  SEQ CHAPTER \h \r 1 

Clean Watersheds Needs Survey

Office of Wastewater Management

EPA ICR Number 0318.12

OMB CONTROL NUMBER 2040-0050

August 2010

SUPPORTING STATEMENT

A.	JUSTIFICATION				

Section 1   Identification of the Information Collection

TITLE:  Clean Watersheds Needs Survey (CWNS) (Renewal) 

ICR NUMBER:  0318.12

OMB Control Number:    2040-0050

ABSTRACT:				

The Clean Watersheds Needs Survey (CWNS) is required by Clean Water Act
(CWA) Sections 205(a) and 516.  It is a periodic inventory of existing
and projected publicly owned wastewater treatment works (POTWs) and
other water pollution control facilities in the United States, as well
as an estimate of how many POTWs need to be built.  The CWNS is a joint
effort of EPA and the States.  The Survey records cost and technical
data associated with POTWs and other water pollution control facilities,
existing and projected, in the United States.  The State respondents who
provide this information to EPA are State agencies responsible for
environmental pollution control.  No confidential information is used,
nor is sensitive information protected from release under the Public
Information Act.  EPA achieves national consistency in the final results
through the application of uniform guidelines and validation techniques.

Section 2    Need for and Use of the Collection

Need for the Collection:

EPA provides an estimate of POTWs construction and other water pollution
control requirements for each State, Territory, and the District of
Columbia to Congress under CWA Section 516, 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.”

Further, CWA Section 604(a) states the Clean Water State Revolving Funds
shall be allocated in accordance with CWA Section 205. CWA Section 205
provides that allotments shall be made only in accordance with a revised
cost estimate made and submitted to Congress in accordance with CWA
Section 516 and only after such revised cost estimate shall be approved
by law specifically enacted hereafter.

uSE OF THE COLLECTION:

In addition to CWA Section 205 uses of the data for funds allotment,
Congress utilizes the data to assist deliberations on specific
legislation and funding measures related to water pollution control. 
Additional uses of the data include:

Local, state, and other uses of the data for NPDES permit writing, Total
Maximum Daily Load analyses, and other environmental program support

Wastewater treatment technology and environmental measures support
related to EPA’s Sustainable Infrastructure Initiative

Private industry efforts to target technical support for facilities 

Baseline data for EPA, Department of Homeland Security, and other
agencies for use in more specialized reports and for providing program
focus.

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.  The appendices of
the Report are detailed state-by-state and national summary tables.  The
Report and the detailed graphs and tables are publicly available at  
HYPERLINK "http://www.epa.gov/cwns/"  http://www.epa.gov/cwns/ .  

Section 3  Nonduplication, Consultations, and Other Collection Criteria

Nonduplication:  

EPA avoids duplication of effort in a number of ways.  To begin each new
Survey, EPA provides each State their exact inventory of data from the
preceding survey to update and revise, with EPA updating only the cost
data for inflation.  States also have access to technical and cost data
contained in the CWNS data system from previous Surveys.  This
eliminates the need for States to provide information which has already
been approved and ensures national consistency.  States and EPA Regions
are informed of the data and document update procedures at the CWNS
Kickoff Meeting and via web seminars and other electronic
communications. 

The new Data Entry Portal for CWNS 2008 was developed in the EPA
Enterprise Portal to provide many features that avoid duplication of
effort.  The system provides ability to:

Transfer wastewater discharge permit data from EPA’s Permit Compliance
System and EPA’s Integrated Compliance Information System directly
into the CWNS 2008 data system,

Click on locations in the internet WATERS Lite Viewer mapping tool and
have the location data transferred into the CWNS 2008 data system,  

Incorporate data from EPA’s Impaired Waters and Clean Water State
Revolving Fund Benefits databases,  

Have local communities update their CWNS information, and

Upload and comment upon documents to minimize effort related to data and
document quality assurance reviews (EPA is scanning and posting in the
system documents submitted in prior surveys) 

In addition to system enhancements, required data elements were reduced
between CWNS 2004 and CWNS 2008.  Data quality assurance methods have
also been streamlined to require less respondent time while preserving
data quality assurance.

Consultations

EPA, with input from an advisory CWNS Workgroup composed of State and
EPA Regional representatives, refines the approaches and methodologies
used in each Survey.  The CWNS 2012 Workgroup was established in
November 2009 following an October 2009 invitation to a list of State
environmental department commissioners provided by the Environmental
Council of the States.  Recommendations made by the CWNS 2008 Workgroup
at the end of the 2008 Survey, along with recommendations from the CWNS
2012 Workgroup, informed the refined methods for the CWNS 2012 data
collection addressed by this ICR.  The CWNS 2012 Workgroup provided
input on updating the eligibility criteria, data collection/submission
methodologies, and the CWNS Data Entry Portal.  As with past surveys,
the updated criteria, methodologies and data system guidance will be
published in a detailed user manual for State and EPA Regional CWNS
Coordinators. 

