REPORT TO THE GOVERNOR ON THE WEST VIRGINIA DRINKING WATER SYSTEM CAPACITY DEVELOPMENT PROGRAM

Transcription

1 REPORT TO THE GOVERNOR ON THE WEST VIRGINIA DRINKING WATER SYSTEM CAPACITY DEVELOPMENT PROGRAM Bureau for Public Health Office of Environmental Health Services Environmental Engineering Division September 2002

2 REPORT TO THE GOVERNOR ON THE WEST VIRGINIA DRINKING WATER SYSTEM CAPACITY DEVELOPMENT PROGRAM Executive Summary Table of Contents Summary of the West Virginia Drinking Water Capacity Development Program...1 Why We Are Providing a Report to the Governor...2 How We Are Implementing Our Capacity Development Program...3 Developing the Baseline Priority Ranking of Our Water Systems...3 What We Have Learned from the Baseline Priority Ranking...3 Other Factors Influencing Drinking Water System TMF Capability...8 Ensuring New Water Systems Have Adequate TMF Capability...8 Ensuring DWTRF Loan Recipients Have Adequate TMF Capability...9 What We Are Finding by Evaluating Water Systems...9 How We Are Assisting Water Systems...10 How Third Parties Are Assisting Water Systems...11 Where We Go from Here...13

3 Tables 1 Drinking Water System Baseline Ranking Data Summary 2 Baseline Score and Service Population Summary - Drinking Water Systems in McDowell, Wyoming and Surrounding Counties Figures 1 Drinking Water System Average Service Populations 2 Drinking Water Systems Service Population Categories 3 Drinking Water System Size Breakdown Appendices Appendix A - West Virginia Water System Baseline Ranking Appendix B - Summary of Water System TMF Capability Evaluations Appendix C - List of Water System Assistance Providers

4 Glossary AWWA - American Water Works Association BPH - Bureau for Public Health CDP - Drinking Water Capacity Development Program DHHR - Department of Health and Human Resources DWTRF or SRF - Drinking Water Treatment Revolving Fund or State Revolving Fund EED - Environmental Engineering Division EPA - US Environmental Protection Agency OEHS - Office of Environmental Health Services H&S - Health and Safety I&CD - Infrastructure and Capacity Development IJDC - Infrastructure and Jobs Development Council MCET - Maryland Center for Environmental Training NDWC - National Drinking Water Coalition NETCSC - National Environmental Training Center for Small Communities NTNC - Non-Transient Non-Community Drinking Water System PM - Preventive Maintenance PSC - Public Service Commission of West Virginia PSD - Public Service District RCAP - Rural Community Assistance Program R&R - Repair and Replacement RUS - US Department of Agriculture - Rural Utilities Service SDWA - Federal Safe Drinking Water Act SNC - Significant Non-Compliance TMF - Technical, Managerial and Financial (Water System Capability) WVETC- West Virginia Environmental Training Center WVRWA - West Virginia Rural Water Association

5 Definitions Business Water System - A community or NTNC privately owned water system utilized to provide drinking water necessary to support a non-drinking water business (e.g., restaurant, manufacturing plant, park, etc.). Community Water System - A public water system that conveys water for human consumption to at least 15 service connections used by year round residents (e.g., municipality, subdivision, etc.). Municipal, Town or City Water System - A community water system owned and operated by a municipal government. Non-transient Non-community Water System (NTNC) - A non-community water system that serves 25 or more of the same persons over six months per year (e.g., schools, factories, office buildings, etc.). PSD Water System - A community water system owned and operated by a Public Service District created by the county commission. Private Water System - A community water system, privately owned and operated, in the business of providing drinking water (e.g., WV - American Water Company, WV Engineering, Inc., Kimball Light and Water, etc.). Public Drinking Water System - A system for the provision to the public of water for human consumption through pipes or other constructed conveyances, if such system has at least 15 service connections or regularly serves an average of at least 25 individuals 60 or more days out of the year.

6 Executive Summary This Report to the Governor on the West Virginia Drinking Water System Capacity Development Program (Report) provides an overview of activities completed, currently underway or planned by our Bureau for Public Health s (BPH s) Capacity Development Program (CDP). The West Virginia Drinking Water CDP helps our state s drinking water systems improve their finances, management, infrastructure and operations so they can consistently provide safe drinking water. In addition, this Report fulfills our obligation under Section 1420(c)(3) of the Safe Drinking Water Act (SDWA) to report the status of our program to you by September 30, Recently we completed an important component of our program, the initial Baseline Priority Ranking of our state s drinking water systems. The Baseline, completed August 5, 2002, ranks 738 West Virginia drinking water systems. Using this Baseline we can identify systems that may need assistance to improve their technical, managerial or financial (TMF) capability. Our CDP staff evaluates the TMF capabilities of water systems regularly. Our water system evaluations are effectively identifying TMF capability deficiencies of water systems. We find water systems requesting evaluation receptive to our findings and recommendations for improvement. As you would expect, these systems pursue recommended assistance and require little or no follow-up. Conversely, many water systems evaluated for other reasons have little interest in our findings and recommendations. Ultimately the quality of the water system s management team determines the successfulness of our evaluation and assistance efforts. Following CDP water system evaluation, assistance is provided to drinking water systems directly by our staff. This assistance to water systems is highly effective with receptive water systems. In addition to assistance from our staff, we commonly refer water systems to third party assistance providers. We note a significant difference in the service populations of inadequate, failing systems and viable systems. The viable water systems have an average customer population more than five times that of the failing systems and more than twice that of marginal systems. We also noted 45 of the 94 failing water systems are located in Wyoming and McDowell counties (48% of our state s failing water systems). Most of the surrounding counties have formed county-wide PSDs, consolidating many of their smaller, failing water systems. In addition, eight small systems in McDowell County have been consolidated into the McDowell County PSD. These county-wide PSD water systems generally are more viable than the numerous smaller water systems in McDowell and Wyoming counties. Consolidation does not always include physical interconnection. Small water systems can benefit dramatically through consolidation of their management, operation and finances. There are hundreds of marginal or failing small water systems throughout our state posing a constant threat of failure, disrupting the drinking water supply to their customers. Such disruptions threaten the health and welfare of the water system s customers. Additionally, the lack of reliable, safe drinking water is a significant impediment to economic development in areas served by these marginal or failing water systems. i

