Entries for 'Steve Wilson'

When you sign up for our Tribal Utility News newsletter, you're asked what challenges tribal water and wastewater systems face, specifically what challenges that are different from other small systems. We've been listening closely to the responses. Here is a summary:
Who Responded
We have had about 60 responses to our survey. Though we don't know who said what, the folks who signed up for the newsletter include tribal operators, various technical assistance providers, and staff from several federal agencies that serve tribal interests. Based on the responses, it seems that everyone in those groups provided at least a little input.
There Are A Lot Of Similarities
First of all, tribal systems are facing many of the same challenges that non-tribal small systems are facing all over the country.  The responses mirror many of the things we hear all the time from small systems.  We'll provide some of that information in a different post, however.
There Are Definately Additional Challenges/Issues For Tribal Systems
Tribal systems face unique challenges related to their sovereignty, government, federal support, and tribal issues/attitude. Remember, we are here to be impartial, share what others have said, and hopefully move forward the dialogue on how to support tribal water and wastewater operators and the systems they serve. Below is the list we have so far. We welcome comments, suggestions, and most importantly, positive ideas for solving the challenges tribal water and wastewater systems face:
Remoteness and Isolation
- Cooperation and compromise with nearby non-tribal systems
- Seclusion from non-tribal resources (state and county)
- Ability to work with state entities (want to be able to)
Support From Tribal Government
- understanding the need for qualified operators
- tribal council involvement can be low
- lack of interest in water and wastewater issues
- need for a water board to make fair decisions (need independence)
- using system for political patronage
Dependence On Federal Entities
- need to take ownership of systems (attitude)
- dependence on slow moving federal bureaucracy/assistance
Tribal Issues/Attitudes
- high unemployment, new operators leave for better job
- cooperation and compromise with non-tribal systems
- non-tribal operators may not be able to stay on reservation
- tribal politics
- reluctance to work with outside entities to deal with problems, repairs
What's The Point?
There was one comment, only mentioned once, that makes the point that everyone involved with water and wastewater needs to remember. They said: "lack of emphasis on compliance for health and safety of citizens." When we all look at why we are involved with this profession and specifically involved in supporting tribal water and wastewater folks, isn't providing safe drinking water and clean discharge to the environment the only thing that really matters? Would some of these issues go away if we just made that the focus everyday, instead of some of the issues mentioned above?
Please Comment
We welcome comments, so please either post a comment on this blog post of send an email to info@smallwatersupply.org.


I was at an asset management workshop recently that included a number of state regulators. The theme was asset management and certification, but O & M and the tie-in to understanding your assets kept coming up.

O & M Is Tied To Asset Management
I realize the title of this blog post is about SCADA systems, and many small communities don't even have them, but whether you use SCADA or not, the principles behind good O & M are important for all systems. It's all about understanding your system, the equipment, infrastructure, and treatment, as well as the process of running the plant (O & M). I know everyone hears about the importance of testing generators monthly and servicing pumps when recommended, but many times these things are low priority. Weeks turn into months and months turn into years. I was at a plant this summer that was using a federal grant to get a new generator for their water plant. I had just been in the wastewater plant for this same community this last fall where there was a perfectly good generator that would serve the purpose. I brought this up to the consultant managing the grant, but he said it wouldn't work. Unfortunately, the community had no warranty on the generator because they didn't follow the maintenance schedule. It had sat in a garage for number of years and not been ran. As a taxpayer, that's frustrating, but as a small systems advocate, it gives us all a black eye.    

So On To Best Practices
At the workshop, someone from Michigan mentioned that one of their larger communities was planning to shut down their SCADA system for a week. This wasn't being done to allow upgrades or changes to the system, this was being done because the Water Supt. wanted to make sure his staff knew how to run the plant. This system is being proactive, both from an emergency standpoint, and also from an operations standpoint. We all rely on technology and automatic this or that for so many things these days, but to really "know" your plant, to be able to troubleshoot and tell when something isn't quite running right, you really have to have a comprehensive understanding of how your system works. 
I Know, You Already Know Your Plant That Well
You are thinking, I already have that level of understanding of my plant, I know when something doesn't sound right, look right, or even feel right. Thats great, but what about the next level of support? What happens when you are not there? Do you ever take vacation or have to be out of town for a day or two? Is the person left in charge of your plant as familiar with your system as you are?  Do they know your plant well enough to troubleshoot when a problem pops up? They need to have that level of understanding, or have something they can turn to that has those details.
That brings us back to one of those O & M things that are a pain, take time, and because you know the plant so well, keep putting off or don't see a need for. You should have an O & M manual for your plant. No one else can write it, and its only as useful as the information you put into it. It comes down to being prepared and taking full responsibility for the operation of the plant. That also means being prepared in case you can't be there for some reason.    

