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WaterOperator.org Blog

Tools to Help Utilities Get the Word Out Fast

Last week, we talked about the role public advisories can be used to garner community buy-in and create more informed rate payers. Planning and adopting a comprehensive advisory framework, though, takes time—something most small utilities just don’t have to spare.

With that reality in mind, we wanted to let you know about a few public notification services available on the market. A quick disclaimer first—we at WaterOperator.org aren’t endorsing these or any other company, and we recommend you do research on your own to find the system that best fits your needs. Whether you contact one of these companies, another, or none at all, it’s worth the time to find out how a system like this might benefit your community. Also, please remember to check with your primacy agency as to whether your chosen (lowercase) public notification option may or may not be used for compliance with the requirements of the (uppercase) Public Notification regulation, or simply as a trust-promoting public service.

Swiftreach Networks

Using the SwiftH2O™ internet-based platform, utilities easily create and send thousands of voice, text, fax and email messages within minutes to any number of individuals on any device. These notifications are directly targeted to affected customers and tracked, allowing you to track who received and listened to your messages.

RapdiNotify

This international company’s web-based mass notification system allows you to notify your staff, rate payers, and other contacts via phone, email, and text messages. The product includes a self-registration widget for your website, as well as GIS mapping to help you target mass communication inside specific, user-defined geographic areas.

WARN

WARN offers multiple notification platforms built with small communities in mind. 

If paid services aren’t right for your utility, remember that social media platforms like Facebook and Twitter have extremely broad reaches—with the added perk of allowing rate payers to respond. Whether your system is a social media beginner or veteran, the free resources below are worth checking out.

Communications, Customer Service, Social Networking

This 10-slide presentation breaks social media sites into basic kinds (conversational, one-way, interactive, etc.), and briefly discusses how many people use many of the most popular sites, basic uses of some social media outlets, and customer service on social media. 

Social Networking: The Old and the New, Interaction and Communication Between Communities and Their Customers and Operator to Operator Connectivity

This 23-slide presentation discusses social networking and social media. It discusses the importance, possible uses, and approach to using social media, particularly Facebook, for communication and outreach, and includes several screenshots of national water organization's Facebook pages. 

You can also contact us directly at info@wateroperator.org or join our Small Communities #TalkAboutWater LinkedIn group to get advice on how to tap into the power of social media. 

Public Advisories: They're Not Just for Emergencies

In the wake of Flint and similar events, questions about the effectiveness of public notification requirements are on the minds of many. In fact, the U.S. House of Representatives earlier this year voted 416-2 in support of a bill that would strengthen notification requirements related to lead levels. With concerns and emotions high, it can be difficult to remember that the best public notification procedures are about much more than emergency response and compliance.

In their Drinking Water Advisory Communication Toolbox, the Centers for Disease Control encourages drinking water systems to use advisories to

  • Provide information—An advisory may be issued when consumers need to receive important information by do not need to take any action. For example, a water system may issue and advisory to inform households about seasonal changes in water taste.
  • Encourage preparedness—Advisories may help customers prepare for a planned disruption in service or anticipated water quality threats. Advisories may affect a small area, such as during distribution system construction or repair. Advisories also can urge customers to prepare for a large area event, such as an approaching hurricane. This type of advisory alerts people to water or listen for more information.
  • Recommend action—Advisories may tell customers to take specific actions, such as to boil water or use bottled water. These advisories may be issued as a precaution or in response to a waterborne disease outbreak.
  • Meet public notification requirements—Advisories are required by the Safe Drinking Water Act (SDWA) when specific circumstances exist. The SDWA requires communication with customers when the water system does not comply with a regulation.  

Water operators and communities are undoubtedly quite familiar with the reasons and requirements for the final two uses. But the value of the others may not be as apparent.

In addition to be being good business practices, issuing informative and preparedness advisories can actually help utilities garner community buy-in and help rate payers understand the time, hard work, and other resources that go into delivering clean, safe water. If all customers hear is bad news, they won’t be eager to support the local public system. Notifying people when water main repairs may close roads or when drilling a new well will provide the community with a new resources can change public perception of a utility and its staff.

The CDC toolbox is a great resource for small systems looking to improve their public notification procedures, but operators with lingering questions can visit our Documents Database or contact us directly at info@wateroperator.org. And be sure to check back here for a follow-up post on media platforms and available services that can help get the word out. 

