Partnering for public health during Drinking Water Week

Governor Jared Polis has proclaimed next week, May 3-9, as Drinking Water Week in Colorado. The Colorado Department of Public Health and Environment will observe the week with the theme, "Clean, accessible drinking water is a pillar of community and public health."

As drinking water providers and key stakeholders, you are the foundation upon which this pillar rests. This annual celebration is an opportunity to remind Colorado residents and leaders that the ability to simply turn on a drinking water tap is a modern achievement, one that requires continued vigilance and investment.

Providing reliable, high-quality drinking water is an essential service that underpins the quality of life for every community in Colorado, and it is tied directly to the dedication of water professionals. From source water protection to advanced treatment and robust distribution, your work ensures high-quality water reaches every home and business. Take time during Drinking Water Week to celebrate your expertise and inspire greater public appreciation for drinking water.

The department created a commemorative bookmark for the observance week. The printable bookmark and other Drinking Water Week materials are available on our 2026 Drinking Water Week web page.

We encourage our partners to join in this effort. The department will post content on Facebook and Instagram throughout the week. By sharing our posts and promoting your own local successes, we can work together to ensure that every Coloradan understands the value of their water source and the crucial role you play in delivering a safe and reliable supply. For more information about Drinking Water Week, visit the American Water Works Association website.

➽ Lilie Waterman, Marketing and Communications Specialist

Colorado Water Loss Initiative: Training and Technical Assistance for Water Loss Control

Water loss is water that is lost in a municipal distribution system between treatment and consumption. There are two types of water loss that lead to lost revenue and resources for systems and customers, real loss (leaky pipes) and apparent loss (metering inaccuracies, data handling errors). Real water loss typically occurs before any water meters, which are often located as the water enters buildings. This means that a utility is paying for all the cost of transporting the water from source to treatment plus treatment and distribution costs, but getting no revenue in return. 

Globally, water losses from drinking water supply networks account for 9 billion gallons a day of water use. Cost effective water loss management reduces cost and increases revenue, which improves a systems bottom line and better serves its customers. The Colorado Water Loss Initiative (CWLI) is a program developed by the Colorado Water Conservation Board (CWCB) that provides training and technical assistance to water providers. In November 2023, the Colorado Water Conservation Board instituted an annual water loss reporting requirement for systems supplying at least 2,000 acre feet of water per year to their customers. The CWLI was established to provide a comprehensive training program for systems as part of the Colorado Water Plan strategic objective to support water management activities for all water providers and drive water loss implementation to address future water needs.  The benefit to you, a training course on how to identify water loss, collect water loss data, audit and validate data, along with technical assistance to develop solutions to decrease water loss in your system. 

CWLI Training Program

The CWLI offers a training program to assist systems in learning the AWWA Free Audit Software and implementing the American Water Works Association (AWWA) M36 methodology to quantify water loss. Once systems have completed the data collection, auditing, and validation phase of training, they are then provided technical assistance opportunities to implement controls and tools to minimize water loss. Technical assistance can include activities such as meter testing and design analysis or billing data analysis and prorating. Grant assistance is available to program participants to remedy prioritized water loss interventions that were identified through the program.  

Who can benefit from the training?

All drinking water systems. Do you have a small system and aren’t required to report annual losses but still interested in water loss? No problem, small systems can benefit from the water loss program and are encouraged to register. Water loss best management practices can help all systems save water, money, prepare for water supply shortages, and prepare for future climate impacts. All systems will learn to take the appropriate steps toward effective water loss control management. 

How much is it? And where do I register for the program?

The program and materials are offered at no cost and are available to all eligible drinking water staff. See the below resources to learn more about the program

• Video interviewing participants about their experience
• CWCB Water Talk Podcast - CWLI staff discusses the program
• Register here for the program

Interested in helping to improve water loss control and management? Join the CWLI Committee!

