1U.
S.
Environmental
Protection
Agency.
1999.
Revised
Interim
Guidance
for
EPA
Rulewriters:
Regulatory
Flexibility
Act
as
amended
by
the
Small
Business
Regulatory
Enforcement
Flexibility
Act.
March
29.

2SBA.
2002.
Small
Business
Administration.
Small
Business
Size
Standards:
Size
Standards
by
2002
North
American
Industry
Classification
System.
Federal
Register
67:
56944.
6
September.

1
Date:
4
August
2004
To:
James
Covington,
EPA
From:
Maureen
F.
Kaplan
and
Ian
Cadillac,
ERG
Subject:
Estimated
Number
of
Small
Entities
Owning
Drinking
Water
Facilities
1.
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
50,000.1
For
the
purpose
of
this
memorandum,
we
assume
that
a
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.
2
2.
Summary
All
counts
are
based
on
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").
Table
1
summarizes
the
estimated
number
of
drinking
water
facilities
that
might
be
within
scope
of
an
effluent
limitations
guideline
(
ELG)
and
how
many
of
them
might
belong
to
small
entities.
The
remainder
of
this
memorandum
documents
the
calculations
to
arrive
at
these
estimates.

There
are
an
estimated
52,186
drinking
water
systems
nationwide.
The
effluent
limitation
guideline
would
apply
to
approximately
17
percent
of
the
drinking
water
industry
(
8,830
of
52,186
facilities).
However,
nearly
97
percent
of
these
facilities
belong
to
small
entities,
both
public
and
private
(
8,582
of
8,830
facilities).

These
are
estimates
based
on
the
information
presented
in
Survey
2000.
Should
EAD
decide
to
investigate
this
industry
further,
we
would
recommend
arranging
access
to
the
individual
responses
and
survey
weights
with
ODWGW.
2
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
3.
Methodology
and
Calculations
3.1
Number
and
Percentage
of
Systems
by
Primary
Source
of
Water
Survey
2000
presents
much
of
the
findings
categorized
by
the
primary
source
of
water
and
the
population
served
by
the
system.
In
contrast,
an
ELG
focuses
on
where
the
water
is
discharged
to
and
the
volume
of
that
discharge.
Survey
2000
provides
enough
information
to
estimate
the
number
of
facilities
that
might
be
within
the
initial
scope
of
an
ELG;
this
memorandum
documents
the
assumptions
and
calculations
used
to
obtain
these
estimates.

Table
2
summarizes
the
facility
count
by
water
source
and
population
served.
Note
that
Survey
2000
provides
two
counts
per
water
source,
the
count
of
facilities
that
draw
(
1)
draw
100
percent
of
their
water
from
that
source,
and
(
2)
most
of
their
water
from
that
source.
There
are
35,308
facilities
with
draw
their
water
solely
from
ground
water
sources
and
another
3,280
facilities
that
draw
most
of
their
water
from
ground
water
sources.
There
are
4,595
facilities
with
draw
their
water
solely
from
surface
water
sources
and
another
1,024
facilities
that
draw
most
of
their
water
from
surface
water
sources.
There
are
6,933
facilities
that
purchase
all
of
their
water
from
someone
else
and
another
1,046
facilities
that
purchase
most
of
their
water
from
someone
else.
3
Table
2
Facility
Counts
by
Water
Source
and
Population
Served
Water
Population
Subtotal
Percentage
from
Source
Source
Served
Count
by
Source
100%
Mostly
Ground
25
­
100
11,756
10,358
1,398
101
­
500
13,145
12,521
624
501­
3300
8,970
8,687
283
3301
­
10,000
3,071
2,576
495
10,001
­
50,000
1,340
971
368
50,001
­
100,000
136
80
56
100,001
­
500,000
161
108
53
500,000+
10
7
3
38,589
35,308
3,280
Surface
25
­
100
833
790
43
101
­
500
1,136
897
239
501­
3300
1,212
1,015
197
3301
­
10,000
1,008
835
173
10,001
­
50,000
988
769
220
50,001
­
100,000
210
140
70
100,001
­
500,000
178
113
65
500,000+
53
36
17
5,618
4,595
1,024
Purchased
25
­
100
69
69
0
101
­
500
2,180
2,050
130
501­
3300
3,834
3,412
423
3301
­
10,000
973
773
200
10,001
­
50,000
685
476
209
50,001
­
100,000
125
94
31
100,001
­
500,000
92
46
45
500,000+
21
13
8
7,979
6,933
1,046
Source:
Survey
2000,
volume
2,
Tables
1
and
2.
4
3.2
BAT
Facilities
3.2.1
Count
Survey
2000,
volume
2,
Table
29
lists
the
percentage
of
plants
that
discharge
directly
to
surface
water.
We
assume
this
would
capture
the
BAT
population.
The
table
does
not
include
facilities
that
treat
purchased
water.
The
table
provides
the
percentages
by
three
categories
of
water
source:
ground
water,
surface
water
and
mixed
sources.
We
scaled
the
counts
for
100
percent
ground
water
by
the
ground
water
percentages
(
35,308
facilities,
see
Table
2),
the
counts
for
100
percent
surface
water
by
the
surface
water
percentages
(
4,595
facilities,
see
Table
2),
and
the
counts
for
the
sum
of
facilities
that
get
most
of
their
water
from
either
ground
water
or
surface
water
sources
(
3,280
or
1,024
facilities,
see
Table
2).

