DDW-2024-011705

Report to EPA

on the

State of Utah’s

Capacity Development Program
for
Utah State Fiscal Year 2023
July 1, 2022 – June 30, 2023

Utah Department of Environmental Quality
Division of Drinking Water
Salt Lake City, UT
September 2023

Table of Contents
Section 1 State of Utah Capacity Development Program
1.1 Authority
1.2 Program Rule
1.3 Program and Budget Resources
1.4 State Capacity Development Program Strategy
1.5 Asset Management

Section 2 New System Program
2.1 Control Points
2.2 New Water System List FY2023

Section 3 Existing System Program
3.1 Identifying PWS’s in Need of Capacity Assistance
3.2 Factors that Impair or Enhance Capacity
3.3 Using SDWA Authorities and Resources
3.4 Establishing a Baseline and Measuring Improvement
3.5 Identifying Stakeholders
3.6 EPA Enforcement Targeting Tool (ETT) List
3.7 DWSRF Project List FY2023

Appendix A DWSRF Program Checklists
Appendix B Factors that Impact Capacity
Appendix C Operator Certification Website Overview Graphic
Appendix D Initial Order for New Public Water System - Template
Appendix E 2022 Updated State Capacity Development Program Strategy Document

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Capacity Development Program State of Utah FY2023 Page 1
Section 1 – State of Utah Capacity Development Program
1.1 Authority
The Utah Drinking Water Board operates under authority granted in 1981, and upheld
through subsequent reauthorizations, under Utah Code Title 19 Chapter 4, the Utah Safe
Drinking Water Act. The Utah Drinking Water Board is a 9-person board appointed by
the Governor. The Board is empowered to adopt rules governing the design, operation,
and maintenance of Utah's public drinking water systems, including Capacity
Assessment and Development.

1.2 Program Rule
The Utah Capacity Development Program is codified in Utah Administrative Code Rule
R309-800 Capacity Development Program. The Utah Department of Environmental
Quality, Division of Drinking Water (DDW, the Division) is the primacy agency for the
federal Safe Drinking Water Act (SDWA) and implements and oversees the rules
authorized by the Drinking Water Board. During FY2023 the Division of Drinking
Water completed the process to update R309-800 Capacity Development Program to
meet the new Asset Management requirements. The updated rule became effective on
May 22, 2023. The updated rule is available from the Division of Administrative Rules
website.

1.3 Program and Budget Resources
The State of Utah allocates money to a specific Capacity Development set-aside fund in
accordance with SDWA program guidelines. The State’s fiscal year begins each calendar
year on July 1st and ends on June 30th of the following calendar year. The Division began
FY2023 with $47,800 in the Capacity Development set-aside fund (state financial
tracking Unit Code 3823). During the year $21,041 was charged against this fund. The
Division did not request any funding for this set-aside from the FY2023 capitalization
grant. The Division expects to have $26,800 for Capacity Development Program
oversight for FY2024.
The Utah Capacity Development Program supports the federal and state Drinking Water
State Revolving Fund (DWSRF) programs. For FY2023, the State of Utah Drinking
Water Board authorized funding for 93 total projects through the DWSRF programs. 44
of those projects were planning projects and 49 were infrastructure construction or
rehabilitation projects. Total DWSRF funding authorizations in FY2023 were
approximately $233,260,159 of which $204,650,159 was allocated from the federal SRF
program, $21,614,000 was allocated from the State SRF program, and $6,996,000 was
allocated from American Rescue Plan Act funds appropriated to the State of Utah and

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Capacity Development Program State of Utah FY2023 Page 2
then reallocated by the Utah Legislature to the Drinking Water Board.
From the pool of previously authorized projects, Division Staff closed loans to complete
the funding process for 27 projects during FY2023. Fourteen of those projects were
planning projects and thirteen were infrastructure construction or rehabilitation
projects. Total obligated financial assistance funds in FY2023 were approximately
$51,870,463 of which $35,806,963 was allocated from the federal SRF program,
$1,999,500 was allocated from the State SRF program, and $14,064,000 was allocated
from American Rescue Plan Act funds appropriated to the State of Utah and then
reallocated by the Utah Legislature to the Drinking Water Board.

1.4 State Capacity Development Program Strategy Document
The Division of Drinking Water began updating the State’s Capacity Development
Program Strategy Document during FY2022. The Division submitted its updated
Program Strategy Document to EPA Region 8 on January 9, 2023.

1.5 Asset Management
House Bill 269 Capital Assets Related to Water passed the legislature during Utah’s
2022 legislative session and was signed into law by the Governor. This law reads, in
part:
“(1) As a condition of receiving state or federal financing or grants to be used for an
improvement to a capital asset related to water infrastructure, the governing body of a water
provider shall commit to adopt a capital asset management plan.
(2) (a) The Drinking Water Board shall make rules, in accordance with Title 63G,
Chapter 3, Utah Administrative Rulemaking Act, to establish the elements of a capital asset
management plan required under Subsection (1) for a water provider that is a retail water
supplier.”
In accordance with the requirements outlined in HB269, during FY2023, the Division
updated its DWSRF Program rules, R309-700 and R309-705, and the Capacity
Development Program rule, R309-800. The updated rules became effective May 22,
2023. In addition, the following language was added to authorization letters prepared
for projects receiving financial assistance through either the federal or state SRF
program:

“In compliance with Utah Code Annotated 73-10g-402, water systems applying for federal or
state financial assistance for improvements to capital assets related to water infrastructure shall
commit to adopt a capital asset management plan. The Asset Management Plan shall be
submitted to the Division for review and approval prior to loan closing, unless preparing an
Asset Management Plan is included as part of the project for which the Recipient has applied for

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Capacity Development Program State of Utah FY2023 Page 3
financial assistance. In which case, the Asset Management Plan shall be submitted to the
Division as soon as it is completed or prior to the entity submitting its final project
reimbursement request.”
To further ensure water systems comply with these requirements, asset management
plan sections have been added to our loan closing and construction project
reimbursement request checklists. Copies of these documents are provided in Appendix
A.

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Capacity Development Program State of Utah FY2023 Page 4
Section 2 New System Program
2.1 Control Points
Capacity Development Worksheets or Business Plan
Utah’s legal authority to implement the SDWA’s Capacity Development provisions in
§1420(c)(2)(A) through (F) is codified in Utah Code Title 19 Chapter 4, the Utah Safe
Drinking Water Act. The Utah Drinking Water Board is empowered by this statute to
adopt rules governing the design, operation, and maintenance of Utah’s public drinking
water systems, including capacity development. The Board has adopted Drinking Water
Rule R309-800 Capacity Development Program establishing a state capacity
development program.
Utah’s capacity development program rule requires all proposed new systems, or newly
discovered systems, to demonstrate adequate technical, managerial, and financial
capacity through one of two methods:
1. Proposed new systems must submit a capacity development business plan,
defined in R309-800-6(1), to Utah DDW for review and approval before it may
serve drinking water to the public. The capacity development business plan
requirement has been updated to require proposed systems include an asset
management plan.
2. Newly discovered systems must either submit completed capacity development
worksheets or a capacity development business plan, whichever best suits the
systems situation, to Utah DDW for review and approval. The capacity
development worksheets have been updated to include questions regarding asset
management.
Both methods, updated to include asset management, provide water system owners the
opportunity to understand the financial and operational commitment necessary to
owning and operating a viable, sustainable public water system. They also provide Utah
DDW staff an opportunity to discuss these commitments and regulatory requirements,
as well as encourage asset management, with owners or prospective owners as well as
determine a system’s capabilities and capacity to meet the requirements of the SDWA
and Utah’s drinking water rules.
Engineering and Permitting Approval
Proposed new systems must obtain an operating permit from the Division prior to
providing water for public consumption. Proposed new systems typically follow the
standard approval format:
• Submit the project notification form,
• Submit engineering design plans and specifications for all system infrastructure
to the Division,

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Capacity Development Program State of Utah FY2023 Page 5
• Submit proof of legal right to use water from the proposed source with
documentation provided by the Division of Water Rights,
• Submit a drilling start card from the Division of Water Rights (for well
construction only),
• Respond to comments or questions from Division review engineer (if any),
• Receive Division approval for project construction.
After construction, the system applies for the operating permit and submits the
following information:
• As-built drawings,
• Engineer’s statement that all plan approval conditions were met,
• Water quality data,
• Any Operation & Maintenance Manuals and as-built drawings,
• Any other relevant documentation used in the plan review process.
The Division has prepared an Operating Permit Checklist to help water systems ensure
they are submitting the proper documents.
Initial Order for New Public Water System
When the Division learns of a newly discovered water system serving the public, one of
the first actions undertaken is to notify the responsible party that they are a public water
system and therefore are subject to regulation under state and federal statutes. The
“Initial Order for New Public Water System” docket notice and cover letter is drafted
and sent to the responsible party, via certified mail. A template of the notice and cover
letter are included in Appendix D.
In addition to complying with the requirements outlined in the Initial Order, newly
discovered systems must also apply for and receive an operating permit before they can
receive a system rating and continue legally serving water to the public. This process is
very involved and requires considerable time. The process involves site visits by Division
and Local Health Department (LHD) staff to inspect and evaluate system infrastructure,
investigations to identify any existing engineering plans and specifications, and
identifying any other system data or information including but not limited to, ownership
records, water quality data, and water rights data. The system’s administrative contact
or other responsible party is given specific deadlines by which they must respond to
comply with the requirements of the Initial Order. Lack of a response to the Initial
Order’s requirements may result in enforcement action against the system.

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Capacity Development Program State of Utah FY2023 Page 6
2.2 New Water System List FY2021-2023
PWSID PWS Name
First
Reported to
SDWIS
Highest
ETT (if over
11 what
qtr did the
ETT rtn to
<11)
Discovered
or Planned
TMF self -assessment or TMF assistance -
provide narrative
UTAH13060 CLARK BENCH WATER COMPANY 8/19/2020 0 Discovered
Self Assessment – system provided
information when applying for financial
assistance, system is consolidating with local
water conservancy district, infrastructure
improvement project is in progress
UTAH29126 COBBLES CONDOMINIUM HOA 8/19/2020 0 Discovered
Assistance – Initial Order for New Public Water
System, system is currently rated “Approved”
under Utah’s IPS Rule
UTAH24051 DESERT SAGE HOA 8/19/2020
30
Q4/22 Discovered
Assistance – System received guidance and
assistance from Division staff and local
Improvement District, financial assistance
from American Rescue Plan Act to improve
infrastructure and consolidate with the local
improvement district, project is in progress
UTAH11099 FOOTHILL WUA 11/19/2020 19 Discovered
Assistance – Corrective Action/Enforcement
Order, system is currently rated “Not
Approved” under Utah’s IPS Rule and is
pursuing financial assistance to correct
physical deficiencies, system is also working
on resolving operator certification, source
protection, and monitoring and reporting
violations.

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Capacity Development Program State of Utah FY2023 Page 7
2.2 New Water System List FY2021-2023 (cont)
UTAH18183 MUIRHOUSE HOA 5/13/2020 3 Discovered
Assistance – Initial Order for New Public Water
System, system is currently rated “Approved”
under Utah’s IPS Rule
UTAH19080 SAN JUAN SPANISH VALLEY SSD 8/19/2020 1 Planned
Self Assessment – system provided
information when applying for DWSRF
financial assistance, system is currently rated
“Approved” under Utah’s IPS Rule
UTAH29131 THE RUBY 5/23/2022 1 Discovered
Assistance – Initial Order for New Public Water
System, Compliance Agreement/Enforcement
Order, system is rated “Not Approved” under
Utah’s IPS Rule
UTAH29128
WEBER STATE UNIVERSITY - OGDEN
CAMPUS 11/19/2020 2 Discovered
Assistance – Initial Order for New Public Water
System – the system is currently rate
“Approved” under Utah’s IPS Rule
UTAH06045 ARMSTRONG WATER COMPANY 5/23/2022 0
This is a non-public system and therefore not
regulated under current SDWA or state
statutes

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Capacity Development Program
State of Utah FY2023 Page 8
Section 3 – Existing System Program
3.1 Identifying PWSs in Need of Capacity Assistance
SDWA §1420(c)(2)(A)
The Division developed and defined a list of specific violations with a corresponding
point value based on the severity of the infraction. This list of violations is codified in
Utah Administrative Code Rule R309-400 Improvement Priority System and Public
Water System Ratings. This rule establishes the system by which the Division assigns
compliance ratings to public water systems (PWSs) and prioritizes enforcement action
and technical assistance to those systems.
The Improvement Priority System (IPS) Rule was completely revised in 2018 and 2019
and the new rule went into effect January 1, 2020. Rule revisions included examining
each violation and its associated penalty points to assure more severe violations were
assessed correspondingly more severe penalty points. This revision significantly
impacted the number of water systems that would potentially become “not approved”
systems. However, Division staff and technical assistance providers worked closely with
water system staff and operators to bring systems into compliance and greatly reduced
the number of impacted systems.
DDW evaluates a PWS’s compliance record and based on the total number of deficiency
points, rates the system as “approved,” or “not approved.” The PWS classification
determines how many deficiency points the PWS may accumulate before being assigned
a “not approved” status.
Table 1 – IPS Points for “Not Approved” Status
System Type Assessed Points
Community Water Systems 150
Non Transient, Non Community Systems 120
Non Community Water Systems 100

A “not approved” rating remains in place until the threat to public health is alleviated, or
the violation is corrected. However, a water system may qualify for a “corrective action”
status, if the PWS submits the following three items:
• A written agreement stating a willingness to comply with the requirements of the
Administrative Rules.
• A compliance schedule outlining the necessary construction or changes needed to
correct any physical deficiencies or monitoring failures.

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Capacity Development Program
State of Utah FY2023 Page 9
• Proof of financial ability to correct the deficiencies.
The “corrective action” rating remains in place until the system has resolved all
compliance issues impacting the system’s status.
DDW uses this rating system to identify and prioritize which systems are most in need
of technical assistance, training, or other help. This assistance may include any of the
following:
• site visits • on-site training
• administrative orders • hearings
• penalties • court action

The Division may provide this assistance using Division staff or by employing a third-
party technical assistance provider, such as the Rural Water Association of Utah
(RWAU) or Rural Community Assistance Corporation (RCAC). The Division coordinates
technical assistance for water systems through a quarterly meeting, the Action
Compliance Strategy Meeting, where Division staff meets with technical assistance
provider staff and LHD representatives to discuss out-of-compliance water systems and
what assistance those systems may need to improve their capacity and return to
compliance with SDWA and national water quality standards.

3.2 Factors That Impair or Enhance Capacity
SDWA §1420(c)(2)(B)
Many factors have the potential to either enhance or impair a water system’s capacity.
Division staff and technical assistance providers have held numerous discussions
regarding which factors are most likely to affect capacity. While capacity is measured
through technical, managerial, and financial aspects, oftentimes a specific factor will
have influence across multiple aspects.
For instance, adequate user rates and rate structures is one factor that both Division and
technical assistance provider staff identified as having significant impacts on system
capacity, across all three topics. Without adequate user rates, water systems will lack the
financial wherewithal to hire and train appropriate staff which could negatively impact
both technical and managerial capacity. In addition, there may be insufficient funds to
pay bills on time which could negatively impact credit worthiness, and therefore
negatively impact financial capacity.
Appendix B contains tables of identified factors that will impact water system capacity
as well as whether that impact is positive or negative.

