Capacity Development

Fast-Track to Compliance

RHODE ISLAND DEPARTMENT OF HEALTH Office of Drinking Water Quality

11 / 2011

Under Section 1420(c)(2) of the 1996 SDWA Amendments, Rhode Island and all states are required to

develop and maintain a Capacity Development Strategy which assists existing public water systems in

acquiring and maintaining the technical, managerial, and financial capacities required for achieving and

maintaining compliance. The strategy was submitted for approval in August 2000 and subsequently

implemented in Rhode Island. This Fast-track to Compliance Program is one of several programs,

tools, and activities developed under this strategy.

Capacity Development Mission –

To participate in the development of sustainable water systems

OFFICE of DRINKING WATER QUALITY (DWQ) June Swallow P.E. Steven Boudreau Chief, Office of Drinking Water Quality Capacity Development Program Manager

Identification of systems in need of Capacity Development

A key element of any capacity development effort is ensuring systems are in place to identify the need

for assistance. As documented in our original strategy, the State of Rhode Island has in the past

prioritized public water systems through a priority ranking method which assigns each system to one of

four categories (Level 1, Level 2, Level 3, Level 4) based on a staff evaluation of the following criteria:

⋅ Compliance data (HSNC, sanitary survey results, monitoring data, compliance officer input, and staff knowledge);

⋅ DWSRF data (application materials, project priority list, disadvantage community status, intended use plan);

⋅ Public Water System data (CCRs, source water assessments, operator certification status, consumer complaints); and

⋅ Information provided through annual license renewal applications.

The water system ranking does not rate systems from best to worst. It identifies systems that would

benefit from the capacity development tools we have to offer. Level 3 systems that can be brought into

compliance are the highest priority. Level 2 systems that can be advanced to level 1 with technical or

financial assistance are the next highest priority. In the past it was determined that Level 4 systems

could not be brought into compliance through capacity assistance. Consequently, enforcement action

was required.

The Office of DWQ Capacity Development program has developed this Fast-track to Compliance

Program in an effort to highlight the collaboration efforts of our Capacity Development, Operator

Certification, and Drinking Water State Revolving Fund programs and our Compliance and

Enforcement efforts.

While the efforts of the Capacity Development Program have been very successful in assessing the

needs of our public water systems and providing technical, managerial and financial tools and assistance

to help meet those needs, the Fast-track to Compliance Program enables the entire DWQ staff to

partner with system personnel, owners, and operators, to bring failing water systems (Level 4) back into

compliance. Once a failing system is recognized, Capacity Development staff and DWQ management

undertake an evaluation of the system’s ability to provide safe drinking water to its consumers. Our

assessment of the capacities required to effectively meet this obligation provides an analysis of their

current and future sustainability. The evaluation involves a 5-step return to compliance process that

applies the Principles of Effective Utility Management (EUM); is managed by Capacity Development staff

and is carried out over a 4 – 6 month timeframe.

Depending on the severity of compliance issues, water systems acting alone, without capacity assistance, may require much more than six months to return to compliance – if they ever do.

The 5-steps are:

Step- 1 Analyze & Engage

(EUM)Establishing the need for assistance by engaging DWQ staff in an evaluation process

Step- 2 Assess

Identifying capabilities & assessing current conditions

Applying attributes of sustainable water systems

Ranking of importance & graphing results

Capital improvement planning Step- 3 Respond

Development of a corrective action plan

Step- 4 Implement

Carrying out the plan through capacity development facilitation

Step-5 Evaluate

Assessing results

Step- 1 Analyze & Engage

Establishing the need for assistance by engaging DWQ staff in an evaluation process

By identifying existing capacities and assessing those additional capacities required to bring a system

into compliance we can generally uncover the fundamental problems, that if satisfactorily addressed, will

improve the sustainability of a public water system.

This analysis sets out to:

⋅ define the capacities required to achieve or maintain adequate technical and managerial self-sufficiency;

⋅ uncover any existing financial factors that typically plague small public water systems; and

⋅ link capacity deficiencies to Capacity Development programs and tools.

This step is managed “in-house” – that is the various DWQ program managers perform the analysis and

come to initial conclusions about the system infrastructure, its management and finances.

Step- 2 Assess

Identifying capabilities & assessing current conditions

Applying attributes of sustainable water systems

Ranking of importance & graphing results

Capital improvement planning

During the assessment process Capacity Development program staff applies the ranking of ten Effective

Utility Management (EUM) attributes generally applicable to the sustainability of public water utilities.

The EUM analysis is designed to be performed by the system with the assistance of Capacity

Development. However, because level 4 systems generally lack a formal management team, the initial

analysis is performed by Capacity Development and used to engage the system at a later meeting.

System personnel have the opportunity to update and revise the graph once engaged and when

considering a corrective action plan.

The ranking considers the systems approaches and current levels of achievement for each of the

management attributes; and the degree to which current management systems effectively support each

of the attributes, and their component parts.

