  SEQ CHAPTER \h \r 1 							

Information Collection Request for the 2007 Drinking Water
Infrastructure Needs Survey and Assessment (DWINSA)

(Supporting Statement for ROCIS)

August 2006

Prepared by:

The Cadmus Group, Inc.

57 Water Street

Watertown, MA 02472

Prepared for:

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water

Drinking Water Protection Division



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Table of Contents

  TOC \o "2-2" \t "Heading 1,1,Heading 3,3"  PART A OF THE SUPPORTING
STATEMENT	  PAGEREF _Toc142817564 \h  5 

A.1	IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc142817565
\h  5 

A.1.a	Title of the Information Collection Request	  PAGEREF
_Toc142817566 \h  5 

A.1.b	Short Characterization	  PAGEREF _Toc142817567 \h  5 

A.2	NEED FOR AND USE OF THE COLLECTION	  PAGEREF _Toc142817568 \h  7 

A.2.a	Authority and Need for the Collection	  PAGEREF _Toc142817569 \h 
7 

A.2.b	Use and Users of the Information	  PAGEREF _Toc142817570 \h  7 

A.3	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	 
PAGEREF _Toc142817571 \h  9 

A.3.a	Nonduplication	  PAGEREF _Toc142817572 \h  9 

A.3.b	Public Notice Required Prior to ICR Submission to OMB	  PAGEREF
_Toc142817573 \h  10 

A.3.c	Consultations	  PAGEREF _Toc142817574 \h  10 

A.3.d	Effects of Less Frequent Collection	  PAGEREF _Toc142817575 \h  11


A.3.e	General Guidelines	  PAGEREF _Toc142817576 \h  11 

A.3.f	Confidentiality Questions	  PAGEREF _Toc142817577 \h  12 

A.3.g	Sensitive Questions	  PAGEREF _Toc142817578 \h  12 

A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED	  PAGEREF
_Toc142817579 \h  13 

A.4.a	Respondents/NAICS Codes	  PAGEREF _Toc142817580 \h  13 

A.4.b	Information Requested	  PAGEREF _Toc142817581 \h  14 

A.4.b.i 	Data Items	  PAGEREF _Toc142817582 \h  14 

A.4.b.ii	Respondent Activities	  PAGEREF _Toc142817583 \h  16 

A.5	INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT	  PAGEREF _Toc142817584 \h  19 

A.5.a	Agency Activities	  PAGEREF _Toc142817585 \h  19 

A.5.b	Collection Methodology and Management	  PAGEREF _Toc142817586 \h 
20 

A.5.c	Small Entity Flexibility	  PAGEREF _Toc142817587 \h  24 

A.5.d	Collection Schedule	  PAGEREF _Toc142817588 \h  24 

A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	  PAGEREF
_Toc142817589 \h  25 

A.6.a	Respondent Burden	  PAGEREF _Toc142817590 \h  25 

A.6.a.i	Burden to Public Water Systems	  PAGEREF _Toc142817591 \h  25 

A.6.a.ii	Burden to Primacy Agencies	  PAGEREF _Toc142817592 \h  29 

A.6.b	Respondent Costs	  PAGEREF _Toc142817593 \h  33 

A.6.b.i	Costs to Public Water Systems	  PAGEREF _Toc142817594 \h  33 

A.6.b.ii	Cost to States	  PAGEREF _Toc142817595 \h  34 

A.6.c	Agency Burden and Cost	  PAGEREF _Toc142817596 \h  35 

A.6.d	Estimating Respondent Universe and Total Burden and Costs	 
PAGEREF _Toc142817597 \h  38 

A.6.e	Bottom Line Burden Hours and Costs	  PAGEREF _Toc142817598 \h  38 

A.6.f	Reasons for Change in Burden	  PAGEREF _Toc142817599 \h  41 

A.6.g	Burden Statement	  PAGEREF _Toc142817600 \h  41 

PART B OF THE SUPPORTING STATEMENT (FOR STATISTICAL SURVEYS)	  PAGEREF
_Toc142817601 \h  43 

B.1	Survey Objectives, Key Variables and Other Preliminaries	  PAGEREF
_Toc142817602 \h  45 

