 

Information Collection Request for 

The Community Water System Survey 2006 (CWSS)

(Supporting Statement)

September 8, 2006

Prepared by:

The Cadmus Group, Inc.

1620 Broadway, Suite G

Santa Monica, CA 90404

Prepared for:

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water

Standards and Risk Management Division

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TABLE OF CONTENTS

 tc "TABLE OF CONTENTS" 

  TOC \o "1-3" \h \z    HYPERLINK \l "_Toc146012787"  PART A OF THE
SUPPORTING STATEMENT	  PAGEREF _Toc146012787 \h  7  

  HYPERLINK \l "_Toc146012788"  A.1	IDENTIFICATION OF THE INFORMATION
COLLECTION	  PAGEREF _Toc146012788 \h  7  

  HYPERLINK \l "_Toc146012789"  A.1.a.	Title of the Information
Collection	  PAGEREF _Toc146012789 \h  7  

  HYPERLINK \l "_Toc146012790"  A.1.b.	Short Characterization	  PAGEREF
_Toc146012790 \h  7  

  HYPERLINK \l "_Toc146012791"  A.2	NEED FOR AND USE OF THE COLLECTION	 
PAGEREF _Toc146012791 \h  9  

  HYPERLINK \l "_Toc146012792"  A.2.a.	Need/Authority for the Collection
  PAGEREF _Toc146012792 \h  9  

  HYPERLINK \l "_Toc146012793"  A.2.b.	Use/Users of the Data	  PAGEREF
_Toc146012793 \h  10  

  HYPERLINK \l "_Toc146012794"  A.3.	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION CRITERIA	  PAGEREF _Toc146012794 \h  12  

  HYPERLINK \l "_Toc146012795"  A.3.a.	Nonduplication	  PAGEREF
_Toc146012795 \h  12  

  HYPERLINK \l "_Toc146012796"  A.3.b.	Public Notice Required Prior to
ICR Submission to OMB	  PAGEREF _Toc146012796 \h  13  

  HYPERLINK \l "_Toc146012797"  A.3.c.	Consultations	  PAGEREF
_Toc146012797 \h  13  

  HYPERLINK \l "_Toc146012798"  A.3.d.	Effects of Less Frequent
Collection	  PAGEREF _Toc146012798 \h  14  

  HYPERLINK \l "_Toc146012799"  A.3.e.	General Guidelines	  PAGEREF
_Toc146012799 \h  14  

  HYPERLINK \l "_Toc146012800"  A.3.f.	Confidentiality	  PAGEREF
_Toc146012800 \h  15  

  HYPERLINK \l "_Toc146012801"  A.3.g.	Sensitive Questions	  PAGEREF
_Toc146012801 \h  15  

  HYPERLINK \l "_Toc146012802"  A.4.	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc146012802 \h  16  

  HYPERLINK \l "_Toc146012803"  A.4.a.	Respondents/SIC Codes	  PAGEREF
_Toc146012803 \h  16  

  HYPERLINK \l "_Toc146012804"  A.4.b.	Information Requested	  PAGEREF
_Toc146012804 \h  16  

  HYPERLINK \l "_Toc146012805"  A.4.b.1.	Data Items	  PAGEREF
_Toc146012805 \h  17  

  HYPERLINK \l "_Toc146012806"  A.4.b.2.	Respondent Activities	  PAGEREF
_Toc146012806 \h  21  

  HYPERLINK \l "_Toc146012807"  A.5.	THE INFORMATION COLLECTED –
AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	 
PAGEREF _Toc146012807 \h  22  

  HYPERLINK \l "_Toc146012808"  A.5.a.	Agency Activities	  PAGEREF
_Toc146012808 \h  22  

  HYPERLINK \l "_Toc146012809"  A.5.b.	Collection Methodology and
Management	  PAGEREF _Toc146012809 \h  22  

  HYPERLINK \l "_Toc146012810"  A.5.c.	Small Entity Flexibility	 
PAGEREF _Toc146012810 \h  25  

  HYPERLINK \l "_Toc146012811"  A.5.d.	Collection Schedule	  PAGEREF
_Toc146012811 \h  25  

  HYPERLINK \l "_Toc146012812"  A.6	ESTIMATING THE BURDEN AND COST OF
THE COLLECTION	  PAGEREF _Toc146012812 \h  27  

  HYPERLINK \l "_Toc146012813"  A.6.a.	Estimating Respondent Burden	 
PAGEREF _Toc146012813 \h  27  

  HYPERLINK \l "_Toc146012814"  A.6.b.	Estimating Respondent Costs	 
PAGEREF _Toc146012814 \h  27  

  HYPERLINK \l "_Toc146012815"  A.6.c.	Estimating Agency Burden and
Costs	  PAGEREF _Toc146012815 \h  28  

  HYPERLINK \l "_Toc146012816"  A.6.d.	Estimating the Respondent
Universe and Total Burden Cost	  PAGEREF _Toc146012816 \h  28  

  HYPERLINK \l "_Toc146012817"  A.6.e.	Bottom Line Burden Hours and Cost
Tables	  PAGEREF _Toc146012817 \h  29  

  HYPERLINK \l "_Toc146012818"  A.6.f.	Reasons for Change in Burden	 
PAGEREF _Toc146012818 \h  30  

  HYPERLINK \l "_Toc146012819"  A.6.g.	Burden Statement	  PAGEREF
_Toc146012819 \h  30  

  HYPERLINK \l "_Toc146012820"  PART B OF THE SUPPORTING STATEMENT	 
PAGEREF _Toc146012820 \h  34  

  HYPERLINK \l "_Toc146012821"  B.1.	SURVEY OBJECTIVES, KEY VARIABLES,
AND OTHER PRELIMINARIES	  PAGEREF _Toc146012821 \h  34  

  HYPERLINK \l "_Toc146012822"  B.1.a.	Survey Objectives	  PAGEREF
_Toc146012822 \h  34  

  HYPERLINK \l "_Toc146012823"  B.1.b.	Key Variables	  PAGEREF
_Toc146012823 \h  34  

  HYPERLINK \l "_Toc146012824"  B.1.c.	Statistical Approach	  PAGEREF
_Toc146012824 \h  35  

  HYPERLINK \l "_Toc146012825"  B.1.d.	Feasibility	  PAGEREF
_Toc146012825 \h  35  

  HYPERLINK \l "_Toc146012826"  B.2	SURVEY DESIGN	  PAGEREF
_Toc146012826 \h  38  

  HYPERLINK \l "_Toc146012827"  B.2.a.	Target Population and Coverage	 
PAGEREF _Toc146012827 \h  38  

  HYPERLINK \l "_Toc146012828"  B.2.b.	Sample Design	  PAGEREF
_Toc146012828 \h  38  

  HYPERLINK \l "_Toc146012829"  B.2.b.1.	Sample Frame	  PAGEREF
_Toc146012829 \h  38  

  HYPERLINK \l "_Toc146012830"  B.2.b.2.	Sample Size	  PAGEREF
_Toc146012830 \h  39  

  HYPERLINK \l "_Toc146012831"  B.2.b.3.	Stratification Variables	 
PAGEREF _Toc146012831 \h  39  

  HYPERLINK \l "_Toc146012832"  B.2.b.4.	Sampling Method	  PAGEREF
_Toc146012832 \h  40  

  HYPERLINK \l "_Toc146012833"  B.2.b.5.	Multi-Stage Sampling	  PAGEREF
_Toc146012833 \h  41  

  HYPERLINK \l "_Toc146012834"  B.2.c.	Precision Requirements	  PAGEREF
_Toc146012834 \h  41  

  HYPERLINK \l "_Toc146012835"  B.2.c.1.	Precision Targets	  PAGEREF
_Toc146012835 \h  41  

  HYPERLINK \l "_Toc146012836"  B.2.c.2.	Nonsampling Error	  PAGEREF
_Toc146012836 \h  42  

  HYPERLINK \l "_Toc146012837"  B.2.d.	Questionnaire Design	  PAGEREF
_Toc146012837 \h  42  

  HYPERLINK \l "_Toc146012838"  B.3.	PRE-TESTS AND PILOT TESTS	  PAGEREF
_Toc146012838 \h  44  

  HYPERLINK \l "_Toc146012839"  B.3.a.	Pre-tests	  PAGEREF _Toc146012839
\h  44  

  HYPERLINK \l "_Toc146012840"  B.3.b.	Pilot Study	  PAGEREF
_Toc146012840 \h  44  

  HYPERLINK \l "_Toc146012841"  B.4.	COLLECTION METHODS AND FOLLOW-UP	 
PAGEREF _Toc146012841 \h  46  

  HYPERLINK \l "_Toc146012842"  B.4.a.	Collection Methods	  PAGEREF
_Toc146012842 \h  46  

  HYPERLINK \l "_Toc146012843"  B.4.b.	Survey Response and Follow-Up	 
PAGEREF _Toc146012843 \h  46  

  HYPERLINK \l "_Toc146012844"  B.5.	ANALYZING AND REPORTING SURVEY
RESULTS	  PAGEREF _Toc146012844 \h  48  

  HYPERLINK \l "_Toc146012845"  B.5.a.	Data Preparation	  PAGEREF
_Toc146012845 \h  48  

  HYPERLINK \l "_Toc146012846"  B.5.b.	Analysis	  PAGEREF _Toc146012846
\h  48  

  HYPERLINK \l "_Toc146012847"  B.5.c.	Reporting Results	  PAGEREF
_Toc146012847 \h  48  

  HYPERLINK \l "_Toc146012848"  Appendix A   Relevant Sections of
Statutes	  PAGEREF _Toc146012848 \h  50  

  HYPERLINK \l "_Toc146012849"  Appendix B  Comments and Response to
Comments	  PAGEREF _Toc146012849 \h  94  

  HYPERLINK \l "_Toc146012850"  Response:	  PAGEREF _Toc146012850 \h  98
 

  HYPERLINK \l "_Toc146012851"  Response:	  PAGEREF _Toc146012851 \h  99
 

  HYPERLINK \l "_Toc146012852"  Response:	  PAGEREF _Toc146012852 \h 
100  

  HYPERLINK \l "_Toc146012853"  Response:	  PAGEREF _Toc146012853 \h 
101  

 

LIST OF TABLES tc "LIST OF TABLES" 

 TOC \f D 

  TOC \h \z \t "Table Title" \c    HYPERLINK \l "_Toc140635588"  Table
A-1. Number of Water Systems	  PAGEREF _Toc140635588 \h  16  

  HYPERLINK \l "_Toc140635589"  Table A-2. Preliminary Burden and Cost
Estimate for Respondents	  PAGEREF _Toc140635589 \h  27  

  HYPERLINK \l "_Toc140635590"  Table A-3. Preliminary Burden and Cost
Estimate for the States	  PAGEREF _Toc140635590 \h  28  

  HYPERLINK \l "_Toc140635591"  Table A-4. Agency Burden Cost Estimates	
 PAGEREF _Toc140635591 \h  29  

  HYPERLINK \l "_Toc140635592"  Table A-5. Summary of Burden and Cost
Estimates	  PAGEREF _Toc140635592 \h  30  

  HYPERLINK \l "_Toc140635593"  Table B-1. Frame and Sample Sizes by
Strata	  PAGEREF _Toc140635593 \h  40  

 

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PART A OF THE SUPPORTING STATEMENT 

 tc "PART A OF THE SUPPORTING STATEMENT" A.1	IDENTIFICATION OF THE
INFORMATION COLLECTION  tc "A.1	IDENTIFICATION OF THE INFORMATION
COLLECTION " \l 2 

A.1.a.	Title of the Information Collection  tc "A.1.a	Title of the
Information Collection " \l 3 

The title of this information collection request (ICR) is Information
Collection Request for Community Water System Survey 2006. The Office of
Management and Budget (OMB) control number for this ICR is 2040-new; EPA
ICR No. 2232.01.

A.1.b.	Short Characterization  tc "A.1.b	Short Characterization " \l 3 

In compliance with Executive Order 12866, the Regulatory Flexibility
Act, and the Safe Drinking Water Act (SDWA), the U.S. Environmental
Protection Agency’s Office of Ground Water and Drinking Water (OGWDW),
Standards and Risk Management Division (SRMD) conducts periodic surveys
of the financial and operating characteristics of community water
systems (CWSs). This information is essential to support economic
analyses of the costs and benefits of new regulations and changes to
existing regulations on consumers, the water supply industry, and the
nation. The information also will be used to measure the financial
burden of EPA’s regulations on consumers and the industry.
Furthermore, data from the survey will help EPA identify, evaluate and
develop guidance on Best Management Practices used in water treatment
and distribution systems.

EPA will collect basic information on the infrastructure, organization
and financial characteristics of community water suppliers by a variety
of survey methods, depending on the size of the system. EPA estimates
that the survey will provide data from 1,703 respondents, requiring
5,938 hours to complete at a total cost to those respondents of
$203,293. Previous surveys of CWSs were conducted in 1976, 1982, 1986,
1995, and 2000 



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A.2	NEED FOR AND USE OF THE COLLECTION  tc "A.2	NEED FOR AND USE OF THE
COLLECTION " \l 2 

A.2.a.	Need/Authority for the Collection  tc "A.2.a	Need/Authority for
the Collection " \l 3 

The legal authority for this data collection is the Public Health
Service Act (Safe Drinking Water Act), Section 300j-4(1)(A), 33 U.S.C.
Section 1316. Copies of the relevant sections of this statute, cited in
the order they appear in this information collection request, are in
Appendix A.

EPA must conduct this survey in order to collect the data needed to
carry out its program development and management responsibilities under
the three sections of the 1996 SDWA Amendments which require that EPA
have financial information about water systems when performing several
regulatory functions. Section 300g-1(b)(3)(C) requires EPA to analyze
“quantifiable and nonquantifiable costs . . . [which] are likely to
occur solely as a result of compliance with the maximum contaminant
level,” and “the incremental cost and benefits associated with each
alternative maximum contaminant level considered.” Section
300g-1(b)(4)(D) instructs the Agency to take “cost into
consideration” when determining what constitutes “feasible”
technology for meeting prescribed Maximum Contaminant Levels (MCLs).
Section 300g-4(a)(1)(A) allows EPA to grant variances from National
Primary Drinking Water Regulations” on the condition that the system
install the best technology, treatment techniques, or other means, which
the Administrator finds are available (taking costs into
consideration).” Section 300g-4(e) makes special provision for
“Small System Variances” and notes that a variance under this
subsection may be available only to a system “that cannot afford to
comply, in accordance with affordability criteria established by the
Administrator (or the state in the case of a state that has primary
enforcement responsibility under Section 300g-2) with a national primary
drinking water regulation , . . .” Section 300g-4(e)(7) discusses the
Administrator's ongoing responsibility to publish information that will
assist states in developing affordability criteria. Section 300g-5(a)(1)
allows for a system to receive an exemption from meeting an MCL upon a
finding that “ . . . due to compelling factors (which may include
economic factors), . . . the public water system is unable to comply
with such contaminant level or treatment technique requirement or to
implement measures to develop an alternative source of supply.” 

Given this statutory background, it clearly is not possible to consider
treatment costs in a vacuum. Cost impacts can only be assessed when
something is known about the operations and treatment-in-place for
community water systems—conditions that establish the baseline costs
of those bearing the burden of future regulations. Economic factors
cannot be adequately considered unless the agency knows something about
water system economics. The issue of affordability requires additional
information on both costs and the financial condition of community water
systems. Further, the 1996 SDWA Amendments have added new dimensions to
compliance that imposes additional needs for information on the
operations of the regulated systems. The information from this survey,
therefore, is essential for the Agency to meet its statutory
obligations.

EPA also needs this data collection in order to meet its economic
analysis obligations under Executive Order 12866, its obligation to
assess and mitigate impacts under the Regulatory Flexibility Act
(including the additional requirements of the Small Business Regulatory
Enforcement Fairness Act of 1996, (SBREFA)). In addition, the Unfunded
Mandates Reform Act (UMRA) of 1995 requires that agencies assess the
impact of federal regulatory actions on state, local, and Tribal
governments. An effective analysis of incremental costs and benefits, as
required of Economic Analyses (EAs) under Executive Order 12866, plus
other economic analyses required by SBREFA and UMRA must begin with an
analysis of baseline costs. This survey will provide the Agency with
baseline information relating to the physical and financial
characteristics of drinking water systems. Such information provides the
opportunity to evaluate the incremental costs of new regulations as well
as to evaluate the consequences of previous actions. For example,
current EAs are unable to take into account current information on
storage and distribution costs when trying to model the likely responses
of a utility to new regulatory requirements. The results of this survey
will allow EPA to replace assumptions with actual, statistically valid,
supporting data and to introduce new factors relating to less capital
intensive treatment alternatives. Identifying cost-effective regulatory
options and establishing the efficacy of subsequent rules will be
immensely complicated, if not impossible, without accurate baseline
information to be supplied by the survey. 

When implementing regulations, there is considerable need for EPA to
provide additional guidance to state Public Water Supply Supervision
(PWSS) Programs and regulated community water systems. To better design
such guidance, EPA needs to know the operating and financial
characteristics of these systems. 

Finally, the 1996 Amendments to the SDWA created new, preventive
programs to help public water systems provide safe drinking water to
their customers. One of the most notable of these programs is Section
300g-9, “Capacity Development.” Under this Section, states must have
the “legal authority or other means to ensure that all new community
water systems … demonstrate technical, managerial, and financial
capacity with respect to [National Primary Drinking Water
Regulations].” States also need to have a “capacity development
strategy” that will help existing water systems acquire and maintain
technical, managerial, and financial capacity. The provisions of Section
300g-9 apply primarily to small water systems, and the information on
operating and financial characteristics of the proposed survey represent
vital background data for the implementation of Section 300g-9.

A.2.b.	Use/Users of the Data  tc "A.2.b	Use/Users of the Data " \l 3 

OGWDW, and particularly SRMD is the primary user of the data. OGWDW uses
the data in meeting its program management responsibilities under the
SDWA. This includes taking costs and economic factors into consideration
where required by statute (as indicated above) and in meeting the
agency’s responsibilities under Executive Order 12866, the Regulatory
Flexibility Act, SBREFA, and UMRA, as noted above. Specifically, staff
from SRMD will use the data in analyses and models which are used to
support calculations of the national costs and benefits associated with
proposed drinking water regulatory alternatives.

The Drinking Water Protection Division (DWPD) of OGWDW is responsible
for working with states and regulated water systems to implement all
regulations. To achieve their mission, staff in DWPD need information on
the operating and financial characteristics of water systems. DWPD also
is responsible for implementation of Section 300g-9, “Capacity
Development.” As indicated above, the information on financial and
operating characteristics of small systems that will be a product of
this survey represent essential inputs to the ongoing work in Capacity
Development. 

The Water Security Division (WSD) works with the states, tribes,
drinking water and wastewater systems, and others to enhance the
security of water systems and their ability to respond to security
threats and breaches.  The Division will use the data on system
operations and security programs to evaluate the security measures in
place.  WSD will use the data to assess systems’ need for additional
measures and information.  The data will help the Division better
allocate resources in meeting the security needs of water systems.  

Data collected in previous surveys have been used by other program
offices administering the Superfund and Resource Conservation and
Recovery Act (RCRA) programs. Other agency users would include the
Office of Policy and the Office of Regional Operations and State/Local
Relations in the Office of the Administrator.

Data collected in previous surveys have also found uses outside of the
Agency. Past users have included the Department of Agriculture's Rural
Utilities Service, the Department of the Interior, the Department of
Housing and Urban Development, the U.S. Army Corps of Engineers, White
House task forces, the Federal Emergency Management Agency, public
interest groups and many private companies and individuals.

A.3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA  tc
"A.3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA " \l
2 

The following sections verify and affirm that this information
collection satisfies OMB’s collection guidelines, has public support,
and does not duplicate another collection.

A.3.a.	Nonduplication  tc "A.3.a.	Nonduplication " \l 3 

EPA has searched the Federal Information Locator System (FILS) in an
effort to ensure nonduplication of the data collection efforts. To the
best of the Agency’s knowledge, financial and operating information of
the type needed are not available from any sources other than the 2000
Community Water System Survey (CWSS). Since this survey is now nearly
six years old EPA has diminishing confidence in its reliability. Also,
since 2000, dramatic changes have occurred in the water industry and its
regulatory environment. Specifically, EPA has promulgated a significant
number of new rules that may have resulted in significant changes to the
operating and financial characteristics of community water systems
(CWSs).

