1
Date:
11
August
2004
To:
James
Covington,
EPA
From:
Maureen
F.
Kaplan,
ERG
Subject:
Drinking
Water
Facilities
Profile
1.
Introduction
The
drinking
water
supply
and
treatment
industry
was
identified
as
an
industry
sector
currently
not
regulated
by
effluent
guidelines
through
stakeholder's
suggestions
for
the
2003/
2004
effluent
guidelines
program
plan.
EPA
examined
discharges
for
this
industry
in
the
Toxics
Release
Inventory
(
TRI)
and
Permit
Compliance
System
(
PCS)
databases
(
USEPA,
2003)
This
memorandum
provides
an
initial
industry
profile.

Section
2
describes
the
primary
data
sources,
industry
subsets
of
interest,
and
the
data
limitations
for
an
in­
depth
analysis
at
this
time.
Section
3
summarizes
the
estimated
number
of
direct
and
indirect
dischargers
(
i.
e.,
potential
BAT
and
PSES
facilities,
respectively).
Section
4
presents
the
ownership
profiles
and
small
business
estimates.
Section
5
lists
the
type
of
contaminants
found
in
the
raw
water
concentration
(
i.
e.,
before
treatment).
Section
6
discusses
typical
treatment
practices
that
might
result
in
effluents.
Section
7
discusses
the
financial
characteristics
of
drinking
water
facilities.

2.
Data
Sources
U.
S.
EPA,
Community
Water
System
Survey
2000,
Volumes
1
and
2,
EPA
815­
R­
02­
005A
and
EPA
815­
R­
02­
005B,
December
2002
(
hereafter
called
"
Survey
2000")
is
the
primary
data
source
for
this
industry
profile.
Survey
2000
is
based
on
a
sample
count
of
about
1,250
questionnaires
returned
to
EPA
from
facilities
in
50
states
and
the
District
of
Columbia.
In
contrast,
the
data
sources
for
the
draft
effluent
guidelines
plan
are
TRI
and
PCS.
TRI
had
only
two
observations.
The
PCS
database
contained
wastewater
flows
for
13
facilities
in
SIC
4191
(
water
supply),
however,
only
7
observations
are
from
the
50
States
and
the
District
of
Columbia.
(
The
remainder
are
from
Puerto
Rico.)
The
data
sets,
then,
have
little
overlap.
Sections
5
and
6
of
this
memorandum
are
based
on
Survey
2000
to
provide
a
general
idea
of
the
initial
contaminants
and
treatment
practices
that
might
be
found
in
an
effluent
limitations
guideline
analysis
of
drinking
water
systems.

ERG
does
not
have
access
to
the
individual
observations
in
the
Survey
2000
data
base,
only
what
is
published
in
the
report.
Therefore
all
estimates
are
very
general.
For
example,
we
cannot,
at
this
time,
correlate
facilities
that
discharge
to
surface
waters
with
particular
treatment
practices
that
might
generate
sludges
of
interest.
The
remaining
discussion
in
this
section
must
be
read
with
this
caveat
in
mind.
2
3.
Number
of
Direct
and
Indirect
Dischargers
Survey
2000
indicates
that
there
are
approximately
52,186
drinking
water
facilities
nationwide.
For
the
purpose
of
estimating
the
subset
of
facilities
that
might
be
within
scope
of
an
effluent
guideline,
we
need
to
identify
the
number
of
facilities
that
discharge
to
surface
waters
(
direct
dischargers
or
BAT
facilities)
and
which
discharge
to
a
sanitary
sewer
(
indirect
dischargers
or
PSES
facilities).
Survey
2000,
volume
2,
Table
29
lists
the
percentages
of
plants
that
discharge
(
1)
directly
to
surface
waters
and
(
2)
to
a
sanitary
sewer.
Based
on
this
information,
we
estimate
there
are
about:

#
8,830
drinking
water
systems
that
might
be
within
scope
of
an
effluent
guideline
#
5,694
of
the
8,830
systems
discharge
to
surface
waters
(
BAT)

#
3,136
of
the
8,830
systems
discharge
to
a
sanitary
sewer
(
PSES).

See
ERG,
2004
for
details
on
the
calculations.
In
other
words,
an
effluent
guideline
might
apply
to
about
17
percent
of
the
drinking
water
treatment
facilities
(
that
is,
8,830
of
52,186
facilities).

