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Are You Ready to Communicate to Key People in a Water or Water Quality Emergency?

Posted By Robert Cullick Communications, Friday, October 16, 2020

(Attached: One-Pager for Digital Download)

The safety of drinking water will continue to an important concern for your customers. From Flint, Michigan, to East Texas, from oilfield fracking to agricultural chemicals, public concern over the safety of drinking water remains high. Sometimes it hides behind timely concerns such as economic conditions and the pandemic, but when someone gets sick or something else bad happens, the problem can easily accelerate into a crisis.  Communications must be perfectly executed. Are you ready to deliver? Ask yourself these questions:

Know who will speak for the utility

  • Does staff know when to alert the General Manager of an event?
  • Does the General Manager know when to alert the Board of Directors?
  • Has the Board approved an Emergency Communications Procedure empowering the General Manager?
  • Does the General Manager know when and how to involve the Board of Directors?
  • Do you have an emergency management plan that includes a core group of people who will function as your emergency management staff?
  • Can your emergency management team function if you are not there?
  • Do employees know utility business cannot be discussed on their social media?
  • Do employees know whether they should answer news media questions at the site?

Know and practice the order of communications

  • Are written procedures in place for alerting regulators and health authorities?
  • Are procedures in place for notifying elected officials?
  • Are procedures in place for alerting employees?
  • Are procedures in place for alerting customers?
  • Can you put a message on at least two social media channels within 30 minutes day or night?

Know what to say in public statements – and what not to

  • Do you know when to empathize with those affected?
  • Do you know when to say, “I don’t have the answer. We are working on getting good data. We will let you know.”
  • Do you know how to coordinate with the region’s Emergency Management Coordinator (often the County Judge in rural counties) and can you reach them 24/7?
  • Do you know how to time-bracket restoration when there is a service delivery issue?

Know your customers’ news media

  • Do you know what your customers consider reliable, local news sources?
  • Do you have a recent and accurate list of key news media? Are you connected on social media?
  • Does your list include radio and TV?
  • Do you know the Five Ws that news media need to write a story?

Now is the time to become better prepared for the unexpected. You’ll be glad you did.

  • All check marks? Perfect. Now practice.
  • Half of boxes checked? Make a plan to expand and improve your emergency response.
  • Only a few? Make this a priority for 2021 for your Board and the staff you most rely on.

Prepared for the Texas Rural Water Association by Robert Cullick Communications. Robert Cullick has handled electric and wet utility communications in Texas for more than 30 years and speaks at TRWA conventions.  He is an independent consultant operating out of Travis County, Texas, and responds to your questions at 

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Fifth Circuit Follows TRWA’s Amicus Brief in Green Valley SUD’s Major CCN Decertification Case

Posted By TRWA Communications , Tuesday, August 11, 2020

On August 7, the New Orleans-based Fifth Circuit Court of Appeals overturned long-standing precedent established in North Alamo WSC v. City of San Juan, a 1996 decision by the same court holding that a federally-indebted utility’s duty to provide service under its CCN is the equivalent to “making service available” under federal law.  North Alamo has been one of the cornerstones in Texas rural water utilities’ fight to protect their CCNs from decertification by neighboring providers, though this precedent has been largely unique to Texas since courts in other jurisdictions have not applied the same standard.  While the Fifth Circuit recently chose to overturn this key precedent in Green Valley Special Utility District v. City of Schertz, et al, it did so in a manner proposed by TRWA that hopefully minimizes the negative impact their decision will have on the rural water industry.


As background, Green Valley SUD scored a victory for rural water in 2019 with a favorable U.S. district court decision in their ongoing CCN decertification case with the cities of Schertz and Cibolo.  The cities immediately appealed that decision to the Fifth Circuit Court of Appeals, the appellate court directly below the United States Supreme Court responsible for hearing appeals from district courts in Texas, Louisiana, and Mississippi.  A panel of three judges is usually assigned to hear the majority of cases, but here, the Fifth Circuit took the unusual step of having the case argued before all 17 judges.  Historically, when appellate courts choose to have the whole court hear a case, it sends a strong signal that they are planning to overturn established precedent.    


The Public Utility Commission (PUC) and the cities argued that a utility can only show service has been made available if the utility has infrastructure in place dedicated to serving the property to be decertified.  Had the Court overturned North Alamo in favor of this standard, rural utilities would have found their CCNs extremely vulnerable to decertification by neighboring providers, because utilities simply do not, and cannot plan for future growth in that way.  TRWA submitted an amicus brief in support of Green Valley, which argued in favor of the North Alamo precedent; however, given the likelihood that the North Alamo standard would fall, we also offered the court a reasonable alternative already used in other jurisdictions across the country.  The Court essentially adopted TRWA’s alternative argument in its entirety, the best possible outcome short of a full affirmation of North Alamo.  


