For Oregon’s Clean Water Services, Digital Transformation is About Smarter Watershed Management

Located on the Tualatin River Basin, Clean Water Services in Oregon serves a population of over 600,000 residents in urban Washington County and businesses including Nike and Intel. A fitting name, Clean Water Services is internationally recognized as a leader for holistic watershed management, and a One Water approach that integrates wastewater and stormwater collection and treatment.

But it wasn’t always this way. This is the story of how a polluted river, reduced to just a stream, spawned what today has become one of the most innovative water systems in America.

In this article, we’ll dive into key lessons from CWS’ digital transformation, and how it flows from a commitment to watershed restoration.

Necessity breeds innovation


In the late 1960s, Washington County’s water was in crisis. The Tualatin River, the area’s only river, was choked with pollution. Twenty-six treatment plants were discharging contaminated wastewater into area streams, provoking a moratorium on any new development in the region. The viability of the entire region was in question.

In the summer, the river was so small in some places, you could stand across it.

By 1970, the people of Washington County voted two-to-one in favor of creating a regional sewer utility—one of the first in the state. The vote signaled the community’s early commitment to protecting public health and the local environment through clean water.

And now…

Fast forward to today, and Clean Water Services’ CEO Diane Taniguchi-Dennis will tell you that everything the organization does aims to protect public health while enhancing the natural environment of Oregon’s Tualatin River Watershed. 

That means that CWS’ job doesn’t stop at the treatment plant: it includes building salmon habitat, planting a canopy that mitigates evaporation, and offering conservation education.

As organic as it all might sound, these initiatives aren’t driven by intuition. They’re backed by cold, hard data, and a commitment to innovation. 

For Washington Country, there’s no other way: this is about securing a safe water supply for generations to come. 

Digital transformation requires culture change

In an industry historically focused on pipes and pumps, CWS has learned to stop viewing itself as a team of engineers, and instead as 400 water entrepreneurs working together to leverage science and technology through the power of Mother Nature. 

“In my experience, significant sustainable advances in smart water are only possible through culture change,” says Taniguchi-Dennis. “It’s really about a mindset focused on learning, thriving, and growing that drives digital transformation.” 

The defining features of CWS’ culture of innovation include: 

  1. Practicing agility and change readiness.

  2. Becoming less hierarchical and more networked.

  3. Bridging gaps between different subject matter expertise via multidisciplinary project teams.

It’s a commitment that cascades across every level of the organization, but is perhaps best illustrated by the tech team.

Transform IT into a Digital Solutions team

Innovating at the watershed-scale depends on having the right leaders around the table. That’s why CWS has transformed its IT department from a service center into a strategic business partner. 

The Digital Solutions team, led by Dr. Ting Lu, is a confluence of Information Technology (IT), Operations Technology (OT), and Engineering Technology (ET) that supports the organization on everything from permit compliance to optimizing water for the region. 

This team’s impact has been transformative, having introduced:

  • Dashboards to support transparency & decision making throughout the district

  • Real-time controls to optimize storm runoff capacity 

  • Automated vehicle-locator technology, sewer sensors and GIS data integration for data driven operations 

  • Technology to optimize basin planning and risk management

  • Virtual collaboration and learning platforms

  • Open-source, low cost IoT sensor solutions

And they’re not stopping there. 

Dr. Lu shared her vision for the next decade: “We would like to be using smart water and digital twin systems to provide insights and operational and planning decision support to not only our gray infrastructure, but also integrating our green infrastructure, natural systems and the watershed together at scale.”

Start with the basics

Like any good digital strategy, CWS started with the basics: compliance.

In 1991, the organization was targeting an aggressive Total Maximum Daily Loads (TMDL) target of 0.1 milligrams of phosphorus per liter, which meant they needed to be operating some of the most advanced wastewater treatment facilities of the time. 

The effort was so paramount, it provoked its own sing-song slogan: “Point one in ninety one!

So, when CWS later ran into a thermal compliance issue based on excess ammonia in the water from fisheries, they saw the opportunity to rise above their regulatory duty and take control of their own destiny. 

“We realized that just focusing on the water chemistry or water quality wasn’t going to be enough to really meet the promise that the Clean Water Act brings to us, which is fishable, swimmable, drinkable waters,” says Taniguchi-Dennis. 

Instead of putting chillers at the treatment facility outfalls—where the benefit would have washed away just a few miles downstream—CWS decided to look at the problem holistically across the watershed. The solution? Planting trees and shrubs along the river and its tributaries.