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Capacity Development Program
State of Utah FY2023 Page 10
3.3 Using SDWA Authorities and Resources
SDWA §1420(c)(2)(C)
3.3.1 Assist PWSs with Compliance
The Division has implemented a number of programs and activities to assist water
systems achieve and maintain compliance with SDWA and national drinking water
standards. A few of these programs are described below.
o The engineering plan review and operating permit program.
• Water systems are required to submit engineering plans and specifications
to the Division for review and approval prior to beginning construction on
any facility improvement or expansion.
• The Division’s Permitting Section reviews the submitted plans to assure
compliance with the Division’s construction rules (codified in Drinking
Water Rules R309-500 through -550, available on the Division’s website
here: https://deq.utah.gov/drinking-water/laws-and-rules#500).
• The Permitting Section typically responds with plan approval or denial
within 30 days of receiving the submittal, depending on project complexity
and size.

o The Drinking Water State Revolving Fund financial assistance program.
• The Division’s Infrastructure Funding Section provides oversight to two
revolving fund financial assistance programs.
 The state-funded program receives an annual allotment from the
state sales tax revenue, capped at approximately $3,600,000 per
year.
 This financial assistance is available only to political
subdivisions of the state (municipalities, water districts,
etc.).
 The federal revolving fund program receives an annual
capitalization grant from USEPA based on Congressional
allocation and varies from year to year.
 Financial assistance from this program is available to both
publicly and privately-owned water systems.
• Financial assistance is available for planning or construction of
infrastructure improvement projects designed to help water systems
achieve or maintain compliance with SDWA requirements and national
drinking water regulations.

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Capacity Development Program
State of Utah FY2023 Page 11

o The source water assessment and protection program.
• The source water assessment program assesses the risk of accidental
contamination of all drinking water sources.
• Utah’s source protection rules require that each public drinking water
supplier prepare a source protection plan. The plan must describe and
delineate source protection zones and describe protections in place to
protect source waters from accidental contamination.
• All source protection plans must be reviewed and approved by Division
source protection staff.

o The Sanitary Survey program.
• Utah state regulations require that a sanitary survey be conducted at least
every three years on all public water systems. These surveys assess water
system construction, operations, and record keeping and identify potential
conditions that may present a public health risk.
• Sanitary surveys are conducted either by Division of Drinking Water
personnel, Utah Department of Environmental Quality District Engineers,
local health officials, or other qualified individuals authorized in writing by
the Division Director.

3.3.2 Encourage Partnerships Between PWSs
Utah encourages partnerships between water systems through a number of different
avenues.

The Utah Water Quality Alliance
The Alliance consists of the largest surface water suppliers in Utah, as well as small- and
medium-sized systems that operate water treatment plants. The Alliance meets
quarterly and provides training to water system staff as well as networking
opportunities for PWSs. The Alliance’s goals include assisting drinking water utilities
with water quality optimization projects, updating utilities on regulatory updates and
new regulations, and a commitment to continuous drinking water quality enhancement.
Alliance members work together to find ways to improve monitoring source water and
treated water quality, optimize water treatment processes, and enhance treatment plant
performance in removing contaminants, evaluate new technologies, participate in
drinking water research, provide input in the federal and state regulations, and assist

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Capacity Development Program
State of Utah FY2023 Page 12
smaller water utilities to produce drinking water of the best quality for the citizens of the
State of Utah.

Utah WARN
The Utah Water/Wastewater Agency Response Network’s (WARN) mission is to support
and promote statewide emergency preparedness, disaster response, and mutual
assistance matters for public and private water and wastewater utilities. The Utah
WARN website provides members with emergency planning, contact, and recovery
information, before, during, and after an emergency.

System Consolidation and Regionalization
The Division encourages water systems to investigate and implement regionalization or
consolidation efforts to the extent possible. Regionalization or consolidation may take
on a number of different forms, from merging system infrastructure, to sharing source
capacity, to managerial cooperation where multiple neighboring systems share
management and operational staff to reduce costs and take advantage of economies of
scale and improve buying power.

3.3.3 Assist PWSs through Operator Training and Certification
Water systems serving more than 800 people, and all systems that use physical or
chemical treatment processes to alter the water’s characteristics, must have a certified
operator. In State Fiscal Year 2023 there were 1,054 documented public water systems
in Utah. Table 2 shows the number of each public water system type reported to the
state that year.
Table 2 – Public Water System Classification FY23
Type Number
CWS 505
NTNCWS 83
NCWS 466

The Division’s Operator Certification Program website (https://deq.utah.gov/drinking-
water/operator-certification) provides individuals with information about the Operator
Certification Program, details on how to become a certified water operator, certification
application and renewal forms and their associated fees, information on upcoming

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Capacity Development Program
State of Utah FY2023 Page 13
continuing education opportunities, continuing education course forms, as well as a
frequently asked questions section.
Division records indicate that in Utah there were 2,706 certified water operators holding
a total of 3,226 certifications during state FY2023. Also, during FY2023, 637 individuals
sat for certification examinations in one or more certification disciplines. Of those 637
individuals, 384 passed the exam, a 60.3% pass rate. Furthermore, during the same
time frame 2,083 individual operators participated in 549 reported unique continuing
education courses. During FY2023 many courses were offered virtually or combined in-
person and virtually. Continuing education courses are offered by a number of different
entities, including RWAU, RCAC, the American Water Works Association
Intermountain Section (AWWA-IMS), individual water systems, and various online
providers. All courses submitted for operator certification continuing education unit
credits must be reviewed and approved, or pre-approved, by the Operator Certification
Commission Secretary.

3.4 Establishing a Baseline and Measuring Improvement
SDWA §1420(c)(2)(D)
Utah uses the IPS point system outlined in Utah Drinking Water Rule R309-400 to
establish baseline water system regulatory compliance. The Division tracks changes to a
water system’s deficiency points in the WaterLink database and web application. The
WaterLink web application was developed to provide a central access point for Division
information related to water systems, including contacts, deficiencies, violations,
infrastructure inventories, site visit information, engineering plan review and approval
activities, operator certification records, and DWSRF project data.
WaterLink is available on the Internet at: https://waterlink.utah.gov/deqWater/. Public
access to general water system information is available from the basic WaterLink access
page. Access to more specific information requires users to apply for a portal account.
Compliance improvement will be measured on the basis of the number of systems either
reducing their deficiency point count, returning to compliance and an “approved” status
after being rated either “not approved” or “corrective action,” entering voluntary
compliance agreements, or applying for and using financial assistance to resolve
infrastructure deficiencies.

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Capacity Development Program
State of Utah FY2023 Page 14
3.5 Identifying Stakeholders
SDWA §1420(c)(2)(E)
Stakeholders may include any party interested in evaluating or improving water system
capacity. Stakeholders can include any or all of the following entities:
Regulatory Agencies
o Environmental Protection Agency
o Division of Drinking Water
o Local Health Department
o County and/or municipal governments
o Governing boards and bodies for privately-owned water systems
Technical Assistance Providers
o RWAU
o AWWA-IMS
o RCAC
o Educational Institutions
o Environmental Finance Centers
Associations
o League of Cities and Towns.
o American Planning Association
o Utah City Engineers Association
This list is by no means all-encompassing, and many other groups may consider
themselves stakeholders in addressing and improving water system capacity.
Another important stakeholder group that deserves consideration is the general public.
A water system’s user base is perhaps the most affected stakeholder group of any listed.
The Division strongly encourages all of the state’s water systems to be open and
transparent with their users in all aspects of water system operation, maintenance, and
construction.

3.6 Asset Management
SDWA §1420(c)(2)(F)
Asset management can help water systems address aging water infrastructure, make
sound financial decisions to maximize limited financial resources, make costs
transparent, and support budgeting decisions. A proper asset management plan can
improve a system’s service and reliability, reduce risk and unexpected costs, and

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enhance communication with customers and stakeholders, in addition to many other
benefits.
An asset management plan is the foundation for an effective asset management program
and typically includes sections describing level of service goals, current performance
metrics and measurements, future demand estimates, risk management, life cycle
management plans (e.g., maintenance plans, rehabilitation and replacement plans), and
financial forecasts.
The asset management framework is built on the following five core questions, the
answers to which will form the basis of each section in the asset management plan.
1. What is the current state of the utility’s assets?
2. What is the utility’s required “sustainable” level-of-service?
3. Which assets are critical to sustained performance?
4. What are the utility’s best “minimum life-cycle cost” capital improvement plan
and operations and maintenance strategies?
5. What is the utility’s best long-term financing strategy?
Utah DDW’s capacity development program will use DWSRF set-asides and third-party
contractors to provide training on these five core elements and promote and encourage
asset management for all the state’s public water systems. Asset management training
will focus on helping systems understand asset management, developing asset
management plans, identifying tools & techniques for inventory development, water
system mapping methods, financial planning and implementation strategies including
rate structures, billing policies and procedures, and proper budgeting methods. Other
pertinent aspects of asset management plans and asset management programs will also
be included based on water system input and comments.
In addition, Utah House Bill 269 Capital Assets Related to Water, was passed in the
2022 State Legislature and signed into law by the Governor. The law requires existing
water providers to develop and implement a capital asset management plan before they
can receive financial assistance from either state or federal funds. The law also requires
that water providers participate in any infrastructure needs surveys or evaluations
required by Utah DDW.
Utah DDW will send Capacity Assessment Worksheets to those systems ranked highest
with respect to need for technical, managerial, financial, or asset management capacity
assistance to ensure this foundation is established at the state’s most vulnerable
systems. Those systems that are, or may soon be, ranked “corrective action” or “not
approved” or that are approaching an EPA ETT score of 11 will be targeted as high
priority to receive the self-assessment worksheets. These self-assessment worksheets

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include the five core components of asset management and references to Utah DDW’s
website for additional capacity assessment and asset management information. Utah
DDW believes that capacity assessment and asset management can benefit all public
water systems regardless of ranking and will provide training to encourage the state’s
systems to complete the self-assessment capacity worksheets and develop and
implement capacity assessment and asset management programs.
Public water systems seeking financial assistance from the Drinking Water State
Revolving Fund program must complete the Capacity Assessment Worksheets and
submit them to Utah DDW for review and comment before any financial assistance will
be approved. However, all public water systems are encouraged to download these
worksheets and determine their needs with respect to technical, managerial, and
financial capacity or asset management. Upon request Utah DDW will review each
system’s responses on the self-assessment worksheets and help systems better
understand how to resolve any issue discovered during that review.

Capacity Development Worksheets
Utah’s legal authority to implement the SDWA’s Capacity Development provisions in
§1420(c)(2)(A) through (F) is codified in Utah Code Title 19 Chapter 4, the Utah Safe
Drinking Water Act. The Utah Drinking Water Board is empowered by this statute to
adopt rules governing the design, operation, and maintenance of Utah’s public drinking
water systems, including capacity development. The Board has adopted Drinking Water
Rule R309-800 Capacity Development Program establishing a state capacity
development program.
Utah’s capacity development program rule provides a method for all existing drinking
water systems to determine or demonstrate their technical, managerial, and financial
capacity. The capacity development worksheets, which have been updated to include
questions regarding asset management, provide all systems, regardless of size or
complexity, a means to perform a self-assessment and gauge their level of technical,
managerial, and financial capacity. These self-assessments give the systems a starting
point from which they can begin to plan for and implement changes to improve capacity
and better manage assets to become more viable and resilient.

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Capacity Development Program
State of Utah FY2023 Page 17
3.6 EPA ETT List FY2021 - 2023
Existing systems (Com, NTNC and TNC) list of PWSs (last three years) with an ETT score of 11 or greater
for the Utah 2023 Annual Capacity Development Program Report.
PWSID PWS Name PWS Type
Highest
ETT
TMF self -assessment or TMF assistance -
provide narrative
UTAH13001 ALTON TOWN WATER SYSTEM Community 11
Assistance – System under Compliance Order to
resolve physical deficiencies with source and
storage as well as operator certification and
cross-connection program deficiencies
UTAH03002
AMALGA TOWN WATER
SYSTEM Community 27
Assistance – System lacks a certified direct
responsible charge operator, compliance assessment completed 3/24/2023; source
protection issues; physical deficiencies at 4
active sources
UTAH28037 ASPEN RANCH
Non-Transient
Non-Community 16
Assistance – Systems has failed to collect and
report point of entry chlorine residual samples.
Needs technical assistance to improve system
technical capacity.
UTAH26050
BACK FORTY RANCH HOUSE
GRILL
Transient Non-
Community 12
Assistance – System has failed to collect and
report nitrate samples. Needs technical
assistance to improve technical capacity.
UTAH22090 BEAR RIVER ADMIN SITE
Transient Non-
Community 11
Assistance – Triggered groundwater rule
monitoring due to TC+/EC- results w/o reports;
wellhead terminates approximately 5 feet below
ground surface in 4-foot diameter casing,
requires retrofit.
UTAH22033 BEAR RIVER CAMPGROUND
Transient Non-
Community 11
Assistance – System sanitary survey 8/20/2020,
IPS updated Sep 9, 2023, system is rated
“Approved.”
UTAH22036
BRIDGER LAKE
CAMPGROUNDS
Transient Non-
Community 11
Assistance – System failed RTCR monitoring in
June 2023, needs technical and managerial
assistance
UTAH11053 BUENA VISTA COMMUNITY Community 11
Assistance – System lacks redundant source,
system needs technical assistance to resolve
physical deficiencies on source and storage
facilities
UTAH22114 BULL MOOSE WATERWORKS
Transient Non-
Community 11
Assistance – System has temporary operating
permit for source requiring treatment; system
failed to monitor and report chlorine residuals;
system has physical deficiency on storage tank
UTAH15023 CAMP ZARAHEMLA
Transient Non-
Community 22
Assistance – System lacks complete Cross-
Connection Control Program, otherwise no
physical deficiencies or monitoring and reporting
violations; system is rated “Approved”

Annual Report to US EPA
Capacity Development Program
State of Utah FY2023 Page 18
3.6 EPA ETT List FY2021 – 2023 (cont)
UTAH29062
CAMPS BEN LOMOND-
SHAWNEE
Transient Non-
Community 11
Assistance – System lacks permanent operating
permit; violation for lack of public notice linked
to violation; system failed routine RTCR
monitoring; system lacks complete Cross-
Connection control program
UTAH25009 CEDAR FORT WATER SYSTEM Community 11
Assistance – System failed to monitor and report
distribution system chlorine residuals. System
requires technical assistance to ensure samples
are correctly drawn, analyzed and reported.
UTAH22112
CHRISTMAS MEADOWS
CABINS
Transient Non-
Community 13
Assistance – System has several physical
deficiencies identified during sanitary surveys
and requires technical assistance to resolve the
issues.
UTAH02053
COLEMAN MOBILE HOME
COURT Community 11
Assistance – system received assistance from
DDW and RWAU to resolve both physical
deficiencies and operator certification violations.
System has returned to compliance.
UTAH03005
CORNISH TOWN WATER
SYSTEM Community 16
Assistance – System requires technical assistance
to resolve cross-connection control program
deficiencies and operator certification
deficiencies. System has applied for financial
assistance to resolve physical infrastructure
deficiencies.
UTAH26071 DANIELS SUMMIT ESTATES
Transient Non-
Community 11 Assistance – System lacks sufficient storage for
fire suppression.
UTAH10012
DAY STAR ADVENTIST
ACADEMY Community 11
Assistance – System DRC not certified at proper
level. System lacks more than 20% of required
storage capacity, issued a temporary exception
to storage requirement (expires Aug 2024). System needs technical assistance on monitoring
and reporting requirements.
UTAH22101 DEEP SPRINGS WATER CO Community 13 Assistance – System not current on all DWSP
Plans. Storage facility needs repair.
UTAH26033 DEER CREEK PARK
Transient Non-
Community 32
Assistance – System spring collection area not fenced, issued a temporary exception which
expires Jan 2024. System lacks more than 20% of
required storage capacity, issued a temporary
exception which expires Sep 2024. System needs
technical assistance with monitoring and
reporting.
UTAH23028 DELLE AUTO TRUCK STOP
Transient Non-
Community 12
Assistance – System has several physical
infrastructure deficiencies with temporary
exceptions expiring July 2025.

