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Drinking Water Increased Readability Rulemaking

 -- Rewriting the Colorado Primary Drinking Water Regulations

 

The Department completed a rulemaking to revise the Colorado Primary Drinking Water Regulations (CPDWR) in December 2013. The revised regulation became effective March 1, 2014.

 

The objective of the revisions was to reorganize, simplify, and clarify the existing CPDWR. These revisions to the CPDWR are not substantive in nature and did not change any current implementation practices or requirements. These readability revisions make the CPDWR easier to comply with and understand. These revisions are intended to be assistive to public water systems. Public health is better served by regulations that are clear, easy to read and understand. A rough timeline for the CPDWR increased readability rulemaking is depicted below.

 

The Department maintained the current structure of the CPDWR which is organized by drinking water rule. However, within each article the CPDWR has been reorganized by the lifecycle of the rule (initial, routine, reduced, increased, etc.). This new structure is consistent throughout the CPDWR so that readers can navigate the requirements with greater ease. 

 

The Department simplified and clarified the language of the current requirements. This was accomplished through the use of the following devices to make the CPDWR easier to comply with and understand:

  • Shorter sentences,
  • Active voice,
  • Consistent terms and definitions,
  • Logic tables,
  • Remove typos,
  • Remove outdated requirements, and
  • Remove errors in references.

These revisions to the Colorado Primary Drinking Water Regulations were not a federal requirement and Colorado’s primary enforcement authority was not contingent upon adopting these revisions.  The new Regulation 11 can be found on the Water Quality Control Commission’s webpage.   Regulation 11 (CPDWR) Quick Guide pdf file   provides an overview of the new regulations.

 
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At the initial stakeholder meetings in the summer of 2012 we introduced the concepts of the Increased Readability Rulemaking and gave stakeholders the opportunity to provide input on the concepts presented. There were 5 meetings (Denver, Glenwood Springs, Pueblo, Grand Junction, and Fort Collins) with a total attendance of 89 stakeholders participating.

 

The initial round of stakeholder meetings was accompanied by an online comment period and the opportunity to sign up to participate in the Stakeholder Advisory Group. (The deadline to sign up for the Stakeholder Advisory Group was October 5, 2012)

 

Click here to view the comments left by stakeholders during the initial stakeholder period from the online form.

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At the initial stakeholder meetings in the summer of 2012 stakeholders were given the opportunity to sign up to participate in the Stakeholder Advisory Group by October 5, 2012. A total of 25 stakeholders signed up to participate in the Stakeholder Advisory Group.

 

The Stakeholder Advisory Group has two goals:
   1.)   Verify that the Policy and Planning Unit made the CPDWR more clear and easier to read
   2.)   Determine the sequence of the Articles

 

The Stakeholder Advisory Group will meet four times (see dates below) to review and discuss draft regulations that the Policy and Planning Unit has prepared.

 

Date
Content to be Covered
October 30, 2012 Draft CPDWR Article 6 - Chemical Contaminants and Radionuclides pdf file
Draft CPDWR Article 13 - Groundwater Rule pdf file                                                                                        
December 19, 2012 Draft CPDWR Sections 7.1-7.5 - Surface Water Treatment Rule, Long Term 2, and Filter Back Wash Rule pdf file
Draft CPDWR Article 11 - Sanitary Surveys pdf file
Draft CPDWR Article 12 - Cross Connection Control pdf file
January 30, 2013

Draft CPDWR Article 4 - Variance and Exemptions pdf file

Draft CPDWR Article 8 - Lead and Copper Rule pdf file

February 28, 2013

Draft CPDWR Sections 7.6-7.8 - Disinfection Byproducts Rule, Maximum Residual Disinfectant Levels, Disinfection Byproducr Precursors pdf file

Draft CPDWR Article 9 - Consumer Confidence Reports and Public Notification Rule pdf file

Draft CPDWR Article 1 - Authority and General Requirements pdf file

Draft CPDWR Article 5 - Total Coliform Rule pdf file

Organization of the Final Regulation:

 

 

The Stakeholder Advisory Group will receive the draft language from the Policy and Planning Unit one week prior to each meeting to allow for an in-depth review before the meeting. During this week we encourage participants to share with others in their organization that may also want to provide input so that they can come prepared to discuss all comments.

 

An online comment period will be open one week prior to each meeting and will remain open for 2 weeks following each meeting to allow the Stakeholder Advisory Group to send us specific comments on specific citations regardless of whether or not you will be attending the meeting. At the meeting the Policy and Planning Unit will facilitate a group discussion of the draft language.

 

After the 2 week comment period following each meeting the Policy and Planning Unit will compile all stakeholder comments and write a response to each one. A comment resolution table will be posted on this webpage for the Stakeholder Advisory Group to review.

