1
February
24,
2006
MEMORANDUM
Subject:
Supporting
Analysis
for
a
County­
Level
Affordability
Screening
Approach
From:
Kira
Smith,
TAB
Jonathan
Shefftz,
Industrial
Economics,
Incorporated
Thru:
Dan
Olson
Affordability
Team
Leader,
TAB
To:
Record
In
its
February
Federal
Register
notice,
Small
Drinking
Water
Systems
Variances
 
Revision
of
Existing
National­
Level
Affordability
Methodology
and
Methodology
to
Identify
Variance
Technologies
that
are
Protective
of
Public
Health,
EPA
requests
comment
on
a
number
of
questions
related
to
the
methodology
the
Agency
uses
to
evaluate
the
affordability
of
its
National
Primary
Drinking
Water
Rules.
The
three
key
issues
are
as
follows:
­
First,
EPA
is
requesting
comment
upon
the
size
of
the
system
the
Agency
should
consider
as
representative
of
each
the
system
size
categories
specified
under
SDWA.
This
question
is
critical
to
determining
the
cost
each
household
must
pay
for
the
treatment
to
comply
with
a
new
regulation.
Smaller
systems
have
fewer
households
over
which
the
fixed
costs
of
treatment
can
be
distributed
and
therefore
experience
higher
household
costs.
EPA
is
specifically
asking
if
the
median
(
or
middle
sized)
or
tenth
percentile
(
a
system
that
serves
fewer
people
than
90
percent
of
the
other
systems
in
the
category)
should
be
selected
as
the
representative
system
for
the
category.
­
Second,
EPA
is
requesting
comment
upon
the
affordability
threshold
(
the
maximum
cost
that
is
affordable
to
customers
served
by
small
systems).
EPA
is
proposing
to
calculate
the
affordability
threshold
by
taking
a
percentage
of
the
median
annual
household
income
(
MHI)
among
small
systems
which
as
of
September
2005
was
between
$
40,000
and
$
44,000.
EPA
is
requesting
comment
upon
three
different
alternative
thresholds
equal
to:
0.25%
MHI
($
100
to
$
110
under
Sept.
2005
income
estimates),
0.50%
MHI
($
200
to
$
220
under
Sept.
2005
income
estimates),
or
0.75%
MHI
($
310
to
$
330
under
Sept.
2005
income
estimates)
2
­
Third,
EPA
is
requesting
comment
upon
whether
or
not
EPA
should
evaluate
affordability
strictly
on
a
national
level,
or
to
use
a
two­
step
process
that
includes
both
a
national­
level
evaluation
of
affordability,
and
a
second
analysis
conducted
at
the
County
level.
EPA
would
perform
this
second
step
only
when
the
first
step
found
a
standard
to
be
affordable
at
the
national
level.
EPA
would
evaluate
economic
data
to
identify
economically
disadvantaged
Counties
in
the
U.
S.
that
cannot
afford
to
comply
regardless
of
the
outcome
of
the
national
determination.

This
memorandum
provides
supporting
analysis
for
the
third
question,
whether
EPA
should
evaluate
affordability
by
using
a
two­
step
process
that
includes
both
a
national­
level
evaluation
of
affordability,
and
a
second
analysis
conducted
at
the
County
level.
In
developing
the
proposed
revisions
to
its
national
affordability
methodology,
EPA
carefully
considered
the
recommendations
of
its
Science
Advisory
Board
(
SAB)
and
the
National
Drinking
Water
Advisory
Council
(
NDWAC)
including
the
NDWAC
majority
report
and
National
Rural
Water
Association
(
NRWA)
minority
report.
The
SAB
stated
that
"
regional
income
measures
and
expenditure
baselines
would
capture
affordability
relative
to
the
resources
available
in
a
community
more
accurately
than
national
values;
however,
a
national
affordability
threshold
is
necessary
to
implement
the
fairness
goal."
The
NDWAC
recommended
that
EPA
establish
differential
regional
affordability
criteria
when
sufficient
supporting
data
are
available.
In
particular,
the
NDWAC
recommended
that
EPA
separate
the
median
household
income
(
MHI)
into
rural
and
urban
categories
to
more
accurately
reflect
actual
ability
and
willingness
to
pay.

