Clean
Watershed
Needs
Survey
Office
of
Wastewater
Mangement
EPA
ICR
Number
0318.09
OMB
CONTROL
NUMBER
2040­
0050
February
2002
SUPPORTING
STATEMENT
A.
JUSTIFICATION
Section
1
Identification
of
the
Information
Collection
Title:

Clean
Watersheds
Needs
Survey
Report
to
Congress
ICR:
Clean
Watersheds
Needs
Survey
ICR
Number
0318.09
OMB
Control
Number:
2040­
0050
ABSTRACT
The
Needs
Survey
is
required
by
Sections
205(
a)
and
516(
b)(
1)
of
the
Clean
Water
Act.
It
is
an
inventory
of
publicly­
owned
wastewater
treatment
works
(
POTWS)
in
the
United
States
as
well
as
an
estimate
of
how
many
POTWs
are
needed
to
be
built.
The
Survey
is
a
joint
effort
of
the
States,
EPA
Headquarters
(
Office
of
Wastewater
Management
(
OWM))
and
EPA
Regions.
The
Survey
records
cost
and
technical
data
associated
with
all
POTWS,
existing
and
proposed,
in
the
United
States.
The
States
provide
this
information
to
EPA.
EPA
achieves
national
consistency
in
the
final
results
through
the
application
of
uniform
guidelines
and
validation
techniques.

The
burden
estimate
for
State
respondents
to
complete
the
1996
Survey
was
estimated
as
a
2­
year
effort
for
a
total
13,888
hours.
The
burden
estimated
for
1998
of
3025
hours
was
for
6
States
only
to
assist
in
modernization
of
the
CWNS.
A
total
burden
of
21,000
hours
(
for
the
total
2­
year
effort)
was
estimated
for
the
2000
Survey
which
reflected
an
increase
in
the
burden
for
information
collection
as
a
result
of
the
CWNS
modernization,
and
an
increase
in
the
number
of
POTWs.
The
modernization
included
the
collection
of
needs
for
nonpoint
source
pollution
control
and
geographical
point
of
record
data
(
i.
e.
facility
latitude/
longitude,
discharge
points
and
watershed),
as
well
as
training
on
the
newly
modenized
database.
The
Survey
is
now
being
conducted
every
four
years.
The
annual
burden
estimated
for
the
2004
Survey
is
7,
672
hours
for
the
56
respondents
to
allow
for
continual
data
updates
beyond
the
CWNS
collection
period
for
State
use
and
benefit.

1
2
Section
2
Need
for
and
Use
of
the
Collection
Need
for
the
Collection
EPA
provides
an
estimate
of
needed
POTWS
construction
requirements
for
each
State,
Territory,
and
the
District
of
Columbia
to
Congress
under
Section
516(
b)
of
the
Clean
Water
Act
which
says
in
part:
"
The
Administrator
in
cooperation
with
the
States,
including
water
pollution
control
agencies
and
other
water
pollution
control
planning
agencies,
shall
make
(
A)
a
detailed
estimate
of
the
cost
of
carrying
out
the
provisions
of
this
Act;
(
B)
a
detailed
estimate,
biennially
revised,
of
the
cost
of
construction
of
all
needed
POTWs
in
each
of
the
States...
The
Administrator
shall
submit
such
detailed
estimate
and
such
comprehensive
study
of
such
cost
to
the
Congress
no
later
than
February
10
of
each
odd
numbered
year."

Further,
section
205(
a)
of
this
Act
provides
that
"
allotments
for
fiscal
years
which
begin
after
the
fiscal
year
ending
June
30,
1975,
shall
be
made
only
in
accordance
with
a
revised
cost
estimate
made
and
submitted
to
Congress
in
accordance
with
Section
516(
b)
of
this
Act
and
only
after
such
revised
cost
estimate
shall
be
approved
by
law
specifically
enacted
hereafter."