And thanks to innovation at every level—from financing and revegetation to partnerships that tap into new revenue sources—CWS has the resources to do so quickly. Where CWS could previously plant 2 million trees and shrubs in a decade, they can now reach that target in a single year.

“You have to get to a point where regulatory compliance is just one part of an output of what your utility does, but really your purpose, or the outcomes you’re trying to achieve, are so much greater than that,” says Taniguchi-Dennis.

“And that’s really what smart technology is starting to allow us to do. It’s allowing us to really hear what’s going on in the environment.”

The Ultimate Guide to Writing Your Utility’s Digital Playbook

The water industry is awash with tech buzzwords. Digital twin, smart water, biosensors, IoT, artificial intelligence. They all sound great. But for most utilities, these technologies are so far from the present reality that they sound more like a distraction than a realistic goal.

“I’m using a software system that was built in 1991, and you want to talk to me about smart water and biosensors?”

“We don’t have the money or the time to experiment with this right now.”

“We’ve been burned by Cisco before—how do we know this will be different?”

These common frustrations reflect two challenging realities in the world of water today:

  • On one hand, the world of work has changed, and so have the challenges facing the industry. But many utilities are making do with outdated, offline technology, and threadbare budgets.

  • Meanwhile, major technology providers selling data warehousing projects have missed the boat on water. They promised the moon and then failed to deliver. But the costs of those projects are permanently stained on the balance sheet. 

It’s time for a new approach.

You need a systematic way to tackle digital transformation in bite-sized chunks in a way that works for your organization. What you need is a digital playbook

In this guide, we’ll show you how to write your digital strategy and drive buy-in with a step-by-step approach.

Why you need a digital playbook

Future proofing your organization

Change is coming fast and furious. 

About a third of the water workforce will retire in the next few years. Much of the knowledge and processes we rely on are currently trapped in those workers’ desk drawers, corkboards, spreadsheets—or worse, their heads.

Meanwhile, the nature of the work is getting more complex: regulations are more stringent, and weather patterns are less predictable. 

You can’t afford to work with tech that doesn’t work.

Finding the middle ground

Moving closer to the water utility of the future doesn’t involve moving a massive boulder. Instead, it happens brick-by-brick

There is a middle ground between the world of offline spreadsheets and the false promise of enterprise-scale data warehousing. Cloud-based tools can help bring mission-critical data out of Excel and into powerful dashboards, so your organization can act on those insights sooner.

How digital transformation happens

Tying innovation to organizational goals

Digital transformation without North Star goals will just result in more of the same. The key is to ensure your investments are being made with vision and purpose

All utilities share a universal goal: delivering clean and safe water. To do that today, and for generations to come, most utilities are looking to:

  • Capture efficiency gains to do more with less

  • Identify new opportunities for revenue capture

  • Engage the community 

  • Deliver excellent customer service

That means that any digital transformation project that’s worth its salt should tackle these challenges in some way or another.

Building blocks of change

There’s a reason that so many tech overhauls have failed: change is hard. And for that same reason, you can’t expect to leap from an Excel spreadsheet to AI-driven decision making overnight. To maximize benefit while minimizing disruption, you’ll need to approach transformation in stages. 

One framework we’ve found useful for thinking about this is the Data, Information, Knowledge, Wisdom (DIKW) Pyramid.

The DIKW Pyramid

The idea here is that you can’t move up the pyramid before laying the foundation—and the bedrock of every good digital strategy is data.


Data is the lifeblood of our connected world, increasingly defining how our industry plans, understands, and executes projects.
If you’re just starting to experiment with digital transformation, removing data from silos and making it more accessible to everyone in your organization—i.e. freeing it from the C-drive or the desk drawer—should be the target.
It’s important to keep in mind as well that more data isn’t necessarily better. It might be that what your organization actually needs most is a data diet, i.e. a sustained effort to become more specific and intentional with the data you do collect.


Of course, data is meaningless without context. 
For example, let’s say you’ve just spent the last few weeks collecting cost data. Without labels—i.e. ‘who’, ‘what’, ‘when’ and ‘where’ each cost is occurring—that data is just a series of numbers: “$5,876.46,” “$447.64,” “$77.89.”
To make data work for us, we need to ask it questions. And when that happens, data becomes information. It starts to tell us things about our organization that we didn’t know before—like which parts of the business are the most or least expensive to operate.

Knowledge and Wisdom

For that information to become something we can act on, we need to know why and how those things are happening. When we ask those questions, information turns into knowledge and wisdom.
In the water world, this part of the DIKW pyramid is where we’ll be able to use things like artificial intelligence and digital twins to make predictions. But that’s a bit beyond the scope of this guide: we’re focused on utilities that are just starting to grapple with data and how best to start metabolizing it.

