Illinois EPA Requirements for Submetered Water from a Public Utility Company

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Does anyone know the Illinois EPA Requirements for Submetered Water from a Public Utility Company?

I am in the process of purchasing a mobile home park in Springfield, IL and apparently I am required to have a certified operator test the water that is being provided to my park by the Springfield utility company. Is anyone familiar with this requirement? Is this a real requirement?

I own a park in southwest Chicago that also has submetered water and I have not encountered this requirement at that park. Or perhaps this is just something I have not been aware of.

Thanks much for your help!

Jim

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Jim, I do not specifically know the requirements, but based on your first sentence, it seems that some of the terms may be conflated - EPA, Submetered Water, and Public Utility Company, in particular. Generally the EPA is worried about contamination. The Illinois Commerce Commission regulates Public Utilities and sub metering regulations and may have testing requirements. I would suggest you contact the ICC. They most likely have an expert who can answer your question better than anybody on this forum.

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Thank you for the recommendation! I will do that.

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EPA AND SUB-METERING;

As long as you are a re-seller (pass through of costs) of water/sewer and specifically not a producer (as in a providing well water or septic service) and there is no profit motive, MHP owners who sub-meter are exempt EPA over site.

Federal EPA standards and the Safe Drinking Water Act do not disallow sub-metering. Also the Congressional Records reflect in brief “there is empirical evidence that sub-metering promotes water conservation and the Safe Water Drinking Act should not discourage water sub-metering”.

Just remember you are a re-seller not an utility.

“We’re here to answer your sub-metering questions”

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Thanks, Dan. Very helpful. I am going to look into this further and let the IL EPA we don’t plan to continue this testing if it is not required of us as a re-seller.

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Did you ever get this resolved? I am under contract for a park in Illinois and my reading of the Manufactured Home Community Code is the same as yours (that owners with submetered communities are subject to the Illinois EPA regulations).

I believe Dan may be correct if referring to the US EPA, but not for the Illinois EPA.

The regulation as written in Illinois is:

If the system is connected to a community public water supply system and the residents are billed by the manufactured home community owner for the water based on the readings from the meters at each site, the manufactured home community owner is considered a water supplier and is subject to the requirements of the Illinois Environmental Protection Agency. The distribution system up to the individual service line to each home shall be subject to the requirements of the Illinois Environmental Protection Agency. (Type B Violation)

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Are you a member of the Illinois Manufactured Housing Association? If not, why not? They actually can lead you to the right answers, because some of the answers you are getting here are not correct and will get you in more trouble than you can handle. Not only do you have to answer to the State, but also either Sangamon County or the City of Springfield depending on your location.

IMHA has offices right across the street from the state capitol. The paid exec is Frank Bowman.

There are a number of IMHA Board Members who are dealing with this and quite a few communities where the owners themselves are Certified Operators.