How
the
Data
Will
Be
Used:

The
collected
data
support
cost
estimates
which
are
used
by
Congress
in
developing
allotment
formulas
for
the
distribution
of
funding
under
the
State
Revolving
Fund
Program
under
Title
VI
of
the
Clean
Water
Act.
The
Agency
uses
the
data
in
support
of
water
programs,
identifying
costs
to
clean­
up
and
control
pollution
in
watersheds
of
all
States
in
the
nation.

Section
3
Nonduplication,
Consultations,
And
Other
Collection
Criteria
Nonduplication:
We
avoid
duplication
of
effort
in
the
following
ways:
To
begin
the
new
Survey,
EPA
provides
each
State
their
exact
inventory
of
data
from
the
preceding
survey
to
update
and
make
revisions
to.
EPA
updates
only
the
cost
data
for
inflation
before
facility
data
are
made
available
to
the
States
for
review
and
update.
States
and
Regions
are
informed
of
the
cost
inflation
factor
applied
and
updating
procedures
at
the
EPA/
State
start­
up
Survey
meetings.

The
States
also
have
access
to
technical
and
cost
data
contained
in
the
Needs
Survey
data
base
from
previous
Surveys.
This
eliminates
the
need
for
States
to
provide
statistics
which
have
already
been
approved
and
ensures
national
consistency.
The
addition
of
geographical
data
for
each
facility
record,
i.
e.
latitude/
longitude,
city
and
county,
further
aids
in
nonduplication
of
data.
3
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
Public
comments
to
the
July
27,
2001
Federal
Register
Announcement
(
Attachment
A)
of
this
ICR:
We
received
no
response
during
the
public
comment
period
concerning
the
burden.

The
information
requested
in
the
Clean
Watersheds
Needs
Survey
(
CWNS)
is
collected
from
each
State
using
an
automated
online
data
system
in
a
windows
95
environment.
At
the
beginning
of
the
data
collection
period,
each
State
is
provided
two
user
manuals:
1)
a
technical
and
comprehensive
system
manual,
and
2)
a
user
manual
with
detailed
policies
and
procedures
specific
to
the
objectives
and
conduct
of
the
CWNS
2004.
At
the
end
of
each
CWNS,
a
report
is
written
and
published
highlighting
the
national
results
of
the
survey
and
describing
the
methodology
used
to
collect,
document,
and
quality
assure
all
of
the
State
data
included
therein.
The
Report
includes
many
tables
and
graphs
of
the
various
categories
of
needs
throughout
the
text,
as
well
as,
percentile
changes
in
environmental
results
since
the
2000
CWNS.
The
appendices
of
the
Report
are
detailed
state­
by­
state
and
national
summary
tables.
States
are
allowed
continuous
updating
on
the
newly
modernized
database,
but
are
issued
a
final
date
that
EPA
will
accept
State
updates
for
inclusion
in
the
CWNS
Report
to
Congress.
The
time
period,
established
at
the
startup
meeting,
for
conducting
the
actual
data
collection
and
completing
all
survey
updates
is
at
least
nine
months
in
length
from
the
start­
up.
The
estimated
time
it
may
take
a
user
to
collect
and
enter
one
record,
including
copying
and
mailing
hard
copies
of
the
documentation
is
1.55
hours.

The
newly
modernized
data
system
was
used
first
for
the
CWNS
2000,
is
very
user
friendly
and
a
national
system
update
is
built
into
the
software.
The
new
CWNS
system
is
designed
to
help
States
store
and
organize
much
more
relative
data
to
facilitate
their
ability
to
assess
impacts
to
their
most
critically
impaired
watersheds
as
a
whole.
States
may
fully
utilize
the
extraneous
technical
data
fields
pertaining
to
georeferencing
data,
operation
and
maintenance
details,
and
funding
source
types
and
amounts,
etc.
Depending
on
the
quality
and
quantity
of
data
States
enter,
States
can
download
into
a
GIS
and
do
analyses
for
determining
environmental
benefit
tradeoffs.
This
use
could
aid
the
efficient
use
of
limited
funding
to
achieve
the
best
water
quality
improvements
for
environmental
dollars
spent.