Annual Report to US EPA
Capacity Development Program
State of Utah FY2023 Page 19
3.6 EPA ETT List FY2021 – 2023 (cont)
UTAH24051 DESERT SAGE HOA Community 30
Assistance – System lacks a cross-connection
control program. System has numerous physical
infrastructure deficiencies. System needs
technical assistance with monitoring and
reporting. System has received financial
assistance to update and resolve infrastructure
issues and will be consolidated with a local water
conservancy district. Project is in progress.
UTAH26073
DIAMOND HILLS
ASSOCIATION
Transient Non-
Community 13 Assistance – System needs technical assistance
with monitoring and reporting.
UTAH05001
DUTCH JOHN TOWN WATER
SYSTEM Community 12
Assistance – System needs technical assistance
to ensure proper monitoring and reporting for
phosphates in distribution system due to
iron/manganese removal process at treatment
plant.
UTAH25146 EAGLES LANDING Community 11
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete.
UTAH04012 EAST CARBON CITY Community 11
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System is building a new water
treatment plant to resolve physical deficiencies
in existing plant.
UTAH22003
ECHO MUTUAL WATER
SYSTEM Community 11
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System has multiple TCR violations
and is investigating spring sources as the cause.
Drought has reduced spring flow rates to below
sustainable levels and the System is investigating
solutions to the problem.
UTAH12004 EUREKA TOWN Community 12
Assistance – System needs technical assistance
to update source protection plans. System needs
technical assistance with monitoring and
reporting requirements. System needs technical
assistance to resolve operator certification
issues.
UTAH11099
FOOTHILL WATER USERS
ASSOCIATION Community 23
Assistance – System has multiple physical
infrastructure deficiencies. System has applied
for financial assistance to help resolve these
physical deficiencies. System needs technical
assistance with monitoring and reporting
violations. System needs technical assistance to
ensure cross-connection control program is
complete.

Annual Report to US EPA
Capacity Development Program
State of Utah FY2023 Page 20
3.6 EPA ETT List FY2021 – 2023 (cont)
UTAH14032 GARRISON CHURCH
Transient Non-
Community 11 Assistance – System needs technical assistance
with monitoring and reporting.
UTAH02031 GIRLS HOME
Transient Non-
Community 40
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete.
UTAH03086 HIGH CREEK WATER CO Community 12
Assistance – System failed to report annual
water use or verify data accuracy. System has no
means to measure flow rate of water treated at
its chlorination facility or to measure flow rate of
water produced at its source.
UTAH14050
INTERMOUNTAIN POWER
SERVICE CORP
Non-Transient
Non-Community 12
Assistance – This system has no IPS points
reported in the Division’s database and is rated
“Approved.”
UTAH01008 KENTS LAKE CAMPGROUND
Transient Non-
Community 12 Assistance – System needs technical assistance
with monitoring and reporting for RTCR.
UTAH18179 L & B RESOURCES
Non-Transient
Non-Community 15
Assistance – This system has no IPS points
reported in the Division’s database and is rated
“Approved.”
UTAH22104 LAKE ROCKPORT ESTATES
Transient Non-
Community 13
Assistance – System lacks sufficient storage
capacity. System failed to report annual water
use data. System has physical deficiencies that
have not been resolved.
UTAH02078
M & J TRAILER HOME
COMMUNITY Community 17
Assistance – System has multiple physical
deficiencies and needs technical assistance with
monitoring ands reporting. System has received
financial assistance to update infrastructure an
consolidate with a local water system. Project is
proceeding.
UTAH11045 MEADOWS RANCH Community 14
Assistance – System lacks updated source
protection plans. System storage facility access
hatches lack sufficient height above facility roof.
UTAH20039
MIA SHALOM RECREATION
CAMP
Transient Non-
Community 11 Assistance – System needs technical assistance
with monitoring and reporting chlorine residuals.
UTAH15015
MOUNTAIN GREEN WATER
ASSOCIATION Community 11
Assistance – System has not implemented its
source protection plan. System lacks backup
power at a t least one non-naturally flowing
source. System lacks sufficient fire flow.
UTAH29009
NORDIC MTN WATER
COMPANY Community 11
Assistance – System needs technical assistance
to ensure its cross-connection control program is
complete.
UTAH27086 NORTH VALLEY RANCHES SUB Community 20 Assistance – System needs technical assistance
with monitoring and reporting for RTCR.
UTAH11043 OLD MEADOWS WATER CO Community 14
Assistance – System well house lacks flood
protection and a floor drain. System needs
assistance to resolve physical deficiencies.

Annual Report to US EPA
Capacity Development Program
State of Utah FY2023 Page 21
3.6 EPA ETT List FY2021 – 2023 (cont)
UTAH12027
OLD PINERY RECREATION
AREA
Transient Non-
Community 12
Assistance – System needs technical assistance
with monitoring and reporting nitrates. System
needs to install pressure gauge on
hydropneumatic tanks.
UTAH23075 PENNEYS GRILL LLC
Transient Non-
Community 18
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System needs to install level
measuring device in its well.
UTAH22013 PEOA PIPELINE COMPANY Community 14
Assistance – System needs technical assistance
with monitoring and reporting chlorine residuals.
System needs technical assistance to resolve
operator certification issues. System failed to
submit annual water use data.
UTAH02012
PORTAGE TOWN WATER
SYSTEM Community 14
Assistance – This system has no IPS points
reported in the Division’s database and is rated
“Approved.”
UTAH17023 RENDEZVOUS BEACH
Transient Non-
Community 20
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System lacks sufficient fire
suppression storage.
UTAH25179
RIGTRUP EGG FARM
PROCESSING PLANT
Non-Transient
Non-Community 23
Assistance – This system has no IPS points
reported in the Division’s database and is rated
“Approved.”
UTAH25077 RIVERBEND GROVE INC
Transient Non-
Community 22
Assistance – System lacks engineering approval
and operating permits for all facilities. System
lacks cross-connection control program. System
is “Unapproved.”
UTAH19077 ROCKLAND RANCH Community 13
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System lacks an updated source
protection plan.
UTAH04008 SCOFIELD TOWN
Transient Non-
Community 11
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System lacks a means to measure
water levels in its well.
UTAH23046
SIMPSON SPRINGS
CAMPGROUND
Transient Non-
Community 11
Assistance – System lacks an updated source
protection plan. System needs technical
assistance with monitoring and reporting.
UTAH09053 SKOOTS CREEK SUBDIVISION
Non-Transient
Non-Community 11
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System needs technical assistance with monitoring and reporting RTCR.
UTAH29071 SNOWBASIN RESORT
Non-Transient
Non-Community 12
Assistance – This system has no IPS points
reported in the Division’s database and is rated
“Approved.”

Annual Report to US EPA
Capacity Development Program
State of Utah FY2023 Page 22
3.6 EPA ETT List FY2021 – 2023 (cont)
UTAH15029 STODDARD INN
Transient Non-
Community 18
Assistance – System lacks a means to measure
water levels in its well. System needs technical
assistance with monitoring and reporting RTCR.
UTAH10016 SUN SLICKROCK RV LLC
Transient Non-
Community 12
Assistance – System needs technical assistance
to ensure cross-connection control program is
complete. System needs flow measuring device
on its well.
UTAH17030 SUNRISE CAMPGROUND
Transient Non-
Community 11
Assistance – This system has no IPS points
reported in the Division’s database and is rated
“Approved.”
UTAH15038 TAGGARTS GRILL
Transient Non-
Community 13 Assistance – System needs technical assistance
with monitoring and reporting RTCR.
UTAH25082 TIE FORK REST AREA
Transient Non-
Community 13 Assistance – System needs technical assistance
with monitoring and reporting RTCR.
UTAH08043 TRAIL CYN RESIDENTS ASSN Community 14
Assistance – System has an unapproved facility at the source. System lacks a flow measuring
device at its source. System storage tank lack a
gasket on the lid.
UTAH12028
UTAH GREENHOUSE
COMPANY
Non-Transient
Non-Community 11 Assistance – System needs technical assistance
with monitoring and reporting RTCR.
UTAH17006 VISTA GRANDE
Transient Non-
Community 12
Assistance – System lacks pressure gauge,
smooth-nosed sample tap, and trapped air
release on well discharge piping.
UTAH26010
WASATCH MOUNTAIN ST
PARK
Transient Non-
Community 11 Assistance – System lacks sufficient fire flow
storage.
UTAH09019
WHITE BRIDGE
CAMPGROUND
Transient Non-
Community 14 Assistance – System needs technical assistance
with monitoring and reporting RTCR.
UTAH22012
WILLOW DRAW WATER
SYSTEM
Transient Non-
Community 12
Assistance – This system has no IPS points
reported in the Division’s database and is rated
“Approved.”,
UTAH11069 WOODS RANCH
Transient Non-
Community 11 Assistance – System needs technical assistance
with monitoring and reporting RTCR.

Annual Report to US EPA
Capacity Development Program
State of Utah FY2023 Page 23
3.7 DWRF Project List FY2023
During State Fiscal Year 2023 Drinking Water State Revolving Fund Program staff
presented 33 construction project applications for federal DWSRF financial assistance
to the Utah Drinking Water Board for funding approval. Each of these construction
projects submitted the capacity assessment worksheets to DWSRF Program Staff with
the financial assistance application. The submitted worksheets were reviewed and a
capacity development report was drafted by staff prior to presenting the project to the
Board for authorization.

Loan No. System Name System No.
3F1876 CANYON MEADOWS MUTUAL WATER COMPANY UTAH26069
3F1874 BEAVER CITY WATER SYSTEM UTAH01001
3F2002 UKON WATER COMPANY UTAH02014
3F1911 HIDDEN LAKE ASSOCIATION UTAH22029
3F1908 OGDEN CITY WATER SYSTEM UTAH29011
3F1900 UPPER WHITTEMORE WATER CO UTAH25136
3F1883 HANNA WATER & SEWER IMPROVEMENT DISTRICT UTAH07062
3F1847 HOLDEN TOWN WATER SYSTEM UTAH14013
3F1878 MORONI CITY UTAH20013
3F1850 GRANGER-HUNTER IMPROVEMENT DISTRICT UTAH18007
3F2001 GENOLA CITY UTAH25012
3F1928 STOCKTON TOWN WATER SYSTEM UTAH23010
3F1889 WALLSBURG TOWN WATER SYSTEM UTAH26009
3F1913 PARAGONAH TOWN WATER SYSTEM UTAH11014
3F1892 LEEDS DOMESTIC WATER USERS ASSOCIATION UTAH27010
3F1851 SCIPIO TOWN UTAH14011
3F1856 LEVAN TOWN WATER SYSTEM UTAH12001
3F1904 WILSON ARCH WATER & SEWER SSD UTAH19069

Annual Report to US EPA
Capacity Development Program
State of Utah FY2023 Page 24
3F1930E GREEN HILLS COUNTRY ESTATES UTAH29053
3F1909 VIRGIN UTAH27020
3F1890 PINE VALLEY MT FARMS UTAH27061
3F1873 PROVO CITY UTAH25006
3F1910 BRIAN HEAD TOWN WATER SYSTEM UTAH11001
3F1929 WALES TOWN WATER SYSTEM UTAH20010
3F1862 JOHNSON WATER DISTRICT UTAH07006
3F1896 BALLARD WATER IMPROVEMENT DISTRICT UTAH24001
3F1926 SPRING CITY UTAH20008
3F1920 LEAMINGTON TOWN WATER SYSTEM UTAH14012
3F1877 TIMBER LAKES WATER SSD UTAH26057
3F1925E GREEN RIVER CITY UTAH08005
3F2008 KANE COUNTY WCD - JOHNSON CANYON UTAH13038
3F2003 PAYSON CITY WATER SYSTEM UTAH25021
3F1879 SOUTH DUCHESNE CULINARY WATER UTAH07067

Appendix A

DWSRF Program Checklists

DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF DRINKING WATER
STATE OF UTAH REVOLVING FUND

PAYMENT REQUEST CHECKLIST

Project Name Project Number

Payment Request No.

Reviewer Date

Yes/Adequate X No/Inadequate O Not Applicable N/A
1 Are the correct certification forms (B1, B2, & B3 forms) included in the payment request? PM

Are the certification forms (B1, B2, & B3 forms) complete and signed by an authorized
individual?

3 Has the community met all of the special loan authorization conditions? PM
Are all costs identified in the disbursement request supported by copies of checks
and invoices/construction estimates of work in place?

Are construction estimates of work in place signed by a representative of the
consulting engineering firm and the contractor?

Have all change orders for which payment is being requested been approved and
added to the Project Cost Tracking Sheet?

Do the unit prices on the construction estimate of work in place agree with the unit
prices on bid proposals and approved change orders?

Are quantities on pay request equal to or less than bid quantities, if not, has a change
order been negotiated?

9 Has the physical existence of materials stored on-site been verified with copies of invoices? PM

Are all the costs identified in the request eligible for funding participation and
allowable in accordance with the approved project scope?
2
4
5
6
7
8
10
PM
PM
PM
PM
PM
PM
PM

If costs identified in the request are determined to be force account costs, was a force
account proposal approved? (Use of water system labor)

12 Are the cumulative costs for each contracted service or purchase within the contract ceiling? PM

13 Date of last inspection: By: PM

Did the latest inspection determine that construction was proceeding without
discrepancies which must be corrected prior to further payment?

Are there sufficient funds in the project budget to complete the project? (bank/escrow
reconciliation worksheet attached)

Does the request include a cost which was incurred as a direct result of unapproved
extended construction periods? If so, should it be paid from liquidated damages?

If land is being acquired for this project, have the provisions of the Uniform
Relocation Assistance and Real Property Acquisition Act (40CFR pt. 4) been adhered
to? (must be a willing seller, if eminent domain was used, will not be eligible for
SRF funds)
18 FOR FINAL PAY REQUESTS VERIFY THE FOLLOWING:
Final Inspection report with all the pending items addressed? PM
Certificate of Completion from the Engineer? PM
Lien releases secured from Contractors, Subcontractors & Suppliers? Private water systems only
Have the appropriate DBE Report(s) been submitted and are they up-to- PC date? (DBE: N/A FOR STATE PROJECTS)
System Asset Management Plan Submitted? PM
I certify to the best of my knowledge and belief, this disbursement request has not been previously requested and
should be made in accordance with the loan conditions.