The important thing to remember here is that the tools you use to make decisions about your organization—whether management tools, artificial intelligence, etc.—are only as good as the data and information you feed into them.

You can’t jump from “data” to “wisdom” overnight. But by asking the right questions and being intentional with the data collected, you can make steady incremental progress towards that goal.

Executing the Playbook: Procurement

We’ve already mentioned how digital transformation is best handled in small, easy to manage, confidence-boosting chunks, rather than messy system-wide overhauls. 

Incremental change is king, and that applies to procurement and implementation, too.

But if multi-year tech installs aren’t the way to go, what’s the alternative? If you ask us, it’s pilots.

Pilots 101

Pilots have become the new gold standard for tech acquisition within municipal utilities because they’re lower risk, more manageable, and can help drive buy-in among teams that are resistant to sweeping changes.

To run a pilot, you’ll need to define project goals, involve key internal stakeholders, and pick a vendor that meets your specific needs and your budget.

Pilots don’t succeed every time—in fact, many of them won’t. Some utilities set themselves a goal of a 40% success rate for pilots. However high you do set the bar, the point is to not set it too high. 

Keep in mind that many utilities today have dedicated innovation budgets, and smaller scale pilots may run below the RFP thresholds, which makes it easier to get up and running quickly.

Picking a vendor: a checklist

With your game-plan set, the final step is to select vendors to work with.

Just as there is no one single perfect vendor for any one single utility, there is no universal rule for picking a vendor. This checklist, however, comes pretty close:

1. They understand the problem you’re trying to solve A good vendor should focus on your objectives, will spend time listening to your problems, and will demonstrate that they understand your particular needs. A bad vendor will spend more time talking about their specific product’s features, and will leave you feeling like they don’t really “get it.”

2. Selling a tool tailored to your utility’s needs One size does not fit all. Will configuring a tool for your needs end up costing more than the tool itself? When exploring vendors, don’t shy away from asking tough and pointed questions: that will help you determine whether the vendor really knows how to cater to a utility like yours.

3. Has a partnership mindset  Vendor support should be ongoing, not just at the time of install. It should feel like your vendor is on your side, that they’re available to help you when you need it—and not like they’re just trying to hand off responsibility and move on to the next project. 

4. Integrates with parallel systems 

New technology should reduce data silos, not create new ones. If it feels like a particular tool or implementation might be creating more problems than it’s solving, your vendor might not actually understand what your organization needs.

5. Searches for utility-wide benefits Digital initiatives should drive cross-departmental collaboration. Vendors should understand this and should be proactively looking for and suggesting opportunities, rather than just waiting for you to do so.


Although digital transformation represents an exciting opportunity for water utilities, implementing new processes and technologies takes time, money, and one resource that is particularly difficult to get back once you lose it: the trust of your team members. 

Instead of pursuing expensive and demoralizing data warehousing projects, utilities are far better off taking a pragmatic, gradual approach to achieving their smart water goals. Cloud-based solutions tailored to utilities’ needs make this new approach possible.  

With a digital playbook to guide your decisions, you can start driving change right now, not ten years from now.

Preparing for the Retirement Wave: How Technology Can Capture Permitting Expertise

How many people on your team are already planning for retirement? The silver tsunami cascading across the industry means that most water utilities are at risk of seeing institutional knowledge walk out the door. 

The transition can put serious pressure on your team. This is especially true when it comes to permitting, as employees who carry the essential know-how for specific protocol and day-to-day operations take that expertise with them when they leave.

Fortunately, by using smart, digital tools to document that knowledge and to systemize the permitting process, you can mitigate the risks that come with institutional brain drain. 

In this article, you’ll learn how technology can help capture the insights that currently live in employees’ brains so that you can develop a uniform, replicable process for managing permitting across the entire utility.

Why continuity planning is critical for permitting

When you need essential details about a specific type of permit, but the team member who knew it like the back of their hand has retired, it’s more than an inconvenience. 

Not only do you have to dig up, read, and parse the details of the permit; you’re going into the job minus all the hard-earned knowledge that your former team member provided.

And the stakes are high: missing a detail could lead to costly fines, or worse, public health risks. Take wastewater discharge that falls outside of NPDES criteria, which can rack up fines up to $25,000 a day—and that’s for the first offence.

Day-to-day, gaps in institutional knowledge:

  • Eat up time and energy as personnel track down key information 

  • Damage morale and lower internal confidence in your organization

  • Lead to patchwork systems that create more chaos later on

Plus, if your organization is mired in legacy software and spreadsheets, you risk alienating a younger generation that is more comfortable working in an online environment. 