ILWARN Offers Emergency Assistance for Small Systems

A lot of challenges can impact a small utility. Anything from a tornado to multiple water main breaks on the same day to half the staff out with the flu can have a huge effect on a utility’s ability to function. While small local agreements are often a great first step to ensuring your bases are covered in the event of an emergency, statewide programs like ILWARN can be a great supplement to your emergency planning.

Small Utility Support

ILWARN is working to get the word out that the mutual aid assistance services they offer can be just as useful to small systems as they are to large ones. Their small systems flyer provides lots of introductory information, FAQs, and mythbusting on their resources and membership requirements. It’s worth noting here that there is no registration fee to join ILWARN, there are no size restriction, that members will be reimbursed for their assistance, and that no member is required to offer assistance. Pre-existing local agreements are not affected by ILWARN membership. Utilities wanting a more detailed idea of how ILWARN membership works might also want to check out the Operational Plan, which has resource sections for before, during, and after an emergency. 

A Helping Hand in the Signup Process

If you’re convinced ILWARN is a solid resource for your utility, there are more resources to help you get started. ILWARN has provided step-by-step guides to completing your registration with their website, requesting and offering assistance through the website, and requesting and offering assistance when the internet isn’t available or an emergency occurs after hours. And of course, you need to sign the mutual aid agreement and turn it in before you can participate in ILWARN assistance requests. 

Small utilities face lots of challenges, but you don’t have to face them alone. Statewide mutual aid agreements help get as many people as possible in your corner when the chips are down. If your utility isn’t in Illinois but you’re interested in WARNs in your area, you can learn more about the WARN regions here.

Better ERPs Part 4: Is Your System All-Hazard Ready?

Last year saw record-breaking heat, severe storms, and worsening drought conditions across the country. And current NOAA predictions suggests the first half of 2016 won’t be much different as El Nino continues to have widespread effects. If these events have left you asking, “What would I do if something like that happened in my community,” you’re not alone. 

In part four of our series on improving emergency response plans, we want to help you find an answer. The tips and resources below will walk you through the process of developing an all-hazards response plan and provide specific guidance for some of the most common hazards.

  1. Understand your vulnerability to extreme weather. The Federal Emergency Management Agency is a great resource here. Their Ready.gov website has information on when and where extreme events are most likely to take place.
  2. Identify vulnerable assets. Are key equipment located in the floodplain? Are your circuitry and control panels secured for high winds?
  3. Identify possible mitigation measures would protect vulnerable assets and priority operations. Putting in place a procedure to top off water in storage tanks prior to a hurricane or bolting down chemical tanks in advance of a flood are just a few examples.
  4. Determine which mitigation measures should be implemented. Keep in mind costs, effectiveness, and practicality when making this decision.
  5. Identify actions that will need to be taken immediately before and after an event. For example, sandbagging treatment sheds or turning off water meters at destroyed homes and buildings.
  6. Write a plan to implement mitigation and rapid-response measures. This should be revised periodically and integrated into your utility's overall asset management process.
  7. Be prepared to act. Include rapid-response measures in your employee training programs and keep staff and other stakeholders up-to-date on any changes.

For more planning tips and information on common hazards, check out these resources and visit our documents database. You can also learn more about drought preparedness in part two of this series.

Water/Wastewater All-Hazards Boot Camp Training
This training course is designed for water and wastewater employees responsible for emergency response and recovery activities. It also explains why and how to implement an all-hazards program. The program walks you through a scenario with Our Town Utility staff, lets you hear from water sector representatives, and tests your knowledge on prevention and mitigation, preparedness, response, and recovery.

Water, Sanitation, & Hygiene (WASH)-Related Emergencies & Outbreaks
This CDC portal offers a comprehensive set of tools and resources for not only responding to a crisis but also preparing for the worst. Preparedness resources include preparedness toolkits, preparedness training, and directions for emergency disinfection of water.

Climate Ready Water Utility: Adaptation Strategies Guide & Planning for Extreme Weather Events
This webinar presentation highlights the Workshop Planner and the Adaptation Strategies Guide, and how a utility can use them both when developing adaptation plans. It also highlights utility experiences with the tools.

