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
www.health.ri.gov