the need for assistance throughindividuals calling to request assistance, through data gathering efforts, customer complaints, referralsfrom other government agencies, or other means. WVBPH’s on-site assistance is provided throughthe Sanitary Survey program. WVBPH on-site visits allow opportunities for unlimited technical

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assistance to owners/operators.

The WVBPH has developed a Financial Capacity Guidance Document for Small Systems (GuidanceDocument). The Guidance Document breaks the water system financial capacity assessment into astep by step process, minimizing the time and effort necessary for a small system to develop anadequate financial plan. The Guidance Document is designed to be completed by the water system.However, where necessary WVBPH will provide assistance. A copy of the Guidance Document isproved in Appendix C.

4.4.2 Third Party Technical Assistance

The SDWA Amendments allow states to use funds from the DWSRF for various program activitiesincluding technical assistance and capacity development. The WVBPH has chosen to use some ofits set-aside funds to contract with a technical assistance provider to perform on-site assistance forwater systems and to develop and present seminars covering technical, managerial and financial topicsto promote and assist with Capacity Development.

4.5 Measurement of Progress and Improvement in Water System Capacity

Updated data for the four factors (compliance, condition, managerial and financial capacity, andfuture regulation impacts) will be collected in calendar year 2005 for all water systems to assess theoverall effectiveness of the Capacity Development program. This time frame was chosen because thistype of effort may not show measurable improvements for several years until the on-site assistanceand other WVBPH programs related to capacity development have had a chance to make an impact.After four to five years, however, WVBPH should see measurable improvements. The reassessmentof water systems will be conducted in a manner similar to the baseline assessment process used toestablish the baseline (see Section 4.2). The reassessment will be accomplished with the NRWAsurvey and WVBPH and PSC data.

In addition to measuring improvement by looking at overall system assessment data, WVBPH willbe able to measure improvement by examining the results of its assistance programs. All watersystems receiving assistance through the Capacity Development program will be monitored followingcompletion of the assistance to assess water system progress and improvement in capacity. WVBPHwill have data regarding the number of water systems helped and the progress made in improving thecapacity of those water systems. Data collected by the WVBPH Regulatory Development andCompliance Section (enforcement actions, quarterly SNC List, etc.) will also be helpful in measuringimprovement in water system capacity.

These analyses will indicate to WVBPH whether significant improvements have been achieved bysome assistance programs but little or none by others. In this manner, WVBPH will be able toredirect assistance to the program activities with demonstrated effectiveness.

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5.0 Stakeholder Involvement in the Development of the Strategy

Stakeholder involvement is important for several reasons. Participation in the strategy developmentprocess by groups and individuals having an interest through using, owning, managing, operating orfinancing water systems can improve the quality of the strategy. Stakeholders can improve thedecision-making by providing additional information, diverse perspectives, and sensitivity to keyissues. As a group, the stakeholders can assist in identifying common goals and developing strategiesand actions to meet those goals. It is important in the implementation process for all of thestakeholders to buy into the strategy for it to work over a long period of time. A strategy developedwith a consensual approach can also help to avoid or mitigate problems.

A stakeholder group can also help to improve communication between different groups and withinthe constituencies of the various groups. Much of the work of the Capacity Development Strategywill be educating water system governing boards, managers, operators and consumers. A stakeholdergroup having access to these people through their membership newsletters and other mechanismscan enhance the success of the strategy by providing information and educating their constituents.It is also important to have a continuing dialogue between the stakeholders and the regulatory andfunding agencies as the capacity development strategy is implemented, to understand what elementsare working and what elements are not working. A stakeholder group can work collaboratively tomeet the common goal of developing the capacity of water systems to provide safe drinking waterfor all West Virginia residents.

5.1 Public Participation Strategy

The WVBPH Public Participation Strategy for Capacity Development gathers advice and input fromthe general public, interest groups and associations. EPA guidance requires the states to get publicinput in three general areas of the Capacity Development Program.

Area #1 - How does the WVBPH plan to identify and rank drinking water systems for CapacityDevelopment?

Area #2 - How will the WVBPH help drinking water systems comply with national drinking waterstandards, encourage systems to work together and support training and certification programs foroperators?

Area #3 - How will the WVBPH measure the progress it is making?

This Public Participation Strategy shows how the WVBPH will gather public input, involvestakeholders, and address public comments and advice.

5.2 Public Interest Groups

The WVBPH’s public participation strategy is designed to ensure broad based input is obtained. For

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the purpose of obtaining public input, two types of public groups are identified. The first groupincludes the public represented by formal organizations and associations. This may include thefollowing organizations: WV Rural Water Association, WV Chapter of American Water WorksAssociation, Rural Community Assistance Program, WV Municipal League, County HealthDepartments, Rural Utility Service, National Environmental Training Center, Public ServiceCommission, Water Development Authority, and Infrastructure and Jobs Development Council. Themembership of these stakeholder groups is broad based and includes most of the drinking waterinterest groups in West Virginia. A stakeholders meeting was held at the WVBPH Charleston, WestVirginia office on June 8, 2000, to solicit input on the proposed strategy. A list of the participantsin the June 8, 2000 meeting is provided in Appendix D.

The second target group is the public at large. Obtaining their input demands a special approach.This strategy proposes a number of activities to overcome these problems. This strategy for thegeneral public provides the opportunity for face to face meetings and direct written commentsthrough the mail or internet access.

5.3 Formal Process

All oral or written public input received during the public comment period will be recorded andplaced in a Capacity Development Comment and Response Log. All comments, meeting attendeesand associations will be identified. The WVBPH will document all contacts. These contacts may bewith the general public, the results of formal meetings with associations and the general public or e-mail messages sent to a specially designed homepage for West Virginia’s Capacity DevelopmentProgram.

The WVBPH will solicit comments and positions from all associations willing to participate. Thegeneral public will also have the opportunity to send written comments. A comment and responsedocument (fact sheet) will be developed with the final strategy and be available to any interested partyupon request. A schedule of public participation activities is provided in Appendix E.

5.4 Tools for Obtaining Public Input

The WVBPH uses a number of public participation tools to obtain input. The sections below includethose to be used for receiving public input for the Capacity Development Program.

5.4.1 Capacity Development Homepage

Access to the WVBPH Internet Homepage is a new tool for obtaining public input. Used inconjunction with other public participation tools, it multiplies opportunities to receive public input.The WVBPH will create an interactive homepage for the Capacity Development Program. Alldocuments, meetings, position papers and strategies will be posted at this site. More important, ane-mail station will exist for the purpose of direct instantaneous input.

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The public at large and associations can view the development of our Capacity Development Programand offer comments as the program evolves. The special e-mail feature will direct questions andcomments to a program staff member. This way the staff developing the program will haveimmediate public response to their work products. The public will also have an opportunity to seethe WVBPH’s response to their questions.

5.4.2 WV Rural Water Association TechnicalAssistance for Small Water Systems

The WV Rural Water Association (WVRWA) provides assistance for small water systems. WVRWArepresents a broad cross section of the small water industry in the state. WVRWA will serve as theprimary ongoing focus of public participation for Capacity Development. WVRWA was provideda copy of a preliminary draft of this Capacity Development Strategy and asked to providerecommendations to WVBPH dealing with the development and administration of the CapacityDevelopment Program. WVRWA also participated in the June 8, 2000 stakeholders meeting (seeSection 5.2).

5.4.3 Public Notice and Hearing

This public participation strategy provides for a stakeholders meeting (see Section 5.2) with interestedgroups. The stakeholders meeting was followed by a 30 day public notice and posting of this strategyon the WVBPH web page. Near the conclusion of the public notice, a public hearing was held (seeAppendix E). The purpose of this public hearing was to solicit oral and/or written comments priorto preparation of the final strategy for submission to US EPA.

5.4.4 District Offices

Each District Office was provided a copy of the draft Capacity Development Strategy for review bythe public. The District Office staff directed the public to provide comments to a central officeCapacity Development staff member.

5.4.5 Public Participation Results

A comments and response summary log was maintained and included the following information:

• All comments from the public.

• All responses from the WVBPH.

• All meetings, locations and attendees.

• All association positions.

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5.4.6 Distribution of Public Participation Results

The results of Public Participation shall be provided to the public upon request. All associationsparticipating in the public participation process will be mailed a copy of the final results. Thecomplete document will be posted on the WVBPH’s Internet Capacity Development Homepage forthe general public.

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6.0 Factors Encouraging or Impairing Capacity Development

6.1 Factors Encouraging Capacity Development

There are several positive factors in West Virginia increasing the likelihood water systems will havethe capacity to provide safe and reliable service to the public. Perhaps most important is theconsolidation of most regulatory functions regarding water systems within WVBPH coupled withadequate legal authority for WVBPH to perform those functions.

6.1.1 WV Bureau for Public Health Regulatory Programs

Through the construction permit requirement (see Appendix A), WVBPH has the authority toprohibit the construction of new water systems unable to demonstrate the capability to provide safeand reliable service. The effective use of this authority reduces, if not completely eliminates, theformation of water systems not demonstrating a long-term commitment to providing acceptable levelsof service.

