Developing an Asset Management Program Asset management is a critical component to the short and long-term success of every water and wastewater utility regardless of size or system type. When a system understands the condition of its assets, in addition to present and future projected needs, the utility can make informed decisions about infrastructure operations, management, and investments. These decisions will minimize expenditures, equipment failures, and risk to public health while promoting reliability, resiliency, compliance, and customer satisfaction. Asset management moves utilities from reactive to proactive decision making and allows systems to get the most out of what they have. If your facility has never developed an asset management plan or it’s been quite some time since you’ve last revised your plan, we’ve highlighted our favorite resources to get you back on track. A well-developed plan includes asset inventories, operation and maintenance tasks, emergency response and contingency planning, comprehensive financial plans, succession planning, and an understanding of current and future service level goals. Without addressing the technical, managerial, and financial management of your system, your plan will be incomplete. So without further ado, here’s our favorite resources to help you improve your understanding of asset management and develop your own program. What is Asset Management? Successfully Protecting Your Investment in Drinking Water Infrastructure: Best Practices from Communities & Local Experts U.S. EPA and USDA This 12-page guide explains how asset management can improve system reliability, cost efficiency, and customer communication. Strategies for developing a plan and case studies that highlight solutions to asset management challenges are included in the document. Learn more: U.S. EPA Asset Management Resources for States and Small Drinking Water Systems AWWA Asset Management Definitions Guidebook American Water Works Association In this 33-page guidebook, systems can clarify common terminology used by asset management professionals and asset management program guides. Learn more: AWWA Asset Management A.M Kan Work! An Asset Management and Energy Efficiency Manual Southwest Environmental Finance Center A.M Kan Work Is a digital asset management manual that uses videos and texts to teach systems how to develop their own program based on their five core components of asset management. Learn more: SW EFC Asset Management Effective Utility Management: A Primer for Water and Wastewater Utilities Water Effective Utility Management (EUM) This 60-page guide identifies 10 key attributes of an effectively managed utility that should be considered in your asset management plan. The Primer teaches utilities to self-assess operations and make improvements. An interactive primer is available to assist in self-assessment. Learn more: Water EUM Resources Developing an Asset Management Plan Asset Management: A Handbook for Small Water Systems U.S. EPA This asset management STEP Guide Series will teach water systems how to inventory, prioritize assets, and develop long-term maintenance plans. Learn more: Asset Management Resources Check-Up Program for Small Systems (CUPSS) U.S. EPA CUPSS is a desktop application (Windows-only) based on the EPA’s STEP guide series that will help utilities record assets, schedule required tasks, assess their financial practices, and develop and asset management plan. Learn more: Building the Capacity of Drinking Water Systems Asset Management Guidance for Water Systems and Wastewater Utilities Michigan Department of Environment, Great Lakes, and Energy This Excel workbook can be filled out as utilities acquire data for their asset management program. The pre-made tables make it easy to know what information to record during the planning process. Learn more: EGLE Forms and Guidance Writing Your Plan Asset Management Program – Small Community Guidance Ohio Environmental Protection Agency The state of Ohio requires all public water systems to maintain a written asset management program. This 22-page guide describes what should be included in a small community asset management plan to increase technical, managerial, and financial capacity. The link below includes Ohio template plans for non-community systems and small systems. Learn more: Public Water Systems (PWS) – Asset Management A Guide to Asset Management for Small Water Systems Georgia Association of water Professionals This 19-page guide describes what to include in a strategic asset management plan and how to implement a program. Learn more: Georgia Association of Water Professionals Technical Resources Additional Help: Asset Assessment, Financial Planning, and Program Review Taking Stock of Your Water System U.S. EPA Use this 38-page guide to understand the elements of an asset inventory and perform a simple inventory using the worksheets provided. The document includes how to prioritize assets and integrate the inventory results into a budget and asset management plan. Learn more: U.S. EPA Asset Management Resources for States and Small Drinking Water Systems The Basics of Financial Management for Small-Community Utilities Rural Community Assistance Partnership This 44-page guidebook describes how to manage utility finances through cost planning, budgeting, record keeping, and financial oversight. Learn more: RCAC Guidebooks Effective Utility Management Benchmarking Tool The Water Research Foundation This download is designed to help