The Colorado Water Loss Control & Management Committee was formally established in December 2023 by the Colorado Water Conservation Board. The committee's objective is to improve water loss control and management by planning water loss strategies, trade technical information, inform water loss policy discussions, train and educate water utilities on water loss, and support water loss goals of the Colorado Water Conservation Board. You can find more information at the Colorado Water Loss Control & Management Committee  website.  

➽ Angela Green Garcia, Drinking Water Training Specialist

➽ Kevin Reidy, DNR, Senior Water Efficiency Specialist 

Mobile Home Park Drinking Water Regulations

In a recent AquaTalk article, the following quiz question was proposed for readers:

If a mobile home park does not have a well or treatment system, but bills customers for water, what regulations apply?

1. The plumbing code alone
2. The plumbing code and the new Mobile Home Park Water Quality Act
3. The plumbing code, the new Mobile Home Park Water Quality Act, DOLA’s Mobile Home Park Oversight program, and Regulation 11 within the distribution system.
4. None of the above are fully correct; it’s complicated!

It is complicated! All of the above (and more) may apply, but the answer is 4 because it depends on some important variables that must be evaluated on a case by case basis. Hopefully after reading this, the statutory and regulatory frameworks that apply to mobile home park water quality regulations will be more clear. 

DOLA’s Mobile Home Park Oversight Program

The Department of Local Affairs (DOLA), Division of Housing’s Mobile Home Park Oversight Program (MHPOP) implements the Mobile Home Park Act. The program also conducts outreach, education and maintains an annual mobile home park registration system. DOLA has all of the applicable laws, rules, and policies located on their MHP rules website.

What is a mobile home park? MHPOP’s definition of MHPs is on their website. To summarize, a "mobile home park" is a parcel of land that accommodates five or more mobile homes. And the park operates for the monetary benefit of the land owner. Homes must be "designed for long-term residential occupancy". This language clarifies the difference between mobile home parks and recreational vehicle (RV) parks. Refer to MHPOP’s definition to understand the nuances between housing communities. To add, if a mobile home park does not have 5 or more manufactured homes, it is not considered a mobile home park. 

Mobile Home Park Water Quality Act

The Colorado Department of Public Health and Environment’s Water Quality Control Division implements the Mobile Home Park Water Quality Act (Act). This Act applies to all mobile home parks that meet the MHPOP definition. This Act was signed into law by Governor Polis in June 2023. This law establishes a water quality testing program for mobile home parks. The following occurs under the law:

• Mobile home parks are prioritized for testing based on criteria in the law.
• Site-specific testing plans are created for each mobile home park.
• The department’s contractor, Terracon, completes water quality testing.
• The analysis is completed at certified laboratories.
• All test results are submitted to the department.
• The department has 10 days to notify the mobile home park owner of test results. The wholesaler also receives a copy of the notice.
• Test results are posted online in English and Spanish.
• Mobile home park owners must provide residents with a notice of test results within five days.
• If a water quality issue is identified, the department will typically require the mobile home park to complete additional testing. Remediation or temporary measures necessary to address acute health risks may be required.

The purpose of the Act is to conduct water quality testing at all mobile home parks over a four year period. The law considers resident concerns about water quality. The Act also requires the department to create an Action Plan. The Action Plan will provide an overview of findings and offer longer term recommendations to improve water quality in parks across Colorado. 

In February, we posted an informative AquaTalk article about the new Mobile Home Park Water Quality Act.

Colorado Primary Drinking Water Regulations - Regulation 11

The Colorado Department of Public Health and Environment’s Water Quality Control Division implements Regulation 11. This Regulation is applicable to public water systems (PWS). A PWS is defined as:

• A system that provides the public water for human consumption through pipes or other constructed conveyances; 
• Has at least fifteen service connections; and/or
• Regularly serves an average of at least 25 individuals daily at least 60 days per year; and
• Includes either a source or treatment, or receives all of its water from a public water system and sells water to its customers.