County­
level
screening
approach
In
determining
how
to
both
consider
economically­
at­
risk
areas
and
implement
a
fair
national
affordability
methodology,
EPA
is
requesting
comment
on
a
two­
part
screen
at
the
national
and
then
county
level.
The
county­
level
screening
approach
is
based
on
analysis
presented
in
two
papers
by
Scott
Rubin
for
the
NRWA,
in
which
socioeconomic
criteria
(
median
household
income,
poverty
rate,
and
unemployment
rate)
are
applied
at
the
county
level
to
measure
a
community's
ability
to
afford
increased
water
costs.
1
EPA
considered
MHI
figures
based
on
geographic
regions
and
rural
versus
urban
areas.
Of
the
four
regions
in
the
U.
S.,
the
northeast
had
the
highest
MHIs,
whereas
the
south
had
the
lowest.
Income
in
the
Midwest
and
west
did
not
appear
to
have
systematic
differences.
Urban
household
income
was,
in
general,
higher
than
rural
income.
However,
Scott
Rubin's
NRWA
white
papers
suggested
that
MHI
alone
was
not
an
accurate
measure
of
the
ability
of
a
community
to
afford
increased
water
costs.
Mr.
Rubin
suggested
that
MHI
was
not
necessarily
related
to
the
incidence
of
poverty
and
recommended
that
EPA
concentrate
on
identifying
areas
that
are
economically
at­
risk
by
looking
at
counties
with
not
only
low
income,
but
also
high
poverty
and
high
unemployment.
EPA
is
requesting
comment
on
two
distinct
approaches
for
determining
affordability.
Both
approaches
would
start
by
determining
whether
the
incremental
household
cost
of
treatment
to
meet
a
new
regulation
exceeds
an
increment­
based
threshold.
Under
the
first
approach,
this
would
be
the
sole
criterion
for
determining
affordability.
Under
the
second
approach,
the
1
Rubin,
Scott
J.
2001.
White
Paper
for
National
Rural
Water
Association,
Criteria
to
Assess
the
Affordability
of
Water
Service.
Available
at
http://
www.
nrwa.
org
or
can
be
found
in
the
docket.

Rubin,
Scott
J.
2002.
White
Paper
for
National
Rural
Water
Association,
Criteria
to
Assess
Affordability
Concerns
in
Conference
Report
for
H.
R.
2620.
Available
at
http://
www.
nrwa.
org
or
can
be
found
in
the
docket.
3
approach
discussed
in
this
memo,
if
EPA
were
to
find
the
compliance
technology
affordable
at
the
national
level,
EPA
would
then
take
the
additional
step
of
identifying
counties
that
are
economically
at­
risk,
and
list
affordable
variance
technologies
for
small
systems
in
these
counties.
These
systems
could
then
apply
to
their
primacy
agency
for
a
variance.
In
other
words,
EPA
would
determine
that
any
regulation
is
potentially
unaffordable
for
small
systems
in
these
economically
at­
risk
counties.
Then,
as
with
the
current
approach,
EPA
would
leave
it
to
the
primacy
agency
to
evaluate
affordability
individually
for
systems
applying
for
a
variance,
as
they
are
required
to
do
under
the
SDWA
for
all
small
system
variance
requests
if
the
State
includes
such
variances
in
its
drinking
water
program.
The
national­
level
screen
would
work
the
same
way
as
under
the
national­
level
approach,
except
that
because
of
the
additional
screen
for
at­
risk
counties,
EPA
might
choose
a
higher
percentage
of
median
system
MHI
for
the
national
screen
than
it
would
under
the
first
approach.
Should
the
national­
level
screen
find
that
the
compliance
treatment
costs
are
affordable
for
some
or
all
small
systems,
the
Agency
would
proceed
to
a
county­
level
screen
to
identify
economically
at­
risk
counties,
in
which
States
could
still
grant
variances.
For
any
small
drinking
water
system
in
counties
deemed
to
be
at­
risk
in
this
second
part
of
the
affordability
test,
compliance
technologies
would
be
considered
potentially
unaffordable,
regardless
of
EPA's
national
per
household
cost
estimates,
and
it
would
be
up
to
the
primacy
agency
to
grant
variances
where
appropriate
based
on
a
system
specific
analysis
of
affordability.
That
is,
States
would
be
enabled
to
determine,
based
on
the
criteria
in
SDWA
Section
1415(
e),
whether
to
grant
small
system
variances
to
small
systems
in
those
at­
risk
counties.
EPA
is
requesting
comment
on
three
socioeconomic
triggers
for
the
county­
level
screen:
(
1)
MHI
less
than
or
equal
to
65
percent
of
the
national
MHI,
(
2)
poverty
rate
at
least
twice
the
national
average,
or
(
3)
two­
year
average
unemployment
rate
at
least
twice
the
two­
year
national
average.
Under
this
option,
triggering
any
one
of
these
measures
would
be
sufficient
to
trigger
a
finding
of
unaffordability
for
small
systems
within
the
county.
Therefore,
this
methodology
allows
for
regional
socioeconomic
conditions
to
supplement
the
national­
level
affordability
determination.
Exhibit
1
below
displays
initial
estimates
to
convey
a
sense
of
how
many
counties,
small
systems
within
those
counties,
and
populations
served
by
those
systems,
would
be
eligible
to
apply
for
variances
under
the
three
socioeconomic
triggers.
4
Exhibit
1
Results
of
County­
Level
Screen
Criterion
Number
of
Counties
%
of
All
Counties
Number
of
Small
Systems
%
of
All
Small
Systems
Population
Served
%
of
National
Population
MHI
<=
0.65%
National
MHI
356
11.3%
3,485
7.3%
4,372,677
1.5%