The attributes are: (in no particular order)

Infrastructure Stability Operational Optimization Water Quality

Community Sustainability Financial Viability Employee and Leadership Development

Customer Satisfaction Operational Resiliency Water Resource Adequacy

Stakeholder Understanding and Support

Step- 3 Respond

Development of a corrective action plan

The success of the Fast-track to Compliance Program relies heavily on an appropriate corrective

action plan that brings together the stakeholders and where appropriate provides for use of tools and

programs developed through DWQ Capacity Development efforts.

The corrective action plan is developed as a living document. It is revised and updated as necessary

throughout the return to compliance process and involves input from local officials such as town

managers, town planners, building officials and others. Built into the corrective action plan are activities

carried out by these stakeholders prior to engaging the system ownership. At this early planning stage

the state is attempting to partner with local officials to uncover options and remedies at the town level.

Local assistance can vary from provision of meeting space to assistance with grant applications and

expedited permitting and approval processes.

Capacity Development develops the corrective action plan and meets with system owners to facilitate

execution. Capacity Development programs and tools are included where appropriate throughout the

corrective action plan. Small water system management guides, financial templates, facility

improvement plans, circuit rider assistance, education plans and engineering assistance are all

examples of Capacity Development tools used during this process.

Step- 4 Implement

Carrying out the plan through Capacity Development facilitation

Implementation of the corrective action plan occurs in stages The first stage involves:

⋅ bringing together various system, local, state and, federal resources;

⋅ brainstorming all options at all levels for either bringing the system into compliance or uncovering

alternative solutions;

⋅ gaining consensus on the most suitable option; and

⋅ incorporating this new information into the goals of the corrective action plan. The second stage involves:

⋅ engaging the system owner(s);

⋅ reviewing assessment findings and compliance options; and

⋅ gaining consensus The third stage involves:

⋅ implementing the corrective action plan. The final plan, associated work sheets and tasks lists vary

depending upon the path to compliance chosen by the stakeholders.

Step-5 Evaluate Assessing results

⋅ Measuring performance is important to understanding the likelihood for system sustainability and

self sufficiency.

⋅ This process involves evaluating system performance and trends in the months after returning to

compliance.

⋅ Performance measures are selected that support compliance objectives and goals as well as the

ten attributes of sustainable water system management. The system is involved in this process to

improve decision making, clarify expectations, and focus improvements throughout the process.

⋅ Capacity Development is involved in developing, tracking, and reporting of success measures.

Criteria such as expectations, improvement over previous years, performance, or other

appropriate comparisons are used and are tied to improving performance in the ten attributes of

sustainable water systems.

Action Item No. Action Item Due Date Status

A

DOH / Town Official Meeting � DWQ invites town officials to participate. Educate

Town on the compliance issues and ramifications of not returning to compliance. Invite alternative solutions

04-15-2011

Attended by Town, DWQ Management Capacity Development Health Legal Counsel

B

Association/System /Homeowners Meeting � Attend joint system, DOH, and Town Council

meeting, to be scheduled by DWQ.

05-11-11

2nd meeting - Home/system owners are notified by DWQ. All parties are present for Power Point Presentation

C

Steering Committee � Elect a 5 person steering committee to oversee the

corrective action plan and report back to members and the Board, if one exist.

05-11-11

1st meeting of owners with Capacity Development Facilitation

D

Corrective Action Plan � Return executed copy of this Action Item Schedule to

DOH

06-01-11 Prepared by Capacity Development

Sample Corrective Action Plan

E Future Association Meetings � Submit a schedule of Association meetings through 07-

22-11

06-01-11

F Meeting Agendas � Submit a copy of meeting agendas for Association

meetings through 07-30-11

No later than 3 days

prior to each

meeting

G

Meeting Minutes � Submit a copy of meeting minutes for Association

meetings through 07-30-11

No later than 3 days after each meeting

H

Bylaws � Draft and file amended bylaws to reflect appropriate

rules and regulations relating to the management of the public water system, setting of rates, collection of fees, termination of service, and funding of a separate water system account.

06-15-11

I

Management Plan � Submit a written plan for management of the public

water system

� Meet with DOH Capacity Development to update and review Small Water System Management Guide funded by DOH

06-15-11

J

Logbook � Provide on-site logbook and document all work

completed on the system

� Enter weekly meter readings into the logbook

Ongoing

K

Association Roster � Maintain and submit a current roster of those properties that

remain connected to the public water system including property address and owner contact information. Specify board members and file updates with DOH as changes occur

06-15-11 &

Ongoing

L Cross Connection Control Survey Implement a homeowner Cross Connection Survey and submit results to DOH

07-22-11

M

Participate in DOH Small System Facility Improvement Plan Program � To be arranged with DOH contractor and funded by DOH

�

ONGOING

N

Construction � Advise DOH when Water System Improvements approved by

DOH on 3/21/2011 begin

� Provide construction schedule outlining each aspect of the project

� Complete all work by 7-22-11

AS NOTED

O Abandoned Storage Tank � Remove and properly dispose of abandoned storage tank.

07-22-11

For more information about this or any of HEALTHs Public Water System programs: Please contact: Steven Boudreau Principal Community Development Training Specialist Office of Drinking Water Quality Department of Health Three Capitol Hill, Room 209 Providence, RI 02908-5097 Phone: 401.222.7781 Fax: 401.222.6953

steven.boudreau@health.ri.gov

www.health.ri.gov