One indicator of the weakness of the existing CWSS database is that
OGWDW engineers routinely seek other sources of data when working on
regulatory development activities. While this results primarily from the
analytic requirements of the 1996 amendments, SBREFA etc., the age of
the CWSS data also is a factor.  For example, one source that was used
before the 2000 CWSS data were available was WATER STATS, results from a
1998 survey conducted by the American Water Works Association. 

While WATER STATS is useful for a few questions, it also has its
weaknesses. One of the most significant weaknesses is that there are
very few small system respondents. Indeed, EPA users of WATER STATS tend
to use it only for requirements that will apply to medium and large
systems. In other words for data on small systems—the subject of many
Regulatory Flexibility Act analyses—WATER STATS cannot help. Second,
WATER STATS is not, nor does it purport to be, a statistical survey.
Therefore, its data cannot be used to reliably characterize the entire
regulated industry.

Existing studies by other agencies also do not meet EPA’s needs. While
the Census of Governments and Survey of Governments contain considerable
information on CWSs owned and operated by counties, municipalities, and
special districts, their scope does not extend to privately-owned and
ancillary systems. Since most small systems are privately owned (and,
for reasons stated previously, small systems are of major interest to
the Agency), the systems covered in Census studies are of limited
usefulness to EPA. Census studies also typically lack details on
operating characteristics. 

Information about the financial condition of some CWSs is provided by
financial rating services, such as Dun and Bradstreet. Like the Census,
the rating services are limited only to financial information and do not
provide data on operating characteristics of importance to EPA. In
addition, systems evaluated by such services are not a statistical
sample. Rather, it represents the active, well- managed systems that
could realistically seek private-sector financing. Omitted from such
reports would be the weaker systems that would likely be the object of
any Federal or state assistance. 

EPA is expected to collect data from water systems through two other
surveys.  However these surveys do not meet the objectives of the CWSS.
The CWSS was designed to characterize the technical and financial
aspects of CWSs on a national basis. The other surveys EPA is expected
to conduct are:

The Drinking Water Infrastructure Needs Survey and Assessment (DWINSA). 
The DWINSA is used to develop national estimates of capital needs and
provide state-by-state estimates. It is anticipated that EPA will
conduct a new DWINSA in 2007. Where possible, EPA will combine any
efforts for the CWSS and DWINSA such as the small system site visits.
Even though the data collected is different, the burden may be reduced
if only one site visit is conducted to a system to collect data for both
the CWSS and DWINSA. 

Drinking Water Treatment Screener and Detailed Questionnaire. EPA plans
to conduct a survey of drinking water treatment plants as part of its
effort to evaluate the need for national effluent guidelines regulations
for the drinking water treatment point source category. This survey
requests information on drinking water treatment plants operating during
the 2005 calendar year. This survey is conducted under the authority of
Section 308 of the Clean Water Act (Federal Water Pollution Control Act,
33 U.S.C. Section 1318). This survey will only collect data from systems
serving more than 10,000 people and will be collecting operating
information specific to drinking water treatment residuals.  However, 
there may be an opportunity to reduce burden by combining efforts
through the use of similar financial questions.  Preliminary estimates
indicate that over 200 systems may be jointly sampled by the two
surveys. An effort to use the same financial questions on each 
questionnaire is currently being pursued. This would mean jointly
sampled systems would experience less burden than if slightly different
questions were asked twice: once on each survey. Any such possible
burden reduction was not taken into account in the burden calculations
(A.6).   

Finally, EPA maintains the Safe Drinking Water Information System
(SDWIS) that contains information on the operating characteristics and
compliance records of all public water suppliers. However, SDWIS
contains no financial information and thus does not meet the majority of
Agency objectives in conducting this survey. It will, however, be
possible to perform regression analyses with SDWIS compliance data and
the survey’s financial and operating data, to explore possible causes
of non-compliance.

A.3.b.	Public Notice Required Prior to ICR Submission to OMB  tc "A.3.b.
Public Notice Required Prior to ICR Submission to OMB " \l 3 

To comply with the 1995 Amendments to the Paperwork Reduction Act (PRA),
EPA solicited public comment on this ICR for a 60-day period before it
was submitted to OMB. Specifically, EPA published a notice in the
Federal Register (FR) on Thursday June 1, 2006 requesting comment on the
estimated respondent burden and other aspects of this ICR (71 FR 31176).
This notice is included in Appendix B. Before submission to OMB, EPA
considered any comments received and determined if any adjustments were
needed to the burden and cost calculations or to the supporting
statement for this ICR. Comments received and EPA’s responses are
included in Appendix D. An additional Federal Register notice will be
published when this ICR is submitted to OMB. The public comment period
for this additional notice is 30 days.

A.3.c.	Consultations  tc "A.3.c.	Consultations " \l 3 

In the development of the survey questionnaire and sampling plan, OGWDW
has consulting with Barry D. Nussbaum, Chief Analytical Products Branch
in the Office of Environmental Information and Professor Bimal Sinha of
the University of Maryland.  OGWDW also will conduct an independent peer
review of the sampling plan.  OGWDW has taken comments from the American
Water Works Association and the Association of Metropolitan Water
Agencies and will incorporate their comments whenever possible. 

OGWDW received feedback from several CWSs. As part of the pre-test of
the questionnaire (discussed in section 3.a of part B), OGWDW received
comments on the questionnaire from four Massachusetts water systems: 

				Table A-1. Pre-test Participants

Community Water System	CWS Representative

Abington/Rockland Joint Water	Daniel Callahan   

City of Cambridge Water Department	Edward Dowling

Tauton Water Treatment Plant	John Chase

Acton Water District	James Deming



The systems reviewed the data collection instrument, provided feedback
on its design, and helped OGWDW gauge the level of effort required to
fill out the questionnaire. 

A.3.d.	Effects of Less Frequent Collection  tc "A.3.d.	Effects of Less
Frequent Collection " \l 3 

The information in this survey has not been requested since 2000. As
mentioned above, some of the information from the 2000 survey suffers
from problems relating to both it’s the age of the data and the
changes in the industry that have limited its utility. 

To the extent that the Agency lacks accurate, up-to-date information on
the operating characteristics of community water systems, the regulatory
development process suffers. Regulations currently in process,
particularly those related to disinfection and disinfectant by-products,
require a detailed understanding of system sources, flows, and residence
time in various parts of the system. Lack of accurate information could
lead to regulations that are inconsistent with the operational realities
of the systems being regulated. Information from this survey is
essential for realistic policy formulation.

The information on financial characteristics of CWSs is needed to meet
the analytical requirements of Executive Order 12866 and the Regulatory
Flexibility Act. Old or inaccurate financial data could contribute to
overly burdensome or inadequately protective rulemaking.

A.3.e.	General Guidelines  tc "A.3.e.	General Guidelines " \l 3 

This information collection complies with the guidelines in the
Paperwork Reduction Act. Specifically, the collection does not require
water systems to:

Submit regular reports to EPA.

Retain any records for more than three years.

Prepare a written response to the questionnaire.

Maintain or provide information in a format other than that in which it
is customarily maintained.

Submit any information that they may consider to be confidential.

Submit more than one original document.

This information collection:

Is a statistical survey designed to produce data that can be generalized
to the universe of the study (See Part B.2).

Does not provide remuneration to participants.

Will transcribe information collected into an automated form.

Is designed particularly with small entities in mind (See Part A.4.c). 

Does not concern grants or grantees.

Is voluntary.

A.3.f.	Confidentiality  tc "A.3.f.  Confidentiality " \l 3 

This information collection does not require the respondent to disclose
any confidential or sensitive information. There were no claims of
confidentiality or complaints that the questions were sensitive in the
1986, 1995, and 2000 CWSSs. Respondents are not obliged to answer these
strictly voluntary surveys if the concern should arise.   

The inside front cover of the questionnaire contains the following
statement:  “Participation in the survey is voluntary. However, as a
matter of policy, EPA will not disclose the identity of any respondent
to this questionnaire, nor the identity of any participating water
system. While no respondent has ever claimed that the information asked
for in this survey contains confidential business information (CBI), EPA
will offer the opportunity of claiming CBI to a representative of your
water system in the event that we receive a Freedom of Information Act
request for any data that would identity you or your system. It should
be noted, however, that EPA has never received a Freedom of Information
Act request for such information.” 

A.3.g.	Sensitive Questions  tc "A.3.g.  Sensitive Questions " \l 3 

The questionnaires do not ask any “sensitive” questions pertaining
to sexual attitudes/behavior or religious beliefs.

A.4.	THE RESPONDENTS AND THE INFORMATION REQUESTED  tc "A.4.	THE
RESPONDENTS AND THE INFORMATION REQUESTED " \l 2 

A.4.a.	Respondents/SIC Codes  tc "A.4.a.	Respondents/SIC Codes " \l 3 

Respondents to this survey will be drawn from a national sample of CWSs.
A CWS is one that serves at least 15 connections or at least 25
year-round residents (40 CFR 141.2). The North American Industry
Classification System (NAICS) code for Public Water Systems (PWSs) is
221310. Some CWSs do not supply water as their primary business. These
businesses, such as mobile home parks (531190), apartment buildings
(531110), condominium and homeowner associations (813990), and nursing
homes (523311, 623110, and 623312) sometimes meet the definition of CWS
and thus may also be sampled.

As shown by TableA-2 below, community water suppliers represent only a
small portion of all public water systems. Also included as public water
systems are nontransient noncommunity water systems (NTNCWSs), serving
at least 25 of the same people at least six months per year (such as
schools, factories, and hospitals), and transient noncommunity water
systems (TNCWSs), serving non-residential areas (such as campgrounds,
motels and gas stations).

Table A-2. Number of Water Systems tc "

Table A-1.  Number of Water Systems  " \f D  

Type of Water Systems	Number of Water Systems

CWS		51,433

NTNCWS		19,375

TNCWS		87,583



Because NTNCWSs and TNCWSs are exceptionally diverse and do not lend
themselves to statistical analyses, the Agency has decided to exclude
these systems from the survey. Virtually all of the NTNCWSs and TNCWSs
are small entities; therefore, this decision will reduce the data
collection burden on small entities. 

A.4.b.	Information Requested  tc "A.4.b.	Information Requested " \l 3 

The information that respondents are asked to provide for this survey is
generally maintained and reported as a function of the management and
operation of the water system. For example, as part of state oversight
of the drinking water program, systems generally are required to provide
basic data on operations in order to obtain or renew construction and
operating permits. Systems, therefore, have a description of the
physical plant and daily operating procedures, including information on
source, treatment, production, and distribution. Treatment information
also may be required by state or Federal regulatory personnel to
demonstrate a system's compliance with regulatory requirements. Finally,
information on revenues, expenses, and debt are basic accounting
information that reasonably could be expected of any business. Also,
because many CWSs are regulated by state public utility commissions,
they are required to provide financial information in the form of annual
financial reports describing all revenues, expenses, assets and
liabilities.

A.4.b.1.	Data Items  tc "A.4.b.1.	Data Items " \l 4 

This section provides justification for each of the data items requested
in this survey. Separate questionnaires were designed for small, medium,
and large systems (serving 25 – 500,000 customers), and very large
systems (serving over 500,000 customers). Although there are few very
large systems, they supply water to the majority of customers and bear
most of the potential burden associated with regulations. Therefore, the
questionnaire for very large systems requests some information regarding
production and treatment not asked of smaller systems. 

The Drinking Water Treatment Screener questionnaire, cited on P. 13,
will only collect data from systems serving more than 10,000 people and
will be collecting information specific to drinking water treatment
residuals.  In addition to the very different sampling plans and
purposes of the two surveys, the opportunity to reduce burden by
combining efforts is also restricted by the limited use of similar
financial questions and dramatically different questions pertaining to
operating characteristics.  Such a combined effort would greatly
complicate data collection, custody and processing and would make
uniform quality control difficult.   Copies of the questionnaires are in
Appendix C.

Question 1 asks for information on potential contacts in the CWSs that
might be able to answer questions that might arise during the survey.
Such information is an integral part of the data collection methodology
(described below) that is designed to reduce burden on potential
respondents. EPA has asked for a telephone number, fax number, and
e-mail address to add flexibility to our communications process. There
is a field for CWSs to include information for the most knowledgeable
person working at the water system in case the survey respondent differs
from who might be contacted if necessary.

Question 2 requests information on the reporting period for which data
are being provided. This is necessary in order to ensure that
cross-system analyses are not biased by data from different time
periods. During data analysis, financial information will all be
converted to July 2006 dollars for all systems.

Question 3 asks systems to classify the ownership of the system. This
information will allow EPA to (1) confirm the ownership information in
SDWIS, (2) distinguish ancillary systems from other private systems, and
(3) evaluate the operating and financial data provided in subsequent
sections of the survey. Because many small water systems provide water
as an ancillary but necessary part of another business, this information
is essential to analyze the impact of rules and regulations on small
systems. 

Question 4 asks systems to describe their current computer status,
access to available programs and the internet. This information will
help EPA (1) determine if systems have computer access as an option for
viewing training materials, (2) target the most widely used computer
programs, and (3) determine the best delivery methods for distribution.
In making new regulation determinations, the proper method of delivery
for information and comment is critical and can become an excessive
burden on stakeholders if the systems do not receive it properly
explained to them in an acceptable period of time.

Operational Characteristics

Information about the operating characteristics of water systems is
needed to assist EPA’s OGWDW in fulfilling statutory requirements
under SDWA and the Regulatory Flexibility Act, as well as requirements
of Executive Order 12866. Information on operating characteristics of
water systems is a key component for designing, assessing the impacts
of, and implementing Agency programs. Because of the diversity in the
water supply industry, information on system operating characteristics
gives EPA a basis for developing more accurate assessments of the
feasibility of treatment alternatives, and the costs and benefits of
federal regulatory efforts on the regulated utilities and impacted
consumers. This information also enables the Agency to assess the
differential impact of regulations across different types of systems.
This information is needed to meet the standard-setting requirements of
Section 104 of the 1996 SDWA Amendments. The information also is useful
in developing and targeting technical assistance programs, and in
assisting the Agency in identifying the types of systems that would
benefit from technical training and guidance.

Operating information acquired through this survey also will be used to
verify data in SDWIS and to analyze sources of non-compliance by
comparing data collected with information in SDWIS.

This questionnaire seeks to obtain comprehensive information on all
sources, all treatment, all production, and all entry points to the
distribution system. The need for this comprehensive approach arose for
two reasons. First, it became clear from analyses of earlier surveys
(prior to the 2000 survey), that the Agency's failure to get such
comprehensive pictures of operations made it very difficult for the
Agency to assess the impacts of alternative regulatory approaches.
Second, the growing importance of the risk-risk tradeoff between
disinfection and disinfectant by-products requires that the Agency have
a more detailed understanding of the entire production process. For
example, the Agency needs to know when disinfection is introduced, or
what the retention time of treated water is in various parts of the
system. 

Information from surveys before 2000 has proven to be inadequate for
current rules. The 2000 CWSS began collecting information in the
described manner. During a series of meetings held during the design
phase of the 2000 CWSS, it became clear that an understanding of the
treatment in place required a comprehensive approach that provided
information on all sources and linked the flows from all sources to all
treatment plants. 

Questions 5 through 7 seek information on the number and flow
characteristics of ground water sources, surface water intakes,
purchased water connections, and treatment plants at a utility. EPA has
found it difficult to reliably characterize the impacts of regulations
without a clear understanding of this intake-specific and plant-level
information. Indeed, the Agency has been hindered in past regulatory
development efforts by having only aggregate utility-level data. 

Question 5 asks a system to draw a schematic of their water system. A
visual layout of the water system helps EPA understand the challenges
different types of systems face for transmission, treatment, and
distribution of water. 

Question 6 asks for average flow, peak daily production, design flow,
whether the source is a seasonal or emergency connection and if the
water is treated. This will help complete a characterization of the
system by identifying the number of sources, intakes, and connections
that contribute to the total system volume. These data will allow the
Agency to understand the size of the system in order to evaluate rate
structures and identify relationships between cost and volume of water. 

Question 7 asks for this information by water treatment plant. The
description of water sources from these questions is critical because of
the different regulatory programs and options that may apply only to
water of a specific source type. For example, many of the current rules
on microbials were designed specifically for systems whose source water
came from surface water sources. Also, very large water systems
typically have mixed water sources. The data will support Agency
occurrence analyses, since vulnerability to certain contaminants is
related to the type of water source. These data will be used in the cost
analyses which support regulation development.

 

Question 8 provides critical plant-level information necessary for
reliably characterizing the feasibility of treatment alternatives. The
information from this question will enable the Agency to estimate the
range of costs and contaminant removal potential of those alternatives
in relation to the flows that would be treated at the individual plant
level within utilities having multiple plants. Treatment objectives
describe the cost feasibility of future regulations without increasing
the cost to a system for Agency cost analysis.

Question 9 addresses residuals management, an increasingly important
part of the cost of regulations. Each EA must address the cost of
residuals management, and the Agency currently does not have an adequate
baseline on types of residuals management being used.

Very large systems will be asked to provide additional details regarding
treatment. Question 10 of the very large system questionnaire requests
that systems provide raw water and post-treatment concentrations for any
unregulated contaminants the system monitors. The Agency realizes that
the water systems may not have concentration data for all entry points;
therefore, the questions request available aggregate data. The Agency
will use these data to assist in performing occurrence analyses,
treatment evaluations, and affordability determinations used for
regulation development. This type of analysis is feasible for very large
systems because of their small number; at the same time, it is important
because these systems supply much of the nation’s drinking water. 

Many of the possible alternative sources of data for contaminants, such
as the National Drinking Water Contaminant Occurrence Database (NCOD)
and SDWIS, do not contain complete data on regulated or other
contaminants of concern. For example, SDWIS only contains occurrence
data for public water systems with MCL violations. Also, public water
systems are not required to submit contaminant occurrence data to the
NCOD. As a result the, databases currently used may have substantial
gaps in occurrence data; therefore, Question 10 is the only source of
these data that will allow the Agency to perform accurate analyses for
regulation development. 

Question 11 is the survey's only question on storage. The number of
different types of storage in use is necessary to better estimate
degradation in distribution system water quality and potential risk in
the distribution system. The volume of treated storage in the system is
vital to an analysis of regulatory options in the Microbial and
Disinfection/Disinfectants Byproducts (M/DBP) cluster of rules.
Disinfection and the likely contact time with the disinfectant are
determinants of the potential risk posed by disinfectant byproducts. The
purpose of the tank, physical arrangements, how it is operated,
maintenance activities and turnover rate facilitate understanding in how
tanks are operated and how utilities consider the impacts of operation
on water quality that lead to public health risks. This will be used to
estimate existing risk and regulatory options for reducing risk related
to storage. Storage tanks have been identified by experts as a priority
issue of concern for public health risk in the distribution system.
There is no reliable data for small systems, and the method for getting
accurate information is through the survey site visits to small systems.


Question 12 collects data on the current inventory of pipe, the amount
of transmission lines and distribution mains replaced in the past 5
years in each water system, and the amount of new transmission lines and
distribution mains installed. The importance of this information is
related to the significance of the long-term costs associated with
transmission and distribution system replacement. The Agency will use
this information to develop its own assessment of these costs in terms
of overall system requirements. 

Questions 13 requests that the system describe the pressure zones
located in their distribution system. Pressure zones and backflow are
considered a high priority by most experts and stakeholders. Pressure
reductions can lead to backflow or intrusions, and control of pressure
helps reduce the risks from both. As contamination does not spread
evenly throughout the distribution system, the number of pressure zones
will be used to estimate the total population affected during a
contamination event because water circulates within a pressure zone but
less frequently between pressure zones. The pressure range is requested
to estimate the number and frequency of contamination events to update
occurrence estimates, risk reduction, and economic analysis. The amount
of booster disinfection in the distribution system indicates
opportunities for water quality control in the distribution system and
is very important for controlling contamination events. Booster
disinfection by pressure zone is not available and will be used to
determine regulatory options and cost to utilities. These data will be
used to estimate possible approaches to risk reduction and economic
impact of potential requirements.  Some of this information is known for
large utilities, but there is little data on smaller systems that do not
participate in research projects.  

Questions 14 through 17 requests information on the system’s flushing
practices in the distribution system. The information on what utilities
are doing on a regular basis to maintain water quality in the
distribution system will be used to determine what is working, what is
not, and which existing programs can be built upon to best reduce public
health risk in the distribution system. It will be used to estimate
costs for potential requirements when determining how many systems
already have programs in place versus how many have to add new programs.
This information is not available in a nationally representative sample
and is especially lacking for small systems. 