In Green Valley’s case, the Court adopted the “physical ability” test, which states that a utility must show that it has adequate facilities to provide service to the area within a reasonable time after a request for service is made and that it has the legal right to provide service to the area.  The opinion also states that courts will need to make a fact-specific determination in each case as to whether a utility can make service available within a reasonable time after it receives a request for service.  While not the best possible outcome for Green Valley and rural utilities in Texas, the physical ability test should give rural utilities, with federal debt, protection from decertification when they are ready and able to serve high-growth areas.  The court remanded the case to the federal district court to further rule on the facts based on this opinion.

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NRWA Backs Emergency Assistance for Rural Water Systems Act

Posted By NRWA, Tuesday, August 4, 2020

WASHINGTON, DC, August 4, 2020 - Congressmen David Rouzer of North Carolina (NC-07) and Filemón Vela Jr. of Texas (TX-34) introduced the Emergency Assistance for Rural Water Systems Act today.

The Emergency Assistance for Rural Water Systems Act allows USDA Rural Development to provide affordable and sustainable financial options for rural utilities impacted by COVID-19.  Assistance includes grants, zero percent loans, one percent loans, principal and interest reduction, loan modifications and direct operational assistance to provide financial stability for the impacted utility to get through this crisis.


NRWA strongly supports these tools for Rural Development to employ in this crisis. NRWA’s 30,000 member utilities need these tools and resources to directly address the financial concerns and continuity of operations challenges that the rural utilities are currently experiencing, especially as they continue to provide uninterrupted essential services now and in future disasters or economic downturns.


“Access to clean drinking water and safe wastewater treatment is vital to every American, especially during the COVID-19 pandemic,” stated Kent Watson, NRWA President and Texas National Director. “Serving as a manager of a rural utility for 30 years, I understand the necessity of the Emergency Assistance for Rural Utilities Act. This Act will provide assistance that is direly needed by many utilities in our Nation that are suffering the financial effects of the pandemic and will ensure future sustainability for these systems during times of crisis.”


This legislation comes at a time that is desperately needed for Rural America and Rural Water.  Small and rural communities have done their part to meet the public’s needs during the COVID-19 pandemic by maintaining and restoring customer access to water services regardless of payment. NRWA estimates small water and wastewater systems stand to lose $998 million in revenue due to customer nonpayment alone. This lost revenue will never be recovered by utilities and does not include emergency operational costs.


Most of the country’s drinking water and wastewater utilities are small. Roughly 80 percent of the country’s approximately 17,000 wastewater utilities serve populations less than 10,000 persons. Over 90 percent of the country’s approximately 50,000 community water systems serve a populations less than 10,000 persons.


“I’m proud to introduce this much-needed legislation to address our rural water infrastructure," said Congressman David Rouzer.  "Our rural communities have been struggling for years to maintain and update critical water infrastructure, a problem that has been made that much worse by revenue shortfalls due to the pandemic. This legislation will provide critical resources to better ensure we have the sound water infrastructure necessary to providing basic services for rural families.” 


Congressman Filemón Vela is "proud to introduce bipartisan legislation that would provide much needed assistance to rural water and waste disposal systems affected by the novel coronavirus pandemic. This health crisis has showcased the important role safe drinking water and sanitary waste disposal play not only in public health, but also in the economic vitality of rural America. As we continue to fight this pandemic, we must ensure that our nation’s rural water and waste disposal systems have the resources and infrastructure needed to support families living in rural communities.” 


Rural America and TRWA are proud of the commitment made by Congressmen Rouzer and Vela.


 “Congressman David Rouzer has been a long-standing supporter of rural water utilities as far back as his days working at the USDA Rural Development and later the NC General Assembly. His determination to assist rural North Carolina and water and wastewater systems has never wavered and has once again been exhibited by his Emergency Assistance for Rural Water Systems Act. As a resident of Congressman Rouzer's district, I could not be more proud of his attentiveness to the needs of his district and the priorities of rural and eastern North Carolina,” said Daniel Wilson, Executive Director of North Carolina Rural Water Association.


Brian Macmanus, Texas Rural Water Association’s Immediate Past President, acknowledges Congressman Vela’s vision. “Congressman Vela has always listened to the needs of his rural water constituents in District 34, and is aware of our systems’ financial needs.  On two occasions he has visited our local surface water treatment facilities.  Here in Deep South Texas and across our entire state and country, we are very pleased with the potential relief this bill provides to our water and wastewater systems in Rural America.”