Poverty
Rate
=>
Twice
National
Average
81
2.6%
532
1.1%
950,205
0.3%

2­
Year
Unemployment
Rate
=>
Twice
National
Average
80
2.5%
920
1.9%
1,391,226
0.5%

One
or
more
of
the
Above
410
13.1%
4,249
8.8%
5,485,158
1.9%

Notes:

1.
MHI
test
is
based
on
county­
level
and
national
data
for
2005
MFI
estimates
from:

http://
www.
huduser.
org/
datasets/
il.
html
2.
Poverty
test
is
based
upon
2003
data
from
http://
www.
census.
gov/
hhes/
www/
saipe/
saipe.
html
3.
Unemployment
test
is
based
upon
2003
and
2004
data
from
http://
www.
bls.
gov/
lau/
home.
htm
Exhibits
2
and
3
show
how
the
measures
and
cut­
off
values
for
these
socioeconomic
triggers
compare
to
those
for
other
EPA
programs
and
at
other
federal
agencies.
The
following
pages
feature
additional
exhibits
that
display
geographical
representations
of
where
these
counties
are
located,
as
well
as
the
number
of
small
systems
within
them
along
with
the
populations
they
serve.
Specifically,
Exhibit
4
shows
the
location
of
counties
that
would
be
eligible
to
apply
for
variances
under
the
previously
presented
criteria
for
a
county­
level
screen.
Exhibit
5
provides
counts
for
small
systems
located
within
those
counties.
Exhibit
6
illustrates
the
population
levels
collectively
served
by
these
small
systems
within
each
application­
eligible
county.
And
finally,
Exhibit
7
repeats
the
same
graphs
for
Alaska.
(
No
separate
graphs
are
provided
for
Hawaii,
since
no
counties
in
that
state
triggered
any
of
the
criteria.)
5
Exhibit
2
Selected
Examples
of
Socioeconomic
Triggers
for
Other
EPA
Programs
Office/
Guidelines
Purpose/
Context
Socioeconomic
Indicator(
s)
Threshold(
s)

Office
of
Water;

Programs
Operations
Facilities
Requirement
Division
Financial
Capability
Guidebook
(
1984)
$
Determine
eligibility
for
grants
to
finance
the
construction
of
a
wastewater
facility.

$
If
the
community
can
demonstrate
the
capability
to
pay
for
the
capital
investment
and
the
cost
of
operation
and
maintenance,
then
it
will
qualify.
Rate
of
Change
of
Population
(
many
other
indicators,
but
all
focused
on
financial
condition)
Weak
<
­
1%,
Average
­
1%
to
1%,
Strong
>
1%

Region
5,
Water
Division,
NPDES
Support
and
Technical
Assistance
Branch
Procedures
for
Conducting
Municipal
Financial
Capability
Analysis
in
Support
of
Water
Enforcement
Actions
(
December
1999)
$
To
determine
if
financial
or
economic
constraints
limit
the
ability
to
pay
penalties
or
comply
with
regulations.

$
Procedures
are
divided
into
a
preliminary
Phase
I
(
with
a
socioeconomic
focus),
a
follow­
on
Phase
II,
plus
a
Phase
III
for
litigation
support.