7 We are finding water systems must have effective, pro-active management to acquire and maintain adequate TMF capability. In all instances where water systems have inadequate financial or technical capability, we have noted inadequate, ineffective current or past management. Our experience has shown it is considerably more difficult for smaller systems to develop and maintain the management expertise necessary to operate a viable water system. In addition to managerial difficulties often encountered by small water systems, they also lack the economies-of-scale achieved by larger water systems. Our West Virginia CDP has been in place for approximately two years. As a result, this initial report focuses more on the problems discovered and suggestions to address those problems, than on improvements made by our state s water systems. A more pro-active, handson approach may be necessary to help more water systems move forward. Several potential actions are being developed or considered to improve water system response. The action with the greatest potential to encourage failing water systems to improve is developing and implementing an operating permit program. At this time water systems only obtain a permit to construct a water system (either new water systems or modifications to existing water systems). However, the authority already exists to require a permit to operate a public water system. We are in the process of developing a plan to implement an operating permit program within the BPH. ii

8 Summary of the West Virginia Drinking Water Capacity Development Program The West Virginia Drinking Water Capacity Development Program (CDP) helps our state s drinking water systems improve their finances, management, infrastructure and operations so they can consistently provide safe drinking water. The Department of Health and Human Resources (DHHR), Bureau for Public Health (BPH), Office of Environmental Health Services (OEHS) works with water systems to ensure they acquire and maintain the technical, managerial and financial resources necessary to meet the requirements of our public drinking water statutes and regulations. Our CDP consists of several components outlined in our Capacity Development Strategy (Strategy)*. We submitted the Strategy to the US Environmental Protection Agency (EPA) in August The primary components outlined how we will: Develop and maintain a priority ranking of all of our water systems (Baseline); Ensure new water systems have adequate technical, managerial and financial (TMF) capability; Ensure Drinking Water Treatment Revolving Fund (DWTRF) loan recipients have adequate TMF capability; Assess the capabilities of existing water systems; and, Help deficient water systems achieve and maintain adequate TMF capability. We are implementing the CDP through our BPH, Environmental Engineering Division (EED) Infrastructure and Capacity Development (I&CD) Unit. * Copies of the Strategy are available from our Charleston office located at: Bureau for Public Health Office of Environmental Health Services Environmental Engineering Division Capacity Development Program 815 Quarrier Street, Suite 418 Charleston, WV or on our website at: 1

9 Why We Are Providing a Report to the Governor This Report to the Governor on the West Virginia Drinking Water System Capacity Development Program (Report) provides an overview of activities completed, currently underway or planned by our CDP. In addition, the Report will inform you of problems and impediments encountered implementing our CDP. This Report also fulfills our obligation under Section 1420(c)(3) of the Safe Drinking Water Act (SDWA). Section 1420(c)(3) of the SDWA requires the CDP lead agency report the status of our program to you by September 30, Specifically, the Report informs you of the effectiveness of our strategy and progress made improving the TMF capabilities of our state s water systems. Failure to provide this Report results in the EPA withholding 20% of our State Revolving Fund (SRF) capitalization grant money. This capitalization grant money funds all or part of the following programs: Capacity Development Program; Source Water Protection Program; Public Water Supply and Supervision Program; A technical assistance grant to an independent, non-profit contractor to provide assistance to small drinking water systems; Loan monies to drinking water systems; and, Administration of the WV DWTRF program. 2

10 How We Are Implementing Our Capacity Development Program In this section each program component noted on page one is discussed, including its background, status and effectiveness. Where appropriate, impediments to effective implementation and suggestions to overcome these impediments are addressed. Developing the Baseline Priority Ranking of Our Water Systems Section 1420(c)(2)(D) of the SDWA requires all states develop a Baseline Priority Ranking of their water systems. In our Strategy we described how our Baseline would be developed. The Baseline ranks the 738 West Virginia community and non-transient non-community (NTNC) water systems (NTNC water systems serve at least 25 of the same persons over a minimum of six months per year). To compile the Baseline, information was gathered from the water systems and from our EED district office staff (our district offices are located in Wheeling, St. Albans, Beckley, Philippi and Kearneysville). Our CDP staff evaluated the information collected and developed a score for each water system. Once evaluated, every water system was assigned a score between 0% and 100%. A description of how our initial scoring was developed and a copy of the preliminary Baseline was presented to a meeting of WV drinking water stakeholders held on March 15, Representatives from the following organizations attended the March 15 meeting: WV Department of Health and Human Resources (DHHR) US Department of Agriculture Rural Utilities Service (RUS) WV Section of the American Water Works Association (AWWA) Rural Community Assistance Program (RCAP) National Drinking Water Coalition (NDWC) National Environmental Training Center for Small Communities (NETCSC) WV Rural Water Association (WVRWA) Public Service Commission of WV (PSC) WV Association of Counties WV Infrastructure and Jobs Development Council (IJDC) After receipt and review of any input from these stakeholders, our CDP staff prepared the final Baseline. On August 5, 2002, we completed the Baseline and forwarded it to EPA. A high Baseline score indicates a viable water system with adequate TMF capability. Similarly, a low score indicates a failing water system with inadequate TMF capability. A copy of the Baseline is provided in Appendix A. Low ranking systems on the Baseline are a high priority for detailed, system specific TMF capability assessment. As a result, we will be focusing our assessment and assistance efforts on many of these systems. What We Have Learned from the Baseline Priority Ranking Some key Baseline data are summarized in the tables in figures on the following pages. 3

11 Table 1 Drinking Water System Baseline Ranking Data Summary Water System Score Number Percent Failing (Score # 40%) Marginal (Score > 40% and < 70%) Viable (Score $ 70%)