WV Title 64 CSR 4 requires certified water plant operators. The classifications (I-D through IV)required are dependent on the size of the water system. Minimum operator certification requirementsare based on education, experience, and satisfactory completion of an examination administered bythe WVBPH. WVBPH provides regularly scheduled training sessions and examinations for alloperator classifications. Proposed regulations requiring continuing education for operators have beendeveloped and filed with the WV Secretary of State. This continuing education program foroperators will enhance the existing WVBPH operator certification program.

WVBPH District office engineering staff conduct regularly scheduled water system inspections. Inaddition, detailed Sanitary Surveys are conducted every three years (surface water sources), fiveyears (groundwater sources) and ten years (NCWSs using groundwater requiring only disinfection).These inspections encourage adequate capacity by identifying problems or deficiencies in the watersystem and bringing them to the attention of the water system and WVBPH management.

In addition, WVBPH has a comprehensive program for providing technical assistance to existingwater systems. The technical assistance program can be used to help water systems develop thenecessary capabilities. As mentioned earlier in this strategy, WVBPH is developing ways to bettertarget technical assistance and to identify those water systems most in need of certain types ofassistance. This technical assistance program, coupled with WVBPH’s goal of conducting annual sitesurveys of every community water system provides a high level of oversight of water systems in thestate of West Virginia.

6.1.2 Structural Factors

The majority of people in West Virginia are provided drinking water by some branch of localgovernment or the major investor owned utility in the state. In most instances, this helps insure a

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minimum level of planning, management, and financial viability exists.

A major positive factor is West Virginia’s abundant water resources. These water resources aregenerally readily available and appropriate for drinking water use with minimal treatment. The state’sSource Water Protection Program is in place to protect this resource.

6.1.3 Public Service Commission of West Virginia Regulatory Programs

Any public service districts, investor owned and municipal water systems currently serving orproposing to construct facilities also fall under the regulatory jurisdiction of the Public ServiceCommission (PSC). The PSC regulation serves to ensure water systems provide adequate andreliable service at reasonable rates. Responsibilities of the PSC include: making administrativeinterpretations and rulings relating to water system rates and regulations; investigating customercomplaints regarding quality of service; issuing certificates of convenience and necessity; andconducting formal rate increase and quality of service proceedings. Except for municipalities, thePSC may require revision of a system’s rates and regulations. Municipalities set their own rates,subject to review by the PSC following petition from 25% of the customers or a discriminationcomplaint. They may also require service improvements, if necessary to protect the public interest.Water systems failing to comply with PSC regulations can be placed into receivership.

The PSC has the authority to review, and approve or deny, County Commission Public ServiceDistrict (PSD) orders, including orders related to creation or modification of PSDs. Through thisreview and approval process, the PSC can prevent the creation of new, nonviable PSDs.

The state code requires all Public Service District Board Members attend a training course within sixmonths of appointment. This board member training is taught by the PSC, Division of EnvironmentalProtection (DEP) and WVBPH to educate new PSD Board Members of regulatory requirements.Through PSC action in the county circuit court, PSD Board Members failing to attend the requiredtraining can be removed from the board. Although not mandated by law, municipal and associationemployees and board members may, and frequently do, attend this PSC training.

6.1.4 Water System Industry Organizations, Governmental Organizations and Local Government

Through DWSRF funding, WVBPH has developed technical assistance contracts for the followingservices to be performed annually:

• Circuit Riders - A third party will provide on-site operational assistance to water systems withless than 10,000 population.

• Source Water Protection - A third party will provide guidance to water systems in developingand implementing a Source Water Protection Program.

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• Compliance guidance - An independent contractor will provide assistance to water systemsin significant non-compliance.

• Comprehensive Business Plan - A third party will provide hands-on guidance and assistanceto water systems in developing a Comprehensive Business Plan meeting WVBPH guidelines.

A number of organizations and entities of local government encourage Capacity Development. Watersystem industry organizations sponsor workshops and seminars and publish newsletters providingguidance and assistance to members. County government can create PSDs, redraw PSD boundariesor assist in efforts to consolidate or merge systems (with PSC approval). Local planning commissionscan consider adequacy of existing public services, including water, during the approval process forproposed new development. The WVRWA has numerous programs encouraging capacitydevelopment. WVRWA has developed a handbook to assist PSD board members and is in theprocess of developing a similar handbook for municipalities.

Financial resources are available from a number of state and federal sources to improve the technicalcapacity of water systems. These funds, coupled with the IJDC requirements for adequate technical,managerial and financial capacity, encourage adequate capacity through construction and upgradeof viable water systems.

6.2 Factors Impairing Capacity Development

There are several factors working against WVBPH’s goal of ensuring every water system has theTMFC to provide safe and reliable service. This section is not meant to address all possible factorsimpairing the capacity of systems, but rather will discuss a few of the more pervasive factors makingit difficult for systems to develop their capacity to provide quality water service.

6.2.1 Structural Factors

One of the problems in West Virginia, as in many other states, is the large number of independentlyowned and operated small water systems. Many of these are very small, serving fewer than 100homes, and frequently are not actively operated or managed. Many of these very small systems donot have full time employees, professional staff, skilled operators, emergency response plans, capitalreserves, or access to engineering, accounting, and legal expertise. Under normal conditions, manyof these very small systems are able to provide safe water to their customers. However, under stress(equipment failures, main breaks, extreme weather conditions), it is unlikely these systems canrespond appropriately, resulting in a potentially serious threat to the public health and safety.

Another factor making it difficult to improve the capacity of water systems is the lack of profit motivein the operation of most systems. Many systems in West Virginia are owned and operated on a non-profit basis (municipal systems, public service districts, schools, homeowners associations, etc.).While these owners are concerned about public service, protection of the public health and welfare,etc., often their financial needs are competing with other public services. When a business is operatedon a nonprofit basis, it often relies on volunteers to perform key functions, ranging from service on

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boards of directors to assisting in the operation and maintenance of the water system. In addition,some nonprofit systems have little incentive for the operators to authorize new investments, improvethe quality of operation or service or provide a high-quality product.

Finally, the location of a system can also impede its ability to develop the required capacity. Systemslocated in sparsely populated rural areas are unlikely to be able to rely on a regional water provideror service company. Similarly, systems not having access to high-quality raw water will face highercosts and technical challenges not existing where higher-quality raw water sources are available.

There are many instances in West Virginia where low user rates and the resulting poor or marginalwater system are institutionalized, particularly in rural areas. The attitude of the customers and watersystem board members or managers in many of these instances is an impediment to generatingadequate financial capacity to properly maintain the water system and pay for qualified operators.

6.2.2 Legal and Regulatory Factors

Water systems in West Virginia are adequately regulated through the WVBPH permitting system.This regulation generally ensures they meet minimum standards for design, construction andoperation. Prospective new or non-complying system owners are free to choose any ownershipoption to assure compliance with the public water systems regulations and the West Virginia Code.

Except for PSC statutory oversight of County Commission orders related to PSDs, current legal andregulatory factors do not discourage the proliferation of small, stand-alone systems. Such systemsare unlikely to generate substantial reserves of capital, aggressively invest in new equipment andtechnology, or afford the levels of professional expertise common in larger systems.

While the PSC has regulatory authority to require PSD board members to attend training, this trainingis not required for other water system board members or operators. As a result, many water systems(especially smaller systems) lack knowledge of the technical, managerial and financial capacitynecessary to properly operate a water system. This lack of knowledge, combined with the frequent,substantial opposition to any rate increase, has resulted in a number of small, underfunded, poorlymanaged water systems.

Private water systems generally do not have legal or regulatory authority or support for zoning/landuse controls necessary for source water protection. These systems also do not have condemnationpowers to obtain land for facilities (wells, tanks, etc.).

6.2.3 Economic and Demographic Factors

Any discussion of the problems impairing the capacity of systems would not be complete withoutrecognizing varying economic and demographic factors playing a major role in the ability of a watersystem to provide safe and reliable service. If funds were unlimited, there would be few impedimentsto high-quality service by any water system. However, in the real world there are significant limitson the ability of a system to raise rates to generate the funds required to provide reliable service. The

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majority of low interest government funding available for system improvements remains unavailableto private owners.

Systems in areas facing demographic challenges (relatively few people, low income levels, a highpercentage of people with incomes below the poverty level, high unemployment, a high percentageof elderly people) are likely to have water systems with capacity development challenges.

In some instances grants are available to subsidize the cost of construction, upgrade or replacementof failing water systems. However, the financial condition of the system may affect the eligibility forgrants. As a result, in some instances, a water system may improve the possibility of obtaining grantsto help fund water system upgrade or replacement by having inadequate financial capacity.

6.3 Mechanisms to Address Capacity Impairment

Some methods to address barriers to capacity development are listed below. Resources available tothe State through the Capacity Development Program will be used to monitor the effectiveness ofthese programs and support and expand them, where appropriate. As resources allow, new programsmay be developed, pilot tested and, if effective, implemented where appropriate.

Methods to Eliminate Structural Impairments

• Provide State loans or grants to enable systems to improve their infrastructure.