Tags:  emergency assistance  NRWA  rural water 

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NRWA Coronavirus Update

Posted By Sam Wade, CEO, National Rural Water Association, Thursday, April 2, 2020

As we endure another week of the coronavirus pandemic, we must continue to recognize and thank each of the men and women working every day to ensure our water continues to flow and waste treatment systems continue to operate, while protecting our source waters and the environment. These services are essential to maintain public health, essential to protect the environment and essential to mitigate and eliminate the threat of this virus on our American communities and families. For all these reasons, each individual operating and working in these systems is considered essential to carry out these critical services during this emergency. 


Systems of all sizes have taken necessary steps to ensure continuity of service and to protect the industry workforce. State Rural Water Associations have developed a listing of 2,786 retired or otherwise qualified operations specialists to support systems if critical, local utility staff are unable to perform their duties due to the virus. State and federal agencies continue to adjust as the pandemic evolves including extending operator certification deadlines and allowing flexibilities in the regulatory area.   


At this point, the financial impact of this virus is resonating throughout the industry across rural America. NRWA anticipates congressional actions in the near future that could include infrastructure funding, and your association will advocate for provisions that will address rural utilities that have been financially impacted from this pandemic. We have heard your voices and concerns and are responding accordingly.


Utilities should continue to monitor and update the financial impact on their historic revenue streams as the consequences of this virus continue to evolve. The impact is compounded by several moving factors including businesses that have closed or temporarily shut down; the downturn in the economy; resulting in increased unemployment and lower return on investments. As a result, systems will likely see more late or non-payment for residential services soon. As systems assess this financial impact, if necessary, they should start discussions with their State Rural Development office and other lending institutions regarding what assistance or servicing actions are available to them at this time. Your State Rural Water Association has the resources and expertise to assist in this effort. This assistance can be rendered remotely, maintaining the recommended social distancing guidelines.


Overcoming these challenges in the months ahead will require a common goal of ensuring the continuation of these essential services to the public. It will require patience, perseverance and understanding by all. Your State Rural Water Association has the staff expertise and experience to assist your system and jointly take on these challenges. 


This long- term trusted partnership with each of you, including our federal, state and local leaders, will ensure that rural America will get through this crisis together. As our nation continues to deal with the pandemic, we thank each and every individual as you continue to take all the precautions you can to maintain social distancing, disinfect surfaces, wash your hands, resist touching your face, all things necessary to stay healthy and lessen the spread of this dreadful outbreak.  


Thank you for dedication and service.

Sam Wade

CEO, National Rural Water Association

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The Power of Partnership for Public Water Systems

Posted By Texas Commission on Environmental Quality, Monday, March 30, 2020
During this uncertain time, it is especially important to consider the power of partnership to aid in your daily scope of work. Please consider what resources you could share with a neighboring system, and vice-versa (chemicals, operators, knowledge). A great example of this would be sharing a 55-gallon drum with your neighboring PWS to ensure you both have enough NSF Standard 60 certified sodium hypochlorite during any shortages. Understanding the shelf-life of your disinfectant chemicals is key to ensure you are dosing your systems appropriately, thus confirming the inactivation of viruses.

You may search for neighboring PWSs using Texas Water Development Board’s Water Service Boundary Viewer. Please use the search bar in the top left for addresses, PWS IDs, or Counties. Once you find a nearby water system, click inside the boundary of the water system and a pop-up window should appear with a link to Texas Drinking Water Watch (highlighted in the image below).


Alternatively, you can search for neighboring systems using our Drinking Water Watch website. Please use the drop down under ‘Principal County Served’ and ‘Water System Type’ to search for facilities near you (highlighted in the image below). On the next page, please click ‘Summary Sheet’ and you should see contacts listed under the ‘All Water System Contacts’.


If you need assistance calculating the specific feed and dosing rates, please work with TCEQ’s Texas Optimization Program (they can help you calculate a chemical mix for creating alternative disinfection chemicals that are NSF Standard 60 certified). The contact is Mr. Kenneth Dykes and his email is

Please work with your manufacturing suppliers to certify you understand their supply amounts, their designated ratios, and their manufacturing suggestions.  Please view the list of Texas suppliers on our COVID-19 webpage.

If you need help at any time, please reach out to the SBLGA Hotline at 1-800-447-2827.

For more resources on TCEQ’s COVID-19 response to public water systems please visit our COVID-19: Public Water Systems webpage.

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Employment Law and COVID-19

Posted By Veronica Cruz and Felicity A. Fowler, McGinnis Lochridge Law, Thursday, March 19, 2020


As the COVID-19 situation continues to evolve, many water utilities will be faced with tough decisions relating to maintaining a healthy work environment without running afoul of applicable employment laws.  Below is a helpful guide for employers as they strive to maintain a healthy workplace while conducting their vital business operations. 


