POATRI Water History 2009 – 2022
POATRI /Terlingua Ranch and its water supply is considered by the State to be a Transient Non-Community Public Water Supply System. Meaning we provide water to the public by various delivery systems but do not have metterd water lines delivering water to private individuals. We are bound by all governmental regulations to provide safe potable water through a system that meets all the current minimum code requirements.
In 1997, West Texas Consultants reported that our water system, at that time, lacked the capacity to meet TNRCC capacity requirements and the water system was constructed in the 70’s of salvaged surplus pipe that had now outlived its useful life.
Board Meeting Minutes, found, from 2009-2021 do not show any water conversations or reports until 2011. At this time we are in transition from the 3 Mile Well to the Smith Well as our primary potable water source.
From 2011 onward there are many issues with non-potable wells and work continues on the Smith Well and water line repairs. The TCEQ letter of August 16, 2018 outlines their disapproval of our Smith Well project.
Waters concentration of sulfates and total dissolved solids exceeds secondary constituent level.
The water is slightly corrosive
Well head in flood plane
Undersized water lines
Provide documentation on system piping
Provide documentation on ground tank
Well supply is undersized and additional water supplies will need to be developed.
Jacob Martin Engineers were hired to get us through the TCEQ approval process. To date we have not received that approval.
TCEQ Letter dated November 23, 2022 outlines further conditions and deadlines for implementation.
Conditions:
Only valid for 1 1/4″ line on road 4
loop existing 1 1/4″ line with adjacent 2″ in northern line by May 31, 2023- engineering drawings and photos by July 23, 2023
Must maintain 35 psi.
Exception only good for remaining service life of line. New line must meet current standards.
As-built distribution lines and appurtenances ( pressure tanks and shade structures) that have not been previously approved must be submitted for review and approval. ( must use licensed engineering firm). NOTE: Prior to any work contact Plan and Technical Review Section
To grant an exception for any other existing waterline we can avoid a 60 day pressure test by looping southern portion of 1 1/4″ line on road 4 is looped with the southern portion of the 2″ line on road 3 and the 3″ waterline along road 1 and road 2. Engineering analysis is necessary.
All exceptions are subject to review and if it is confirmed that public health, degraded service, or water quality is compromised, they can be revoked.
I have compiled all the available reports and comments in the board minutes from the Poatri.org website for the years 2009-2021. All Water Committee reports since the formation of the Water Committee can be found at the committee website poatriinthedesert.com. (News link)
In addition, for that period, I present the summarized the reports, comments and correspondence with TCEQ. A binder is available in the office to view these correspondence and Jacob Martin engineering reports.
Board Meeting
Water Reports 2009-2021
2nd Quarter 2011
“Waiting for a well house decision-we have cost estimates for material. Once the system is complete, it will be completely
automated and in case of power failure, would be able to gravity feed. Status of leaks was discussed also. Frank O
mentioned that we have worked mostly inhouse, and saved a great deal of money. Cost of water has been raised to 4
cents per gallon to pay for the pump that has been purchased for the non potable water. Estimated time to repay is
several months. Some discussion ensued regarding old wells. No decision made.
3rd Quarter 2011
Vanessa reported on the successful repair of a water leak last week, as
well as securing a contract for TCEQ TCR samples and overnight sample delivery.
4th Quarter 2011
“Our water record keeping has improved with our monthly samples being sent over night. Val is getting his Class D water
license. Vanessa has been in contact with the Brewster County Groundwater Conservation District in
terms of the Smith well coming online.”
1st Quarter 2012
Marbert Moore reported on the Smith Well status. The metal building has been fabricated and the fence to meet TCEQ security standards is in place. Next is the slab construction.
New Well-Marbert reported that the pump has been installed, tested and we are awaiting wellhead
piping and electrical. He also reported that there was a bad leak in the water line earlier in the month
that has been repaired.
2nd Quarter 2012
The water system has been doing well, only one recent leak. The maintenance staff will be installing the passive solar heating panels that were donated by President Marbert Moore
3RD Quarter 2012
The Smith Well work continues. The building is done, electrical work is now being done. The piping will be delivered next week. Our consulting engineer was here 3 days ago and said that after looking at the water analysis of the new well, we will have much less iron oxide in our water which has caused some brown water on occasion with the 3 Mile wells.