Effects of Less Frequent Collection 

The Needs Survey was initially conducted every two years.  In 1994, a
survey was mandated for the collection of drinking water infrastructure
needs.  Therefore, after the completion of the CWNS 1992, the CWNS began
being conducted every four years, alternating with the drinking water
survey.  

Each item in the CWNS is necessary to accomplish one or more goals of
the Clean Water Act (CWA).  Failure to update the information could put
EPA, States and Regions in the position of being unable to respond in a
timely and accurate manner to the Report’s CWA mandates.  The CWA and
state revolving fund allotment formula is overdue for reauthorization by
Congress and the needs data submitted by States may play an important
role in determining the appropriation of funds.  The Needs Survey data
also play a major part in evaluating costs for regulations such as
stormwater rules and in related reports such as the Water and Wastewater
Infrastructure Gap Analysis Report.  Additionally, the data need regular
updating to support the variety of additional uses described at the end
of Section 2.

General Guidelines

The Survey follows OMB’s general guidelines.

Confidentiality 

No confidential 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/NAICS Codes 

The North American Industry Classification System (NAICS) information
for the respondents affected by this collection activity are as follows:

	Establishment	Group Number	Industry Number

	Water Pollution Control	924	924110

	Sewage Plants and Systems	221	221320

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 to control wastewater, stormwater, nonpoint source discharges,
and combined sewer / sanitary sewer overflows.	

Section 5  The Information Collected – 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, stormwater, and non-point source projects,

Submitting proper documentation where necessary,

Justifying certain specified categories of need that are based on
construction cost curves, and

Addressing questions about populations served anomalies.

EPA Headquarters is responsible for:

Managing the Survey and its data base to ensure national consistency,

Setting national documentation standards and identifying data sources,

Reviewing documentation to ensure its acceptability and updating
records,

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, and

Preparing the final Report to Congress and disseminating Survey
information over the internet (  HYPERLINK "http://www.epa.gov/cwns/" 
http://www.epa.gov/cwns/ ).

EPA Regions are responsible for:

Promoting States’ full participation in CWNS,

Assisting States with state-specific data collection / update
methodologies,

Assisting States in addressing States’ submissions evaluated by EPA as
not meeting CWNS criteria, and

Arranging Regional briefings on conduct of the data collection and
results of the survey.

Collection Methodology And Management

EPA consistently has used current technology to complete the Survey.  In
1974, the data were collected on 35-page questionnaires (EPA-1 Form),
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.  

In response to terms of clearance of ICR (#0318.10), EPA, in partnership
with States, made several enhancements to the database to streamline
data entry, including reducing data element requirements and integrating
with other EPA datasets.  EPA has also strengthened procedures to ensure
outdated information is removed from the database. 

While reviewing data, EPA reviews supporting documentation submitted by
States to ensure that data entered in the system meets CWNS eligibility
criteria and is consistent with data in the documents.  CWNS eligibility
criteria are:

A description of the water quality impairment and information on the
potential source. The problem description should include specific
pollutant source information. A general statement about water quality
impairment does not meet this criterion.

The location of the problem, included as a latitude/longitude point, or
in the case of an nonpoint source (NPS) project, as a polygon (of the
project location and/or the beneficial receiving waters).

One or more specific pollution control measures or BMPs used to address
the problem.

The capital cost to implement each pollution control measure or BMP.
General estimates for the problem area were not permitted; only
site-specific data are acceptable to generate the costs.

The source of the costs (e.g., an engineer’s estimate, facility plan,
cost of comparable practices, estimates from equipment suppliers) for
each solution.

The total capital costs for all pollution control measures and BMPs
documented for a facility (all costs will be converted to January 1,
2012, dollars for CWNS 2012.)

For all needs entered into CWNS, if a facility / NPS project need is
greater than $20 million (January 1, 2012 dollar base), the
documentation date needs to be January 1, 2006, or more current; for all
other facility / NPS project needs, the documentation date needs to be
January 1, 2002, or more current. 

In addition to these criteria, the CWNS user manual lists a set of
document types that are pre-approved for use in documenting needs and
related costs.  Cost curves are utilized to estimated costs for a small
portion of documented needs that do not have well documented costs.

For CWNS 2012, EPA is offering States two options for participating: (1)
the Traditional Method and (2) the Gap Approach Option.  The Gap
Approach Option enables a State to comprehensively assess at the State
level, for various facility size groupings, wastewater facility revenues
and capital and operation maintenance (O&M) expenses over 20 years. 
This comprehensive facility economic analysis supports State and EPA
sustainable infrastructure programs.  The Traditional Method enables
States to assess the capital needs for each facility within the state. 
This spatially comprehensive assessment of capital needs, along with
current and projected populations receiving various levels of wastewater
treatment, supports holistic watershed management approaches.   