systems evaluate their current management program based on the 10 key utility management attributes that were identified in the EUM Primer report listed above. Learn more: Water Research Foundation Asset Management Resources Asset Management IQ Southwest Environmental Finance Center Use this online tool to establish a baseline for your system’s current asset management practices. Return to the test over time to monitor and measure system progress. Learn more: Asset Management Developing a new plan can seem like an intimidating project, however utilities will ultimately improve their services and decision making capacity while saving time, resources, and money. If your system needs help developing or assessing a program, check out the EPA’s list of technical and financial assistance providers or contact WaterOperator.org to have help finding a provider. The EPA maintains a list of capacity development contacts that can answer any questions about specific requirements of your primacy agency. To find additional information on asset management, visit our resource library. You can use the category filter to narrow down your search by topics in asset management, financial management, utility management, and more. Our library can also be filtered by resource type such as manuals, videos, or templates. The other filter options can refine your results to a specific host organization or state. Check out our tutorial to use the library to the best of its capabilities. August 28, 2019 By Jill Wallitschek Asset Management, Capacity Development, Financial Management, Utility Management amp, asset management, asset management plan, asset management program, featured document 0 0 Comment Read More »
An EPA Guide for Climate Resiliency Planning Many utilities are developing plans to increase short-term and long-term climate resiliency in response to extreme weather events, changing water availability, or the risk and resiliency assessment requirements set forth in the America’s Water Infrastructure Act of 2018 (AWIA). To assist in the early developmental stages of resiliency planning, the EPA's CRWU program designed the Resilient Strategies Guide for Water Utilities. This online application prompts utilities with a series of questions about their system and its resiliency concerns to provide recommend strategies that will decrease vulnerability. This web application was updated in August 2019 to allow utilities to specify their system size and find funding sources for the projects they want to pursue. Both water and wastewater systems can use the tool. The foundation of the guide is built using the CRWU Adaptation Strategies for Climate Change and a funding list maintained by the Water Finance Clearinghouse. Completing the guide takes roughly 20 minutes. After answering a series of questions that identify your system type, size, location, assets, preferred resiliency strategies, and funding interests, the application will produce a report that can be used as a starting point to develop a more complex plan. Once the guide is launched, you will start by answering questions about your facility and its resiliency priorities. The priorities indicate the concerns that your system wants to address. You can filter the list of priorities in the left hand menu to narrow your focus to topics such as drought preparation, flood protection, energy efficiency, etc. The ‘More Info’ button will elaborate on any option you're considering. Once you’ve selected your priorities, you’ll indicate what assets are present within your system. From there you can select your preferred planning strategies that have been suggested based on your previous answers. Filter the strategies with the left hand menu to narrow down your options by cost or category. For example, if you want to exclude strategies that require new construction, you could check the ‘repair & retrofit’ category instead. The last section recommends potential funding sources that might assist with the strategies you've selected earlier. The strategies and funding sources will be used to generate the final report. Continue to the end and select ‘Generate Report’. This report will include a detailed summary of your answers, contact information for any funding sources you've selected, and case studies relevant to your utility. To save a copy of the report you will have to copy and paste the results into a Word document. If you have a CREAT account, you can select ‘Export CREAT File’ to download a file that can be imported into your CREAT account’s existing analysis. CREAT (Climate Resilience Evaluation and Awareness Tool) is a more in-depth risk assessment and planning tool that can be used once you've done your initial research. You can preview the CREAT tool framework with their guide here. August 23, 2019 By Jill Wallitschek Emergency Response, Funding, Internet, Sustainability featured document, resiliency, resiliency planning, risk assessment, vulnerability 0 0 Comment Read More »