Flood Resilience: A Basic Guide for Water and Wastewater Utilities
With a user-friendly layout, embedded videos, and flood maps to guide you, EPA's Flood Resilience Guide is your one-stop resource to know your flooding threat and identify practical mitigation options to protect your critical assets.

Incident Action Checklist – Tornado
Use this comprehensive list from U.S. EPA to prepare for, respond to, and recover from a tornado.

Emergency Response for Drinking and Wastewater Utilities
This EPA portal has a variety of tools, including mobile-friendly websites, to support utility preparedness and response.

Better ERPs Part 3: Are You Prepared for a Drought?

For those of us outside the arid West, it can be easy to push aside droughts and their impacts as something others have to worry about. But a look at the U.S. Drought Monitor quickly reveals that droughts—even long-term ones—are a concern coast-to-coast. In fact, increasing temperatures and changes in rainfall patterns are exposing more and more communities to the risk of droughts and other extreme weather events.

Incorporating a drought contingency plan into your broader emergency response plan is one of the best ways to ensure your public water system is prepared for water shortages and other drought impacts. And there are a number of resources available to help you do just that.

The templates and guides below can help you design a plan that meets your system and community needs. Whether you use one of these or create your own, keep in mind these seven steps to an effective drought management plan. These were developed by the Rural Community Assistance Corporation based on the model used by the Texas Commission on Environmental Quality.

  1. Seek public involvement by forming a committee of stakeholders who encourage and support a public "buy-in.
  2. Define goals and objectives, such as targets for reduced consumption, identifying which customers can and should be restricted and which cannot, legal requirements, minimum flow requirements, etc.
  3. Assess supply and demand—identify all existing and potential water supply sources and balance these against average and peak demand, historic demand trends, use by customer sector, interior vs. exterior use, and projected future demand.
  4. Define a system-specific drought index, such as ground and/or surface water storage, stream flows, soil moisture, rainfall deficit, well drawdown levels, and other indices.
  5. Identify potential mitigation measures, such as water audits, alternative supplies, leak detection and repair, public education, restrictions/bans on non-essential use, pricing disincentives (surcharges), and, finally, rationing.
  6. Assess potential impacts of mitigation measures, such as reduced revenues, customer acceptance, rate equity, legal implications, history, and implementation costs.
  7. Develop and implement the plan using the management strategies, templates, and statistics assembled during the assessment process.
If you don't see something that fits your system's needs below, search "drought" in our documents database to find more resources. You can also find information on water conservation, energy efficiency, and renewable energy for small utilities in Sustainable Infrastructure for Small System Public Services: A Planning and Resource Guide. And be sure to read the Part 2 of this four-part series for help building a comprehensive emergency response plan.

Drought Contingency Plan for a Public Water System (Example): ABC Water Company Drought Contingency Plan
This 11-page document provides an example of how to fill out the model drought contingency plan for retail public water suppliers.

Drought Management Toolkit for Public Water Suppliers
This 49-page handbook was developed by the Utah Division of Water Resources to help public water suppliers better prepare for and manage future droughts. This toolkit consists of two main elements: a model drought mitigation plan and a model drought response plan (or contingency plan, which can also be used to address other water shortages).

Drought Contingency Plan: Public Water System
This 36-page template can be used for a drought contingency plan for a tribal public water system. The template covers a broad list of sections and topics with the aim of being applicable for a majority of the water systems. Because tribal water systems vary, it is recommended that the tribe edit and modify the template to best fit their specific situation and context, and only include those sections that are necessary.

Better ERPs Part 2: Templates

So you've held a water emergency roundtable discussion and are ready to put pen to paper, so to speak. Fortunately, you don't have to start with a blank piece of paper. There is a suite of resources available for utilities—and small water suppliers particularly—to help you prepare for the unknown and plan for the rare events.

The free templates provided here will help you get started. If you don't see something that fits your system's needs, search "emergency response plan templates" in our documents database to find more resources.

Emergency Response Planning Template for Public Drinking Water Systems

This 22-page document developed by the Rural Community Assistance Partnership is intended for use by any water system serving a population of 3,300 or fewer and can be modified to fit specific system needs. The template is intended to be used as a starting point based on what is relevant for the type, size, and complexity of the system.

