Capacity Development

The Capacity Development Program was created under the Safe Drinking Water Act (SDWA) Amendments of 1996 (section 1420) to promote drinking water systems development of finances, management, infrastructure, and operations so they can provide safe drinking water consistently, reliably, and cost-effectively. More specifically, the capacity development provisions provide a flexible framework within which states and water systems can work together to ensure that systems acquire and maintain the technical, financial, and managerial capacity to consistently achieve the health objectives of the 1996 SDWA.

Subsequently, America’s Water Infrastructure Act of 2018 (AWIA) amended Section 1420(c) to add asset management into their state capacity development strategies. AWIA contains the following requirements: (1) encourage public water supplies (PWSs) to create asset management plans (AMPs); (2) assist public water systems in training to implement AMPs; (3) include a summary of these efforts in a triennial capacity development report to the governor. Consistent with this statutory change, state drinking water programs are expected to revise their capacity development strategies to include a description of how asset management will be promoted through addressing the five-core-question framework of asset management. This provision aligns with EPA’s strategic measure of reducing the number of public water supply systems with health-based violations by ensuring long-term sustainability of the public water supply systems.

• Montana Capacity Development Strategy
• EPA Approval Letter for DEQ Capacity Development Strategy
• Administrative Rule associated with Capacity Development | ARM 36.23.108
• 2023 Report to the Governor
• 2024 Capacity Development Annual Report

• Enhance performance beyond compliance through measures that improve efficiency, effectiveness, and service excellence. Control points to achieve this goal include prolonging asset life, sustainability, financial planning, meeting expectations, emergency response, improving security, and reduce operating costs.
• Promote and implement Montana’s capacity development strategy with emphasis on asset management tools for new and existing public water supplies (PWSs) through meeting SDWA Sections 1420(C)(2)(A-F).
• Strive to achieve and maintain all PWSs compliance in accordance with the SDWA.
• Track and prioritize PWSs that fail to meet compliance requirements as outlined in the SDWA.
• Provide resources to systems in support of their efforts to supply customers with an adequate quantity, quality and reliable source of water.
• Continue stakeholder engagement to optimize capacity development efforts.
• Maintain and further develop Montana PWS history of system support through partnerships with regional technical assistance providers and our existing State Revolving Fund (SRF) TMF contract.

The Montana Department of Environmental Quality has made significant strides in development and promotion of the capacity development program as a whole since implementing a fulltime employee as the Capacity Development Coordinator in January of 2022. The five-core-question framework of asset management is now emphasized through the MDEQ updated Capacity Development Strategy and will be an integral component of our program as we move forward. MDEQ encouragement of the asset management program is promoted through the following methods:

• Implement and support a designated Capacity Development Coordinator position in MDEQ PWS. The long-term goals of this position will direct capacity development efforts with emphasis on asset management, serve as the technical assistance specialist for PWSs with persistent issues, and continue to develop Montana’s involvement in the Area Wide Optimization Program (AWOP).
• Asset management questions have been incorporated into the capacity development self-assessment form. Self-assessment forms will be provided to systems through sanitary surveys, technical assistance visits, engineering review, rules management, and training events. The self-assessment form will be provided to systems with a ETT score of 10+ when appropriate.
• Table A-1 has been placed back into DEQ-1 and is referenced in DEQ-3
• A capacity development webpage that will be accessible to the general public is under construction, and will include asset management tools and resources.
• DEQ PWS will create a drop-box within the capacity development webpage for systems to submit their asset management plans and self-assessment forms for professional review.
• MDEQ PWS Field Staff must discuss CD/AM with the system representative, verify if the system has an asset management plan, present the representative with a business card that has the Capacity Development Coordinator contact information on the back, and note CD/AM contact within the sanitary survey inspection reports.
• Expansion of the Operator Certification Program to include facility-based training water and wastewater opportunities for CD and AM centered training through approved providers during technical assistance visits. Creation of an asset management plan must be emphasized. Area technical assistance providers were encouraged to develop asset management knowledge through additional formal training.
• Continue to offer capacity development training opportunities with an emphasis on asset management tools throughout Montana, and encourage area technical assistance providers to promote system specific asset management plans through field visits and annual training events.

CAPACITY DEVELOPMENT FOR NEW SYSTEMS

Section 1420(a) of the SDWA requires the state to ensure that all new community (C) and non-transient non-community (NTNC) systems beginning operations after October 1, 1999 must demonstrate the capacity to comply with regulations. The MDEQ PWS program incorporated capacity development requirements into the current public water supply rules and referenced design circulars to address TMF components prior to new construction.

MDEQ rules and design circulars require new systems to demonstrate adequate technical, managerial and financial capacity as part of the approval process. The following list includes circulars referenced by MDEQ to ensure new systems have addressed TMF prior to construction.

• Self-Assessment for Capacity Development for New Systems

1. Design standards and capacity development regulations

• DEQ 1 - Standards for Water Works
• DEQ 3 - Standards for Small Water Systems
• DEQ 7 - Montana Numeric Water Quality Standards
• DEQ 10 - Standards for the Development of Springs for Public Water Systems
• DEQ 16 - Standards for Hauled Water Cisterns (Water Storage Tanks) for Non-Community Public Systems
• PWS 5 - Groundwater under the Direct Influence of Surface Water
• PWS 6 - Source Water Protection Delineation

All new community (C) and non-transient non-community (NTNC) systems must include Appendix A and Table A-1 from the current MDEQ PWS construction circular (DEQ-1) along with the referenced self-assessment (SA) form (DEQ-1 Appendix A part A.1) to demonstrate consideration of technical, managerial and financial planning with emphasis on the five-core-question framework of asset management. See attached Appendix A, Table A-1 and self-assessment form. Creation of asset management plans are encouraged through MDEQ PWS staff and a variety of resources are available on the MTDEQ PWS webpage. The webpage is currently under construction, but will be operational in 2023. 

Montana has over 2,200 existing public water supplies scattered across our large state with current and projected growth that continues to stress our limited staff capacity. Given the large number of systems, vast size of Montana, and a shortage of staff, MDEQ has chosen to provide capacity development services with asset management emphasis primarily through the Capacity Development Coordinator, engineering review, technical assistance contractors, and collaborating with other qualified regional technical assistance providers. MDEQ PWS field staff discuss capacity development and asset management with the system representative(s) and refer them to the Capacity Development Coordinator for further assistance. All technical assistance entities working within Montana have been encouraged to pursue formal asset management coursework to enhance their effectiveness. Technical assistance providers completing additional formal asset management courses are requested to report the training to the MDEQ Capacity Development Coordinator and will be considered a preferred TA provider for facility-based asset management training.

• Self-Assessment for Capacity Development for Existing Systems

Chemical Feed Pump

Chemical Dosing On-Site Training

More Coming Soon!