4.
Ownership
and
Small
Entities
4.1
Types
of
Ownership
Survey
2000
notes
that
community
water
systems
are
evenly
split
between
public
and
private
ownership.
Public
facilities
are
owned
by
counties,
cities,
towns,
or
other
forms
of
local
government.
Private
facilities
are
owned
by
one
of
three
types
of
entity:

#
Most
(
39%)
systems
are
ancillary
systems.
That
is,
water
treatment
is
not
the
primary
business
of
the
owner.
The
owner
supplies
water
as
an
integral
part
of
their
business.

#
About
one­
third
(
34%)
of
the
private
community
water
systems
are
rum
as
not­
for­
profit
entities.

#
For­
profit
entities
constitute
the
smallest
proportion
of
private
community
water
systems
(
27%).

In
general,
public
and
private
systems
have
different
rate
structures,
sources
of
funding,
and
the
size
of
the
population
served.
These
are
discussed
in
more
detail
in
Section
7.

4.2
Counts
by
Ownership
Survey
2000
crosstabulates
the
public
and
private
ownership
of
drinking
water
facilities
by
primary
source
of
water
and
the
population
served
(
volume
2,
Table
3).
Combining
this
information
with
that
presented
in
volume
2,
Table
29
(
residual
management
by
primary
source
of
water
and
the
population
served)
to
estimate
the
number
of
public
and
private
BAT
and
PSES
facilities.
The
estimates
are:
3
#
4,592
public
facilities
S
2,515
BAT
S
2,077
PSES
#
4,239
private
facilities
S
3,179
BAT
S
1,060
PSES
4.3
Small
Entity
Definitions
The
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Flexibility
Act
(
RFA/
SBREFA)
defines
a
"
small
governmental
jurisdiction"
as
the
government
of
a
city,
town,
county,
school
district,
or
special
district
with
a
population
of
less
than
50,000
(
USEPA,
1999)
For
the
purpose
of
this
memorandum,
we
assume
that
a
public
drinking
water
facility
that
serves
50,000
or
fewer
persons
belongs
to
a
small
entity.

Drinking
water
facilities
are
part
of
NAICS
code
221310
Water
Supply
and
Irrigation
Systems.
The
Small
Business
Administration
size
standard
for
NAICS
221310
is
$
6.0
million
dollars
in
revenue
(
SBA,
2002).
However,
as
noted
in
Section
4.1,
nearly
four
out
of
every
ten
private
drinking
water
systems
are
ancillary
systems.
This
means
that
the
primary
business
would
be
a
NAICS
code
other
than
221310.
For
the
purpose
of
estimating
the
number
of
small
entities,
however,
we
assume
all
private
drinking
water
systems
with
less
than
$
6.0
million
in
annual
revenues
belongs
to
a
small
entity.
ERG,
2004
provides
more
information
on
how
small
commercial
business
were
identified
by
the
revenue
ranges
by
population
served
reported
in
Survey
2000,
volume
2,
Table
47.

Table
1
summarizes
the
results.

5.
Initial
Contaminants
Survey
2000
asked
systems
that
served
more
than
500,000
people
about
nine
contaminants
in
the
raw
water
prior
to
treatment
(
volume
2,
Table
27).
(
That
is,
about
64
systems.)
If
a
system
did
not
test
for
a
contaminant,
the
response
was
"
N/
A."
If
a
system
tested
for
the
contaminant
and
did
not
detect
it,
the
response
was
"
ND."
EPA
calculated
the
mean,
median,
and
90th
percentile
concentrations
for
the
systems
that
reported
positive
concentrations.

