Thus, systems that provide water through constructed conveyances other than pipes may avoid regulation as public water systems if, for some or all of their connections, the water is used exclusively for purposes other than drinking, bathing, and cooking, or other similar uses; the EPA Administrator or state primacy agency has determined that alternative water (e.g., bottled or hauled water) is provided for drinking and cooking and that this water achieves a level of public health protection equivalent to that provided by the applicable national primary drinking water regulations; or the EPA Administrator or state primacy agency has determined that the water provided for drinking, cooking, and bathing is treated centrally or at the point of entry by the provider, a pass-through entity, or the user to achieve a level of public health protection equivalent to that provided by the applicable national primary drinking water regulations. Households Using Water From Irrigation Systems Are Limited in Location and Number

According to EPA officials, California and Texas are likely to contain the largest concentrations of people relying on water from irrigation systems in the United States. Given the wide availability of irrigation water within these two counties and the lack of alternative sources, state and local officials believe that a significant number of these households are likely to be using irrigation water for at least some of the purposes defined as human consumption, such as bathing or washing dishes. Difficulties Exist in Determining Precise Extent of Reliance on Water From Irrigation Systems

Although precise data are not available, our review suggests that in both California and Texas, several thousand households are probably using untreated water from irrigation systems for one or more of the purposes EPA defines as human consumption, including drinking, cooking, bathing, showering, dish washing, and maintaining oral hygiene. Rather, such customers are, for the most part, believed to be buying bottled or hauled water for drinking and cooking or to be relying on point-of-entry water treatment units to process all of the water entering the home. While several types of financial assistance are available to offset the cost of some alternatives, in most instances these programs serve multiple purposes, and water suppliers will have to compete with other types of projects to obtain the funding needed to meet the new requirements. Overall, we found that the cost of buying bottled or hauled water for drinking and cooking ranges from about $120 to $650 per year. Considering the relatively low median income in some areas, some alternative water sources may not be feasible without financial assistance. For example, under the 1996 amendments to SDWA, irrigation districts and other special purpose systems that also have residential users must be regulated as public water systems unless they can meet certain exclusion criteria. To determine the number and location of households that rely on irrigation systems for some or all of their residential water needs, we gathered data using a case study approach in California and Texas. The state and local officials we interviewed in California and Texas also provided information on the sources and costs of the water used by households relying on irrigation systems and the cost and feasibility of alternative sources. To identify implementation issues that are likely to affect the states’ and irrigation systems’ ability to comply with the new definition of a public water system, we interviewed EPA officials responsible for developing guidance on the new requirements as well as state and irrigation district officials responsible for implementing the new requirements.
Why GAO Did This Study

Pursuant to a congressional request, GAO provided information on the: (1) location and number of households that rely on irrigation systems or other special purpose water systems for some or all of their residential water needs; (2) cost of the water used by such households and the cost and feasibility of alternative sources; and (3) implementation issues that are likely to affect the states' and special purpose water systems' ability to meet the new requirements.

What GAO Found

GAO noted that: (1) according to officials of the Environmental Protection Agency, California and Texas are likely to contain the largest concentrations of people relying on water from irrigation systems in the United States; (2) preliminary estimates by irrigation systems managers indicate that in California, in the counties where residential use of irrigation water is believed to be most prevalent, several thousand households are relying on such water for some or all of their residential water needs; (3) several factors make it difficult to obtain precise data on the extent of usage, particularly the uncertainty about whether and how water from irrigation and other special purpose systems is being used inside the home; (4) given the extensive availability of irrigation water within these Texas counties and the lack of alternative sources, state and local officials believe that a significant number of these households are probably using irrigation water for at least some residential water needs; (5) the vast majority of the households relying on such water in both California and Texas are believed by state, local, and irrigation system officials to be purchasing bottled or hauled water for drinking and cooking and using the water from irrigation and other special purpose systems for other uses; (6) residential users of irrigation systems currently pay from $100 to $700 per year for untreated water that is supposed to be used only for nondomestic purposes; (7) the cost of buying bottled or hauled water currently ranges from $120 to $650 per year; (8) other alternatives can be considerably more expensive and may not be affordable without financial assistance; (9) several factors affect the cost of treatment, including the quality of the source water, the terrain, the distance between residential customers, and the proximity of existing community water systems; (10) most residential users of special purpose water systems are located in areas with relatively low median incomes, but federal and state funding is available to help offset the cost of some alternatives; (11) both the difficulty of identifying residential users and the costs and technical issues associated with finding alternatives to irrigation water are likely to present major challenges to states and special purpose water systems when implementing the new requirements established in the 1996 amendments to the Safe Drinking Water Act; and (12) state officials also indicated that their ability to implement the new requirements would be affected by competing demands for the limited resources of the states' drinking water programs.