On October 18th, TCEQ did their 3 year inspection. John compiled all the paperwork for the inspection. We passed on all our water samples and have some minor paperwork, posting type of compliance to correct. In July, there was a TCEQ violation that has been posted on the website and at the office. The violation was a result of UPS being unable to deliver the sample on time and notification back to us that the sample had not been received came too late to deliver a second sample.
4st Quarter 2012
We’ve had numerous water issues in the last quarter. The Smith well, due to Marbert’s foresight and work, has had all the paperwork submitted by our consulting engineer, and is online with TCEQ being notified. The 3 Mile wells have had trouble. The little pump burned up, the big pump started cavitating, due to low water levels. These wells will remain as POATRI’s backup wells, and with the recent rains and
rest, we expect them to be fine as a backup water source. The non-potable well pump died around New Year’s eve. We replaced it on the cold and nasty evening of January 3, 2013, just before the snow storm.
1st Quarter 2013
1) Smith Well Renaming Resolution Carried on 2/3/13
4th Quarter 2014
We now need to look ahead at the water system. We need
a thorough survey of the water system and we need to be prepared for sticker shock. We might be looking at $75,000
to do it right.
2nd Quarter 2016
The Non Potable well seems to be keeping up with the demand, by adding daily restrictions and adding the pump tech, that helps us watch the re-charge time, and use of the well. I have prepared a water report for this meeting.
2016 WATER REPORT
This report has been produced as a result of the Non Potable well that went down in May of this year. As we move into 2017, we are seeing more and more people move to the desert, I have been here since 2005, where I started off in Redford, and bought land on the ranch in 2007. Since then I have seen many people come and go. Since 2012-2013 I have seen many more people come and stay. There are more commercial agriculture ventures, Air B&B’s, more people with livestock, and just more families in general moving into the area. The non-potable good system is being taxed daily. This has us looking into the future for sustainability here on the ranch. In recent weeks, the Study Butte/ Terlingua Main Well has gone down, and several private wells in the area have gone dry. Currently Terlingua / Study Butte area are under water conservation advisories.
There are a couple of options for long term remedies. Limiting the water to 500 gallons per visit, and 5000 gallons per day, has helped the well to maintain a recharge level consistent with what we are using. This is a band aid to help along our water supply. Of Course, Rain always helps.
So that brings us to what are our options as an association to provide water long term for our members. There is a piece of property that has come available next to the lodge that has a well, a main house, a pump house, and 12 rv spots. I have spoken with Arrowhead Drilling, and Kade will come out and inspect the well for us for $400.00 or $200. If we can catch him while he has another service call in the area. The property is the Bare Bones Camp Park. The listed price for this property is 135,000.
Also, there is another option, and that is to drill a new well. This report is to get you thinking about the future and where we are going to invest. To drill a new well, its $25.00 a foot for a 6inch hole, this includes, Grout, Welding, Cementing, PVC, Travel, and Picking a good site. There will also be a charge of $336.00 for a piece of steel surface pipe that has to be laid, if they encounter more gravel, then we may need another joint, (21ft) _ The Brewster County Permit for a new good cost 100.00. Then you would add the cost of a good house, and pump system separately. Wells can be expensive, and there are no guarantees that you will hit where you drill or far you will have to go to hit water.
Please be thinking of how we should proceed, and help protect our water source in the future. As of now, we will continue with the 500-gallon max load per visit, until further notice.
– Anita Goss Ranch Manager
3rd Quarter 2016
Anita, Linda, and I attended the August water board meeting in Alpine where their board discussed registering water wells.
Last Spring break the smith well had some issues keeping up with demand during 2 weeks of March. Arrowhead drilling came out, and suggested that we lower the pump at the smith well before busy season again. In Sept of this year, we had this done. The Pump was lowered 252 ft. We are now at 430Ft. When this was done, we had to go ahead and upgrade the size of the motor to 2hp. This should move us forward into the future without any more foreseeable problems. Also as of now the non-potable well seems to be doing good. We have had no other issues with slow recharging. I want to thank everyone for being patient with the water sales, and the delicate balance of providing water to ranch owners. As we look into 2017, if rain persists we will lift the 500. Gallon per visit rule. Right now, we are looking at a dry mild winter, and are considering keeping the restriction in place until Spring 2017. We will be working on water usage charts to present in the future, so we may track water usage.