Table
2
presents
the
findings
for
very
large
systems
that
use
groundwater.
The
relevance
of
this
information
to
effluent
guidelines
is
as
follows.
Suppose
a
drinking
water
system
uses
groundwater
as
a
source
and
the
water
has
a
contaminant.
Suppose
the
drinking
water
system
removes
the
contaminant
during
treatment.
The
residuals
then
contain
the
contaminant.
If
the
drinking
water
system
discharges
to
surface
water,
it
could
contribute
the
contaminant
to
the
surface
water.
4
Table
1
Estimated
Number
of
Drinking
Water
Systems
Belonging
to
Small
Entities
Number
of
Drinking
Water
Systems
52,186
Estimated
ELG
Drinking
Water
Systems
8,830
Drinking
Water
Systems
belonging
to
Small
Entities
8,582
Estimated
BAT
Drinking
Water
Systems
(
Total)
5,694
Public
Ownership
2,515
Private
Ownership
3,179
Public
Ownership
­
Small
2,378
Private
Ownership
­
Small
3,163
Estimated
PSES
Drinking
Water
Systems
(
Total)
3,136
Public
Ownership
2,077
Private
Ownership
1,060
Public
Ownership
­
Small
1,991
Private
Ownership
­
Small
1,050
Numbers
do
not
sum
due
to
rounding.

Table
2
Concentration
of
Various
Contaminants
in
Very
Large
Groundwater
Systems
%
Reporting
Concentration
(
ppm
unless
Radon)

Contaminant
NA
ND
Median
Mean
90th
Percentile
Arsenic
19.2%
11.5%
0.010
0.007
0.025
Radon
(
pCI/
L)
80.8%
2.6%
371.1
417.5
554.5
MTBE
33.3%
48.7%
0.175
0.004
0.050
Atrazine
33.3%
57.7%
0.043
0.001
0.210
Metolachlor
47.4%
44.9%
0.053
0.001
0.210
Boron
51.3%
2.6%
0.173
0.120
0.273
2,4­
D
34.6%
57.7%
0.001
0.001
0.001
Simazine
32.1%
59.0%
0.043
0.001
0.210
Glyphosate
34.6%
56.4%
0.002
0.001
0.006
5
Source:
Survey
2000,
volume
2,
Table
27.
6.
Treatment
Practices
Survey
2000,
volume
2,
Tables
23
and
24
indicate
the
percentage
of
facilities
that
use
certain
treatment
practices
such
as
chlorination
only,
disinfection
prior
to
sedimentation
or
filtration,
coagulation/
flocculation,
polymers,
settling/
sedimentation,
softening,
or
various
types
of
filtration.
Facilities
that
use
coagulation/
flocculation
might
contain
a
subset
of
interest
 
those
that
use
alum,
ferric
chloride,
or
ferric
sulfate
in
the
process.
(
Aluminum
and
iron
are
two
of
the
contaminants
reported
in
the
PCS
data
for
this
industry
group.)
Although
60.8
percent
of
facilities
treating
surface
water
and
2.1
percent
of
the
facilities
treating
groundwater
use
coagulants
and/
or
flocculating
agents,
we
cannot
tell
at
this
time
how
many
of
these
facilities
also
discharge
to
surface
waters
or
sanitary
sewers.
Access
to
the
Survey
2000
database,
however,
would
presumably
allow
EPA
to
estimate
the
population
with
both
of
these
characteristics
and
target
the
smaller
set
of
facilities
for
more
detailed
investigation.

7.
Financial
Characteristics
7.1
Industry
Revenues
and
Expenses
In
2000,
water
system
revenue
was
about
$
38.8
billion
and
expenses
were
about
$
32.2
billion
(
see
Table
3).
While
the
overall
relationship
between
revenues
and
expenses
is
positive,
there
are
systems
that
show
losses.
Although
the
number
of
drinking
water
systems
is
nearly
evenly
split
between
public
and
private
ownership,
nearly
90
percent
of
the
revenues
are
associated
with
public
systems.
This
is
consistent
with
water
production,
that
is,
about
91
percent
of
the
water
produced
is
produced
by
public
systems
(
Survey
2000,
volume
1,
p.
10).

