OHA Drinking Water Services
Contact Report Details

PWS ID: OR41 01361
Who Was Contacted: Steve Klein
Contact Phone: -- (Email address hidden)
Contact Date: 03/12/2020
Contacted By: PARRY, BETSY (DWP)
Contact Method/Location: Email
Assistance Type: OTHER REGULATORY - Not a purchasing system if connect to Brookings
Reasons: Operations
Details: Rainbow Rock Service Association (RRSA) has been looking into connecting to the City of Brookings water lines and discontinuing use of their surface water source. Initially, I thought they would become a purchasing water system at that time. However, during the last few months, a Drinking Water Services rule interpretation has been expanded which clarifies the situation. I sent this rule interpretation to Steve Klein and we've emailed back and forth to clarify how it fits.

The determination is that if RRSA connects to the Brookings distribution line, it would become just another connection and NOT a purchasing public water system because:

- RRSA would not add any other sources or treatment; and

- The water consumers are all located on one parcel of property. Although composed of a few adjacent tax lots, the area served is considered one continuous parcel owned by a single entity - the "Pacific Vista Condominium Association." One tiny point: the Rainbow Rock Service Association was formed to serve the condo association, but both associations have the same membership = all the condo owners.

- Whether the association submeters and bills its membership according to their water use does not figure into this determination. (This point was clarified both by the EPA and the DWS Rule Interpretation.)

Steve says this potential switch to City water is still being considered. But progress is very slow while they investigate various options.

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