The profile of a small water system is kaleidoscopic – every time you try to pin it down, you see something different.
Two words spell trouble for most small systems today: money and regulation. Funding is disappearing even as the demand for water and the cost of producing it increases. Regulators, pushing for the cleanest product possible, require expensive changes to the way small systems treat and manage their water. Of course, many operators want to comply, but as part of the financial reality they wonder how that can be done.
And then, exactly what is a small water system?
Small System Definition Based On Regulatory Approach
The U.S. Environmental Protection Agency (EPA) defines a small water system as any system that serves from 15 connections (25 people) up to 1,000 connections (3,300 people). The EPA recognizes small systems as either public or private (both subject to the same regulations) and distinguishes between community and non-community systems.
Small water systems as a group vary from homeowner associations with independent water supplies to all kinds of small rural communities to mobile home parks that are not served by a city or town and even to some smaller, “non-community” entities like hospitals or campgrounds that have their own water supply. This entire group of small systems numbers 200,000!
Small System Definition By Water Source
Small water systems can also be defined by the source of water used. While the vast majority of small systems rely on groundwater (wells), the quality of that water varies widely throughout North America.
Currently, some groundwater is still of such high quality and quantity that it can be consumed without treatment just as it is extracted from the ground. Disinfection of some sort is required or recommended in most states. Although compliance requirements for small systems in this category are relatively easy, non-compliance occurrences exist based on lack of operator time (non-reporting) or money (lack of testing).
Other groundwater may be “surface water influenced” or require treatment for contaminants of health significance such as pesticides, organic wastes or natural heavy metals, and some consumers may desire removal of aesthetic contaminants such as tastes, odor, iron or hardness.
Small systems in this category usually have some kind of treatment system and must comply with a broader scope of requirements based on the potential exposure to health threatening contaminants. The incidence of non-compliance is probably slightly higher than in the first category although the water may still be very “safe.”
Surface water use requires treatment beyond simple disinfection, although some systems can maintain high water quality through watershed protection. This is a decision which is determined on a state by state basis. The treatment must be designed for the specific water quality concerns at each location. Compliance requirements for these systems is the most stringent and requires operator dedication and time. Compliance statistics for this category are not yet available since the “Surface Water Treatment Rule” was phased in just last month.
Are There Common Characteristics?
Can one say that a small water system is a miniature water system? No. The treatment of very small flows of water requires different equipment design; the financial basis of these small systems is usually very unpredictable; and the availability of good operator help in sometimes remote locations at low pay is hard to find. All of these items together spell CHALLENGE for the small water system.
Can one say that all small water systems need help? No. Although all water systems, regardless of size, can use support in the current climate of changing knowledge and regulations, many small systems are doing a great job of providing safe water. Many, many others are struggling. What makes the difference?
Variations on a Small System
The mobile home park small water system generally does not consider itself in the business of providing water. The water service charge is incorporated in the “lot rent,” meters are generally scarce, and the owner’s knowledge about current regulations can be minimal or non-existent. Does that mean that the water is unsafe? No. All it means is that the water quality is probably “unknown” and that the full impact of regulatory control has not hit home yet.
The homeowner’s association small water system is generally run by one of the homeowners, sometimes not by desire but by “recruitment.” Meters may be used, some bookkeeping and an auditing process may be used (although here, too, charges may be included in association dues), and regulatory concerns are only met if the “operator” cares. The homeowners are generally more inclined to protect their investment if the investment is worth protecting, so great differences exist.
The small rural community usually employs one or two all-purpose employees who serve as “the crew” charged with town hall maintenance, street repairs, water plant operations, wastewater operations, dog catching and even police duties. The water supply system may get only a few hours of attention each week, and service charges often fall far short of the true cost of water delivery. While the operator is a handyman and understands the mechanics of his system, he is not a chemist, engineer or financial manager and must rely on other town employees (or volunteers) for that knowledge.
Vary from State to State
To further complicate all these variations of “small,” some states regulate as a small system those which have as few as two connections while other systems with as many as 10,000 people consider themselves small.
This inconsistency of identification is noticeable throughout the administration and control of small systems. Where some states have decreed that all operators need to be certified no matter how small the system, some states have low-level cutoffs that are actually rather high. Some states do not require certification of systems which serve fewer than 800 people; some states set the lower limit at 500 connections, and so it goes.
The inconsistency in the governance or regulation of small systems has added a hodge-podge aspect to the profile of small systems. It is generally agreed that the regulatory view of a small system is synonymous with problematic water quality and poor business management practices.
The public’s perception of a small system is one of strongly defended rights to independence and unique survival techniques. This combination of independence and survival traits brings about some non-traditional approaches to water management and compliance with the regulatory demands under the Safe Drinking Water Act (SDWA).
One common denominator in most small water systems is that the operator is generally not a water professional and does not consider the “water job” the most important part of his or her responsibilities.
If the small system is financially sound either by virtue of good management or by reason of good development parameters, the system’s compliance records usually are good because the relationship between “sound home equity” and “sound water system management” are interchangeable. If, on the other hand, the system has been allowed to grow like “topsy,” is located in a remote rural area, or has been established without any planning tools in place, the chances of major compliance problems and questionable water quality increase.
Because of the wide diversity of physical profiles of small systems, there is an equally wide diversity in attitudinal profiles. Some small systems are run by “operators” who take pride in their product and their small
system. Some of these operators are certified, some are not. Some are highly educated, some are not. Some consider themselves water operators, some consider the job a hobby, and some don’t want to talk about it!
Safe Water and Regulation
Get a group of water people together and without fail two words come up: safe water. Close behind, another word follows: regulation. Often, the two are taken to mean the same thing. But do they? No. As important as water quality and regulation are, safe water is more: It also encompasses reliability, adequate supply, and a distribution system that works without interruption.