Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
1. Given that a water supply meets all objective regulatory requirements, how does your agency achieve reasonable assurance that an
unfiltered water supply is safe to drink? What factors go into this conclusion?
 Long-Term Watershed Protection Plan and the
 Conduct water quality testing in the watershed tributaries and
Filtration Avoidance Determination (FAD) issued by
reservoirs
EPA. Programs cover:
 Wide range of daily testing from the source to the tap—before, during,
- WWTP upgrades
and after treatment
- septic repair and replacement
 Ensure restricted access in the watershed (human and livestock) and
- construction of new community wastewater
patrol intake area
management facilities
 Well-operated, -monitored, and –maintained treatment facilities
- stormwater management
 Develop a protection program based on assessments of how water
- land acquisition
quality could be compromised
- waterfowl management
 Design and construct treatment based on long-term water quality of
- implementation of agricultural and forestry BMPs
the lake
- riparian buffer protection
 Use BMPs
 Strong Watershed Rules and Regulations (WR&Rs)
 Check and double check treatment chemicals
 Pathogen monitoring in the watershed
 Water quality customer complaint system to track customer calls as an
 Syndromic surveillance program
early warning to water quality changes
 Keep close contact with state Epidemiologists and
 Research projects
unfiltered systems, discussing issues early on.
 Regional partnerships
 Systems sample above and beyond monitoring
 Outreach and education
requirements
 Advanced technologies
 Annual watershed inspections and the annual report
 On-the-ground implementation and monitoring
 Contaminant inventory, activities log, perimeter
 Source Water Assessment (SWA)
posting
 Source Water Protection Plan (SWPP)
 Monitor for more contaminants and at a greater frequency than
required
 Infectious disease surveillance and waterborne disease risk
assessment program to monitor for any potential outbreaks
 Back-up ground water supply that meets base water demands when
turbidity (or other risk factors) create the need for a shut-down
 The water department publishes SOPs, policies, and specifications
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
2. How do you sufficiently manage microbial risk when you don’t necessarily have certain data, clear models, or fully-developed, formal
risk assessments available?
 Assess the genotypes of Cryptosporidium detected in
 Permanent programs to manage microbial risk
the watershed
 Detailed sanitary surveys in tributary areas
 Multi-tiered Water Quality Modeling Program
 Update the Watershed Protection Plan
 Crypto-Giardia Action Plan to ensure prompt and
 Administrative controls, including:
complete communications and response in the event
- Purchasing watershed land
of elevated pathogen levels
- Restrict access
 Raw water bacteria monitoring
- Prohibit industrial/agricultural activities
- Forestry management
 Unfiltered PWSs own/control part of the watershed
- Decommission roads
and acquire conservation restrictions to protect
- Prevention planning for invasive species
watershed lands
- Site-specific water quality management plans
 Prohibit bodily contact in the unfiltered supplies
 City-owned and privately operated treatment facilities
 Prohibit sources of contamination (e.g., cattle feed
 Extensive and frequent monitoring
operations or human septic/sewage)
 Work with regulatory community
 Annual watershed inspections
 Develop and operate an Early Warning System to provide advanced
 Identify potential threats (e.g., wildlife, agricultural
warning of water quality contamination events
runoff, stormwater, erosion, public access)
 UV treatment facility
 Publish guidance and SOPs
 Identify greatest threat and develop plan to address threat
 Communicate successful programs/techniques of one
PWS to other PWSs
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
3. What do you think are the most accurate AND efficient ways to measure microbial risk at water supplies?
 Routine water quality monitoring
 Regular tributary and reservoir transect sampling in the watershed
 Storm event monitoring
 Fecal and e. coli monitoring of raw water around the lake and its
tributaries
 Genotyping of Cryptosporidium
 Real-time monitoring and modeling of sources of microbial
 Routinely monitoring for viruses in source water, along
contamination
with other water quality parameters, acting as
indicators for changing water quality associated with
 Giardia and Crypto monitoring
increased microbial risk
 GIS capabilities to understand landscape conditions
 Reliable, extensive, and redundant treatment
 Daily monitoring/inspection by city personnel
monitoring
 Understand wildlife as a potential vector
 Turbidity and coliforms according to federal
requirements
 Water supply monitoring near the intake and near
identified vulnerable areas
 Assess activities that occur in the direct watershed
 Recognize and control microbial threats (e.g., storm
water, erosion, wildlife, land use)
 Measure risk through research studies
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
4. Which source water protection requirements do you think provide the least amount of public health protection? Which provide the
greatest amount of public health protection?
