--- title: what source water protection already does for a utility canonical_url: https://ensurance.app/guide/what-source-water-protection-already-does-for-a-utility markdown_url: https://ensurance.app/guide/what-source-water-protection-already-does-for-a-utility.md subtitle: the plant treats what the land above the intake sends category: ecosystem-services --- # what source water protection already does for a utility *the plant treats what the land above the intake sends* The morning after a hard rain, the first number an operator checks is not on the plant. It is on the river. Raw-water turbidity tells the shift what the day will cost before anyone touches a valve: how much coagulant, how many backwashes, whether to slow the intake or close it and run on storage. The plant did not choose that number. The land above the intake did. That land is the supplier a utility has never signed with. It delivers every gallon the plant will treat, and it sets the condition that gallon arrives in. **Source water protection** is the name for keeping that supplier in a state the plant can handle. Most of it is already happening, whether or not anyone wrote it down. :::johnson **the plan is on file. the protection is on the land.** — A source water protection plan describes the land that drains to the intake. The protection is the condition of that land on the day the storm comes. [which job to do first on that land →](/guide/which-ecological-restoration-job-to-do-first?from=guide) ::: ## what source water protection is EPA's definitions are plain, and worth quoting because the phrase gets used loosely. **Source water** is water in rivers, streams, lakes, reservoirs, springs, and groundwater that supplies public water systems and private wells, before treatment. **Source water protection** is the set of actions that safeguard, maintain, or improve the quality or quantity of that water and the area that contributes to it. And the sentence that surprises people: there is no federal mandate requiring comprehensive source water protection. EPA says so directly. The program is largely voluntary. States run assessments, utilities write plans, partnerships form upstream, EPA says there is no federal mandate requiring a comprehensive source water protection program, and that the program is largely voluntary. The Safe Drinking Water Act did require source-water assessments, and the Clean Water Act still applies to the river. An assessment is not the same thing as a funded program on the land. That matters for how to read the rest of this post. Source water protection is not a compliance box. It is a description of the work that keeps a treatable river treatable. The plant is the regulated asset. The land above it is the reason the plant's job is possible at the cost it currently is. ## the protection area is the land above the intake For a surface water intake, the protection area is the land upstream that drains to it. A **watershed** is the land area from which water drains to a stream, river, or reservoir. Rain falls on a slope, moves through cover and soil and channel, and arrives at the intake carrying whatever the land let go of on the way. In a large watershed, that area is bigger than any utility can manage as one thing. EPA's guidance is practical: systems often split the area into zones, and focus on the land closest to the intake and on the upstream areas that actually send the problem. That second half is the part to hold onto. Not all upstream land matters equally. A burn scar far up a canyon can matter more than stable ground next door, because the burn scar is what moves when it rains. Zoning the protection area is a way of saying: here is the land whose condition shows up in my turbidity readings. It is a map of the supplier, drawn by where the problem comes from. ## three beliefs that stand in for the protection Each of these is common. Each one lets a document, a plant, or a regulator take the place of the land. ### "we have a source water protection plan, so we are protected" A plan is a document. It names the protection area, lists the threats, assigns actions. It is useful, and it is not the protection. The protection is the condition of the land that drains to the intake: the cover on the slope, the state of the channel, the ground that holds or lets go when it rains. A plan can be current while the land it describes has burned, dried, or been scraped. The reading at the intake follows the land, not the binder. ### "the plant handles it" A well-run plant handles a lot. Higher coagulant doses, longer settling, more frequent backwash, slowing the intake, running on storage. Those are real tools, and operators are good at them. Each one is also a cost that arrives because the land upstream stopped doing a job it used to do unpaid. The plant is where the bill lands. It is not where the condition is set. A plant that absorbs a bad day is proof of good operations, not proof that upstream does not matter. ### "if it mattered, someone would require it" EPA states there is no federal mandate for comprehensive source water protection. That is a design choice, not an oversight: federal law regulates the water leaving the plant, and leaves the land above the intake largely to the utility, the state, and whoever owns and works that ground. Waiting for a requirement means waiting for a thing EPA has said is not coming. A utility that wants the land protected has to want it on its own account, because the plant's account is where the failure of that land shows up. ## what the land already does for the plant Here is what is in it for the utility, stated as the function the land already performs. | when the land above the intake holds | what the plant does not have to do | |---|---| | Cover and soil keep sediment on the slope | Dose and settle out the sediment that did not arrive | | Channel and floodplain spread a storm pulse | Slow or close the intake for a pulse that did not come | | Ground on a burn scar recovers its cover | Run the storm season on storage | | The land between storms stays in the condition the plant was designed for | Explain a raw-water spike to the board | None of these appear as a line item, because each is the absence of a line item. That is the whole difficulty. A utility's books record what the plant spent. They do not record what the land above the intake kept the plant from having to spend. A utility can underfund its own supplier for years and see nothing but good numbers, until the land changes. The second post in this series is about how to book that absence. ## one river, one intake The City of Rifle, in Garfield County, Colorado, takes its municipal water from the Colorado River mainstem. In 2020 the Grizzly Creek Fire burned in Glenwood Canyon, upstream on that river. The Post Independent reported on July 27, 2022 that USGS stations along the middle watershed usually sit at or below 200 NTU, rose above 600 NTU on July 20–22, then fell back under 200. NTU is a turbidity unit: how much sediment is in the water. The river supplies Silt, Rifle, and Parachute. The plant that slowed and replaced filters in that story is Silt's. Rifle takes from the same mainstem. This is not a claim that Rifle's plant failed. The Middle Colorado Watershed Council already monitors this reach and warns plants downstream. That warning is not the same thing as the condition of the slope, and the towns downstream are among the ones who receive its results. ## the test for your own intake Four questions. If the answers are in your head, write them down. If they are not, the plan is doing the standing-in. 1. **Name the river, reservoir, or aquifer.** Not "our source." The name. 2. **Name the zone that sends the problem.** Where in the protection area does the turbidity, the taste and odor, or the nitrate actually come from? Use EPA's zone logic: the land closest to the intake, and the upstream areas that actually send it. 3. **Name what the plant does when it arrives.** The operator knows. Put it in the same sentence as the zone, so the land and the cost sit next to each other. 4. **Name who already works that land.** A watershed council, a ranch, a forest district, a land trust. The protection is their day job before it is your plan. If you can answer all four, you can see whether the plan is standing in for the land. Naming the burn scar is not the condition of the slope. If you cannot answer the second one, the document is standing in for the land. For which job on that land to do first, and in what order, the paired services post walks through it: [which ecological restoration job to do first](/guide/which-ecological-restoration-job-to-do-first?from=guide). ## frequently asked questions ### is source water protection required by federal law? No. EPA states there is no federal mandate requiring comprehensive source water protection; the program is largely voluntary. Federal law regulates the finished water a system delivers. The land above the intake is left to the utility, the state, and the people who own and work it. ### what is a source water protection area? For a surface water intake, it is the land upstream that drains to the intake. In a large watershed, systems often split that area into zones and focus on the land closest to the intake and on the upstream areas that actually send the problem. ### what does source water protection do for a utility? It keeps the raw water in a condition the plant was built to treat. When the land above the intake holds, the plant does not spend on the sediment, the pulse, or the storm season that did not arrive. The benefit shows up as the absence of a line item. ### is a source water protection plan the same as source water protection? No. The plan is a document that describes the protection area and the actions. The protection is the condition of the land on the day it rains. ## what to read next The next post in this series asks what the fit looks like: [what natural capital solutions are for](/guide/what-natural-capital-solutions-are-for?from=guide), the match between the land above an intake and the job a utility already has. If you want the land side first, start with the paired services post, [which ecological restoration job to do first](/guide/which-ecological-restoration-job-to-do-first?from=guide). The river above an intake exists whether or not the utility has a nature program. A solution is the fit between that living system and the job you already have. [Ensurance](https://ensurance.app/?from=guide) funds the living system. It is not the org chart, and it is not a new department. ## sources [EPA — basic information about source water protection](https://www.epa.gov/sourcewaterprotection/basic-information-about-source-water-protection) — definitions of source water and source water protection; statement that there is no federal mandate requiring comprehensive source water protection [EPA — delineate the source water protection area](https://www.epa.gov/sourcewaterprotection/delineate-source-water-protection-area) — protection area for a surface intake as the land upstream that drains to it; zoning in large watersheds [Post Independent, July 27, 2022 — navigating the Colorado River's many colors](https://www.postindependent.com/news/navigating-the-colorado-rivers-many-colors/) — USGS mid-watershed readings over 600 NTU affecting Silt, Rifle, and Parachute ## the series 1. [what a business already gets from ecosystem services](/guide/what-a-business-already-gets-from-ecosystem-services?from=guide) 2. [an avoided cost is the benefit you can book](/guide/an-avoided-cost-is-the-benefit-you-can-book?from=guide) 3. what source water protection already does for a utility (this post) 4. [what natural capital solutions are for](/guide/what-natural-capital-solutions-are-for?from=guide) ## the other series 1. [what ecosystem services actually do for you](/guide/what-ecosystem-services-actually-do-for-you?from=guide) 2. [an ecosystem service benefit is a bill you don't get](/guide/an-ecosystem-service-benefit-is-a-bill-you-dont-get?from=guide) 3. [which ecological restoration job to do first](/guide/which-ecological-restoration-job-to-do-first?from=guide) 4. [when ecosystem services consulting pays for itself](/guide/when-ecosystem-services-consulting-pays-for-itself?from=guide)