12 5

13 6

14 Figure 3 Drinking Water System Size Breakdown 7

15 By comparing viable, marginal and failing water systems we note a significant difference in the service populations. The viable water systems have an average customer population more than five times that of the failing systems and more than twice that of marginal systems. As can be seen, adequate service population is important to achieve and maintain water system viability. We noted 45 of the 94 failing water systems are located in Wyoming and McDowell counties (48% of our state s failing water systems). These two counties contain only 12 viable water systems and 20 marginal water systems (3% of our viable water systems and 8% of our marginal water systems). The failing water systems are primarily small community water systems (both publicly and privately owned). In contrast, the viable water systems are primarily schools, government operated facilities or larger community water systems. Other Factors Influencing Drinking Water System TMF Capability To acquire and maintain adequate TMF capability, water systems must have effective, proactive management. In all instances where water systems have inadequate financial or technical capability it is the result of inadequate, ineffective current or past management. Our experience has shown it is considerably more difficult for smaller systems to develop and maintain the management expertise necessary to operate a viable water system. This appears to be especially true of water systems owned and operated by small towns or municipalities where management (typically the mayor and town council) is frequently reluctant to make the difficult decision to raise water rates and generate revenue necessary to maintain adequate financial and technical capability. PSDs, where the water system is managed by a board appointed by the county commission, and larger municipalities, with appointed water boards separate from the elected officials, generally function more independently and operate more like a business. This more independent, businesslike operation generally results in a water system with better TMF capability and increased long term viability. In fact, there are a number of instances in our state where these smaller, non-viable municipal water systems have dramatically improved their TMF capabilities following consolidation into a larger PSD. In addition to managerial difficulties often encountered by small water systems, they also lack the economies-of-scale achieved by larger water systems. The ability of larger water systems to spread administrative and management costs over a larger customer base and operate larger, more centralized and efficient water systems tends to result in a lower overall cost per customer. Ensuring New Water Systems Have Adequate TMF Capability Persons applying to OEHS for a Permit to Construct a new water system must complete a Capacity Development Questionnaire, Form EW-100 Addendum. By reviewing the applicant s completed questionnaire, we evaluate the TMF capability of any proposed new water system. Applicants providing inadequate budget information are required to prepare a water system budget. When they need assistance, we provide our self-help document, Financial Capacity Guidance Document for Small Systems. A Permit to Construct is issued only to applicants with adequate TMF capability. The goal of this finance and management review of proposed new water systems is to prevent creation of new non-viable water systems. 8

16 Ensuring DWTRF Loan Recipients Have Adequate TMF Capability We evaluate the TMF capabilities of all water systems seeking DWTRF loans. Water systems with insufficient TMF capabilities are required to develop a capital improvement plan, budget and five-year budget projection prior to loan closing. This financial information is typically obtained by completing the OEHS s Financial Capacity Guidance Document for Small Systems. Evaluating the TMF Capability of Existing Water Systems We regularly evaluate the TMF capabilities of water systems. This evaluation is performed by meeting with water system personnel and completing our TMF Capability Development Assessment Form. Reasons for evaluating water systems include: The water system requests an evaluation or assistance; Our field or permitting staff recommend evaluating the system; The water system is applying for DWTRF financing; The water system is on the Significant Non-compliance (SNC) list; or, We have determined the water system is failing (systems scoring less than 40% on the Baseline). Since the Strategy was completed in August 2000 and we began evaluating water systems in February 2001, our CDP has evaluated the TMF capabilities of 19 water systems. A summary of this work is provided in Appendix B. What We Are Finding by Evaluating Water Systems Our water system TMF capability evaluations are effectively identifying TMF capability deficiencies of water systems. Our capability evaluation reports are informing the water system and other governmental entities having jurisdiction (e.g., PSC, county commissions, town councils, etc.) of the system s deficiencies. However, the effectiveness of evaluations (pointing out deficiencies, making recommendations and suggesting assistance providers) for correction of the noted deficiencies is questionable. Except when potential project funding is threatened, when there is a likelihood of enforcement action, or when the system requested our assistance evaluating their system, most water systems evaluated are not actively pursuing the recommendations made or contacting the assistance providers suggested. Generally we find water systems requesting evaluation of their TMF capabilities receptive to our findings and recommendations for improvement. As you would expect, these systems pursue recommended assistance and require little or no follow-up except where they need help from us with a specific problem. Conversely, many water systems evaluated for the other reasons noted above have little interest in our findings and recommendations. In addition, these systems commonly do not contact assistance providers (an assistance provider list is included in the TMF capability report) and pursue assistance resolving their TMF capability deficiencies. Ultimately the quality of the water system s management team determines the successfulness of our evaluation and assistance efforts. 9

17 How We Are Assisting Water Systems Assistance is provided to drinking water systems directly by our staff. In addition, assistance is available from other state agencies and water system industry organizations. Mechanisms for assistance include: Direct on-site, hands-on assistance; Workshops, seminars and training sessions; and, Self-help guidance documents. We primarily provide direct assistance to water systems through our OEHS field staff. This assistance is provided through sanitary surveys, site visits and meetings with water system operators and managers. Our field staff conduct approximately 250 sanitary surveys every year and are in contact with water systems on a regular basis checking compliance and providing advice and assistance. This ongoing assistance to water systems through our field staff is highly effective with receptive water systems. Our Strategy proposes using information from the Baseline, TMF capability evaluations, sanitary surveys, etc. to identify and divide water system deficiencies into two categories: Site-specific TMF capability deficiencies These deficiencies are characterized by being unique to a specific water system. In addition, site-specific deficiencies typically require on-site, hands on assistance. Examples of site-specific deficiencies are: Distribution system leaks and breakdowns; Treatment works problems and breakdowns; No distribution system maps; Poor or no treatment system plans; Lack of knowledge of critical system components and their condition; and, Inadequate spare parts inventory Global TMF capability deficiencies These deficiencies are characterized as being common to numerous water systems. Often these types of deficiencies can be addressed through guidance documents or workshops delivered to a larger audience. Examples of global deficiencies are: No preventive maintenance (PM) program; No health and safety (H&S) program; No long range financial planning; Poor or no treatment system plans; and, Lack of knowledge of critical system components and their condition 10