The firm has also compiled this analysis of the Families First Coronavirus Response Act, which is expected to be signed into law by President Trump soon.  This resource explains employers’ obligations relating to the Act’s Emergency Family and Medical Leave and Emergency Paid Sick Leave provisions which could affect TRWA members in the coming weeks and months.


The severity and lasting impacts and effects of the spread of COVID-19 remain unknown.  Each day federal, state, and local governments deploy new measures in an effort to curtail the spread of the virus, and such measures will impact the workforce and implicate legal obligations of employers.  For example, some jurisdictions have closed, or are considering closing, schools, which may require parents without access to childcare to remain home.  Additionally, individuals who tested positive or were exposed to someone who tested positive to COVID-19 may be required or advised to quarantine for several weeks. 

In the most recent move, the CDC and President Trump issued new guidance on March 16, 2020, recommending the avoidance of gatherings larger than ten (10) people.  In light of these developments, employers should consider their options on how best to decrease the spread of the virus in light of their obligations under applicable employment laws, such as the Americans with Disabilities Act (“ADA”), the Family and Medical Leave Act (“FMLA”), the Fair Labor Standards Act (“FLSA”), and related state and local laws.  Additionally, to the extent an employer is considering implementing temporary layoffs or furloughs, employers should be aware of their obligations under the Worker Adjustment and Retraining Notification (“WARN”) Act, and related state laws. 

Based on the information we have to date regarding the virus and the Department of Labor’s existing guidance, we developed the following practice guide for employers.


Recommendations to Frequently Asked Questions

The following recommendations are based on the unique and extraordinary circumstances presented by the coronavirus (COVID-19), the declaration of a pandemic, and guidance public health officials, including the Centers for Disease Control (“CDC”), and federal and local governments as of the date of this publication. 

Maintaining a safe and healthy workplace:
Q: An employee is displaying symptoms of COVID-19, can an employer require the employee to go home?

A:Yes.During a pandemic, an employer is allowed under the ADA to require an employee to leave the workplace, particularly if the employee is exhibiting symptoms that would pose a threat to the remaining workforce.

Q: Can an employer measure an employee’s temperature during the coronavirus pandemic?

A: Generally, under the ADA measuring an employee’s temperature is a “medical examination” that must meet specific requirements to be permissible.However, during a widespread pandemic, an employer is allowed to measure an employee’s temperature to determine whether the employee would pose a threat to the remainder of the workforce.

Q: Can an employer ask an employee whether the employee has symptoms of COVID-19 (e.g., fever, shortness of breath, etc.)?

A: Yes, an employer can ask if an employee is experiencing symptoms of COVID-19.However, any information received from the employee must be treated as confidential medical information.Therefore, as with any other employee medical information, such information must be stored in a confidential file, separate from the employee’s personnel file.Additionally, employers should not disclose the identity of an employee diagnosed with COVID-19 or experiencing symptoms of COVID-19.

Q: Can an employer require employees to disclose an underlying health condition that potentially makes the employee more susceptible to complications of the coronavirus?

A: No.An employer cannot require employees to disclose medical conditions unrelated to the coronavirus, even if such conditions make the employee more susceptible to complications of contracting coronavirus. However, if an employee voluntarily discloses such a condition, the employer must treat this information as confidential medical information.Additionally, the employer should work with the employee to determine if the employee requires a reasonable accommodation that would allow the employee to perform the essential job functions while mitigating any health risk to the employee (such as, allowing the employee to telework, placing the employee in a separate office, etc.).

Q: If an employee recently returns from a trip from an area designated as a “hot spot” by the CDC or other government officials, can the employer ask the employee to remain at home?

A:Yes, an employer can require an employee returning from a recent trip to remain at home. The employer should advise the employee to “self-isolate” in accordance with guidelines from the CDC and local public health officials.

Continuing business operations:
Q: Can an employer require employees to work from home during a pandemic?

A:Yes, an employer can require its employees to telework or work from home during a pandemic. However, the employer must provide the employee with the tools and equipment necessary to allow the employee to work from home, such as laptops, phones, printers, etc.Under the FLSA, employers cannot require employees to reimburse the costs of providing laptops, phones, etc., if doing so would cause the employee’s earnings to fall below the required minimum wage. Under the ADA, employers cannot require employees working from home as a reasonable accommodation to reimburse the employer for the costs of providing laptops, phones, etc.

Q: Is an employer required to allow employees to work from home?

A:No, unless (i) an employee with a disability requests telework as a reasonable accommodation and doing so does not impose an undue burden on the employer; and/or (ii) the federal, state, or local government orders the closure of businesses.