Consultations
OWM
and
an
advisory
workgroup
composed
of
EPA
Regional
and
state
representatives
determine
the
basic
approach
and
methodology
to
be
used
in
the
Survey.
This
group
has
monthly
conference
calls
and
meets
one
time
a
year,
as
necessary.
OWM
will
consult
the
workgroup
in
developing
update
criteria
and
procedures
for
the
2004
CWNS,
to
be
4
incorporated
in
the
user
manuals
distributed
to
States
and
EPA
Regional
coordinators
at
the
Survey
start­
up
meetings.

Effects
Of
Less
Frequent
Collect
The
Needs
Survey
is
required
to
be
conducted
every
2
years.
In
1994,
a
survey
was
mandated
for
the
collection
of
drinking
water
needs.
Therefore,
after
the
completion
of
the
1992
Clean
Water
Needs
Survey
(
CWNS),
the
CWNS
began
being
conducted
every
four
years,
alternating
with
the
drinking
water
survey.
Funding
constraints
and
information
security
requirements
delayed
the
2000
CWNS
more
than
one
year
and
may
delay
start­
up
and
completion
of
the
2004
survey.

Each
item
in
the
Needs
Survey
is
necessary
to
accomplish
one
or
more
goals
of
the
Clean
Water
Act
(
CWA).
Failure
to
collect
the
information
could
put
EPA,
States
and
Regions
in
the
position
of
being
unable
to
respond
to
its
Congressional
mandate
or,
responding
in
an
untimely
manner
with
information
that
is
inaccurate
and
incomplete.
The
Needs
Survey
data
play
a
major
part
in
evaluating
costs
for
regulations
such
as
the
Total
Maximum
Daily
Load
(
TMDL)
rule,
the
Sanitary
Sewer
Overflow
(
SSO)
rule,
and
Storm
Water
Phase
I
and
Phase
II.
The
CWA
and
state
revolving
fund
allotment
formula
is
overdue
to
be
reauthorized
by
Congress
and
the
needs
data
submitted
by
States
will
play
an
important
role
in
determining
a
fair
appropriation
of
funds
for
them.

General
Guidelines
The
Survey
follows
OMB's
general
guidelines
Confidentiality
No
confidentiality
information
is
used.

Sensitive
Questions
The
Needs
Survey
does
not
ask
for
information
considered
sensitive
or
which
appears
to
fall
within
the
types
of
confidential
data
protected
from
release
under
the
Public
Information
Act.

Section
4
The
Respondents
And
The
Information
Requested
Respondents/
SIC
Codes
The
Standard
Industrial
Classification
for
the
respondents
affected
by
this
collection
activity
are
as
follows:
5
Establishment
Group
Number
Industry
Number
Water
Pollution
Control
951
9511
Sewage
Plants
and
Systems
495
4952
Information
Requested
The
types
of
data
that
will
be
collected
relate
to
wastewater
infrastructure
and
the
costs
thereof,
including
publicly­
owned
wastewater
treatment
and
conveyance
systems
that
need
to
be
built
or
upgraded.
Cost
and
technical
data
for
infrastructure
to
control
wet
weather
pollution
are
collected,
including
storm
water,
combined
sewer
and
sanitary
sewer
overflows.
Nonpoint
source
and
small
community
needs
are
also
captured
in
this
survey.

Section
5
The
Information
Collected
B
Agency
Activities,
Collection
Methodology,
and
Information
Management
Agency
Activities
Every
four
years,
the
data
are
collected,
reviewed
and
summarized
over
a
two­
year
time
period
to
give
EPA
sufficient
time
to
complete
review
and
verification
and
to
prepare
the
final
report.
The
States
and
Regions
also
review
the
collected
data
during
this
time.
Specifically,
the
States
are
responsible
for:


collecting,
reviewing
and
updating
the
data
on
municipal
wastewater
treatment
facilities,
storm
water,
and
Non­
point
source
projects.


submitting
proper
documentation
where
necessary.


justifying
certain
specified
categories
of
need
that
are
based
on
construction
cost
curves.


addressing
questions
about
population
anomalies.