Table
3
2000
Annual
Revenues
and
Expenses
(
Billions)

Ownership
2002
Revenues
2002
Expenses
Public
$
34.5
$
29.1
Private
$
4.3
$
3.1
Total
$
38.8
$
32.2
Source:
Survey,
2000,
volume
1,
p.
15
Table
4
summarizes
the
average
annual
revenues
per
facility
by
ownership
and
by
the
population
served.
Ancillary
systems
are
excluded
from
the
calculations
because
they
frequently
do
not
charge
for
water.
Water
is
provided
as
part
of
a
larger
service.
The
range
is
spans
three
orders
of
magnitude.
For
systems
serving
fewer
than
500
individuals,
privately­
owned
systems
earn
about
one­
fourth
of
the
revenues
for
a
publicly­
owned
system
in
the
same
population
category.
6
Table
4
2000
Average
Annual
Revenues
by
Population
Served
2000
Average
Annual
Revenues
(
Dollars)

Population
Served
Publicly
Owned
Privately
Owned
Fewer
than
500
$
53,176
$
12,795
501
to
3,300
$
185,867
$
178,375
3,301
to
10,000
$
756,035
$
792,240
10,001
to
100,000
$
3,654,402
$
3,601,541
More
than
100,000
$
40,797,408
$
45,853,541
Source:
Survey,
2000,
volume
1,
p.
26.

7.2
Sales
Distribution
Survey
2000
reports
the
percentage
of
water
sales
revenue
by
customer
class.
The
dataset
excludes
ancillary
systems
because
they
frequently
do
not
charge
separately
for
water.
This
information
is
summarized
in
Table
5.
For
the
smallest
systems,
residential
sales
make
up
nearly
90
percent
of
the
water
sales
revenue.
This
percentage
decreases
as
the
system
size
increases.
For
systems
serving
more
than
100,000
persons,
residential
sales
make
up
about
half
the
revenues.
Commercial/
industrial
water
use
grows
from
7
percent
to
21
percent
of
the
revenues
from
the
smallest
to
the
largest
systems.
Wholesale
sales
make
up
less
than
5
percent
of
revenues
for
systems
serving
fewer
than
10,000
persons
but
form
nearly
a
quarter
of
the
revenue
for
systems
serving
more
than
100,000
persons.

Table
5
Distribution
of
2000
Revenues
by
Customer
Type
Population
Served
Customer
Type
Below
500
501
to
3,300
3,301
to
10,000
10,001
to
100,000
Over
100,000
Residential
89.3%
83.5%
73.6%
67.1%
49.8%

Commercial/
Industrial
6.8%
11.3%
18.6%
21.1%
20.7%

Wholesale
1.1%
2.0%
4.3%
7.4%
24.7%

Other
2.8%
3.3%
3.5%
4.4%
4.9%

Total
100.0%
100.0%
100.0%
100.0%
100.0%

Source:
Survey,
2000,
volume
1,
p.
16.
Note:
Excludes
ancillary
systems.
7
7.3
Profitability
Survey,
2000
provides
ratios
of
total
revenues
to
total
expenses
by
ownership
(
public/
private)
and
population
served,
see
Table
6.
Total
expenses
is
defines
as
total
operating
expenses
including
debt
service
but
excluding
capital
and
other
non­
operating
expenses.
If
the
ratio
is
less
than
1.0,
costs
exceed
revenues
and
the
facility
is
losing
money
or
relying
on
non­
operating
revenue
to
finance
operations.
Shaded
boxes
in
Table
6
indicate
subgroups
with
ratios
less
than
1.0.
A
ratio
of
1.0
means
that
the
facility
operates
at
the
break­
even
point,
i.
e.,
revenues
equal
costs.
A
ratio
greater
than
1.0
means
that
the
facility
has
more
funds
available
to
pay
down
debt.
Survey
2000
notes
that
a
ratio
above
1.2
is
considered
strong.