Date Project Engineer

Date Accounting

11 PM
14
15
16
17
PM
PM
PM
PM
PM

Bond Counsel Bill Prater [phone] [e-mail] Bond Counsel DDW Manager Michael Grange [phone] [e-mail]
DDW Project Manager System Presiding Official System Treasurer/Recorder Project Engineer
Environmental Consultant
Task Description Responsible Party Target Date Comments
0 Capacity Assessment DDW NA for State
1 DWB Authorization Letter DDW
2 Discuss conditions on funding and timeframe to resolve DDW
3 Submit Engineering Report / Master Plan Engineer
4 Submit Water Conservation Plan System
5 Submit Asset Management Plan System
6 Submit Emergency Response Plan System NA < 3300 population
7 Submit Engineering Contract Engineer
Legal
8 Submit Verification of Water Rights Engineer
9 Register for a Unique Entity ID at SAM.gov System
NA for State,required for
ARPA and BIL
Supplemental, LSL, EC and
Equivalency only projects
10 Submit copy of Project Notification to users / water bill insertSystem
11 Submit copy of Minutes showing public support of project System
12 Submit copy of Minutes from Rate Increase Hearing System
13 Submit Rate and Enforcement Ordinance for approval System
14 Verify new rates are adequate DDW
15 Parameters Resolution (submit copy of minutes that it passeSystem/ bond attorney NA if private
16 Bond resolution (submit copy of minutes that it passed) System/ bond attorney NA if private
17 Deed of Trust (water)System Private only
17 Deed of Trust (real property)System Private only17aTitle Commitment System Private only18Copy of Fidelity Bond (2x annual P&I payment)System
19 Attorney Opinion letter System attorney
Environmental
20 Submit Environmental Review Checklist Engineer NA for State
20a Send environmental review checklist and cross cutter list DDW
21 Cultural Resources Report/Tribal Consultation Engineer
22 Submit consultation letter to SHPO DDW
23 Publication of FONSI/CatEx System NA for State
24 Submit copy of FONSI/CatEx Affidavit of Publication System NA for State
25 Submit minutes of public meeting for FONSI System NA for State
Plan Approval/ Bids
26 Provide SRF boilerplate to Engineer DDW BABA & DBE Equivalency
projects only
27 Submit plans/specs to DDW Engineer
28 Plan Approval DDW
29 Submit copy of Affidavit of Publication of Notices to Bid Engineer
30 Submit copy of Bid Tab Engineer
31 Submit copies of top 3 bid packages Engineer
31a Submit Certification Re: Debarment Engineer/Contractor
31b Submit Certification of Non-Segregated Facilities Engineer/Contractor
31c Submit DBE Certification and Contact Log Engineer/Contractor NA for State
Contract
32 Engineer's recommendation to award Engineer
33 Submit copy of Notice of Award Engineer
34 Submit copy of Construction Contract Engineer
35 Submit copy Payment and Performance Bonds for constructi Engineer
36 Notice to Proceed Engineer
Closing
37 Verify/update repayment schedule DDW
38 Construction Schedule / Quarterly Drawdown Schedule Engineer
39 Expenses incurred to date Engineer
40 Escrow Agreement (due a min of 2 weeks prior to loan closinSystem / DDW
41 Executed Principal Forgiveness Agreement System / DDW if applicable (agreement or in bond documents)42 Request Funds DDW Finance 2 weeks prior to loan closing43Single Audit Letter DDW Finance NA for State - Equivalency projects only
Notes:
Target Dates:
Pre-Closing Conference Call Checklist
Project:
Funding:
System To-Do Engineer To-Do DDW To-Do

Appendix B

Factors that Impact Capacity

Table A1 – Factors that Impact Capacity
Capacity
Aspect Factor Measure Impact
Technical
Source
Adequacy
Valid Water
Right
Systems with a legal right to the
water they serve their users have
additional control of that water
including, source water protection
and water quality, and available
water quantity.
Source
Quantity
Sufficient source water quantity
assures that the system is able to
meet its water use needs to protect
public health.
Source Quality
Adequate source water quality helps
systems better protect public health.
It also reduces potential treatment
costs related to treating water to
drinking water standards.
Source
Protection
A system’s control over source
protection issues provides additional
public health protection as well as
potentially reducing treatment costs.
Infrastructure
Adequacy
Facility
Condition
Properly maintained water system
infrastructure provides an
environment conducive to good
water quality as well as preserving
water quantities delivered to users.
Facility Life
Expectancy
When properly maintained, water
infrastructure can have significant
life expectancy. This can help water
systems continue to provide
sufficient quantities of quality
drinking water to their users at
reasonable rates.
Capital
Improvement
Plan
A capital improvement plan allows a
system to proactively plan for
infrastructure improvement projects.
These projects can include major
facility repair and/or new
construction for both anticipated
growth and compliance with drinking
water standards.

Capacity
Aspect Factor Measure Impact
Technical
(continued)
Technical
Knowledge
Certified
Operator
Properly certified operators
positively affect water system
capacity by applying their knowledge
to provide the system’s users with
water that complies with drinking
water standards and the SDWA.
Operator
Knowledge
Operators with sufficient knowledge
of drinking water regulations,
operations and maintenance
procedures, and customer service
contribute significantly to a water
system’s technical capacity.
System O&M
Program
A robust system operations and
maintenance plan allows system staff
to plan and follow through on
proactive system maintenance which
can significantly improve staff
efficiency, infrastructure condition
and life expectancy and reduce costs.
A good plan also provides direction
to staff on system policy, procedures
and best management practices for
each facility within the system.
Knowledge
Application
Operating
Standards
Properly applied standards help
system maintain public health
protections.
O&M Program
Implementation
Proactive O&M Programs prolong
infrastructure life and preserve water
quality and volume.

Capacity
Aspect Factor Measure Impact
Managerial
Ownership
Accountability
Owner Clearly
Identified
A clearly identified owner indicates
that the water system takes its
responsibilities seriously. A clearly
identified owner is typically more
willing to be actively involved in
running the system that complies
with regulations and the SDWA.
Owner
Responsibility
An owner willing to take
responsibility for system compliance
are actively involved with system
operations and ensure O&M policies
and procedures are in place to
maintain compliance and protect
public health.
Staffing &
Organization
System Staff
Clearly
Identified
A well-defined organizational
structure with clear lines of authority
and management can reduce staff
and constituent confusion and
contributes to a well-run water
system. An organization chart
provides a visual description of the
system’s structure as well as the
management and reporting
structure.
Operators
Certified
Drinking Water systems are required
to have at least one certified operator
responsible for day-to-day system
operation and maintenance. These
operators should be clearly identified
in the systems organization chart
and other management tools.
Operational
Expertise
A well run system will properly
maintain records related to system
infrastructure, such as infrastructure
maps, infrastructure
construction/installation dates,
maintenance work orders,
monitoring schedules, and
operational procedures and
activities.

Capacity
Aspect Factor Measure Impact
Managerial
(continued)
Effective
External
Linkages
Customer
Interactions
A well-run water system will be
transparent with its users, on both
good news and bad. Effective
communication with customers is
critical to improving and maintaining
managerial capacity.
Regulator
Interactions
One sign that a system has adequate
managerial capacity is whether it
views regulatory bodies as
adversaries or resources. Better
relationships with regulators can be a
sign that a system is working to
maintain or improve its managerial
capacity.
External
Resources
This measure includes many
different aspects including access to
and willingness to use outside
technical and financial assistance
services. Systems with adequate
managerial capacity will recognize
and use assistance services offered by
entities such as RWAU, AWWA,
RCAC, DDW, the DWSRF program,
etc.

Capacity
Aspect Factor Measure Impact
Financial
Sufficient
Revenue Revenue
Systems demonstrate adequate
financial capacity through
maintaining water rates sufficient to
meet expenses. They will have
appropriate rate and enforcement
ordinances or bylaws, will regularly
review rates and rate structures, will
employ adequate budgeting policies
and procedures, will have or
establish debt and facility
replacement reserve accounts, and
will have emergency operating
expense reserve accounts to carry
them through challenging times.
Sufficient
Revenue
(continued)
Expenses
Well run systems will track control
expenses and will maintain sufficient
revenue and reserve funds to cover
expenses.
Credit
Worthiness
Paying bills on
time
Systems demonstrate financial
capacity by having sufficient revenue
to meet their debt obligations in a
timely manner, even in times of
distress. Adequate rates and
emergency operating fund accounts
contribute to this measure.
Access to
Capital
A system’s access to both public and
private capital, as demonstrated by a
good credit rating is a good indicator
of a system’s financial capacity.
Fiscal
Management
Adequate
Records
A well run system will have
appropriate financial statements
either prepared by a CPA or regularly
audited by a CPA. An audit every
three years is the recommended
minimum.

Appropriate
Budgeting and
Accounting
A system with adequate financial
capacity will use generally accepted
accounting principles.
Effective
Revenue
Management
The operating ratio, coverage ratio,
and debt service ratio will all be
within accepted parameters.

Appendix C

Operator Certification Website Overview Graphic

https://deq.utah.gov/drinking-water/operator-certification

Appendix D

Initial Order for New Public Water System

195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144830 • Salt Lake City, UT 84114-4830 Telephone [phone] • Fax [phone] • T.D.D. [phone] www.deq.utah.gov
State of Utah
SPENCER J. COX Governor
DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality Kim Shelley Executive Director
DIVISION OF DRINKING WATER Tim Davis. Director

Check off Workflow - Check once complete Sent on
● WTTC Editor (Colt/Jen)
● Chems (David)
● Lead/Copper (Bridgette) (transient WS, not needed)
● Chlorination (Luke) (is not needed system does not disinfect or purchase disinfected water)
● Coliform (Sitara)
● Permitting (Hunter/DE)
● Source Protection (Deidre/Melissa)
● OpCert (Helen L./Dawnie) (system does not have a TP and is transient, not needed)
● Capacity Development (Michael Grange/Heather)
● Field Services (Ryan)

Sent on
● Water Quality Section Manager (Mark)
● COA Section Manager (Helen)
● Permitting Section Manager (Newberry)

Sent on
● Assistant Director (Michelle)
● Assistant Director (Nathan)

Sent on
● Attorney General (Bret/Shane)

Sent on
● Formatting and Tim’s Signature (Jessica)
● Director (Tim)
● WTTC Editor (Colt/Jen)

Transient
Non-Transient Non-Community
Community
[Name of Legally Responsible Person] Page 2 of 21 DATE CERTIFIED MAIL #### [Name of Legally Responsible Person]
System [Address] City State, Zip Subject: Initial Order for New Public Water System for [Name of Water System and Number] [Name]:
According to available information, it has come to the attention of the Utah Division of Drinking Water (the “Division”) that [Name of Legally Responsible Person], a Utah [Type of entity (limited liability company, non-profit corporation, etc.)], is the owner and/or operator of a public water system (PWS) as
explained in the Utah Safe Drinking Water Act and the Utah Public Drinking Water Rules in R309-100-4. As a result, the Director of the Division of Drinking Water is required by law to initiate a formal administrative process to recognize the system as a new public water system and to ensure that it
complies with both state and federal drinking water regulations. As part of that process, I have attached an Initial Order for New Public Water System explaining the requirements for the system.
The Division understands that compliance with state and federal legal requirements can involve significant administrative and financial burdens for public drinking water systems, especially new systems. Those regulations are designed to ensure that public water systems are able to provide safe and
reliable drinking water to the people they serve. Coming into compliance with state and federal regulations can require time and resources. Utah’s public water systems, including your system, provide essential services that directly impact human health and welfare. The attached order includes contact information for Division staff with expertise in the rules and regulations that apply to public water systems. Containers for samples are available from all certified laboratories. While the Division cannot recommend a specific laboratory, we have enclosed a list of certified laboratories that perform water testing. In all correspondence with our office and the laboratories, please indicate the public water system number. The number for your water system is UTAH[number]. Clearly mark the system number on all
samples. Enclosed is the inventory list for your system. Please carefully review this report and return it to our office with any corrections.
Enclosed is also a copy of your Improvement Priority System (IPS) Report. IPS points are used to rate and track a water system’s compliance with state and federal drinking water regulations. This report indicates several dormant deficiencies associated with the required actions listed in the attached Order.
These dormant deficiencies serve as a tracking tool and reminder; they do not affect the water system’s points or rating unless the due date for the required task has expired. The dormant deficiencies are removed from our database when the PWS completes the required tasks and notifies the Division. The Division has online tools to help manage your water system, including: ● Waterlink.utah.gov: WaterLink is an online tool that allows public water systems to access
current system information, including the system’s inventory, monitoring schedules, IPS Report, operator records, and the system’s Bacteriological record for the last 12 months. To
[Name of Legally Responsible Person] Page 3 of 21 get full use out of these tools, you will need to create a Waterlink portal account. You can do this by navigating to the Public/Portals menu on the top right side of the waterlink.utah.gov home page and selecting the Portal. For help creating a WaterLink Portal account please
contact Mz. (Tammie) Allen at [phone] or [e-mail] ● Eqedocs.deq.utah.gov: Each water system’s public records are available here. These records may include previous monitoring results, Division correspondence, former Consumer
Confidence Reports, and other documents related to the water system. Browse to your water system listed alphabetically under “County” to see what we have on record for your system. Please call the Division at [phone] if you have any questions.
We are here to help you through this process. If you have any questions about this Order, please contact Colt Smith at [phone] or [e-mail]. To contest or appeal this Order, please contact Bret
Randall of the Attorney General’s office at [phone] or [e-mail] (alternatively Elizabeth Burns of the Attorney General’s office at [phone] or [e-mail]). Sincerely,
Tim Davis
Division of Drinking Water Enclosures: Initial Order for New Public Water Systems
Improvement Priority System (IPS) Report Inventory List
Total Coliform Sample Site Plan Template
cc: Terry Smith, Rural Water Association of Utah, [e-mail] Plan Review Engineer or District Engineer Shauna Benvegnu-Springer, Utah Division of Public Utilities, [e-mail] LHD
Bret F. Randall, Assistant Attorney General, [e-mail] -or Elizabeth A. Burns, Assistant Attorney General, [e-mail]
EQDWMonitoring, EQDWCOA, and EQDWFS [Insert Registered Agent from Finding 1.(c)]

1
UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF DRINKING WATER
In the Matter of: [System Name], a Utah Public Water System (UTAH[Number])
INITIAL ORDER FOR NEW PUBLIC WATER SYSTEM Docket No. UTAH[Number]