• Provide funding to encourage the creation and expansion of regional water suppliers(either wholesale or retail).

• Training is available from a number of organizations on a wide variety of capacityrelated topics. Consolidation and/or coordination of these training resources may helpeliminate some structural impairments.

Methods to Eliminate Legal and Regulatory Impairments

• Continue to encourage/require all systems to develop a Comprehensive Business Plan.

• Strengthen the encouragement of the consolidation or merger option through fundingof infrastructure (e.g., DWSRF) and enforcement/compliance actions.

• PSC authority to order PSDs to approach the County Commission and requestconsolidation to create larger, more viable water systems.

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Methods to Eliminate Economic and Demographic Impairments

• Develop incentives for satellite management or other types of regionalization in areaswith economic and demographic challenges.

• Develop programs to assist systems with a large number of low-income customers.

• Educate consumers in low-income areas about their water rates and service.

• Develop mentoring and/or peer review programs.

6.4 Ongoing Determination of Factors Impairing and Enhancing Capacity

As part of the technical assistance contracts WVBPH has developed, reports are sent to WVBPHdescribing the contractor’s activities. The reports will address factors the contractor has experiencedenhancing or impairing system capacity. The contractor will identify additional factors beyond thosealready identified by WVBPH. In this manner, WVBPH will have an ongoing mechanism to identifyfactors impairing or enhancing capacity.

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7.0 Implementation Plan

To achieve long term technical, managerial and financial capacity, the Capacity Development Programmust transfer knowledge, skills and abilities needed by the water system to implement correctiveactions. The goal of the West Virginia Capacity Development Program is to utilize new and existingcapacity development resources to correct identified capacity deficiencies.

7.1 Implementation Within the Agency

WVBPH is responsible for the overall implementation of the Capacity Development Strategy. TheWVBPH will designate a Capacity Development Team Leader responsible for coordinating andimplementing activities associated with TMFC areas with DWTRF, PSC, district offices, third partycontractors, and management.

7.2 Reporting Requirements

The reporting requirements related to the Capacity Development portion of the 1996 SDWAAmendments are shown on Table 7-1.

7.3 Action Plan

7.3.1 Action Plan for Evaluating New Water Systems

The federal deadline for having a comprehensive program for ensuring new water systems have therequisite TMFC was October 1, 1999. By letter dated April 19, 1999, EPA notified WVBPH of theirdetermination that the West Virginia program met the EPA guidance and statutory requirements (seeAppendix A).

7.3.2 Action Plan for Evaluating Existing Water Systems

The SDWA requires West Virginia to have and be implementing a capacity development strategy forexisting water systems no later than August 6, 2000, to avoid losing 10% of its SRF allotment.

The baseline assessment described in Section 4.2.2 will be completed by August 6, 2002. Completeupdates of the baseline assessment addressing all water systems will be done every five (5) years tomeasure system improvements over time and assess Capacity Development program effectiveness(See Table 7-2). All water systems receiving assistance through the Capacity Development programwill be monitored and reassessed following the assistance to determine if the water system isachieving the necessary capacity.

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8.0 Communication Strategy

8.1 Governmental Agency Communication

In the implementation of the Capacity Development Strategy, WVBPH will need to communicatewith other governmental agencies. This communication includes reporting to EPA and the Governorinformation regarding the success of the strategy and the overall improvement to the water systemsin the State. Within WVBPH-EED, staff will need to communicate regularly on the review ofDWSRF applicants and the status of any technical assistance efforts related to the DWSRF applicants.In addition, WVBPH will need to communicate with other agencies funding water systems throughthe IJDC and Rural Utilities Service.

8.2 Water Systems Communication

An important component of the overall strategy is ensuring water systems are aware of capacitydevelopment issues, responsibilities and requirements, and the financial and technical assistanceavailable. There are many mechanisms for information and assistance communications to watersystems, as described below.

• WVBPH has a small system technical assistance contract with WV RWA to provide on-siteassistance.

• The sanitary survey personnel understand the requirements of the Comprehensive BusinessPlans, will be familiar with the Capacity Development Strategy and can inform the watersystems about the program at the time of the survey.

• The third party contractor providing technical assistance developing Comprehensive BusinessPlans has other technical assistance contacts with water systems and can inform them of theStrategy and available assistance.

• WVBPH and WVRWA routinely publish news letters with articles relating to capacitydevelopment.

• The WVBPH, WVDEP, and PSC jointly hold two seminars each year to provide training toPSD Commissioners.

• WVBPH water operator training and certification courses.

• WVBPH and WV RWA Web pages.

• The PSC holds training seminars on selected topics.

• The WVRWA holds training seminars on selected topics.

TABLES

Table 4-1

Existing WVBPH Activity and the Relationship to 1996 SDWA Amendments

Requirements in 1996 SDWA Amendments

ExistingWVBPHActivity

StateAuthorit

yfor NewSystems

Identifyingand

PrioritizingSystems in

Need of T, M& F

Assistance

Factors Encouraging Capacity

How the State Will Use It’s Resources to: Establish

Baselineand

Certification

of Operators

IdentifyPersons

Interested inDevelopingCapacity

DevelopmentStrategy

Methodsto EnsureSystems

Eligible toReceiveDWTRF

Funding HaveSufficient T,

M, & FCapacity

Assistance Complying

withRegulations

Encourage theDevelopment

of Partnership

AssistSystems in

Training andCertificationof Operators

SanitarySurvey

Program/ / / / / /

PlanReviews/Permits

/ / / / / / /

Compliance Monitoring

(WaterQuality)

/ / / / / /

Phase II/VVulnerabilityAssessment

/ / / / /

Compliance/Enforcement

Program/ / / / / /



StateAuthorit

yfor NewSystems

Identifyingand


Need of T, M& F

Assistance

Factors Encouraging Capacity


Baselineand

Certification

of Operators

IdentifyPersons


DevelopmentStrategy




M, & FCapacity

AssistanceComplying

withRegulations

Encourage theDevelopmentof Partnership

AssistSystems in


Public WaterSystem

Database/ / / /

TechnicalAssistanceRelated to

Circuit Rider

/ / / / / / /

TechnicalAssistanceRelated to

Comprehen-sive Business

Plan

/ / / / /

OperatorCertification / / / /

/



StateAuthorit

yfor NewSystems

Identifyingand


Need of T, M& F

Assistance

FactorsEncouraging Capacity


Baselineand

Certification

of Operators

IdentifyPersons


DevelopmentStrategy




M, & FCapacity

AssistanceComplying

withRegulations

Encourage theDevelopment

of Partnership

AssistSystems in


OperatorTraining ByThird Party

/ / / / /

Source WaterAssessment

Program/ / / /

Table 7-11996 SDWA Capacity Development Reporting Requirements

Section When Report To Report By Description

1420(c)(3) Not later than 2 yearsafter the date onwhich a State adopts acapacity developmentstrategy and every 3years thereafter

The Governor - andalso available to thepublic.

The head of the StateAgency with primaryresponsibility to carryout this title in theState shall submit. WVBPH is the stateagency.

Report shall be on theefficacy of thestrategy and progressmade towardimproving thetechnical, financial,and managerialcapacity of publicwater systems in theState.

1420(b)(2) Not later than 5 yearsafter the date ofenactment of thissection and as part ofthe capacitydevelopment strategyof the State

The EPAAdministrator.

State Agency -WVBPH

Each State shall reporton the success ofenforcementmechanisms andinitial capacitydevelopment efforts inassisting the publicwater systems listedunder paragraph (1) toimprove technical,financial, andmanagerial capacity.

1420(b)(related toabove 1420(b)(2)).

August 6, 1997 (and every 3 yearsthereafter)

The EPAAdministrator

State Agency -WVBPH

List of communitywater systems andnon-transientnoncommunity watersystems with a historyof significantnoncompliance, andthe reasons for theirnoncompliance

Table 7-2

Capacity Development Strategy - Timeline for Action

Action Date

Baseline Assessment 8-6-2000 thru 8-6-2002

Adopt Strategy to prevent losing 10% SRF grant 8-6-2000

Submit Strategy to EPA 1420(c) 8-6-2000

1420(b)(1) List Update 8-6-2000

1420(b)(2) Report to EPA 8-6-2001

1420(c)(3) Report to Governor/Public 8-6-2002

Baseline Reassessment 1-1-2005 thru 12-31-2005

1420(c)(3)* Report to Governor/Public 8-6-2005

*1420(c)(3)Reports to the Governor and to the public are due every three (3) years from 8-6- 2005.