4th Quarter 2016
Increase Water Rates for potable and non-potable water – increase rates as a way to maintain the sustainability of our resources here on the ranch. Do we raise the rates across the board? Would it be appropriate to have water rates separated by residential and commercial? There was a suggestion to have water rates based on usage. Source of water is well water. This year we had a lot of rain and a lot of usage. The non-potable well could not replenish and restrictions were put in place. The restriction would remain in place regardless of price. Current rates are non-potable is $.03 per gallon and the potable is $.06 per gallon. Is it possible to track by a per person rate? Currently water sales are tracked via a sign-up sheet. Proposed rate to go to $.05 per gallon for non-potable and $.08 per gallon for potable. Restrictions have helped to reduce the commercial use of POATRI’s limited non-potable water.
A water task force was appointed to study the water issue including education, water catchment, etc. The task force will look at all the state restrictions regarding water catchment. Steve Elliot volunteered to chair the Water Task Force. The task force will look at the different rates in the area, different ways of conserving water, restrictions and educating guests. Anita will help Steve do research and write a water conservation article for the newsletter. Jim Miller, Jr. will also participate on the water task force. Nestor Reyes and Alan Baker also volunteered to be on the task force.
A review of the reasons to increase water rates – we would increase water rates due to having an influx of new property owners and increased water usage. The P&L shows an increase of approximately 55% in water usage in 2016. The Brewster County Water Board is charging fees per half acre of water and we will have to start paying a fee for selling water. Anita wrote a report on the water board meetings that is on the News page of POATRI.org. Scroll down for the report.
Kathy moved and Marilynn seconded that as a result of increased water usage and increased Brewster County water board fees, be it hereby resolved to increase the potable water rate to $.08 per gallon and non-potable water rate to $.05 per gallon, effective immediately.
The Non Potable well seems to be keeping up with the demand, by adding daily restrictions and adding the pump tech, that helps us watch the re-charge time, and use of the well. I have prepared a water report for this meeting.
1st Quarter 2017
Water Conservation Task Force – Steve Elliott, Nester Reyes, Jim Miller, Jr. – Marilynn Anthenat reported that this task force was developed for three reasons: 1) to educate property owners and guests about the importance of conserving water; 2) monitor what county and state agencies are doing about water regulations; and 3) monitor what other entities selling water in the area are charging and if they are doing any rationing as they did in years past. Steve Elliott is chair and attended a water symposium meeting on April 22nd. Unfortunately, he was unable to be with us today. The Brewster County Groundwater Conservation District (BCGCD) is looking at having folks voluntarily report their wells; they are also implementing fees to entities selling water commercially. This is something we will continue to monitor. The BCGCD is having their meeting on June 15th. Anita Goss shared that there is a report on poatri.org on the blog page on the news tab.
2nd Quarter 2017
Thank you to Steve for attending the water board meeting in Alpine. He has spent considerable personal time traveling to meetings and researching the history of water catchment and ways to conserve water. If you have an interest in water conservation and would like to help on the water task force, please give Steve a call at the office.
Water Task Force Report
Brewster County Groundwater Conservation District
I did attend a meeting June 15, 2017 in Alpine. The ground water board issues permits for wells in Brewster County.
*750 feet from property line for commercial wells
*50 feet from property line for private wells
Was voted to help property owners to get wells. New rules for Sept.2017
District meetings are held on the third Thursday of each month at 9:00 am, at the conference room, 207 North 7th, Alpine, unless otherwise indicated
3rd Quarter 2017
Water Conservation Task Force by Steve Elliott, Nester Reyes and Jim Miller, Jr. Steve shared that the Brewster County Groundwater Conservation District has new proposed rates. There is a district meeting on October 30, 2017 in Alpine. Anyone interested in joining Steve on this task force please contact Marilynn or Steve.
4th Quarter 2017
Water Conservation Task Force: Steve Elliott, Nester Reyes. There was no report
The water system at the Lodge is also getting an upgrade. There are some key components that were planned to be put into place back in 2012, and now we can complete these items and upgrade the system.