This INITIAL ORDER FOR NEW PUBLIC WATER SYSTEM (“Order”) is issued by the Director of the Utah Division of Drinking Water (“Director”), under the Director’s legal authorities
described below. This Order is issued to [Name of Legally Responsible Person], a Utah [Type of
entity (limited liability company, non-profit corporation, etc.)], in [his, her, its] capacity as the “Supplier” who is legally responsible for the water system.
STATUTORY AND REGULATORY AUTHORITY
1. In 1974, Congress enacted the federal Safe Drinking Water Act, codified at 42 U.S.C. §
300f et seq., as amended. 42 U.S.C. § 300g-2 allows states to achieve primary enforcement
responsibility after the Environmental Protection Agency (“EPA”) has determined that the state has adopted and can implement a state program that is no less stringent than the federal public drinking water program (“Primacy”).
2. The Utah legislature has enacted the Utah Safe Drinking Water Act, codified at Utah Code
§ 19-4-101, with the intent of achieving Primacy.
3. Utah Code § 19-4-104 authorizes the Utah Drinking Water Board (the “Board”), among other things, to make rules regulating public water systems in the state of Utah. Utah Code § 19-4-104(1)(c)(vi) charges the Board to “meet the requirements of federal law related or pertaining to drinking water.” The Board has promulgated the Utah Public Drinking Water
Rules, codified at Utah Administrative Code (“UAC”) R309.
4. In 1980, the EPA Administrator determined, in accordance with 40 C.F.R. § 142.11, that the Utah public drinking water program met the federal requirements for Primacy. See 45 Fed. Reg. 6647 (January 29, 1980). In accordance with 40 C.F.R. § 142.17, the EPA Administrator has reviewed, and continues to review annually, the Utah public drinking
water program to evaluate its continuing compliance with the requirements set forth in 40 C.F.R. Part 142.
5. The Board has defined public water systems under the Utah Public Drinking Water Rules, UAC R309-110-4.
6. UAC R309-100-7 requires the Director to “assign a rating to each public water supply in
order to provide a concise indication of its condition and performance” in accordance with
[Name of Legally Responsible Person] Page 2 of 21
R309-400. This rule is generally known as the Improvement Priority Rating (“IPS”) rating system.
7. The IPS rating system “is a point system used by the division to evaluate a public water
system’s performance and compliance with the drinking water rules in Title 309, Environmental Quality, Drinking Water.” UAC R309-400-3(1). Under the IPS rating system, each public water system is assigned a rating “to characterize the water system’s compliance with drinking water rules and overall operation and performance.” UAC R309-
400-3(2). The IPS rating system is “used by the division to assign compliance ratings to
public water systems and to prioritize enforcement action based on points assessed for noncompliance with drinking water rules.” UAC R309-400-1(1).
8. UAC R309-400-5 provides that a water system’s IPS rating shall be assigned “based on the total number of points assessed for noncompliance,” based on a point system
established by the Board. Generally, the number of points represents the threat to the quality of the water and thereby public health.
9. UAC R309-400-4(1)(a)(ii) sets the maximum number of points any given type of system may have before it is rated by the Director as “Not Approved” status. For systems exceeding the point threshold, the Director is required to issue a “Not Approved” rating.
The thresholds are as follows: (i) for community water systems, 150 points; (ii) for non-transient, non-community water systems, 120 points; and (iii) for non-community water systems, 100 points.
10. UAC R309-400-4 allows the Director to assess points against public water systems upon their failure to comply with Division directives and orders.
11. UAC R309-400-5 allows the Director to rate any public water system as “Not Approved” at any time if an immediate threat to public health exists.
12. UAC R309-400-5 provides that a public water system may qualify for a “Corrective Action” rating for its public water system upon submission of a written agreement stating a willingness to comply with the requirements set forth in the Rules and complying with
other requirements.
13. Pursuant to Utah Code § 19-4-106(d), the Director may enforce rules promulgated by the Board through the issuance of orders. See also UAC R309-100-8.
14. Utah Code § 19-4-107 provides that upon discovery of any violation of a rule or order of the Board, the Director shall promptly notify the supplier of the violation, state the nature
of the violation, and issue an order requiring correction of that violation.
15. Utah Code § 19-4-109 provides that any person who violates the Act or a rule or order made or issued pursuant to the Act may be subject to an administrative penalty of up to $1,000 per day of violation or a civil penalty of up to $5,000 per day of violation.
[Name of Legally Responsible Person] Page 3 of 21
16. [Insert #15 for Federal facilities only] The Director’s jurisdiction to issue this Order is based, in part, on Section 1447(a) of the Safe Drinking Water Act, codified at 42 U.S.C. §
300j-6. The federal act provides that if a state has achieved enforcement primacy, then
federal agencies are subject to the jurisdiction of the state agency with enforcement primacy. In directing federal facilities to be subject to and to comply with all state requirements “in the same manner and to the same extent as any [non-governmental entity,]” the explicit language of the federal act demonstrates Congress’ intention that
federal facilities be treated as any other public water system covered by the federal act and,
in turn, the state law (the Utah Safe Drinking Water Act) and rules that implement the federal act. Thus, the Director is required to assert jurisdiction over the Supplier in this matter in the same manner and to the same extent as any non-governmental entity.
FINDINGS
Based on information available to the Director, the Director makes the following Findings for purposes of this Order:
1. [Name of legally responsible person] (“Respondent”) is a [type of entity, Utah limited liability company, non-profit corporation, governmental entity of some type, a human being, etc.] Based on public records on file with the Utah Division of Corporations:
a. Respondent has the following registered business address: [business address] b. The principal or owner of Respondent is [name of principal] with the following address: [Principal address]
c. The legal registered agent of Respondent is [Registered Agent name], with the following registered agent address: [Registered Agent address]. 2. There exists a public water system (the “System”) located at [geographically location, insert
an address or coordinates and a description of the closest town or landmark if address is not available]. The System is a public water system based on the following facts: a. Respondent owns a [describe the type of business or operation, including when it operates]. There are approximately [number of residents or visitors and whether they
are full-time residents]. Respondent serves culinary water to the foregoing
population. NO OP: b. The System has [describe the active source of culinary water- well, consecutive
connection, surface water, etc.] and an independent distribution system serving
approximately three service connections. NEW OP c. On August 10, 2022, the Division issued Respondent an Operating Permit related to
the System, including approval of the use of a groundwater source, Well 1 (WS001),

and an independent distribution system serving approximately one service connection.
Respondent owns and operates the System and is responsible for its maintenance and repair.
3. On DATE, Respondent submitted a Supplemental Form for New Public Drinking Water System signed and submitted by PERSON.
4. [Name of administrative contact] is the Division’s administrative contact for the System.
CONCLUSIONS OF LAW
Based on the foregoing Findings of Fact, the Director hereby makes the following conclusions of law:
1. Respondent is the owner and operator of the System, which is a public drinking water system within the meaning of the Utah Safe Drinking Water Act and the Utah Public Drinking Water Rules. 2. Respondent is a “Supplier” within the meaning of the Utah Safe Drinking Water Act, Utah
Code § 19-4-102(10). 3. The System qualifies as a community, non-transient non-community, transient non-community Public Water System under the Utah Public Drinking Water Rules. ORDER
Based on the foregoing Findings of Fact and Conclusions of Law, IT IS HEREBY ORDERED as follows:
1. System Status: The System is hereby rated as an active but [“not approved” or “unrated”
or “approved”] community, non-transient non-community, transient non-community water
system under the Division’s water rating system rules, UAC R309-400. A water system’s rating can only become “approved” after it obtains an Operating Permit from the Director for the entire water system, including its drinking water sources.
2. Plan Review

Case by case basis -if no history in waterlink or d2 include this paragraph. Division review eng. Responsible can delete if they have worked with them previously and feel this is redundant-Primary purpose is to get a list of facilities, contact info, etc.
a. New Public Water System Supplemental Form: Included with this Order is a blank
copy of the Division’s New Public Water System Supplemental Form (the “Information Form”). Respondent shall complete and return this form to the Division on or before 30 days from the date of issuance of this Order. The

findings set forth in this Order, together with Division records, may be updated based on information submitted in the Information Form.
Case by case basis-include if this new PWS that has existing facilities or new ownership to ensure
they don’t get stuck with previous owners ATF fees. This is an optional requirement to avoid ATF fees-up to the discretion of the Division review engineer to require or not b. Engineering Evaluation Report: This water system was previously known and
regulated as the XXXXXX (UTAHXXXXX) water system’s design and construction have been reviewed for compliance with Utah’s public drinking water system standards in Utah Administrative Code R309-500 through 550. OR Because the System has been in existence and operation prior to the date of this Order, Respondent shall submit an Engineering Evaluation Report prepared by a Professional Engineer licensed to practice in Utah to the Division on or before 180 days from the date of issuance of this order. The engineering evaluation report shall contain detailed information of all current drinking water facilities including source springs and/or wells, storage tanks, pumps, distribution system, number of connections, water rights, System schematics, etc. and hydraulic model report.
An Engineer Evaluation Report is a document to start the process of the Division’s review of all the existing drinking water facilities associated with your system to ensure compliance with the current design and construction standards for public drinking water systems (Utah Code R309-550). The Division will use this report to
enter all drinking water facilities into the Division’s database and to determine all drinking water facilities meet applicable R309-500 requirements to protect the public’s drinking water.
The Division will issue after-the fact Plan Approval and an Operating Permit for all
drinking water facilities detailed in the Engineering Evaluation Report. A new water system’s rating becomes “approved” after it obtains an Operating Permit from DDW. Please contact ENG STAFF, if you have any questions regarding the engineering evaluation report.

c. Plan Review Files: Rules R309-500 through 550 govern the design, construction, operation, maintenance, and plan review procedure requirements for drinking water projects. Drinking Water Projects are defined in Rule R309-500-5(1) as any part of the project that includes the construction of, addition to, or modification of a public
drinking water facility that may affect the quality or quantity of water delivered.
All Drinking Water Projects must have Division Plan Approval prior to construction and Division issuance of an Operating Permit before facilities can be placed into service. Please see our website for general information on the Plan Review process,
documentation required, and contact ENG STAFF from the Division’s Permitting
Section regarding the permitting process.

This section is meant to list the current/open/pending plan review files that still need to be followed up by the current owner. Perhaps if the list is long add a note about an attachment and print out the plan review summary report in Waterlink.
i. The System currently had the following plan review files in the Division’s plan review database: (edit the items below to include recent history and state important approval dates or is something is missing, e.g. OP) 1. File # XXXXX – project name Review: One line summary of
project, include project history date of PA, OP etc. Highlight if missing any approval documentation required, and contact ENG STAFF from the Division’s Permitting Section with any question regarding the permitting process. 2. File # XXXXX – Water System Sources: This file was created to
track the review of all sources. One line summary of project, include project history date of PA, OP etc. Highlight if missing any approval documentation required, and contact ENG STAFF 3. (add following if need ATF language and no previous project history in waterlink) Because the System has been in existence prior to the
date of this Order and/or had a period of inactivity, Respondent shall submit As-built Plans and Specifications as part of the Engineering Evaluation Report of all existing drinking water facilities for the Division to review and issue Operating Permits.
d. Operating Permit: Respondent shall complete all of the Director’s requirements to obtain an After-the-Fact Operating Permit on or before 18 months from the date of issuance. The Division will assess 50 deficiency points for using unapproved facilities and 200 deficiency points for using an unapproved water source if this
water system is in operation and does not obtain an Operating Permit for the entire
water system on or before 18 months from the date of issuance. 3. Capacity Development Evaluation
a. Drinking Water Rule R309-800 requires an assessment of a new water system’s
technical, managerial, and financial capabilities. b. Respondent shall comply with R309-800 by documenting the System’s capabilities using one of the methods described on the Division’s website.

i. Existing water systems should submit completed copies of the Capacity Assessment Evaluation forms, located on the Division’s website at: https://documents.deq.utah.gov/drinking-water/forms/DDW-2018-003083.pdf; or

ii. New or proposed water systems shall submit a business plan as described in UAC R309-800-5(4) for Division review and approval within one year of the date of issuance of this Order.

Receiving approval of the capacity assessment worksheets or the business plan is a prerequisite for issuing an Operating Permit for this water system. Please contact Michael Grange at [phone] ([e-mail]) for assistance related to Capacity
Development/Assessment. 4. Sanitary Survey and Emergency Response For a PWS that has previously had a sanitary survey, put the due date 10/31 three years from that
survey a. Sanitary Survey: Respondent shall schedule the onsite inspection/sanitary survey on or before 365 days from the date of issuance of this order and before an operating permit can be issued. Please contact Ryan Dearing at 801-560-8456 or [e-mail], if you have any questions regarding scheduling of the onsite
inspection or engineering review. The last sanitary survey on record was performed by STAFF on DATE. (delete if no history) b. In the event of any situation constituting an emergency, the Supplier is required to contact the Division within eight hours of identifying the emergency as outlined in
R309-105-18. Division personnel may be reached at all times by calling 801-560-8456. Emergency situations include any of the following: i. Malfunction of any disinfection or treatment facility ii. Malfunction of any treatment plant clearwell which constitutes a turbidity spike of 5 NTU for greater than fifteen minutes.
iii. Water discoloration for a significant number of connections that cannot be explained by air entrainment or re-suspension of sediments normally deposited within the distribution system. iv. Malfunction or accident that could introduce surface water or other potential
contamination into the distribution system, e.g. cross connection, major
water break, chemical spill or overfeed, pressure loss, or natural disaster. v. Threat of sabotage or act of vandalism to any drinking water facility. vi. Any instance where a customer reports sickness from drinking the water and that claim is substantiated by a doctor.

c. The supplier is advised to develop contingency plans to cope with possible emergency situations including earthquake, wildfire, flooding, and other natural or human caused disasters.
5. Cross Connection Control Program
Respondent shall develop a cross connection control program for the System to prevent any cross contamination. There are five elements to a cross-connection control program: local authority statement, annual public education or awareness, operator training, written
records, and on-going enforcement. If you have any questions about the cross-connection
control program, please contact Gary Rager at [phone] ([e-mail]). a. Respondent shall complete the local authority statement on or before 90 days from the date of issuance.

b. Respondent shall complete the annual public education or awareness, operator training, written records, and on-going enforcement on or before 180 days from the
date of issuance. 6. Source Protection Program a. If the system and source are new to division records, insert this paragraph: A Preliminary Evaluation Report (PER) is required for all sources connected to the
System. Guidance for preparing the PER can be found online at https://deq.utah.gov/drinking-water/preparing-source-protection-plans. Please call [phone] and ask to speak to the source protection staff if you have questions about this requirement. Respondent shall submit the PER on or before [Date]. b. If the system and source are in compliance with SP requirements, insert this
paragraph: Based on information available to the Division, the System’s source(s) is/are currently in compliance with source protection requirements. As a reminder, (an) updated source protection plan(s) will be due on or before [Date]. Guidance for preparing the updated plans can be found online at https://deq.utah.gov/drinking-water/preparing-source-protection-plans. Please call [phone] and ask to speak
to the source protection staff if you have questions about this requirement. c. If the system and source are not in compliance with SP requirements, insert this paragraph: System source(s) is/are currently not in compliance with source protection requirements. [Specifically describe problem here.] Respondent shall submit a corrected plan/PER/update on or before [Date]. Please call (801)536-
4200 and ask to speak to the source protection staff if you have questions about this requirement. d. If the only source is a wholesale connection to another system, insert this paragraph: Since the System’s current source(s) is/are solely (a) consecutive connection(s),
source protection requirements do not apply. If any new sources are added in the
future, source protection requirements may apply at that time. Please call [phone] and ask to speak to the source protection staff if you have questions about this requirement.
7. Operator Certification
A community, non-transient non-community drinking water system that serves a population of <population> requires a Direct Responsible Charge Operator (DRC) to be certified at a <Distribution/Treatment Grade Level> to operate the system. The System must obtain
the appropriate grade level of certification on or before 365 days from the date of issuance.
For any questions regarding the operator certification rules, contact Dawnie Jacobo at [phone] or [e-mail]. 8. Consumer Confidence Reports
Respondent shall prepare a consumer confidence report for the System and notify all System consumers of its availability and make it available upon request by July 1, 2024. This report must include administrative information on the System, information on the source of water delivered, the level of detected contaminants during 2023, information

regarding System violations and deficiencies, and other specific language as provided more fully in UAC R309-225-5. For any questions regarding the consumer confidence reports, contact Brandi Smith at [phone] ([e-mail]).
9. Monitoring and Reporting Requirements a. Total Coliform Monitoring Respondent shall take at least one routine coliform bacteriological sample from the distribution system and submit it to a certified laboratory for each calendar month that the water system is used. It is the responsibility of Respondent to send a copy of the results to our office by the 10th of the following month. In the event of a coliform positive result, Respondent shall take three repeat samples and a triggered source
Esherichia coli sample for each ground water source in service at the time of the original positive sample. For any questions regarding the Total Coliform Rule or Groundwater Rule, contact Sitara Federico at [phone] ([e-mail]).
b. Total Coliform Sample Site Plan Respondent shall develop a written sample site plan that identifies sampling sites and sample collection schedules that are representative of water throughout the distribution system. Respondent shall collect the total coliform samples according to the written sample site plan template. Included with this Order is a blank copy of the Total Coliform Sample Site Plan. For any questions regarding the bacteriologic sample site plan, contact Sitara Federico at [phone] ([e-mail]).