Q: Does an employer have to compensate non-exempt employees who are unable to work due to the effects of the coronavirus?

A:Under the Fair Labor Standards Act, employers are only required to pay non-exempt employees for hours actually worked. However, if an employer offers paid time off, the employer should follow its normal policies and procedures relating to paid time off.

On March 18, 2020, President Trump signed the Families First Coronavirus Response Act (“FFCRA”), which among other things, amends the Family and Medical Leave Act (“FMLA”) and enacts a separate Emergency Paid Sick Leave Act.  For more information regarding the FFRCRA, please click here.

Q: In order to maintain business operations, an employer requires some employees to report to work, while other employees can work from home or are deemed “non-essential.”  How does an employer determine which employees need to report to work?

A: The decision to allow some employees, while not others, to work from home must be based on legitimate business reasons in light of the nature of the job functions. Employers cannot select employees to report to work based on protected categories, such as race, national origin, gender, age, religion, disability status, or veteran status. Additionally, employers should consider which job functions can be performed remotely and whether some job functions are not necessary due to a reduction in the Company’s operations.

Addressing a reduction in business operations:
Q: Due to a decrease and disruption to the company’s operations, the company is considering temporarily laying off employees on furloughs.  What obligations (if any) does the company have to provide notice under WARN?

A: If an employer is considering permanently or temporarily laying off workers, it should consider its obligations under the federal Worker Adjustment and Retraining (“WARN”) Act. The WARN Act requires covered employers to provide employees 60 or 90 days’ notice of any “plant closing” or “mass layoff.”The federal WARN Act applies to employers with 100 or more employees (excluding part-time employees working less than 20 hours per week, employees who have worked less than 6 months).

The WARN Act does not apply if: (i) fewer than 50 people lose their jobs as a result of a mass layoff or plant closing; (ii) the planned layoff is less than 6 months; (iii) for employers with 50–499 employees, the layoff results in less than 33% of the total active workforce at a single worksite; or (iv) the work hours are not reduced 50% in each month for any 6-month period.

Further, the WARN Act does provide certain exceptions to the 60 or 90-day notice requirement for unforeseeable business circumstances or natural disasters. The unprecedented effects of COVID-19 may qualify as “unforeseeable circumstances” exempting an employer to provide the full 60 or 90 day advance notice. However, employers covered by WARN may still be required to provide employees notice of a mass layoff or plant closing as soon as practicable. The applicability of the federal WARN Act is very fact-intensive and specific advice requires understanding of the specific facts at issue.

Q: Due to a decrease and disruption to the company’s operations, the company is considering temporarily laying off employees.  Can employees collect unemployment benefits due to a temporary layoff? 

A: Yes. In Texas, employees affected by a temporary layoff may qualify for unemployment benefits, subject to the eligibility requirements.If an employer is considering a mass layoff (in addition to evaluating its obligations under the WARN Act), the employer should consider whether it should file a mass claim of unemployment benefits on behalf of the terminated employees. Filing a mass claim for unemployment benefits offers a means to simplify the process and ease the burden on employers and employees relating to the unemployment benefit claim process.

Q: Prior to the widespread effects of COVID-19, the Company extended an offer of employment to an individual.  However, given the current circumstances, the Company can no longer employ the individual.  Can the Company revoke its offer of employment?

A: Depends. Generally, employees in Texas are considered “at will,” meaning the employer or employee can terminate the employment relationship for any reason or no reason at all. However, if the employment relationship is governed by an employment agreement or other contract, the employer must review the terms of the employment agreement to determine its obligations.

Other Considerations

Continuously monitor guidance from the CDC and state or local public health officials.  The federal government, states, and municipalities have declared states of emergencies, recommended small gatherings, ordered the closure of bars and restaurants, and issued “shelter in place” orders.

Maintain ongoing and open communications with employees.  As the guidance from the CDC and federal and local governments evolve each day, it is important for the Company to provide periodic updates to its workforce regarding the impact of the guidance on the Company’s operations, policies, and procedures.    

Critically evaluate whether telework is appropriate and necessary to continue the Company’s business operations.  Telework may be an effective temporary solution for some workers, however, it may not make sense for all workers.  For example, the nature of some positions require in-person attendance, such as store clerks, IT professionals who need physical access to the Company’s IT infrastructure, etc.  Additionally, telework may not be a long-term solution.  Many employers are adopting telework procedures as a “last resort” to protect the health and safety of its employees while continuing the Company’s operations.  However, telework may not be ideal, create inefficiencies, or cause business disruptions.  Therefore, employers should notify its telework employees that these measures are directly related to the extraordinary nature of the coronavirus and guidance from public health officials, and that these policies are subject to change based on new guidance from health officials and the elimination of the need for social distancing.