 Greatest:
 Greatest
- Land ownership and control
- Wildlife control
- Restricting human activities
- Restrict access
- Developing zonal protection areas
- Hazardous material spill prevention projects
- Emergency response preparedness
- Land acquisition for the long-term
- Maintain forest cover
- Inspect development
- Programs that minimize fecal load to the reservoirs (e.g., Waterfowl
Management Program, Watershed Agricultural Program)
- Implementing BMPs
- Foot patrol by inspectors to identify failing septic systems
- Joint municipal and federal legal protections of watershed
 Least
- Difficult to determine, could be public education
- In the event of contamination, sampling and analysis is less protective
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
5. How does your agency or organization measure the effectiveness of a water utility’s source water protection program? What are the
most and least informative metrics?
 Water quality standards
 Track and report on all programs and projects, keeping different (but
consistent) metrics and measurements for each
 Review of FAD deliverables
 Water quality monitoring
 Annual on-site inspection
 Document and monitor sound ecological practices
 EPA guidance and criteria
 Long-term trends of source water quality
 State-designed watershed control program
evaluation/inspection form
 Wildlife studies
 Improvements/stability in water quality
 Inspections
 Minimum requirements plus something extra (e.g.,
 Hours of inspections per week
education/outreach program, robust land acquisition
 Percent NRPA sites inspected
program, involvement in local stakeholder groups)
 Number of Lakescaping consultations
 PWS land ownership (the more land owned and
 Planning Board agendas reviewed
directly controlled by the utility, the better the
 Trophic state of lake
watershed control program)
 Monitoring results:
 Limited access to watershed
- intake zone for acute contaminants
 Difficult to identify specific metrics, as effective
- lake for acute and chronic parameters
programs are holistic
- watershed for acute, chronic, and biological parameters
 Adherence to the measures of success identified by
 Utilized Lakescaping budget each year, maximized leverage of
the state
Lakescaping funds
 Short- and long-term updates from PWS
 Passed annual water department audit
 Assessment of staffing situation (including turnover)
 Presented lake data or principles to watershed audiences
 Strong relationships between PWS, watershed
 Land placed in easement or purchased in fee
communities, landowners, and general public
 Organized Lake Keepers Roundtable
 Organized Code Enforcement Officers Roundtable
 Less informative metrics:
 Met or collaborated with watershed partners
- Paperwork
 Completed and reviewed Source Water Assessments
- Documents prepared by the PWS
 Completed and reviewed Source Water Protection Plan
- Number of violations and other numerical data are not
 Completed and reviewed Watershed Control Plan in compliance with
as helpful as the prevention measures/response to
SDWA LT2 goals
those violations
 Modeling
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
 Comprehensive 5-year assessment report
 Annual reported and abated violations
 Documentation/analysis of incidents

-
Least informative metric:
Positive coliform samples within the distribution system
6. What actions, issues, or areas related to source water protection (and its measurement) are there where you find tough tradeoffs
between cost/resource demand, efficiency, and efficacy?
 Crypto removal/inactivation where it has been
 Transportation system improvements are costly
determined that there is little to no risk
 Infrastructure projects are costly
 Requiring PWS upgrades instead of enacting
 Land acquisition
(conservation?) ordinances in PWS-owned land
 Seasonal variations in workload for watershed inspectors
 Managing public access and SWP (e.g., resource
 Sampling/lab analysis—use of a contract lab versus an in-house lab
protection vs recreational use of reservoir)
7. In the source water protection efforts you manage, what are the areas where you think there could be greater efficiencies or cost
savings without sacrificing efficacy?