Table
6
Ratio
of
Total
Revenues
to
Total
Expenses
By
Ownership
System
Service
Population
Category
Ownership
Type
100
or
Less
101
to
500
501
to
3,300
3,301
to
10,000
10,001
to
50,000
50,001
to
100,000
100,001
to
500,000
Over
500,000
All
Sizes
Public
Systems
Average
Ratio
2.1
1.1
1.3
1.2
1.1
1.3
1.2
1.2
1.2
10th
Percentile
0.8
0.6
0.8
0.9
0.8
0.9
0.9
0.9
0.8
25th
Percentile
1.2
0.9
0.9
1.0
1.0
1.0
1.0
1.0
0.9
50th
Percentile
1.7
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
75th
Percentile
3.4
1.4
1.4
1.3
1.2
1.2
1.3
1.2
1.4
90th
Percentile
3.4
1.6
2.3
1.7
1.4
1.6
1.5
1.6
1.9
Private
Systems
Average
Ratio
1.5
1.5
1.1
1.3
1.2
1.3
1.2
1.2
1.4
10th
Percentile
0.5
0.8
0.9
0.8
1.0
1.0
1.0
1.1
0.7
25th
Percentile
1.0
0.8
1.0
1.1
1.0
1.1
1.0
1.1
0.9
50th
Percentile
1.2
1.1
1.1
1.2
1.2
1.2
1.1
1.2
1.1
75th
Percentile
1.8
1.8
1.2
1.3
1.3
1.4
1.2
1.4
1.6
90th
Percentile
2.8
2.5
1.3
2.2
1.6
2.1
1.8
1.4
2.5
Source:
Survey
2000,
volume
2,
Table
65.
8
A
comparison
of
Table
3
and
Table
6
indicates
how
the
overall
ratios
can
mask
the
variability
in
financial
status
within
the
drinking
water
industry.
For
public
facilities,
the
overall
average
ratio
is
1.2,
i.
e.,
healthy.
The
10th
percentile,
however,
consistently
shows
expenses
exceeding
revenues
for
all
size
categories.
For
facilities
serving
101
to
500
and
501
to
3,300
persons,
the
lower
quartile
still
shows
expenses
exceeding
revenues.
For
publicly
owned
drinking
water
facilities,
one
out
of
every
four
facilities
shows
expenses
exceeding
revenues.
Two
factors
need
to
be
considered
before
drawing
conclusions
about
the
financial
state
of
public
drinking
water
facilities.
First,
depreciation
is
included
as
an
expense.
Depreciation,
however,
is
a
non­
cash
expense
reflecting
wear
and
tear
on
the
equipment.
So
it
is
possible
for
a
facility
to
show
a
total
revenues
to
total
expenses
ratio
that
is
less
than
1.0
but
still
have
positive
cash
flow
for
the
year.
Second,
the
survey
provides
a
1­
year
"
snapshot"
of
financial
data.
Some
systems
with
ratios
less
than
1.0
might
be
waiting
for
rate
increases
to
take
effect.
Some
combined
systems
(
e.
g.,
water
and
sewer
or
water
and
power)
had
difficulty
separating
expenses
but,
presumably,
the
costs
associated
with
drinking
water
treatment
have
an
equal
probability
of
being
over­
or
under­
estimated.

The
data
for
private
systems
are
more
difficult
to
interpret.
Like
public
systems,
the
overall
ratio
is
1.4
and
about
one
in
four
systems
shows
a
ratio
less
than
1.0.
But
the
private
ownership
category
has
three
subcategories:
ancillary
systems,
not­
for­
profit,
and
for­
profit
organizations.
Each
could
appear
differently
in
the
data.

As
mentioned
in
Section
4.1,
nearly
40
percent
of
the
privately
owned
drinking
water
treatment
facilities
are
ancillary
systems
where
the
water
is
supplied
as
part
of
a
larger
business
operation.
Ancillary
systems
might
appear
in
any
one
of
three
ways
in
the
ratio
data:
(
1)
as
a
cost
center
[
costs
but
no
revenues,
ratio
=
0.0
or
undefined],
(
2)
a
break­
even
operation
[
i.
e.,
revenues
from
the
larger
operation
are
allocated
to
drinking
water
treatment
to
cover
costs,
ratio
=
1.0],
or
(
3)
customers
are
billed
separately
for
water
use
[
ratio
reflects
actual
cost
recovery
ratio].

About
one­
third
of
the
private
systems
are
run
as
"
not­
for­
profit"
organizations.
Survey
2000
provides
an
example
where
a
small
homeowners
association
might
show
costs
exceeding
revenues.
The
technical
insolvency
could
be
resolved
quickly
by
levying
a
small
assessment
on
all
customers
to
become
solvent.
So
a
ratio
less
than
1.0
in
the
2000
"
snapshot"
might
not
indicate
long­
term
insolvency.