FIGURES

Figure 4-1

WVBPH Existing Water System Capacity DevelopmentBaseline Assessment And Referral System

Z Z Z º

AWater System

Compliance Factor(From ExistingContaminant

Monitoring Information&

BWater System

Condition Factor(From Sanitary

Survey & NRWASurvey)

CWater SystemManagerial &

FinancialCapacity Factor

(From SanitarySurvey & NRWA

Survey)

DFuture

RegulationImpact Factor

(NRWASurvey)

Overall WaterSystem

CapacityAssessment

ViolationsvSNCvTreatmentTechniquevFrequent M/RvCCR Failure

v>16 Hour operationvFailure to meet currentdesign/constructionstandards-sourcevFailure to meet currentdesign/Constructionstandards-treatmentvFailure to meet currentdesign/constructionstandards-distributionpipingvFailure to meet currentdesign/constructionstandards-storage

vFrequent CustomerComplaintsvNo CBPvUnmeteredvOperations staff does notmeet Regs.vFacility MapsvCross Connection ControlProgram(approved/effective)vResponsiveness tocorrecting recommendations

Currently cannot meetRegulationsvOperator CertificationvLT1IESWTRvStage 1 D/DBPvGWRvFilter BackwashRecyclevRadon

Priority ReferralSystem

PriorityHigh

ModerateLow

Figure 4-2

GENERAL PROCESS AND USE OF WATER SYSTEM ASSESSMENT INFORMATION

AWater

SystemsCompliance

Factor

BWater

SystemsCondition

Factor

CWater

SystemsManagerial

&FinancialCapacity

Factor

DFuture

Regulation ImpactFactor

Data Entered Into Database

Establish

Measure ProgressOver Time

Report toCommissioner,

Governor, Legislature& EPA

Prioritize WaterSystems for Technical

Assistance

Assist WVBPH inDirectingResources

(Personnel &Financial

FIGURE 4-3

PROCESS FOR REFERRALFOR ON SITE ASSISTANCE

1. SRF TARGETED 2. CAPACITYRECIPIENTS DEVELOPMENT

ASSESSMENTRecipient List PROCESS

Existing Systems

WVBPH INFRASTRUCTURE/CAPACITY DEVELOPMENT SECTION

OVERSIGHTReview and Prioritize Referrals

(Consult with Field Office)

DEVELOP ACTION PROVIDEPLANS FOR PROGRESS

WATER SYSTEMS REPORTS

ON-SITE ASSISTANCEPROVIDER

FIGURE 4-4COMPREHENSIVE NEEDS ASSESSMENT

HIGH PRIORITY DRINKING COMPREHENSIVE NEEDS FAILS TO VERIFY HIGHWATER SYSTEM ASSESSMENT PRIORITY RATING

VERIFIES PRIORITY RATING ANDIDENTIFIES CAPACITY NO FURTHER ACTION

DEVELOPMENT NEEDS

TECHNICAL NEEDS MANAGERIAL NEEDS FINANCIAL NEEDS

CAPACITY DEVELOPMENTASSISTANCE PROGRAMS

IDENTIFICATION OF CAPACITYDEVELOPMENT ASSISTANCE IMPLEMENT IDENTIFIED

PROGRAM AND PROVIDER TO MEET ASSISTANCE PROGRAMTHE NEEDS OF THE DRINKING

WATER SYSTEM

APPENDICES

APPENDIX A

Documentation of State Authority for

New Water Systems

APPENDIX B

WVBPH Water System Permit

Application Process

EW-77 B5/5/99

WEST VIRGINIA BUREAU FOR PUBLIC HEALTHOffice of Environmental Health Services

Environmental Engineering Division815 Quarrier Street, Suite 418

Charleston, West Virginia 25301-2616(304) 558-2981

PUBLIC WATER SYSTEM WELL APPLICATIONForms and Required Information

Please read carefully and submit Four (4) COPIES of the required information. Omission of any ofthe required information will result in the application being denied. PLEASE ENCLOSE A CHECKOR MONEY ORDER for the application fee in the amount of $150 payable to the WVDEPARTMENT OF HEALTH AND HUMAN RESOURCES.

Project Name:_________________________________County:_______________Date:_______

Required:

____ Four (4) copies of completed and signed form EW-100. If there is no engineer, strike outengineer, and write in the WV Certified Well Driller’s name, address and certification number.

____Provide the name, address, and certification number of the WV Certified Well Driller, if notprovided on form EW-100.

____Four (4) copies of the section of the US Geological Survey (USGS) topographic map showingthe approximate location of the proposed water well(s) and the property lines of the facilities beingserved (8 ½" x 11" photocopy will be acceptable).

____Four (4) copies of a brief description of what the proposed water well(s) will serve and howthe well(s) is to be constructed (casing, pressure grouting of casing, size of well, etc.). Note that thewater well casing must be above the 100 year flood plain or be protected from a 100 year flood event.If the proposed well is to replace an existing well, please explain, in detail, the problem with theexisting well (surface water contamination, chemical or biological contamination, loss of production,improper well construction, etc.).

____Four (4) copies of a sketch of the location of the proposed well(s) site showing the distance(feet) to and the location of any existing water wells, sewage facilities (sewer lines, septic tanks,septic tank fields or beds, privies, sewage treatment plants, etc.), buildings, roads, streams, creeks,rivers, drain lines, barnyards/feeding areas, hazardous chemical storage facilities (gasoline tanks, oiltanks, pesticide tanks, etc.), and any other potential sources of contamination within a 200 feetradius of the proposed water well site.

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Specifications and Contract Documents

____Provide detailed specifications for the sewer and water line materials, such as type of pipe, size,type of joints, pressure ratings for water line and sewage force mains, ASTM designation, NSFdesignation for plastic water lines, valves, fire hydrants, meters, pressure reducing stations, waterstorage tanks, manholes, cleanouts, thrust blocks, sewer line anchors, sewage pump stations, waterbooster stations, controls, structures, etc.

Plans

____Provide a detailed site plan showing the facilities (subdivision lots, mobile home lots, buildings,commercial lots, schools, camp sites, etc.) to be served, all dimensions and property lines, locationof existing or proposed sewer and water lines, location of manholes and cleanouts, location ofexisting and proposed sewage pump stations and water booster stations, location of existing orproposed water wells, location of existing water and sewage treatment facilities, location of waterstorage tanks, location of valves, location of sewer line anchors, location of sewer and watercrossings, location of road bores, size and length of sewer and water lines, etc. Also, provide the sizeof the existing sewer and/or water lines.

____Provide detailed profiles of all gravity and pressure sewer lines showing manholes, cleanouts,existing and finished ground level, manhole and cleanout invert elevations, grade of gravity sewers,road bores, water crossings, size and length of gravity and pressure sewer lines. Recommend detailedprofiles of water lines be provided showing existing and finished ground elevations, depth of waterlines, valves, fire hydrants, sewer crossings, road bores, size and length of water lines, etc.

____All plans must be signed and stamped by a West Virginia Registered Professional Engineer.

____Plans shall not be less than 18"x 24" in size or greater than 27"x 40"

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Addendum To Permit Applications To Install, Extend, OrModify A Community or Non-Community, Non-TransientPublic Water System-Capacity Development Requirements

General: All community and non-community, non-transient public water systems arerequired to meet the United States Environmental Protection Agency requirementsfor capacity development. These water systems are to be evaluated by the WestVirginia Bureau For Public Health, Office Of Environmental Health Services,Environmental Engineering Division for managerial, technical and financialcapability. The following will be required when a water system applies for a permitto install, extended or modify their facilities:

Managerial:

*1. Name of the water system____________________________________(municipality, public service district or water utility regulated by the WV Public Service

Commission)

Address of the water system__________________________________ __________________________________ __________________________________

Telephone No.:_______________ Fax No.:_______________ E-mail:______________

*2. If the water system is not a municipality or public service district or a utility regulatedby the West Virginia Public Service Commission, such as a privately owned or property owner’sassociation owned system, provide the following:

Name of the owner________________________Title (ie: president, etc.)_____________Additional contact ________________________ Title ______________________Address of the owner_____________________________________________

______________________________________________ ______________________________________________

Telephone No.:________________ Fax No.:______________E-mail:_______________

3. Who or what governing body is or will make managerial decisions for the watersystem, such as the hiring of certified operators, user fees, budgets, operation and maintenanceexpenses, equipment purchases, laboratory fees, utility payments, etc.?____________________________________________________________________________________________________

4. Provide a list of any management courses that current managers have attended in thelast three (3) years. (For example: WV Public Service Commission public service districtmembers training courses, WV Bureau For Public Health courses or WV Rural Water Associationseminars, etc.)____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

5. Provide a list of all currently employed water system certified operators, including theirnames, classification, certification number, and expiration date of their certification.(Ifapplicable)_______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

6. Provide a list of all current employees and their job duties, other than the water systemcertified operators, such as management staff, office support staff and operation and maintenancestaff.(If applicable)____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

7. Provide a description of the proposed project, including all materials to be used,number of customers to be served and the purpose of the project. See form No. ES-77 A forforms and required information to be submitted with the application__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Technical:

1. All plans submitted for review and approval must be seal (stamped) and signed by aWest Virginia Registered Professional Engineer. Provide the engineers name and registrationnumber.