Question 18 asks for data on the concentration of disinfection residuals
during different time periods of the year. As these data varies by
season, this information is critical to understand the nature of
disinfection by products for regulation analysis. They will be used to
estimate the economic impact of current and future regulations.

 

Question 19 is a request for information about the service area of the
system. This is approximated by information on ZIP codes of customers.
This information is needed to estimate median household income and other
demographic characteristics in the service area, and it will be used to
help the Agency better understand the financial context in which the
system operates.  

Question 20 asks systems to describe their current water system security
programs and if they use any of the training materials provided by EPA.
Identifying the most used training materials, best methods of delivery
and how stakeholders incorporate assistance materials into their
programs will allow EPA to better allocate resources in meeting the
needs of the system.

Financial Characteristics

An essential question in any economic analyses is whether the regulated
community can afford to implement proposed regulations. This question
requires an analysis of the financial impacts of the regulation on both
the water system and its consumers. The financial questions ask basic
information that is essential to this analysis. These questions are
updated from previous surveys to provide the most accurate portrait of
the system. Although still relatively simple, they describe the whole
picture of a systems financial stability.

The information requested in Question 21 is for total production flows,
the distribution to different customer types, and types of revenue from
each customer type. It also gathers information on the customer base of
the water system. This information is critical for understanding the
cost impacts of regulations on household consumers and other water
system customers. Revenue is one of the essential elements from any
operating statement that would enable the Agency to assess the financial
condition of the system. This information has been collected in all
previous versions of the CWSS, and these data form an important part of
the financial baseline for EAs. 

Question 22 and 23 ask about the system’s rate structure and forms of
rate relief for customers with low or fixed incomes. These questions are
essential for evaluating the impact of proposed regulations on
households. 

Question 24 gathers information on seasonal populations or events that
might affect production. This information is used in conjunction with
the information requested in Questions 21 to understand the benefits and
per capita cost impacts of regulatory alternatives. 

Question 25 and 26 ask for system expenses. This basic information has
been collected in all previous versions of the CWSS, and these data form
an important part of the financial baseline for EAs. 

Question 27 gathers information on capital investments and the source of
funds for such investments. Part of the EA process involves estimation
of the cost of capital for new investment required by regulations. These
questions provide the baseline information that can be used to estimate
the cost of capital. 

Question 28 asks a system if they have an asset management plan. These
plans are necessary for a financially stable water system. It is
critical for EPA to understand the water industry's adoption of asset
management – a key “Pillar” in the Agency's Sustainable
Infrastructure initiative. With Questions 27 and 28, EPA can determine
the level of outreach necessary for promoting an asset management plan
based on this response.

A.4.b.2.	Respondent Activities  tc "A.4.b.2.	Respondent Activities " \l
4 

Respondent activities will vary by system size. For small systems
(serving populations of fewer than 3,300), our data collection approach
involves a site visit by an experienced water system engineer. The site
visit staff will make a physical inspection of the physical plant in the
system and complete the questions about production, treatment, storage,
and distribution. The respondent will be asked to provide the
information necessary to answer the financial questions. For example, if
the respondent has a financial statement, that should be sufficient for
most of the questions. For those questions where there is no available
data, respondents will be asked to provide estimates.

Systems serving populations over 3,300 will be asked to fill out the
questionnaire. Systems serving more than 3,300 people may fill out a
traditional paper version of the questionnaire.  They also will be given
two ways to fill out an electronic version of the questionnaire. They
can request a spreadsheet version that they can fill out on their
computer.  Respondents can fill out a web-based version of the
questionnaire by visiting a CWSS web site that will allow them to start
their responses, add to them and complete them over a period of time. If
they wish, they also can respond to the questionnaire through a
telephone interview.  

Systems may respond to questions by attaching schematics, diagrams, or
reports when possible. Finally, we will request the system's most recent
financial statement. Based on our experience, most medium, large, and
very large systems have financial statements prepared by professionals.
Also the larger the system is the more likely that these statements have
also been audited. 

A.5.	THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT  tc "A.5.	THE INFORMATION
COLLECTED – AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION
MANAGEMENT " \l 2 

The following sections describe Agency activities related to analyzing,
maintaining, and distributing the information collected. The primary
activities associated with this collection will be performed by a
contractor hired by the Agency to develop the collection methodology and
to collect and analyze the data.

A.5.a.	Agency Activities  tc "A.5.a.	Agency Activities " \l 3 

The EPA will be involved in the following activities:

Providing guidance on questionnaire design and information collection.

Reviewing requests for confidentiality and providing appropriate
protections.

Answering questions from respondents regarding the purpose and use of
the information gathered.

Distributing the information.

Conducting additional analyses of the data, as needed.

Upon completion of the collection, review, and initial analysis of the
survey data, a database will be developed to sort the raw data for easy
access and subsequent analysis by EPA personnel. The Agency will receive
an electronic copy of this database. In addition, the Agency will
receive a summary report providing descriptive information on various
financial and operational characteristics of water systems resulting
from this survey.

Additional Agency activities resulting from this collection are assumed
to be part of the overall activities in support of the OGWDW ICR
regulatory development program pursuant to the SDWA. Burdens associated
with specific regulations and the Public Water System Supervision (PWSS)
Program are estimated separately in other ICRs. 

A.5.b.	Collection Methodology and Management  tc "A.5.b	Collection
Methodology and Management " \l 3 

The collection methodology proposed by the Agency will vary by system
size. For the smallest systems (those serving populations of 3,300 or
less), EPA proposes to have all information collected by senior
engineers employed by the contractor. These engineers will make on-site
visits to all systems in this size category. The collection methodology
is identical to that which has been used successfully in the 1995 and
1999 DWINSAs, as well as the 2000 CWSS. In all cases, the quality of
information collected was high.  The response rates for the DWINSA
exceeded 99 percent; for the 2000 CWSS, the response rate was more than
90 percent. 

As far as the types of data collected, the difference between the CWSS
and the DWINSA is that the CWSS asks for the collection of some
financial information, while the DWINSA focused exclusively on
infrastructure. (From the standpoint of purpose, the two surveys are
very different. The DWINSA seeks estimates of future capital needs. The
CWSS seeks data on current operating and financial characteristics.) To
ensure the quality of data collection, the engineers proposed for the
field data collection will be trained in basic accounting principles and
procedures to be used in the collection of financial data. In addition,
EPA anticipates drawing a single small system sample for both the 2007
CWSS and 2007 DWINSA and that one site visit will be conducted to each
system selected.  Both surveys will be completed during that one site
visit, therefore reducing the burden on the state, EPA, and small
systems. 

For systems serving populations greater than 3,300, the Agency is
proposing the use of a mail survey, with telephone follow-up.
Questionnaires will be mailed to a random sample of CWSs, who will be
asked to fill out the questionnaire and return it to EPA. To assist
systems in filling out the questionnaire, each potential respondent will
be assigned an analyst who will work with the system throughout the
survey and will be able to answer all technical questions. Each
potential respondent will be contacted by the analyst assigned to it to
confirm the receipt of the survey, explain the questionnaire, and to
respond to the system’s questions. Each system also will receive at
least one additional follow-up phone call. Systems also may contact EPA
contractor staff through a dedicated toll-free telephone number. 

Systems serving more than 3,300 people may fill out a traditional paper
version of the questionnaire. They also will be given two ways to fill
out an electronic version of the questionnaire. They can request a
spreadsheet version that they can fill out on their computer.  Systems
can also fill out a web-based version of the questionnaire by visiting a
CWSS web site. If they wish, they can also respond to the questionnaire
through a telephone interview.  

Systems serving more than 3,300 people can provide the following
documentation: 

A diagram of the system, showing flows from source to distribution;

Submit site plans and flow charts of the treatment facilities; and

A current financial statement.

The pre-test group participants (listed in section A.3.c, above)
indicated that, for some questions, they would prefer to provide
documentation that provides the information requested rather than fill
out that part of the questionnaire. Therefore, when a question can be
answered by attaching diagrams, charts, or financial or other reports
that contain the information requested, systems will be given the option
of attaching the documents in lieu of filling out that question. Small
systems will be visited by contractor staff that will draw diagrams and
schematics as needed; small systems also may provide additional
documentation to respond to questions as appropriate. 

Any documentation provided will be used to validate the information
provided through the questionnaire and to create in-depth profiles. All
documents submitted will become an integral part of the completed
questionnaire and survey record for review by EPA staff. 

The data collection method proposed for systems serving populations
greater than 3,300 was pre-tested and will be pilot-tested prior to its
use. 

The pre-test of the data collection instrument consisted of four
systems, of different ownership, sizes and water source types. Since EPA
has reliable information on the general approach for small systems, the
pre-test focused on systems serving populations greater than 3,300. Once
the survey is approved by EPA and OMB, a pilot test of up to 50
representative systems will be conducted before conducting the
full-scale survey. The respondents will be a representative sample of
systems. (See Section B.2 for details.) The completed questionnaires
will be collected and tracked through receipt, data entry, and data
cleaning steps, tabulated, and returned to OGWDW. OGWDW will check the
data and maintain it as a data file for Agency analysis. The contractor
will provide OGWDW with a description of the database and how to use it.

It may be possible for OGWDW to collect financial information from some
larger systems through another survey being conducted by EPA’s Office
of Science and Technology (OST). In which case, the financial questions
for systems being co-sampled will be omitted from the CWSS, and the data
will be gathered through the OST Survey.

Data quality will be assured by implementing the following procedures
throughout the collection and processing phases of the survey:

Selection of Contractor Personnel. The Cadmus Group, Inc. has been
responsible for several of the largest surveys of public water supplies
(e.g., the 1995, 1999, and 2003 DWINSAs and the 1995 and 2000 CWSS).
Central to EPA’s approach to these surveys has been the reliance on
experienced water system professionals for data collection. Whether
conducting on-site data collection or telephone follow-up, the personnel
thoroughly understand water supply. The staff have worked in the
industry for many years and they can speak the language, ask the right
questions, and properly interpret responses. 

Training. This is one of the most important steps in quality assurance.
It is particularly important when relying heavily on the judgment of a
large cadre of trained professionals working independently (as will be
the case for small systems). The factor which reduces the likelihood of
errors and increases the identification of those that do occur is a
well-trained staff that has a common and thorough understanding of all
aspects of the survey – the questionnaires, the data to be collected,
and the ultimate uses of these data. The training will include a
detailed review of the coding guide. 

Quality Assurance of Data Collection. The staff working on this project
will be supervised by a senior-level Data Collection Manager. The
Manager will review the first 25 questionnaires submitted by each person
working on the project. This will enable the Manager to perform a
quality assurance process to ensure that all personnel are fully trained
and using identical assumptions and procedures. Furthermore, the
schematics, flow charts, and financial reports submitted by each system
will be used to validate the systems’ responses to the questionnaire. 

Documentation. As questionnaires are completed and submitted by small
system contractor personnel, these personnel will be asked to submit
documentation to support the conclusions in their questionnaires. This
documentation should be sufficient to enable the Data Collection Manager
to review the questionnaire and understand how the personnel reached
their conclusions. 

Receipt Control. The primary objective of the receipt control system
will be to ensure that completed questionnaires are logged in promptly
and given proper custody. A second objective is to monitor cumulative
receipts to identify potential problems with the response rate for which
action would be appropriate. Data related to the case identification and
its disposition code will be given scan edit promptly so that forms
received can be moved into the data preparation process as rapidly as
feasible. Bar codes will be used to expedite the process, minimize
errors in respondent identification and avoid unnecessary following
after the form is returned. 

Data Entry. Verification will be 100 percent. It is believed that the
best approach to keying accuracy is careful design of instrument layout
and well trained personnel. The approach used will be 100 percent
independent key verification to uncover inevitable errors. The second
(more senior) key operator will resolve discrepancies. Although the
survey is designed to minimize coding as much as possible, recoding will
be done to provide a measure of the degree of inter-coder reliability.
In such cases, a 5 percent sample of forms will be duplicated and sent
to independent coders before coding. Ordinarily, manually-coded data
items will receive a 100 percent verification of the first 20 cases
coded by each coder and a 10 percent sample thereafter. Error rates will
be used as a criterion for release or retraining.

Data Edit and Imputation. Data edits will be developed by EPA. Edits
will specify when respondents are to be followed up to resolve unlikely
or inconsistent responses. EPA will determine which questions contain
information that is critical for conducting subsequent analyses in
support of regulatory development and implementation efforts. Responses
to these questions will receive additional review by technical experts.
The review will focus on determining whether the responses to these
questions are consistent with each other and to responses to other
questions. 

The questionnaires will be subjected to 100 percent editing review. The
process will check skip patterns, standardize the recording of
quantitative data, and identify any potential problems. Protocols will
guide the data preparation staff; any changes to responses will be
documented and logged. Data validation checks will include distribution
frequencies for categorical and continuous variables, univariates for
each continuous variable, item-specific cross tabulations of categorical
variables, item-specific cross-univariates of continuous data, and
item-specific logic edits. 

Monitoring. A routine component of quality control effort is monitoring
staff performance and reporting on data quality and system performance.
Recognizing that every system has inherent variability, these monitoring
activities will seek to uncover unexpected variations having assignable
causes. Also, they will provide a baseline for future guidance.

Data Processing. Once the reviewed, edited, and validated database is
prepared, several data processing steps will create files suitable for
analysis and tabulations. These steps include devising rules for
handling missing data, creating derived variables from the survey data,
and attaching sample weights to the analytical file. Detailed
specifications will guide each step, and each step will be documented.
Version control will be maintained for all computer programs and for
each interim stage of all data files. 

In addition, the Agency will develop an electronic reporting form that
systems can use to complete the questionnaire. It is anticipated that
this form will reduce the burden for systems completing the form and for
Agency to perform data entry. 

A.5.c.	Small Entity Flexibility  tc "A.5.c.	Small Entity Flexibility "
\l 3 

EPA has proposed for CWSs that the data be collected by professional
water supply engineers. The principal method, used by the professional
water supply engineers when on-site, will be a physical inspection of
the water system’s plant and equipment. This exercise imposes no
burden on the small system owner and operator. Therefore, the only
burden anticipated for small entities is that associated with providing
small amounts of information that cannot be supplied through the
physical inspection. These will include location of financial
information (if any) and giving oral answers to questions posed by the
site engineer. 

This method has been used in both the 1995 and 1999 DWINSAs and the 2000
CWSS. In all of these surveys, it was credited with substantially
increasing small entity flexibility.

A.5.d.	Collection Schedule  tc "A.5.d.	Collection Schedule " \l 3 

The following schedule assumes OMB clearance for this collection will be
obtained by November 2006. For each task, we show the date by which the
task will be completed.

Table A-3. Proposed CWSS Schedule

Task	Date to be Completed

Design Questionnaires and Sampling Plan	May - July 2006

Pretest Questionnaires		June 2006

Conduct Pilot Test		November 2006

Draw Sample and Begin Full Survey	January 2007

End Data Collection 	July 2007

Submit Draft Report		June 2008

Submit Final Report	October 2008



A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION  tc "A.6
ESTIMATING THE BURDEN AND COST OF THE COLLECTION " \l 2 

A.6.a.	Estimating Respondent Burden  tc "A.6.a.	Estimating Respondent
Burden " \l 3 

Respondent cost estimates are based on separate estimates for systems
with service populations of 3,300 and below, those with service
populations of 3,301 to 50,000, those with service populations of 50,001
to 500,000, and those with service populations over 500,000. As
mentioned above, our data collection methods will be different for small
systems. To the extent possible, the current estimates are based on the
pre-test and the experience of The Cadmus Group, Inc. with similar
surveys using the same methodologies for the same respondents. These
include the 1995, 1999, and 2003 DWINSAs and 2000 CWSS. 

For small systems (serving populations of up to 3,300), the most likely
respondent will be the system operator. For financial questions,
particularly for systems with service populations larger than 1,000, the
operator may need to consult with a clerical person who handles
financial records. For systems serving populations greater than 3,300,
the primary respondent will be the system operator, or system engineer.
The request for financial information will be referred to the accounting
department. As with small systems, it usually can be handled by a clerk
or bookkeeper in the accounting department. EPA assumes that the average
hourly rate for respondents in systems serving populations greater than
50,000 will be $33.88, and the hourly rate for systems serving
populations 50,000 and fewer will be $28.24. These are the rates used in
the ICR for the 2007 DWINSA. They also are consistent with rates used in
other drinking water ICRs associated with proposed regulations. These
are conservative estimates. 

The average amount of time required for a respondent in a system serving
populations of 3,300 and fewer is 1 hour. While our site visit personnel
may be on-site for a longer time, much of that time is spent conducting
a physical inspection of the system rather than asking questions. Our
current estimate of the average amount of time required for a respondent
in a system serving populations of more than 3,300 is 5 hours. 

In addition to the activities of CWSs, the states will be asked to brief
the site visitors about the small systems to be visited. (See section
B.2.b. in part B.) EPA assumes states personnel will spend 0.5 hours on
each small system to be visited. It also assumes the average hourly rate
of those reviewing the list of small systems is $36.10 per hour. This
rate, which has been inflated to year 2005 dollars ($65,255) is
consistent with the rates used in ICRs recently developed by SRMD. 

These hour estimates are based on EPA’s experience in the DWINSAs and
previous CWSSs. This is planned as a one-time collection and does not
entail any record keeping or future reporting.

A.6.b.	Estimating Respondent Costs  tc "A.6.b.  Estimating Respondent
Costs " \l 3 

The total respondent costs are calculated below based on the labor
effort and costs described in the previous section (A.6.a.). There are
no capital or operating and maintenance costs to the respondents in this
collection effort.

Table A-4. Preliminary Burden and Cost Estimate for Respondents  tc "

Table A-2.  Preliminary Burden and Cost Estimate for Respondents " \f D 


Size of System	Sample Size	Burden Hrs.	Cost/Hr.	Total Hrs.	Total Cost

Less than 3,300	600	1	$28.24	600	$16,944

3,301 to 50,000	363	5	$28.24	1,815	$51,256

50,001 to 500,000	637	5	$33.88	3,185	$107,908

Greater than 500,000	92	5	$33.88	460	$15,585

	Total	1,692	3.5816	$31.63	6,060	$191,693



The estimated burden and costs to the states are shown in Table A-5,
based on the labor effort and costs described in the previous section. 

Table A-5. Preliminary Burden and Cost Estimate for the States  tc "

Table A-3.  Preliminary Burden and Cost Estimate for the States " \f D  

Size of System	Sample Size	Burden Hrs.	Cost/Hr.	Total Hrs.	Total Cost

Less than 3,300	600	0.5	$36.10	300	$10,830

3,301 to 50,000	0	0	0	0	0

50,001 to 500,000	0	0	0	0	0

Greater than 500,000	0	0	0	0	0

	Total	600	0.5	$36.10	300	$10,830



A.6.c.	Estimating Agency Burden and Costs  tc "A.6.c.	Estimating Agency
Burden and Costs " \l 3 

Annual agency burden and cost estimates for the survey are based upon
the experience of EPA’s technical staff in developing surveys of this
magnitude. These estimates are presented in Section A.6.e. 

The labor rates used to calculate costs of EPA employees and contractors
performing the survey activities were estimated for three labor classes:
Manager, Technical, and Clerical. The Manager rate is $58.58 per hour
assuming GS15, Step 5. The technical rate is $49.80 per hour based on a
GS14, Step 5. The clerical rate is $16.13 based on a GS5. Overhead costs
were equal to 60% of direct labor. The Contractor rate was assumed to be
$80.00 per hour to develop the questionnaire and sampling plan, $70.00
per hour to collect the data from medium, large, and very large systems,
conduct quality assurance and quality control, develop the data base,
and to conduct the initial analysis of the data, and $173.00 per hour to
conduct the site visits. These rates included all direct and all
applicable indirect costs and fee. 

A.6.d.	Estimating the Respondent Universe and Total Burden Cost  tc
"A.6.d.	Estimating the Respondent Universe and Total Burden Cost " \l 3 

Since EPA is expecting 600 completed data collection instruments for
systems serving populations of less than 3,300 at 1 hour per system, it
is estimated that the total respondent burden for small systems is to be
600 hours total. EPA estimates the total burden for the states to be 0.5
hours per small system, for a total burden to the states of 300 hours.
Since EPA is expecting 1,092 completed data collection instruments for
systems serving populations of more than 3,300 at 5 hours per system, it
is estimated that the total respondent burden for medium, large, and
very large systems to be 5,460 hours. There is no record keeping burden
associated with these surveys; therefore, the annual burden and cost is
the same as the respondent burden and cost.

