DDW-2025-003951

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
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Tim Davis
Executive Director
DIVISION OF DRINKING WATER
Nathan Lunstad, Ph.D., P.E.
Director
April 10, 2025
Roam America
Escape RV Resorts- Knotty Pine
5175 E SR 35
Kamas, UT 84036
Subject: Administrative Order: “Approved” Rating Determination for Escape RV
Resorts- Knotty Pines Water System UTAH22022
Dear Knotty Pines Water System,
The Division of Drinking Water would like to inform Escape RV Resorts-Knotty Pines Water
System of our decision to change its status to the “Approved” rating in accordance with the Utah
Drinking Water Rules. Enclosed is the “Administrative Order: ‘Approved’ Rating Determination.”
We appreciate the efforts you have taken to be in compliance with Utah’s Drinking Water Rules.
Those rules were adopted to ensure safe, reliable drinking water and to protect public health. My
staff and I stand ready to continue to assist you. Please contact us if there is anything we can do to
support you.
Sincerely,
Nathan Lunstad, Ph.D, P.E.
Director, Division of Drinking Water
Sincerely,
NNathan Lunstad Ph D P E
Escape RV Resorts- Knotty Pine
Page 2 of 8
April 10, 2025

Enclosures: “Administrative Order: ‘Approved’ Rating Determination”, “IPS Report”

cc: Roam America, Escape RV Resorts- Knotty Pines, 5175 E. SR 35 Kamas, UT 84036
Cody Fishel, Roam America, [e-mail]
Nathan Brooks, Summit County Health Department, [e-mail]
Chris Brown , Environmental Protection Agency-Region 8, [e-mail]
Dani Zebelean, Division of Drinking Water, [e-mail]
Colt Smith. Division of Drinking Water, [e-mail]
Melissa Noble, Division of Drinking Water, [e-mail]
EQDWMonitoring, EQDWCOA, and EQDWFS
Bret F. Randall, Assistant Attorney General, [e-mail]
Tim Davis, Utah Department of Environmental Quality, [e-mail]

Administrative Order: “Approved” Rating Determination

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
Printed on 100% recycled paper

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Tim Davis
Executive Director

DIVISION OF DRINKING WATER
Nathan Lunstad, Ph.D., P.E.
Director

UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF DRINKING WATER

In the Matter of:

Escape RV Resorts-Knotty Pines

ADMINISTRATIVE ORDER:
“APPROVED” RATING
DETERMINATION

Docket No. UTAH22022-2025

This ADMINISTRATIVE ORDER: “APPROVED” RATING DETERMINATION
(“Order”), relating to Roam America dba as Escape RV Resorts-Knotty Pines (the “System”),
has been issued by the Director of the Utah Division of Drinking Water (“Director”) based on the
authorities and findings provided herein. Notice of this Order is being provided to Roam
America, a DBA, as the “Supplier” who is legally responsible for the 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
Escape RV Resorts- Knotty Pine
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April 10, 2025

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 R309-400. This rule is generally known as the Improvement Priority System(“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 R309-400-4(1)(a)(ii) directs the Director to establish “the point thresholds for
assigning an Approved or Not Approved rating for each type of water system.” For
systems exceeding the point threshold, the Director may 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.
9. UAC R309-400-4(4) allows the Director to assess points against public water systems
upon their failure to comply with Division directives and orders.
10. UAC R309-400-5(1)(b)(ii) allows the Director to rate any public water system as “Not
Approved” at any time if an immediate threat to public health exists.
11. UAC R309-400-5(1)(c) provides that a public water system may qualify for a “Corrective
Action” rating for its public water system “based on a current, written agreement with the
division to resolve underlying noncompliance according to a compliance schedule.”
12. 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.
13. Utah Code § 19-4-107 provides that upon discovery of any violation of the Act or a rule
of the, 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.
Escape RV Resorts- Knotty Pine
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April 10, 2025

14. 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.
15. The Director’s jurisdiction to issue this AO 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 in the Division’s administrative files, the Director makes the following
Findings for purposes of this Order:
1. The System is a public drinking water system within the meaning of the Utah Safe
Drinking Water Act and the Utah Public Drinking Water Rules.
2. The Supplier is the owner and/or operator of the System and is therefore legally
responsible for the System and for compliance with applicable laws, rules, and
regulations.
3. The System qualifies as a Transient Non-Community system under the Utah Public
Drinking Water Rules. The maximum number of points allowed for this type of system
is 100.
4. The System is currently rated as “Corrective Action”.
5. For the reasons stated in the Master IPS Report attached hereto as Exhibit A, the System
has been assigned 55 points. This number is below the threshold provided in the IPS
Rule. The Master IPS Report is incorporated herein by this reference.
6. On October 8, 2024, the Supplier entered into a Compliance Agreement Enforcement
Order (“CA/EO”) relating to the System. As reflected in the Master IPS Report and
Division records, the Supplier has achieved compliance with the requirements in the
CA/EO.
ORDER
Based on the foregoing Findings and good cause appearing, IT IS HEREBY ORDERED as
follows:
Escape RV Resorts- Knotty Pine
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April 10, 2025

1. The System is hereby rated as “Approved” under the Utah Public Drinking Water Rules.
2. The CA/EO dated October 8, 2024, is hereby closed.