To the extent an employer decides to temporarily or permanently lay off employees, an employer should internally document and maintain records relating to: (i) the business reason for conducting layoffs (e.g., unexpected and/or dramatic reduction in business operations due to the impact of the coronavirus—be as specific as possible); (ii) the criteria the employer used to identify the employees who would be impacted by the layoffs; and (iii) communications to employees regarding the layoffs.


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Coronavirus Readiness for Water Utilities

Posted By TRWA Communications , Monday, March 16, 2020

Water operators are essential personnel and should be prepared to address potential impacts to supply due to personnel interruptions tied to COVID-19. Water systems play a vital role in public health and Texas Rural Water Association is here to help systems put measures in place that ensure seaml­­ess operations during the Coronavirus/COVID-19 pandemic.


Critical Operations Preparedness

  • Identify essential employees required to maintain continuous operation and designate an emergency backup for these employees in the case they cannot report to work.
  • Strategize implementation of an ancillary workforce (e.g. neighboring water systems, contractors, employees in other job titles/descriptions, retirees) to operate utilities on emergency basis.
  • Stay stocked on chemical supplies and order products ahead of schedule to avoid delays from understaffed chemical suppliers.
  • Generate back-up supplier contact list for essential chemical and operation needs.
  • Update/create detailed written instructions for crucial operations (i.e. shutdown, water quality sampling, public notification).
  • Review/update emergency response plan and contacts. Identify key customers—hospitals or care facilities—with special needs.
  • Discuss cyber security precautions when using remote access. Back-up critical files frequently as a prevention measure to restore data.
  • Consider emergency food and overnight necessities at 24-hr facilities for personnel working long shifts.
  • Encourage personnel to stay home when they are sick. Provide work-from-home or sick leave options. Discuss backup or alternative shift rotations for personnel that need to stay home to care for themselves and/or loved ones.
  • If possible, make a plan with your family and any groups that you lead in case of have school/work closures.
  • Limit meetings, gatherings and travel. Encourage personnel to postpone all non-essential travel to areas affected by COVID-19.


Public water systems are expected to continue to monitor water quality and provide sample results to regulators during the COVID-19 epidemic.


Mutual Aid Assistance


There may be systems, that due to an outbreak of COVID-19, require operational assistance.  If you are interested in potentially helping a system in need in an emergency situation, please contact


Frequently Asked Legal Questions 


It can be difficult to comply with all the laws written for a normal time while still being responsible in dealing with this pandemic. The TRWA Legal Department has fielded a high volume of calls about how best to conduct business, elections, and their annual meetings during these uncertain times. Click here to review frequently asked questions and answers. 



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Coronavirus Concerns and RWC2020

Posted By TRWA Communications , Tuesday, March 10, 2020


Update: 3/13/2020


On March 13, in response to the global Coronavirus pandemic, San Antonio Mayor Ron Nirenberg issued a Declaration of Public Health Emergency relating to the pandemic which bans gatherings of more than 500 people in the City of San Antonio through March 20, 2020.  Additionally, President Donald Trump declared a national emergency and Governor Greg Abbott declared a statewide disaster. 


Based on the Mayor’s Declaration which we believe will likely be extended, and out of concern for the health and safety of our attendees, the Texas Rural Water Association Board of Directors decided to cancel our Annual Convention scheduled for March 25-27, 2020, in San Antonio.


We want to thank each of you for your patience and support as this was a difficult decision.  In the history of TRWA, this is the first time we have canceled our Annual Convention, which we value as time together to learn and enjoy the camaraderie of our rural water community. 


The TRWA team will work to minimize inconveniences presented by this cancellation, including providing full refunds of your registration and exhibit fees.  Our TRWA staff team is switching gears from planning the details of this event to the administration of the cancellation activities. Please continue to be patient with them through this process. 


Each of you will receive an email next week about the processing of your refunds.  Please also see the FAQ below for additional information.


Our board and staff team are disappointed that we will not be gathering together in San Antonio this month, but we hope and expect to resume our regular pattern of conferences throughout the rest of the year and look forward to seeing you soon.


Thank you for your dedication to your communities and our industry. 



We have received several questions about whether we intend to continue our plans to hold our annual convention later this month, so we wanted to be sure all our members knew our plans and stance on the situation. RuralWaterCon 2020 is on course to be held as planned in San Antonio at the Grand Hyatt on March 25-27. The Texas Rural Water Association is committed to caring for our colleagues and our members, as your safety and well-being is a top priority. We continue to closely monitor the COVID-19 situation, remain vigilant, and follow recommended precautionary measures, protocols and guidelines from various health organizations including the World Health Organization (WHO), U.S. Centers for Disease Control and Prevention (CDC), and local authorities, in an effort to ensure our conference participants remain in a safe and healthy environment.   