Developing & Implementing a Cost Effective Water Utility Safety Program Even with advances in smart water technology, any supervisor knows that a utility can't run without its dedicated staff. While workers take care of equipment operations, maintenance, billing, or customer service, it's the responsibility of the person in charge to ensure these duties are being carried out in a safe environment using appropriate precautions. Water and wastewater utilities have a history of experiencing occupational injuries, illnesses, and fatalities (IIF) at a higher rate than most other occupations. The Bureau of Labor Statistic’s Incidence Rates - Detailed Industry Level table from each year’s Industry Injury and Illness Data Summary Tables has generally supported this trend. Their reports show the average non-fatal incident rate for the water and sewage industry has historically been higher than the industry average as a whole. The data from this table was taken from the Bureau of Labor Statistics Incidence Rates- Detailed Industry Level for 2008 and 2017. (Click table to enlarge.) The table above shows the rate of non-fatal injuries reported by the Bureau of Labor Statistics in 2008 and 2017. While any year can have variability, in 2008 the non-fatal injury incident rate was much higher than the industry average. In 2017 you can see that the average number of injuries has decreased since 2008 and is now closer to the industry average. These values don’t include the number of fatal injuries experienced by the water and wastewater industry, but as an overall trend, non-fatal injury reports to the Bureau of Labor Statistics support that the water industry has improved since the early and late 2000’s. Types of Injuries As utilities continue to prioritize and promote a safe work culture, we hope to reduce the frequency of incidents even further. There are many hazards that pose a risk to operator safety. The most frequent non-fatal water and wastewater injuries reported by the Bureau of Labor Statistics in 2017 were due to over exertion during lifting, being struck by a tool or object, and falls, slips, and trips. Water and wastewater utilities also have to manage the risks posed by confined spaces, electrical equipment, trenching, road safety, ladders, hazardous chemicals, blood borne pathogens, and more. Safety Costs According to Bureau Veritas’ presentation at the 2008 CSWEA Maintenance and Safety Seminar, the financial costs for water and wastewater injuries can be quite expensive. Budgeting for a good safety program will protect your employees and incur less expenses than the direct and indirect costs that result from a poor safety program. Developing and Implementing a Safety Program Since every system faces different hazards, your safety plan should be specific to your system hazards. To get started, the Occupational Safety and Health Administration (OSHA) recommends seven core elements for your system’s safety program: management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, program evaluation and improvement, and communication and coordination for host employers, contractors, and staffing agencies. OSHA’s Recommended Practices for Safety and Health Programs website provides an explanation of these elements in addition to a list of helpful tools, case studies, additional resources, and a download for the recommended practices guide. We also encourage you to check out the Water Research Foundation’s Water Utility Safety and Health report to review safety program best practices and cost evaluations for various proactive and reactive programs. Once you’ve done your research, West Virginia Rural Association has developed an Injury and Illness Prevention Program template that systems can expand from. Water System Specific Hazards As you continue to promote safety in the work place remember that complacency is the adversary to injury and accident prevention. More specific guidelines for electrical safety, traffic control, hazardous material communication, competent persons, confined space, chemical handling, chlorine exposure, fires, and waterborne disease can be found in Chapter 8 of the Alaska Department of Environmental Conservation’s Intro to Small Water Systems Correspondence Course. The OSHAcademy also offers a variety of water and wastewater specific safety training. If you have a different safety question, more resources are available at WaterOperator.org’s document library or under our blog post category Operator Safety. August 16, 2019 By Jill Wallitschek Operator Safety injuries, featured document, finances, osha, safety 0 0 Comment Read More »
Nocardia Foam in Activated Sludge Systems Nocardioforms are filamentous, Gram positive actinomycete bacteria that can cause persistent and excessive foaming in activated sludge plants during the summertime. There are nine main genus of nocardioforms. Two of these genera are involved in activated sludge foaming, Rhodococcus and Nocardia with the latter being the better known troublemaker. How to best control Nocardia foam is a highly debated topic. Nocardioforms are known for their branch-like hyphae that extend from the cell wall similar to the hyphae found in fungi. These branches link together with other filaments and floc. Simple and complex organic material make up their diet which includes fats, oils, and grease (FOG). Nocardioforms are slow growing and utilize the aerobic conditions established by an aeration tank. These actinomycetes generally have difficulty out-competing other wastewater microorganisms, but once established they're a handful to remove. Present in lower concentrations, Nocardia help to stabilize floc structure. The bacteria can rapidly breakdown biochemical oxygen demand (BOD) which can be beneficial to high strength wastewater. In higher concentrations, Nocardia can rip the floc apart and swiftly breakdown BOD starving out floc forming bacteria. The dense, brown foam that accompanies an outbreak forms when filaments float to the surface as a result of their low-density fatty acid membrane and