$
As
both
Phase
I
and
II
are
very
comprehensive
and
detailed,
only
selected
indicators
are
provided
here.
$
Examination
of
recent
Census
data,

making
comparisons
to
State,
County,

and/
or
Standard
Metropolitan
Statistical
Area
averages
$
Comparative
analysis
of
historical
and
projected
population
and
income
data
$
Review
of
employment
trends
at
the
County
or
Metro
level
and
compared
to
State
of
National
Averages
Conclusions
from
the
socioeconomic
data
should
enable
a
classification
of
the
community's
socioeconomic
condition
as
average,
above
average,
or
below
average.
6
Exhibit
2
Selected
Examples
of
Socioeconomic
Triggers
for
Other
EPA
Programs
Office/
Guidelines
Purpose/
Context
Socioeconomic
Indicator(
s)
Threshold(
s)

Office
of
Water,

Office
of
Water
Management
Combined
Sewer
Overflows
(
CSO):

Guidance
for
Financial
Capability
Assessment
and
Schedule
Development
(
March
1997)
Residential
Indicator
determines
the
financial
impact
of
current
and
proposed
waste
water
treatment
and
combined
sewer
overflow
controls
on
residential
users
(
first­
stage
screening).

If
the
residential
indicator
is
above
2%,

then
a
second­
stage
test
is
administered
to
assess
the
financial
capacity
of
the
permittee,
which
includes
some
socioeconomic
measures.

A
composite
score
is
generated
based
on
how
these
indicators
compare
to
industry
or
national
averages
(
with
weak
assigned
1
point,
mid­
range
2
points,

and
strong
3).
The
total
score
determines
the
appropriate
control
implementation
schedule
(
i.
e.,
low
burden
entailing
normal
engineering
construction,
medium
burden
an
extended
schedule,
and
high
burden
an
even
more
extended
schedule).
Unemployment
(
relative
to
national
average)

Median
Household
Income
(
relative
to
national
average)
Weak:
>
1%
above,
Mid­
range:
+/­
1%,

Strong:
>
1%
below
Weak:
>
25%
below,
Mid­
range:
+/­
25%,

Strong:
>
25%
above
7
Exhibit
2
Selected
Examples
of
Socioeconomic
Triggers
for
Other
EPA
Programs
Office/
Guidelines
Purpose/
Context
Socioeconomic
Indicator(
s)
Threshold(
s)

Office
of
Water
Office
of
Wastewater
Management
To
determine
if
the
cost
of
compliance
with
WQS
will
prove
difficult
for
the
municipality
and
its
households.
Unemployment
Weak:
>
1%
above
National
Average
Mid­
range:
National
Average
Strong:
>
1%
below
National
Average
Economic
Guidance
for
Water
Quality
Standards
(
WQS)
(
April
1995)
If
compliance
costs
exceed
0.8%
of
MHI,

then
a
second­
stage
test
is
administered
to
assess
the
financial
capacity
of
the
municipality.

Financial
capacity
is
examined
on
three
levels:
debt
capacity,
socioeconomic
health,
and
financial
management.
A
composite
score
is
generated
from
these
indicators
to
determine
whether
there
is
reason
to
downgrade
the
water
quality
standard.
Median
Household
Income
Weak:
>
10%
below
State
Median
Mid­
range:
State
Median
Strong:
>
10%
above
State
Median
Office
of
Enforcement
and
Compliance
Assurance,
Office
of
Regulatory
Enforcement
Municipal
Ability
to
Pay
Model
­
MUNIPAY
To
assess
the
municipality's
ability
to
pay
for
compliance
costs
and/
or
penalties:

not
media­
or
office­
specific.

Note
that
thresholds
act
as
a
multiple
constraint
model.
The
following
indicators
are
used
for
both
the
1990
and
2000
Census,
and
compared
both
over
time
and
to
national
and
state
values:

Population
Percent
Population
below
Age
18
Percent
Population
65
and
above
Percent
Individuals
below
125%
of
Poverty
Median
Home
Value
and
%
of
State
Value
Median
Household
Income
and
%
of
State
No
thresholds
are
employed,
and
instead
the
comparison
is
only
for
background
information.
8
Exhibit
3
Selected
Examples
of
Socioeconomic
Triggers
at
Other
Federal
Agencies
Agency/
Guidelines
Purpose/
Context
Indicator(
s)
Threshold(
s)

U.
S.
Department
of
Agriculture,

Rural
Utilities
Service
Water
and
Waste
Loans
and
Grants
(
Revised
June
1999)
$
To
determine
eligibility
for
loans
and/
or
grant
funds
for
water
and
waste
projects
in
an
effort
to
ensure
affordable
user
costs
for
rural
residents
and
businesses.