GENERAL PROVISIONS

1. 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.
2. 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.
3. The Date of Issuance shall be the date that this Order is signed by the Director.
CONTEST AND APPEAL RIGHTS

1. This Order is effective immediately and shall become final unless the Supplier
contests its validity or correctness in writing within thirty (30) days of the date of its
issuance. See Utah Code Utah Code § 63G-4-102(2)(k). The validity or correctness of
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 the
validity or correctness of 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 operates 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.

Escape RV Resorts- Knotty Pine
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April 10, 2025
IT IS SO ORDERED.
DATED this _10th _ day of __April__, 2025.
DIVISION OF DRINKING WATER
By:
Nathan Lunstad, Ph.D, P.E.
Director, Division of Drinking Water
y:
hdh
Escape RV Resorts- Knotty Pine
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April 10, 2025

CERTIFICATE OF SERVICE

I certify that I served a copy of Administrative Order: “Approved” Rating
Determination for Escape RV Resorts-Knotty Pines UTAH22022 via registered mail to the
following:

Roam America

REGISTERED MAIL #
5175 E. SR 35
Kamas, UT 84036

Escape RV Resorts-Knotty Pines

REGISTERED MAIL #
5175 E. SR 35
Kamas, UT 84036

_______________________________
Name

_______________________________
Date
Utah Department Of Environmental Quality
Division Of Drinking Water
IPS 2020 Report
IPS Report
ESCAPE RV RESORTS -KNOTTY PINE PWS ID: UTAH22022 Rating: Approved 04/21/2025 Active
Legal Contact
ROAM AMERICA
5175 E SR 35KAMAS, UT 84036
Phone: [phone]
County: SUMMIT COUNTY
System Type: Transient Non-Community
Population: 354
Site Updates
Last Inventory Update: 03/19/2025
Last Surveyor Update: 10/17/2023
Surveyor: ROCKY PACE
Operating Period: 1/1 - 12/31
Last IPS Update: 04/21/2025 07:10:00
Consumptive Use Zone
Irrigation Zone: null
Date:
IPS Summary Total IPS Pts: 55
Admin & Physical Facilities Quality & Monitoring Significant Deficiency
55 0 0
DEQ | Drinking Water
Run Date: 04/21/2025 08:09:27 | Rating: Approved UTAH22022 ESCAPE RV RESORTS - KNOTTY PINE page 1 of 2
Physical Facility Points 2020 Total Pts: 55
Facility Facility Name Status Points Effective
DS001 UTAH22022 DISTRIBUTION SYSTEM A 45.0
Code Description Severity Comments Determined Date
NotAssessed Assessed
V034 SYSTEM LACKS MORETHAN 20% OFREQUIRED STORAGECAPACITY (FIREDEMAND NOTINCLUDED)
SIG TEMPORARY EXCEPTIONGRANTED 12/10/2024.SYSTEM MUST CORRECTDEFICIENCY OR RENEWEXCEPTION BY 12/31/2027.FILE #17631
10/17/2023 50 0
M003 CCC-LACKS LOCALAUTHORITY MIN Operator is unsure of anydocuments 10/17/2023 15
M004 CCC-NO ANNUALPUBLIC EDUCATIONOR AWARENESS
MIN They do not really have anypublic awareness oremployee training as itpertains to the water system
10/17/2023 15
M005 CCC-LACKSOPERATOR TRAINING MIN They do not have backflow101 training completed.10/17/2023 15
WS001 KNOTTY PINE WELL A 10.0
Code Description Severity Comments Determined Date
NotAssessed Assessed
S015 WELL LACKS AMEANS TO MEASUREWATER LEVELSPERIODICALLY
MIN No plans or means tomeasure water levels.10/17/2023 5
S024 NO CHECK VALVE ONWELL DISCHARGEPIPING
MIN Did not see a check valve onwell discharge line.10/17/2023 5
Operator Certification
Type Level Required Highest Certificate
Distribution
Treatment
Open Compliance Schedule
Type Required Activities Severity Created Due
TEMPORARY EXCEPTION GWR CORRECT DEFICIENCY 120 DAYS SIG 10/08/2024 12/31/2027
DEQ | Drinking Water
Run Date: 04/21/2025 08:09:27 | Rating: Approved UTAH22022 ESCAPE RV RESORTS - KNOTTY PINE page 2 of 2