Under the “Traditional Method” of documenting water pollution
control needs, states submit capital needs for all facilities in the
state: 

•   Wastewater Treatment Plants

•   Separate Sewer Systems

•   Combined Sewer Systems 

•   Stormwater Management

•   Decentralized Wastewater Treatment

•   Nonpoint Source (NPS) Control

For each need, states submit one or more supporting documents (Facility
Plan, Engineer’s Estimate,…).  Revenue and O&M needs data are NOT
collected in the Traditional Method.

Under the “Gap Approach” to documenting water pollution control
needs, states submit capital & O&M needs and revenues for a sample of
these facilities:

•   Wastewater Treatment Plants

•   Separate Sewer Systems

•   Combined Sewer Systems

For these sampled facilities, revenues are submitted and asset condition
analysis data is used to estimate capital and O&M needs.  Results from
the sample set of facilities are extrapolated to provide State level
estimates at +/- 10% accuracy.  Average sample rates are:

•   10-25% for facilities serving less than 10,000 people 

•   30-60% for facilities serving between 10,000 and 100,000 people

•   100% (census survey) for the largest 3% of facilities in each
state

Since in CWNS the Gap Approach is only applicable to Wastewater
Treatment Plants, Separate Sewer Systems, and Combined Sewer Systems,
States selecting the Gap Approach will use the Traditional Method for
all other facilities (Stormwater Management, Decentralized Wastewater
Treatment, NPS Control).

	

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.  EPA allows States to submit simplified forms
for their data from communities of 10,000 and less.

Collection Schedule

The CWNS 2012 data entry period will be December 15, 2010 through
October 26, 2012.  Data quality assurance and analysis activities will
be performed November 2012 through February 2013.  The Report will be
developed and submitted to OMB for review in Summer 2013.

Section 6  Estimating The Burden And Cost Of The Collection

Estimating Respondent Costs					

The average cost to States of staff compensation and benefits is
estimated to be $40.32 per hour (Department of Labor, May 2008), the
annual State burden hour estimate of 7,183 hours equates to overall
State costs of $289,598.  The average cost to Local Facilities of staff
compensation and benefits is estimated to be $42.17 per hour (Department
of Labor, May 2008), the annual wastewater facility burden hour estimate
of 1,932 hours equates to overall wastewater facility costs of $81,468. 
 There are no additional costs beyond costs associated with the above
burden hour estimate.

Burden for State Government and Local Facility Participation in Data
Collection

This table summarizes burden estimates across all States.  It results
from summing the values in tables in the following three pages.

This table summarizes burden estimates for the estimated 49 States that
will select the Traditional Method.

This table summarizes burden estimates for wastewater collection and
treatment facilities the estimated 7 States that will select the Gap
Approach Option.

This table summarizes burden estimates for other facilities (Stormwater
Management, Decentralized Wastewater Treatment, NPS Control) in the
estimated 7 States that will select the Gap Approach Option.



Estimated Agency Burden and Costs

The annualized estimate for the total cost to the Federal Government is
$929,320; to include $90,000 for CWNS system maintenance at EPA’s
computing facility, $535,000 for contractor support, and $304,320 in EPA
employee compensation and benefits cost.  

  SEQ CHAPTER \h \r 1 

REasons for change in burden

There is an increase of 308 hours in the total estimated respondent
burden compared with that identified in the ICR currently approved by
OMB.  The 308 hour increase is the net result of a decrease of 52 State
burden hours combined with an increase of 360 hours in Local Facility
burden hours.  These changes are estimated impacts of 7 States selecting
the Gap Approach Option.  In this option, total state effort is
projected to decrease slightly due to the sampling design (the greater
State effort per facility is slightly more than offset by entering data
for a sampled portion rather than for all facilities).  For Local
Facilities, the projected increased burden results from the extra per
facility effort being slightly more than the burden saved by switching
from a census to a sampling approach.

Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 1.55 hours per response.  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 which have
subsequently changed; 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.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OW-2003-0019, which is available for public viewing at the Water
Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301
Constitution Ave., NW, Washington, DC. The EPA Docket Center Public
Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday,
excluding legal holidays.  The telephone number for the Reading Room is
(202) 566-1744, and the telephone number for the Water Docket is (202)
566-2426.  An electronic version of the public docket is available
through http://www.regulations.gov. Use www.regulations.gov to submit or
view public comments, access the index listing of the contents of the
public docket, and to access those documents in the public docket that
are available electronically.  Once in the system, select “search,”
then key in the docket ID number identified above.  Also, you can send
comments to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503,
Attention: Desk Officer for EPA.  Please include the EPA Docket ID No.
EPA-HQ-OW-2003-0019 and OMB control number 2040-0050
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