$
Once
eligibility
is
determined,

applications
are
ranked
and
funding
level
is
based
on
MHI
as
well
as
a
composite
score
based
on
population,
health
priorities,

and
related
criteria.

$
Special
consideration
is
given
to
Rural
or
Native
Alaskan
Villages.
Median
Household
Income
(
MHI)
$
Below
the
poverty
line
or
80%
of
the
state
non­
metropolitan
median
income:
project
receives
up
to
75%
funding
$
More
than
80%
of
state
non­
metropolitan
median
income,
but
less
than
100%:

project
receives
up
to
45%
funding
Population
$
<
1,500
=
30
points
$
>
1,500
to
3,000
=
20
points
$
>
3,000
to
5,000
=
15
points
MHI
relative
to
statewide
nonmetropolitan
MHI
$
<
70%
=
30
points
$
70
to
80%
=
20
points
$
80
to
90%
=
10
points
$
>
90%
=
0
points
Applicants
are
awarded
additional
points
(
and
given
higher
priority
status)
depending
on
the
cause
of
decline
in
water
quality/
quantity.
Decline
stems
from
or
quality
issues
involve:

$
Private
individually
owned
wells
or
other
individual
sources
of
water
=
30
points
$
Established
system=
s
water
source
=
20
points
U.
S.
Department
of
Agriculture,

Rural
Utilities
Service
Emergency
Community
Water
Assistance
Grants
(
July
2001)
$
To
determine
priority
status
for
grant
money
that
will
address
a
significant
decline
in
the
quantity
or
quality
of
drinking
water.

$
A
higher
score
is
given
higher
priority
(
as
reflected
in
the
assigned
points
listed
under
the
threshold
column)
and
allocated
more
funds
Other
Factors
$
In
case
of
acute
shortage
=
10
points
$
Geographic
distribution
of
funds,
rural
residents
hauling
water,
severe
contamination
levels,
etc.
=
30
points
(
at
the
discretion
of
the
Administrator)
9
Exhibit
3
Selected
Examples
of
Socioeconomic
Triggers
at
Other
Federal
Agencies
Agency/
Guidelines
Purpose/
Context
Indicator(
s)
Threshold(
s)

If
determined
to
be
eligible,
then
an
area
is
able
to
receive
a
grant.
The
size
of
the
grant
is
determined
by
additional
factors
in
a
second­
round
analysis.
Population/
Location
Eligible
if:

$
central
city
of
Metropolitan
Statistical
Area;

$
metropolitan
area
with
a
population
of
at
least
50,000;
or,

$
urban
counties
with
a
population
of
at
least
200,000
(
excluding
population
of
entitled
cities).

"
A"
is
an
average
of
the
following
ratios,
dividing
the
city/
county's
indicator
by
that
for
all
metropolitan
areas:

$
population;

$
extent
of
poverty;
and,

$
extent
to
which
housing
is
overcrowded.

U.
S.
Department
of
Housing
and
Urban
Development
Eligibility
for
Community
Development
Block
Grants
­

Entitlement
Communities
Eligibility
for
Renewal
Communities,
Empowerment
Zones,
and
Enterprise
Communities
(
Current
Guidelines)
Grant
Size:
If
found
to
be
eligible
for
a
grant,
then
the
size
of
the
grant
is
determined.
Indian
Tribes
receive
special
consideration
and
1%
of
total
appropriated
funds
are
reserved
for
such
applicants
(
from
this
pool,
funds
are
allocated
competitively
among
tribes).
The
remaining
funds
are
divided
among
the
eligible
areas
on
the
following
basis:
The
percent
of
total
funds
appropriated
in
a
year
and
given
to
a
specific
area
is
based
on
two
averages,
comprising
different
metrics,
both
of
which
reflect
the
conditions
of
the
area.
"
B"
is
an
average
of
the
following
ratios,
dividing
the
city/
county's
indicator
by
that
for
all
metropolitan
areas:

$
extent
of
growth
lag;

$
extent
of
poverty;
and,

$
age
of
housing.
Out
of
the
total
funds
appropriated,
the
proportion
to
be
received
by
a
given
metropolitan
city/
county
is
based
on
the
greater
of
Average
"
A"
or
"
B"
for
that
city/
county.