Rural & Small Water and Wastewater System Emergency Response Plan Template

This 47-page template is designed to be a guide for Emergency Response Planning. Emergency response planning should be a coordinated and planned process. Proper planning can lessen the impact of an emergency. All staff should be trained as to their responsibility within the plan and how it will be implemented. This template was designed to address various emergency hazards that may occur in rural and small systems. It incorporates emergencies that may be the result of terrorism. Regardless of the type of emergency whether natural or man-made each system has the responsibility to be prepared to protect the public health and to restore services that may be impacted.

Disaster-Specific Preparedness/Response Plan for Public Drinking Water Systems - XYZ Water System Template

This 69-page template has been developed to help you prepare your Emergency Response Plan. The ERP Guide (see separate document, here) and Template is intended for use by any water system and may be modified to fit the specific needs of each system. The ERP guide follows the outline in the template—section by section

Emergency Response Plan Template
This 26-page form is an outline of an emergency response plan for water operators to fill out and complete. This document is in pdf form, but the fillable Word format of this document can be found here.

Emergency Response Plan of Action
This 40-page template is used to create an emergency response plan for a public water system. There are many situations that may cause impairment of water quality or disruption of service. In Maine, the most common is loss of water pressure or contamination of the water supply, source, or lines. Some common examples include main breaks, power outage, treatment failure, numerous types of contamination, extreme weather and or structural damage, floods, and equipment failure. This template goes over each topic to create the most efficient ERP. 

Better ERPs Part 1: Hosting a Roundtable Discussion

Creating a strong emergency plan is often easier said than done—and the middle of an emergency is the worst time to discover you’ve forgotten something. This is the first of a four-part series with guides and tips to help you build a comprehensive emergency response plan. 

Before you start drafting, though, consider hosting a water emergency roundtable discussion. These events provide a unique opportunity to connect water security with broader preparedness and community resiliency efforts underway in your region. Here’s a quick glance at what you can do to host a successful discussion: 

  1. Consult with partners within your water community to identify the groups that need to be at the table. Some groups to consider include hospitals, schools, farm operations, industrial parks, municipal pools, and first responders.
  2. Set a date and secure a meeting place that meets your meeting needs.
  3. Work with partners or co-hosts to ensure that the room has the equipment needed, such as a laptop, PowerPoint projector, and pens and pads for meeting participants.
  4. Have your water utility manager or superintendent call the groups to invite them to the event. A personal call typically results in a more positive response and can be followed by a formal invite and RSVP request.
  5. Call confirmed participants to outline what types of information participants will need to bring with them, how the discussion will be facilitated, and how sensitive information will be treated.
  6. Confirm with partners or co-hosts who will be responsible for facilitating the discussion, compiling participant data, putting together registration packets, welcoming participants, presenting, taking notes, and writing a meeting summary.
  7. Arrive at least on hour before the event is scheduled to set up materials and manage last minute details.
  8. Use meeting notes and discussed action items to develop a short report for participants.
  9. Write and distribute an internal and external report on progress towards action items approximately six months after the event.
  10. Determine the need for a follow-up meeting.

For more tips and sample invitation scripts, read the Water Emergency Roundtable—Outline for Discussion developed by the Association of State Drinking Water Administrators and EPA Region 5. And check back for part two of our series for free templates you can use when you're ready to write your emergency response plan. 

Do You Rely on Your SCADA System Too Much?

*Originally posted on SmallWaterSupply.org July 9, 2012 by Steve Wilson. 

I was at an asset management workshop recently that included a number of state regulators. The theme was asset management and certification, but O & M and the tie-in to understanding your assets kept coming up.

O & M Is Tied To Asset Management
I realize the title of this blog post is about SCADA systems, and many small communities don't even have them, but whether you use SCADA or not, the principles behind good O & M are important for all systems. It's all about understanding your system, the equipment, infrastructure, and treatment, as well as the process of running the plant (O & M). I know everyone hears about the importance of testing generators monthly and servicing pumps when recommended, but many times these things are low priority. Weeks turn into months and months turn into years. I was at a plant this summer that was using a federal grant to get a new generator for their water plant. I had just been in the wastewater plant for this same community this last fall where there was a perfectly good generator that would serve the purpose. I brought this up to the consultant managing the grant, but he said it wouldn't work. Unfortunately, the community had no warranty on the generator because they didn't follow the maintenance schedule. It had sat in a garage for number of years and not been ran. As a taxpayer, that's frustrating, but as a small systems advocate, it gives us all a black eye.