Where offline documents fall short

Not all permitting systems are created equal. At many utilities, every manager has their own process for tracking permits. Permit requirements and renewals are tracked across spreadsheets, Word docs, and even on paper. Without a centralized place to see the status of all permits, it’s easy to miss something. 

Here are a few common challenges of managing permitting offline:

  • Relying on memory: Whether it’s knowing the specific criteria required for a specific type of permit; ensuring you’re not running a generator overtime; or getting ahead of permit renewals, so much of the permitting process tends to rely on memory.

  • Prone to duplications and errors: Files hosted locally on individual computers don’t sync up—meaning, that if Employee A makes changes to a spreadsheet, they won’t be reflected in Employee B’s copy. So, either A needs to send B an update, or mistakes are going to happen.

  • Lack of transparency: If your colleague were to win the lotto and not show up for work on Monday, how would you know to pick up where they left off? Managing permitting tasks offline often means relying on a lot of guesses, assumptions, and blind trust.

  • Not standardized: Team members often create their own private documents and spreadsheets to track tasks and manage information overload. Once that team member has retired, interpreting their files can become a headache.

  • Files are easily lost or corrupted: Local files are fragile. Even if you have your own in-house servers, they’re at risk of damage (natural disasters, malfunctions, negligence) or theft. If your entire organization’s knowledge base is hosted on a humming box kept in a storage closet, you’re much more vulnerable than you would be keeping your information in the cloud.

For many utilities, offline systems may work for now. But as soon as a new team member comes onboard, and needs to get up to speed, they have a massive task on their hands.

If your permitting system is leaving you at risk of missing something, it’s time to start looking at software solutions.

How digital permitting software supports continuity

When your employee ‘Mike’ is the only one who knows how to deal with a specific type of permit, or when the status of renewals is tracked on a spreadsheet on someone’s desktop, it creates risk for your organization.

Cloud-based software can help you systemize your permitting processes, making it easier to manage day-to-day tasks, interpret requirements, and flag abnormalities—all while ensuring your team will continue succeeding well into the future.

And, since so many teams in your utility have a stake in permitting, adopting a universal system promises to save time, increase collaboration, reduce the risk of error, and create greater visibility at every level of the organization.

Here’s how software can support continuity:

Documenting institutional knowledge

A single, unified system can help pass on Mike’s knowledge to other team members. 

When a new team member has a question about a permit, or when they need to confirm that all of the requirements are being met, they can turn to your permitting system and get the info they need. That saves time, and reduces the risk of serious errors.

Reducing risk

When it comes to permitting, tiny oversights can have big consequences. A generator left running overnight can lead to a six-figure penalty and a damaged relationship with the regulator. Digital tools can eliminate these kinds of risks by proactively triggering alerts for deadlines, exceedances, renewals, and more. 

Plus, an online system allows for increased transparency which introduces checks and balances within the team, so that one person isn’t responsible for catching every single mistake.

Managing workflows

Managing permits means tracking tasks, sticking to standards, and creating reports. Modern water utility software (like Klir) automates many parts of the process, while setting up fail-safes to make sure everything is completed on time. Instead of always double checking that you have all the information you need, or that you’ve checked every task off a list, you can focus on managing your organization.

Klir Demo Video

Simplifying permit renewals 

With all your permitting information in one place, it’s easy to generate reports, visualize data, and plan. Rather than waiting for a tidal wave of permit renewals to roll in, a comprehensive system lets you get a bird’s eye view of the work ahead, and allocate resources as needed.

What to look for in permitting software

Permitting software has the potential to make your job easier, reduce the likelihood of errors, and ensure the longevity of your organization. 

But what kind of software is right for you? Here are four key criteria to look for:


A solution based in the cloud, accessible via web browser, wipes out a lot of headaches by creating a single source of truth that can be accessed anytime. There’s no need to install and update software, and it’s easy to share info between team members without resorting to email. Plus, thanks to encryption and off-site servers, your data is secure.


General enterprise software, meant to be used by a wide swath of different companies and organizations, often requires customization that’s not only costly, it often means sacrificing on functionality. Aim to use a software that is specifically designed for your needs. 

Ease of installation

On-premise software systems typically charge a large fee up front to install locally on your servers. Not only does this cost you more money out of pocket, but it slows down the entire process of getting your system up and running. 

Try to choose a system that is easy to install or configure, and won’t leave you in the lurch for months as technicians work on it.