At $28.24 an hour, 600 small systems will complete the survey at a cost
of $16,944. At $28.24 an hour, 363 medium systems will complete the
survey at a cost of $51,256. At $33.88 an hour, 729 large and very large
systems will complete the survey at a cost of $123,493. The total cost
to respondents is estimated to be $191,692. At a cost of $36.10 an hour
the cost to states to brief the small system site visit contractors on
the 600 small systems is $10,830. 

ANNUAL BURDEN:

Burden to Respondents: 

Hrs. per Small System Respondent (1) x No. of Respondents (600) +

Hrs. per Medium System Respondent (5) x No. of Respondents (363) +

Hrs. per Large System Respondent (5) x No. of Respondents (637) +

Hrs. per Very Large System Respondent (5) x No. of Respondents (92) =
6,060

Average burden per respondent = 3.58 hours (3 hours 35 minutes)

Burden to States:

Hrs per Small System (0.5) x No. of Respondents (600) = 300 hours

ANNUAL COST:

Cost to Respondents: 

Cost per Hour for Small Systems ($28.24) x No. of Hours (600) +

Cost per Hour for Medium Systems ($28.24) x No. of Hours (1,815) +

Cost per Hour for Large Systems ($33.88) x No. of Hours (3,185) +

Cost per Hour for Very Large Systems ($33.88) x No. of Hours (460) =
$191,693

Average cost per respondent = $113.31

Cost to States: 

Cost per Hour ($36.10) x No of Hours (300) = $10,830. 

A.6.e.	Bottom Line Burden Hours and Cost Tables  tc "A.6.e.	Bottom Line
Burden Hours and Cost Tables " \l 3 

The Agency master table displaying the Agency burden and cost estimates
– including contractor costs – is presented in the table below:

Table A-6. Agency Burden Cost Estimates  tc "Table A-4.  Agency Burden
Cost Estimates " \f D  

	Hours

	Tasks	Contractor	Manager 	Technical	Clerical 	Total 	Total Cost 

Administration	102	0	0	0	102	8,466

Defining Survey Objectives	411	40	200	8	659	54,006

Questionnaire Design	931	40	400	8	1,379	$113,104

Sample Design	400	24	300	8	732	$59,562

Internal EPA and OMB Approval	520	24	350	8	902	$73,507

Sample Selection	500	40	210	8	758	$55,690

Training for Data Collection	560	40	420	8	1,028	$80,163

Data Collection	9,800	130	1,060	40	11,030	$1,017,683

QA/QC of Data	600	80	210	8	898	$66,440

Data Base Development	3,000	40	320	8	3,368	$264,456

Data Analysis	3,000	130	530	8	3,668	$264,627

Report Preparation	3,000	40	530	40	3,610	$297,016

Storing and Maintaining Data	0	4	210	40	254	$18,142

Total	  =SUM(ABOVE) \# "#,##0"  22,824 	  =SUM(ABOVE) \# "#,##0"  632 	 
=SUM(ABOVE) \# "#,##0"  4,740 	  =SUM(ABOVE)  192 	  =SUM(ABOVE)  28,388
	  =SUM(ABOVE) \# "$#,##0;($#,##0.00)"  $2,372,862 



AGENCY TOTAL BURDEN:	28,388 HRS.

AGENCY TOTAL COST:	$2,372,862

Table A-7 summarizes the total burden and cost of the survey, including
respondent, contractor, and agency burdens and costs. 

Table A-7. Summary of Burden and Cost Estimates  tc "

Table A-5.  Summary of  Burden and Cost Estimates " \f D  

	EPA	Contractor	States	Respondents	Total

Burden (hours)	5,564	22,824	300	6,060	  =SUM(LEFT) \# "#,##0"  34,789 

Cost (dollars)	$441,916	$1,930,946	$10,830	$191,693	  =SUM(left) \#
"$#,##0;($#,##0.00)"  $2,57 5,385



A.6.f.	Reasons for Change in Burden  tc "A.6.f.	Reasons for Change in
Burden " \l 3 

This section is not applicable since we are not renewing or modifying an
existing ICR.

A.6.g.	Burden Statement  tc "A.6.g.	Burden Statement " \l 3 

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 3.55 hours per response,
including the time for reviewing instructions, gathering information,
and completing and reviewing the collection of information.  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 OMB control number. 
The OMB control numbers for EPA's regulations are listed in 40 CFR part
9 and 48 CFR chapter 15.   

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 Number
EPA-HQ-OW-2006-0454, which is available for online viewing at
www.regulations.gov, or in person viewing at the Water Docket in the EPA
Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Avenue,
NW, Washington, D.C.  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) 566-2422.  An
electronic version of the public docket is available at
www.regulations.gov.  This site can be used 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.  When 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, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OW-2006-0454 in any correspondence.

The following burden statements appear on the inside covers of the
questionnaires. 

Participation in the survey is voluntary. However, as a matter of
policy, EPA will not disclose the identity of any respondent to this
questionnaire, nor the identity of any participating water system. While
no respondent has ever claimed that the information asked for in this
survey contains confidential business information (CBI), EPA will offer
the opportunity of claiming CBI to a representative of your water system
in the event that we receive a Freedom of Information Act request for
any data that would identity you or your system. It should be noted,
however, that EPA has never received a Freedom of Information Act
request for such information. 

The public reporting and record keeping burden for this collection of
information is estimated to average 3 hours 35 minutes per response or
to range from 1 hour to 5 hours per respondent annually. 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 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 Ave., NW,
Washington, D.C. 20460; and 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. Include the EPA
ICR number and OMB control number in any correspondence. Do not send the
completed survey to this address.



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PART B OF THE SUPPORTING STATEMENT 

 tc "PART B OF THE SUPPORTING STATEMENT" B.1.	SURVEY OBJECTIVES, KEY
VARIABLES, AND OTHER PRELIMINARIES

 tc "B.1.	SURVEY OBJECTIVES, KEY VARIABLES, AND OTHER PRELIMINARIES

" 

B.1.a.	Survey Objectives  tc "B.1.a.	Survey Objectives " \l 3 

The overall purpose of conducting this survey is to supply the Office of
Ground Water and Drinking Water (OGWDW) with accurate, up-to-date
information on the water systems it regulates so that it may comply with
statutory requirements and executive orders, support the
administration’s recommendations for reauthorizing the Safe Drinking
Water Act (SDWA), and accomplish its many other program responsibilities
as described in Part A, Sections A.2.a, A.2.b, A.3.d, and 5.c.

In accomplishing this purpose, the survey will achieve the following
objectives: 

Help to determine the cost of any new federal drinking water
regulations.

Help predict the ability of water systems of various sizes to absorb
additional regulatory costs imposed by EPA.

Determine the extent of need by water systems for technical and
financial assistance in maintaining existing operations and in meeting
current Federal requirements.

Determine the collective impacts of all water regulations implemented
since the last survey in 2000.

Help guide implementation of significant new administration initiatives.

Assist the agency in crafting regulations that are sensitive to small
system needs and capabilities.

Guide states and other assistance providers in targeting needy water
systems and developing technical assistance programs.

Help determine the operating and financial factors associated with
successful regulatory compliance, and identify factors associated with
poor compliance records.

Help to verify the accuracy of information contained in the Safe
Drinking Water Information System (SDWIS).

B.1.b.	Key Variables  tc "B.1.b.	Key Variables " \l 3 

To satisfy the objectives of the survey the following kinds of essential
information for the water systems will be collected:

Size of population served.

Type of ownership.

Type, number and geographic distribution of water source.

Volume of water pumped and delivered.

Type and extent of distribution system.

Types of water treatment processes employed.

Revenues (by source).

Expenditures (by source).

Rate structure.

Sources of capital.

B.1.c.	Statistical Approach  tc "B.1.c.	Statistical Approach " \l 3 

The survey will be of a scientific probability sample of community water
systems (CWSs). The inferences to be made to the entire target
population will satisfy the survey objectives and the information needs
of EPA’s programs. A sample survey is being conducted instead of a
census survey because the latter would be prohibitively expensive, and
unnecessarily burdensome to CWSs.

The survey is being designed and conducted with the assistance of a
contractor:

Contractor	Contractor Roles

The Cadmus Group, Inc.

57 Water Street

Watertown, MA 02472	Technical oversight for all contractor activities. 

Questionnaire design and testing. 

Oversight of field operations, including site visits and administration
of questionnaire.

Statistical sample design.

Data processing. 

Training, mailing, and logistics.

Preparation of tables and final statistical report and survey
documentation. 

Data collection and data processing. 



B.1.d.	Feasibility  tc "B.1.d.	Feasibility " \l 3 

For medium, large, and very large systems, the survey questionnaires
have been designed with the capabilities of the typical respondent in
mind. A major portion of the survey questionnaires are refinements of
the 2000 survey. This survey provided guidance in developing questions
that respondents would be able to answer. Generally, the respondent
should be able to obtain the requested information from readily
accessible records and reports kept by the system. 

To reduce the burden on small systems, EPA contractor engineers will
visit the water systems that serve 3,300 or fewer people. The contractor
engineers will spend approximately an hour with the system owner or
operator, requesting information that will be helpful in estimating
system infrastructure needs. The engineer will then conduct a physical
inspection of the system to confirm information provided by the owner or
operator. 

Reliance on site visits to small CWSs was strongly recommended by the
EPA workgroup to avoid problems faced in past surveys of small CWSs: 

Total non-response. Since many systems have not clearly identified
responsible parties, and since responsible parties often are reluctant
to respond to data collection instruments, it is difficult to use a mail
or telephone survey to obtain the necessary information. 

Item non-response. System owners and operators often do not know the
details of the operating or financial characteristics of their systems.
Because EPA contractor engineers will conduct site visits to gather
data, item non-response should be eliminated. 

Reliability. State drinking water regulators are suspicious of
information provided directly from owners or operators of small CWSs.
Unlike larger systems, small CWSs usually do not have professional,
certified operators. Instead, one is likely to meet trailer park owners,
volunteers from homeowners associations, and others who are not water
supply professionals. 

Finally, employing site visits will substantially reduce the burden on
small CWSs. Total burden on the systems, on average, will be about an
hour. Instead of completing a data collection instrument, the system
owner or operator can answer questions asked by the visiting engineer.
The approach was discussed with knowledgeable state drinking water
regulators, as well as representatives of small CWSs, and all parties
agreed that it was the best approach to achieve the desired results of
the survey.

Sufficient funds are available in the existing contract to complete the
survey.

The time frame for the survey is acceptable to users of the data within
the OGWDW.



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B.2	SURVEY DESIGN  tc "B.2	SURVEY DESIGN " \l 2 

B.2.a.	Target Population and Coverage  tc "B.2.a.	Target Population and
Coverage " \l 3 

The target population is CWSs in operation in 2007. A CWS is a public
water system that serves at least 15 service connections used by
year-round residents or regularly serves at least 25 year-round
residents (40 CFR 141.2). 

B.2.b.	Sample Design  tc "B.2.b.	Sample Design " \l 3 

The CWSS will be based on a nationally representative sample of CWSs.
The survey will use a stratified random sample design to ensure the
sample is representative. The sample will be stratified by several
characteristics of water systems to increase the efficiency of estimates
based on the sample. To improve the quality of the data collected, the
survey will be administered on-site for small systems; to limit the
travel costs involved in visiting each small system in the sample, they
will be selected in geographic clusters in a two-stage design. 

B.2.b.1.	Sample Frame  tc "B.2.b.1.	Sample Frame " \l 4 

The sampling frame is developed from the SDWIS. SDWIS is a centralized
database of information on public water systems, including their
compliance with monitoring requirements, maximum contaminant levels
(MCLs), and other requirements of the SDWA Amendments of 1996. The
following information will be extracted from SDWIS for the statistical
survey: 

	

Name of system.

Address of system.

Population served.

Total design capacity.

Number of connections. 

Primary source (surface water or ground water).

Public water system identification number (PWSID).

Ownership type. 

Consecutive system (i.e., does system purchase or sell water).

From these data, we will develop a list frame from which we will (1)
calculate summary statistics for use in calculating sample size, and (2)
randomly choose systems within the design strata which will take part in
the survey.

Justification For The Use of SDWIS

SDWIS is the appropriate sampling frame because:

It fully covers the target population.

It contains no duplication.

It contains no foreign elements (i.e., elements that are not members of
the population).

It contains information for identifying and contacting the units
selected in the sample.

It contains other information that will improve the efficiency of the
sample design.

SDWIS is the ideal choice for a sample frame because of its inclusive
coverage of all units of observation for this survey. In addition, SDWIS
has two other advantages: it contains information that will facilitate
contacting the respondents, and it contains other information that is
useful in stratifying the sample, thereby improving the efficiency of
the sample design.

The use of SDWIS as a sample frame in previous surveys was subject to
some criticism. Since 1989, EPA has conducted audits of the quality of
SDWIS data. As a result, EPA is aware of the problems with SDWIS. The
audits, however, show that errors in classification of systems by strata
proposed for this survey are rare. Audits show that systems are
misclassified by population or source in fewer than one percent of all
cases. 

The EPA is taking several steps to prepare SDWIS for use as a sample
frame for the 2007 DWINSA. Problematic data will be identified and the
states will be asked to review the data and provide any necessary
changes. These data will serve as the sample frame for the 2007 CWSS. 

B.2.b.2.	Sample Size  tc "B.2.b.2.	Sample Size " \l 4 

The domains of the population of interest for the OGWDW are based on two
major characteristics of the systems. 

The primary source of water. Systems that rely primarily on ground water
are distinguished from surface water systems. 

The size of the population served by the system. Eight size categories
will be used: systems that serve less than 100 people; systems that
serve 101 to 500 people; systems that serve from 501 to 3,300 people;
systems that serve from 3,301 to 10,000 people, systems that serve from
10,001 to 50,000 people; systems that serve 50,001 to 100,000 people;
systems that serve from 100,001 to 500,000 people; and systems serving
more than 500,000 people. 

The two water sources and the eight system sizes produce 16 strata. 

The regulatory impact models require reasonably precise parameter
estimates from each of these domains. The sample size in each domain
should be large enough to provide a sufficient number of completed
questionnaires to obtain estimates with reasonable precision. Table B-1
shows the number of systems in the sample frame and the minimum sample
size required to obtain an estimate for a 50 percent statistic with an
error not exceeding ± 10 percentage points (except for a 1 in 20
chance) in each domain. We will take a census of systems serving more
than 100,000 people. 

We used a 50 percent statistic because the standard error is largest
when the population percentage is 50 percent. The error will be smaller
for other population percentages. 

B.2.b.3.	Stratification Variables  tc "B.2.b.3.	Stratification Variables
" \l 4 

The sample is stratified to achieve two goals. First, stratifying the
data allows us to draw inferences about specific population domains. For
example, EPA may wish to draw conclusions about systems serving
populations of less than 10,000 or 3,300. We can ensure that estimates
of the sub-populations will meet the required levels of precision by
drawing the necessary number of observations for each stratum. 

The second goal achieved by stratifying the data is that we can increase
the efficiency of our estimates by grouping systems into relatively
homogeneous strata. The strata were chosen to minimize the differences
among systems within strata, and to maximize the differences among
strata. Based on the results of previous surveys, we assume there are
important differences in the way systems are operated and in their
finances across the strata selected. The operating characteristics and
treatment requirements of ground water systems tend to be different from
surface water systems. The operating and financial characteristics of
large systems tend to be more complex than small systems. System
management, and the resources available to it, also may vary by system
size. 

Table B-1. Frame and Sample Sizes by Strata  tc "

Table B-1.  Frame and Sample Sizes by Strata " \f D  

Source of Water	Population Served	Frame Size	Sample Size

Ground	100 or less	12,503	96

	101-500	14,827	103

	501 - 3,300	12,063	158

	3,301 - 10,000	3,672	94

	10,001-50,000	2,330	93

	50,001 - 100,000	352	76

	100,001 - 500,000	188	188

	More than 500,000	23	23

Surface	100 or less	268	71

	101-500	573	83

	501 - 3,300	1,164	89

	3,301 - 10,000	953	88

	10,001-50,000	1,043	88

	50,001 - 100,000	298	73

	100,001 - 500,000	300	300

	More than 500,000	69	69

All

50,626	1,692



The size of the population served and the primary source of water are
the explicit stratification variables. The sample frame will be divided
by eight population sizes: less than 100; 100 – 500, 501 – 3,300,
3,301 – 10,000, and 10,000 – 50,000, 50,001 – 100,000, and 100,001
– 500,000, and more than 500,000. Systems will be further divided by
two source-water categories: ground water and surface water. 

B.2.b.4.	Sampling Method  tc "B.2.b.4.	Sampling Method " \l 4 

Systems serving populations greater than 100,000 will be selected with
certainty. For systems serving populations of 100,000 or fewer, the
sampling method will be an equal probability systematic sample within
each explicitly defined stratum. There are 12 such strata, given by the
intersection of the six population size classes whose systems are not
being selected with certainty and the two water sources. Within each
stratum, the data will be sorted by EPA Region and size of the
population served. This ensures the geographical dispersion among the
sample systems and increases the probability that a range of population
sizes within each explicit stratum is sampled. The total sample size –
including the strata that will be sampled with certainty – will be
1,703. 

The survey statisticians will prepare detailed specifications to direct
the sampling, and to document the process. These specifications will
ensure the sample is drawn in conformity with the sample design and in a
statistically valid manner. Standard statistical software will be used
to draw the sample. 

B.2.b.5.	Multi-Stage Sampling  tc "B.2.b.5.	Multi-Stage Sampling " \l 4 

In order to achieve the required precision, reduce the burden to small
systems, and to keep costs down, a two-stage cluster sample will be used
for systems serving fewer than 3,300 people. The use of a two-stage
sample design will result in slightly reduced precision for the
stratum-level estimates. 

	First-Stage Sample

All small CWSs will be assigned to a county (or county equivalent in
jurisdictions that do not have counties). Data on all small CWSs will be
sorted by county so that EPA can determine the number of systems, by
strata, in each county. If a particular county does not contain the
required number of systems (a minimum of 6 systems), it is grouped with
an adjacent county; the combined county group is referred to as a
county-cluster. The first-stage sample will be approximately 120
counties, selected with probability proportional to size, where size is
a composite measure of the number of small systems in each county. This
method ensures that counties with more CWSs serving 3,300 or fewer
people have a greater probability of being selected.  

States will be given a SDWIS list of small CWSs in the county (or
counties) selected in the first-stage sample for their jurisdictions,
and EPA will ask states to verify that the systems on the list are
active CWSs with populations of 3,300 and fewer and assigned to the
appropriate county. If the number of systems in a county is large (e.g.,
100 or more), EPA will select a sub-sample of the systems in that county
to reduce the burden on the state. This review by the states will
produce a clean sample frame for the second-stage sample.

	Second-Stage Sample

In the second stage, a stratified random sample of five systems is drawn
from each of the counties or county-clusters selected in the first stage
of sampling. 

B.2.c.	Precision Requirements  tc "B.2.c.	Precision Requirements " \l 3 

B.2.c.1.	Precision Targets  tc "B.2.c.1.	Precision Targets " \l 4 

To satisfy EPA’s decision-making needs, the sample is designed to
provide estimates of percentages of error not exceeding 10 percentage
points (expect for a 1 in 20 chance) within each domain for an estimated
proportion. The domains are shown in Table B-1. For example, suppose 50
percent of the systems in a domain report that they boost chlorine
residuals in their distribution system. EPA could be 95 percent
confident that between 40 percent and 60 percent of the systems within
this domain boost chlorine residuals. 

Systems serving populations greater than 100,000 will be sampled with
certainty; therefore, there will be no sampling error in these domains. 

B.2.c.2.	Nonsampling Error  tc "B.2.c.2.	Nonsampling Error " \l 4 

EPA will use several quality assurance techniques to maximize response
rates, response accuracy, and processing accuracy to minimize
nonsampling error. A pre-test will supplement the experience of EPA and
its contractors in formulating a strategy to reduce non-sampling error. 

The data collection approach proposed by EPA should reduce both overall
non-response rates and item non-response. It also should improve both
the accuracy and consistency of the data reported by the systems. Small
systems will be visited by EPA contractor engineers, which will ensure
that the necessary data are collected and are consistent across systems.
Technical assistance will be made available to medium, large, and very
large systems to help them fill out the questionnaire and to ensure
accurate and consistent responses to the survey’s questions. Each
system will be contacted by contractor staff; also, systems will be
provide a dedicated toll-free telephone number they can call for
assistance. 