 


 First Stakeholder Advisory Group Meeting Outcomes:

 

Drafts Discussed on October 30, 2012 Resolution of Stakeholder Comments

Draft CPDWR Article 6 - Chemical Contaminants and Radionuclides pdf file

SAG Comment Table: CPDWR Article 6 - Chemical Contaminants and Radionuclides pdf file
Draft CPDWR Article 13 - Groundwater Rule pdf file SAG Comment Table: CPDWR Article 13 - Groundwater Rule pdf file

 


Second Stakeholder Advisory Group Meeting Outcomes:

  

Drafts Discussed on December 19, 2012
Resolution of Stakeholder Comments
Draft CPDWR Sections 7.1-7.5 - Surface Water Treatment Rule, Long Term 2, and Filter Back Wash Rule pdf file SAG Comment Table: CPDWR Sections 7.1-7.5 - Surface Water Treatment Rule, Long Term 2, and Filter Back Wash Rule pdf file
Draft CPDWR Article 11 - Sanitary Surveys pdf file SAG Comment Table: CPDWR Article 11 - Sanitary Surveys pdf file
Draft CPDWR Article 12 - Cross Connection Control pdf file SAG Comment Table: CPDWR Article 12 - Cross Connection Control pdf file

 


Third Stakeholder Advisory Group Meeting:

 

Drafts Discussed on January 30, 2013 Resolution of Stakeholder Comments
Draft CPDWR Article 4 - Variance and Exemptions pdf file SAG Comment Table: CPDWR Article 4 - Variance and Exemptions pdf file
Draft CPDWR Article 8 - Lead and Copper Rule pdf file SAG Comment Table: CPDWR Article 8 - Lead and Copper Rule pdf file

 


Fourth and Final Stakeholder Advisory Group Meeting:

 

Drafts Discussed on February 28, 2013
Resolution of Stakeholder Comments
Draft CPDWR Sections 7.6-7.8 - Disinfection Byproducts Rule, Maximum Residual Disinfectant Levels, Disinfection Byproducr Precursors pdf file SAG Comment Table: CPDWR Sections 7.6-7.8 - Disinfection Byproducts Rule, Maximum Residual Disinfectant Levels, Disinfection Byproducr Precursors pdf file
Draft CPDWR Article 9 - Consumer Confidence Reports and Public Notification Rule pdf file SAG Comment Table: CPDWR Article 9 - Consumer Confidence Reports and Public Notification Rule pdf file
Draft CPDWR Article 1 - Authority and General Requirements pdf file SAG Comment Table: CPDWR Article 1 - Authority and General Requirements pdf file
Draft CPDWR Article 5 - Total Coliform Rule pdf file SAG Comment Table: CPDWR Article 5- Total Coliform Rule pdf file
Survey Results for One Regulation Versus Many pdf file

 


 

Questions? Contact: Julie Kreyche
Email: julie.kreyche@state.co.us
Phone: 303-692-3405

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The Division has decided to maintain the current regulatory structure of one regulation with multiple articles.

 

The Department explored several options for dividing the current one drinking water regulation into multiple regulations. We received stakeholder input on these various options through a survey. The survey options were as follows:

 

   1.   Break the regulation into multi-article regulations that are grouped (examples below)
   2.   Keep the articles of the CPDWR together as one regulation (with articles organized as noted above)
   3.   Make each article of the regulation its own separate regulation

 

For more information on this issue and to view the results of the survey, click here

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The final series of stakeholder meetings for the Increased Readability Rulemaking for the Colorado Primary Drinking Water Regulations were held on May 7th and May 9th. The Safe Drinking Water Program encourages all interested parties to participate and provide comment on the proposed revisions to the Colorado Primary Drinking Water Regulation.

Read the Proposal:  2014 Proposed Revisions to the Colorado Primary Drinking Water Regulations pdf file

View the Stakeholder Presentation:  Final Stakeholder Meeting Presentation - CPDWR IRR pdf file                                                                                            

Review Stakeholder Comment Resolution:  IRR Final Stakeholder Meeting Comments May 2013 pdf file                                                                                         


Denver Meeting

Date:
Time:
Location:

Tuesday, May 7, 2013 (Complete
8:30 am - 12:30 pm
Daniels Fund Building
101 Monroe St.
Denver, CO 80206


Conference calling access information:
Dial-in Number: 1-877-663-3863
Conference ID: 6923500

Webinar access information:
URL: https://www.livemeeting.com/cc/cdphe/join?id=DN7SJ7&role=attend&pw=GKxPd.BG3
Meeting ID: DN7SJ7
Attendee Entry Code: GKxPd.BG3


Grand Junction Meeting

Date:
Time:
Location:

Thursday, May 9, 2013 (Complete)
8:30 am - 12:30 pm
Clarion Hotel
755 Horizon Drive
Grand Junction, CO


Conference calling access information:
Dial-in Number: 1-877-663-3863
Conference ID: 6923500

Webinar access information:
URL: https://www.livemeeting.com/cc/cdphe/join?id=5FMFGF&role=attend&pw=GKxPd.BG3
Meeting ID: 5FMFGF
Attendee Entry Code: GKxPd.BG3


Participants should register to attend at geteams.com as capacity is limited. If you are unable to attend in person, you may participate via webinar access and a conference call number. Registration is not required to participate via webinar/conference calling.


What to expect: The final proposal for review is posted on this website. Please review the draft language to verify that the goals of making the CPDWR more clear and easier to read were met. At this time, whether or not you will be attending, an online comment form is available so that you may provide written comments prior to the meeting. The comment form will remain available until May 16th for additional comments you may have.

To provide comments online please use our comment form.

The Water Quality Control Commission rulemaking hearing is scheduled for November 4, 2013.

Questions? Contact: Julie Kreyche
Email: julie.kreyche@state.co.us
Phone: 303-692-3405