1st Quarter 2018
February 20, 2018 – this conference call was to choose an engineering firm to properly permit the Smith well. Present were M Anthenat, R Bundy, Y Diaz, B Ellis, L Leaming, K Pothier, B Vogl. Absent were C King and C Small. Jacob Martin Engineering firm was unanimously hired as the engineering firm by the board members present on the conference call
March 29, 2018 – this conference call was to discuss the non-potable well issues and solutions. Present were M Anthenat, R Bundy, Y Diaz, B Ellis, K Pothier, C Small and B Vogl. Absent were C King and L Leaming. Water conservation measures and a limit on number of gallons per day were blessed. More information from the well driller was necessary. No formal vote was taken because of this conference call.
April 10, 2018 – this conference call was to hear the information from the well driller and act on that information. Present were M Anthenat, R Bundy, Y Diaz, B Ellis, C King, K Pothier, B Vogl. Absent were L Leaming and C Small.
The board present voted to authorize Anita to have a pump installed on the North wells as a back-up/emergency water source and road crew use.
1st Quarter 2018
The new well is complete, it is 300ft deep, and pumps 10gallons per minute with a static level of 95 feet. We will be working very quickly to get it working and online for sales. A special thanks to the Board of Directors for pushing the funding thru !
Water is a critical issue facing the ranch. The non-potable water well is not recharging quickly enough to keep up with demand. With the support of the Board, Anita implemented emergency water restrictions including weekly limits per household and daily sales limits. She initiated non-transferable water management cards to monitor usage and sales. Well drillers have done on-site evaluations of the existing well and provided options including fracking the existing well, drilling a new well next to the existing well, or drilling a new well at another location. UPDATE: The new non-potable well has been drilled and water was reached at approximately 300 feet at the rate of 10 gallons per minute. As a temporary conservation measure, water sales are increasing to a maximum per property owner account of up to 2000 gallons per month with no transfers and no carryover. Based on the recovery rate of the non-potable wells, ranch management may need to limit total water sales per day. There will be no water sales to non-property owners. People delivering water to other property owners must show written permission from that property owner for each delivery. Efforts to conserve water and become better stewards of this resource are being evaluated including additional water conservation measures, water catchment systems, water conservation in bathhouse and other ranch areas, and possibly increasing water rates. We welcome your input; please share your ideas and suggestions with Anita.
2nd Quarter 2018
Non-potable and Potable Water Conservation Update by Anita Goss, Manager – The new well is doing well. There are continued conservation measures being done i.e. locking down water bibs around the property, adding controls as it relates to conservation. Notices have been placed in the rooms, changed the filter in the pool. Looked into water collection for use in the office/laundry. We are unable to do it as we are a public water system. Not looking at coin op showers at this point but are looking at other options for the showers. Anita will put up signs and larger stickers for the rooms. Are we fixing leaks? Yes, we have two master plumbers on staff and they are attending to the leaks as they happen. Is the north well up and running? Yes, both are running and being used for non-potable backup. The smaller well is being used for road work.
TCEQ and water system improvements update: After reviewing the three bids received, the Board approved hiring Derek Turner with Jacob Martin Engineering. Although based in Weatherford and Abilene, they have experience with projects in our area including Lajitas and Study Butte Water Supply Corporation. Mr. Turner did an on-site assessment in March and has requested an extension on TCEQ’s compliance deadline to correct concerns and submit as-builts. On April 4 we received an update that TCEQ had only granted an extension until the end of July and Mr. Turner stated he will push to meet the deadline. On June 6, 2018 Mr. Turner submitted his engineering report to TCEQ. His report included a response to the 02-16-18 letter from TCEQ, map and sanitary control, record drawings, property deed, State of TX well reports, U.S. Geological survey 7.5-minute topographic quadrangle map, pump test, bacteriological analysis reports, and a chemical analysis.
3rd Quarter 2018
TCEQ Well Status – We have small issues with the Smith well regarding regulating pressure. We are working with Arrowhead Drilling to get pressure regulated.
TCEQ and water system improvements update: On August 16 we were notified by TCEQ that they had received Mr. Turner’s response to TCEQ alleged violations and provided the as-builts. At that time, TCEQ was unable to approve the well until additional issues were resolved. The ranch is diligently working on clarifying the issues and rectifying them. Recently, on Oct. 1st, Mr. Turner sent a letter to TCEQ including responses to TCEQ’s comments regarding sulfate level monitoring, height of wellhead, system certification, and well pump capacity.