Hands-on support

When your whole organization relies on software for permitting, you shouldn’t be left to your own devices if problems come up. Make sure your software solution offers technical support from real, live humans with experience in water, who can answer questions particular to your industry.

Curious to see how permitting software works, and learn what it can do for your organization? Talk to a Klir specialist.

How to Automate Your Water Monitoring Plan

As regulations become more numerous and complex, water monitoring plans follow suit. Restrictive budgets and personnel shortages don’t make the job any easier.

How is your utility keeping up? With sampling responsibilities spread across different teams and individuals, and data constantly coming in from these different sources, how do you know you’re using resources efficiently?

Automating your water monitoring plan with technology can help you avoid errors, save time, and adapt to new reporting protocols. 

In this article, you’ll learn how to use automation to track and execute your water monitoring plan, so that your team will be ready for anything that comes down the pipe.

What does it mean to automate your water monitoring plan?

Sampling runs, lab tests, these are important jobs carried out onsite by skilled individuals. But the work that goes into scheduling those sampling events and consolidating the results? Those administrative tasks take up valuable time—and that’s where technology is well suited to play a role. 

With the right software, you can instantly analyze reams of sampling data, build out comprehensive and adaptable sampling schedules, and generate regulatory reports at the click of a button.

Why automate your water monitoring plan?

When you automate your water monitoring plan, you minimize the administrative work that’s involved. For compliance managers, those time savings can free up an entire workday every week.

Plus, an automated water monitoring plan can deliver benefits across the organization:

Break down data silos

If the Water Quality Department is maintaining Safe Drinking Water standards, another team is managing NPDES permit samples, and yet another team is managing samples based on customer complaints, how can you tell where these needs intersect and overlap? 

Automation creates a single source of truth, bringing all sampling activities into a single view. Information that once lived in spreadsheets or filing cabinets can now be made accessible utility-wide. Plus, your efforts go further: non-compliance sampling results can be easily attributed to overlapping regulatory reporting needs.

Manage timelines across multiple departments

As new sampling needs come up, an automated online schedule lets you adapt. Easily slot in new runs while ensuring that all other testing requirements are being met on time.

Simplify monitoring & reporting 

Online tools can unlock instant analysis of the raw data coming in from your LIMS. Then, generating a monthly report is as easy as clicking a button.

Rather than struggling with Excel or Word templates, where duplicate files and offline edits lead to mistakes, you can create standardized reporting templates that feed in accurate data from the same source every time.

Improve consumer confidence

With powerful tools to analyze sampling results in real-time, you can feel confident that you always have an accurate read on water quality. That means that when issues arise, you can mitigate the consequences with faster interventions and proactive communications.

And when it comes time to generate your annual Consumer Confidence Report, there’s no scrambling to consolidate and reconcile Excel sheets. You have all the data you need—accurate, up-to-date, and accessible.

Tools to automate your water monitoring plan

There are many tools that you can implement to automate your water monitoring plan. Some software tools are purpose-built for the job, while other familiar tools like spreadsheets and basic online scheduling software can be configured to introduce some level of “automation”, despite limitations. 

If you have the time, resources, and expertise to set up a series of Excel sheets to track all your compliance tasks, for instance, it may be able to save your organization a lot of time and energy. Otherwise, these tools can end up being just “more of the same,” adding to the complexity of your current plan.

The following list weighs the pros and cons of both DIY and cloud-based digital tools for automating your water monitoring plan—many of which may already be in use: 


Use: Formatting and compiling reports


  • Compatible across multiple computer systems

  • Relatively straightforward to generate reports from templates


  • Will not automatically populate with reporting data 
  • Multiple versions of reports (drafts) can create confusion


Use: Collating data, doing simple calculations


  • Familiar to many users at your organization
  • Can be incredibly simple or very complicated, depending on user skill level and need


  • Difficult or impossible to integrate with other systems, such as scheduling software or LIMS
  • Typically must be manually updated

  • Offline or duplicate file versions introduce risk

Cloud-based scheduling apps

Use: Tracking sampling runs and frequency


  • Cloud-based scheduling software lets you share schedules between multiple teams and individuals
  • Ability to create recurring events


  • Information is separate from where sampling data “lives”

Purpose built cloud software (eg. Klir)

Use: Task-management including scheduling sampling runs, analyzing water quality data & automating reporting


  • Introduces single source of truth with all sampling data in one location
  • Integrates with LIMS and other systems

  • Accessible utility-wide, with the ability to set permissions, schedule and assign tasks

  • Automatically generates reports from data

  • Delivers automatic alerts for crossed thresholds

  • Can be easily modified and expanded by users to adapt to new sampling requirements

  • Tailored to water utilities


  • Possible pushback from individuals accustomed to spreadsheets and traditional methods of scheduling / data management
  • May require organizational changes as processes become more efficient

Steps to automating your water monitoring plan

Here are six steps to follow when automating your water monitoring plan:

1. Identify sampling needs across your organization

Document where and when sampling events are occurring across the organization for both regulatory or non-regulatory purposes. Part of this process may involve connecting with different departments, interviewing key personnel, and learning about their goals—as well as the difficulties they face.