c. Lead and Copper Monitoring Five lead and copper first-draw tap samples are required from the distribution system every six months. After two consecutive six-month sample periods, the frequency
may be reduced to annual or once every three years. Respondent shall send the results of the analyses to the Division. Please refer to this letter for the most accurate information, or contact Bridgette Charlebois at [phone] ([e-mail]).
d. Chemical Monitoring
Respondent shall monitor each source for six classes of chemicals: Inorganics and Metals, Nitrate, Nitrite, Volatile Organic Chemicals, Radionuclides, and Pesticides. The sampling frequency for each class is different and will be specified
after receipt of the new source chemistry results. Please contact David Kruse at (385)
566-7789 ([e-mail]) with questions. Respondent shall monitor New Source Inorganics and Metals. After the initial analysis has been done, and if the results are in compliance, then your source will be

required to be sampled for Nitrate once a year and Sulfate every three years. Please contact David Kruse at [phone] ([e-mail]) with questions.
e. Chlorination Monitoring: i. Respondent shall submit a quarterly chlorination report and distribution system chlorine residual results for the System to the Division. The chlorination report and chlorine residual data are both due by the tenth day of the month following each quarter, i.e., January 10th, April 10th, July 10th, and October 10th. ii. Respondent shall take a chlorine residual at the point of entry to the distribution system (before the first connection) for every day that the system is treating water and shall be at least 0.2 ppm. Additional chlorine residuals shall be taken from different locations throughout the distribution system a minimum of 3 times per week, for a total of 12 times per month in accordance with State Rules R309-105-10-(1)(c). The distribution system
chlorine residual averages can be reported via the online form at https://mrdl.utah.gov. iii. All chlorine residuals shall remain detectable in the distribution system, but shall not exceed 4.0 ppm. Please contact Luke Treutel at [phone] ([e-mail]) for disinfection by-products (DBP) sampling requirements. f. Monitoring Schedule

A current monitoring schedule for the System has been enclosed. Respondent shall become current with System total coliform monitoring and submit a sample site plan to the Division by [Date], lead and copper monitoring requirements by [Date], DBP monitoring requirements by [Date], and chemical monitoring by
[Date]. Please contact Mark Berger at [phone] ([e-mail]) for
general monitoring schedule questions. GENERAL PROVISIONS
1. Upon satisfactory compliance with the requirements in the Order section, the Director may
issue a subsequent administrative order changing the status of the System to “Approved” in accordance with UAC R309-100-7 and R309-400. Pursuant to such subsequent order, the Director may also take other appropriate actions or impose appropriate conditions, based on the facts presented.
2. This Order does not in any way relieve the Supplier from any other obligation imposed under
the Act or any other state, federal, or local law, rule, or regulation.

3. Nothing contained in this Order shall preclude the Director from taking actions to include additional penalties against the Supplier for future violations of State or Federal law.
4. The Date of Issuance shall be the date that the Director signs this Order.
5. The dates set forth in the Order section may be extended in writing by the Director, in the Director’s sole discretion, based on the Supplier’s showing of good cause. Good cause for an extension generally means events outside of the reasonable control of the Supplier, such as force majeure, inclement weather, contractor or supplier delays, and similar circumstances. However, the Director expects the Supplier to employ reasonable means to
limit foreseeable causes of delay. The timeliness of the Supplier’s request for an extension shall constitute an important factor in the Director’s evaluation.
COMPLIANCE AND PENALTY NOTICE All violations of the Utah Safe Drinking Water Act, the Drinking Water Rules, and this
Order will be strictly enforced during the time that this Order remains in effect. The Utah Safe Drinking Water Act, Utah Code § 19-4-109, provides that any person who violates a rule or order made or issued pursuant to the Act may be subject to an administrative penalty of up to $1,000 per day of violation or, in a civil proceeding, to a civil penalty of up to $5,000 per day of violation. Under certain circumstances of willfulness or gross negligence, a Utah district court judge may
impose an additional penalty up to $5,000 per day of violation. Under the act, each day may be considered a separate violation. A violator may also be subject to injunctive relief pursuant to Utah Code § 19-4-107(2).
CONTEST AND APPEAL RIGHTS
1. This Order is effective immediately and shall become final unless contested in writing within thirty (30) days of the date of its issuance. This Order may be contested by filing a written Request for Agency Action in accordance with UAC R305-7. Filing a request for a hearing or a general statement of disagreement is not sufficient under Utah Code § 63G-4-
201(3)(a) to preserve your right to contest this Order. A request for Agency Action must
include the information specified in UAC R305-7. Contest proceedings are also governed by Utah Code Section 19-1-301. Failure to file a Request for Agency Action within the period provided waives any right of administrative contest, reconsideration, review, or judicial appeal. An extension is only available under UAC R305-7.
2. To contest this Order, the Supplier must respond in writing and must comply with the
applicable procedural requirements found at UAC R305-7 and with the applicable requirements of the Utah Administrative Procedures Act, including Utah Code § 63G-4-201(3)(a) and (b). The Supplier’s written Request for Agency Action must be filed and served in accordance with UAC R305-7-104(5) within 30 days of the date of issuance of
this Order. For U.S. Mail delivery under UAC R305-7, the Director’s address is Director,
Division of Drinking Water, P.O. Box 144830, Salt Lake City, UT 84114-4830.

IT IS SO ORDERED.
DIVISION OF DRINKING WATER
By:_____________________________ Tim Davis
Director Date:___________________________

System Name: System Name System Number: System Number Administrative Contact: Name Email: email Phone Number: ***-***-****
New System Order Due Dates
Date of Issuance
Plan Review Item 2a New Public Water System Supplemental Form

Action Completion Due Date
Submit a completed New Public Water System Supplemental Form. Within 30 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Jennifer Yee / Colt Smith 385-515-1501 / 385-515-1529
[e-mail] / [e-mail] Item 2b Engineering Evaluation Report Rule Citation
R309-500
Action Completion Due Date
Submit an Engineering Evaluation Report prepared by a Utah
licensed engineer containing detailed information on all system facilities.
Within 180 days of the Date of
Issuance of this Order.
Division of Drinking Water Contact
Assigned Engineer Phone Number Email

Item 2c Operating Permit Rule Citation
R309-500-4
Action Completion Due Date
The respondent shall complete all requirements to obtain an Operating Permit. Within 545 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Assigned Engineer Phone Number Email

3. Capacity Development Evaluation Item 3e Capacity Development Evaluation Rule Citation
R309-800
Action Completion Due Date
The respondent shall complete all requirements for their capacity development. Within 545 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Michael Grange 801-674-2563 [e-mail]
4. Sanitary Survey and Emergency Response Item 4a Sanitary Survey Rule Citation
R309-100-6
Action Completion Due Date
The respondent shall schedule an onsite inspection/sanitary survey. Within 365 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Ryan Dearing 801-560-8456
[e-mail] 5. Cross Connection Control
Item 5a Local Authority Statement Rule Citation
R309-105-12(2)
Action Completion Due Date
The respondent shall submit a complete Cross Connection Control Local Authority Statement to the Division Within 90 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Gary Rager 385-549-7609 [e-mail] Item 5b Public Education, Operator Training, Record Keeping, On-Going Enforcement Implementation Rule Citation
R309-105-12(2)
Action Completion Due Date
The respondent shall complete the annual public education or awareness, operator training, record keeping and on-going enforcement plan and submit evidence to the Division
Within 180 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Gary Rager 385-549-7609 [e-mail]

6. Source Protection Program
Item 6a Preliminary Evaluation Report Rule Citation
R309-600-13
Action Completion Due Date
Respondent shall submit a Preliminary Evaluation Report Within 180 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Assigned SP Staff Phone Number Email Item 6b Drinking Water Source Protection Plan Rule Citation
R309-600-7
Action Completion Due Date
The respondent shall submit a Drinking Water Source Protection Plan. Within 365 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Assigned SP Staff Phone Number
Email Item 6c Submit Ongoing Source Protection Plans Rule Citation
This system is already in compliance with source protection requirements. This is a reminder to submit updates R309-600-7(2)(e)
Action Completion Due Date
The respondent shall submit source protection updates. By MONTH,DD,YYYY
Division of Drinking Water Contact
Assigned SP Staff Phone Number Email

Item 6d Become Current With Source Protection Requirements Rule Citation
This system’s source(s) are not currently in compliance with source protection requirements. R309-600-7(2)(b)
Action Completion Due Date
The respondent shall ***** By MONTH,DD,YYYY
Division of Drinking Water Contact
Assigned SP Staff
Phone Number Email

7. Operator Certification Item 7 Operator Certification Requirement Rule Citation
This system requires a direct responsible charge operator R309-105-11
Action Completion Due Date
The respondent shall submit documentation to the Division showing the system has a direct responsible charge operator certified at the required level.
Within 365 days of the Date of Issuance of this Order.
Division of Drinking Water Contact
Dawnie Jacobo 385-272-5038 [e-mail]
8. Consumer Confidence Report Item 7b Consumer Confidence Report Rule Citation
R309-225-4
Action Completion Due Date
The respondent shall submit a copy of the Consumer Confidence Report to the Division. By July 1, 2024
Division of Drinking Water Contact
Brandi Smith 385-515-1650
[e-mail] 9. Monitoring and Reporting
Item 9a Total Coliform Monitoring Rule Citation
R309-211
Action Completion Due Date
The respondent shall submit monthly routine coliform bacteriological samples to the Division each month the system
is open.
By Date
Division of Drinking Water Contact
Sitara Federico 385-515-1459 [e-mail] Item 9b Total Coliform Sample Site Plan Rule Citation
R309-211-4
Action Completion Due Date
The respondent shall submit a written total coliform sample site plan to the Division. By Date
Division of Drinking Water Contact
Sitara Federico 385-515-1459 [e-mail]

Item 9c Lead and Copper Monitoring Rule Citation
R309-200-5(2) and R309-210-6
Action Completion Due Date
The respondent shall take and submit all required lead and copper sampling. By Date
Division of Drinking Water Contact
Bridgette Charlebois 801-247-7422 [e-mail]
Item 9c Chlorination Monitoring Rule Citation

Action Completion Due Date
The respondent shall take and submit all required lead and copper sampling. By Date
Division of Drinking Water Contact
Luke 801-247-7422
[e-mail]
Item 9d New Source Chemistries Rule Citation
R309-515-4(5)
Action Completion Due Date
The respondent shall take and submit all required New Source Chemistries for each active source. By Date
Division of Drinking Water Contact
David Kruse 385-566-7789 [e-mail]
Item 9d Source Monitoring Rule Citation
R309-200-5(1) and R309-205-5
Action Completion Due Date
The respondent shall take and submit all required New Source Chemistries for each active source. By Date
Division of Drinking Water Contact
David Kruse 385-566-7789 [e-mail]

Appendix E

2022 Updated
State Capacity Development Program
Strategy Document

State of Utah
Capacity Development Strategy
for New and Existing Systems

Utah Department of Environmental Quality Division of Drinking Water
Salt Lake City, UT

December 2022

Table of Contents
Section 1 Introduction
1.1 Authority
1.2 Program Rule
1.3 State Capacity Development Strategy Document
1.4 Water System Demographics

Section 2 State of Utah Capacity Development Program Strategy – New Systems

Section 3 State of Utah Capacity Development Program Strategy – Existing Systems

Section 4 Capacity Development Program Elements; SDWA 1420(c)(2)(A-F)
A Methods or Criteria to Prioritize Water Systems
B Factors that Impair or Enhance Capacity
C Using SDWA Authorities and Resources
D Establishing a Baseline and Measuring Improvements
E Identifying Stakeholders
F Promoting Asset Management

Section 5 Implementation Plan

Appendix A Factors that Impact Capacity

State of Utah Capacity Development Program Strategy Page 1 of 16
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Section 1 – Introduction
1.1 Authority
The Capacity Development Program was created by the Safe Drinking Water Act
Amendments of 1996. According to Section 1420(a), states are to "ensure that all new
community water systems and nontransient, noncommunity water systems commencing
operations after October 1, 1999 demonstrate technical, managerial, and financial
capacity with respect to each national primary drinking water regulation in effect, or
likely to be in effect, on the date of commencement of operations."
The Utah Drinking Water Board operates under authority granted in 1981, and upheld
through subsequent reauthorizations, under Utah Code Title 19 Chapter 4, the Utah
Safe Drinking Water Act. The Utah Drinking Water Board is a 9-person board appointed
by the Governor. The Board is empowered to adopt rules governing the design,
operation, and maintenance of Utah's public drinking water systems.

1.2 Program Rule
The Utah Capacity Development Program is codified in Utah Administrative Code Rule
R309-800 Capacity Development Program. The most recent version of the rule is
available on the Division of Drinking Water’s “Drinking Water Laws and Rules”
webpage. The Utah Department of Environmental Quality, Division of Drinking Water
(DDW, the Division) is the primacy agency for the federal Safe Drinking Water Act
(SDWA) and implements and oversees the rules authorized by the Drinking Water
Board. The program rule applies to new and existing drinking water systems and has
been updated to meet the requirements of the America’s Water Infrastructure Act
(AWIA) of 2018, specifically to encourage water systems to develop and implement
asset management programs.
Public Involvement
In order to implement the updated Capacity Development Strategy, Utah DDW was
required to update its existing Capacity Development Program Rule to include
references to asset management as required by AWIA. Utah DDW staff began updating
the existing rule early in 2022. Proposed revisions were sent to a variety of individuals
from stakeholder communities potentially impacted by changes to the rule and the
strategy, including water systems, technical assistance providers, and consulting
engineers. Comments were reviewed and evaluated, and appropriate changes were
made to the proposed rule. The updated rule is expected to be adopted by the Drinking
Water Board at its March 2023 meeting.

