December 6, 2023

New Asset Management Requirements: How Georgia Water Utilities Can Comply with EPD

Beginning January 1, 2024, as part of new drinking water permit requests or renewals, water utilities serving more than 3,300 people must provide a water asset management plan. The details of this new requirement as adopted by the Georgia Environmental Protection Division (EPD) are included in Appendix C of the Georgia Minimum Standards of Public Water Systems.

The Appendix C requirements are based on the 2018 America’s Water Infrastructure Act (AWIA), which requires state drinking water programs to consider and include, as appropriate, asset management into their state capacity development strategies. In accordance with this requirement, the EPD is updating its EPA-approved Capacity Development Program to assist public water systems in the development and implementation of their asset management plans.

As part of the type of information Appendix C requires to renew or request new drinking water permits, Georgia EPD expects a high-level summary documenting five elements of an Asset Management Plan:

1. Develop a summary to describe the process to inventory assets, including asset condition, and how the inventory is maintained and updated.
2. Establish and document level of service categories and metrics
3. Establish critical assets for sustained performance
4. Procedure to determine minimum life cycle costs
5. Document long-term funding strategy, including Reserve Fund

Detailed information, such as the asset inventory, does not need to be submitted, but instead should be available for review during system audits.

For utilities renewing or requesting permits in early 2024, the EPD will focus initially on the plan’s framework and strategy but will expect the Asset Management Plan components to be more complete by the next renewal in five years. The systems that are renewing permits later in the five-year cycle will have more time to prepare and thus will have higher expectations on level of completeness. The plan is intended to be a living document that continues to be updated and implemented, but it does not need to be updated every time a utility adds or removes an individual asset from service. It is a plan for Asset Management, separate from the implementation of Asset Management, but EPD does expect utilities to implement the Plan.

Build and understand your long-term funding plan for resilience.

Public water systems should take steps to understand their financial needs and timelines for both routine repair and maintenance projects and future renewals and replacement projects. This enables systems to estimate the amount of reserve funds needed to sustain a water system proactively with minimal disruptions to service and reduce costs associated with emergency repairs.

While a rate study is not explicitly required for compliance with Appendix C, water systems do need to provide a plan to finance a reserve fund. A rate study may be a part of that plan as utilities can reinforce reserve funds with appropriate rate-setting.

Freese and Nichols’ Master Planning and Management Consulting team has extensive experience supporting utilities with strategic asset management planning, like what is required by Georgia EPD. Here are some of the ways we can help:

• Establishing asset management framework
• Conducting asset inventories and condition assessments
• Identifying critical assets and risks
• Estimating the remaining useful life as well as maintenance and rehabilitation strategies for your assets
• Developing funding strategies

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Contact Paula Feldman, Casey Porter, or Steven Rhodes for more information.

Resources:

• Appendix C Asset Management Draft
• Georgia EPD Drinking Water