So On To Best Practices

At the workshop, someone from Michigan mentioned that one of their larger communities was planning to shut down their SCADA system for a week. This wasn't being done to allow upgrades or changes to the system, this was being done because the Water Supt. wanted to make sure his staff knew how to run the plant. This system is being proactive, both from an emergency standpoint, and also from an operations standpoint. We all rely on technology and automatic this or that for so many things these days, but to really "know" your plant, to be able to troubleshoot and tell when something isn't quite running right, you really have to have a comprehensive understanding of how your system works.

I Know, You Already Know Your Plant That Well
You are thinking, I already have that level of understanding of my plant, I know when something doesn't sound right, look right, or even feel right. Thats great, but what about the next level of support? What happens when you are not there? Do you ever take vacation or have to be out of town for a day or two? Is the person left in charge of your plant as familiar with your system as you are? Do they know your plant well enough to troubleshoot when a problem pops up? They need to have that level of understanding, or have something they can turn to that has those details.

That brings us back to one of those O & M things that are a pain, take time, and because you know the plant so well, keep putting off or don't see a need for. You should have an O & M manual for your plant. No one else can write it, and its only as useful as the information you put into it. It comes down to being prepared and taking full responsibility for the operation of the plant. That also means being prepared in case you can't be there for some reason.

Getting Started
First of all, develop an emergency response plan. There are templates available from a number of sources. You can contact a TA provider you work with, they will be able to get you started. If you want to look at some of the better ones, type in "emergency response plan" in our document keyword search, and use "type = templates". But, for those of you that already have an ERP, take the next step, develop an O & M plan for your plant. Pennsylvania, Massachusetts, and Florida require O & M plans, I'm sure there are others. New Jersey has an O & M template that operators can use to help them develop their O & M plan, as do Florida, Louisiana, and Vermont. Georgia has a guidance manual as well. It was also brought up at the workshop that Colorado is developing an O & M and training manual geared toward walking you through developing an O & M plan for your facility. It sounds like it will be a great resource. Once the Colorado document is available, we'll post an update and provide those details. Lastly, if you need some help, email or call us. We can either help you directly or find someone in your area who can help you get started.

Water Reuse in Illinois: Part 2

Last week, we introduced you to Rick Manner, the director of the Urbana-Champaign Sanitation District. In the part two of our interview, you'll hear about how changes in the State Revolving Loan Fund opened the door to reuse project and how the district determined the market value of their effluent. 

Illinois EPA is allowing Cronus to apply for SRF funding to build the pipeline. Can you tell us more about that?

State Revolving Loan Fund is part of how wastewater plants expanded in the 1970s. The U.S. EPA set up a big pot of money that the states could draw from for loans to city sanitation districts to help them expand their treatment facilities. Treatment facilities then pay back the loan over time, which sets up the revolving nature of the program. The payments going in this year can then go out to someone else.

Originally, SRF was set up exclusively for wastewater treatment plants, but then they set up an equivalent for drinking water plants. Then the Water Resources Reform and Development Act was passed in 2014. In that, Congress explicitly called out an expansion of SRF. They explicitly said that reuse projects, including the pipelines associated with them, can be eligible for loan options. In particular, they said that because reuse is a little bit unusual, the funding can go not only to municipal bodies but also to private sector entities.  

Before these amendments, it was ambiguous as to whether this project would have been eligible for SRF dollars. We would have had to argue that it was part of our treatment plant. But now Illinois EPA is willing to consider it because Congress has said that reuse can be eligible.

This is significant because the reason reuse projects often fail is the difficult economic hurdle of building the pipeline from point A to point B. The biggest reason Cronus might not want to do reuse is the $20 million hurdle of building the long pipeline. Even though it may cost more on a per gallon basis to make a drinking water pipe larger, that up front capital cost is so difficult to overcome that it often kills reuse projects. So SRF really helps make reuse a more appealing operation to consider because the interest rate is so good.

How did you decide what to charge for the effluent?

That is one of the more interesting elements of this whole process. Currently, we get nothing for the 20 million gallons a day that we discharge. So, in theory, if I were to get $1 for it, we would come out better. In reality, we did bit of research to try and find out what projects are out there and what other people are charging. It was a bit challenging because they’re aren’t very many in the Midwest. There are a few golf courses that use effluent about a hundred miles from here. But for the most part, they get a very large volume at a low rate. And that’s because the golf course happens to be right across from the water treatment plant. There really aren’t good models for effluent pricing.