The
remaining
systems
are
for­
profit
organizations
with
the
more
typical
interpretation
of
financial
ratios.
As
with
the
public
systems,
a
ratio
less
than
1.0
might
correspond
to
a
positive
cash
flow
due
to
the
inclusion
of
depreciation
as
an
expense.

This
information
has
several
implications
for
an
economic
analysis
of
the
drinking
water
industry.
In
particular,
the
methodology
will
need
to
address
four
different
types
of
financial
communities:

#
Public
systems.
The
economic
analysis
might
investigate
the
cost
increase
passed
to
residential
customers
and/
or
the
ratio
of
the
cost
increase
to
the
median
household
income
for
the
region.

#
Ancillary
systems.
These
might
be
covered
under
effluent
guidelines
for
the
larger
business
operation,
such
as
happened
in
the
transportation
equipment
cleaning
industry
where
in­
house
operations
(
as
opposed
to
commercial
operations)
were
considered
regulated
under
a
different
industry.
The
size
standards
for
this
group
of
facilities
would
be
set
by
the
NAICS
code
for
the
larger
business.
For
this
group,
it
might
be
less
9
expensive
to
shut
down
their
treatment
operations
and
becoming
a
customer
to
another
drinking
water
treatment
system.

#
Not­
for­
profit
organizations.
The
economic
analysis
for
this
group
might
resemble
that
for
publicly­
owned
systems
rather
than
other
privately
owned
systems.

#
For­
profit
organizations.
A
more
traditional
financial
analysis
(
e.
g.,
discounted
cash
flow,
closure,
company
financial
health)
is
possible
for
this
group.

7.5
Sources
of
Capital
Funds
Table
7
summarizes
the
different
sources
of
funds
tapped
by
publicly­
and
privately­
owned
drinking
water
systems
to
finance
infrastructure
replacement,
system
expansion,
or
improvements
to
water
quality.
The
data
are
restricted
to
facilities
that
made
capital
expenditures
during
1996­
2000.
The
percentages
sum
to
more
than
100
percent
because
facilities
typically
use
a
mix
of
funding
sources.

Seventy
percent
of
public
systems
and
81
percent
of
private
systems
used
current
revenues
to
fund
capital
expenditures.
About
10
percent
of
the
public
systems
received
Drinking
Water
State
Revolving
Fund
(
DWSRF)
loans.
Seven
percent
of
the
population
had
part
or
all
of
the
DWSRF
principal
payment
forgiven.
Most
of
these
were
small
systems
serving
fewer
than
500
people.
Some
states
do
not
make
DWSRF
available
to
private
systems,
thus
explaining
the
low
use
of
this
source
of
funds
in
the
private
sector.

Publicly­
owned
systems
are
more
likely
to
use
other
government
loans
and
grants
(
13
percent
and
22
percent,
respectively)
than
privately­
owned
systems
(
3
percent
and
5
percent,
respectively).
Small
publicly­
owned
systems
are
more
likely
to
get
grants
(
28
percent)
than
large
systems
(
6
percent).

Twenty
percent
of
the
publicly­
owned
systems
borrow
from
the
private
sector.
This
is
actually
a
larger
percent
than
the
proportion
of
privately­
owned
systems
(
13
percent).

Table
8
shows
how
much
of
each
(
average)
system's
total
capital
expenditures
came
from
each
funding
source.
The
difference
between
the
public
and
private
systems
is
apparent.
Public
systems
derive,
on
average,
about
half
their
funding
for
capital
expenses
from
current
revenues.
In
contrast,
private
systems,
on
average,
derive
nearly
80
percent
of
their
funding
for
capital
expenses
from
current
revenues.
Both
types
of
ownership
derive
between
15
percent
to
17
percent
of
their
funding
from
borrowing
from
the
private
sector
and
other
sources
of
revenue.
The
difference
is
that
publicly­
owned
systems
obtain
nearly
one­
third
(
32
percent)
of
the
funding
from
a
combination
of
government
loans
and
grants.
This
source
of
funding
is
barely
available
to
the
private
sector.