18 We are addressing site-specific deficiencies using site-specific tools, such as: Assistance from our district office staff; Assistance from our permitting staff; Assistance from CDP staff; and, Referral to third party assistance providers. Global deficiencies are addressed using tools more suitable to global deficiencies, such as: Workshops; Group training sessions or seminars; and, Guidance documents The most common global deficiencies noted include: No long-term repair/replacement (R&R) planning; Little or no long-term financial planning; No PM procedures or policies; No H&S procedures or policies; No emergency/contingency plans; and, Lack of management understanding their ultimate responsibility for ensuring the technical capability of their water system to provide reliable, safe drinking water and an adequate budget and rates to support long-term viability of their water system. As we implement our assistance efforts, the need for additional assistance tools to address global deficiencies is becoming apparent. To address the other global deficiencies identified, we are developing a workbook to guide water systems in their efforts to prepare PM procedures, H&S procedures and emergency/contingency plans. The workbook will include generic procedures and plans, providing a framework/blueprint for the water system to develop their plans and procedures. We expect this workbook will help water systems develop and implement necessary procedures and ensure these vital areas of water system operation are addressed. To assist water systems with long term R&R and financial planning we distribute our selfhelp Financial Capacity Guidance Document for Small Systems. We have provided this document to almost every water systems we have evaluated. While we are getting this assistance document to the water systems needing them, they are frequently not completed. We believe, as the CDP evolves, it will be necessary to take a more hands-on, pro-active approach. This more aggressive approach to assistance may ensure water systems complete these self-help documents and improve their system s TMF capability. Implementing such hands-on, pro-active assistance may require additional manpower and resources. How Third Parties Are Assisting Water Systems In addition to assistance from our staff, we commonly refer water systems to third party assistance providers. We include a list of assistance providers in every TMF capability report. Third party assistance is provided through existing contractual agreements or by other state, federal or 11

19 non-profit entities. The primary third party assistance providers available to our water systems include: The Public Service Commission of West Virginia (PSC) The West Virginia Rural Water Association (WVRWA) The Maryland Center for Environmental Training (MCET) The National Environmental Training Center for Small Communities (NETCSC) The Rural Community Assistance Program (RCAP) The WV Environmental Training Center (WVETC) Arranging peer assistance from other water systems A complete list of assistance providers is included in Appendix C. 12

20 Where We Go from Here Our West Virginia CDP has been in place for approximately two years. As a result, this initial report focuses more on the problems discovered and suggestions to address those problems, than on improvements made by our state s water systems. In our Strategy, we commit to update the Baseline in calendar year 2005 (to assess the overall effectiveness of the CDP). This time frame was established because assistance efforts may not show measurable improvements for several years. Additional Reports to the Governor will be prepared every three years, with the next Report due by September 30, By the time of the next report, we expect to be able to show improvement in our water systems as a result of our work. In addition to measuring overall improvement, we evaluate water system improvement by examining the results of assistance programs. Information gathered indicates water systems are not doing an adequate job addressing recommendations provided in the TMF capability evaluation reports or seeking help from suggested assistance providers. As noted previously, a more pro-active, hands-on approach may be necessary to help more water systems move forward and address TMF capability recommendations. Several potential actions are being developed or considered to improve water system response, including: Develop generic/framework water system policies and procedures; Workshops where water systems develop long term financial plans/capital improvement plans; Require water systems develop and implement operation and maintenance procedures and long term planning; Develop a public awareness program to educate the public about the value and cost of providing reliable, safe drinking water; and, Develop additional capability, either within the BPH or through a third party, to provide more direct assistance to water systems to address common TMF capability deficiencies. We have some of these efforts currently underway or being developed. We anticipate addressing the third item (requiring water systems develop and implement operation and maintenance procedures and long term planning) through an operating permit program. At this time we only require water systems obtain a permit to construct a water system (either new water systems or modifications to existing water systems). However, our office has the authority, in 64CSR61-5, to require a permit to operate a public water system. We are in the process of developing a plan to implement an operating permit program within the BPH. As noted earlier in this report, nearly 50% of the failing water systems are located in McDowell and Wyoming counties. It is beneficial to compare the water systems in these counties with those in surrounding counties with similar, depressed, coal based economies. Most of the 13

21 surrounding counties have formed county-wide PSDs, consolidating many of their smaller, failing water systems. In addition, eight small systems in McDowell county have been consolidated into the McDowell County PSD. These county-wide PSD water systems generally are more viable than the numerous smaller water systems in McDowell and Wyoming counties. The average Baseline scores and service populations for the county-wide PSDs and the small, independent community water systems in Wyoming and McDowell counties are summarized in Table 2. Table 2 Baseline Score and Service Population Summary Water Systems in McDowell, Wyoming and Surrounding Counties Water System Baseline Score 1 Consolidated Overall System Service Population Average Service Population of Component Systems Mingo County PSD 2 70% 2, Logan County PSD 68% 18,960 1,640 Raleigh County PSD 60% 7, McDowell County PSD 60% 3, Small Unconsolidated McDowell County Systems 4 Small Unconsolidated Wyoming County Systems 4 25% 5, % 9, Average Baseline Score of component systems. 2 Much of Mingo County PSD is new, including the Naugatuck Regional Water System (under construction) 3 Projected service population if consolidated. 4 Water systems with a service population <3,000. Recently, Wyoming county formed the Eastern Wyoming PSD to consolidate eight of their failing systems (of the 25 Wyoming county systems summarized in Table 2). In part because the consolidation utilized DWTRF funding, our CDP staff evaluated the TMF capabilities of the Eastern Wyoming PSD in June At the time of our evaluation the PSD was still in the process of 14