EPA
Headquarters
is
responsible
for:


setting
national
documentation
standards
and
identifying
data
sources.


managing
the
Survey
and
its
data
base
to
ensure
national
consistency.


acting
as
the
final
arbitrator
in
disputes.


preparing
the
final
Report
to
Congress
and
disseminating
Survey
information.
6

reviewing
documentation
to
ensure
its
acceptability
and
updating
records.


performing
file
search
of
specific
facilities
and
cataloguing
the
type
of
documentation.


assigning
proper
basis
of
estimates
to
all
cost
estimates
and
applying
EPA
Cost
Curve
procedures
where
appropriate.


reviewing
and
approving
new
facility
data
submitted
by
the
States.


performing
quality
assurance
checks
on
needs
and
population
data.


deleting
needs
estimates
for
facilities
that
cannot
be
properly
documented
in
accordance
with
the
established
list
of
acceptable
criteria.

EPA
Regions
are
responsible
for:


assisting
in
the
review
of
selected
facilities.


acting
as
arbitrator
in
State/
EPA
disputes.


arranging
Regional
briefings
on
conduct
of
the
data
collection
and
results
of
the
survey
Collection
Methodology
And
Management
EPA
has
consistently
used
current
technology
to
complete
the
Survey.
In
1974,
the
data
were
collected
on
a
35
­
page
questionnaire
(
EPA­
1
Form)
which
was
manually
completed
by
the
States.
This
method
placed
a
large
burden
on
State
and
EPA
regional
personnel
and
resources.
In
1976,
the
EPA­
1
Form
was
redesigned
and
considerably
reduced
in
size
and
was
made
computer
compatible.
In
1983,
the
EPA­
1
Form
was
reviewed
and
revised
to
two
pages
which
were
computer
compatible.
Subsequent
Surveys
were
conducted
in
a
similar
manner.
The
1986
Survey
preprinted
information
for
States
to
update
on
one
­
page
fact
sheets
which
were
easier
to
use
than
the
computerized
EPA
­
1
Form.

Since
1988,
the
Needs
Survey
review
and
update
process
are
computerized
to
further
reduce
the
workload
for
the
States
and
Regions
in
collecting
and
updating
facility
data,
through
computer
screened
entry
and
verification
of
data
and
approval
by
EPA
Headquarters.

EPA
will
continue
to
use
the
computerized
database
approach
to
maintain
minimal
burden
on
States
and
Regions
for
the
2004
Survey.
In
addition,
relationship
edits
have
been
built
into
the
system
to
reduce
errors
and
research
time.
States
will
now
have
the
capability
to
maintain
data
year
round
and
utilize
the
data
with
other
State
GIS
information.
7
Small
Entity
Flexibility
Collection
of
information
associated
with
the
Needs
Survey
does
not
involve
small
businesses.
The
primary
respondents
are
the
States,
usually
the
State
Water
Pollution
Control
Agency
or
the
Department
of
Environmental
Protection.

Collection
Schedule
In
years
past,
the
Needs
Survey
was
planned
and
collected
in
a
specific
2­
year
timeframe,
because
the
national
needs
estimates
are
required
to
be
summarized
in
a
Report
to
Congress
on
a
biennial
basis.
However,
the
2004
Survey
data
inventory
(
approved
and
carried
over
from
the
2000
Survey)
may
be
updated
by
States
at
their
convenience
and
on
a
continual
basis.