4th Quarter 2018
TCEQ Well Status by Anita Goss. The non-potable well is doing good – less minerals – better water. We haven’t had any issues since the new non-potable was dug. The old non-potable well is still online and can be used in tandem with the new well if necessary. Smith Well permitting with TCEQ. We were assessed a fine of $168 due to the well not being properly cemented. It is now. We will be conducting ongoing testing of the water from the Smith well.
TCEQ and water system improvements update: Mr. Turner notified us on January 7th that he had begun the process of complying with TCEQ’s ordering provisions. Per agreement with TCEQ, water quality testing will be done on a monthly basis for 36 months. TCEQ charged a minimal fine of less than $175.
1st Quarter 2019
Anita reported she is waiting on approval from TCEQ for the as-built plans on the Smith Well.
Anita also reported water sales from 9:00 am to 1:00 pm, Sunday through Thursday. Water will be limited to 500 gallons per week per property owner account.
A couple of weeks ago the non-potable well was depleted and is extremely slow to recover. Anita and her team quickly put “plan B” into action and within a couple of days water was available to our residents and nightly rentals. In 2018, the board authorized the well, called the “north well” to be brought back on line for back up to the current non-potable well.
The Non-Potable water sales are still operational although we have moved the operation to the 3 Mile Well or otherwise known as the north well. We are currently selling 500 gallons max to property owners per week, per member account. If you have someone hauling water for you. Property owners must send written permission to the office to place on file for our records. For now, water sales are limited to 9am to 1pm Sundays thru Thursdays. We are
looking to put in a token operated water dispenser for long term operations. We are in the process of sourcing a system out that will be suitable for POATRI. This token system will more than likely be more like a magnetic card that can be pre-filled at the office and used at the property owner’s convenience. We will keep you up to date on the water system as things change.
2nd Quarter 2019
TCEQ update – Anita reported that we are still waiting communication from TCEQ regarding
next steps necessary to permit the Smith well.
TCEQ is still working with us to get the water system up to date, I have nothing new to report at this time.
3rd Quarter 2019
On Sept. 16th we received. A signed copy from TCEQ for the agreement that was approved by the board back in January of 2019. This has been an ongoing submission process to bring the Smith Well and the water system up to date. As of now we have no other actions to be taken. Everything has been submitted to TCEQ. We are awaiting TCEQ As built department to give us our next steps.
4th Quarter 2019
We continued working with TCEQ to receive final permitting on the Smith Well.
There was a question from a board member regarding the current water situation and the boil notice. It was a precautionary notice, following state guidelines. A water testing company is coming out May 7, 2020 to test designated wells for mineral content, contaminants, etc. After that meeting, we will have a list of all wells, level depth, water levels, and quality of water in each well. We will establish a flow chart based on this information.
1st Quarter 2020
Is Terlingua Ranch a public water system? There was general discussion with the board and attendees. One board member shared that the impression was that the lodge operation is a public water supply, but the non-potable is not considered a public water supply. Jay stated that his research has confirmed this impression. The Brewster County Groundwater District has a different definition and one board member thinks we do not meet their requirements for a public water supply. No clear understanding that if this is true, then what was the reasoning for TCEQ to require the permitting of the Smith well. Jay is looking at TCEQ requirements for non-potable water. Ranch staff has a regular water system meeting each week. We currently have no Class C water operator to sign off on the required monthly water testing. We are still in process obtaining a full picture of what is required. Not having a closed loop system, we may continue to have issues. We may need to start looking at other places to drop another well to support the increased residential owner use. Lack of water could shut us down faster than COVID-19. Jay will continue his research with TCEQ and our water system. We have a total of 6 wells. We had previously contracted with Jacob Martin Engineering company and Derek Turner, engineer. Brewster County Groundwater District is available to come out and monitor our wells. A water task force was established by the President. Jay, Rick, Guy Hopkins and Larry Sunderland are now members of this water task force with Rick as the chair of the task force. Commissioner Sarah Colando is available for assistance by email if needed. Rick will communicate with the board when this task force meets.
3rd Quarter 2020
Water Task Force Update – VP Chris King
A meeting was set up with Derek Turner of Jacob Martin, who has helped us with the as-builts and certification of the Smith Well, to follow-up on the certification with TCEQ of the Smith Well. As part of the certification we had to perform a year of testing concerning water quality and a few other things. Derek has taken our log results and is presenting them back to TCEQ (Texas Commission on Environmental Quality) with the anticipation that they will officially certify the Smith Well towards the middle to end of November. This is good news as it makes the well official with TCEQ.