Name:_____________________________ Registration No._________________

Telephone No.:_____________ Fax No.:_______________ E-mail:_________________

The following questions only apply to existing public water systems:

2. Has the water system been under WV Bureau For Public Health or WV Public ServiceCommission administrative orders to correct deficiencies relating to water quality or service in thelast five (5) years? Yes_____ No____

If yes, provide details, including the date of the order(s), description of the violation,whether you are back in compliance and if not, why not?_________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

3. Is the water system current with all WV Bureau For Public Health sampling and testingrequirements? Yes_____ No____

If no, provide details of non-compliance._________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

4. Has the water system been required to perform a Public Notice in the last five (5) years? Yes____ No____

If yes, provide details.________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

5. Has the water system received certification from the Source Water Assessment andProtection Program? Yes___ No___ If no, explain why not. If you have any questionsconcerning this certification, please contact the Source Water Assessment and ProtectionProgram at (304) 558-2981_________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

6. If the water system water source is an existing well(s), is there an approved WellheadProtection Program? Yes___ No____

If no, please explain why not. If you have any questions, contact the Source WaterAssessment and Protection Program at (304) 558-2981.___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

7. If the WV Bureau For Public Health has completed a sanitary survey of the existingsystem, have all of the noted deficiencies in the sanitary survey been corrected? Yes___ No____

If no, please explain why not.________________________________________________

__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Financial:

1. How will this new water system project be funded? For example: bonds, loans, grants,user fees, or private funds? Provide details._______________________________________________________________________________________________________________________________________________________________________________________________________

2. Has the water system prepared an annual budget? Yes___ No____ (Note that all watersystems are required to develop an annual budget.) If yes, provide a copy. If no, explain whynot._____________________________________________________________________________________________________________________________________________________________________________

The following questions only apply to existing public water systems:

3. Has the water system been audited in the last two (2) years? Yes___ No____ If yes,provide a copy of the audit.

4. If the water system is under the jurisdiction of the WV Public Service Commission,have annual reports been prepared? Yes___ No___ If yes, provide a copy of the most recentreport. If no, explain why not._________________________________________________________________________________________________________________________________________________________________________________________________________________

5. Does the existing water system have outstanding long term debt? Yes___ No___ Ifyes, provide details of the type, balance and status._______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

6. Has the existing water system been delinquent on any private, state or Federal longterm debt? Yes___ No____ If yes, explain in detail.______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

7. Is the public water system out of compliance with any current lenders? Yes___ No___If yes, explain in detail._____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

V:\Capacity Development EPA submittal Aug 6, 2000\Appendix_B_capacitydevelopment.421.wpd

APPENDIX C

Financial Capacity Guidance

Document for Small Systems

West Virginia Departmentof Health and HumanResources

Bureau for Public HealthOffice of Environmental Health Services815 Quarrier Street Suite 418Charleston, WV 25301-2616(304) 558-2981

i

Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1How to Use this Guidance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Step One: Determine the Cost of Infrastructure Replacement and Upgrades . . . . . . . . . . . . . . . . 2Worksheet 1: Condition and Cost of Major Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . 3Worksheet 2: Planning for Future Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Follow-Up Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Table 1: Average Life Expectancies of Water System Equipment . . . . . . . . . . . . 5

Step Two: Develop a Capital Improvement Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Worksheet 3: Instructions for Preparing a Capital Improvement Plan . . . . . . . . . . . . . . 7

Table 2: CIP Annual Cost per Expense Category . . . . . . . . . . . . . . . . . . . . . . . . 7

Step Three: Create a System Budget . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Worksheet 4: Water System Budget . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Follow-Up Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Step Four: Complete a 5-Year Budget Projection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Worksheet 5: 5-Year Budget Projection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Helpful Hints for Projecting Revenues and Expenses . . . . . . . . . . . . . . . . . . . . . . . . . . 16

1

L If you are not sure if this guidanceapplies to you, please contact the Office ofEnvironmental Health Services WestVirginia at (304) 558-2981 to discuss therequirements pertaining to your system.

Introduction

Background

The 1996 Amendments to the Safe Drinking Water Act (SDWA) introducedthe concept of capacity development. Simply stated, a water system with

capacity has the technical, managerial, and financial resources to reliably produce and deliverwater meeting all national primary drinking water regulations in effect, or likely to be in effect. This guidance focuses on your system’s financial capacity, or your system’s ability to acquire andmanage enough money to achieve and maintain compliance with all SDWA and Staterequirements.

Community water systems (CWSs) andnontransient, noncommunity water systems(NTNCWSs) must secure a permit from theDepartment of Health (the Department)before constructing, awarding a contract toconstruct, modifying, or extending a publicwater system. In order to receive this permit,you must demonstrate to the Department thatyou have the financial resources to manageand operate your system in accordance with the law. This guidance will help systems preparesome of the materials to be submitted to the State and is designed to help owners and operators ofnew or existing systems to plan for, achieve, and maintain financial capacity.

How to Use this Guidance

Systems are required to develop, among other things, a business plan including a capitalimprovement plan (CIP), a budget, and a 5-year budget projection demonstrating financialcapacity. The Drinking Water State Revolving Fund program will review your business plan toevaluate your system’s financial capacity. This guidance describes a 4-step process you can useto prepare the financial information you need to submit to the State. Easy-to-understanddescriptions of basic budgeting principles will lead you through the process of analyzing thefinances of your system. In this process, you will be asked to:

C Examine the cost of replacing and updating your system’s infrastructure andfacilities.

C Begin to develop a Capital Improvement Plan (CIP).C Complete a System Budget.C Complete a 5-year Budget Projection.

While this process may seem overwhelming, don’t worry! This guidance breaks systembudgeting into a manageable, step-by-step process that can be completed with a little time andeffort. There are also follow up questions providing additional guidance. You should completethe worksheets to the best of your knowledge and ability and seek help if needed.

1 Example: Assume your system’s transmission main is 10 years old, has a useful life of 30 years, and willcost $2,000 to replace. Subtracting the main’s age from its useful life will result in a total of 20 years of useful liferemaining. Dividing the replacement cost by the useful life remaining ($2,000/20 years) yields an annualized costof $100 per year. In other words, if you were to put $100 in the bank every year for the next 20 years, you willhave saved $2,000 (the cost of a new transmission main) by the time the old pipe will likely need replacing(excluding any interest you may earn on your savings).

2

Step One: Determine the Cost of InfrastructureReplacement and Upgrades

You will probably need to replace parts of your system within the first 10years of operation— and consistently thereafter— as equipment wears out. Failure to replaceaging parts or facilities could threaten the quality and safety of your system’s water and pose risksto public health. By planning for future needs, you will reduce the possibility of facing largeunexpected costs you and/or your customers may not be able to afford.

Worksheet 1 is designed to help you start planning, funding, and carrying out necessaryequipment replacements and improvements. When complete, the chart will help you determine components most in need of replacement and approximately how much system upkeep will cost. To complete the table:

1) Change the worksheet to match your own system. Add more components if necessaryand remove listed equipment you do not have.

2) Estimate each component’s age and useful life (the length of time a piece of equipmentis expected to function reliably and safely).

3) Estimate the remaining useful life of each piece by subtracting the equipment’s agefrom its useful life.

4) Find out how much it would cost to replace the component today (talking to partsdistributors or other systems may help you with this).

5) Calculate how much you should put aside each year (the annualized replacement cost)by dividing the replacement cost of each piece by its remaining useful life. 1

6) Add up the last column to find out the total annualized cost of maintaining yoursystem. This total represents the amount of money you need to set aside to cover theexpected replacement cost of your entire system.

3

Worksheet 1: Condition and Cost of MajorEquipment

Major Equipment

A B C D E

EstimatedAge

Useful Life

RemainingUseful Life

(B-A)

ReplacementCost

AnnualizedCost

(D÷C)

1. Intake Structures

2. Wells and Springs

3. Galleries andTunnels

4. Transmission Mains

5. Treatment Equip.

6. Storage Equip.

7. Pumps

8. Distribution Pipes

9. Valves

10. Service Lines

11. Hydrants

12. Backflow Prevention

13. Lab/MonitoringEquip.

14. Tools, Shop Equip.

15. Hoses

16. Meters

17. Other

Total Annualized Cost(Sum of E1 thru E17)

As you can see, replacing equipment will not be cheap. Setting aside enough money to replaceevery component (the total annualized cost you calculated above) will probably not be possible. Worksheet 2 asks you to think about the most important components of your system or those inthe poorest condition. Keep these worksheets close at hand when you begin to work on thebudget worksheets later in this document.

2 Determine annualized costs by completing Worksheet 1 and copying Column E figures here.

4

Worksheet 2: Planning for Future Capacity

Because it will be hard to save enough money to replace each systemcomponent, use this worksheet to help you think about the cost of replacingthe most critical or worn-down parts. Answers to these questions will helpyou budget and plan for the future.

Which parts of your system are in the poorest condition (are most in need of replacement)?

1) ______________________________ Annualized Cost 2:_____________

2) ______________________________ Annualized Cost:_____________

Which parts of your system are most crucial to safe water provision?

1) ______________________________ Annualized Cost:_____________

2) ______________________________ Annualized Cost:_____________

3These figures will differ according to factors such as your system’s environment, water quality, and typeof equipment. (Figures taken from the Rhode Island Guide for Infrastructure Replacement.)

5

Follow-Up Questions

1) What should I do if my system is in poor technical condition but will cost too muchmoney for me to fix?