In
other
words,
the
economic
analysis
for
an
effluent
guideline
for
the
drinking
water
industry
will
need
to
address
the
differences
in
access
to
different
types
of
capital
by
publicly­
owned
and
privatelyowned
drinking
water
treatment
systems.
10
Table
7
Source
of
Capital
Funds
in
the
Past
5
Years
By
Ownership
System
Service
Population
Category
Ownership
Type
100
or
Less
101
­

500
501
­
3,300
3,301
­

10,000
10,001
­

50,000
50,001
­

100,000
100,001
500,000
Over
500,000
All
Sizes
Public
Systems
Current
Revenues
6.3
63.8
70.1
73.9
79.9
81.7
90.4
95.9
69.5
DWSRF
Loans
24.4
9.4
12.6
3.4
7.7
8.8
9.3
25.7
9.8
DWSRF
Principal
Repayment
Forgiveness
16.3
14.0
6.9
1.5
4.3
3.5
2.9
2.1
7.1
Other
Government
Loans
0.0
13.1
12.6
14.2
16.4
8.3
7.4
2.1
12.9
Other
Government
Grants
6.5
28.3
17.9
28.0
21.6
13.8
6.0
6.2
21.8
Borrowing
from
Private
Sector
3.2
10.0
12.6
27.3
36.0
50.5
40.8
75.1
19.5
Other
46.9
0.0
3.0
3.5
1.1
2.7
3.6
2.0
3.6
Private
Systems
Current
Revenues
79.2
86.5
71.6
67.5
85.9
73.6
92.9
64.0
81.2
DWSRF
Loans
0.0
0.0
0.0
0.0
3.2
0.0
14.1
36.0
0.1
DWSRF
Principal
Repayment
Forgiveness
0.1
0.0
0.0
11.6
0.0
0.0
0.0
0.0
0.5
Other
Government
Loans
3.3
0.3
8.6
2.4
22.6
17.6
15.3
0.0
3.3
Other
Government
Grants
0.0
4.9
14.8
11.6
18.3
8.8
0.0
0.0
4.8
Borrowing
from
Private
Sector
12.4
6.1
24.1
51.1
36.6
55.8
70.6
68.0
13.4
Other
7.5
3.9
6.9
9.3
10.4
0.0
0.0
0.0
6.0
Source:
Survey
2000,
volume
2,
Table
79.
11
Table
8
Percentage
of
Funds
by
Source
for
a
Average
System
Ownership
Type
Funding
Source
Public
Private
Current
Revenues
51%
78%

DWSRF
Loans
7%
0%

DWSRF
Principal
Repayment
Forgiveness
4%
0%

Other
Government
Loans
8%
2%

Other
Government
Grants
13%
4%

Borrowing
from
Private
Sector
14%
10%

Other
3%
5%

Sum
100%
100%

Source:
Survey,
2000,
volume
2,
Table
80.
Numbers
do
not
sum
due
to
rounding.

8.
References
ERG.
2004.
Eastern
Research
Group,
Inc.
"
Estimated
Number
of
Small
Entities
Owning
Drinking
Water
Facilities."
Memorandum
to
James
Covington,
III,
EPA
dated
4
August.

SBA.
2002.
Small
Business
Administration.
Small
Business
Size
Standards:
Size
Standards
by
2002
North
American
Industry
Classification
System.
Federal
Register
67:
56944.
6
September.

USEPA.
2003.
U.
S.
Environmental
Protection
Agency.
Preliminary
Effluent
Guidelines
Program
Plan
for
2004/
2005.
Federal
Register
68:
75515­
75531.
31
December.

USEPA.
2002.
U.
S.
Environmental
Protection
Agency.
Community
Water
System
Survey
2000.
Volumes
1
and
2,
EPA
815­
R­
02­
005A
and
EPA
815­
R­
02­
005B.
December.

USEPA.
1999.
U.
S.
Environmental
Protection
Agency.
Revised
Interim
Guidance
for
EPA
Rulewriters:
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Flexibility
Act.
March
29.