Some tools are built to help you compile and systemize these requirements, so your software supplier may be able to help with this step. If you’re taking the DIY route (say, using Excel), this work may involve consolidating documents on a single internal server.

2. Feed in data inputs

Determine how your system is going to connect with your LIMS and the other places data “lives”. Do the tools you’re using allow you to automatically import LIMS data? How will other sources of information, like SCADA, integrate with your system? 

If this information is online, the goal should be to feed the data directly into the system through a secure intermediary (typically called an API). Purpose-built software like Klir can pull this data in automatically. If these data sources are air-gapped, you might need to identify which personnel are responsible for providing the raw data imports on a regular basis (say, nightly). 

3. Document your processes

Different sampling requirements have different processes—in terms of frequency, types of testing and reporting, chains of custody, and practical matters of access for technical operators. 

To automate your monitoring plan, you’ll need to document the process for each sampling event within your organization.

Then, make sure the personnel involved have access to this information, ideally within the system that you’re using to schedule jobs.  

4. Set alerts for important thresholds

Any utility tracks for 90+ contaminants within a given year, and querying a spreadsheet is not only time consuming, it exposes you to the risk of missing something.

With an automated system, you can set parameters so that the system will proactively alert you any time the levels are approaching or exceeding a limit. When silence is a good thing—when your system isn’t telling you your levels are in danger of crossing the line—you can rest easy. 

5. Schedule sampling jobs

Once you have all of your sampling requirements, you can create a master schedule, with filters for different departments, types of reporting, etc. 

Your master schedule will include samples that must be taken weekly, monthly, quarterly, and yearly. This will be a key reference point to assign tasks and work orders. That’s why the option to filter specific reporting requirements or create sub-schedules is key—so every individual can find what they’re looking for, without sacrificing insight into the schedule as a whole.

Of course, sampling schedules change, so a truly automated system should be able to account for contingencies and reallocate resources accordingly.

6. Generate reports

Finally, automation will let you quickly, easily, and consistently generate reports from the data that you’re constantly generating. Ideally, this step involves establishing a template once, so that the system can pull in accurate data from the same data input at any given time.


Automating your water monitoring plan saves you time, reduces the likelihood of errors, and improves communication at all levels of your organization.

While you can use tools to develop a DIY approach, automated systems like Klir are the fastest, easiest way to get up and running.

Ready to learn more? Talk to one of our specialists to learn about automating your utility’s water monitoring plan.

7 laws of Compliance Planning

Those who have seen me speak publicly or read some of my previous work may know how much I tip Compliance Resource Planning as being the next big thing not just in water, where it is now prevalent but in other sectors where it is emerging. I am often asked what are the core principles when in comes to CRP implementations in Water so I have decided to write down what I see as the seven universal principles of CRP systems. The beauty of the internet is I get to revise and add to these rather than committing to ink so please do input with your thoughts and experience!

1. Compliance is your North Star

This doesn’t mean every regulation you are forced to adhere to is right, correct, practical or a good idea. Very, very far from it. I would never suggest such a thing! But the spirit of the regulation and your corporate objectives must be tightly aligned.

A great example of this is the water sector. The Safe Drinking Water in the US aims to do exactly what it says, make drinking water safe for human consumption. Is its interpretation or how it manifests in permits always right? No but the core objective of a water utility and the regulation is the exact same. Compare this with a mining operation whose core objective is profit first and foremost. It operates in a space with a variety of regulation which is at odds to this core purpose. Therefore implementing CRP would not work as it isn’t aligned to the companies North Star. If it was a triple bottom line company or a certified B corp then CRP would work but not a strict profit only entity.

You must be intellectually honest with yourself and your colleagues to truly ask if your organizations mission & culture is the same as the regulation which dominates your space.

2. Compliance Team versus Compliance Organization

In nearly every water utility I have seen worldwide, a compliance team or some variant of it exists. I imagine this came to pass when business consultants started designing utility hierarchy’s and took their inspiration from manufacturing. I know that’s what I did in a early stage of my career. The fact of the matter is this won’t work. It must be many peoples responsibility across your organization to do their job in a way which bubbles compliances up rather than retrospectively patching it.