Some mobile home parks treat their own water source, but a majority of mobile home parks in the state are connected to existing public water systems. Parks that get water from a public water system and bill customers for water based on usage are selling water. Any water billing structure that fluctuates based on water usage is considered selling. This includes submetering and splitting a bill amongst users. If water charges are included in rent, the mobile home park is not considered selling. Any mobile home park with 25 or more residents or 15 service connections that sells water is a public water system and subject to Regulation 11.

If a mobile home park meets the definition of a public water system but receives all of its water from another public water system, it is still required to monitor water quality in the distribution system (disinfection, disinfection byproducts, lead and copper, total coliform bacteria). The mobile home park must also comply with operator certification and backflow prevention requirements, storage tank inspections/maintenance requirements, recordkeeping requirements, and perform public notifications. The Department also performs sanitary surveys on a 3-5 year frequency.

Water and Wastewater Facility Operators Certification Requirements - Regulation 100

The Colorado Department of Public Health and Environment’s Water Quality Control Division and the Water and Wastewater Facility Operators Certification Board implement Regulation 100. Regulation 100 is applicable to the mobile home parks that meet the PWS definition. Regulation 100 ensures that people who operate water and wastewater facilities are properly trained and certified. If a mobile home park receives all of its water from another public water system, it is still required to have a certified operator for its distribution system.

Plumbing Code

Another critical requirement is the plumbing code. The State Plumbing Board licenses, registers, and regulates plumbers, apprentices, and plumbing contractors. Information is available at The Department of Regulatory Agencies' plumbing website. The Colorado Plumbing Rules and Regulations are an adoption of the International Plumbing Code and International Residential Code 2021 edition. These regulations and plumbing codes are applicable to mobile home parks. The terms Manufactured Home and Manufactured Housing is used throughout the plumbing code to refer to mobile home parks.

Hypothetical Examples

What rules and regulations apply to a mobile home park that has 13 mobile homes, 28 residents, is connected to a public water system and bills customers for water based on usage?

• DOLA’s Mobile Home Park Oversight Program
• CDPHE’s Mobile Home Park Water Quality Act
• Regulation 11
• Regulation 100
• Plumbing Code

What rules and regulations apply to a mobile home park that has 50 mobile homes, 100 residents, is connected to a public water system and includes water in resident’s rent without fluctuation based on usage.

• DOLA’s Mobile Home Park Oversight Program
• CDPHE’s Mobile Home Park Water Quality Act
• Plumbing Code

The number of mobile homes in the mobile home park, number of residents or service connections, and billing structure are important variables when identifying applicable rules and regulations. 

➽ Ian Ferguson, Drinking Water Compliance Specialist

Asset Management - the Key to a System's Capacity

The Water Quality Control Division’s Local Assistance Unit is charged with assisting Colorado’s public water systems with building their capacity to provide safe drinking water to their communities now and into the future. Capacity can be defined  as the amount that something can hold or produce, whether it is applied to people, things or systems. In a public water system (PWS), capacity is an indicator of the overall health of a system. A PWS’s capacity is assessed using 3 criteria: Technical, Managerial, and Financial or T-M-F. Just 3 little letters, sounds simple, right?  

Don’t let the  simplicity of those letters fool you, they are powerful. The key to a successful and healthy water system is T-M-F capacity. Every part of a water system can be classified under one (or more) of these criteria areas. So, it makes sense that understanding your system's capacity is essential to running a successful water system. In fact, when applying for funding an in depth capacity assessment may be required, depending on the funding source.  Beyond funding however, it is a tool that helps you manage and assess your system’s needs both short and long term.  

How can you determine your system's capacity?  