If you discover much of your system is in poor condition and will be too expensive tomaintain, seek help now! Waiting until your system fails may have drastic public healthconsequences and may be far more expensive to fix than replacing older parts before they break. Financial help from lenders will also be more easily available if your system and finances are ingood shape at the time you apply. See the Resource Guide at the end of this document forsources of additional information on financial assistance for technical improvements.

2) I don’t know how to evaluate the condition or estimate the useful life of my water systemparts. What should I do?

If you don’t know how to assess the condition of your infrastructure, you may need tohire an engineer to make a formal review. You can use the following chart to help you“guesstimate” the useful life of your system parts in order to complete Worksheet 1. Contactingsimilar systems or parts distributors may also help you figure out how long you can expect yourequipment to last.

Table 1: Average Life Expectancies of Water System Equipment3

Equipment Years Equipment Years

Intake structures 35-45 Transmission/Distribution 35-40

Wells and springs 23-35 Services Lines 30-50

Treatment Facilities 25-50 Meters 10-15

Storage equipment 10 Hydrants 40-60

Reservoirs and tanks 30-60 Tools, shop equipment 7-10

Pumping equipment 10-15 Laboratory equipment 10-15

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Step Two: Develop a Capital Improvement Plan

As part of your financial application, you will need to develop and submit acapital improvement plan (CIP). A CIP is a tool to help you plan, fund, andcarry out necessary infrastructure replacements and improvements. The CIPshould demonstrate you are financially prepared to repair or replace worn

out equipment, can afford any new equipment required to support a growing service population,and comply with current and future SDWA requirements. Worksheet 3 walks you through theprocess of creating a CIP. Remember to complete Worksheet 1 first, as the total annualized costyou calculated (Column E) will be included in Worksheet 3.

CIP expenses can be grouped into four categories:

a. New Capital Facilities. This includes all expenses associated with developing new orgrowth-related facilities, excluding those required by SDWA. Examples might includethe extension of service, the installation of new wells or piping facilities, or thecreation of any other new— as opposed to replacement— facilities.

b. Safe Drinking Water Act Compliance Costs. This includes capital costs associatedwith SDWA compliance. Thinking about SDWA requirements (licensing and permitfees, average testing and lab costs, operator certification training costs, etc.) can helpyour system more accurately project future expenses.

c. Equipment Replacement. Refer to Worksheet 1 Column E to determine how muchmoney you will need every year to replace equipment. Remember this amount couldbe the same for all 5 years or could fluctuate depending on your replacement schedule.

d. Non-Facility Expenses. This includes any expenses not related to the physicalupkeep of the system. For example, the cost of developing and implementing newconservation programs, providing source water protection, or conducting a watershedsurvey would be included here.

7

Worksheet 3: Instructions for Preparing a CapitalImprovement Plan

To complete your CIP you will need to describe projects, schedules, costsand payment methods. The information should be compiled into a report

using the following steps:

1. Think about (and research) the system projects you’ll need to complete over the nextfive years to continue to provide safe drinking water to your service population (andany new customers). The projects should fit into one of the categories describedabove.

2. Describe and rank the importance of these projects. You should refer back toWorksheets 1 and 2 and consider parts of your system in the poorest condition (mostin need of replacement) or most crucial to safe water provision.

3. Based on the priority list you develop, estimate the costs of the projects and estimate atime schedule for expenses. For example, if you plan on taking out a loan to replaceyour storage tank in three years you will need to include the new loan payments inyour CIP starting in year three.

4. Enter these annual costs into the Table 2. The table can become part of your CIP.

Table 2: CIP Annual Cost per Expense Category

Expense Categories Year 1 Year 2 Year 3 Year 4 Year 5

New Capital Facilities

SDWA Compliance Costs

Equipment Replacement

Non-Facility Expenses

Total

5. Describe how you will pay for the improvements (e.g., reserves, loans, grants, bonds).

8

Step Three: Create a System Budget

This section includes a budget worksheet to help you financially account foryour water system. The worksheet can serve as a general indicator of yourfinancial capacity. The budget worksheet will ask you about your reserveaccount and CIP expenses (Worksheet 4: Line II(K)), so you should keep

Worksheets 1 and 3 nearby.

Complete Worksheet 4 by answering each question to the best of your ability. If you don’tknow the answer to some of these questions, fill out what you do know and try to estimate the otheramounts. Even if your system does not currently budget separately for water system operation andmaintenance, you should complete the questions on the worksheet using your best educated guesses. If you are unsure of several of the answers, you may want to spend some time finding out about thewater-related finances associated with your organization.

Remember, the revenues and expenses you should include on Worksheet 4 are limited tothose related to your water system. If your water system is only one part of your overall business(for example, you run a mobile home park, school, or factory and generally serve 25 or more of thesame people on a regular basis), you will need to separate out the expenses of running the watersystem from your overall business expenses. For example, perhaps only 15% of your organization’selectricity use is devoted to water provision. You will need to think carefully about the break-downof your revenues and costs in terms of what portion you use to provide water.

Upon completion of Worksheet 4, you should have a rough estimate of your water system’snet income. Having a positive net income and being able to cover all other expenses associated withyour business, is a good indication of adequate financial capacity. If your net income is negative, youwill need to think about ways your organization can increase revenues or decrease the costs ofrunning your water system.

Note for Completing Worksheet 4: Line II(J): Depreciation refers to the decrease in thevalue of property and equipment over time. If you do not account for depreciation, leave thedepreciation expense line blank. Also leave the depreciation line blank if you contribute to adepreciation fund/reserve account each year and the amount you contribute is greater than or equal toyour annual depreciation expense. However, if you do not have a replacement fund or contributesignificantly less to your depreciation account/replacement fund than the value of your depreciationexpense, enter the value of your depreciation expense on Worksheet 4: Line II(J). Again, if you donot account for depreciation, leave this line blank.

9

Worksheet 4: Water System BudgetFor the year ending _________, 20____

I. Revenue $ Amount

A. Water Revenue: How much does your system earn per year by providing water (flat-rate charge,portion of fees, metered water, etc.)? ___________

B. Other Revenue: How much money do you dedicate to water provision or systemmaintenance/upgrades (loans, parent org. support (NTNCWSs), reserves, etc.)? ___________

Total Water System Revenue (I.A + I.B) (1)

II. Expenses

A. System Maintenance: How much do you spend on water system maintenance per year (parts,supplies, labor, etc.)? ___________

B. System Utilities: How much do you spend on water-related utilities per year (electricity for pumps,purchased water, etc.)? ___________

C. Operators and Employees: How much do you spend on water system operator and employeesalaries and benefits per year? ___________

D. Office Supplies and Postage: How much do you spend on water system-related office supplies andpostage per year (computer software, postage for bills, etc.)? ___________

E. Insurance: How much do you spend on water system-related insurance per year? ___________

F. Contract Services: How much do you spend on water-related contract services per year (legal,accounting, engineering, consulting, etc.)? ___________

G. Property: How much do you spend for water system-related property per year (land, rent, propertytaxes, etc.)? ___________

H. Monitoring: How much does it cost to monitor your water each year (include lab costs, chemicals,monitoring equipment, etc.)? ___________

I. Loan Principal and Interest: How much do you pay (total) in principal and interest costs forwater system-related loans per year? ___________

J. Depreciation: How much does your water system equipment depreciate per year? If you do not account for depreciation, leave this line blank. ___________

K. CIP/Reserves: How much do you plan to spend on capital improvements and deposit in reserveaccounts this year (refer to Worksheets 1 & 3)? ___________

L. Other: Do you have any other water system-related expenses not included above (transportationcosts, taxes other than property taxes, etc.)? Explain:_______________________________ ___________

Total Water System Expenses (Add II.A through II.L) (2)

III. Net Income

(1) MINUS (2) EQUALS

Revenue Expenses Net Income

10

L Remember that in West Virginia,Public Service Districts and investorowned water utilities must apply to thePublic Service Commission (PSC)before they may enact a rate or a ratechange. For more information call thePSC at 1-800-344-5113.

Follow-Up Questions

If you discover your net income is negative and you need to boost system revenues, there are severaloptions to consider. Ask yourself the following questions:

1. Can I raise the money I need from my customers?

The following suggestions might help you increase water revenue:

C If you don’t already do so, charge a separate fee for water use.It will be easier to estimate your system’s revenues and expenses if water use fees areseparate from other fees you charge your customers (e.g. mobile home park lot rental feesor homeowner association fees). You will be able to more accurately budget for yourwater system and more easily determine if you will need to increase fees to cover water-related expenses. By charging separately for water, your customers will also be able torecognize the true cost of providing waterand SDWA compliance. You should alsokeep your water system’s cost recordsseparate from the costs of the rest of youroperation.

C Increase prices or rates.You may need to increase water rates or theprices of other goods and services youprovide to raise the money needed tooperate your system in compliance withSDWA. If you need to increase rates and areconcerned customers cannot afford such a large increase, consider raising rates gradually. This will give your customers a chance to prepare and budget for the increase. Of course,this option may not work if you need a significant amount of money in a short amount oftime.