The
national
EPA/
State
meeting
to
kickoff
the
2004
Needs
Survey
will
be
held
about
2
years
before
the
Report
is
planned
to
go
to
Congress
(
approximately
February,
2005).
This
encourages
States
to
review
and
update
their
facility
data,
if
they
have
not
been
doing
so
continually,
and
gives
them
a
planned
schedule
to
work
toward.
After
this
point
in
time,
EPA
reviews
State
supplied
documentation
and
checks
for
quality
assurance
of
the
data.

Presently,
the
2000
CWNS
Report
is
being
prepared
by
EPA
Headquarters
and
will
be
submitted
to
Congress
by
August,
2002.
The
printed
Needs
Survey
Report
to
Congress
can
be
obtained
by
those
in
the
public
and
private
sectors
on
the
EPA
web
site,
through
EPA's
National
Services
Center
for
Environmental
Publications,
and
for
a
fee
through
the
EPA
Instruction
Resource
Center
at
Ohio
State
University.
The
Needs
Survey
data
are
used
by
members
in
the
public
and
private
sectors
for
environmental
program
evaluation
and
studies
and
new
technology
product
marketing.

Section
6
Estimating
The
Burden
And
Cost
Of
The
Collection
Estimating
Respondent
Burden
There
are
56
respondents
involved
and
a
total
of
29,698
facilities
currently
in
the
Needs
Survey
data
base.
The
number
of
facilities
each
State
respondent
has
in
their
data
inventory
may
range
from
1
to
2,500
per
State.
It
is
estimated
that
an
average
of
1.55
hours
are
needed
to
complete
each
facility
review
and
update.

Experience
shows
that
respondent
involvement
varies
considerably,
depending
on
the
available
resources
and
the
individual
effort
a
respondent
makes
in
completing
the
Survey.
Some
respondents
conduct
a
selective
review
of
the
needs
and
data
while
others
review
and
analyze
needs
and
data
in
detail.
States
generally
update
less
than
half
of
their
facilities
8
each
Survey.

The
total
respondent
burden
for
the
2004
Survey
are
estimated
to
be
23,016
hours
[
29,698
facilities
/
2
=
14,849;
x
1.55],
over
a
3­
year
period.
The
annual
burden
per
respondent
will
average
137
hours
[
23,016/
3
=
7,672;
/
56]
to
complete
facility
update/
reviews.
The
major
respondent
activities
are
shown
in
Table
l
with
detailed
burden
estimates.

Estimating
Respondent
Costs
Experience
indicates
that,
because
participation
varies
from
respondent­
to­
respondent,
the
estimated
cost
be
based
on
an
overall
average
rate.
The
estimated
cost
to
the
56
respondents
for
the
2004
Survey
is
based
on
an
average
rate
of
$
30.06
per
hour
(
including
personnel,
compensation
and
benefits,
costs)(
PC&
B).
The
annual
cost
per
respondent
is
estimated
at
$
4,118
[
137
x
$
30.06].
There
are
no
O
&
M
or
start­
up
costs
anticipated.
The
total
annualized
cost
for
all
56
respondents
is
estimated
at
$
230,608
[$
4,118
x
56].
These
costs
are
shown
in
detail
for
each
activity
in
Table
I.

Estimated
Agency
Burden
and
Costs
The
annualized
estimate
for
the
total
cost
to
the
Federal
Government
is
$
1,519,777
,
to
include
an
estimated
$
895,000
for
the
EPA
contract
cost
to
support
the
survey.
It
is
based
on
the
average
of
PC&
B
costs
of
the
EPA
Headquarters
and
the
regional
components
and
includes
the
costs
of
an
EPA
support
contract.
The
EPA
headquarters
annual
burden
is
approximately
4
work
years
and
the
regional
component
of
the
burden
are
estimated
annually
at
3
work
years
[
10
regions
X
0.30
Fte].
The
total
agency
burden
is
estimated
at
an
annualized
cost
of
$
624,777
[
2080
hrs.
x
$
42.91
=
$
89,253
x
7].
The
activities
for
EPA
and
the
CWNS
support
contractor
are
itemized
in
Table
I.
9
TABLE
1
ACTIVITY
AGENCY
Labor
Hrs.