Table
3
presents
the
calculations.
There
are
an
estimated
5,694
BAT
drinking
water
facilities.

3.2.2
Public
versus
Private
The
definition
of
a
small
entity
differs
by
whether
it
is
public
or
private
(
commercial)
in
organization.
Survey
2000,
volume
2,
Table
3
provides
a
breakout
of
the
counts
of
total
facilities,
public
facilities,
and
private
facilities
by
water
source.
(
Survey
2000
mentions
that
facilities
that
purchase
water
are
not
included
in
the
table.)
This
information
is
summarized
in
Table
4
below.

ERG
multiplied
the
number
of
facilities
that
discharge
directly
to
surface
waters
from
Table
3
by
the
percentages
shown
in
Table
4
to
estimate
the
number
of
public
BAT
facilities.
The
number
of
private
facilities
was
calculated
by
difference
(
see
Table
5).
ERG
estimates
that
there
are
approximately
2,515
public
and
3,179
private
drinking
water
facilities
that
are
direct
dischargers.

3.2.3
Drinking
Water
Facilities
Belonging
to
Small
Entities
As
mentioned
in
Section
1,
drinking
water
facilities
that
serves
populations
of
50,000
or
fewer
are
considered
"
small."
To
estimate
the
number
of
small
public
drinking
water
facilities,
we
sum
the
number
of
facilities
in
the
five
size
categories
that
serve
<=
50,000
persons
for
each
of
the
four
water
source
categories
in
Table
5.
There
are
2,378
small
public
drinking
water
facilities.
Another
way
of
saying
it
is
that
94.6
percent
of
the
public
drinking
water
facilities
belong
to
small
entities.

To
calculate
the
number
of
drinking
water
facilities
that
belong
to
small
commercial
businesses,
we
need
to
estimate
the
population
size
categories
which
correspond
to
$
6
million
in
revenues
or
less.
We
also
make
the
simplifying
assumption
that
all
private
drinking
water
facilities
are
in
NAICS
category
221310.
Survey
2000,
volume
1,
page
8
states
that,
of
the
private
community
water
systems
#
34
percent
are
run
as
not­
for­
profit
entities
#
27
percent
are
run
as
for­
profit
entities,
and
#
39
percent
are
privately
owned
ancillary
systems.
That
is,
the
primary
business
is
not
water
supply
but
the
business
supplies
water
as
an
integral
part
of
their
business.
5
Table
3
Estimated
Number
of
BAT
Facilities
100%
Groundwater
Count
%
Direct
Discharge
Estimated
Number
of
BAT
Facilities
Pop
Served
25
­
100
10,358
6.6%
684
101
­
500
12,521
4.4%
551
501­
3300
8,687
11.7%
1,016
3301
­
10,000
2,576
3.3%
85
10,001
­
50,000
971
7.0%
68
50,001
­
100,000
80
4.0%
3
100,001
­
500,000
108
17.0%
18
500,000+
7
0.4%
0
Subtotal
35,308
2,425
100%
Surface
Water
Pop
Served
25
­
100
790
8.4%
66
101
­
500
897
32.5%
292
501­
3300
1,015
29.5%
299
3301
­
10,000
835
32.4%
271
10,001
­
50,000
769
17.2%
132
50,001
­
100,000
140
16.2%
23
100,001
­
500,000
113
14.7%
17
500,000+
36
14.3%
5
Subtotal
4,595
1,105
Mixed
Plants­
Mostly
Goundwater
Pop
Served
25
­
100
1,398
100.0%
1,398
101
­
500
624
33.6%
210
501­
3300
283
0.0%
0
3301
­
10,000
495
24.1%
119
10,001
­
50,000
368
31.5%
116
50,001
­
100,000
56
39.9%
22
100,001
­
500,000
53
19.5%
10
500,000+
3
66.7%
2
Subtotal
3,280
1,878
Mixed
Plants­
Mostly
Surface
Water
Pop
Served
25
­
100
43
100.0%
43
101
­
500
239
33.6%
80
501­
3300
197
0.0%
0
3301
­
10,000
173
24.1%
42
10,001
­
50,000
220
31.5%
69
50,001
­
100,000
70
39.9%
28
100,001
­
500,000
65
19.5%
13
500,000+
17
66.7%
11
Subtotal
1,024
286
6
Source:
Survey
2000,
volume
2,
Table
29.
7
Table
4
Percentage
of
Drinking
Water
Facilities
that
are
Publicly
Owned
Water
Source
Population
Served
Total
Count
Public
Count
Percent
Ground
25
­
100
11,756
489
4.2%