22 formation, acquiring component systems and finalizing contractual agreements with the Logan County PSD for operation and management of the Eastern Wyoming PSD water systems. Since this PSD was only recently created, it has not yet significantly impacted the viability of these eight water systems. However, we anticipate significant improvement in the managerial and financial capability of these systems as a result of consolidation and expect these systems to improve dramatically. Within a few years the Eastern Wyoming PSD systems should achieve the viability of the countywide PSDs in surrounding counties. By consolidation we do not necessarily imply the physical consolidation or interconnection of existing water systems. While physical consolidation is valuable where appropriate and feasible, many smaller systems cannot be physically consolidated. However, these small systems can benefit dramatically through consolidation of their management, operation and finances. There are hundreds of marginal or failing small water systems throughout our state. These systems pose a constant threat of failure, disrupting the drinking water supply to their customers. Such disruptions threaten the health and welfare of the water system s customers. Additionally, the lack of reliable, safe drinking water is a significant impediment to economic development in areas served by these marginal or failing water systems. It is common for these small systems to come to your office needing tens or hundreds of thousands of dollars in emergency funds to haul water, repair or replace storage tanks, pumps, distribution system piping or treatment plant equipment. Except in the event of a natural disaster, the need for these emergency repairs is typically the result of the water system s management failing to maintain water rates adequate to properly operate, maintain, repair and replace essential water system components necessary to ensure their customers have safe, dependable drinking water. We believe drinking water systems seeking such emergency assistance from your office should receive assistance only when water system management agrees to the following obligations: Their TMF capability will be evaluated by the Bureau for Public Health Capacity Development Program; They complete a thorough financial analysis of their water system by completion of our Financial Capacity Guidance Document for Small Systems or having the PSC conduct a rate study; They be evaluated by a joint BPH/PSC task force; and, They promptly and aggressively pursue the recommendations provided by these agencies. Failure of the water system to fulfill these obligations would result in the denial of future requests for any government funds. Currently the IJDC reviews every drinking water project requesting state funds to determine if consolidation with another water system would be beneficial. While this is a very valuable review, at times resulting in a larger, more viable water system, this review process has several shortcomings, including: This consolidation review is limited to water systems applying for funding through the IJDC; 15

23 Generally, the IJDC review only considers physical consolidation opportunities and does not address opportunities for managerial/operational/financial consolidation while maintaining physically separate water systems; The IJDC can encourage failing water systems adjacent to a system applying for state funding to consolidate with the system applying for funding; however, the IJDC s jurisdiction is limited to approving or withholding funding from the applicant; as a result, even though consolidation may be the best option for both water systems, there is currently no leverage to make an adjacent failing system consolidate with the applicant system. In addition to the evaluation of water systems seeking emergency funds from your office, we anticipate an additional role for the proposed joint BPH/PSC task force. We believe an additional function of this proposed task force should be a comprehensive review of all of our state s marginal and failing water systems. The goal of this review would be identification of circumstances where: Groups of small, marginal or failing water systems can be consolidated into a larger, more viable water system; or, One or more small, marginal or failing water systems can be consolidated with an existing larger, more viable system. Currently, consolidation of small PSDs is completely under the jurisdiction of each of our state s 55 separate county commissions. In addition, small municipalities, subdivisions and other small community water systems operate with nearly complete independence. Where these small systems are well run and have adequate TMF capability they are not a problem. However, as we have seen from the Baseline data, these small systems constitute the majority of our failing and marginal drinking water systems. To address this problem, the proposed joint BPH/PSC task force should also be charged with identifying mechanisms to further encourage, and where necessary force, consolidation of failing or marginal water systems. 16

24 APPENDICES

25 APPENDIX A WEST VIRGINIA WATER SYSTEM BASELINE RANKING

26 West Virginia Community and Non-transient Non-Community Water Systems FINAL Statewide BASELINE - - August 2002 PWSID# SYSTEM COUNTY Score NAME % WV Gassaway Concrete Company Braxton 0% WV McLaughlins Trailer Park Braxton 0% WV Harranda MHP Berkeley 10% WV PRENTER WATER COMPANY BOONE 10% WV BOONESBOROUGH COMMUNITY WATER FAYETTE 10% WV DUO WATER WORKS GREENBRIER 10% WV CRITESTOWN WATER HARDY 10% WV Krates MHP Jefferson 10% WV ARCH OF W V RUFFNER LOGAN 10% WV ELKHORN PSC-ELKHORN/CROZIER McDOWELL 10% WV ELKHORN PSC-GREENBRIER/M McDOWELL 10% WV BIG FOUR PSD McDOWELL 10% WV O'TOOLE WATER-LISA McDOWELL 10% WV WAR WATER WORKS-YUKON McDOWELL 10% WV ELKHORN-UPLAND McDOWELL 10% WV UPCC-INDIAN RIDGE McDOWELL 10% WV KIMBALL L&W-LANDGRAFF, ECKMAN McDOWELL 10% WV Kimball L&W McDOWELL 10% WV ELKHORN-ROLFE McDOWELL 10% WV KIMBALL L&W-TIDEWATER McDOWELL 10% WV Ciampanella Rental Property MCDOWELL 10% WV HOOT OWL COMMUNITY WATER MERCER 10% WV EASTERN WYOMING PSD - BUCKEYE STEVENSON WYOMING 10% WV EASTERN WYOMING PSD - WELTON WATER WYOMING 10% WV GARWOOD COMMUNITY WATER WYOMING 10% WV EASTERN WYOMING PSD - PIERPONT WYOMING 10% WV EASTERN WYOMING PSD - BUCKEYE IROQUOIS WYOMING 10% WV GLOVER COMMUNITY WYOMING 10% WV BROOKSIDE-OTSEGO WYOMING 10% WV HERNDON COMMUNTIY WYOMING 10% WV COAL MOUNTAIN COMMINITY WYOMING 10% WV WYOMING CO Wtr - Pineville, Town of WYOMING 10% WV A T MILLER I I I M H P BOONE 13% WV SISTERSVILLE MUNICIPAL TYLER 13% WV RIG WATER ASSOCIATION HARDY 20% WV COUNTY WATER 2 KANAWHA 20% WV NIKKI'S DAY CARE MORGAN 20% WV ELIZABETH WATER DEPT WIRT 23% WV WAR WATER WORKS-CITY REALTY McDOWELL 25% WV HAMPTON ROADS WATER McDOWELL 25% WV KEYSTONE MUNICIPAL McDOWELL 25% WV WAR WATER WORKS-EXCELSIOR McDOWELL 25% WV FEMA Camper Park - Old Regular Baptist Church MCDOWELL 25% WV FEMA Camper Park - Cline Panther MCDOWELL 25% WV EASTERN WYOMING PSD - MULLENS NURIVA WYOMING 25%