the waxy, hydrophobic biosurfactant that coats their bodies. Bubbles from the aeration system can also help the filaments to float. Unlike Microthrix, nocardioforms are not often associated with sludge bulking. Unfortunately, the conditions required for a nocardioform outbreak are still debated. In general, any change in temperature, pH, dissolved oxygen (DO), solids concentration, or nutrients might spur an outbreak. It’s believed that nocardioforms will be most favored under warm temperatures with a high concentration of FOG, low food to mass (F/M) ratio, and/or a high mean cell residence time (MCRT). Since nocardioforms grow slowly, they need ample time to proliferate, and under low F/M their larger surface area helps to secure nutrients easily. Some people theorize that anaerobic conditions in parts of the aeration tank or surfactants can encourage Nocardia growth as well. Before deciding on a treatment solution, it helps to confirm that you are dealing with nocardioforms and not some other filament. Just because your foam is brown, doesn’t ensure that Nocardia is the culprit. Toni Glymph has developed a manual that describes how to identify filaments under the microscope. Nocardia is both Gram positive and Neisser positive, but after reading his guide you’ll find that only a Gram stain is really required for identification. Treatment solutions for nocardioform foam are also highly debated. Using a high volume water spray will temporarily break down the foam, but be prepared for its return. A better solution is to skim off excess foam so the bacteria is not recycled back into the system. Chlorination is not highly recommended. The branching Nocardia filaments prevent sufficient disinfectant contact while healthy floc bacteria are killed. Many companies promote defoaming products, but the interlocking filaments are often too stable for these chemicals as well. Most resources recommend reducing your MCRT to under 8 days while increasing (F/M). Wastewater technician, Jeff Crowther, lists three of his own treatment recommendations on page 10 of the H2Oregon Springs 2016 Newsletter. Solids wasting may be the most common control method. Operators should learn about the life cycle of Nocardia to maintain a system that avoids future foaming incidents. August 9, 2019 By Jill Wallitschek Operations and Maintenance, Wastewater foaming, nocardioform, activated sludge, foam, nocardia 0 0 Comment Read More »
Featured Video: Replacing the Power Cord on a Sewage Pump Submersible sewage pumps can be used for a variety of applications spanning the needs of residential homes to wastewater treatment plants depending on their size and design. A submersible pump is made up of a submerged motor filled with air or oil. Various impellers designs determine what sized solids the pump can handle. In this week’s featured video, Chris with R.C. Worst & Co. demonstrates how to replace the power cord on a submersible sewage pump. This particular pump is designed for septic tanks and the sewage handling of commercial and residential applications. While working on the pump, he offers some tips and tricks that can help you to save money during repairs and prevent additional damage. As a bonus he discovers some unexpected factory damage and demonstrates how to repair broken wiring. If you need to fix a pump from your own system, remember that this sort of repair work should only be made by operators with the appropriate training. You can find hands-on pump training in your area by visiting our operator event calendar. August 2, 2019 By Jill Wallitschek Onsite, Small System O&M, Wastewater pump repair, pumps, septic systems, sewage pumps, submersible pumps 0 0 Comment Read More »
A Veteran’s Guide to Becoming a Water or Wastewater Operator The career path of a water or wastewater operator is a great fit for veterans that want to continue serving the public with the skills developed during their time on active-duty. The profession requires mechanical, hands-on problem solving abilities and in turn offers job security, good pay, benefits, and professional development opportunities. Utilities can mutually benefit by recruiting veterans. Talent gaps created by retiring operators can be filled by veterans returning home from active duty. Their military training ensures that they have the dedication, flexibility, accountability, and communication skills necessary to juggle small system needs. Furthermore, veterans are familiar with working nontraditional hours that are sometimes required to maintain smaller water systems. Given the compatibility between veterans and the water industry, this blog will provide resources and guidelines veterans can use to become a water or wastewater operator. Obtaining certification will be easiest if military personnel can start developing the necessary qualifications before leaving the military. Operators need to have a broad knowledge of chemistry, microbiology, math, equipment operations, and mechanics. Try to work in water operations or other positions that develops transferable skills during active duty. Request that these experiences be documented by your superiors. Saved military evaluations can also be useful to demonstrate qualifications. Once you’ve left the military, research the certification requirements under your state. Each state’s certification requirements can vary, however many programs will convert military training into college credits or certification requirements. In the state of Virginia, “substantially equivalent” military