In addition, the following steps will improve the quality of the data: 

A brief cover letter will be sent to the respondents that will explain
the purpose of the survey and the information to be collected. It will
be on official EPA letterhead, and will be signed by a senior EPA
official. 

The data collection instrument design, content, and format will be
thoroughly reviewed and tested before the survey begins. The approach
will be pre-tested to ensure that the necessary data can be collected. 

Items being asked are those that owners or operators of systems should
know. We do not ask questions that require monitoring, research, or
calculations on the part of the respondents. 

Standardized software will be used for sample selection. 

We expect complete coverage of the target population using SDWIS, as
updated by EPA. 

Data will be 100 percent independently keyed and verified. 

The Agency will also will develop an electronic reporting form that
systems can use to complete the questionnaire. It is anticipated that
this form will reduce the burden for systems completing the form and for
Agency to perform data entry and improve the accuracy of the data. The
electronic versions of the questionnaire will include data validation
checks to confirm responses as they are provided. Systems also will have
the option of filling out a web-based questionnaire. The web-based
version also will include data validation checks to confirm responses as
they are provided and will allow respondents to pause in answering the
questions and return to complete the questionnaire at a later time .  

B.2.d.	Questionnaire Design  tc "B.2.d.	Questionnaire Design " \l 3 

The questions contained in the surveys are designed to obtain
information on a variety of water system related technical and financial
data. Many of the questions seek to obtain qualitative information,
which would then be used to create descriptive statistics. Section
A.4.b.1. provides the justification for each question in the survey. 

In order to limit the burden on respondents and to improve the quality
of the data collected, small CWSs will not be required to fill out a
questionnaire. As discussed in section B.4, EPA contractor engineers
will visit water systems serving 3,300 or fewer people, and will fill
out the questionnaire based on the information they collect. Contractor
personnel will provide assistance to systems serving populations over
3,300. If the information requested in a question is available in
schematics or other documentation of the system, the system may simply
attach the documentation to the question rather than fill out the
question. 

To ensure quality of the data collected by the questionnaire, it was
subject to several rounds of close review and comment by EPA, Cadmus,
and independent reviewers. (See section A.3.c in Part A for the list of
reviewers.) Special attention will be paid to the presentation and
layout of the questions, response categories, response recording blocks,
and instructions to clarify the questionnaire for respondents. 

B.3.	PRE-TESTS AND PILOT TESTS  tc "B.3.	PRETESTS AND PILOT TESTS " \l
2 	

B.3.a.	Pre-tests  tc "B.3.a.	Pretests " \l 3 

The survey instrument was sent to nine water systems. Three systems
participated in a focus group discussion of the questionnaire. A fourth
system provided comments separately. The other five systems did not
comment on the questionnaire; OGWDW is following up with these systems
to get any comments they may have on the questionnaire. The
questionnaires and instructions were revised in accordance with the
results of the pre-test. 

B.3.b.	Pilot Study  tc "B.3.b.	Pilot Study " \l 3 

Following OMB approval the, a pilot study of up to 50 respondents will
be conducted for both the site visits to small systems and the
multi-step data collection for medium and large systems. 

The purpose will be to fine-tune any troublesome questions, increase
clarity, reduce respondent burden, and test survey processing systems
before the surveys are fielded. EPA plans to use the pilot responses for
any water systems also selected in the main survey. 



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B.4.	COLLECTION METHODS AND FOLLOW-UP  tc "B.4.	COLLECTION METHODS AND
FOLLOW-UP " \l 2 

B.4.a.	Collection Methods  tc "B.4.a.	Collection Methods " \l 3 

Site visits will be conducted of small systems — those serving 3,300
or fewer systems. EPA contractor engineers will physically inspect the
system and interview system owners and operators. They will then fill
out the questionnaire based on the information they collect. 

Systems serving populations of over 3,300 will be asked to fill out the
questionnaire electronically or by hand. Each potential respondent will
be contacted to provide technical assistance and to respond to
questions. Systems will be asked to mail in site plans and other
diagrams along with the completed questionnaire. 

Several measures will be in place to assure the quality of the data
collection. The final version of the questionnaires will incorporate
lessons learned from the pre-test and pilot test. Complete and detailed
question-by-question specifications will be prepared for every
questionnaire item, to unambiguously document for interviewers and
analysts the meaning, purpose, and context of all questions.
Interviewers will receive formal training for interviewing techniques
and for specific CWSS topics. Staff with detailed substantive knowledge
of water systems will conduct follow up phone calls to address technical
issues that may arise. Supervisory staff will monitor the interviews.
Special data collection operations (such as tracing) will be used to
improve response rates, sample coverage, and locating the correct
sampled CWS. 

B.4.b.	Survey Response and Follow-Up  tc "B.4.b.	Survey Response and
Follow-Up " \l 3 

The response rate is the ratio of responses to eligible respondents. 
The target response rate for the survey will be 75 percent for systems
serving more than 3,300 people and 95 percent for systems serving 3,300
and fewer, for an overall response rate of 81%.  These anticipated
response rates are based on actual response rates from the 2000 CWSS,
factoring in a slight increase resulting from the small systems site
visits being conducted in conjunction with the 2007 DWINSA, which
historically achieves a higher response rate, and the use for the first
time of a web-based questionnaire to facilitate responses.  



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B.5.	ANALYZING AND REPORTING SURVEY RESULTS  tc "B.5.	ANALYZING AND
REPORTING SURVEY RESULTS " \l 2 

B.5.a.	Data Preparation  tc "B.5.a.	Data Preparation " \l 3 

The contractor will key and independently verify the data. Senior data
entry operators will be used for the verification to assure quality
control. Editing will consist of automated logic and range checks, and
checks for missing data. Missing data will be imputed by using standard
methods such as cell means, regression, and hot deck to supply values
for the missing items. 

B.5.b.	Analysis  tc "B.5.b.	Analysis " \l 3 

The statistical procedures used to analyze the data will be left up to
the individual data users. The contractor will prepare a report
tabulating the results of the survey and indicating the precision of the
resulting national estimates. Examples of statistics that will be
produced are: 

Frequency distributions of all discrete variables in the questionnaire.

Counts of customers being served by water systems in each domain (e.g.,
the number of active residential connections served by ancillary
systems, with fewer than 500 customers, receiving primarily surface
water).

Counts for each domain of interest of water systems with certain
characteristics (e.g., the number of treatment technologies for each of
the population categories and water sources).

Mean and median rates by customer category, revenues, expenses, capital
expenditures, and other financial data for each domain of interest. 

The fully weighted data will be provided on a data file accessible to
the EPA program offices for customized analyses. 

B.5.c.	Reporting Results  tc "B.5.c.	Reporting Results " \l 3 

The survey results will be made available to the Agency and the public
through the following means: 

A printed report of key statistical tables. These survey results will be
distributed to all interested offices at EPA.  Additional copies will be
made available to the general public through the National Technical
Information Service (NTIS); 

An electronic copy of the report will be posted to the OGWDW web site;
and

Mainframe access (Agency only).

A report containing the questionnaire, sampling plan, weights,
variances, and formulas and response rates will be prepared and
distributed with the data. Record layouts, codes and complete file
documentation will be developed for Agency mainframe data file users. 



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Appendix A

Relevant Sections of Statutes tc "Appendix A

Relevant Sections of Statutes" 



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Sec. 300j-4(a)(1)(A)

(1)(A) Every person who is subject to any requirement of this subchapter
or who is a grantee, shall establish and maintain such records, make
such reports, conduct such monitoring, and provide such information as
the Administrator may reasonably require by regulation to assist the
Administrator in establishing regulations under this subchapter, in
determining whether such person has acted or is acting in compliance
with this subchapter, in administering any program of financial
assistance under this subchapter, in evaluating the health risks of
unregulated contaminants, or in advising the public of such risks. In
requiring a public water system to monitor under this subsection, the
Administrator may take into consideration the system size and the
contaminants likely to be found in the system's drinking water. 

Sec. 300g-1(b)(3)(C)

(C) Health risk reduction and cost analysis. - 

(i) Maximum contaminant levels. - When proposing any national primary
drinking water regulation that includes a maximum contaminant level, the
Administrator shall, with respect to a maximum contaminant level that is
being considered in accordance with paragraph (4) and each alternative
maximum contaminant level that is being considered pursuant to paragraph
(5) or (6)(A), publish, seek public comment on, and use for the purposes
of paragraphs (4), (5), and (6) an analysis of each of the following: 

(I) Quantifiable and nonquantifiable health risk reduction benefits for
which there is a factual basis in the rulemaking record to conclude that
such benefits are likely to occur as the result of treatment to comply
with each level. 

(II) Quantifiable and nonquantifiable health risk reduction benefits for
which there is a factual basis in the rulemaking record to conclude that
such benefits are likely to occur from reductions in co-occurring
contaminants that may be attributed solely to compliance with the
maximum contaminant level, excluding benefits resulting from compliance
with other proposed or promulgated regulations. 

(III) Quantifiable and nonquantifiable costs for which there is a
factual basis in the rulemaking record to conclude that such costs are
likely to occur solely as a result of compliance with the maximum
contaminant level, including monitoring, treatment, and other costs and
excluding costs resulting from compliance with other proposed or
promulgated regulations. 

(IV) The incremental costs and benefits associated with each alternative
maximum contaminant level considered. 

(V) The effects of the contaminant on the general population and on
groups within the general population such as infants, children, pregnant
women, the elderly, individuals with a history of serious illness, or
other subpopulations that are identified as likely to be at greater risk
of adverse health effects due to exposure to contaminants in drinking
water than the general population. 

(VI) Any increased health risk that may occur as the result of
compliance, including risks associated with co-occurring contaminants. 

(VII) Other relevant factors, including the quality and extent of the
information, the uncertainties in the analysis supporting subclauses (I)
through (VI), and factors with respect to the degree and nature of the
risk. 

(ii) Treatment techniques. - When proposing a national primary drinking
water regulation that includes a treatment technique in accordance with
paragraph (7)(A), the Administrator shall publish and seek public
comment on an analysis of the health risk reduction benefits and costs
likely to be experienced as the result of compliance with the treatment
technique and alternative treatment techniques that are being
considered, taking into account, as appropriate, the factors described
in clause (i). 

(iii) Approaches to measure and value benefits. - The Administrator may
identify valid approaches for the measurement and valuation of benefits
under this subparagraph, including approaches to identify consumer
willingness to pay for reductions in health risks from drinking water
contaminants. 

(iv) Authorization. - There are authorized to be appropriated to the
Administrator, acting through the Office of Ground Water and Drinking
Water, to conduct studies, assessments, and analyses in support of
regulations or the development of methods, $35,000,000 for each of
fiscal years 1996 through 2003. 

Sec. 300g-1(b)(4)(D)

(D) Definition of feasible. - For the purposes of this subsection, the
term ''feasible'' means feasible with the use of the best technology,
treatment techniques and other means which the Administrator finds,
after examination for efficacy under field conditions and not solely
under laboratory conditions, are available (taking cost into
consideration). For the purpose of this paragraph, granular activated
carbon is feasible for the control of synthetic organic chemicals, and
any technology, treatment technique, or other means found to be the best
available for the control of synthetic organic chemicals must be at
least as effective in controlling synthetic organic chemicals as
granular activated carbon. 

Sec. 300g-4(a)(1)(A)

(a) Notwithstanding any other provision of this part, variances from
national primary drinking water regulations may be granted as follows:

(1)(A) A State which has primary enforcement responsibility for public
water systems may grant one or more variances from an applicable
national primary drinking water regulation to one or more public water
systems within its jurisdiction which, because of characteristics of the
raw water sources which are reasonably available to the systems, cannot
meet the requirements respecting the maximum contaminant levels of such
drinking water regulation. A variance may be issued to a system on
condition that the system install the best technology, treatment
techniques, or other means, which the Administrator finds are available
(taking costs into consideration), and based upon an evaluation
satisfactory to the State that indicates that alternative sources of
water are not reasonably available to the system. The Administrator
shall propose and promulgate his finding of the best available
technology, treatment techniques or other means available for each
contaminant for purposes of this subsection at the time he proposes and
promulgates a maximum contaminant level for each such contaminant. The
Administrator's finding of best available technology, treatment
techniques or other means for purposes of this subsection may vary
depending on the number of persons served by the system or for other
physical conditions related to engineering feasibility and costs of
compliance with maximum contaminant levels as considered appropriate by
the Administrator. Before a State may grant a variance under this
subparagraph, the State must find that the variance will not result in
an unreasonable risk to health. If a State grants a public water system
a variance under this subparagraph, the State shall prescribe at the [1]
time the variance is granted, a schedule for -

(i) compliance (including increments of progress) by the public water
system with each containment level requirement with respect to which the
variance was granted, and 

(ii) implementation by the public water system of such additional
control measures as the State may require for each contaminant, subject
to such contaminant level requirement, during the period ending on the
date compliance with such requirement is required. Before a schedule
prescribed by a State pursuant to this subparagraph may take effect, the
State shall provide notice and opportunity for a public hearing on the
schedule. A notice given pursuant to the preceding sentence may cover
the prescribing of more than one such schedule and a hearing held
pursuant to such notice shall include each of the schedules covered by
the notice. A schedule prescribed pursuant to this subparagraph for a
public water system granted a variance shall require compliance by the
system with each contaminant level requirement with respect to which the
variance was granted as expeditiously as practicable (as the State may
reasonably determine). 

Sec. 300g-4(e)

(e) Small system variances 

(1) In general A State exercising primary enforcement responsibility for
public water systems under section 300g-2 of this title (or the
Administrator in nonprimacy States) may grant a variance under this
subsection for compliance with a requirement specifying a maximum
contaminant level or treatment technique contained in a national primary
drinking water regulation to - 

(A) public water systems serving 3,300 or fewer persons; and 

(B) with the approval of the Administrator pursuant to paragraph (9),
public water systems serving more than 3,300 persons but fewer than
10,000 persons, if the variance meets each requirement of this
subsection. 

(2) Availability of variances A public water system may receive a
variance pursuant to paragraph (1), if - 

(A) the Administrator has identified a variance technology under section
300g-1(b)(15) of this title that is applicable to the size and source
water quality conditions of the public water system; 

(B) the public water system installs, operates, and maintains, in
accordance with guidance or regulations issued by the Administrator,
such treatment technology, treatment technique, or other means; and 

(C) the State in which the system is located determines that the
conditions of paragraph (3) are met. 

(3) Conditions for granting variances A variance under this subsection
shall be available only to a system - 

(A) that cannot afford to comply, in accordance with affordability
criteria established by the Administrator (or the State in the case of a
State that has primary enforcement responsibility under section 300g-2
of this title), with a national primary drinking water regulation,
including compliance through - 

(i) treatment; 

(ii) alternative source of water supply; or 

(iii) restructuring or consolidation (unless the Administrator (or the
State in the case of a State that has primary enforcement responsibility
under section 300g-2 of this title) makes a written determination that
restructuring or consolidation is not practicable); and 

(B) for which the Administrator (or the State in the case of a State
that has primary enforcement responsibility under section 300g-2 of this
title) determines that the terms of the variance ensure adequate
protection of human health, considering the quality of the source water
for the system and the removal efficiencies and expected useful life of
the treatment technology required by the variance. 

(4) Compliance schedules A variance granted under this subsection shall
require compliance with the conditions of the variance not later than 3
years after the date on which the variance is granted, except that the
Administrator (or the State in the case of a State that has primary
enforcement responsibility under section 300g-2 of this title) may allow
up to 2 additional years to comply with a variance technology, secure an
alternative source of water, restructure or consolidate if the
Administrator (or the State) determines that additional time is
necessary for capital improvements, or to allow for financial assistance
provided pursuant to section 300j-12 of this title or any other Federal
or State program. 

(5) Duration of variances The Administrator (or the State in the case of
a State that has primary enforcement responsibility under section 300g-2
of this title) shall review each variance granted under this subsection
not less often than every 5 years after the compliance date established
in the variance to determine whether the system remains eligible for the
variance and is conforming to each condition of the variance. 

(6) Ineligibility for variances A variance shall not be available under
this subsection for - 

(A) any maximum contaminant level or treatment technique for a
contaminant with respect to which a national primary drinking water
regulation was promulgated prior to January 1, 1986; or 

(B) a national primary drinking water regulation for a microbial
contaminant (including a bacterium, virus, or other organism) or an
indicator or treatment technique for a microbial contaminant. 

(7) Regulations and guidance 

(A) In general Not later than 2 years after August 6, 1996, and in
consultation with the States, the Administrator shall promulgate
regulations for variances to be granted under this subsection. The
regulations shall, at a minimum, specify - 

(i) procedures to be used by the Administrator or a State to grant or
deny variances, including requirements for notifying the Administrator
and consumers of the public water system that a variance is proposed to
be granted (including information regarding the contaminant and
variance) and requirements for a public hearing on the variance before
the variance is granted; 

(ii) requirements for the installation and proper operation of variance
technology that is identified (pursuant to section 300g-1(b)(15) of this
title) for small systems and the financial and technical capability to
operate the treatment system, including operator training and
certification; 

(iii) eligibility criteria for a variance for each national primary
drinking water regulation, including requirements for the quality of the
source water (pursuant to section 300g-1(b)(15)(A) of this title); and 

(iv) information requirements for variance applications. 

(B) Affordability criteria Not later than 18 months after August 6,
1996, the Administrator, in consultation with the States and the Rural
Utilities Service of the Department of Agriculture, shall publish
information to assist the States in developing affordability criteria.
The affordability criteria shall be reviewed by the States not less
often than every 5 years to determine if changes are needed to the
criteria. 

(8) Review by the Administrator 

(A) In general The Administrator shall periodically review the program
of each State that has primary enforcement responsibility for public
water systems under section 300g-2 of this title with respect to
variances to determine whether the variances granted by the State comply
with the requirements of this subsection. With respect to affordability,
the determination of the Administrator shall be limited to whether the
variances granted by the State comply with the affordability criteria
developed by the State. 

(B) Notice and publication If the Administrator determines that
variances granted by a State are not in compliance with affordability
criteria developed by the State and the requirements of this subsection,
the Administrator shall notify the State in writing of the deficiencies
and make public the determination. 

(9) Approval of variances A State proposing to grant a variance under
this subsection to a public water system serving more than 3,300 and
fewer than 10,000 persons shall submit the variance to the Administrator
for review and approval prior to the issuance of the variance. The
Administrator shall approve the variance if it meets each of the
requirements of this subsection. The Administrator shall approve or
disapprove the variance within 90 days. If the Administrator disapproves
a variance under this paragraph, the Administrator shall notify the
State in writing of the reasons for disapproval and the variance may be
resubmitted with modifications to address the objections stated by the
Administrator. 

(10) Objections to variances 

(A) By the Administrator The Administrator may review and object to any
variance proposed to be granted by a State, if the objection is
communicated to the State not later than 90 days after the State
proposes to grant the variance. If the Administrator objects to the
granting of a variance, the Administrator shall notify the State in
writing of each basis for the objection and propose a modification to
the variance to resolve the concerns of the Administrator. The State
shall make the recommended modification or respond in writing to each
objection. If the State issues the variance without resolving the
concerns of the Administrator, the Administrator may overturn the State
decision to grant the variance if the Administrator determines that the
State decision does not comply with this subsection. 

(B) Petition by consumers Not later than 30 days after a State
exercising primary enforcement responsibility for public water systems
under section 300g-2 of this title proposes to grant a variance for a
public water system, any person served by the system may petition the
Administrator to object to the granting of a variance. The Administrator
shall respond to the petition and determine whether to object to the
variance under subparagraph (A) not later than 60 days after the receipt
of the petition. 

(C) Timing No variance shall be granted by a State until the later of
the following: 

 (i) 90 days after the State proposes to grant a variance. 

 (ii) If the Administrator objects to the variance, the date on which
the State makes the recommended modifications or responds in writing to
each objection. 