U.
S.
Department
of
Health
and
Human
Services
(
HHS)

Administration
for
Children
and
Families
Community
Services
Block
Grant
(
Current
Guidelines)
Grants
are
made
to
states,
which
distribute
funds
to
entities
that
provide
services
to
low­
income
individuals
and
families.
Eligible
entities
are
identified
based
on
the
income
level
of
the
constituency
they
serve.
Income
level
of
served
constituency.
$
Income
<
Poverty
line
(
States
can
revise
the
income
limit,
but
it
must
not
exceed
125
percent
of
the
official
poverty
line.)
10
Exhibit
3
Selected
Examples
of
Socioeconomic
Triggers
at
Other
Federal
Agencies
Agency/
Guidelines
Purpose/
Context
Indicator(
s)
Threshold(
s)

U.
S.
Department
Commerce
Economic
Development
Administration
Grants
for
Public
Works
and
Economic
Development
Facilities
(
January
1,
2001)
If
at
least
one
criterion
is
met,
areas
receive
grants
for
projects
that
provide
long­
term
economic
development
and
assist
in
the
construction
of
public
works
and
economic
development
facilities,
in
order
to
create
or
retain
high­
skill,

high­
wage
jobs
in
the
private
sector.
$
Unemployment
Rate
$
Per­
capita
income
$
Special
circumstances
that
will
cause
or
have
caused
severe
unemployment
or
economic
adjustment
problems
$
>
1%
above
national
average
$
<
80%
of
national
average
$
Out­
migration,
underemployment,
military
base
closure
or
realignment,
natural
or
other
major
disasters,
extraordinary
depletion
of
natural
resources,
closure
or
restructuring
of
industrial
firms,
and/
or
destructive
impacts
of
foreign
trade.

Round
I
Communities:

$
Population
$
Poverty,
unemployment,
general
distress
$
Poverty
rate
$
Capped
at
30,000
$
"
Pervasive";
indicators
may
include
per
capita
income
(
below­
average
level,
or
decline),
earnings
per
worker,
per
capita
property
tax
base,
average
years
of
school
completed,
out­
migration
and
population
decline
$
At
least
20%
in
each
census
track,
25%
in
90%
of
the
covered
census
tracks,
and
35%
in
50%
of
the
covered
census
tracks
U.
S.
Department
of
Agriculture
Rural
Development
Rural
Empowerment
Zone
and
Enterprise
Community
Program
Three
rounds
of
community
designations
(
representing
different
rounds
of
funding,
not
multi­
phase
socioeconomic
screens)
have
entailed
various
levels
of
benefits;

some
communities
that
applied
for
and
received
benefits
under
initial
rounds
have
later
applied
for
and
received
benefits
under
later
rounds.

Note
that
only
the
more
relevant
socioeconomic
measures
are
displayed
here.
Round
II
and
III
Communities:

$
Essentially
the
same
as
Round
I,
but
an
out­
migration
test
may
be
substituted
for
the
poverty
test.

Round
I
Communities:

$
Poverty,
unemployment,
general
distress
$
Unemployment
rate
$
Poverty
rate
$
Income
levels
$
"
Pervasive"

$
150%
of
national
level
$
At
least
20%
in
each
census
track
and
35%
in
50%
of
the
covered
census
tracks
$
For
urban
areas,
at
least
70%
of
households
must
have
incomes
below
80%
of
the
local
area
average
U.
S.
Department
of
Housing
and
Urban
Development
Community
Planning
and
Development
Empowerment
Zones,
Enterprise
Communities,
Renewal
Communities
Round
II
and
III
Communities:

$
Essentially
the
same
as
Round
I,
but
no
requirement
for
at
least
35%
poverty
rate
in
50%
of
the
covered
census
tracks
11
Exhibit
4
Locations
of
Counties
Triggering
One
or
More
Criteria
12
Exhibit
5
Small
System
Counts
for
Application­
Eligible
Counties
13
Exhibit
6
Populations
Served
by
Small
Systems
in
Application­
Eligible
Counties
14
Exhibit
7
Application­
Eligible
Counties,
Small
System
Counts,
and
Populations
Served
in
Alaska
15
16