training, education, or experience can be credited toward licensure requirements. Virginia also waives the costs for the certification exam. If you haven’t met all the requirements necessary to sit for the certification exam, use our national training calendar to find relevant certification courses and local training providers. Veterans that are just beginning to fulfill certification requirements should consider joining a certificate program within their state. Certificate programs consist of a series of classes that take anywhere from 6 months to 2 years for completion. At the end of the program students will be prepared and qualified to take the state certification exam. The best programs facilitate hands-on training at a local utility, however these experiences can also be gained in an apprenticeship. To find an apprentice program, reach out to local water utilities, assistance providers, and the National Rural Water Association’s nation-wide apprentice program. Working at a water utility early on will ease the job hunting process after passing the exam. For additional assistance, contact the AWWA’s veteran program. Scholarships, internships, and career advice in the water workforce can be found at Work for Water. Residents of New England states, can look into the Water Warriors Initiative to find assistance in certification, training, and internships. If you need help finding additional resources for your state’s certification program, contact WaterOperator.org and we’ll point you in the right direction. July 26, 2019 By Jill Wallitschek Certification, Workforce workforce development, apprenticeships, certification, veterans, workforce 0 0 Comment Read More »
Featured Video: Water Tower Collapse Compilation Online trends can seem bizarre, but browsing the web is worth the effort when you stumble upon videos likes these. If you’ve ever searched for distribution maintenance videos on YouTube, you may have already encountered water tower tipping videos. Some of them have reached millions of viewers. Once you watch a few for yourself, you’ll realize why. There are many reasons a water system might want to remove an existing water tower. Older towers have a higher probability of failing an inspection or causing safety issues to the community. When that happens, it may be easier to just remove the tower provided it’s no longer necessary for the system. If a system has already connected to a newer tower, the costs to maintain redundant towers may drive the incentive for removal. Other times, communities might remove a tower due to damage incurred from a natural disaster or because they want to open the property for other uses. Only a very small number of tanks are tipped over like the ones in this week’s featured video. Collapsing a tower is a dangerous job only performed in wide open areas with experienced professionals. Generally most tanks are dismantled with a crane instead. Before removal the site may undergo an environmental review. Then if the tower is still in use, it will have to be disconnected from the current water and power supply. After putting out a bid and selecting a contractor, the system will coordinate the rest of the planning with them. Crane dismantling involves cutting the tower into pieces with a torch and lowering those pieces down with a crane. Often times any leftover steel can be sold to a local scrap yard. So even though tipping a tower is much less common, please enjoy this week’s featured video. It’s hard to look away once you start! July 19, 2019 By Jill Wallitschek Distribution demolition, distribution, tanks, towers, water tank, water tower 0 0 Comment Read More »
Preventing a Bloodworm Invasion Midge fly infestations can pose considerable challenges for activated sludge systems and lagoons. Also known as Chironomids or bloodworms in their larvae stage, these insects resemble mosquitos without the blood sucking proboscis. Adult males can be distinguished from females based on their feather like antennae. After dormancy in the winter, midge flies emerge in the summer ready to lay between 100 and 3,000 eggs per female. Though midge flies do not suck blood like mosquitos, they disrupt communities in other ways. Swarms annoy both local residents and operators by flying into unsuspecting mouths and flooding outdoor lighting. A study by Selden et al. (2013) found that wastewater operators can develop allergic reactions from midge fly exposure. Chironomids can also cause quite a startle to the public when bright red larvae make their way into drinking water systems. When it comes to maintaining treatment systems, wastewater operators may be most concerned with the larvae stage of midge flies. Their sticky red bodies cling to suspended solids encasing them in a cocoon of decaying organic matter. Under the protection of these cocoons, they can consume considerable amounts of sludge, bacteria flocc, and nitrifying bacteria. An infestation will cause sludge clumping, rising solids, or foaming issues. In one small town a bloodworm invasion wreaked havoc on an activated sludge plant over a single weekend. The wastewater operator found sticky clumps of eggs had congested the system’s pumps while larvae had eaten away at his mixed liquor suspended solids (MLSS). Facultative lagoons and secondary clarifiers are a favored breeding ground for these pests. Midge flies prefer to lay their eggs in still, high-nutrient water with fixed media, floating scum, or algae. Once the eggs hatch, larvae will likely sink to the