C Meter each member’s connection.Water meters will let you know how much water each of your customers uses. Once youhave that information, you can set up a rate schedule allowing you to cover your costs. Rates based on use may help you increase the amount of money you collect in watercharges. Meters may also save you money by helping you detect leaks in the system.

C Make sure all customers are paying their bills.You should not increase rates to make up for customers regularly not paying their waterbills. If you have customers not paying their bills, figure out how much money each ofthem owes. Consider setting up a payment schedule for these customers and treating theiraccounts as delinquent. Service to any nonpaying customers may be terminated inaccordance with PSC regulations.

11

L All state funding, except AbandonedMine Lands require review by the WestVirginia Infrastructure and JobsDevelopment Council. For moreinformation on the availability of funding orto find out how to apply for loans andgrants, call (304) 558-4607 or the localregional planning council.

2. Can I get financial help?

There are federal and state programs to provide publically owned systems with money forrepairs, replacements, or improvements to your system. Many of these programs have certainconditions you must meet in order to be eligible. If you do not qualify for these programs, thereare private financial institutions where you can go for help.

Banks and government funding agencies usually provide money for “hardware costs” such astreatment facilities, distribution lines, and water source development. Other costs, such asoperation, maintenance, and water quality monitoring, must be paid for out of water charges orsupport from your parent organization. Remember, if you get a loan you may have to increasewater charges to meet the loan payments.

Before you apply for funding, find out what each source will pay for and what information theywill need to consider your application. Most lending and granting agencies will want to seefinancial statements such as budgets, income statements, and cash flow documents.

A. Government Sponsored Options

C Drinking Water State RevolvingFund (DWSRF)The Bureau for Public Health provideslow interest or no interest loans toeligible water systems. The loans canfinance the cost of infrastructureimprovement projects. To be eligiblefor a loan, a system must either havetechnical, managerial, and financialcapacity or be able to achieve andmaintain technical, managerial, and financial capacity through the use of the funds. Contact the DWSRF program at (304) 558-2981.

C Infrastructure & Jobs Development Council (IJDC)IJDC provides loans to water systems (0 to 3%) for up to 40 years. There are also grantsavailable through the IJDC. Contact IJDC at (304) 558-4607.

C Water Development Authority (WDA)WDA provides loans for construction costs to eligible water systems. Contact WDA at(304) 558-3612.

C Appalachian Regional Commission (ARC)Limited grant monies for distressed communities are available to be used in combinationwith other funding services for public water systems. For more information on ARCgrants, contact the West Virginia Development Office at (304) 558-3248.

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• Rural Utility Service (RUS)The U.S. Department of Agriculture, through the RUS, provides loans to develop watersystems in rural areas and towns with a population not in excess of 10,000. The funds areavailable to public entities such as municipalities, counties, special-purpose districts, Indiantribes, and corporations not operated for profit. RUS also guarantees water and wastedisposal loans made by banks and other eligible lenders. Contact your local RUS office or the RUS Morgantown office at (304) 291-4796.

C Small Business Administration (SBA)The SBA provides two types of loan assistance to small businesses. It guarantees loansmade by local banks, thus providing a reduced interest rate to the borrower. It alsoprovides direct loans to businesses unable to get an SBA-guaranteed loan through a bank. Funds for direct loans are limited and are often available only to firms owned by or servingdisadvantaged groups. For more information on SBA loans, contact SBA at (304) 347-5220.

C Community Development Block Grants/Small City Block GrantsThese grants, by the U.S. Department of Housing and Urban Development (HUD), mustbe applied for and administered by the eligible town or county commission where yoursystem is located. The funds, however, may be used to make improvements in privatewater systems. Contact HUD personnel at (304) 558-4010.

C Abandoned Mine Lands (AML)The AML program provides grants for drinking water systems in areas where the watersupply has been affected by acid mine drainage. The amount of the grant is determined bythe percent of the mining related damage. Contact the Division of EnvironmentalProtection (304) 759-0521.

C Other SourcesOther potential sources of government funding include: Economic DevelopmentAdministration; County Commission; WV Municipal League; Governor’s CommunityPartnership Grants; Legislative Budget Digest; and the Housing Development Fund.

B. Private Financial Institution Options

C Lines of CreditSimilar to a credit card, a line of credit allows a system to borrow funds by accessing acredit account. The cost associated with this form of borrowing is often based on the totalamount of the loan and the amount of money drawn against the credit line. Althoughinterest rates may be higher than for term loans, a system does not need to pay interest onmoney not yet spent (particularly beneficial if the system is doing work requiring progressive or incremental payments).

C Term LoansA term loan allows a system to borrow a sum of money from an institution. These loansbegin accruing interest immediately. The system could then make repairs and pay themoney back over time (usually within a three-, five-, or seven-year period).

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C Hybrid LoansSome lending facilities offer hybrid loans (mixtures of the above funding mechanisms). Hybrid loans allow a system to draw funds on a fixed time frame and pay interest onlyduring that time. Upon completion of the project, the credit facility will transform into aterm loan the system can pay off in monthly installments. In this way, a system paysinterest only on the funds used and has additional time to pay off the loan.

3. What other options should I consider?

C ConsolidationThere are two types of consolidation, operational and physical. Operational or managerialconsolidation gives systems the opportunity to share costs. For example a treatment plantoperator might be able to serve more than one system, allowing these systems to share thecost of employing the operator. Systems can jointly buy materials, supplies, or non-essential equipment (and then share its use). Buying in bulk may yield cost savings. Physical consolidation means two or more systems altering their physical infrastructure tobecome a larger system. The new system will spread costs over a larger rate base.

C Create a Homeowner’s CooperativeIf you are a private system and are having difficulty covering your costs, and if yourcustomers cannot afford water rate increases, you may want to meet with your customersto discuss your concerns. There may be financial and technical assistance programs tohelp low-income residents buy out private water systems to set up a homeowner’scooperative. It may be possible to work with your customers to file the legal papersneeded to form a water district or other publicly-owned management group.

C Public Private PartnershipA public system may make an operational and maintenance agreement with a privatecompany to provide service for the water system.

4 The net income earned in one year may be “rolled over” to help fund the following year of water systemoperation. You will not have any rollover funds if you have never budgeted for your system before or if the systemdid not have a positive net income the preceding year. The net income from Year 1 will become the rollover totalfor Year 2, the net income for Year 2 will become the rollover for Year 3, and so on.

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Step Four: Complete a 5-Year Budget Projection

The 5-Year Budget Projection Worksheet (Worksheet 5) asks you to projectyour budget through a 5-year budget cycle. This will help you and thoseassessing your system to see whether your system will remain financially healthyin the near future.

Worksheet 5 contains line items for the same budget categories used in Worksheet 4, with onenew category called “Rollover”4. Your job on Worksheet 5 is to estimate how much you will earn(revenue) or spend (expenses) per line item during each of the next 5 years. You’ve alreadycompleted Year 1 (simply copy the figures you came up with on Worksheet 4 in the Year 1 column).

The 5-year budget projection process involves more than simply multiplying your current costsby the expected inflation rate for the next five years. Rather, you must think about and consider avariety of influences and connections among the budget categories. Following the Worksheet, weprovide helpful hints to help you estimate each particular line item through the 5-year budget cycle,taking into account some of those influences and connections. Several questions and comments havebeen included help you think about, and account for, factors impacting your calculations. Refer to thetext if you need help estimating budget figures.

Instructions for Worksheet 5

1. Transfer revenue, expenses, and totals from Worksheet 4 into the Year 1 column.

2. Calculate your net income for Year 1 (subtract total water system expenses (Line 2) fromtotal water system revenue (Line 1) or copy the numbers from Worksheet 4.

3. Transfer Year 1 Net Income to the rollover line for Year 2.

4. Estimate totals for each line item in Year 2 and calculate total water system revenue,expenses, and net income.

5. Include a 5% inflation rate for each line item (particularly for goods and services) unlessyour system has documented a different rate of inflation.

6. Transfer the net income for Year 2 to the rollover line for Year 3.

7. Repeat steps 4 thru 6 for the remaining years.

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Worksheet 5: 5-Year Budget Projection

Line Item Year 1 Year 2 Year 3 Year 4 Year 5

I. R

even

ue Rollover

A. Water Revenue

B. Other Revenue

1. Total Water System Revenue (IA+IB)

II. E

xpen

ses

A. System Maintenance

B. System Utilities

C. Operators & Employees

D. Office Supplies and Postage

E. Insurance

F. Contract Services

G. Water System Property

H. Monitoring

I. Loan Principal and Interest

J. Depreciation

K. CIP/Reserves

L. Other

2. Total Water System Expenses (Sum of IIA through IIL)

Total Water System Revenue (1)

Minus Total Water System Expenses (2)

Equals Net Income

If you’ve accurately projected your budget throughout the 5-year budget cycle, a positive netincome in each and every year will indicate general financial health and adequate financial planning.

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Helpful Hints for Projecting Revenues andExpenses

I. WATER SYSTEM REVENUE

A. Water RevenueIf you expect your CWS to grow in the next five years, you may need to increase rates or

fees to cover any expansion costs. You should take these increases into account as you predictfuture water revenue.

