During sanitary surveys, the Field Services Section (FSS) has encountered serious significant deficiencies at water systems such as tanks with collapsing roofs, major water loss in raw water transmission lines and distribution systems, or evidence at water treatment plants of a substantial lack of preventative maintenance. Many of the systems experiencing these major issues are small community water systems struggling to manage a water system and keep up with replacement of aging infrastructure. Fundamental to this issue is Technical, Managerial, and Financial (TMF) Capacity of a public water system (PWS). TMF capacity, also known as Capacity Development, is part of the 1996 Safe Drinking Water Act (SDWA) Amendments. Capacity Development is a process for PWSs to build technical, managerial and financial (TMF) capacity to be able to continuously provide safe drinking water to the public. Activities involved with developing adequate TMF capacity include items such as asset management, financial planning and water rate setting in addition to managerial and technical capacity as shown below:
Source: US EPA - Building the Capacity of Drinking Water Systems
As inspectors work with PWSs during the sanitary survey process, they may ask basic questions regarding TMF actions that the PWS has implemented. If a PWS has TMF capacity areas of improvement, a new observation will be listed in the inspection report. This observation will be coded as R541 TMF and will explain the importance of TMF and provide links to resources that are available to PWSs. Water system operators may find it helpful to review this observation with system ownership and management to gain support to undertake needed TMF capacity development activities and get help as discussed below.
Please note that Regulation 11.4.1 also requires all new community or non-transient, non-community water systems commencing operations after October 1, 1999 to receive Department approval of a TMF capacity assessment using the criteria found in the New Public Water System Capacity Planning Manual (Drinking Water Policy 11). Please reach out to the WQCD Engineering Section at CDPHE.WQEngReview@state.co.us for any questions regarding new PWS TMF requirements.
Resources:
- Colorado has a Capacity Development Program to assist public water systems in building TMF capacity. TMF coaching is available from our Local Assistance Unit by filing out the coaching request form.
- Additional TMF capacity resources are available on EPA’s TMF for small systems website
➽ Heather Young, PE, CWP, Field Services Section Manager
➽ Tom Valenta, Field Unit III Work Group Lead
