Since then, the division has been working with stakeholders to better understand the logistic, technical and public communication challenges associated with DPR and develop mechanisms to address those challenges. We realized that DPR was not prohibited, but that we did not have specific rules to ensure that DPR would be done safely. As the effort progressed we understood that beyond the technical treatment issues, public communication and acceptance of the process was vital. In March 2021 we launched a stakeholder process to develop a specific rule to address DPR. The rule will include requirements that address both the technical and communication aspects. The rule is being drafted this fall and the concepts in this article are considerations as we move forward.
Regarding communication, the draft rule provides that a communication and public outreach program must be developed and implemented. Disproportionately impacted members of the community must not be left out of the process and deserve to have a say in the safety and quality of their drinking water. Therefore, in support of equity, diversion and inclusion, the communications and public outreach program must be conducted in a manner that allows for meaningful involvement and fair treatment of Disproportionately Impacted (DI) communities, as defined in C.R.S. 24-4-109(2)(b)(II), or as approved by the Department.
Meaningful engagement with DI communities means more than sending a typical public notice type of document in the mail. Meaningful engagement means that information is provided in plain language and in a language the community understands. Meaningful engagement means that dialogue takes place, questions are answered, and concerns are addressed to the extent feasible. A description of how the supplier conducted outreach in a manner that allowed for meaningful involvement and fair treatment of DI communities, including a summary of engagement and responses from DI communities, if applicable, must be included in the plan. A certification that states that the supplier has fully complied with the communications and public outreach requirements must also be submitted to the department.
It’s important that the entire community including any DI members be given the opportunity to gain an understanding of:
What DPR is and why it’s being done?
What treatment processes and sampling will be done to ensure that tap water is safe?
What wastewater treatment plant is the source for the recycled, purified water?
Where in the community will the recycled water be supplied?
The entire community or only certain areas?
Are there DI communities in those areas and how will they be impacted?
How will the community be notified if the treatment process fails or sampling results show a problem with the water and how long will that take?
We realize that many people are often unaware of where their water comes from and how safe it is. Therefore, water utilities will need to embark on a general education process about drinking water and the water cycle before getting into DPR issues. This general public education is long overdue and the department advocates that specific utilities as well as the utility community in general embark on public education about how safe our collective drinking water really is. As time goes on we will learn more about implementing DPR and how best to engage with communities about this subject, including DI communities. Both now and in the future incorporating EDI into the process will not only be necessary, it is and will be the right thing to do.
➽ Ron Falco, P.E. Safe Drinking Water Program Manager