B. Other Revenue (Loans, Grants, and Reserves)

Owner Support of NTNCWSs: This amount should not change significantly from year toyear. However, factors like inflation and potential increases in the cost of compliance should beconsidered.

Loans and Grants: You can calculate the amount your system should expect to receive eachyear from sources such as loans and grants by dividing the total amount of the loans your taken orthe grants you’ve already won by the number of years the funds are expected to cover. Forexample, if you have taken out a $2,000 loan with a pay out over 5 years, your system shouldinclude $400 in this category ($2,000/5 years = $400 per year).

It is more difficult to predict how much additional grant and loan money you can expect toreceive in the future. You should begin by looking at your CIP in order to determine how muchmoney you will need to meet capital expenses in the next few years. If capital improvements areplanned beyond your system’s current budget, what will be your most likely source of outsidefunds (DWSRF, loans from private financial institutions, etc.)? If you predict additional loans willserve as a source of funds in the future, remember to include the loan principal and interest onSection II, Line I for the years you will be paying back the loan.

Try and be conservative when estimating the amount of money you expect to receive fromfuture grants and loans. Over-estimating this amount could easily throw off your budgetprojection. For example, if you plan on getting a loan in 3 years to replace your storage tank butbecause of other unexpected expense and a rise in interest rates, the bank won’t loan you themoney, your budget projections will be inaccurate.

Reserves: If your system is planning significant capital improvement projects during the 5-year budget cycle, you may decide to use money from reserve accounts to help defray some ofthese costs. Be careful when planning on using reserves. As you deplete reserves, you alsodecrease the amount of financial security provided to your system in case of cash shortfalls oremergencies. If you plan on using reserve funds, you should also plan on replenishing theaccount. Include the repayments in line item CIP/Reserves Expenses (Section II, Line K).

5Remember, as your system ages it is more susceptible to leak. One possible way to decrease the amountof water you will need to purchase, and therefore lower costs, is to monitor unaccounted for water. All leaksshould be repaired immediately.

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II. WATER SYSTEM EXPENSES

The next twelve line items should encompass all expenses associated with operating,maintaining, and improving your water system. If you are budgeting for a NTNCWS, rememberto include only those expenses associated with the water system.

A. System MaintenanceAverage costs for maintenance materials and labor over the previous two years should help

you estimate how much money to allocate in future years (remember to include expected costincreases due to inflation). If you expect your system to change in size during the next five years,a corresponding change in the cost of materials, supplies, and labor should be reflected here.

Chemical costs may be an important consideration as you estimate system maintenanceexpenses. You will need to account for possible increases in chemical costs due to inflation and other reasons. For example, do you anticipate changes in treatment technique requirementsaltering the kinds or amounts of chemicals you must use? Is your system size expected tosignificantly increase, increasing the amount of water you will need to treat? Can your systemcoordinate with neighboring systems to achieve economies of scale (i.e., buying chemicals at adiscounted bulk rate and sharing them among systems to reduce costs)?

B. System UtilitiesSome of your utility costs will probably remain relatively constant (telephone), while others

may vary according to system size (electricity). In predicting this expense amount, you shouldlook at expected trends in your service population and account for any potential changes insystem size (e.g., a larger treatment plant will require more electricity, translating into higherelectricity costs).

If your system purchases water, you should first estimate how much water will be needed toaccommodate growth in your service population throughout the budget cycle. 5 If you predictyour service population will grow, the probable increase in water demand may lead to a highertotal cost for purchased water. To accurately project this total, you must know the rate structureof your supplier. Will the price per unit of water increase or decrease as the total volume youpurchase increases or decreases?

C. Operators & EmployeesYour organization’s payroll will offer an accurate estimation of current salary and wage

expenses. From this starting figure, you can begin to think about how salaries and wages will beaffected in the future. How much do you expect to increase salaries in the coming years becauseof raises? Will you need to hire additional people to manage new or expanding facilities? Ifvolunteer labor is currently being used, you should also estimate (and include as part of theprojection) the cost if volunteers were to quit. Remember to include all training and certificationcosts.

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D. Office Supplies & PostageUsing the average costs from the past couple of years will give you a rough idea of how

much you can expect to pay for office supplies and postage. You may also want to figure in a 1¢per stamp price increase every year.

E. InsuranceInsurance premiums should remain fairly constant from year to year, depending on the

particular policies. If your system expects to hire additional people or to purchase insurableequipment, you should add the corresponding insurance costs at the appropriate time in thebudget cycle.

F. Contract Services Some contract service costs may remain constant from year to year (e.g., you may hire

outside legal or accounting professionals to help with tax returns each year). However, otherexpenses will be more variable. For example, if you expect your system to expand in size or ifState and federal regulations change, you may need to pay for engineering and other professionalservices. Remember to consider inflation as you project all future contractual service costs.

G. PropertyThe nature of the rental agreements for equipment and real property will provide you with the

easiest method of anticipating costs. For example, any long-term rental agreement should statethe rent on a per year or per month basis and should say whether the rent will increase during thelife of the lease. If the agreement is rent-to-own and your system will retain ownership of theequipment at the end of the lease, your rental expenses will decrease. You should howeverinclude the costs for equipment repair in Section II Line A.

You can refer to past tax records to help project future tax expenses associated with rentedequipment and real property. Remember to include any mortgage payments for any land thesystem owns.

H. MonitoringYou can estimate the laboratory costs by consulting with local labs or reviewing past lab bills.

You can contact the Office of Environmental Health Services to obtain information concerningany monitoring changes expected to take effect in the next five years. This should give youadequate information to estimate laboratory and monitoring expenses throughout the upcoming 5-year budget cycle.

I. Loan Principal and InterestBased on each loan agreement, you should be able to predict the total amount your system

can expect to pay in principal and interest. If you plan to either take on more debt (refer back toyour CIP and Section I Line B of Worksheet 5) these payments will increase. If you plan to payoff existing principal to reduce the life of the loan, interest payments will decrease in future years.

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J. DepreciationIf your system has already established annual depreciation rates, this amount should remain

relatively constant throughout the budget cycle. If you have not, but foresee the inclusion ofdepreciation expenses in the future, you should include this amount at the appropriate time on theworksheet. If you do not account for depreciation, leave the depreciation expense line blank.

K. CIP/ReservesBecause the CIP is a planning tool designed to chart capital expenditures throughout a 5-year

period, projecting all CIP expenses in the corresponding 5-year budget should be as easy ascopying figures directly from your CIP. The CIP should already include reserve expenses, but ifyou have other reserves not included in the CIP or have withdrawn from the replacement reserveand need to replenish it, this expense may be greater than is shown on your CIP.

L. Other ExpensesOther expenses may include such things as transportation costs, taxes (other than property

taxes), or other expenses associated with your water system not captured by the categories above. Transportation expenses should remain fairly constant, though they may vary depending on thecondition of currently owned vehicles. If your system will be expanding in the near future, or if aparticular vehicle is in poor condition and needs increasingly frequent repair, costs in this categorymay increase over the 5-year budget cycle.

Because tax rates do not usually vary significantly from year, the taxes your system owesshould also not change dramatically throughout the budget cycle. However, if your systemexpands in size or gains additional taxable capital or revenue, you should account for thecorresponding increase in taxes your system will owe.

Prudent system management would entail slightly overestimating the total miscellaneous costswhen creating a budget projection. It is always far easier to deal with a cash surplus than it is todeal with a cash shortfall!

APPENDIX D

June 8, 2000 Stakeholders

Meeting Participants

CAPACITY DEVELOPMENT STAKEHOLDER’S MEETING

June 8, 2000

NAME ORGANIZATION PHONE E-MAILADDRESS

Ron Belcastro AWWA/WVAWC 340-2971 rbelcast@wvw

ater.com

Sandra Fallon Nat’l Environ. Training Ctr. 304-293-4191 [email protected]

for Small Communities Ext. 5582

Daniel Parker WV BPH 558-2981 danparker@w

vdhhr.org

Walter Ivey WV BPH 558-2981 walterivey@w

vdhhr.org

Amy L. Swann PSC of WV 340-0481 [email protected]

tate.wv.us

Dan Pauley WV RCAP 265-0323 dpauley@cityn

et.net

Pat Taylor WV BPH 558-2981 patricktaylor@

wvdhhr.org

Sonny Moore WV RWA 727-9981 gmoore@new

wave.net

Randall Lewis WV RWA 757-0985 rlewis@neww

ave.net

Tom Holbrook WV Section AWWA 353-6334 tholbroo@wva

water.com

Ghassan Khaled U.S. EPA 215/814-5780 [email protected]

Fax: 215/814-2318

Rick Watson WV BPH 558-2981 richardwatson

@wvdhhr.org

Bernie Yonkosky WV WDA 558-3612 [email protected]

Fax: 558-0299

APPENDIX E

Schedule of Public

Participation Activities

Schedule of Public Participation Activities

June 8, 2000 Stakeholders Meeting

June 16, 2000 Start of Public Notice Period

July 14, 2000 Public Hearing

July 21, 2000 Close of Public Comment Period

August 4, 2000 Submission of Final Strategyto US EPA