101
­
500
13,145
3,556
27.1%

501­
3300
8,970
6,694
74.6%

3301
­
10,000
3,071
2,560
83.4%

10,001
­
50,000
1,340
1,080
80.6%

50,001
­
100,000
136
124
91.2%

100,001
­
500,000
161
143
88.8%

500,000+
10
9
90.0%

Surface
25
­
100
833
245
29.4%

101
­
500
1,136
683
60.1%

501­
3300
1,212
1,139
94.0%

3301
­
10,000
1,008
935
92.8%

10,001
­
50,000
988
894
90.5%

50,001
­
100,000
210
182
86.7%

100,001
­
500,000
178
162
91.0%

500,000+
53
49
92.5%

Source:
Survey
2000,
volume
2,
Table
3.
8
Table
5
Number
of
Public
and
Private
BAT
Facilities
100%
Groundwater
Estimated
number
of
BAT
Facilities
Percent
Public
(
from
Table
4)
Number
of
BAT
Facilities
by
Ownership
Public
Private
Pop
Served
25
­
100
684
4.2%
28
655
101
­
500
551
27.1%
149
402
501­
3300
1,016
74.6%
758
258
3301
­
10,000
85
83.4%
71
14
10,001
­
50,000
68
80.6%
55
13
50,001
­
100,000
3
91.2%
3
0
100,001
­
500,000
18
88.8%
16
2
500,000+
0
90.0%
0
0
Subtotal
2,425
1,081
1,345
100%
Surface
Water
Pop
Served
25
­
100
66
29.4%
20
47
101
­
500
292
60.1%
175
116
501­
3300
299
94.0%
281
18
3301
­
10,000
271
92.8%
251
20
10,001
­
50,000
132
90.5%
120
13
50,001
­
100,000
23
86.7%
20
3
100,001
­
500,000
17
91.0%
15
1
500,000+
5
92.5%
5
0
Subtotal
1,105
886
218
Mixed
Plants­
Mostly
Groundwater
Pop
Served
25
­
100
1,398
4.2%
58
1,340
101
­
500
210
27.1%
57
153
501­
3300
0
74.6%
0
0
3301
­
10,000
119
83.4%
99
20
10,001
­
50,000
116
80.6%
93
22
50,001
­
100,000
22
91.2%
20
2
100,001
­
500,000
10
88.8%
9
1
500,000+
2
90.0%
2
0
Subtotal
1,878
339
1,538
Mixed
Plants­
Mostly
Surface
Water
Pop
Served
25
­
100
43
29.4%
13
30
101
­
500
80
60.1%
48
32
501­
3300
0
94.0%
0
0
3301
­
10,000
42
92.8%
39
3
10,001
­
50,000
69
90.5%
63
7
50,001
­
100,000
28
86.7%
24
4
100,001
­
500,000
13
91.0%
12
1
500,000+
11
92.5%
10
1
9
Subtotal
286
209
78
Source:
Survey
2000,
volume
2,
Tables
3
and
29.
That
is,
nearly
four
out
of
every
ten
private
drinking
water
systems
might
belong
to
a
NAICS
code
other
than
221310.
The
NAICS
code
of
the
ancillary
systems
would
determine
the
size
standard
to
use
to
classify
the
drinking
water
facility
as
large
or
small.
Should
EPA
perform
a
more
in­
depth
analysis,
we
would
suggest
discussing
with
OGWDW
whether
this
information
can
be
teased
out
of
the
Survey
2000
data.

Survey
2000,
volume
2,
Table
47
presents
total
revenue
by
ownership
by
population
served.
The
table
presents
the
mean
and
the
95
percent
confidence
interval.
Table
6
uses
this
information
to
calculate
the
range
in
revenue
for
each
size
category.
Drinking
water
systems
that
serve
populations
of
50,000
persons
or
fewer
show
less
than
$
6
million
in
annual
revenues.
The
same
five
size
categories
used
to
estimate
the
number
of
small
public
drinking
water
systems
can
be
used
to
estimate
the
number
of
small
private
drinking
water
systems.
There
are
3,163
small
private
drinking
water
facilities.
Another
way
of
saying
it
is
that
99.5
percent
of
the
private
drinking
water
facilities
belong
to
small
entities.