There is additional work to continue with the Smith Well which is a lengthier project in multiple phases. Keven has hit the ground running with this must have project. It involves storage and a new pump. We will be installing a new tank next to the Smith Well and installing an external pump that will pump the water from the new tank and push it through our system and up to the tank on the mountain. The reason for doing this is that during peak, high usage times, the well was having trouble keeping water in the system at a decent pressure. The pump that is in the well has already been replaced once and this project will extend the life of the well pump. There will also be upgrades around the pump regarding water treatment. Derek is creating a project plan that includes the engineering drawings for the project and they will oversee the project.
4th Quarter 2020
Water Task Force – Larry Sunderland, Chair. Members are Rick Bradbury, Kelly Dayton, Scott Walker. Keven will provide the other names to Larry that have already volunteered to serve on the task force.
1st Quarter 2021
Water Committee:
Larry Sunderland has spent countless hours/days researching ranch water issues, State and Federal law and studied best practices used in desert communities to conserve water. Larry’s energy supporting Keven and educating the board will lead us down the path of enhancing our water services and building a solid foundation for water conservation here at the ranch. We all know water is gold here in the desert. If you have any interest in helping preserve this precious resource, place reach out to Larry to volunteer. He has a shortlist of like-minded individuals who can’t wait to join the Water Committee and begin leading forward.
Larry
Water System Notes
June 1997-Nov. 2022
West Texas Consultants June 18, 1997
3 Mile well capacity (10 gpm) is inadequate to meet water usage demands
Well will not meet TNRCC capacity requirements
Estimated cost to bring into compliance – $201,000
August 16, 2018
TCEQ letter of disapproval of The Smith Well
Waters concentration of sulfates and total dissolved solids exceeds secondary constituent level.
The water is slightly corrosive
Well head in flood plane
Undersized water lines
Provide documentation on system piping
Provide documentation on ground tank
Well supply is undersized and additional water supplies will need to be developed
November 21, 2018
TCEQ letter setting out conditions for temporarily granting use of Smith Well
Well drilled for domestic use
Situated in a flood plain
Condition 1: Raw sample must be collected each month and tested by an accredited lab
Updated operations manual must be sent
Updated Manual must be on file in office
Exception will expire November 21, 2021
January 2019
Downloaded TCEQ document titled “Determination of Connections” and “Determination of Population Served”
June 27 2019
TCEQ Discussion of Inadequate system size (Document missing here)
September 10, 2019
TCEQ Agreed Order Docket No. 2018-1187-PWS-E
Agreed settlement
POATRi failed to notify and get approval for significant changes to water facilities
Failed to furnish a copy of well completion data
Ordering Provisions
September 13, 2019
TCEQ Letter deliveringTCEQ Agreed Order
October 25, 2019
TCEQ letter granting temporary exception until October 31, 2020
Condition 1: System must maintain a minimum of 35 Psi throughout the piping system
Must provide 60 days of continuous pressure monitoring data
January 21,2021
Must continue to comply with TCEQ exception dated November 21,2018
Concentrations of Sulphate and Total Disolved Solids exceed the secondary Constitutent level
They will arrange for the collection of an official sample
Additional treatment, blending, or public notice may be required
Chemical feeders shall have a standby or reserve unit
Oct. 25, 2019 addressing distribution line size expires on Octoberr 31,202
November 23, 2022
We are being granted an exception to minimum Water Line Size Requirements.
Conditions:
Only valid for 1 1/4″ line on road 4
loop existing 1 1/4″ line with adjacent 2″ in northern line by May 31, 2023- engineering drawings and photos by July 23, 2023
Must maintain 35 psi.
Exception only good for remaining service life of line. New line must meet current standards.
As-built distribution lines and appurtenances ( pressure tanks and shade structures) that have not been previously approved must be submitted for review and approval. ( must use licensed engineering firm). NOTE: Prior to any work contact Plan and Technical Review Section
To grant an exception for any other existing waterline we can avoid a 60 day pressure test by looping southern portion of 1 1/4″ line on road 4 is looped with the southern portion of the 2″ line on road 3 and the 3″ waterline along road 1 and road 2. Engineering analysis is necessary.
All exceptions are subject to review and if it is confirmed that public health, degraded service, or water quality is compromised, they can be revoked.