1.3 State Capacity Development Strategy Document
Utah developed its initial Capacity Development Strategy in 1999 but has not reviewed

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December 2022
or modified it since then. In addition to the provisions set out in the America’s Water
Infrastructure Act (AWIA) of 2018 that require states to review and update their Capacity
Development Strategies to include encouraging systems to prepare and implement
asset management programs, there have been numerous regulatory, industry, and
economic changes in the past 20 years that Utah DDW considered when reviewing and
updating the state’s Capacity Development Program Rule and Strategy Document. Utah
DDW has completely updated this strategy document and its drinking water regulations
to meet AWIA requirements as well as update the state’s approach to capacity
development.
This completely revised strategy document outlines programs, methods, and tools the
Utah DDW will employ to ensure that new and existing public drinking water systems
have or develop adequate technical, managerial, and financial capacity to operate and
maintain viable, sustainable utilities to provide Utah’s citizens and visitors with adequate
supplies of quality drinking water. The revisions include recommending and
encouraging all drinking water systems to develop and implement an asset
management program, including an asset management plan.
The Capacity Development Strategy must include six distinct elements that all work
together to aid water utilities in developing and maintaining this capacity. These six
elements are defined in Section 1420(c)(2) of the Safe Drinking Water Act as modified
by AWIA Section 2012 and include the following:
A. Methods or criteria to prioritize public water systems
B. Factors that encourage or impair capacity development
C. How the State will use the authority and resources of the SDWA
D. How the State will establish a baseline and measure improvements in capacity
E. Procedures to identify interested parties
F. Methods to promote, encourage, and assist systems to develop asset
management programs, including asset management plans
These six elements are further defined and discussed in Section 4 of this strategy
document.
To comply with AWIA’s capacity development strategy update requirements states must
complete the following steps:
• Solicit and consider public comments on the six strategy elements
• Describe which, if any, elements were excluded from the strategy and why
• Describe how the elements included in the strategy constitute a strategy to aid
systems develop or improve technical, managerial, and financial capacity
• Describe how the state will implement this strategy and evaluate progress to
improving water system capacity
• Document and report on the state’s efforts to encourage and assist systems

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develop and implement asset management programs in the state’s annual report
to EPA and triennial report to the Governor
Furthermore, to comply with the AWIA asset management mandate in the updated
capacity development program strategy Utah DDW has completed the following:
• Solicited and considered public comments on encouraging the development and
implementation of AM plans and training and how it can best be incorporate to
boost TMF capacity
• Described which elements may not need to be updated according to AWIA’s
asset management requirements
• Described how asset management can strengthen water utility’s technical,
managerial, and financial capabilities
• Described how Utah DDW will encourage water utility’s to develop and
implement asset management plans, how the updated strategy will be
implemented, and how training programs and utility progress will be tracked and
evaluated
By incorporating asset management into the strategy Utah DDW will be better able to
document and report on the state’s effort to encourage and assist water utilities to
develop and implement asset management plans and create training in its annual
program report to EPA and the triennial program report to the Governor.

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1.4 Water System Demographics
As of November 30, 2022, there were 1,056 public water systems serving drinking water
to Utah’s residents and visitors. 507 of those systems are community water systems,
and like many other states, most of Utah’s community water systems serve populations
fewer than 3,300.

These small systems often lack sufficient capacity to meet drinking water quality and
quantity standards and mitigate challenges and account for the majority of the
compliance violations issued by Utah DDW. To improve system capacity, Utah DDW
encourages all drinking water systems to develop and implement asset management
programs. Utah DDW works closely with technical assistance providers to develop
asset management training courses and provide asset management training to the
state’s water utilities.

Very Small (0-500)
51%
Small (501-3300)
26%
Medium (3301-10,000)10%
Large (10,001-100,000)
12%
Very Large ( > 100,000)
1%

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Section 2 – State Capacity Development Program Strategy – New Systems
Section 1420(a) of the SDWA requires that states ensure that all new community water
systems (CWS) and non-transient non-community water systems (NTNCWS),
beginning operations after October 1, 1999, demonstrate they have adequate technical,
managerial, and financial capacity to comply with both state and federal drinking water
requirements. AWIA modified the SDWA to require that states encourage water utilities
to develop and implement asset management programs. Utah’s legal authority to
implement SDWA provisions is codified in Utah Code Title 19 Chapter 4, the Utah Safe
Drinking Water Act. The Utah Drinking Water Board is empowered by this statute to
adopt rules governing the design, operation, and maintenance of Utah’s public drinking
water systems, including capacity development. The Board has adopted Drinking Water
Rule R309-800 establishing a state Capacity Development Program. Utah DDW has
revised this rule to include a section on asset management and encouraging water
utilities to incorporate asset management as a means to improve system capacity.
Utah’s capacity development program rule requires all proposed new systems, or newly
discovered systems, to demonstrate adequate technical, managerial, and financial
capacity through one of two methods:
1. Proposed new systems must submit a capacity development business plan,
defined in R309-800-6(1), to Utah DDW for review and approval before it may
serve drinking water to the public. The capacity development business plan
requirement has been updated to require proposed systems include an asset
management plan.
2. Newly discovered systems must either submit completed Capacity Assessment
Worksheets or a Capacity Development Business Plan, whichever best suits the
systems situation, to Utah DDW for review and approval. The Capacity
Assessment Worksheets have been updated to include questions regarding
asset management.
Both methods, updated to include asset management, provide water system owners the
opportunity to understand the financial and operational commitment necessary to
owning and operating a viable, sustainable public water system. They also provide Utah
DDW staff an opportunity to discuss these commitments and regulatory requirements,
as well as encourage asset management, with owners or prospective owners as well as
determine a system’s capabilities and capacity to meet the requirements of the SDWA
and Utah’s drinking water rules.

Section 3 – State Capacity Development Program Strategy – Existing Systems
All water systems that are rated unapproved or that are in significant non-compliance
with SDWA requirements or Utah drinking water rules are subject to assessment under
the Capacity Development Program Rule. Each existing system subject to assessment

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shall be evaluated based on the Capacity Development Criteria defined in R309-800-
4(2) and the five core component framework for asset management plans in R309-800-
5(3). The assessment shall also consider any other information, documents, and
knowledge currently available to Utah DDW including, but not limited to, historical
system documents, database records, sanitary survey results, local health department
records, operator certification records, consumer confidence reports, capacity
assessment and asset management self-evaluations, or Utah DDW staff knowledge.

Section 4 – Capacity Development Program Elements; SDWA 1420(c)(2)(A-F)
A. Methods or Criteria to Prioritize Water Systems
Utah DDW developed and defined a list of specific violations with a corresponding point
value based on the severity of the infraction. The list is codified in Utah Administrative
Code Rule R309-400 Water System Rating Criteria (Improvement Priority System). This
rule establishes the system by which the Division assigns compliance ratings to public
water systems (PWSs) and prioritizes enforcement action and technical assistance to
those systems. Asset management will be incorporated into Utah DDW’s ranking
system to evaluate water utilities compliance with state capacity development program
and asset management regulations and help them understand asset management’s
importance to a system’s overall capabilities.
DDW evaluates a PWS’s compliance record and based on the total number of
deficiency points, rates the system as “approved,” or “not approved.” The PWS
classification determines how many deficiency points the PWS may accumulate before
being assigned a “not approved” status. Community Water Systems may accumulate
150 deficiency points, Non-transient, Noncommunity Water Systems may accumulate
120 deficiency points, and Transient Noncommunity Water Systems may accumulate
100 deficiency points before being rated “not approved.”
A “not approved” rating remains in place until the threat to public health is alleviated or
the violation is corrected. However, a water system may qualify for a “corrective action”
status, if the PWS submits the following three items:
• A written agreement stating a willingness to comply with the requirements of the
Administrative Rules.
• A compliance schedule outlining the necessary construction or changes needed
to correct any physical deficiencies or monitoring failures.
• Proof of financial ability to correct the deficiencies.
The “corrective action” rating remains in place until the system has resolved all
compliance issues impacting the system’s status.
Utah DDW uses this rating system to identify and prioritize which systems are most in
need of technical assistance, training, or other help with respect to technical,

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managerial, financial, or asset management capacity. This assistance may include any
of the following:

• site visits • on-site training
• administrative orders • hearings
• penalties • court action

Utah DDW may provide this assistance using internal staff or by employing a third-party
technical assistance provider, such as the Rural Water Association of Utah (RWAU) or
Rural Community Assistance Corporation (RCAC). The Action Compliance Strategy
Meeting is a quarterly meeting where DDW staff meets with technical assistance
provider staff and local health department (LHD) representatives to discuss out-of-
compliance water systems and what assistance those systems may need to improve
their capacity and return to compliance with SDWA and national water quality
standards, including assistance with capacity development and asset management. A
new compliance list is generated for each meeting to ensure that those systems
requiring immediate attention are prioritized to receive timely technical assistance.
Utah DDW will provide “not approved” systems or systems that have an Enforcement
Targeting Tool score of 11 or greater copies of the capacity assessment worksheets to
help them evaluate the status of their technical, managerial, and financial capacity as
well as asset management plans and programs. Technical Assistance Providers and
Utah DDW staff involved in prioritizing systems for training and assistance opportunities
will be trained in capacity development and asset management to ensure these utilities
receive regular training and updates on capacity development and asset management.
This will encourage systems to understand the importance of overall capacity and asset
management’s role in that capacity.
Capacity assessment worksheets are required of all water systems seeking financial
assistance through the Drinking Water SRF program. Utah DDW may also require a
capacity assessment and asset management self-evaluation in other situations where
such an evaluation is deemed helpful for systems to develop technical, managerial,
financial, and asset management capacity. These evaluations will provide additional
criteria to help Utah DDW prioritize those water utilities most in need of technical
assistance.

B. Factors That Impair or Enhance Capacity
Many factors have the potential to either enhance or impair a water system’s capacity.
Division staff and technical assistance providers have held numerous discussions

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regarding which factors are most likely to affect capacity. While capacity is measured
through technical, managerial, and financial aspects, oftentimes a specific factor will
have influence across multiple aspects.
For instance, adequate user rates and rate structures is one factor that both Division
and technical assistance provider staff identified as having significant impacts on all
aspects of system capacity, including asset management. Without adequate resources
water systems will lack the financial wherewithal to hire and train appropriate staff which
could negatively impact both technical and managerial capacity and maintaining asset
management programs. In addition, there may be insufficient funds to pay bills on time
which could negatively impact credit worthiness, and therefore negatively impact
financial capacity. In addition, encouraging water utilities to develop and implement
asset management programs and plans may enhance their technical, managerial, and
financial resiliency. However, developing and implementing asset management
programs may also be an impairment to water utilities due to additional work for system
staff, Utah DDW staff, and TA providers.
Appendix A contains tables of identified factors that have the potential to impact water
system technical, managerial, financial, and asset management capacity as well as
whether that impact is positive or negative.

C. Using SDWA Authorities and Resources
4.C.1 Assist PWSs with Compliance
The Division has implemented a number of programs and activities, including asset
management, to assist water systems achieve and maintain compliance with SDWA,
national drinking water standards, and state drinking water rules. A few of these
programs are described below.
o The engineering plan review and operating permit program.
• Water systems are required to submit engineering plans and
specifications to the Division for review and approval prior to beginning
construction on any facility improvement or expansion.
• The Division’s Permitting Section reviews the submitted plans to assure
compliance with the Division’s construction rules (codified in Drinking
Water Rules R309-500 through -550, which are available on Utah DDW’s
website.
• The Permitting Section typically responds with plan approval or denial
within 30 days of receiving the submittal, depending on project complexity
and size.
• This program allows Utah DDW to assess a system’s technical capacity
as it relates to infrastructure construction.

State of Utah Capacity Development Program Strategy Page 9 of 16
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o The Drinking Water State Revolving Fund financial assistance program.
• The Division’s Technical Assistance Section provides oversight to two
revolving fund financial assistance programs.
 The state-funded program receives an annual allotment from the
state sales tax revenue, capped at approximately $3,600,000 per
year.
 This financial assistance is available only to political
subdivisions of the state (municipalities, water districts, etc.).
 The federal revolving fund program receives an annual
capitalization grant from USEPA based on Congressional
allocation and varies from year to year.
 Financial assistance from this program is available to both
publicly and privately-owned water systems.
• Financial assistance is available for planning or construction of
infrastructure improvement projects designed to help water systems
achieve or maintain compliance with SDWA requirements, national
drinking water regulations, and state drinking water rules. Eligible planning
activities also include preparing asset management plans.
• Eligible water systems are also prioritized based on plans to improve
technical, managerial, and financial capacity, including developing and
implementing asset management programs.

o The source water assessment and protection program.
• The source water assessment program assesses the risk of accidental
contamination of all drinking water sources.
• Encouraging water utilities to implement asset management programs and
properly inventorying and maintaining their sources will provide another
tool to help them improve their source protection programs.
• Utah’s source protection rules require that each public drinking water
supplier prepare a source protection plan. The plan must describe and
delineate source protection zones and describe protections in place to
protect source waters from accidental contamination.
• All source protection plans must be reviewed and approved by Division
source protection staff.

o The Sanitary Survey program.
• Utah state regulations require that a sanitary survey be conducted at least
every three years on all public water systems. These surveys assess

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water system construction, operations, and record keeping and identify
potential conditions that may present a public health risk.
• Sanitary surveys are conducted either by Division of Drinking Water
personnel, Utah Department of Environmental Quality District Engineers,
local health officials, or other qualified individuals authorized in writing by
the Division Director.
• This program allows Utah DDW to assess a system’s technical capacity
based on infrastructure/asset condition at the time of the site visit.
Systems that exhibit inadequate or aging infrastructure may require
additional training on technical capacity and asset management to
encourage them to improve compliance with SDWA and Utah’s drinking
water rules.

4.C.2 Encourage Partnerships Between PWSs
Utah DDW encourages partnerships between water systems through a number of
different avenues. These partnerships provide additional opportunities to encourage and
advocate for systems to develop and implement asset management programs.
The Utah Water Quality Alliance
The Alliance consists of the largest surface water suppliers in Utah, as well as small-
and medium-sized systems that operate water treatment plants. The Alliance meets
quarterly and provides training to water system staff as well as networking opportunities
for PWSs. The Alliance’s goals include assisting drinking water utilities with water
quality optimization projects, updating utilities on regulatory updates and new
regulations, a commitment to continuous drinking water quality enhancement. Utah
DDW will encourage Alliance members to be leaders in develop their own plans and
then develop training programs that may benefit all systems in the state. Alliance
members may also provide technical assistance to smaller systems that will now include
assistance with asset management.
Alliance members work together to find ways to improve monitoring source water and
treated water quality, optimize water treatment processes and enhance treatment plant
performance in removing contaminants, evaluate new technologies, participate in
drinking water research, provide input in the federal and state regulations, and assist
smaller water utilities to produce drinking water of the best quality for the citizens of the
State of Utah. As these larger systems develop and implement asset management
programs their leadership and experience may encourage other systems to also
develop and implement these programs. Utah DDW will encourage members of the
Alliance to provide mentoring and training to smaller system staff helping them see the
benefits of asset management and encouraging them to develop their own programs.
Utah WARN

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The Utah Water/Wastewater Agency Response Network’s (WARN) mission is to
support and promote statewide emergency preparedness, disaster response, and
mutual assistance matters for public and private water and wastewater utilities. The
Utah WARN website provides members with emergency planning, contact, and
recovery information, before, during, and after an emergency. Members of WARN can
also promote and encourage asset management programs as a means to mitigate
emergency situations as well as enhance all utility’s ability to quickly and fully recover
from emergency situations.
System Consolidation and Regionalization
The Division encourages water systems to investigate and implement regionalization or
consolidation efforts to the extent possible. Regionalization or consolidation may take
on a number of different forms, from merging system infrastructure, to sharing source
capacity, to managerial cooperation where multiple neighboring systems share
management and operational staff to reduce costs and take advantage of economies of
scale and improve buying power. As systems regionalize or consolidate an active asset
management program with an up-to-date asset management plan can ease the process
of transitioning to a new management style or structure as well as provide invaluable
information on system infrastructure, including operations and maintenance schedules
and records.
4.C.3 Assist PWSs through Operator Training and Certification
According to state statute, Utah water systems serving more than 800 people, systems
required by federal statute, and all systems that use physical or chemical treatment
processes to alter the water’s characteristics, must have a certified operator. Utah DDW
has the ability to encourage all regulated water utilities to implement asset management
programs by including appropriate asset management training opportunities for
continuing education credits as well as including asset management questions on
certification tests.
Utah DDW’s Operator Certification Program website (https://deq.utah.gov/drinking-
water/operator-certification) provides individuals with information about the Operator
Certification Program, details on how to become a certified water operator, certification
application and renewal forms and their associated fees, information on upcoming
continuing education opportunities, continuing education course forms, as well as a
frequently asked questions section. Utah DDW will include information on asset
management resources on this website and will work with technical assistance
providers to ensure the most helpful, up-to-date information resources (including web
links, guidebooks and reference documents, spreadsheets, etc.) are included on the
website
Continuing education courses are offered by a number of different entities, including
Rural Water Association of Utah, Rural Community Assistance Corporation, the

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American Water Works Association Intermountain Section (AWWA-IMS), individual
water systems, and various online providers. All courses submitted for operator
certification continuing education unit credits must be reviewed and approved, or pre-
approved, by the Utah Operator Certification Commission Secretary.
Utah DDW regularly works with technical assistance providers and those training the
State’s water supply operators to include courses on asset management programs and
plans. Utah DDW staff also develop training material and participate in training courses
for asset management.