Sec. 300g-2

(a) In general For purposes of this subchapter, a State has primary
enforcement responsibility for public water systems during any period
for which the Administrator determines (pursuant to regulations
prescribed under subsection (b) of this section) that such State - 

(1) has adopted drinking water regulations that are no less stringent
than the national primary drinking water regulations promulgated by the
Administrator under subsections (a) and (b) of section 300g-1 of this
title not later than 2 years after the date on which the regulations are
promulgated by the Administrator, except that the Administrator may
provide for an extension of not more than 2 years if, after submission
and review of appropriate, adequate documentation from the State, the
Administrator determines that the extension is necessary and justified; 

(2) has adopted and is implementing adequate procedures for the
enforcement of such State regulations, including conducting such
monitoring and making such inspections as the Administrator may require
by regulation; 

(3) will keep such records and make such reports with respect to its
activities under paragraphs (1) and (2) as the Administrator may require
by regulation; 

(4) if it permits variances or exemptions, or both, from the
requirements of its drinking water regulations which meet the
requirements of paragraph (1), permits such variances and exemptions
under conditions and in a manner which is not less stringent than the
conditions under, and the manner in which variances and exemptions may
be granted under sections 300g-4 and 300g-5 of this title; 

(5) has adopted and can implement an adequate plan for the provision of
safe drinking water under emergency circumstances including earthquakes,
floods, hurricanes, and other natural disasters, as appropriate; and 

(6) has adopted authority for administrative penalties (unless the
constitution of the State prohibits the adoption of the authority) in a
maximum amount - 

(A) in the case of a system serving a population of more than 10,000,
that is not less than $1,000 per day per violation; and 

(B) in the case of any other system, that is adequate to ensure
compliance (as determined by the State); except that a State may
establish a maximum limitation on the total amount of administrative
penalties that may be imposed on a public water system per violation. 

(b) Regulations 

(1) The Administrator shall, by regulation (proposed within 180 days of
December 16, 1974), prescribe the manner in which a State may apply to
the Administrator for a determination that the requirements of
paragraphs (1), (2), (3), and (4) of subsection (a) of this section are
satisfied with respect to the State, the manner in which the
determination is made, the period for which the determination will be
effective, and the manner in which the Administrator may determine that
such requirements are no longer met. Such regulations shall require that
before a determination of the Administrator that such requirements are
met or are no longer met with respect to a State may become effective,
the Administrator shall notify such State of the determination and the
reasons therefore and shall provide an opportunity for public hearing on
the determination. Such regulations shall be promulgated (with such
modifications as the Administrator deems appropriate) within 90 days of
the publication of the proposed regulations in the Federal Register. The
Administrator shall promptly notify in writing the chief executive
officer of each State of the promulgation of regulations under this
paragraph. Such notice shall contain a copy of the regulations and shall
specify a State's authority under this subchapter when it is determined
to have primary enforcement responsibility for public water systems. 

(2) When an application is submitted in accordance with the
Administrator's regulations under paragraph (1), the Administrator shall
within 90 days of the date on which such application is submitted (A)
make the determination applied for, or (B) deny the application and
notify the applicant in writing of the reasons for his denial. 

(c) Interim primary enforcement authority A State that has primary
enforcement authority under this section with respect to each existing
national primary drinking water regulation shall be considered to have
primary enforcement authority with respect to each new or revised
national primary drinking water regulation during the period beginning
on the effective date of a regulation adopted and submitted by the State
with respect to the new or revised national primary drinking water
regulation in accordance with subsection (b)(1) of this section and
ending at such time as the Administrator makes a determination under
subsection (b)(2)(B) of this section with respect to the regulation. 

Sec. 300g-4(e)(7)

(7) Regulations and guidance 

(A) In general Not later than 2 years after August 6, 1996, and in
consultation with the States, the Administrator shall promulgate
regulations for variances to be granted under this subsection. The
regulations shall, at a minimum, specify - 

(i) procedures to be used by the Administrator or a State to grant or
deny variances, including requirements for notifying the Administrator
and consumers of the public water system that a variance is proposed to
be granted (including information regarding the contaminant and
variance) and requirements for a public hearing on the variance before
the variance is granted; 

(ii) requirements for the installation and proper operation of variance
technology that is identified (pursuant to section 300g-1(b)(15) of this
title) for small systems and the financial and technical capability to
operate the treatment system, including operator training and
certification; 

(iii) eligibility criteria for a variance for each national primary
drinking water regulation, including requirements for the quality of the
source water (pursuant to section 300g-1(b)(15)(A) of this title); and 

(iv) information requirements for variance applications. 

(B) Affordability criteria Not later than 18 months after August 6,
1996, the Administrator, in consultation with the States and the Rural
Utilities Service of the Department of Agriculture, shall publish
information to assist the States in developing affordability criteria.
The affordability criteria shall be reviewed by the States not less
often than every 5 years to determine if changes are needed to the
criteria. 

Sec. 300g-5 (a)(1)

(a) Requisite findings A State which has primary enforcement
responsibility may exempt any public water system within the State's
jurisdiction from any requirement respecting a maximum contaminant level
or any treatment technique requirement, or from both, of an applicable
national primary drinking water regulation upon a finding that - 

(1) due to compelling factors (which may include economic factors,
including qualification of the public water system as a system serving a
disadvantaged community pursuant to section 300j-12(d) of this title),
the public water system is unable to comply with such contaminant level
or treatment technique requirement, or to implement measures to develop
an alternative source of water supply, 

(2) the public water system was in operation on the effective date of
such contaminant level or treatment technique requirement, or, for a
system that was not in operation by that date, only if no reasonable
alternative source of drinking water is available to such new system, 

(3) the granting of the exemption will not result in an unreasonable
risk to health; and reasonably be made that will result in compliance
with this subchapter or, if compliance cannot be achieved, improve the
quality of the drinking water. 

Sec. 300g-9

(a) State authority for new systems 

A State shall receive only 80 percent of the allotment that the State is
otherwise entitled to receive under section 300j-12 of this title
(relating to State loan funds) unless the State has obtained the legal
authority or other means to ensure that all new community water systems
and new nontransient, noncommunity water systems commencing operation
after October 1, 1999, demonstrate technical, managerial, and financial
capacity with respect to each national primary drinking water regulation
in effect, or likely to be in effect, on the date of commencement of
operations. 

(b) Systems in significant noncompliance 

(1) List Beginning not later than 1 year after August 6, 1996, each
State shall prepare, periodically update, and submit to the
Administrator a list of community water systems and nontransient,
noncommunity water systems that have a history of significant
noncompliance with this subchapter (as defined in guidelines issued
prior to August 6, 1996, or any revisions of the guidelines that have
been made in consultation with the States) and, to the extent
practicable, the reasons for noncompliance. 

(2) Report Not later than 5 years after August 6, 1996, and as part of
the capacity development strategy of the State, each State shall report
to the Administrator on the success of enforcement mechanisms and
initial capacity development efforts in assisting the public water
systems listed under paragraph (1) to improve technical, managerial, and
financial capacity. 

(3) Withholding The list and report under this subsection shall be
considered part of the capacity development strategy of the State
required under subsection (c) of this section for purposes of the
withholding requirements of section 300j-12(a)(1)(G)(i) of this title
(relating to State loan funds). 

(c) Capacity development strategy 

(1) In general Beginning 4 years after August 6, 1996, a State shall
receive only - 

(A) 90 percent in fiscal year 2001; 

(B) 85 percent in fiscal year 2002; and 

(C) 80 percent in each subsequent fiscal year, of the allotment that the
State is otherwise entitled to receive under section 300j-12 of this
title (relating to State loan funds), unless the State is developing and
implementing a strategy to assist public water systems in acquiring and
maintaining technical, managerial, and financial capacity. 

(2) Content In preparing the capacity development strategy, the State
shall consider, solicit public comment on, and include as appropriate - 

(A) the methods or criteria that the State will use to identify and
prioritize the public water systems most in need of improving technical,
managerial, and financial capacity; 

(B) a description of the institutional, regulatory, financial, tax, or
legal factors at the Federal, State, or local level that encourage or
impair capacity development; 

(C) a description of how the State will use the authorities and
resources of this subchapter or other means to - 

(i) assist public water systems in complying with national primary
drinking water regulations; 

(ii) encourage the development of partnerships between public water
systems to enhance the technical, managerial, and financial capacity of
the systems; and 

(iii) assist public water systems in the training and certification of
operators; 

(D) a description of how the State will establish a baseline and measure
improvements in capacity with respect to national primary drinking water
regulations and State drinking water law; and 

(E) an identification of the persons that have an interest in and are
involved in the development and implementation of the capacity
development strategy (including all appropriate agencies of Federal,
State, and local governments, private and nonprofit public water
systems, and public water system customers). 

(3) Report Not later than 2 years after the date on which a State first
adopts a capacity development strategy under this subsection, and every
3 years thereafter, the head of the State agency that has primary
responsibility to carry out this subchapter in the State shall submit to
the Governor a report that shall also be available to the public on the
efficacy of the strategy and progress made toward improving the
technical, managerial, and financial capacity of public water systems in
the State. 

(4) Review The decisions of the State under this section regarding any
particular public water system are not subject to review by the
Administrator and may not serve as the basis for withholding funds under
section 300j-12 of this title. 

(d) Federal assistance 

(1) In general The Administrator shall support the States in developing
capacity development strategies. 

(2) Informational assistance 

(A) In general Not later than 180 days after August 6, 1996, the
Administrator shall - 

(i) conduct a review of State capacity development efforts in existence
on August 6, 1996, and publish information to assist States and public
water systems in capacity development efforts; and 

(ii) initiate a partnership with States, public water systems, and the
public to develop information for States on recommended operator
certification requirements. 

 (B) Publication of information The Administrator shall publish the
information developed through the partnership under subparagraph (A)(ii)
not later than 18 months after August 6, 1996. 

(3) Promulgation of drinking water regulations In promulgating a
national primary drinking water regulation, the Administrator shall
include an analysis of the likely effect of compliance with the
regulation on the technical, financial, and managerial capacity of
public water systems. 

(4) Guidance for new systems Not later than 2 years after August 6,
1996, the Administrator shall publish guidance developed in consultation
with the States describing legal authorities and other means to ensure
that all new community water systems and new nontransient, noncommunity
water systems demonstrate technical, managerial, and financial capacity
with respect to national primary drinking water regulations. 

(e) Variances and exemptions Based on information obtained under
subsection (c)(3) of this section, the Administrator shall, as
appropriate, modify regulations concerning variances and exemptions for
small public water systems to ensure flexibility in the use of the
variances and exemptions. Nothing in this subsection shall be
interpreted, construed, or applied to affect or alter the requirements
of section 300g-4 or 300g-5 of this title. 

(f) Small public water systems technology assistance centers 

(1) Grant program The Administrator is authorized to make grants to
institutions of higher learning to establish and operate small public
water system technology assistance centers in the United States. 

(2) Responsibilities of the centers The responsibilities of the small
public water system technology assistance centers established under this
subsection shall include the conduct of training and technical
assistance relating to the information, performance, and technical needs
of small public water systems or public water systems that serve Indian
Tribes. 

(3) Applications Any institution of higher learning interested in
receiving a grant under this subsection shall submit to the
Administrator an application in such form and containing such
information as the Administrator may require by regulation. 

(4) Selection criteria The Administrator shall select recipients of
grants under this subsection on the basis of the following criteria: 

(A) The small public water system technology assistance center shall be
located in a State that is representative of the needs of the region in
which the State is located for addressing the drinking water needs of
small and rural communities or Indian Tribes. 

(B) The grant recipient shall be located in a region that has
experienced problems, or may reasonably be foreseen to experience
problems, with small and rural public water systems. 

(C) The grant recipient shall have access to expertise in small public
water system technology management. 

(D) The grant recipient shall have the capability to disseminate the
results of small public water system technology and training programs.

(E) The projects that the grant recipient proposes to carry out under
the grant are necessary and appropriate. 

(F) The grant recipient has regional support beyond the host
institution. 

(5) Consortia of States At least 2 of the grants under this subsection
shall be made to consortia of States with low population densities. 

(6) Authorization of appropriations There are authorized to be
appropriated to make grants under this subsection $2,000,000 for each of
the fiscal years 1997 through 1999, and $5,000,000 for each of the
fiscal years 2000 through 2003. 

(g) Environmental finance centers 

(1) In general The Administrator shall provide initial funding for one
or more university-based environmental finance centers for activities
that provide technical assistance to State and local officials in
developing the capacity of public water systems. Any such funds shall be
used only for activities that are directly related to this subchapter. 

(2) National capacity development clearinghouse The Administrator shall
establish a national public water system capacity development
clearinghouse to receive and disseminate information with respect to
developing, improving, and maintaining financial and managerial capacity
at public water systems. The Administrator shall ensure that the
clearinghouse does not duplicate other federally supported clearinghouse
activities. 

(3) Capacity development techniques The Administrator may request an
environmental finance center funded under paragraph (1) to develop and
test managerial, financial, and institutional techniques for capacity
development. The techniques may include capacity assessment
methodologies, manual and computer based public water system rate models
and capital planning models, public water system consolidation
procedures, and regionalization models. 

(4) Authorization of appropriations There are authorized to be
appropriated to carry out this subsection $1,500,000 for each of the
fiscal years 1997 through 2003. 

(5) Limitation No portion of any funds made available under this
subsection may be used for lobbying expenses. 



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Appendix B

Comments and Response to Comments 

 tc "Appendix C

2000 Community Water Systems Questionnaires" 

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Part 1:  General Comments and Responses

 

Comment:

The survey instrument provided for review is not the Community Water
System Survey as the CWSS is a survey specifically designed to provide
cost and categorical data to serve as a general resource for EPA’s
SDWA program.

Response: 

The survey instrument provided is the data collection instrument for
Community Water System Survey (CWSS). In addition to gathering
information within the same two broad financial and operating categories
as has been done for over 20 years, 16 of the 28 questions asked in this
questionnaire are either identical to or slight variations of questions
asked in the 2000 CWSS. While the survey has always gathered information
on distribution systems, water storage and residuals management
practices, the Agency’s responsibility to safeguard public health and
evolving program needs require new information in this area from time to
time. This survey instrument will not only serve as a resource for
financial and operating data but will also provide valuable information
on other areas of interest to the Agency, such as water system security.


Comment:

The instrument provided for comment reflects a number of information
collection efforts particular to specific proposed rulemakings,
including the Distribution System Rule and Effluent Guidelines for Water
Treatment Plants. The agency is doing a disservice to these rulemakings
if it conducts an inadequate information collection through the proposed
CWSS survey rather than a robust research and data collection effort for
each rulemaking.

Response:

Like other data collect by the CWSS, the data on distribution systems
and storage are designed to provide general information on current
practices and conditions in the water sector.  While the information to
be collected may inform assessments of risk, it is not the Agency’s
intent to use them to form the basis for formal risk analyses.  

The usefulness of the distribution system questions is not limited to
supporting potential, new regulatory actions, but can also be used to
assess current risk factors and practices that might suggest new rule
making is unnecessary. Any proposed future regulation will be based on
the best information available and will not be limited to data collected
from the CWSS. For example, the effluent guidelines Screener Survey,
soon to be conducted by the Office of Science and Technology, is another
independent source of information in this area.  The usefulness of the
effluent disposal practices information will be discussed in the
response to detailed comments section. 

Comment:

Commenter supports the CWSS in as far as it can be used to help the
Agency understand cost impacts in its regulatory impact analyses. 
Commenter also supports the Agency’s intent to use the survey to
“help the Agency better conduct its outreach efforts to assist the
regulated community[.]”  

Response:

A number of questions have been added to the questionnaire this time
specifically in order to assess the best ways to reach out to water
system managers and operators.

Comment:

Commenter believes the CWSS is being used to discover opportunities for
future rulemakings.  Several of the questions in the survey appear to be
efforts to cast an overly wide net in order to explore regulatory
possibilities that are outside the scope of this effort.  This does not
fit the survey’s purpose. Instead, EPA should collect the data it
needs for future rulemakings in the context of developing risk
assessments and via Information Collection Rules for specific
rulemakings, as is being done for the Effluent Guidelines for Drinking
Water Treatment Residuals Rulemaking.  

Response:

As the Agency is charged with regulating drinking water contaminants, it
is only reasonable to assess risks of contamination and operating
practices which might pose a risk to public health.  Questions of this
nature are intended as much to determine that regulatory measures are
unnecessary as they are to support any that might be needed.  The
questions are purely exploratory and responses will be augmented by
additional information in the future as needed. 

Comment:

The commenter believes EPA should avoid survey questions that could be
answered instead by leveraging other data sources or collection
activities that may be available or underway in the Office of Water. 
AMWA encourages EPA to coordinate its many survey and information
collection efforts occurring to better leverage the information
gathered.  For example, the Office of Science and Technology is planning
a survey of utilities to gather information about treatment and disposal
of treatment residuals, which may overlap with question 18. 

Response:

EPA is in complete agreement.  As far as the Agency is aware, this
survey is the only way of collecting a nationally representative sample
of the financial and operating characteristics of water systems of all
sizes that will support our rule making and programmatic needs.  The
survey to be conducted by the Office of Science and Technology (OST)
requires substantially different treatment and residuals disposal
information than is required by the CWSS.  This derives from the two
different purposes of each office. However, the Office of Ground Water
and Drinking Water (OGWDW) is in the process of coordinating our
financial questions with those being asked by OST so that systems
responding to OST’s financial questions would not have to respond to
those in the CWSS, thus reducing the burden on systems that are jointly
sampled by both surveys.   Also, for the first time this year, EPA is
combining the small system data collection efforts of the CWSS and the
Drinking Water Needs Survey to minimize burden and reduce costs.

Comment:

Infrastructure cost information is being collected by the infrastructure
needs survey as well as the CWSS.  Although the information sought is
slightly different between the efforts, EPA should provide thorough
explanations and context for each question to the best of its ability. 
This will not only help utilities better understand the question but
also help ensure responses are adequate for the Agency’s purposes. 

Response:

The purpose of the Drinking Water Infrastructure Needs Survey and
Assessment (DWINSA) is to estimate future capital needs.  The purpose of
the CWSS is to provide a recent history of financial and operating
conditions. Thus, even though both contain questions related to a
system’s infrastructure, each approaches the subject with a very
different orientation. EPA intends to add additional explanations as to
the purposes of its questions.

Comment:

Commenter believes the burden estimate is too low and anticipates that
large utilities (serving >100,000 persons) will require between 40 and
60 hours to respond to the survey.  With regard to small systems, the
low-end estimate of 30 minutes is too low.  The proposed survey has 28
questions, and several have more than one part.  Commenter estimates it
would take an experienced employee at least 15 minutes just to read and
understand the survey before trying to respond to the questions. 
Commenter also suggests EPA develop an estimate for more than the two
widely disparate categories used in the survey.  It is highly unlikely
that a system serving fewer than 10,000 persons, for example, would
require the same amount of time that a utility serving greater than
100,000 persons would require.

EPA estimates that a public water system (PWS) will complete a 21-page
survey in less than 5 hours. In most systems, completing this survey
will require coordination among multiple individuals.  Even small
systems with limited on-site expertise will likely need to consult with
their consulting engineering firms to answer some of the questions, . 
The current estimate of burden grossly underestimates the amount of time
and effort PWSs of any size and configuration will have to undertake to
complete the survey accurately with information of any reasonable level
of quality.  Given EPA’s own experience conducting surveys at
very-small PWSs, it should be clear to the agency that this burden
estimate is inadequate to reflect a good faith effort to garner the
information requested. 

Response:

The estimated burden is based on past experience with the survey and the
results of a pre-test of the current questionnaire.  The estimate
recognizes differences in potential burden among systems by providing a
range.  EPA recognizes that some questions may take some systems
considerable time to answer completely and encourages systems to provide
estimates when possible.  The estimate for small systems reflects the
amount of time the system will need to spend with the site visitor; past
experience has shown that the site visitors can collect most of the data
without immediate involvement of the system. The 2006 CWSS has 28
questions on 21 pages and an estimated burden of from 1 to 5 hours, with
an average of 3.58 hours.  By comparison, the 2000 CWSS had 32 questions
on 22 pages and a burden estimate of 1 – 4 hours, with an average of
2.24 hours.  

Comment:

Commenter encourages EPA to allow utilities to respond to the survey
using a web-based survey instrument.  EPA should also allow for the
survey to be partially completed and saved online during the completion
process.  This feature is common business practice.  Employing it will
facilitate utilities’ response efforts and thus reduce completion
time. 

Response:

EPA is in complete agreement and plans to offer the respondents the
option of completing the questionnaire in stages as time allows. 