bottom to feed on organic matter and sludge. The hemoglobin that gives bloodworms their red color also allows them to live in low dissolved oxygen (DO) conditions. To avoid bloodworm infestations, operators should focus on encouraging circulation and limiting food sources. Systems can start midge fly control with mixing, limiting surface scum and algae, installing bug zappers, attracting bats and swallows, or turning off lights at night. Introducing a predatory fish can also help. Lagoon operators can encourage circulation by cutting back overgrown vegetation. Any dead spots in circulation should be addressed. When these methods don’t work, some systems will use larvicides and chemical agents as a last resort. Operators should check that the control methods they’ve selected are approved by their local regulatory authorities before use. When summer starts make sure your treatment system is kept clean and free of obstructions to circulation. With good preventative maintenance, you can spare yourself the nightmares of a bloodworm invasion. July 12, 2019 By Jill Wallitschek Wastewater activated sludge, blood worms, chironomids, lagoons, midge flies, red worms 0 0 Comment Read More »
Featured Video: Tech Review: Liquid Flow Velocity Knowledge of flow velocity, volumetric flow rate, and pipe diameter can assist operators in selecting, installing, and troubleshooting flow meters. This week’s featured video will guide operators in the math used to calculate flow velocity using volumetric flow and or pipe diameter. Brent Baird with Instruments Direct demonstrates three techniques that will estimate flow velocity. The old school method utilizes a flow calculator slider ruler. With Brent’s particular ruler, by sliding to the known value for the inside pipe diameter (ID) in inches, the velocity in feet per second (FPS) can be read above the known value for volumetric flow in millions of gallons per day (MGD). Alternatively, the inside pipe diameter can be estimated by lining up the known values for velocity and volumetric flow and then looking at the value indicated under pipe diameter. Brent demonstrates that a cross reference chart performs the same calculations using a different visual. Both of these tools are based off the equation GPM=2.45*ID2*FPS. If neither of his reference tools are available, plugging in the known FPS value for velocity and the inside pipe diameter in inches will calculate the volumetric flow rate. By rearranging the equation to solve for FPS, the flow velocity can be calculated using FPS=GPM/(2.45*ID2). Remember to follow PEMDAS. To calculate the internal pipe diameter with known values for FPS and GPM, rearrange the equation to solve for pipe diameter: ID= √(GPM/FPS/2.45). If the value for the internal pipe diameter is unknown, Brent demonstrates how an ANSI chart can be used to find that value. With the video's final explanation of basic flow meter requirements, these calculations can be used to spot and avoid problem areas for flow metering in your distribution system. July 5, 2019 By Jill Wallitschek Certification, Distribution, Operator Math flow, flow meters, math, pipe diameter, velocity 0 0 Comment Read More »
Guidelines for Public Water Systems in Submitting Public Comments on Regulatory Proposals Submitting comments on proposed regulations can help the Environmental Protection Agency (EPA) to establish inclusive rules that consider the perspective of your public water system. Just one effectively written and well supported comment can create a much bigger impact than hundreds of poorly written arguments. Your best opportunity to submit a comment for a drinking water or wastewater regulation is offered after the Agency releases a Notice of Proposed Rulemaking (NPRM) to the Federal Register. A copy of the proposed rule and supporting documents will be available on the EPA’s electronic public docket system, Regulations.gov, where the public can also submit comment. To comment on a rule with Regulations.gov you should know the Docket number, title of the regulation, or some title keywords. Once you search for the regulation, select ‘comment now’ or ‘Open Docket Folder’ under the correct rule. The docket folder includes information about the proposed regulation, its supporting documents, and other public comments. An effective comment will be written concisely with clear, professional language and sound reasoning. You will want to provide examples that support your stance citing data driven evidence, publications, case studies, or technical resources when possible. Explain the impact of the proposed regulation from the perspective of your water industry experience. If the impact includes a cost analysis, make sure to include how those costs were calculated. A well written argument for or against the regulation will consider both sides of story. When you oppose a particular regulatory action, suggest potential alternatives. Comments that address particular wording or actions within the regulation should cite their exact page number, column, and paragraph from the register document. When submitting the comment, you can choose to attach supporting files, however be sure to read through the restrictions associated with attachments. Finally, remember that anyone can view your comment. Once the public comment period has ended, your decisive utility perspective will inform the revision considerations to the final rule. June 28, 2019 By Jill Wallitschek Regulations public comment, regulations, rules 0 0 Comment Read More »