How Utility Mergers and Acquisitions Affect Backflow Testing Programs

When a water utility gets acquired by a larger regional authority or merges with a neighboring system, most customers notice small things — a new logo on the bill, a different phone number for customer service. What they don't always notice is that the backflow testing program they've been complying with for years may have just changed in ways that could put them out of compliance. For property owners, facility managers, and business operators, understanding what happens to cross-connection control programs during utility transitions is a practical necessity, not an administrative footnote.

A water utility operations center with technicians reviewing compliance maps and cross-connection control documentation on large monitors

Why Mergers Trigger Program Changes

Water utility mergers are more common than most people realize. Smaller municipal systems — often unable to meet tightening EPA water quality mandates or aging infrastructure costs — regularly consolidate into regional authorities or are absorbed by larger investor-owned utilities. When that happens, two separate regulatory frameworks suddenly need to become one.

Every utility runs its cross-connection control program according to a written plan approved by the state drinking water regulator. That plan specifies which properties require backflow prevention assemblies, what device types are acceptable, how often testing must occur, and which certified testers are approved to submit results. When two utilities merge, one of those plans will typically govern the combined service territory — and it may be stricter, or require different device types, than what you've been following.

The acquiring utility is almost always the one setting the new standard. If your old utility allowed a double check valve assembly on an irrigation system and the new one requires a reduced pressure zone device on the same hazard category, you may receive a compliance notice requiring you to upgrade your device — even if you just tested and passed last month.

What Changes for Property Owners

The most immediate impact is usually testing schedules and approved tester lists. Utilities maintain lists of certified backflow testers who are authorized to submit results on behalf of customers. These lists are not automatically interchangeable across utility systems. A tester who was fully approved under the old utility may not appear in the new utility's database, and results they submit may go unrecorded.

This creates a real compliance gap. A property owner who schedules their regular annual test with the same tester they've used for five years could receive a non-compliance notice simply because that tester hasn't registered with the new utility administration. The test happened. The device passed. But the paperwork went nowhere.

Plumber in safety vest testing a large reduced pressure zone backflow preventer on an exposed pipe outside a commercial building

Device approval lists also change. Utilities publish lists of assemblies that are approved for use within their service area, often based on testing by the Foundation for Cross-Connection Control and Hydraulic Research at USC. When a utility transitions, their approved assembly list may differ from your device's current listing. Older devices that had grandfathered approval under the previous program may need to be replaced under the new utility's stricter interpretation.

Testing frequency is another variable. Some utilities require annual testing; others require testing every six months for high-hazard facilities like hospitals, breweries, or irrigation systems with chemical injection. A merger between a utility with lax annual requirements and one with semi-annual requirements for commercial properties can immediately double your compliance obligations.

How to Protect Your Compliance Standing During a Transition

The first step is simple: contact your new water utility directly and ask for a copy of their cross-connection control program requirements. Most utilities post these documents online or will mail them on request. Specifically ask:

• What testing frequency is required for your property's hazard classification?
• Is your current backflow prevention assembly on the approved device list?
• How do you register an approved tester, and can you provide the current approved tester list?
• What is the deadline for complying with any new requirements?

Do not assume that because you were in compliance last year, you remain in compliance now. Merger transitions often include a grace period — typically six to twelve months — during which property owners are notified of new requirements and given time to come into compliance. But that grace period only helps you if you know it exists. Many property owners miss notices sent to billing addresses that differ from the service address.

It's also worth verifying with your current certified tester that they are active in the new utility's system. Many testers who operate across multiple service territories are proactive about this, but some smaller independent testers may not have registered with the new administration. If your tester isn't registered, find one who is before your next testing cycle.

When Utilities Fragment or Dissolve

Utility mergers run in both directions. State infrastructure programs and municipal reorganizations sometimes break large systems into smaller service areas, or transfer water service responsibility to newly formed special districts. In these cases, the new district often starts with a less developed cross-connection control program and phases in requirements over time. Property owners in these transitions may find themselves in a period where requirements are unclear or unenforced — but that doesn't mean standards don't apply.

EPA regulations and state drinking water program rules establish baseline requirements that apply regardless of which local utility administers service. The Safe Drinking Water Act grants states the authority to administer cross-connection control programs, and most states have their own plumbing codes and water code provisions that set minimum standards even when utility oversight is in flux.

Certified backflow tester kneeling beside a commercial irrigation backflow preventer assembly with test gauges and clipboard

Staying Ahead of Compliance Gaps

The safest posture during any utility transition is to keep detailed records of your backflow prevention equipment — device type, manufacturer, model number, installation date, and serial number — along with copies of every test report you receive. If a new utility disputes your compliance history, that paper trail is your best defense.

Working with a certified tester who operates across multiple utility jurisdictions is a significant advantage. These testers understand how to navigate the administrative differences between utility systems and can often flag potential compliance issues before they become formal violations.

When water systems change hands, your responsibility to protect public drinking water does not. Understanding that the rules may have shifted is the first step to making sure you're still on the right side of them.

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Sources

• U.S. Environmental Protection Agency. Cross-Connection Control Manual. EPA 816-R-03-002. Office of Water, 2003.
• American Water Works Association. M14: Recommended Practice for Backflow Prevention and Cross-Connection Control. 4th ed. Denver: AWWA, 2015.
• California State Water Resources Control Board, Division of Drinking Water. Cross-Connection Control Program Requirements and Guidance. Sacramento, CA: SWRCB, 2020.