Our host hotel has ensured us that they are taking extensive precautions to protect their guests, including:

  • Placing hand sanitizers in various public restrooms
  • Routinely cleaning and disinfecting surfaces every 3 hours, including thorough disinfecting of bathrooms in public spaces
  • Utilization of proper EPA approved cleaning products in public spaces and guestrooms
  • Checking guest’s well-being during the check-in process
  • Clean and disinfect frequently touched objects and surfaces
  • Reinforcing proper hand hygiene with all hotel associates

Let us know if you have any additional questions or concerns, and we are excited to see you at our convention in just a few weeks!



Statement from National Rural Water Association: 


The National Rural Water Association continues to monitor the coronavirus (COVID-19) outbreak and recommends all water and wastewater utilities review the best and latest information on the following trusted websites:

At this time, existing safe management techniques in both drinking water and sanitation apply to COVID-19.  Extra measures are not needed. In particular, disinfection treatment processes will facilitate more rapid die-off of the COVID-19 virus. Provision of safe water, sanitation and hygienic conditions play an essential role in protecting human health during all infectious disease outbreaks, including the current COVID-19 outbreak.

Frequent and proper hand washing is one of the most important prevention measures for COVID-19.  Good and consistently applied hygiene in communities, homes, schools, workplaces, marketplaces and health care facilities will further help to prevent human-to-human transmission of COVID-19.

This outbreak continues to evolve and information changes daily. Similar to past viral outbreaks of this magnitude, COVID-19 is something to be taken very seriously. NRWA will continue to monitor the situation and is following the guidance of leading health authorities. Any impact to technical assistance, training programs, meeting and/or conferences will be posted prominently at

The National Rural Water Association (NRWA) is the country’s largest public drinking water and sanitation supply organization with over 31,000 small and rural community members dedicated to drinking water quality, environmental protection and public health protection. Safe drinking water and sanitation are generally recognized as the most essential public health, public welfare, and civic necessities.



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Safe Drinking Water: Not Just the Responsibility of the Water System

Posted By Deborah McMullan, Sourcewater Protection Specialist , Thursday, January 9, 2020

Providing safe drinking water starts with the federal government and the state regulatory agencies. This is where laws and rules are developed for monitoring and maintaining all public water systems. These laws dictate the safety levels of contaminants found within our drinking water. They also dictate how water is to be treated and tested, as well as when and how the public is to be notified if a safety concern arises.

The second level of protection comes from the water system itself. This includes the office staff, managers and water operators. All operators must receive Texas Commission on Environment Quality (TCEQ)-approved training and pass a state license exam to legally operate a water system. During the training the operators learn many ways to protect and provide their customers with safe water.

There’s a third level of protection that most people never stop to consider. That’s you, the consumer! Yes, you too are responsible for protecting your drinking water. There are many ways that you may be of assistance, but the biggest assistance comes in the form of what we refer to as “Cross Connection Control and Backflow Prevention.”

Occasionally, a situation occurs where there is a temporary loss of water pressure due to the breakage or maintenance on a water supply line or main. This can cause the backflow of pollutants or contaminants from a cross connection to enter the water system and threaten the safety of your drinking water. Often your home is the first to receive that contaminated water, then it moves into the water main going on down the street to your neighbors. Even if the backflow event doesn’t cause a health hazard, it could adversely affect the taste, odor or appearance of the water. The contaminant may also be corrosive to your home’s plumbing.

Your first line of defense is utilizing a backflow device outside your home. There are many different types of backflow prevention devices available, some costing as little as $5. All homes should be equipped with an inexpensive vacuum breaker at each outside water faucet. These can be purchased at any hardware store and they are easy to install. They simply screw onto the hose bib and the water hose is then attached to the vacuum breaker.

The common water hose is the biggest culprit when it comes to cross connections in the home and business. For example, animal watering troughs which are common in rural areas for watering cattle or horses can take quite a while to fill. The automatic system for filling a trough is very popular and makes life easy for the owner; however, they require a garden hose or plumbing line to be present. A few years ago, a horse rancher was having a periodic problem where he would suddenly find lots of dirt in the bottom of his swimming pool, brown ice cubes in his freezer and brown water coming from his faucets. After several months of investigations, the water utility staff found the problem.

Every month the utility staff would perform a routine, state required, flushing of the water lines close to the rancher’s home causing a temporary drop in water pressure. The rancher had a very large horse watering trough just outside the back yard of his home. There was a garden hose lying inside the trough and the end of the hose lay in the muck at the bottom of the trough. Every month when the utility flushed the lines, a backflow event was occurring sucking all that muck back into the home’s plumbing system.