27 West Virginia Community and Non-transient Non-Community Water Systems FINAL Statewide BASELINE - - August 2002 PWSID# SYSTEM COUNTY Score NAME % WV GLEN ROGERS PSD WYOMING 25% WV EASTERN WYOMING PSD - MULLENS WYOMING 25% WV RAMEY ADDITION WYOMING 25% WV MIRACLE MEADOWS SCHOOL HARRISON 27% WV LEISURE VALLEY CENTRAL GREENBRIER 30% WV CAVE QUARTER ESTATES JEFFERSON 30% WV EAST BANK WATER DEPT KANAWHA 30% WV WHITMER PUBLIC WATER SYS RANDOLPH 30% WV REEDY WATER ROANE 30% WV FORT GAY WATER WORKS WAYNE 30% WV Queen Shoals Clay 33% WV FOUR STATES P S D MARION 33% WV Ceredo Water Wayne 33% WV PINNACLE WATER ASSOCIATION MERCER 34% WV KANAWHA FALLS COMMUNITY FAYETTE 35% WV BROWN'S WATER SYSTEM GREENBRIER 35% WV Cardinal MOBILE HOME PARK GREENBRIER 35% WV BRADSHAW WATER McDOWELL 35% WV ANAWALT MUNICIPAL McDOWELL 35% WV ASHLAND COMMUNITY McDOWELL 35% WV KIMBALL L&W-KIMBALL McDOWELL 35% WV CRUMPLER COMMUNITY WATER McDOWELL 35% WV PAGETON HEAD START McDOWELL 35% WV McDowell County PSD - IAEGER McDOWELL 35% WV GAP MILLS PSD MONROE 35% WV GREENVILLE WATER COMMISSION MONROE 35% WV BIRCH RIVER PSD NICHOLAS 35% WV TIOGA WATER WORKs NICHOLAS 35% WV RICHWOOD WATER DEPARTMENT NICHOLAS 35% WV BAYLOR MINE RALEIGH 35% WV LESTER MUNICIPAL WATER RALEIGH 35% WV ALPOCA WATER WORKS WYOMING 35% WV EASTERN WYOMING PSD - WYCO WATER WYOMING 35% WV BRENTON PSD WYOMING 35% WV EASTERN WYOMING PSD - MULLENS ITMAN WYOMING 35% WV TALON MANUFACTURING WYOMING 35% WV PINEVILLE MUNICIPAL WYOMING 35% WV BOONE RALEIGH P W S BOONE 37% WV Clay Water Works Clay 37% WV FAIR OAKS SUBDIVISION MARION 37% WV JUDY LYNN M H P BERKELEY 40% WV POTOMAC FARMS WATER CO JEFFERSON 40% WV FOX GLEN UTILITIES JEFFERSON 40% WV HARTFORD MASON 40% WV NEW HAVEN WATER DEPT MASON 40%

28 West Virginia Community and Non-transient Non-Community Water Systems FINAL Statewide BASELINE - - August 2002 PWSID# SYSTEM COUNTY Score NAME % WV HIAWATHA WATER ASSOCIATION MERCER 40% WV CRUM P S D WAYNE 40% WV Hundred-Littleton PSD Wetzel 40% WV Highlanders Alloys Mason 43% WV PICKENS SCHOOL RANDOLPH 43% WV COALTON WATER SYSTEM RANDOLPH 43% WV Davis Water Tucker 43% WV CLIFFTOP COMMUNITY FAYETTE 45% WV DEEPWATER PSD FAYETTE 45% WV ARMSTRONG PSD FAYETTE 45% WV RED JACKET PSD MINGO 45% WV SUMMERSVILLE WATER NICHOLAS 45% WV CRAIGSVILLE PSD NICHOLAS 45% WV BRIAR WOOD ACRES NICHOLAS 45% WV RALEIGH CO PSD-HELEN RALEIGH 45% WV RALEIGH COUNTY PSD-SYCAMORE RALEIGH 45% WV SLAB FORK COMMUNITY UTILITY RALEIGH 45% WV BECKLEY WATER COMPANY RALEIGH 45% WV COVEL WATER WYOMING 45% WV Marshall County PSD #3 Marshall 46% WV JUNIOR WATER BARBOUR 47% WV CHAMBERS M H P BOONE 50% WV INDEPENDENCE COAL JACK BRanch BOONE 50% WV WHISPERING PINES M H P BOONE 50% WV Pleasant Hill PSD - Rt. 5 Dst Calhoun 50% WV Pleasant Hill PSD Calhoun 50% WV MT ZION P S D CALHOUN 50% WV Kingston Mining #2 Fayette 50% WV KINGSTON MINING, INC FAYETTE 50% WV DAVIS-STUART INC. GREENBRIER 50% WV ANTHONY CORRECTIONAL CENTER GREENBRIER 50% WV RONCEVERTE WATER GREENBRIER 50% WV BUFFALO HOLLOW M H P HAMPSHIRE 50% WV Wilding Acres Mobile Home Park Jackson 50% WV Country Day School Jefferson 50% WV Halltown PAPERBOARD COmpany JEFFERSON 50% WV COUNTRY DAY SCHOOL JEFFERSON 50% WV CEDAR GROVE WATER KANAWHA 50% WV HUGH DINGESS ELEMENTARY LOGAN 50% WV HUTCHINSON COMMunity WATER ASsociation MARION 50% WV CITY OF WELCH McDOWELL 50% WV McDowell County PSD - Pageton MCDOWELL 50% WV Mountain View Water MINERAL 50% WV PIEDMONT MUNICIPAL MINERAL 50% WV MINGO CHRISTIAN SCHOOL MINGO 50%