Take the example above of a water utility versus a profit driven mining company. In the later, there would most likely be a Health and Safety or Compliance Team isolated from the rest of the operation. They would spend their time chasing data, enforcing processes and applying/maintaining permits so the rest of the team can get on with their day to day job. Unfortunately, as too often is the case, their peers don’t give them the respect they deserve and they are see as just another line item on their requirements list.

In a progressive water utility there will be an executive responsible for compliance and will work closely with the CEO/General Manager/Director. Their job is not to ‘do compliance’ but instead work it into the organization as a cultural and mission driven focus. CRP is the tool that does this and moves data & jobs around so that it is everyones responsibility

3. It is a stand alone system

If I had a nickel for every time I heard someone say ‘Sure we can just get our existing Asset/CRM/Operations/Legal (delete as appropriate) system to do that with some customization’ I would be the largest commodity owner of nickel-copper in the world. No one would dare suggest using the same pipes for sewerage and drinking water. Or to use a less extreme example, you wouldn’t use Excel to manage a cash register. Just because a system can use a feature for many use cases doesn’t mean it should. I often urge users to get the root of why this approach is suggested and in almost all cases it is because a huge budget was blown on implementing one of these systems that never quite worked. The sponsor (or someone ordained by them) is furiously trying to find a use for what they were mis sold.

A good CRP system promoter will say explicitly what it does do (manage X, Y & Z process) but also explicitly tell you what it doesn’t do. A simple test can weed out the bad system by asking can you put a process/area into it that has nothing to do with Compliance. For example, if you ask can you manage HR or Assets in the system and they say ‘Of course, YES!’ then run a mile.

4. Remove human error, not the human element

There is a great example of an AI competition that takes place annually pitting humans against computers. In one example, a AI system to detect cancer in mammograms was set against experienced radiologists. A computer has never beaten a human at this challenge and can detect cancerous cells correctly around 91% of the time. The human radiologist gets it right about 97% of the time. But the interesting thing is if your build a platform that ‘suggests’ detecting to radiologists which they then review, the accuracy goes to about 99.9%. This might only sound like a few percentage points increase but for anyone who has had the pleasure of learning about statistical distribution, this level of improvement is extremely impressive.

This is a very critical element of CRP and one that is particularly important in water. CRP will never serve to cut jobs. Instead it will free up your existing team that have incredible talents to more optimally and economically manage compliance. CRP will augment your users to make the best decisions more of the time rather than have them focus on cleansing data or reformatting excel sheets.

5. The system must continually iterate

A CRP system should be a system to records insights. That may sound extremely nebulous but if you critically challenge any proposed system and ask ‘Will this exponentially over time automatically reduce effort expended on work that doesn’t affect compliance?’ you will have a very good gut instinct. But what does this mean in practice?

With the modern tools available at low cost to software designers today every system should facilitate prediction of what tasks make a difference. This should be represented in a closed feedback look of Data->Decision->Outcome->Check. In one over simplified example, say you are receiving telemetry from a sensor and you make a decision to do something because of an undesired elevated reading, the system should record if the desired outcome was achieved through data (such as the reading being reduced on the telemetry system). If it did then the task should be auto suggested to users and if it didn’t then the system should learn that this course of action doesn’t work.

6. Very few barriers to adoption

A successful CRP implementation requires many users both internal and external to an organization providing data at different points of time. Some users spend every minute in the system and some see it once in their career and never again. If any element of this ecosystem breaks or is prevented from engaging then the CRP implementation will fail. The three most common barriers to entry I have see are:

Prohibitive licensing requirements. For example every user is required to have an expensive licence which proves impractical and cost prohibitive.

People need to adapt to the system rather than the system adapt to them. Of course some change is always required but fundamentally changing processes because of system limitations is a big red flag.

An extension of the previous point is extremely well thought out user experience. The system must be user obsessed and allow a variety of users (from technophobes using it once off, to expert super admins using it daily) extract maximum value with minimal effort.

7. Explicit, aligned success criteria

In almost all cases you should be using a vendor with specific domain and system expertise. This vendor’s success must be heavily driven off what you deem success and no more. Driving them down on pricing will mean they will be forced to recoup on consulting or change requests. Similarly if their measure of success is the amount of consulting days sold every year after implementation then it is a misfit.

Setting out what success looks like for you and your users early and often makes sure everyone is continually aligned. You should draw confidence from how they describe the approach they will take to meet your success criteria. If it is constantly pushed back as ancillary then they are not the right partner for you.