Getting Started 
First of all, develop an emergency response plan. There are templates available from a number of sources. You can contact a TA provider you work with, they will be able to get you started. If you want to look at some of the better ones, type in "emergency response plan" in our document keyword search, and use "type = templates". But, for those of you that already have an ERP, take the next step, develop an O & M plan for your plant. Pennsylvania, Massachusetts, and Florida require O & M plans, I'm sure there are others. New Jersey has an O & M template that operators can use to help them develop their O & M plan, as do Florida, Louisiana, and Vermont. Georgia has a guidance manual as well. It was also brought up at the workshop that Colorado is developing an O & M and training manual geeared toward walking you through developing an O & M plan for your facility. It sounds like it will be a great resource. Once the Colorado document is available, we'll post an update and provide those details. Lastly, if you need some help, email or call us. We can either help you directly or find someone in your area who can help you get started.
WIFIA stands for Water Infrastructure Finance and Innovation Authority. AWWA, WEF and AMWA are supporting a new bill to establish this Authority as a funding mechanism for large water and wastewater infrastructure projects. When you read the summary they have put together that explains what WIFIA will be able to do, it seems like a cost effective approach for helping systems deal with their infrastructure needs.  You can read the summary here.
But, And There Is Always A But...
WIFIA could end up being a problem for the current DW and CW SRF programs. WIFIA is meant to be a more open access sort of loan program whereby large projects can get low interest loans that save the utility and their customers money. It doesn't specify that the loans go to the systems with the greatest needs or those that are out of compliance. Thus, in some cases the funding could go for expansion projects that benefit the utility, rather than the intended use of dealing with the massive infrastructure problems being predicted for this country. On the other hand, SRF funds are directed toward those projects with the greatest need, with the goal being to protect public health and maintain compliance with the SDWA and CWA. This difference is important, especially in some states that have many small, rural systems.
Another difference between WIFIA and SRF are the use of cross-cutter rules. SRF requires utilities receiving money to meet certain federal requirements that limit how the funds can be used and requires the utilities to meet certain standards. The framers of WIFIA would prefer that the program not require many of those rules, which would make it easier for the utilities to receive funding, but reduce the oversight to ensure that the funding is being used for its intended purpose.
Lastly, SRF programs include set-aside monies that provide funding for the states to administer their programs and provide for state-managed activities that include things like technical assistance to small systems. WIFIA doesn't provide for these state resources. 
Some Possible Advantages
The WIFIA summary points to lower overall costs for consumers, based on current rates, as compared to the bond market. It also points out that there are 27 states that currently leverage their SRF funds on the bond market and this would allow them to borrow from WIFIA instead with potentially 16% savings long term. I've also heard that because private companies can't get SRF funds in some states, WIFIA would be an option over corporate bonds that would lower overall costs for customers at these systems.
Some Possible Disadvantages
The biggest concern with WIFIA is how it will affect the SRF programs. The SRFs are successful programs with a strong track record that provide funding for water and wastewater system projects. SRF programs are managed at the state level by the agencies that regulate the utilities, work with them to stay in compliance,  and know them best. States use the SRF programs to increase compliance and to protect public and environmental health. WIFIA would be a national program, managed at the national level that has the intended purpose of reducing the overall cost for infrastructure projects. Will national rules affect loan approval? Will the states be involved in decisions or the process for the WIFIA program? What about the small struggling system that doesn't have the ability to raise capital for infrastructure projects and is too small for a WIFIA loan?
When you read the SRF example in the summary, you might ask yourself why even have SRFs if WIFIA funding is available. The example basically says that the state financing authority could apply for WIFIA funding instead to fund its program, and indicates the cost savings over leveraging bonds instead. SRF costs the federal government about $2 billion dollars each year. WIFIA is being promoted as potentially having no long term cost to the federal government, so why would Congress want to keep both programs? That's the unintended consequence that many are worried about, and the reality that we could soon be faced with if a WIFIA bill doesn't have provisions to maintain the SRF program.
Loans For Small Systems