 Comment:  

The CWSS is specifically designed to support the development of national
regulations, particularly the cost implications of national rules. 
Typically, this means estimating the national average impact.  Though
estimates for individual size categories and percentiles other than the
50th percentile will be generated in most rulemakings, the quality of
those estimates is typically much lower than that of the aggregate
central tendency estimates.  Understanding this fundamental inadequacy
in the agency’s current analyses should lead the agency to revise its
objectives for the CWSS.  It is clear from the questions posed and the
scope of the survey effort (e.g., 1,700 of 50,000 CWSs) that the survey
is inadequate to make a meaningful contribute to either of the latter
goals identified by the agency in its description of the CWSS’s
objectives: 

  

1. “measure the impact of drinking water regulations,” or  

2. “measure the effectiveness of [state] programs already in
existence” 

Response:

As stated above, the sampling design meets the data quality objectives
of the survey.  The sampling rate in itself is not an indicator of the
quality of the data.  The sample size, nearly 500 systems larger than
the previous CWSS, was determined using standard statistical techniques
and it is adequate to meet the objectives of the survey. Because the
survey is designed to be accurate at the national level, rather than the
state level, it would not be possible to measure the effectiveness of
any particular state’s program.  Nor is it the purpose of this survey
to do so.  Commenter was in error in inserting “[state]” into the
quotation.  

Comment: 

Only one question bears on discerning the impact of drinking water
regulations retrospectively on PWSs and none of the questions bear on
the effectiveness of state programs. 

Response:

The primary purpose of the CWSS is to provide a baseline of information
on the financial and operating characteristics of  water systems on
which potential future rules might impact. While it is not designed to
measure individual rule impacts retrospectively, it can show how
revenues and expenditures have increased in order to cover a wide
variety of purposes. Also, by collecting information in question 27 B,
EPA can gather data on the proportion of total capital expenditures have
been devoted to regulatory-related expenses. EPA is conducting a
separate collection effort which will look retrospectively at rule
impacts. Being designed to provide information that is representative on
a national rather than state level, the CWSS is not intended to collect,
nor has it ever collected, information that bears on the effectiveness
of state programs.  It does, however, seek to assess progress in
implementing certain drinking water programs nationwide.  

Comment:  

The CWSS does not provide any protection of sensitive information from
Freedom of Information (FOIA) requests, yet the CWSS requests this
information without warning PWSs of this lack of security. 

Response:

The CWSS has always protected the anonymity of respondents, although
details of this had not yet been added to the early version of the
questionnaire available for commenters’ reviews.  We do not publish
any document that reveals either the name of the respondent of the water
system. Because of this, the voluntary nature of the survey and the fact
that we provide systems with an opportunity to claim confidential
business information (CBI) if EPA receives a FOIA request, we do not
provide respondents an opportunity to claim CBI in the questionnaire.
However, we have provided and will provide the following information on
the inside front cover of the questionnaire:

Participation in the survey is voluntary. However, as a matter of
policy, EPA will not disclose the identity of any respondent to this
questionnaire, nor the identity of any participating water system. While
no respondent has ever claimed that the information asked for in this
survey contains confidential business information (CBI), EPA will offer
the opportunity of claiming CBI to a representative of your water system
in the event that we receive a Freedom of Information Act request for
any data that would identity you or your system. It should be noted,
however, that EPA has never received a Freedom of Information Act
request for such information. 

 Comment:

Review of how EPA has employed the data from previous CWSS’s suggests
that there is little if any value for PWSs to submit additional
schematics of treatment, diagrams of distribution systems or other
facilities, or indeed more detailed financial responses than are
required by the survey itself.  The data is unlikely to be used
constructively and there is the added potential for it to be found and
misused through FOIA or other means. 

Response:

The CWSS requests this information to reduce the burden on systems. 
Systems may provide a financial report in lieu of filling out the
questionnaire if the report contains the requested information.  The
supporting documentation also is useful for validating responses and
ensuring the responses to the questionnaire are internally consistent. 
In most cases, the supporting documents requested are public
information.  If not, the system does not need to provide them. 
Additional procedures to safeguard system-specific information from FOIA
requests are in place as noted above.  The diagrams are extremely useful
for the Agency.  The agency does not use the diagram to draw statistical
inferences to the nation as a whole.  Rather, it uses the diagram to
validate responses to the survey.  For example, it uses it to ensure it
can account for each water source in a system.  

 

Part 2:  Detailed Comments and Responses

Comment:

 It is not clear how the survey can be compiled to accurately reflect
CWS conditions at a specific point in time if the survey results do not
consistently reflect the same time period.  The survey currently
requests that respondents provide information for the “most recent
12-month period for which data is available” and indicate what period
of time the response reflects.  Consequently, small system data
collected by EPA may reflect a substantially different period of time
than PWSs that respond using end-of-year financial statements, and
different yet again from PWSs that calculate answers from the latest 12
months of operation.  Given recent trends in energy and construction
price indices, the differentials in capital and operational costs could
be substantial even over short periods of time.  EPA should select a
specific calendar year. 

Response:

While a valid concern, it is not uncommon that respondents to surveys
report results for different time periods.   In most cases, the data are
reported for similar period, so the impact is relatively small.  EPA
does not ask for the data for specific year for two reasons.  First, it
would prefer to have audited financial data.  These data may not be
available for the year requested, and the quality of the data that are
provided would likely be lower. Second, this request would significantly
increase the burden of the survey on respondents. In fact, pre-test
participants specifically suggested that the survey request data for the
latest year available rather than for a specific year. EPA has
successfully used this approach in the last two surveys.  

 Comment:

 It is not clear how questions 4B and C regarding the details of PWS
computer equipment will assist the agency.  It is not clear what the
agency can infer from the data collected or that the data will have any
reasonable shelf life as computer equipment is typically obsolescent
within 3 years of purchase.  Is there national significance to the
number of PWSs with DVDs, high-speed modem access, and other new
computer equipment? 

Response:

Understanding the technological resources available to a PWS will assist
primarily with  rule implementation. The Agency, states and technical
assistance providers develop a variety of products and tools to help
systems understand and comply with regulations.  Our goal is to ensure
that these materials are appropriate for the target audience.  Since the
last CWSS, we have learned anecdotally that many more small PWS are
using computers on a daily basis.  This exercise will validate this
information as well as refine our project planning for the future.  In
addition, information exchanges may occur more frequently and more
accurately through the use of the internet via email, webpage postings,
etc., thus keeping our stakeholders better informed and up-to-date on
new rules as well as the old.  

 

Comment:

Constructing a relationship diagram like that in Figure 1 to answer
question 5 is not useful to the agency for at least two reasons.  First,
it is not useful because the agency cannot collect enough information to
make the relationships described informative when using other data
collected in the survey.  Second, the relationship diagrams for every
drinking water system is unique. Consequently, the agency will not be
able to draw any conclusions from the diagrams that it collects as the
sample size of 1,700 is too small to adequately capture even general
trends in such relationship diagrams.  

Response:

The agency does not use the diagram to draw statistical inferences to
the nation as a whole.  Rather, it uses the diagram to validate
responses to the survey.  For example, it uses it to ensure it can
account for each water source in a system.  The sample size is adequate
for the purposes of the survey as noted above. A similar diagram was
provided by respondents to the 2000 CWSS.

Comment:

Question 6A will result in inconsistent and consequently unusable
observations.  To provide valid responses, the PWSs completing the
survey must have common definitions for the following: 

 

1. What is the definition of a “seasonal” source?  For example, if a
utility cycles its entire well field are all of the sources
“seasonal”; if a source is used to meet peak demand but that peak
occurs both in the winter from main breaks and in the summer from
increased lawn watering, is it “seasonal”?   

2. What is the definition of an “emergency” supply? Is every supply
that is used less than 30 days a year, supplies that are of low quality
and only used with there is no other choice, supplies that are
particularly robust and unlikely to be affected by natural disasters,
etc.? 

3. What constitutes “treatment”?  Treatment could be maintaining a
residual disinfectant, operating a tray aerator, softening, conventional
treatment, or advanced treatment.  Where on this continuum is
“treatment” occurring for the purposes of this survey?     

 In order to determine what definition is appropriate, the agency will
need to consider how the survey results will be used.  For example, if
“treatment” is tracked as application of any unit operation and the
agency used the subsequent data to track whether more ground water
systems “treated” ground water as a result of the Ground Water Rule,
it would underestimate the impact of the rule by generating a false
baseline of existing 4-log disinfection or equivalent treatment
practice. 

Response:

A seasonal source is one used on for a portion of the year only.  For
example, a source used to account for seasonal fluctuations in demand. 
Emergency sources are ones used on an emergency basis only.  There is no
limit on the number of days it can be used or the type of emergency. 
These data are used to characterize the overall capacity of water
systems.  

Treatment includes any process intended to improve or maintain water
quality. It includes disinfection.  Subsequent questions ask systems to
characterize the type of treatment.  A definition of treatment will be
added to the question.  The treatment question in question 6 is an
internal consistency check; it is to ensure that additional information
about the treatment process is provided for all water treated by the
system.  This information is intended to provide a general
characterization of the myriad types of treatment used in the water
industry; it will not be used to evaluate the effectiveness of a
particular rule or to estimate the level of disinfection achieved by
systems.

Comment:

 

Question 6A also includes the following sub-question, “Estimate the
maximum daily amount of water that can be drawn from this source that
supply each ground water entry point.”  This question does not allow
for the impact of the water quality limitations on withdrawals. The
subsequent footnote also provides for the possibility of unlimited
withdrawal. Without an appreciation of state and local water resource
plans, local economic development and growth projections, and numerous
other factors, this data element is of little to no value to the agency.


Response:

Collected routinely since 1995, these data are used to characterize the
capacity of systems, including the variability in system capacity. 
Systems should account for water quality issues when providing estimates
of the quantities of water that can be withdrawn from a source.  They
also should take into account local water resource plans or other
factors that limit withdrawals.  Text will be added to the question to
ensure systems take these issues in to account when the estimate the
limitations on withdrawals.

 

Comment:

All of the points made above regarding question 6A are relevant to 6B
regarding surface water supplies and 6C regarding purchased water
connections.  Question 6B includes a category of surface supplies that
withdrawn but not treated by the PWS.  It is not relevant to the
agency’s needs to understand if a PWS withdraws water and provides
that water untreated to a non-drinking water customer.  There are PWSs
that are also bulk water providers and power producers – neither of
these business elements bear on the agency’s purview under the Safe
Drinking Water Act.  Another definitional problem emerges in Question 6B
and 6C – what is “typical” needs to be clearly stated.  For
example, in question 6B is this value intended to be the annual average,
annual mean, seasonal average, or some other statistic.  Is the value
intended to reflect the previous 12 months of record or some longer more
meaningful period of time that would reflect more than the most recent
weather pattern?  Question 6C complicates the use of typical further by
asking for the amount of water purchased on a “typical day” “on
average”; so not only is this value “typical” but it is typical of
the “average” day, where there is no context for what constitutes an
“average day.” In Question 6C, it is not clear how a PWS could
purchase water from a supplier and not know if it was finished drinking
water or not as suggested by one of the fifth sub-question.   

Response:

These data are used to characterize the capacity of systems. This
characterization must account for non-drinking water use; otherwise, it
may overestimate the drinking water capacity of a system.  Wholesalers
(“bulk providers”) and combined water and power utilities are
subject to EPA regulations under SDWA.  

The question asks for average withdrawals data requested are for the 12
month period reported in question 2 of the questionnaire.  While that 12
month period may be unusual, the CWSS is intended to provide a snapshot.
 The terms “average” and “mean” are synonymous and are generally
understood. Because means can be sensitive to extreme values, the
question asks for the average use on typical day. Systems will have some
discretion as to how they define typical.  Based on the experience of
past surveys, systems have little trouble interpreting these questions.
The option for providing a response of “Unknown” in Question 6.C is
simply to capture all possible, albeit unlikely, responses. 

Comment:

 

Question 6C also asks if booster disinfection occurs – but does not
specify when booster disinfection might occur.  Should a PWS only
indicate that booster disinfection occurs if the whole volume of water
purchased from a given source receives additional disinfection?  How
should a PWS respond if water is purchased from the same supply from
multiple turnouts, only some of which require booster disinfection? 
This same question applies equally to the question of treatment more
broadly in the following sub-question. 

Response:

The question asks for information by connection.  If a system purchases
water from one source but has multiple connections or turnouts, it
should list each separately.  This point will be clarified in the
instructions.

Comment:

Question 7 is reminiscent of the Information Collection Rule.  Asking
each of 1,700 rather than just the 372 CWS serving more than 100,000
persons to identify all of their water treatment plants and associate
the sources and flows of those sources for each of its plants.  This
information was captured in the ICR and the agency found that even with
monthly water quality data and treatment characterization data, it was
very difficult to use this information constructively in the development
of rule provisions.  It is not clear that the agency will be able to use
this data productively for a much larger group of systems if collected
today.   

Response:

These data have been collected by past CWS Surveys and are used to
provide a general picture of the industry.  They are used to estimate
average daily production, treatment capacity ,and peak daily production 
of systems.  They are not used to estimate water quality of systems. 
Data from large systems would not help estimate the capacity of smaller
system; therefore, the data are collected from all systems in the
sample.

Comment: 

The treatment and objective codes provided on page T1 / T2 will provide
some standardization to the PWS response to the following questions. 
Corrections to the codes include:  

1. Combine T3 and T4 (chloramine with free chlorine period and
chloramine with seasonal free chlorine use). 

2. T7 is “Ultraviolet light” not “ultraviolet”. 

3. Delete T8 (potassium permanganate) as potassium permanganate is not a
recognized disinfectant under the SWTR, IESWTR, LT1ESWTR, LT2ESWTR, or
proposed GWR. 

4. Delete T15 (polymer addition) as polymers can be used during
coagulation and filtration and the current survey scheme does not
provide mechanism to distinguish.  Also, the survey does not
characterize coagulants generally (alum, ferric, etc.) so the use of
polymers seems to be an aberration in the survey scheme. 

5. Delete T39 (clearwell) as the clearwell is either a component of
disinfection or storage. This question is about treatment so
disinfection is already covered. 

6. Objective O6 (oxidation) is redundant with other objective codes that
are more descriptive. 

7. Objectives that are missing include, DBP control, meet water
production demands with limited available water resources, meet customer
expectations, meet local water quality goals, and meet state-specific
regulations. 

Response:

1. We agree to consolidate T3 and T4 into one treatment code.

2. The question distinguishes between the seasonal use of free chlorine
addition  and its temporary use to address nitrates or other issues on
an irregular basis.  EPA will consider rephrasing the terms to clarify
the difference.  

3.  EPA agrees and will make this change.  

4. Potassium permanganate is used as an oxidant; some systems may use it
for disinfection,  even though it is not an approved disinfectant.  EPA
will move it to the “Other” category.

5. Polymers are used by some system in addition to coagulants.  Past
surveys indicate they are added in a separate step from coagulants. 
Polymer addition will be moved up in the list of processes so it follows
coagulant .  

6. Clearwell follows filtration, and it must be included to allow
systems to completely characterize the treatment process.  It helps to
understand where and when systems add disinfectant.  EPA will consider
changing the step to “Clearwell and/or contact basin.”  

7. Some processes may be used for either oxidation or disinfection.  For
example, a system may add chlorine prior to filtration for oxidation
purposes; it may add it again afterwards for disinfection.  The
oxidation objective allows systems to make this distinction.  

8. DBP control will be added as an objective. Question 8 requests data
on treatment objectives in terms of the treatment practice’s impact on
water quality, not the overall objective of the system.  The other
objectives suggested are not relevant in this context.  

Comment:

 

Responding to Question 8 (filling in the treatment and objective matrix
for each water treatment plant) imposes objectives on each unit
operation, when in fact, drinking water treatment is a series of
inter-related united operations.  For example, the IESWTR sets a filter
performance standard that reflects the performance of “conventional
treatment” – coagulation, flocculation, settling, and filtration all
have to occur successfully to meet the 0.3 NTU combined filter effluent
treatment technique.  The artificial boundaries imposed by this survey
design will result in difficult to interpret and spurious summaries of
treatment plant unit operation objectives. 

Response:

EPA recognizes that treatment plants use integrated processes.  Several
steps may be required to meet a single objective.  In that case, systems
may repeat the objective on each step.  As some steps have multiple
objectives, systems also may record more than one objective for each
step of the treatment process.  

Comment:

 

Any useful application of the results of Questions 10, 11, 18, and 19
must be premised on a logical linkage between the descriptions of the
treatment plant(s) from questions 7 an 8 and the data that is
subsequently collected.  This linkage does not exist in the current
survey design.  Adding this additional dimension to the survey design
would increase the level of effort required by PWSs to answer the
questions to the order of weeks rather than days of effort. 

Response:

Question 10 is explicitly linked to question 8.  Question 11 is intended
to collect general information about storage and is not linked to the
treatment in place.  Question 18 collects data about the distribution
system; systems with multiple plants may not be able to link the
responses to individual treatment plants.  Question 19 is not related to
treatment, but is intended to provide a proxy measure of the service
area of the system as was done for the 1995 CWSS. The Agency is aware of
the potential shortfalls of using ZIP code data.  The data are used to
link the survey data with data from the US Census.  Alternative
approaches – like asking for service area maps – proved inadequate. 

Comment:

 

Question 9 is inadequate to the task it appears to be attempting to
solve, that is, informing the development of CWA Effluent Guidelines for
drinking water treatment plants.  The survey question is not specific
with respect to what residual streams are of interest.  Indeed, it
provides a number of disposal options, any combination of which may be
applicable to a given plant for some fraction of its residual streams. 
The question also asks “Can you discharge to a water-way?” without
providing any context (is this a question of if pipes are in place for
such a discharge, are there legal prohibitions, are there permit
restrictions, etc.).  AWWA submitted detailed comments on the draft
Water Treatment Plant questionnaire prepared by the CWA Effluent
Guidelines Team.  A review of those comments will illustrate the
complexity of ascertaining useful information about water treatment
plant residual management processes.  The proposed survey question will
not generate any information of value to the Effluent Guidelines effort
or SDWA efforts to understand residuals management.  AWWA has proposed a
detailed alternative survey strategy to EPA for capturing information
about residuals management that the agency should pursue rather than
developing questions that in the CWSS that do not provide data that can
be used to inform decision-making processes. 

Response:

A separate survey conducted by the Office of Science and Technology, not
the CWSS, will collect  data to inform the development of CWA Effluent
Guidelines. Rather, the question provides data on alternative approaches
to residual management practices used by systems as was gathered by a
nearly identical question in the 2000 CWSS.  The data inform estimates
of the cost of treatment by providing information on residual management
practices associated with various treatment processes. Columns 8, 10 and
12 of this question will be re-worded for clarity such that “Can
you…?” will be replaced in all instances with: “Are you legally
able to…?”

Comment:

 

Question 10 cannot be answered by PWSs.  The purpose of the regulatory
process is to determine what must be removed to protect public health
and to what levels it must be reduced to achieve that goal.  The
chemical and physical processes at work in drinking water treatment
plant unit operations also affect the concentrations of constituents in
natural waters that are not regulated.  The extent to which this occurs
is a topic for focused research, not a survey query to PWSs. 
Understanding removal does not occur through a random response from a
survey, it comes from focused experiments that evaluate the conditions
under which specific contaminants are removed by particular treatment
processes or combinations of processes.  The information collected by
this question would not have any utility to EPA because there is
insufficient information collected to understand any removal that is
observed. 

Question 10 appears to be an effort to identify every unregulated
contaminant utilities are monitoring, regardless of EPA’s intent to
regulate those contaminants.  EPA also appears to be seeking
information on contaminants the utilities are removing, again regardless
of EPA’s regulatory plans.  Utilities may test for many unregulated
contaminants, but monitoring for unregulated contaminants is not uniform
across all systems.  Additionally, utilities do not necessarily have, as
the question assumes, information on every unregulated contaminant that
may be reduced or removed by treatment plant technology, given that
treatment may address contaminants not specifically identified by the
utility.  

Instead, unregulated contaminant monitoring should be accomplished
through the third Unregulated Contaminant Monitoring Rule (UCMR) based
on the current Contaminant Candidate List (CCL).  EPA used this approach
in the 2000 CWSS, by asking for raw water and treated water
concentrations of specific unregulated contaminants on the CCL (e.g.,
MTBE) as well as contaminants that had been proposed (e.g. arsenic.) 

In addition, EPA should continue to use the National Contaminant
Occurrence Database (NCOD) for analysis, rulemaking and rule evaluation.
 And the NCOD should be populated by data collected under the UCMR, in
STORET and from USGS surveys and research projects, and not the CWSS.