There was a simple fix to the problem. The rancher first installed vacuum breakers at all his outside hose bibs. Next, he installed plastic PVC piping with an air gap at the trough. An air gap is simply the area between the end of a hose or piping and the surface of the water. This prevents the backflow of water into the water system. If you happen to have a similar situation that needs correction, remember that the air gap should be two times the diameter of the hose or pipe.

With warmer weather approaching, there will be a lot more activities involving the garden hose and with these, other potential cross connection problems. Help protect yourself, your family and your neighbors by removing your water hose from Fido’s bath bucket, the kids wading pools and the garden sprayers. These are other common uses that can cause problems during the summer months. Help spread the word about how everyone in the community can take prevention measures to protect the water system and your homes from contamination.

If you are concerned that you have activities within your home or business that may be causing a cross connection and require backflow protection, we recommend contacting your water system operator. Water operators are very knowledgeable and willing to assist. They can perform a cross connection inspection and make recommendations on devices or processes to prevent back flow events from occurring.

Remember that education, back flow protection devices and changing habits are your best friends when preventing cross connections and backflow events.

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How Do We Keep Pharmaceuticals Out of Our Water Supply?

Posted By Deborah McMullan, Sourcewater Protection Specialist , Wednesday, December 4, 2019

The question of “what do I do with household hazardous waste, particularly unused medicines?” is a question that I’m asked often when working with water systems. This has become a hot topic in the last several years, as we’re hearing more about medicines showing up in our drinking water sources. 

At this time, pharmaceuticals that are unwanted by the consumer are not regulated as hazardous wastes. While there are a few pharmaceuticals on the market that meet the definition of hazardous waste under the Federal Resource Conservation and Recovery Act, the Act exempts household hazardous waste from the U.S. Environmental Protection Agency’s (EPA’s) disposal requirements. However, it is still imperative that everyone aid in the proper disposal of medicines to ensure source waters are not contaminated.

First, let’s talk about how medicines can end up in our drinking water sources. In homes that use septic tanks, prescription and over-the-counter drugs flushed down the toilet can leach into the ground and seep into our ground water/aquifers.

In areas where residences are connected to wastewater treatment plants, prescription and over-the-counter drugs poured down the sink or flushed down the toilet can pass through the treatment system and enter rivers and lakes. Due to prohibitive costs and lack of technology, municipal wastewater systems do not remove medicines before the treated water is released into the outfall. This means that those medicines may flow downstream to serve as sources for community drinking water supplies. Just like wastewater treatment plants, water treatments plants are generally not equipped to routinely remove medicines.

The best option for disposal is collecting all unwanted or expired prescription and over-the-counter drugs and dispose through a drug take-back program. EPA is currently recommending incineration as the preferred disposal method for household drug take-back programs, because they believe that incineration will safely address environmental concerns. If your city or county doesn’t offer this on an annual basis, you may still be able to utilize a take-back service at a local pharmacy or in another nearby city. To locate a collection site go to:, enter your city name and zip code, and you will receive a listing of all available options. 

If you happen to live in an area where there is no convenient location in which to drop off your medications, you can still do your part by following these steps:

1. Take the prescription drugs out of their original containers.
2. Mix drugs with an undesirable substance, such as cat litter or used coffee grounds.
3. Put the mixture into a disposable container with a lid, such as an empty margarine tub, or into a sealable bag.
4. Conceal or remove any personal information, including Rx number on the empty containers by covering it with permanent marker or duct tape, or by scratching it off.
5. The sealed container with the drug mixture and the empty drug containers can now be placed in the trash.

With this said, the U.S. Food and Drug Administration (FDA) maintains a list of drugs they recommend flushing ONLY when an immediate drop-off disposal option is not readily available. The medicines on this flush list may be especially harmful and, in some cases, fatal if used by someone other than the person for whom they were prescribed. Opioids are a good example of such a drug.

Immediately flushing these medicines down the toilet helps to keep children, pets and other individuals safe by making sure these drugs are not accidentally ingested, touched or misused.

Please note that FDA’s flush list indicates which old, unwanted, expired or unused medicines to immediately flush when take-back options are not readily available. Links in the flush list direct you to specific disposal instruction in each medicine’s label. To access this list go to: 

FDA recognizes that the recommendation to flush certain potentially dangerous medicines only when a take-back option is not readily available raises questions about the impact of the drugs on the environment and the contamination of surface and drinking water supplies. However, they believe that the known risk of harm to humans from accidental, and sometimes fatal, exposure to medicines on the flush list far outweighs any potential risk to the environment from flushing these leftover or unused medicines. 
For further information on drug disposal you may visit: and 


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