Table
6
Total
Revenues
for
Private
Organizations
by
Population
Served
Revenues
(
Thousands)
Range
Population
Served
Mean
Conf.
Int.
Lower
Upper
Small?

25
­
100
6
2
4
8
Yes
101
­
500
21
7
14
28
Yes
501­
3300
178
56
122
234
Yes
3301
­
10,000
792
302
490
1,094
Yes
10,001
­
50,000
2,858
1,279
1,579
4,137
Yes
50,001
­
100,000
9,855
2,331
7,524
12,186
No
100,001
­
500,000
24,347
5,670
18,677
30,017
No
500,000+
139,210
15,984
123,226
155,194
No
Source:
Survey
2000,
volume
2,
Table
47.
10
3.3
PSES
Facilities
We
repeated
the
BAT
analysis
for
the
PSES
facilities
by
substituting
the
percentages
of
facilities
that
reported
discharging
residuals
to
a
sanitary
sewer
in
Survey
2000,
Volume
2,
Table
29.
The
PSES
analysis
is
summarized
in
Table
7.
There
are
3,136
PSES
facilities.
Of
these,
2,077
facilities
or
66
percent
belong
to
public
organizations.
Nearly
96
percent
of
the
public
organizations
are
small
(
1,991
of
2,077
facilities.
There
are
1,160
facilities
that
belong
to
private
organizations.
Nearly
91
percent
of
the
private
organizations
are
small
(
1,050
of
1,160
facilities).
11
Table
7
PSES
Analysis
Estimated
Facility
Counts
Water
Source
Population
Served
Count
%
Discharge
to
Sanitary
Sewer
%
Public
PSES
Public
Small
Public
Private
Small
Private
100%
Groundwater
25
­
100
10,358
0.8%
4.2%
83
3
3
79
79
101
­
500
12,521
6.0%
27.1%
751
203
203
548
548
501­
3300
8,687
12.5%
74.6%
1,086
810
810
276
276
3301
­
10,000
2,576
7.0%
83.4%
180
150
150
30
30
10,001
­
50,000
971
15.1%
80.6%
147
118
118
28
28
50,001
­
100,000
80
12.4%
91.2%
10
9
1
100,001
­
500,000
108
6.0%
88.8%
6
6
1
500,000+
7
4.2%
90.0%
0
0
0
Subtotal
35,308
2,264
1,301
1,286
963
961
100%
Surface
Water
25
­
100
790
0.0%
29.4%
0
0
0
0
0
101
­
500
897
5.6%
60.1%
50
30
30
20
20
501­
3300
1,015
23.0%
94.0%
233
219
219
14
14
3301
­
10,000
835
15.2%
92.8%
127
118
118
9
9
10,001
­
50,000
769
29.1%
90.5%
224
202
202
21
21
50,001
­
100,000
140
22.2%
86.7%
31
27
4
100,001
­
500,000
113
13.1%
91.0%
15
13
1
500,000+
36
28.2%
92.5%
10
9
1
Subtotal
4,595
690
620
570
71
65
Estimated
Facility
Counts
Water
Source
Population
Served
Count
%
Discharge
to
Sanitary
Sewer
%
Public
PSES
Public
Small
Public
Private
Small
Private
12
Mixed
Plants­
Mostly
Ground
water
.
25
­
100
1,398
0.0%
4.2%
0
0
0
0
0
101
­
500
624
0.0%
27.1%
0
0
0
0
0
501­
3300
283
0.0%
74.6%
0
0
0
0
0
3301
­
10,000
495
14.6%
83.4%
72
60
60
12
12
10,001
­
50,000
368
10.5%
80.6%
39
31
31
7
7
50,001
­
100,000
56
0.0%
91.2%
0
0
0
100,001
­
500,000
53
19.5%
88.8%
10
9
1
500,000+
3
0.0%
90.0%
0
0
0
Subtotal
3,280
121
101
91
21
20
Mixed
Plants­
Mostly
Surface
water
25
­
100
43
0.0%
29.4%
0
0
0
0
0
101
­
500
239
0.0%
60.1%
0
0
0
0
0
501­
3300
197
0.0%
94.0%
0
0
0
0
0
3301
­
10,000
173
14.6%
92.8%
25
23
23
2
2
10,001
­
50,000
220
10.5%
90.5%
23
21
21
2
2
50,001
­
100,000
70
0.0%
86.7%
0
0
0
100,001
­
500,000
65
19.5%
91.0%
13
12
1
500,000+
17
0.0%
92.5%
0
0
0
Subtotal
1,024
61
56
44
5
4
Column
Totals
44,207
3,136
2,077
1,991
1,060
1,050
Source:
Survey
2000,
Tables
3,
29,
and
47.