29 West Virginia Community and Non-transient Non-Community Water Systems FINAL Statewide BASELINE - - August 2002 PWSID# SYSTEM COUNTY Score NAME % WV Birchfield Water Assoc. Monongalia 50% WV RIVER ROAD P S D MONONGALIA 50% WV TRI - LAKE CAMPGROUND MORGAN 50% WV PRESTON CT P S D 4 PRESTON 50% WV CABELL HEIGHTS PSD RALEIGH 50% WV GLEN WHITE-TRAP HILL RALEIGH 50% WV RALEIGH COUNTY PSD-ARNETT RALEIGH 50% WV MILL CREEK WATER DEPT RANDOLPH 50% WV GRAFTON TAYLOR 50% WV LITTLE KANAWHA ESTATES WIRT 50% WV MATHENY PSD WYOMING 50% WV TRIADELPHIA WATER DEPT OHIO 51% WV Russells Trailer Court Jefferson 53% WV ELK RUN COAL CO CHESS BOONE 53% WV ELK RUN COAL BLACK KING I BOONE 53% WV Pratt Water Kanawha 53% WV UPPER KANAWHA VALLEY P S D KANAWHA 53% WV MONONGAH WATER WORKS MARION 53% WV Gallipolis Ferry Water Mason 53% WV Cass Water System Pocahontas 53% WV DIANA ELEMENTARY WEBSTER 53% WV Haymond PSD Taylor 54% WV HOLDEN WATER COMPANY LOGAN 55% WV Franklin Water Pendleton 55% WV Leight's MHP Jefferson 56% WV BEN CREEK HEAD START MINGO 56% WV C S X HOTELS INC GREENBRIER 57% WV WEST MILFORD WATER WORKS HARRISON 57% WV Evans PSD Jackson 57% WV CLENDENIN KANAWHA 57% WV REAMER HILL WATER ASSOC KANAWHA 57% WV VENTURE COKE CO L. L. C. MARSHALL 57% WV Salem Harrison 59% WV AUSTIN M H P BERKELEY 60% WV G & E M H P BERKELEY 60% WV HOBET MINING INC- PLANT BOONE 60% WV W V D O H DST 1 ROCK CK BOONE 60% WV MILTON WATER CABELL 60% WV LIZEMORE ELEMENTARY SCH CLAY 60% WV ARBUCKLE PSD FAYETTE 60% WV PAGE-KINCAID PSD FAYETTE 60% WV WVAWC-MONTGOMERY FAYETTE 60% WV PAX WATER FAYETTE 60% WV BELLWOOD COMMUNITY FACILITY FAYETTE 60% WV FAYETTEVELLE MUNICIPAL FAYETTE 60%

30 West Virginia Community and Non-transient Non-Community Water Systems FINAL Statewide BASELINE - - August 2002 PWSID# SYSTEM COUNTY Score NAME % WV WVAWC-MONTGOMERY HEIGHTS FAYETTE 60% WV DANESE PSD FAYETTE 60% WV NORMANTOWN ELEMENTARY SCH GILMER 60% WV SEWELL CREEK WATER GREENBRIER 60% WV ALDERSON WATER GREENBRIER 60% WV GREENBRIER COUNTY GREENBRIER 60% WV GRASSY LICK ELEMentary SCHool HAMPSHIRE 60% WV GOLDEN ACRES M H P HAMPSHIRE 60% WV SLANESVILLE ELEMENTARY HAMPSHIRE 60% WV GREEN SPRING VALLEY P S D HAMPSHIRE 60% WV JOHN J CORNWALL SCHOOL HAMPSHIRE 60% WV SPRINGFIELD WATER ASSOC. HAMPSHIRE 60% WV E. A. Hawse Continuous Care Hardy 60% WV PECHINEY ROLLED PRODUCTS JACKSON 60% WV CENTURY ALUMINUM OF W V JACKSON 60% WV Oak Hill MHP Jefferson 60% WV WESTRIDGE WATER WORKS INC JEFFERSON 60% WV VALLEYVIEW M H P JEFFERSON 60% WV JEFFERSON CT. HEADQUARTER JEFFERSON 60% WV KEYES FERRY ACRES NORTH JEFFERSON 60% WV PARKVIEW WOODLAND M H P JEFFERSON 60% WV SHENANDOAH PLANTATION WL JEFFERSON 60% WV KEYES FERRY ACRES CENTRAL JEFFERSON 60% WV GREEN ACRES M H P JEFFERSON 60% WV Kanawha Eagle Coal Kanawha 60% WV LINCOLN P S D LINCOLN 60% WV WEST LOGAN WATER LOGAN 60% WV LOGAN PSD-SHARPLES LOGAN 60% WV RIDGEVIEW ESTATES PROPERTIES LOGAN 60% WV LINCOLN HGHTS IMPROVEMENT MARION 60% WV MOUNTAINEER PLANT MASON 60% WV McDOWELL COUNTY-BERWIND McDOWELL 60% WV DAVY MUNICIPAL McDOWELL 60% WV McDOWELL COUNTY-BARTLEY McDOWELL 60% WV McDOWELL COUNTY-HAVACO McDOWELL 60% WV McDOWELL COUNTY-PREMIER McDOWELL 60% WV NORTHFORK WATER WORKS McDOWELL 60% WV CITY OF GARY McDOWELL 60% WV MCDOWELL - BISHOP MCDOWELL 60% WV PIEDMONT COMMUNITY MERCER 60% WV BURLINGTON PRIMARY MINERAL 60% WV NEWTOWN HOME OWNER'S ASSOCIATION MINGO 60% WV TUG VALLEY COAL PROCESSING MINGO 60% WV CREEKWOOD APTS MINGO 60% WV GILBERT HIGH SCHOOL MINGO 60%