CDPHE’s TMF capacity worksheet tool can assist you. This worksheet offers a condensed, quick-tool version of the more robust TMF assessment done when applying for funding. By completing each question you will generate an estimate of your capacity percentage for each criteria area TM & F.  Using this percentage you can determine which areas are in good shape and which areas require more focus. Good TMF capacity is often tied to good asset management.  Understanding your system as a whole is critical to short- and long-term planning. Assets are everything your system is composed of from the physical infrastructure, pipes, meters, tubing, valves, etc. to the people that work in your system. Asset management is a cumulative inventory of your system as a whole that allows you to critically assess each piece, its lifetime, cost, and to generate a prioritized needs assessment. There are a variety of tools available for developing your asset management plan:

• Asset inventory is a big part of asset management and the EPA’s Taking Stock of Your Water System: A Simple Asset Inventory for Very Small Drinking Water Systems is an easy to follow tool that will help you begin developing your asset inventory. 
• Asset Management: A Handbook for Small Water Systems offers a step by step guide to building a full asset management plan. A robust asset management plan facilitates high capacity and high capacity is directly tied to a systems success.  

Need assistance with asset management or capacity development?

The Colorado Department of Public Health (CDPHE) Water Quality Control Division (WQCD) has capacity coaching available for free through the Local Assistance Unit (LAU). A PWS can request assistance by filling out the Coaching Assistance Form. Please welcome the newest member of our capacity development team Angela Green Garcia. Angela will be focusing on asset management and financial readiness.  

➽ Angela Green Garcia - Drinking Water Training Specialist

Small Utility Boards, Operators, and the Public: Collaboration for Safe Drinking Water

In the Fall 2009 issue of Aqua Talk, the division ran an article on how collaboration amongst small utility boards, operators, and the public helps ensure communities are provided with clean, safe drinking water. We thought it would be a good time to revisit this information and highlight its importance. 

A water board’s primary responsibility is to provide consistently safe drinking water to its community. There are various elements the board must implement to ensure that happens. 

• The water board must retain a Certified Operator in Responsible Charge (ORC) that holds a certificate in a class equal to or higher than the class of the water system; 
• Foster a water system that is protective of its source water; 
• Employ treatment techniques appropriate to the quality of the raw water; 
• Prevent recontamination in storage takes and distribution lines; 
• Meet all regulatory monitoring and reporting requirements; 
• Provide consumers with water quality information; 
• Notify consumers of any health threats; and
• Obtain approval prior to the construction of new facilities.

Clear communication between the board, the ORC, and the state is a collaborative effort and is necessary to provide the community with clean, safe drinking water. Clear communication means establishing and maintaining well-defined duties and expectations, operation and maintenance manuals, standard operating procedures, well-organized records, and financial planning for future repairs, upgrades, and emergencies.  

A well-organized board of directors has established procedures for the recruitment, selection, and orientation of new members. The board should have a mission statement, bylaws, and personnel and procurement policies that are regularly updated. The board must protect its community by providing adequate liability insurance, financial procedures and oversight, and strategic planning. Boards should meet regularly, provide minutes of meetings, retain an organized file of copies of all system records, and continually monitor the performance of the water systems’ services and compliance records. 

Strategic planning is an approach that systematically shapes the future of a water system. It creates a framework for establishing goals, working towards those goals, and evaluating progress that can increase the water system’s efficiency and effectiveness. Strategic planning also helps ensure that the water system has the funds available to support ongoing repair and maintenance needs and to fund capital improvements, as necessary. The development of a strategic plan should be done in cooperation with the system’s operations staff, the board, and members of the community. Strategic plans are never “finished” and the board should make sure that it revisits its strategic plan at least annually.

A board should understand the basics of its water system’s facilities and equipment so it is able to make informed decisions and provide leadership that increases the system’s quality, efficiency, and sustainability. It is important to note that unless certified, board members should never attempt to operate the water system or make process control and/or system integrity decisions as those are reserved to the ORC. Only certified operators may perform operations, adjust the water system, or supervise the repair and replacement of system components. The board’s function is to ensure the water system has the required staff, equipment, guidance, and financial support. 

If you would like to receive water board training to help build your board's technical, managerial, and financial capacity please fill out a drinking water coach request form. 

Source: Water Board Basics for Small Water Systems in Colorado, Rural Community Assistance Corporation, and the Colorado Department of Public Health and Environment. 

➽ Jessica Morgan, Facility and Operator Outreach and Certification Board Liaison