D. Establishing a Baseline and Measuring Improvements
Utah uses the IPS point system outlined in Utah Drinking Water Rule R309-400 to
establish baseline water system regulatory compliance. The Division tracks changes to
a water system’s deficiency points in the WaterLink database and web application. The
WaterLink web application was developed to provide a central access point for Division
information related to water systems, including contacts, deficiencies, violations,
infrastructure inventories, site visit information, engineering plan review and approval
activities, operator certification records, and DWSRF project data.
Community Water Systems may accumulate 150 deficiency points, Non-transient,
Noncommunity Water Systems may accumulate 120 deficiency points, and Transient
Noncommunity Water Systems may accumulate 100 deficiency points before being
rated “not approved.”
Utah DDW plans on including the development and implementation of asset
management plans as information the state will consider tracking. The state will send
out an existing system technical, managerial, financial, and asset management self-
assessment worksheets to any system designated as “not approved.” Technical
assistance providers will assist systems in completing these self-assessments and the
state will review them. Systems will be required to develop at least a basic asset
management plan prior to being approved to ensure continued compliance and
technical, managerial, and financial capacity.
WaterLink is available on the Internet at: https://waterlink.utah.gov/deqWater/. Public
access to general water system information is available from the basic WaterLink
access page. Access to more specific information requires users to apply for a portal
account.
Compliance improvement will be measured based on the number of systems either
reducing their deficiency point count, returning to compliance and an “approved” status
after being rated either “not approved” or “corrective action,” entering voluntary
compliance agreements, or applying for and using financial assistance to resolve

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infrastructure deficiencies. Improvement may also be measured based on a system’s
position on EPA’s ETT list.
Utah DDW will provide “not approved” systems copies of the capacity assessment
worksheets to help them evaluate the status of their technical, managerial, and financial
capacity as well as asset management plans and programs. Technical Assistance
Providers and Utah DDW staff involved in prioritizing systems for training and
assistance opportunities will be trained in capacity development and asset management
to ensure these utilities receive regular training and updates on capacity development
and asset management. This will encourage systems to understand the importance of
overall capacity and asset management’s role in that capacity.

E. Identifying Stakeholders
Stakeholders may include any party interested in evaluating or improving water system
capacity. Stakeholders can include any or all of the following entities:
Regulatory Agencies
o Environmental Protection Agency
o Division of Drinking Water
o Local Health Department
o County and/or municipal governments
o Governing boards and bodies for privately-owned water systems
Technical Assistance Providers
o Rural Water Association of Utah
o American Water Works Association – Intermountain Section
o Rural Community Assistance Corporation
o Educational Institutions
o Environmental Finance Centers
Associations
o League of Cities and Towns.
o American Planning Association
o Utah City Engineers Association
This list is by no means all-encompassing, and many other groups may consider
themselves stakeholders in addressing and improving water system capacity.
Another important stakeholder group that deserves consideration is the general public.
A water system’s user base is perhaps the most affected stakeholder group of any
listed. The Division strongly encourages all of the state’s water systems to be open and
transparent with their users in all aspects of water system operation, maintenance, and
construction.

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Utah DDW will work closely with all stakeholder groups to promote and encourage
technical, managerial, and financial capacity and asset management among Utah’s
water utilities. Utah DDW will encourage stakeholders to take an active role with utilities
through training and discussion to answer questions and provide feedback to Utah
DDW to continuously improve training and hands-on assistance to water utilities during
site visits and assessments.

F. Promoting Asset Management
Section 2012 of the America’s Water Infrastructure Act of 2018 requires that states
include in their Capacity Development Program Strategies a description of how asset
management will be promoted and encouraged within the state. Asset management can
help water systems address aging water infrastructure, make sound financial decisions
to maximize limited financial resources, make costs transparent, and support budgeting
decisions. A proper asset management plan can improve a system’s service and
reliability, reduce risk and unexpected costs, and enhance communication with
customers and stakeholders, in addition to many other benefits.
An asset management plan is the foundation for an effective asset management
program and typically includes sections describing level of service goals, current
performance metrics and measurements, future demand estimates, risk management,
life cycle management plans (e.g., maintenance plans, rehabilitation and replacement
plans), and financial forecasts.
The asset management framework is built on the following five core questions, the
answers to which will form the basis of each section in the asset management plan.
1. What is the current state of the utility’s assets?
2. What is the utility’s required “sustainable” level-of-service?
3. Which assets are critical to sustained performance?
4. What are the utility’s best “minimum life-cycle cost” capital improvement
plan and operations and maintenance strategies?
5. What is the utility’s best long-term financing strategy?
Utah DDW’s technical assistance program will use DWSRF set asides and third-party
contractors to provide training on these five core elements and promote and encourage
asset management for all the state’s public water systems. Asset management training
will focus on helping systems understand asset management, developing asset
management plans, identifying tools & techniques for inventory development, water
system mapping methods, financial planning and implementation strategies including
rate structures, billing policies and procedures, and proper budgeting methods. Other
pertinent aspects of asset management plans and asset management programs will
also be included based on water system input and comments.

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December 2022
In addition, Utah House Bill 269 Capital Assets Related to Water, was passed in the
2022 State Legislature and signed into law by the Governor. The law requires existing
water providers to develop and implement a capital asset management plan before they
can receive financial assistance from either state or federal funds. The law also requires
that water providers participate in any infrastructure needs surveys or evaluations
required by Utah DDW.
Utah DDW will send Capacity Assessment Worksheets to those systems ranked highest
with respect to need for technical, managerial, financial, or asset management capacity
assistance to ensure this foundation is established at the state’s most vulnerable
systems. Those systems that are, or may soon be, ranked “corrective action” or “not
approved” or that are approaching an EPA ETT score of 11 will be targeted as high
priority to receive the self-assessment worksheets. These self-assessment worksheets
include the five core components of asset management and references to Utah DDW’s
website for additional capacity assessment and asset management information. Utah
DDW believes that capacity assessment and asset management can benefit all public
water systems regardless of ranking and will provide training to encourage the state’s
systems to complete the self-assessment capacity worksheets and develop and
implement capacity assessment and asset management programs.
Copies of the capacity assessment worksheets are available in Appendix B and on the
Utah DDW’s website at:
https://documents.deq.utah.gov/drinking-water/construction/DDW-2018-009523.pdf
Public water systems seeking financial assistance from the Drinking Water State
Revolving Fund program must complete the Worksheets and submit them to Utah DDW
for review and comment before any financial assistance will be approved. However, all
public water systems are encouraged to download these worksheets and determine
their needs with respect to technical, managerial, and financial capacity or asset
management. Upon request Utah DDW will review each system’s responses on the
self-assessment worksheets and help systems better understand how to resolve any
issue discovered during that review.

Section 5 – Implementation Plan
The state will encourage not only prioritized systems but all systems to improve the
safety of their water by developing and implementing asset management plans that will
boost their overall technical, managerial, and financial capacity. Improving public water
system awareness of technical, managerial, and financial capacity and asset
management will ensure Utah’s water utilities develop are resilient systems capable of
serving sufficient quantities of quality drinking water. Efforts to improve Utah’s drinking
water systems technical, managerial, and financial capacity requires the combined
efforts of Utah’s drinking water professionals, industry leaders, water system managers

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December 2022
and staff, and regulatory bodies to develop criteria, training, and methods that promote
technical, managerial, and financial capacity and asset management to ensure the true
causes of deficiencies are addressed prior to compliance issues surfacing.
Utah DDW will encourage the state’s water utilities to develop and implement asset
management plans through compliance related activities and our rating system, by
providing technical assistance to water systems that focuses on developing and
applying asset management tools, emphasizing asset management in budgets and
finances, including questions in certification exams and CEUs for operators, and
creating a process to implement continuous improvement in all training courses on
asset management for operators, owners, and managers.
Utah DDW has implemented a policy that requires public water systems requesting
financial assistance through the DWSRF Program provide a copy of their asset
management plan to DDW for review and approval. If a water system does not have an
asset management plan, financial assistance is available to prepare one. Preparing the
asset management plan may progress simultaneously with the system’s infrastructure
construction planning and engineering design process funded by the DWSRF program.
Utah DDW will evaluate our public water systems success in developing and
implementing capacity development programs and asset management plans and
programs as outlined in this policy. Based on that evaluation, Utah DDW will then put
policies and procedures in place that apply to all drinking water systems and will assist
those systems with capacity development an asset management through training and
technical assistance.

Appendix A

Factors that Impact Capacity

Factors that Impact Capacity
Capacity Aspect Factor Measure Impact
Technical
Source Adequacy
Valid Water Right
Systems with a legal right to the water they serve their users have additional control of that water including, source
water protection and water quality, and available water quantity.
Source Quantity Sufficient source water quantity assures that the system is able to meet its water
use needs to protect public health.
Source Quality
Adequate source water quality helps systems better protect public health. It also reduces potential treatment costs related to treating water to drinking water standards.
Source Protection
A system’s control over source protection issues provides additional public health protection as well as
potentially reducing treatment costs.
Infrastructure Adequacy
Facility Condition
Properly maintained water system infrastructure provides an environment conducive to good water quality as well
as preserving water quantities delivered to users.
Facility Life Expectancy
When properly maintained, water infrastructure can have significant life
expectancy. This can help water systems continue to provide sufficient quantities of quality drinking water to
their users at reasonable rates.
Capital
Improvement Plan
A capital improvement plan allows a system to proactively plan for infrastructure improvement projects. These projects can include major facility repair and/or new construction for both anticipated growth and compliance with
drinking water standards.

Capacity Aspect Factor Measure Impact
Technical
(continued)
Technical
Knowledge
Asset
Management Program
A well-thought-out Asset Management Program, including an Asset Management Plan, allows water systems to minimize the total cost of
owning and operating assets and provide customers with the level of service they desire. Asset Management
is a key to developing and maintaining a sustainable utility.
Certified Operator
Properly certified operators positively affect water system capacity by applying
their knowledge to provide the system’s users with water that complies with drinking water standards and the SDWA.
Operator Knowledge
Operators with sufficient knowledge of drinking water regulations, operations and maintenance procedures, and customer service contribute significantly to a water system’s technical capacity.
System O&M Program
A robust system operations and
maintenance plan allows system staff to plan and follow through on proactive system maintenance which can
significantly improve staff efficiency, infrastructure condition and life expectancy, and reduce costs. A good plan also provides direction to staff on system policy, procedures, and best management practices for each facility within the system.
Knowledge Application
Operating Standards Properly applied standards help system maintain public health protections.
O&M Program Implementation
Proactive O&M Programs prolong infrastructure life and preserve water
quality and volume.

Capacity Aspect Factor Measure Impact
Managerial
Ownership Accountability
Owner Clearly Identified
A clearly identified owner indicates that the water system takes its responsibilities seriously. A clearly identified owner is typically more willing
to be actively involved in running a utility that complies with regulations and the SDWA.
Owner Responsibility
Owners willing to take responsibility for system compliance are actively involved with system operations and ensure O&M policies and procedures are in place to
maintain compliance and protect public health.
Asset Management Program
A fully implemented Asset Management Program provides information utility management can use to ensure decisions affecting system O&M and capital facility repair and replacement are made with the best, up-to-date information.
Staffing & Organization
System Staff
Clearly Identified
A well-defined organizational structure with clear lines of authority and management can reduce staff and
constituent confusion and contributes to a well-run water system. An organization chart provides a visual description of the system’s structure as well as the management and reporting structure.
Operators
Certified
Drinking Water systems are required to have at least one certified operator
responsible for day-to-day system operation and maintenance. These operators should be clearly identified in
the systems organization chart and other management tools.
Operational
Expertise
A well-run system will properly maintain records related to system infrastructure,
such as infrastructure maps, infrastructure construction/installation dates, maintenance work orders,
monitoring schedules, and operational procedures and activities.

Capacity Aspect Factor Measure Impact
Managerial
(continued)
Effective External
Linkages
Customer
Interactions
A well-run water system will be
transparent with its users, on both good news and bad. Effective communication with customers is critical to improving
and maintaining managerial capacity.
Regulator Interactions
One sign that a system has adequate managerial capacity is whether it views regulatory bodies as adversaries or resources. Better relationships with regulators can be a sign that a system is working to maintain or improve its
managerial capacity.
External Resources
This measure includes many different
aspects including access to and willingness to use outside technical and financial assistance services. Systems with adequate managerial capacity will recognize and use assistance services offered by entities such as RWAU, AWWA, RCAC, DDW, the DWSRF program, etc.

Capacity Aspect Factor Measure Impact
Financial
Sufficient
Revenue
Revenue
Systems demonstrate adequate financial
capacity through maintaining water rates sufficient to meet expenses. They will have appropriate rate and enforcement
ordinances or bylaws, will regularly review rates and rate structures, will employ adequate budgeting policies and
procedures, will have or establish debt and facility replacement reserve accounts, and will have emergency
operating expense reserve accounts to carry them through challenging times.
Expenses
Well run systems will track control expenses and will maintain sufficient
revenue and reserve funds to cover expenses.
Credit Worthiness
Paying bills on time
Systems demonstrate financial capacity by having sufficient revenue to meet their debt obligations in a timely manner, even in times of distress. Adequate rates and emergency operating fund accounts
contribute to this measure.
Access to Capital
A system’s access to both public and
private capital, as demonstrated by a good credit rating is a good indicator of a system’s financial capacity.
Fiscal
Management
Adequate
Records
A well-run system will have appropriate
financial statements either prepared by a CPA or regularly audited by a CPA. An audit every three years is the
recommended minimum.
Appropriate Budgeting and Accounting
A system with adequate financial capacity will use generally accepted accounting principles.
Effective Revenue Management
The operating ratio, coverage ratio, and debt service ratio will all be within accepted parameters.
Asset
Management Program
A fully implemented Asset Management Program provides information utility management can use to ensure
budgeting decisions, especially those related to asset maintenance or replacement, are made using current
information.