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Reworking the IPS (Improvement Priority System)

Get Involved

The stakeholder process is critical to us. We want to hear your thoughts and concerns over the next few months and adjust the concept, where needed.

Give Comments
Seeking comments through 10/15/19

IPS Rule Update Webinar

Additional Documents

Helpful Links

The Drinking Water Board authorized the Division of Drinking Water on August 27, 2019, to initiate rulemaking for revising R309-400, Improvement Priority System and Public Water System Ratings (IPS Rule). The anticipated implementation start date is January 1, 2020.

IPS Program

The proposed IPS Program document retains most of the current requirements found in R309-400 and reorganizes the deficiencies and violations and puts them into a table format. The IPS Program document identifies all deficiencies and violations with their associated types and point values. The content of the IPS Program document is anticipated to be incorporated by reference in the proposed rule R309-400 (Improvement Priority System and Public Water System Ratings).

New R309-400 Rule

The R309-400 rule will be repealed and a new rule re-enacted in its place due to substantial content change and reorganization of the existing R309-400. The new rule incorporates by reference the IPS Program document, which is a separate document that identifies all deficiencies and violations with their associated types and point values.

We anticipate presenting the new rule to the Drinking Water Board on November 5, 2019, for rule adoption if there is no substantive comment received during the public comment period of September 15 through October 15, 2019. The implementation of the new R309-400 rule starts on January 1, 2020. It will apply to all water systems in Utah.

Please contact Jennifer Yee at or (801) 536-4216 for questions related to the questions related to the new R309-400 rule.

To find out your water system’s current total IPS points:

The IPS rule was first finalized in 1996 as a tool for water systems to track compliance with violations and physical deficiencies. It helps systems understand the severity of any issues and maintain compliance. Water system operators can check the status of the current IPS points for their systems by going to, selecting the system and selecting IPS Report.

To find out your water system’s projected total IPS points after January 1, 2020:

DDW has created a new tool IPS2020 Report to help water systems to prioritize the deficiencies to be corrected and to prepare for the new R309-400 rule. The IPS2020 Report shows the hypothetically projected total IPS points for a water system beginning January 1, 2020. Water systems can access the IPS2020 Report by creating a account at and requested access to the Portal.

Frequently Asked Questions

Why is IPS changing?
  • The IPS rule has not been completely reviewed since 1996.
  • The IPS rule is unique to Utah. The revisions to IPS deficiencies will align better with EPA’s enforcement tracking and health risks.
  • The new IPS rule cleans up deficiencies that were duplicates and clarifies issues for each facility.
  • The revisions remove the possibility that credit points mask deficiencies.
What is the timeline?
  • Now through July 12, 2019, public comment period is open for the IPS2020 Program.
  • July 1, 2019, DDW will mail IPS2020 and Current IPS reports to all public water systems.
  • RWAU/DDW trainings for water operators on IPS2020: July 16, August 1, August 7, and September 17.
  • August 27, 2019, DDW Board Meeting to open official rule-making on R309-400 and adopting IPS2020 Program.
  • September 15, 2019, through October 15, 2019, public comment period for R309-400.
  • November 5, 2019, DDW Board Meeting to adopt final R309-400 rule.
  • Implementation starts January 1, 2020.
Why did my system’s IPS points change?
  • Points are now organized by facility instead of deficiency.
  • Significant deficiencies are now all at least 25 points.
  • Deficiencies identified in multiple facilities are counted separately.
  • To see the list of new point values for all violations and deficiencies, see the Documents section on this page.
My system’s IPS points went up, what can I do?
  • Address and correct the identified deficiencies as soon as possible.
  • Make sure the violations and deficiencies are correct according to your system’s records.
  • Send in any IPS corrections to
  • If your system needs an extension in time to fix a significant deficiency, The CAP is a Compliance Action Plan that extends the timeframe for fixing a deficiency. Once the fix deadline has passed the CAP is no longer an option.
  • If your system needs to request an exception, contact Nathan Lunstad at or 385-239-5974.

Who Can Help Me?

Physical Facility Points

Jennifer Yee
(801) 536-4216

Cross Connection Points

Gary Rager
(801) 536-4498

Treatment Technique Violations

Jennifer Yee
(801) 536-4216

Lead & Copper Violations

Luke Treutel
(385) 258-6084

Chemical Rule Violations

Emily Frary
(801) 536-0070

Source Protection Points

Deidre Beck
(385) 271-7046

Microbial Rule Violations

Sitara Federico
(801) 536-4195

Microbial Rule Violation (Code 36)

Randi Ryan
(801) 536-4170

Consumer Confidence Report

Brandi Smith
(801) 536-4210

Surface Water Treatment

Michelle Deras
(801) 536-4265

Exception to DDW rules

Nathan Lunstad
(385) 239-5974