 More regular, timely reporting to the state regulatory
 Executing a planned land exchange with the US Forest Service to
agency
create a mutually beneficial land ownership plan
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
8. When a source water protection program benefit (including risk reduction) is not quantifiable and costs are high, how is the decision
made to accept or reject making such a program a requirement? (Asked of regulators only)
 An understanding that water quality protection is the
sum of individual programs. The cost of improved
water quality is less than the cost of constructing
filtration plants
 1997 Memorandum of Agreement, includes programs
that were developed to address watershed community
needs and are not directly focused on water quality
benefits
 Take feasibility into consideration. If a proposal is too
expensive, the state regulatory agency would not
require the action.
 Allow PWSs to spend their money as they wish, adding
recommendations where relevant.
 The PWS has to respond to changes that occur in the
watershed, and determines whether or not the costs
of remaining unfiltered are consistent with their
mission/budget.
 PWSs have often opted to acquire conservation
restrictions rather than land purchases, to reduce
costs.
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
9. Which issues do you find most difficult operationally to manage in order to successfully meet quantifiable source water protection
goals? (Asked of utilities only)
 Resources (i.e., staff, money, expertise, equipment)
 Stakeholder buy-in and cooperation
 Bureaucracy of changes (budgets and contracts)
 Turbidity events caused by extreme weather conditions
 Difficult terrain limits water department’s ability to meet goals
 Storms resulting in power losses cause communication issues
 8-hour hold time tor raw water coliforms
 Rigid time constraints around Crypto samples
 Conflicts in mission and coordination between the water department
and US Forest Service
10. If you can, please provide a successful interaction or resolution between the regulator and utility on source water protection. What
do you think were key factors in that success?
 Strong communication led to a direct improvement in
 PWS worked with local and state health departments to implement a
water quality when one regulatory agency provided
composting toilet program that replaced an outdated sewage
testimony in favor of a PWS’ effort to eradicate a
collection service from outhouses and seasonal cottages on lakefront
known source of contamination. The effort was
properties
approved and implemented.
 City granted the city water department a variance to LT2 requirements
 A small, privately owned, unfiltered PWS completed
 State was willing to evaluate a risk assessment approach specific to the
projects with cooperation from the state regulatory
watershed
agency.
 A filtered PWS followed regulatory agency
recommendations to adopt SWP bylaws beyond
requirements and offered outreach.
 The state regulatory agency made a requirement to
document field conditions when collecting water
samples, potentially based on a practice adopted by
filtered PWSs.
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Summary of Survey Results for Source Water Protection Workshop #4528
Regulators
Utilities
11a. As a regulator, what would you need utilities to do to
11b. As a water utility, what would you need regulators to do to make your
make your job more effective?
job more effective?
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Conduct monitoring to evaluate the effectiveness of
stream management projects
Clear communication—let regulators know what they
can do to help improve their SWP program
Make information readily available in advance of an
inspection, maintain SOPs
Purchase the watershed
Invest in quality improvement efforts
Develop and implement their own enforcement
strategies that are effective and concise, possibly
through trial and error



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
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Provide clearly defined end goals and program success measures
Guidance for unpredictable/unusual events
Prior to enacting regulations, improve identification and quantification
of health hazards
Communication on major rules
Timely regulatory reviews
Greater flexibility for compliance options
Keep themselves informed of programs
Provide regulatory assistance and legal support
Share/encourage BMPs from other systems
Make recommendations specific to water systems
Advocate for lake protection in the state legislature
Communicate with the public
Secure funding for watershed land acquisition
12. Given your responses, can you think of any specific areas for fruitful research that we might consider and discuss in the workshop?

Identifying activities and their metrics that are
compatible to water quality efforts

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How to deal with public opposition to watershed projects
Use of new technology to assist in source water monitoring
Private funding of watershed land conservation
Analytical methods
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