We landed on a shared benefit/shared cost scenario. If Cronus was to buy from the drinking water plant, they would be charged about $3 per thousand gallons. However, they would get the pipeline subsidized by the drinking water plant, so it is really more like $2 per thousand gallons range. If we were much more than that, they would logically turn to the groundwater resource. That set a ceiling for the rate we could charge.

But there is also added risk associated with our flow because our water is not as pristine as good aquifer water. We aren’t required to treat it back to groundwater quality. And so, because of that added risk and the fact that they may need to do some chemical treatment on their end. We settled on charging just over $1 per thousand gallons. That’s the baseline price. On top of that, we get a 30 cent per thousand gallons add-on for our capital projects. That is how we will be funded for our lagoon and our pump station. Once we’ve been paid $3 million via that added amount, the extra fee will go away, and we will be back down to the $1 per thousand gallons. There is an inflation factor that is kicking in, so it is a bit more than that.

Ultimately, we will get about $2 million a year in income. Our expenses would be anywhere from $500,000 to a million dollars. So the benefit our ratepayers should expect to see is about $1 million a year net benefit, which is about 7 percent of our annual income. Some of that may be in value from the lagoon that won’t be a direct cash benefit. But we are aiming to keep the cash fraction as close to a full million as we can so that we can feel really good about this being a net benefit for the rate payers

One thing that I need to emphasize is that UCSD’s expenses have been going up continuously. I cannot and never will guarantee no rate increases. But I can absolutely guarantee that all of the finical benefit that UCSD gets will be seen by the rate payers in terms of avoided rate increases.

What other benefits can ratepayers expect?

Our board of trustees also voted to spend about $50,000 a year on habitat projects to make the creeks healthier in the long run. We consider that a reasonable thing to do with some of that income. That way the waterway will be healthier and better able to handle the drought conditions. By adding some pools and riffles, we can add some physical complexities that will help the fish and other aquatic species handle the stress of a drought better.

The pool and riffles idea is something the Illinois Department of Natural Resources has been looking to do for a number of years in the Copper Slough. They already have some money set aside for it as a result of a truck accident that spilled into the waterway. But they are looking for local matching funds, which they have had a hard time securing over the last few years. We would provide those local matching funds to allow that project to finally begin.

What’s the status of the deal with Cronus?

Cronus has announced that, if they build a plant, it will in Tuscola. And we have a contract to sell them effluent, so we would be their main water source if this all goes forward. Right now, they are looking to secure financing for the facility, so they are talking to financial people to get that secured. That is still a work in progress.

Is there an expected timeline?

It’s a process that has taken a few months and will take a few more. The finance people want a lot of assurances before they actually open up the check book. We are hoping for a positive announcement sometime soon. 

Free Board Training Offered for Missouri Utilities

Being on the board at your water utility can be a daunting task. Many small water utilities face a host of managerial challenges, including inadequate revenue, deteriorating infrastructure, and difficulty finding and securing a qualified operator. In addition, small towns can make conflict of interest cases and other infringements on board ethics difficult to avoid. In recognition of these challenges, many TA providers around the country have started offering board training and support in addition to their operator resources. One organization offering free training for boards and councils in their state is Missouri Rural Water Association.

MRWA is offering free 2-hour evening trainings for water boards and councils designed to be presented during or prior to a regularly scheduled board/council meeting. These trainings cover two to three management topics from a list including board/council member responsibilities; how to conduct an effective meeting; Sunshine Law; water system basics; utility rates and finances; conflict of interest/ethics; project financing; and asset management. In addition to these short trainings, MRWA will also offer 1-day, 6-hour courses intended to satisfy the requirements for water district board members to receive attendance fees for board meetings a per RSMo 247.

If your water utility board or council in the state of Missouri would like to schedule a MRWA training session, please contact Liz Grove at 573-231-6797 or by email.

If you think your board would benefit from management training but you don’t live in Missouri, you have a few options. You can check out our event calendar, and filter by your state and one of our management categories (Asset Management, Financial Management, or Utility Management). Or you can check with the TA providers in your area, including the state Rural Water Association and your RCAP region.