Jumping The Permit Compliance Hurdle

How could water utilities better plan for permit compliance? For any entity conducting business – whether it is providing a public service or selling a good – predictability is a key to long-term survival. You might not be able to control input cost changes, shifts in demand, or adverse events, but the better you can foresee and prepare for them, the more you will be empowered to ensure your sustainability.

As Goes Permit Compliance, So Goes Predictability and Sustainability

The sustainability of water utilities hinges on regulatory and permit compliance at the local, state and federal levels. If they cannot get permits, they cannot get off the ground to begin with. But maintaining compliance is the 800-pound gorilla. If permits are violated, utilities can often keep handling wastewater and providing drinking water, as these services are public health-critical, but violations are unsustainably costly on many fronts:

  • Fines can be huge and compound on a daily basis as long as violations are outstanding. Violations can also mean lengthy and expensive legal proceedings involving other government entities, interest groups, and citizens
  • More and more, they are the canaries in the coal mine giving the first notice of failed – sometimes catastrophically so – infrastructure
  • Since water utilities are monopolies and users cannot turn to other providers, the loss of public trust that violations engender can be profound, lasting decades and creating ripple effects up to the highest levels of an organization or government.

Treating Permit Compliance as a Product

All too often, water utilities see permit compliance as a hurdle they must jump to fulfill their mission: providing clean water efficiently and at a reasonable cost. In the worst-case scenario of breach of public trust, where permit compliance is seen as a hurdle, going around it is a possibility – unless and until caught. The Flint, Michigan water supply crisis happened in large part because the Flint Water Treatment Plant maintained permit despite officials knowing it could not provide safe, clean drinking water.

While clearly Flint Water did not plan for permit compliance as a primary product, too few water utilities do either. What if they did? Would planning a product that everyone depends on start to seem much more positive and predictable than jumping a hurdle or avoiding a punishment? Would it help managers and decision-makers feel more like empowered, responsible adults than guilty children?

For drinking water, wastewater and stormwater, permit compliance is a matter of keeping within standards for a wide range of contaminants (such as metals and harmful bacteria) and indicators of health (such as temperature and pH) – that is, maintaining acceptable quality. So many factors go into that – exogenous ones such as weather events and endogenous ones like infrastructure status. And with climate change, ageing assets and emerging technologies, more new and unexpected factors come into play every day, making planning more challenging than ever. So how can utilities plan for compliance as an end product? All signs point to data as a keystone.

Collecting the Right Data at the Right Time

It is no secret: water supply, wastewater, and stormwater utilities all know what their output is supposed to look like: clean water, which equals compliance. To get there, they need to know what is entering the system and when, what tools they need to use to create compliance, and what their measures of success are indicating – all questions that must be answered by gathering data that passes QA muster. Technology such as new types of sensors and even drones are making possible the collection of critical data in the field that just a few years ago would have been unimaginable, greatly leveraging the ability to gather data about what is coming into the system – typically the greatest challenge to compliance. The right data quality and quantity optimizes data-driven decision-making – which only makes sense to achieve a result (regulatory compliance) that is characterized by data measures.

Making Data More Powerful By Expanding Its Accessibility

A single utility may have dozens of different systems where compliance-critical data is kept, each with protocols and nomenclature known only to staff in specific organization units with highly specialized expertise. It is as if staff working towards the same goals just down the hall from each other were operating on different planets, and the message that only a certain few people – rather than everyone working together – are responsible for compliance.

Achieving consistent compliance rather than reacting to violations requires connecting dots and detecting patterns with a clear “line of sight” across all the organization’s data. But using multiple data storage applications stymies this line of sight, making it much more difficult to spot, investigate and respond to potential problems before they lead to violations.

Decisions are Easier and Better When They are Data-Backed

There is probably no water utility manager out there who never struggled over making a big decision when helpful or critical data was simply not available. Some of the most difficult ones are decisions around money – how much should be planned for future infrastructure, what level and what type of efficiencies should be targeted, how should rates be set? Though the connection may seem indirect, these funding decisions are the foundation to maintaining predictability and steady future compliance – and they are frequently finalized by government legislative bodies with no water utility expertise and a long list of other priorities. Rich data, with its significance put into sharp focus through sound and appropriate analytical tools, gives water utilities the best chance at decisions and their aftermath that will help realize predictability, and permit compliance, for the long-term.

Do you want to improve Environmental Permit Management in your organization? Talk to us and ask for a demo: our team of experts spend time with your team to better understand how you currently manage permit compliance and identify optimization priorities.