31 West Virginia Community and Non-transient Non-Community Water Systems FINAL Statewide BASELINE - - August 2002 PWSID# SYSTEM COUNTY Score NAME % WV TUG VALLEY HIGH SCHOOL MINGO 60% WV MINGO LOGAN COAL OFFICE MINGO 60% WV MARROWBONE CREEK MINGO 60% WV CLINE ELEMENTARY SCHOOL MINGO 60% WV LENORE HEAD START MINGO 60% WV LENORE JUNIOR HIGH MINGO 60% WV MINGO LOGAN COAL COMPANY MINGO 60% WV BURCH MIDDLE SCHOOL MINGO 60% WV DINGESS ELEMENTARY MINGO 60% WV JUSTICE PSD MINGO 60% WV DINGESS HEAD START MINGO 60% WV TOWN OF DELBARTON MINGO 60% WV LENORE ELEMENTARY MINGO 60% WV Great Cacapon Elem. Morgan 60% WV Pine Valley School Morgan 60% WV WILDERNESS PSD NICHOLAS 60% WV FENWICK MOUNTAIN PSD NICHOLAS 60% WV WHITE BUCK COAL CO NICHOLAS 60% WV ZELA ELEMENTARY SCHOOL NICHOLAS 60% WV Sherwood Forest Estates Pendleton 60% WV COOL RIDGE-FLAT TOP RALEIGH 60% WV RALEIGH COUNTY PSD-FITZPATRICK RALEIGH 60% WV RALEIGH COUNTY PSD-PEMBERTON RALEIGH 60% WV RALEIGH COUNTY PSD MEMORIAL AIRPORT RALEIGH 60% WV CRAB ORCHARD WATER RALEIGH 60% WV RALEIGH COUNTY PSD-STOTESBURY RALEIGH 60% WV RALEIGH COUNTY PSD-STOCCO RALEIGH 60% WV SOPHIA MUNICIPAL RALEIGH 60% WV RHODELL WATER WORKS RALEIGH 60% WV RALEIGH COUNTY PSD-ODD RALEIGH 60% WV VALLEY HEAD ELEMENTARY RANDOLPH 60% WV GEARY ELEMENTARY SCHOOL ROANE 60% WV WV DOT SUMMERS COUNTY SUMMERS 60% WV Rockspring Development Wayne 60% WV DUNLOW ELEMENTARY WAYNE 60% WV KENOVA MUNICIPAL WAYNE 60% WV THOMPSON SENIOR CENTER WAYNE 60% WV GENOA ELEMENTARY SCHOOL WAYNE 60% WV ROAD BRANCH ELEMENTARY WYOMING 60% WV MARIANNA COMMUNITY WYOMING 60% WV BAILEYSVILLE ELEMENTARY WYOMING 60% WV BAILEYSVILLE HIGH SCHOOL WYOMING 60% WV HUFF CONSOLIDATED SCHOOL WYOMING 60% WV US STEEL WYOMING 60% WV U. S. STEEL 5A-50 WYOMING 60%

32 West Virginia Community and Non-transient Non-Community Water Systems FINAL Statewide BASELINE - - August 2002 PWSID# SYSTEM COUNTY Score NAME % WV Hodgesville PSD Upshur 62% WV Hodgesville PSD Upshur 62% WV Matewan Water Mingo 62% WV Potomac Terrace Subdivision Jefferson 63% WV Sunny View Acres Water Proj. Inc. Marion 63% WV ROANOKE ELEMENTARY SCHOOL LEWIS 63% WV FAIRMONT - RAYFORD ACRES MARION 63% WV ICES RUN P S D MARION 63% WV LITTLE LAUREL RUN IMP ASN MARION 63% WV COUNTRY CLUB ESTATES, INC MARION 63% WV M&G Polymers Mason 63% WV MASON WATER DEPARTMENT MASON 63% WV CHEAT VIEW P S D MONONGALIA 63% WV National RADIO Astronomy Observatory POCAHONTAS 63% WV POCAHONTAS CT P S D POCAHONTAS 63% WV ALPINE LAKE PUBLIC UTILIT PRESTON 63% WV SPIKER M H P PRESTON 63% WV Walton PSD Roane 63% WV PARSONS WATER TUCKER 63% WV BACK CK VALLEY DEERWOOD BERKELEY 63% WV H F CAMPSITES JEFFERSON 63% WV WALNUT GROVE UTILITIES JEFFERSON 63% WV SHENANDOAH JUNCTION M H P JEFFERSON 63% WV HARPERS FERRY CAMPSITES JEFFERSON 63% WV KEYES FERRY ACRES S WELL JEFFERSON 63% WV APPLE ORCHARD ACRES WATER MORGAN 63% WV Shenandoah Mini Homes Jefferson 64% WV KANAWHA FALLS PSD FAYETTE 65% WV MT. HOPE WATER FAYETTE 65% WV MEADOW BRIDGE FAYETTE 65% WV RAINELLE WATER DEPARTMENT GREENBRIER 65% WV WHITE SULPHUR SPRINGS GREENBRIER 65% WV SHINNSTON WATER BOARD HARRISON 65% WV MAN WATER WORKS LOGAN 65% WV LOGAN PSD-BIG CREEK LOGAN 65% WV LOGAN COUNTY PSD-RUM CREEK LOGAN 65% WV LOGAN PSD-MUD FORK LOGAN 65% WV LOGAN COUNTY PSD-STOLLINGS LOGAN 65% WV WEYANOKE-GIATTO MERCER 65% WV KERMIT WATER WORKS MINGO 65% WV GILBERT WATER WORKS MINGO 65% WV NETTIE-LEIVASY PSD NICHOLAS 65% WV GREEN CAMP COMMUNITY WYOMING 65% WV Ministers Run Water Marion 65% WV Gilmer County PSD (Rt. 5) Gilmer 66%