AWWA just released an infrastructure report that says funding for small system projects is going to cost much more per capita compared to larger systems that have the customer base to spread out infrastructure upgrade costs. Because WIFIA funds are meant for large projects, small systems would often not be eligible for WIFIA funding themselves. Asking small systems to bundle their projects, or asking the state to bundle the projects for them, also creates some questions. What if a loan is bundled for 5 projects and one of the projects defaults? What does that mean for the other 4 systems and what does that mean for the state if they applied for the loan? Will the state have to cover the defaulted loan?
If WIFIA replaces SRF, will the states be provided funds for staff to help small systems develop applications? Small systems often lack the managerial capacity to develop applications and instead use engineering firms and planning grants to get that task accomplished. Will those options still be available? They must be or some small systems will be left coming up with those funds themselves. What about states with very few, if any, systems that would qualify for WIFIA funding? If SRF goes away, what will they do to find funding for projects? Could they be out of luck until enough projects could be bundled to meet the WIFIA requirements?
What Needs To Happen
WIFIA is a great concept for dealing with the huge anticipated costs we expect to see for infrastructure upgrades in the next 25 years. As currently proposed, it will make it easy for large systems to get cheaper funding, even though those systems currently have more options available to them already. However, it could potentially have the unintended consequence of reducing or eliminating the SRF programs that support compliance and help small systems that might not have other options. Losing SRF funding would also reduce a state's ability to manage their SDWA and CWA programs because the states rely on the SRF set-asides for part of their program implementation. The SRF's are necessary and must be maintained - and, we would hope, at least at current funding levels. 
Recently, AWWA sent out an email asking its members to support WIFIA, encouraging utilities to contact their senators and representatives to seek their support in co-sponsoring the WIFIA bill. If you are so inclined to get involved, be sure to stress the importance and differences between the SRF programs and WIFIA, and that any reduction in SRF will lead to unintended consequences that include reduced compliance and public health protection for small systems, and could leave many small systems with no options for dealing with their infrastructure needs. Make it clear that you only support a WIFIA bill that leaves the SRF programs intact and fully supported.
I was at the Alabama Rural Water Association Conference a few weeks ago and there was a really interesting talk by a lawyer for an Alabama utility.  The utility is being sued by a few of their customers for poor water quality even though their water meets all health standards.  If a water supply provides water that meets all of the health standards and their operation meets all of the regulatory requirements, should their customers be able to sue them if they percieve there are water quality problems? Thats a tricky question for sure.
Safe Harbor
A safe harbor law basically protects someone from civil suit if they are meeting all of the legal and professional requirements for the services they provide.  For instance, a prosecutor in a district attorney's office has immunity from civil action, even if they help put an innocent man in jail.  For a water system, this type of law would mean that your customers cannot sue you for percieved water quality problems if you are meeting all of the requirements of the Safe Drinking Water Act and your state regulations.  Alabama currently does not have such a law.
What's Happening In Alabama
Because of the lawsuit currently going on in Alabama, there is a push to pass a "safe harbor" law as an amendment to the Alabama SDWA. It's going through their state legislature now and appears to have alot of support.  In the ongoing lawsuit, 10 homeowners that are spread throughout a 53 home subdivision, claim their water has oil and grease in it.  Testing by the utility and extensive testing by the Alabama Department of Environmental Management show there are only normal, background levels in the water (a trip blank even had similar levels in it).  I don't want to get into the details, but 3000 customers use water from the same main, and some of the allegations (like their water catches fire), are hard to understand if the water is meeting all of the SDWA standards. 
What It Means
I'm not a judge or jury, but I do believe that if a utility is meeting its legal obligations and works with their customers fairly and openly, there should be some reasonable expectation that the utility met its obligation and has their customers best interests at heart. As the speaker said, without this legislation, any customer could sue any utility and that could lead to a jury setting water standards in that state, "regulation by litigation" is the term he used.  Can water systems afford litigation because of unhappy customers? 
How about you?  Does your state have "Safe Harbor" legislation attached to its SDWA rules?  Do you think it's a good idea?


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