Response:

Question 10 collects data on raw and finished water concentrations of
unregulated contaminants for very large systems only.  39 of 89 systems
were, in fact, able to provide similar data in the 2000 CWSS.  That data
has proved useful in the past in confirming MTBE and Boron data from the
UCMR.  The question is not designed to estimate the effectiveness of
treatment processes for removing unregulated contaminants and the data
will not be used for that purpose.  Instead, the data would be useful
for several efforts which include (1) the development of the Contaminant
Candidate List (CCL) and the Unregulated Contaminant Monitoring
Regulation (UCMR), (2) the regulatory determinations for the CCL, and
(3) the review process for the Six Year Review.  

In the case of CCL and UCMR, the surveillance of unregulated
contaminants is an important aspect of the Agency’s strategy to
identify potential candidates for CCL and UCMR.  If the data indicate
that some contaminants are occurring in many different systems and if
these contaminants have not yet been identified by either CCL or UCMR,
this information could provide “early warning” and help the Agency
identify contaminants that should be considered for future CCLs and/or
the UCMRs.    

In the case of regulatory determinations for CCL, the Agency primarily
relies on drinking water occurrence data from UCMR to determine whether
a national primary drinking water regulation is needed for a particular
contaminant.  While the Agency gains valuable information from the UCMR
effort, its focus differs from that of Question 10 in one important way
- UCMR occurrence data are collected after treatment is applied, which
means that some raw water contaminants may be removed or greatly diluted
by the treatment process and thus go undetected, leaving a false
impression that the contaminant is absent in the source water.  In cases
where the UCMR finished water data indicate that a contaminant is not
occurring, this would lead the Agency to make a determination not to
regulate a particular contaminant.  If an unregulated contaminant listed
on CCL and monitored by UCMR is being removed because of current
treatment practices, this information is valuable since it demonstrates
that some additional health protection may be occurring and unaccounted
for since we do not have information on raw vs. finished water.  And
even though the Agency decides not to regulate a contaminant based on
the UCMR finished water data, it would be advantageous for the Agency to
point to cases or take credit for unregulated contaminants that are
being removed by current treatment practices.

In the case of Six Year Review, if the data indicates that certain
unregulated contaminants are removed or their concentrations
significantly reduced by the use of treatment processes designed to
treat regulated contaminants, then the Six Year Review process may also
be able to take credit for the benefits of treating unregulated
contaminants. 

Lastly, there is no sampling error (the random error referred to by the
comment), as the survey asks all very large systems for the data.  The
data will not be used to draw inferences to other systems.

 

Comment:

 

Question 11A asks for information on every water storage facility in a
drinking water utility.  It is not clear what the agency could possibly
do with this information.  What is the national significance of the
number of 200,000 gal tanks versus the number of 500,000 gal tanks?  Is
there a national need to know how many tanks are baffled? How many tanks
have separated inlets and outlets? The agency, once again, is collecting
information that is inadequate to answer any important policy questions.
 There are numerous PWSs with large numbers of tanks – completing this
portion of the survey would be an onerous task with little benefit for
the agency.  The agency also specifically asked “"What is the typical
detention time of the water in the vessel (in days)?".   How would this
be calculated – is the standard of care a calculation of the hydraulic
detention time based on plug flow, a modeled result compliant with Stage
2 DBPR IDSE requirements, or a best guess? The information collected
through this question will vary greatly across PWSs and the role of
particular tanks in the PWSs distribution system.  For example, how will
the agency separate out tanks that are used to move water long distances
through a distribution system or combined distribution from tanks that
are used to serve residential areas?  The former will have very short
hydraulic detention times while the later may or may not, but it is only
the later has the greater potential to directly affect water quality at
the customer’s home.  Question 11B asks “Do you use any of the
following practices to maintain water quality in storage vessels in your
system? (check all that apply)”.   Providing this information without
context is meaningless.  Are the options provided used? Yes.  The
information needed is in what situations, and to what effect.  Simply
capturing the frequency utilities respond that they use different
approaches does not make any linkage to water quality, to frequency of
use within a given utility, the tank settings where different approaches
are employed, etc.  With this much missing information, the agency
should reconsider the utility of this question. 

Response: EPA proposes to revise the questions accordingly.

11A:  This question has been deleted.

11B:  The purpose of asking this question is simply to identify the
frequency of common practices, not to reach conclusions about water
quality.  We have added a second column of check boxes next to the first
where systems can react to the following question: “Check below if you
believe you have adequate information on how to use this strategy to
address water quality degradation in your storage facilities”

Comment:

Question 12 uses incorrect definitions for “transmission lines” and
“mains”.  Transmission mains are described as raw water or partially
treated water mains.  However, the term is frequently used in
distribution system parlance as large diameter pipe used to move water
from the plant to major storage facilities and major sources of water
demand.  If raw water piping is to be captured, then a separate table
should be added to the table.  Also, the table for answering the
question specifies all pipe information relates to “mains” (see left
axis) when the text above the table indicates that service lines are
relevant.  Service lines are not “mains” and should not be counted
as such.  Again, a separate category would be appropriate if the agency
has a need for information about service lines.  Since the agency’s
authority under SDWA stops at the customer’s property line, it is not
clear what value information on service lines has for the agency.   

With respect two Question 12, it is curious that the period of
construction captured is 5 years when previous questions have not
specified more than a period of one year.  Consistency is needed within
the survey instrument to reduce inadvertent errors.  Also, this once
again raises the question of what is the pertinent timeframe for the
questions in this survey.  Infrastructure investments occur over
extended timeframes as do other factors that affect PWS decisions. 

Response:  

The 2000 survey asked for the length of pipe replaced during the last 5
years.  A 5 year planning period is appropriate so that outlier years
with significant additions or replacements are spread out over a period
of time to better reflect overall expansion and replacement trends and
ensures that significant expenditures are not overlooked. EPA has
simplified the question to reduce the number of pipe categories from 6
to 4.   Beyond that, EPA believes the following clarifications will
address the rest of the concerns:

.  

A transmission line is defined as a pipeline that transports raw or
partially treated water to a water treatment plant or finished water to
a distribution grid.

A distribution main is defined as part of the pipeline network that
distributes water to the consumers.

Replaced pipe is pipe that has either been physically removed from the
ground or has been subject to major rehabilitation efforts.

New pipe installed is new service lines pipe for transmission lines or
distribution mains that do not replace existing pipe.  

On diagram, “Distribution Mains System”

In table, “Existing (or Current) Length of Pipe”

Comment:

Questions 13 – 17 raise the question of whether this is the Community
Water System Survey or whether it is an Information Collection Rule for
the Distribution System Rule.  If this information collection is
intended to provide a sound backdrop for any cost-analysis of regulatory
or policy decisions made by EPA, then this question is going into an
area of detail that is not pertinent.  If the agency intends for this
information collection activity to support the TCR/DSR rulemaking
effort, then the questions asked are inadequate, lack context to provide
meaningful information, and could lead to misleading assumptions in
development of a rulemaking focused on PWS distribution systems.  With
respect to these questions, the agency does not” 

 

1. Collect information to put booster disinfection use in context –
what percent of distribution system is downstream of booster
disinfection, is booster disinfection continuous, what other activities
are coordinated with booster disinfection (e.g., capital improvement
program for new transmission mains, tankage, etc.). 

2. Identify what “minimum daily operating pressure” means.  (e.g.,
is this water pressure or a pressure related to booster chlorination, if
water pressure is this a value measured at the point of entry (pressure
entering the pressure zone, the pressure at a representative topographic
high point), if water pressure is it pressure at a particular time of
the year (during high demand, low demand, etc.) or averaged over 365
days, etc. 

3. Areal extent of pressure drop below 20 psi (e.g., it is not
appropriate to equally weight the number of pressure losses affecting a
single building (e.g., service line break) with pressure losses
affecting the entire distribution system (e.g., simultaneous loss of
high service pumps and major distribution storage failure).   

  

Again, the definitions used will limit the utility of the survey effort
on flushing.  The definitions of directional and random flushing are
inadequate.  Also, in asking if a utility “has every flushed” the
survey instrument fails to ascertain if any water quality challenges
were evident in the system. 

Response:  

Regarding item 1, above, EPA does not need this other information to
provide context because Although we have reduced the scope of some
questions to minimize the burden to utilities responding to the survey,
we do not believe we need the detail suggested by AWWA to achieve the
purpose for which we intend to use this data.

Regarding item 2, above, the question will be revised to read, “What
is the minimum operating pressure recorded during your peak demand month
across all pressure zones in your system?”

Regarding item 3, above, we are collecting this information because they
affect distribution system water quality and it is the Agency’s
responsibility to safeguard public health. Backflow events are
associated with pressure reductions, and booster disinfection mitigates
the risk associated with backflow. We need to determine the extent to
which management measures are already in place (e.g., use of pressure
zones, booster disinfection) in order to identify whether further
measures are necessary, and the potential utility cost of implementing
risk reduction strategies. The NAS has identified cross connections and
backflow as another high priority distribution system risk.  The recent
NAS report has specifically mentioned improvements in pressure
maintenance as being effective for preventing and controlling DS
contamination; consequently it is important to collect better data on
current practices to support regulatory and costing analyses.

As EPA has previously indicated, the purpose of the CWSS is to obtain
new data to support its development and evaluation of drinking water
regulations.  The Agency plans to use the data for regulatory, policy,
and implementation analyses.  The scope of these questions is indeed
pertinent for inclusion in the CWSS.  EPA has developed these questions
to balance the information needs of the Agency with the burden of
responding to the survey.  

Collecting information to support cost-analysis and regulatory and
policy decisions is pertinent to the CWSS.  As stated in previous CWSS
reports, the purpose of the CWSS is to obtain new data to support its
development and evaluation of drinking water regulations.  The Agency
plans to use the data for regulatory, policy, implementation, and
compliance analyses.   The responses to these questions will provide
baseline data for risk evaluation, costing information, and for
development of guidance and training materials.

Regarding the comment that the survey instrument fails to ascertain if
any water quality challenges were evident in the system, EPA will
determine through engineering and scientific analysis how these
practices best contribute to water quality maintenance in the
distribution system. The flushing questions will inform us to what
extent practices are currently in use, identify need for guidance or
training, and estimate costs for improved or additional flushing
programs. Flushing has been selected as a high priority area for data
collection because it is one of the most common mitigation strategies.

Again, regarding the comment that the survey instrument fails to
ascertain if any water quality challenges were evident in the system,
EPA will determine through engineering and scientific analysis how these
practices best contribute to water quality maintenance in the
distribution system. EPA proposes to make the following revisions to
questions: 

Revision to question 13a (Parts 4 a and b):  

These parts have been eliminated.

Revision to question 16: 

“Uni-) Directional  (Restricting water flow to one direction using
closed valves to maximize velocity, generally from source/plant to the
lowest elevation in the system)”

Random Conventional 

 

Comment:

Question 18 asks PWSs to provide average residual values at the
point-of-entry to the distribution system and in the distribution
system.  Scott Summer’s work in the analysis of the ICR data during
the Stage 2 M/DBP FACA illustrated that this data is of little value in
understanding chlorine decay in the distribution system unless evaluated
on a system-by-system basis.  Collecting this information from 1,700
systems without information characterizing the distribution systems in
detail does not provide any information that can be used constructively.


Response:  

We have identified this as a high priority area because we are not aware
of any other means of access we have to this type of data. It is
necessary to collect new disinfectant residual data because ICR data
will be 10 years old and do not reflect the significant operational
changes that have been implemented in response to the Stage 1 and Stage
2 DBPRs, including reduced disinfectant demand due to greater precursor
removal and changes to residual disinfectant practices.  Utilities rely
on disinfectant residual to mitigate contamination events and control
biofilm and growth.  It is important for EPA to understand disinfectant
levels in the distribution system as systems are complying with the
current regulations to achieve an understanding of baseline risk and
determine whether changes to existing requirements are appropriate. EPA
intends to evaluate data received from this question on a
system-by-system basis and aggregate the results of the system-by-system
evaluation.

Comment:

Question 19 would link 5-digit ZIP codes to PWS service areas for small
to medium-sized PWSs.  The agency should seriously evaluate the utility
of such an approach.  There is seldom a one-to-one match between zip
codes and service areas.  Zip codes will frequently include many more
individuals than are served by a PWS so any extrapolation of the PWS to
zip codes will overstate utility service areas and underestimate per
capita costs. 

Response: 

The Agency is aware of the potential shortfalls of using ZIP code data. 
The data are used to link the survey data with data from the US Census. 
Alternative approaches – like asking for service area maps – proved
inadequate.  The data are not used to estimate per capita costs, so it
will not lead to an underestimate of per capita costs.  

 Comment:

Question 20 is largely a solicitation of opinions.  It is not clear how
the opinions garnered would be actionable by the agency. The questions
in this section will require highly subjective answers and will vary
widely on local opinions, politics, and a utility’s engagement in the
water security arena locally and nationally. By contrast, most other
questions in the CWSS are based on specific data that can be collected. 

Question 20 A.3.a. - Utilities will always be working to improve their
ability to prevent, detect, respond to and recover from a security
incident.  Therefore, utilities will always be needing and seeking more
information on these topics

Response:

The answers to question 20 will help EPA use official responses from
utilities on their security needs to make programmatic decisions, rather
than assuming those needs or justifying program expenses and priorities
because of hearsay. This is essentially what GAO does when they issue a
report with recommendations. GAO sends out a survey and gets responses.
Those responses are used to justify their recommendations for program
priorities and redirection. The same would be true for how EPA will use
these answers.

In addition, question 20 helps EPA gauge the exposure of its security
products in the water sector. If utilities have or have not taken our
training and/or heard of our programs, then that is helpful information
for EPA to know, because it tells us how effective or ineffective our
outreach/training has been.

Comment:

 

Questions 22 and 23 are regarding PWS rate structures and assistance to
disadvantaged households.  Like other pieces of information collected by
the proposed survey instrument, this is interesting information.  But,
to what end is EPA collecting this data?  EPA does not have a need for
this information within its mission, implementing the SDWA. 

Response:

System finance is a critical component of EPA’s capacity development
program.  These data support EPA’s analysis of issues related to
full-cost pricing, affordability, and asset management.  Collected in
1995 and in 2000, the data also support EPA’s overall assessment of
the industry.

Comment:

 

Question 24 will provide the maximum number of residential connections. 
This information has no value.  If the issue is the regulatory bin the
system falls in (e.g., greater or less than 10,000 population served) or
the changing demand on the system then the data needed is the change in
population served.  Secondly, while there are instances where the number
of “residential connections” will increase or decrease the more
common metric is the increase in water delivered to the greater number
of persons present in a given service area. 

Response:

Other data are used to determine the size of the system for regulatory
purposes.  These data are used to further understand the impact of
seasonal populations on systems’ with substantial seasonal
fluctuations in population.  The number of connections is a proxy for
the potential fluctuation in the size of the population served.  EPA
will consider requesting data on changes in water deliveries rather than
connection; EPA suspects this information would be more difficult for
systems to provide than data on seasonal connections.

Comment:

Question 25 is not clear and should be better explained.  Specifically,
is EPA interested in the average number of hours employees work per week
(e.g., 40), or in the cumulative number of hours all operators, managers
and administrative staff work (e.g., 40 hours x total number of
operators.)  How should responses address part-time employees? 

Response:

The question asks for the average number of hours per week system’s
employees work in the system, e.g. 40 hours per week.  Part-time
employees and employees should be included in the average.  Text will be
added to clarify what information is required.  

 

Comment:

Question 26 asks for expenses over the last fiscal years and indicates
that this is the same period as identified in Question 2.  Question 2
asks for the PWS to “the most recent 12-month period for which data
are available”.  Financial data can be compiled for any preceding
12-month period after the receipt of the survey instrument.  This is
different from the preceding fiscal year, which will allow referencing a
standard fiscal report for some, though by no means all of the fiscal
data requested.  

Response: 

The agency will clarify the language for the question.  EPA wants
financial data for the latest 12 month period for which they are
available.  The requirement that systems compile financial data
specifically for the survey would impose a large burden on systems. This
question was also asked in the 2000 CWSS.    

 Comment:

Question 26 A-D asks the respondent to enumerate expenses into a set of
categories.  Are these categories meant to be exclusive (should the
total sum to 100%) or does the agency realize that expenses for
purchased water will include capital and operational costs, that capital
costs will include security costs, etc. 

Response: 

The categories are intended to be mutually exclusive.  Expenses for
purchased water should include the cost of the water only, not the
capital required to bring it to the system.  EPA will clarify this issue
in the next draft of the questionnaire.  

 

Comment:

Question 27.  Again the period for capital expenditures is described as
a 5-year period where the previous question 26 (expenses) was limited to
most recent fiscal year.  The survey continues to mix and match periods
over which data is aggregated. 

Response:

Question 26 asks about regular, routine operating expenses.  Question 27
asks for capital expenses, which are not routine and thus may not have
been made during the last 12-month period.  While the system may not
have incurred capital expenses in the 12 months covered by question 26,
it may have had large investments the years immediately preceding. 
Therefore, as has been done since 1995, the CWSS asks for capital
expenses for a longer period of time so as to gain a more realistic,
annualized estimate.  

 Comment:

It is not possible to answer Question 27B as written “What percentage
of the total capital expenditures identified in part A were used for the
following ... “Compliance with regulations, excluding expenditures for
system expansion and replacement and repair of equipment.”  The costs
of regulations are embedded in every capital decision a drinking water
utility.  By answering this question by using one of the other
categories provided the respondent underestimates the impact of
regulations in its decisions; if the respondent allocates all costs to
this category then the estimate will misrepresent the impact of other
drivers.  Thirdly, even system expansions include cost elements that are
directly related to regulations (e.g., sizing of tanks, choice of pipe
material, selection of treatment processes, selection of water sources,
etc.). 

Response:

The agency recognizes that capital expenses serve multiple purposes. 
The survey asks systems to use their judgment and estimate the share
that goes towards each purpose. Such questions have been successfully
answered by respondents in two prior CWSSs, 1995 and 2000. While EPA
realizes that a variety of purposes underlie each expenditure, the
Agency believes that the system owners and operators are in a better
position to estimate such an allocation for their system than are those
not familiar with the system.

 

Comment: 

Question 28A, like many questions in this survey, lacks a specific
purpose that is closely linked to the agency’s responsibilities under
SDWA.  Moreover, lacking a sound definition of “asset management
plan” the response will be meaningless.  Finally, the selection of a
20-year planning horizon may not be appropriate for systems that choose
to focus aggressively on a shorter-term planning horizon. 

Response:

Over the last several years, along with EPA and many other drinking
water industry stakeholders, AWWA has undertaken considerable effort to
promote sound asset management. For example, from   HYPERLINK
"http://www.awwa.org/education/seminars/index.cfm?SemID=57_" 
http://www.awwa.org/education/seminars/index.cfm?SemID=57  , “This new
AWWA Asset Management seminar will underscore the urgency of getting
started and enable you to launch the appropriate management strategies
to provide prudent stewardship of public utility assets.” However, we
too recognized that the message may not have reach ever owner and
operator, and where it has, we also recognize that a consensus on the
detailed specifications of what makes a sound asset management plan has
not yet been concluded.

At the same time, we do believe that the industry has progress enough in
the area that a general definition can be derived and we will insert one
into the instructions for the Survey.   We believe it is important to
gain some sense of the degree that systems are beginning to avoid the
fundamental folly of "aggressively focusing on a shorter-term planning
horizon" without the context of understanding their long-term asset
management needs.  Similarly, if the industry’s asset management needs
and direction are, as AWWA and many others have stated, true phenomena,
it would be folly for EPA regulatory efforts to proceed over the next
several years in ignorance of the trend.  

Please note that the 20-year horizon has gained some foothold in the
assessment management field including its use in the Drinking Water
Infrastructure Needs Survey conducted every four years by EPA and in
EPA’s “Gap Analysis Report.”  It has also been used in similar
assessments and reports by the Water Infrastructure Network (WIN) as
well as by the Government Accounting Office.  We are open to suggestions
for alternative asset management timeframes but we would need some
rationale for not being consistent with these other efforts. 

 According to the ICR Handbook, an employee works an average of 2,080
hours in one year.

 This method is based on Folsom, R.E., F.J Potter., and S.R. Williams,
“Notes on a Composite Size Measure for Self-Weighting Samples in
Multiple Domains,” American Statistical Association 1987 Proceedings
of the Section on Survey Research Methods, August, 1987, pp. 792-796. 

ICR for 2006 CWSS 	  PAGE  115 	August 2, 2006