/
Year
Federal
Labor
Costs
[$
42.91/
hr.]

[$
89,253/
yr.]
CONTRACT
Costs
/
Year
TOTAL
Agency
Costs/
Yr.
LABOR
HRS.

/
Respondent
/
Year
TOTAL
Respondent
Hours
/
Year
[
Respondents
=
56]
TOTAL
Labor
Costs/
Yr.

/
Respondent
[
at
$
30.06
/
hr.]
TOTAL
Respondent
Costs
/
Year
Contract
Management
0.50
FTE
$
44,627.
0
$
44,627.
0
0
0
Regional
Assistance
[
0.30
FTE
x
10
Regions]
3.00
FTE
$
267,759.
0
$
267.759.
0
0
0
Plan,
Implement,
&
Manage
Survey
1.50
FTE
$
133,880.
50,000
$
183,880.
0
0
0
Provide
Logistics
Support
50,000
$
50,000.
0
0
0
Refine
Modeling
Approaches
100,000
$
100,000.
0
0
0
Provide
computer
support
0.25
FTE
$
22,314.
270,000
$
292,314.
0
0
0
Provide
Technical
Support
0.50
FTE
$
44,627.
210,000
$
254,627.
0
0
0
Participate
in
Meetings
0.25
FTE
$
22,314.
0
$
22,314.
12
672
$
361.
$
20,216.

Data
Update/
Collection
0
107
5,992
$
3,216.
$
180,096.

Workgroup
Support
0.25
FTE
$
22,314.
45,000
$
67,314.
0
0
0
Review,
Q/
A,
and
Reconcile
Data
0.25
FTE
$
22,314.
105,000
$
127,314.
18
1,008
$
541.
$
30,296.

Market
and
promote
CWNS
0.25
FTE
$
22,314.
25,000
$
47,314.
0
0
0
Prepare
Final
Report
0.25
FTE
$
22,314.
40,000
$
62,314.
0
0
0
10
ANNUALIZED
TOTALS
7
$
624,777.
895,000
$
1,519,777.
137
7,672
Reasons
For
Change
In
Burden
Program
Changes:

The
approved
clearance
for
the
past
two
years
was
to
begin
populating
the
newly
modernized
Clean
Watersheds
Needs
Survey
Data
Base
and
to
complete
the
data
collection
for
the
2000
Needs
Survey.
This
extension
request
is
for
the
maximum
allowable
3­
year
period
for
States
to
be
able
to
update
their
data
inventory,
contained
in
the
CWNS
data
base,
continually.
EPA
has
agreed
to
maintain
the
newly
modernized
database
for
States
to
review
and
enter
their
data
on
an
ongoing
basis,
which
will
alleviate
crunch
times.
The
previous
ICR
burden
statements
estimated
hours
and
costs
based
on
a
total
2­
year
survey
effort,
and
did
not
annualize
the
estimates.
This
was
probably
because
the
national
needs
estimates
are
required
to
be
summarized
in
a
Report
to
Congress
on
a
biennial
basis.
However,
as
stated
previously,
the
survey
is
now
being
done
every
4
years.
In
addition,
we
are
collecting
data
from
five
additional
respondents
(
four
territories
and
the
District
of
Columbia)
to
complete
the
national
picture
of
needs
for
the
2004
Report
to
Congress.

Additional
respondents
burden
5
X
137
hrs./
year
=
685
hrs.

This
equals
a
total
of
2055
hours
over
the
next
3
years
[
3
x
685].

Current
Approved
Additional
Needed
Amount
Requested
21,000
2,016
23,016
The
23,016
hours
requested
is
over
three
years
or
7,672
hours
annually.

Burden
Statement
The
average
reporting
burden
for
each
review
per
respondent
is
1.55
hours.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
11
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency,
(
2822),
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Room
10202,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
(
0318.09)
and
OMB
control
number
(
2040
B
0050)
in
any
correspondence.
12
