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Wednesday, August 17, 2022

Capacity – why is it important, and what can I do about it?

You may have heard the term “TMF” come up in a sanitary survey or a design review, but do you really know what it means and how it can affect your water system? TMF stands for Technical, Managerial, and Financial Capacity of a public water system (PWS), and it affects

the ability of a PWS to operate in an effective and proactive manner, to protect public health, successfully apply for funding, and to meet compliance and design requirements. 

Not having adequate TMF increases the chance that a PWS will be unable to acquire the right level of operations or engineering expertise, will be unable to complete public notice or other regulatory requirements or will be unable to pay for emergency repairs or capital improvement projects. Not being able to demonstrate sufficient TMF will also disqualify your PWS from certain funding opportunities, including low interest loans, principal forgiveness, and grants. With the large influx of Federal funding under the Bipartisan Infrastructure Law, there will soon be many funding opportunities available. Don’t miss out on this opportunity because your TMF is inadequate — take steps now to set up your PWS for success. 


Key components of TMF:

Technical

Managerial

Financial

Regulatory Compliance

Organization

Cash Flow Analysis and Financial Plan

Water Resource Management

Planning

User Charge System

Treatment

Recordkeeping

Financial Audit

Distribution

Certified Operator

Insurance

Personnel



How do I know if I have adequate TMF? 

You can perform a self-assessment of your TMF by using the Drinking Water Projects Technical, Managerial and Financial Capacity User Guide. Drinking water projects that apply for State Revolving Fund (SRF) funding complete a TMF evaluation that is embedded in the Project Needs Assessment required for every applicant. If you have questions about SRF funding or the TMF evaluation included in the application you may contact your regional SRF Project Manager indicated on this map. If your PWS is receiving compliance violations, sanitary survey significant deficiencies or violations or multiple requests for information on a design submittal, these are also indications that your PWS is lacking in some area of TMF.

Where can I go for more assistance? 

The Colorado Department of Public Health (CDPHE) Water Quality Control Division (WQCD) has capacity coaching available for free through the Local Assistance Unit. PWS can request assistance by filling out the Coaching Assistance Form. Additionally, the Department of Local Affairs (DOLA) can provide guidance and assistance by contacting your DOLA Manager or by reaching out to the DOLA Water and Wastewater Program Manager, Desi Santerre at desiree.santerre@state.co.us.

What are the requirements if I am setting up a new community or non-transient, non-community PWS?

The federal Safe Drinking Water Act (SDWA) requires that states ensure that all new community or non-transient, non-community systems beginning operations after October 1, 1999 demonstrate their TMF before starting operations. To that end, CDPHE has an extensive New System Capacity Planning Manual that contains step by step instructions, applicability, and a host of links to helpful resources.

➽ Margaret Talbott, P.E., Drinking Water Compliance Manager