B.1.a	Survey Objectives	  PAGEREF _Toc142817603 \h  45 

B.1.b	Key Variables	  PAGEREF _Toc142817604 \h  45 

B.1.c	Statistical Approach	  PAGEREF _Toc142817605 \h  46 

B.1.d	Feasibility	  PAGEREF _Toc142817606 \h  47 

B.2	Survey Design	  PAGEREF _Toc142817607 \h  49 

B.2.a	Target Population and Coverage	  PAGEREF _Toc142817608 \h  49 

B.2.b	Sample Design	  PAGEREF _Toc142817609 \h  50 

B.2.b.i	Sampling Frame	  PAGEREF _Toc142817610 \h  50 

B.2.b.ii	Sample Size	  PAGEREF _Toc142817611 \h  51 

B.2.b.iii	 Stratification Variables	  PAGEREF _Toc142817612 \h  54 

B.2.b.iv	Sampling Method	  PAGEREF _Toc142817613 \h  55 

B.2.b.v	Multi-Stage Sampling	  PAGEREF _Toc142817614 \h  56 

B.2.c	Precision Requirements	  PAGEREF _Toc142817615 \h  56 

B.2.c.i	Precision Targets	  PAGEREF _Toc142817616 \h  56 

B.2.c.ii	Nonsampling Error	  PAGEREF _Toc142817617 \h  57 

B.2.d	Data Collection Instrument Design	  PAGEREF _Toc142817618 \h  59 

B.3	PRE-TESTS AND PILOT TEST	  PAGEREF _Toc142817619 \h  61 

B.3.a	Pre-tests	  PAGEREF _Toc142817620 \h  61 

B.3.b	Pilot Test	  PAGEREF _Toc142817621 \h  61 

B.4	COLLECTION METHODS AND FOLLOW-UP	  PAGEREF _Toc142817622 \h  63 

B.4.a	Collection Method	  PAGEREF _Toc142817623 \h  63 

B.4.b	Survey Response and Follow-up	  PAGEREF _Toc142817624 \h  63 

B.5	ANALYZING AND REPORTING SURVEY RESULTS	  PAGEREF _Toc142817625 \h 
65 

B.5.a	Data Preparation	  PAGEREF _Toc142817626 \h  65 

B.5.b	Analysis	  PAGEREF _Toc142817627 \h  65 

B.5.c	Reporting Results	  PAGEREF _Toc142817628 \h  65 

Appendix A Public Notice Required Prior to ICR Submission to OMB	 
PAGEREF _Toc142817630 \h  67 

Appendix B Data Collection Instrument and Lists of Codes	  PAGEREF
_Toc142817632 \h  71 

Appendix C Comments and Response to Comments Received on the 1st Federal
Register Notice	  PAGEREF _Toc142817634 \h  91 

 

LIST OF TABLES tc "LIST OF TABLES" 

 TOC \f D 

  TOC \h \z \t "Exhibit" \c    HYPERLINK \l "_Toc143678799"  Exhibit
A-5-1 Collection Schedule	  PAGEREF _Toc143678799 \h  24  

  HYPERLINK \l "_Toc143678800"  Exhibit A-6-1 Estimated Unit Burden for
Systems Serving More Than 50,000 People	  PAGEREF _Toc143678800 \h  26  

  HYPERLINK \l "_Toc143678801"  Exhibit A-6-2 Estimated Unit Burden for
Systems Serving 3,301 – 50,000 People	  PAGEREF _Toc143678801 \h  28  

  HYPERLINK \l "_Toc143678802"  Exhibit A-6-3 Estimated Unit Burden for
Small CWSs	  PAGEREF _Toc143678802 \h  28  

  HYPERLINK \l "_Toc143678803"  Exhibit A-6-4 Overall State Burden
Summary	  PAGEREF _Toc143678803 \h  29  

  HYPERLINK \l "_Toc143678804"  Exhibit A-6-5 State Unit Burden for
Up-Front Activities	  PAGEREF _Toc143678804 \h  30  

  HYPERLINK \l "_Toc143678805"  Exhibit A-6-6 State Unit Burden for
Systems Serving More Than 50,000 People	  PAGEREF _Toc143678805 \h  31  

  HYPERLINK \l "_Toc143678806"  Exhibit A-6-7 State Unit Burden for
Systems Serving 3,301 – 50,000 People	  PAGEREF _Toc143678806 \h  33  

  HYPERLINK \l "_Toc143678807"  Exhibit A-6-8 State Unit Burden for
Small Systems	  PAGEREF _Toc143678807 \h  33  

  HYPERLINK \l "_Toc143678808"  Exhibit A-6-9 Total Burden and Cost to
Water Systems	  PAGEREF _Toc143678808 \h  34  

  HYPERLINK \l "_Toc143678809"  Exhibit A-6-10 Total Burden and Cost to
States	  PAGEREF _Toc143678809 \h  35  

  HYPERLINK \l "_Toc143678810"  Exhibit A-6-11 Burden/Cost to EPA
(Excluding Contractor Activities)	  PAGEREF _Toc143678810 \h  36  

  HYPERLINK \l "_Toc143678811"  Exhibit A-6-12 Burden/Cost of Contractor
Activities	  PAGEREF _Toc143678811 \h  37  

  HYPERLINK \l "_Toc143678812"  Exhibit A-6-13 Bottom Line Respondent
Burden	  PAGEREF _Toc143678812 \h  38  

  HYPERLINK \l "_Toc143678813"  Exhibit A-6-14 Burden Hours and Costs
for Respondents per Year	  PAGEREF _Toc143678813 \h  38  

  HYPERLINK \l "_Toc143678814"  Exhibit A-6-15 Bottom Line Burden Hours
and Costs for EPA (including its contractor)	  PAGEREF _Toc143678814 \h 
39  

  HYPERLINK \l "_Toc143678815"  Exhibit A-6-16 Disaggregated Burden by
Affected Information Collection (IC) Entities	  PAGEREF _Toc143678815 \h
 40  

  HYPERLINK \l "_Toc143678816"  Exhibit B-2-1 State Sample Sizes	 
PAGEREF _Toc143678816 \h  52  

 



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PART A OF THE SUPPORTING STATEMENT

A.1	IDENTIFICATION OF THE INFORMATION COLLECTION tc "A.1	IDENTIFICATION
OF THE INFORMATION COLLECTION" 

A.1.a	Title of the Information Collection Request tc "A.1.a	Title of the
Information Collection " \l 2 

The title of this information collection request (ICR) is Information
Collection Request for the 2007 Drinking Water Infrastructure Needs
Survey and Assessment (DWINSA). The Office of Management and Budget
(OMB) control number for this ICR is 2040-new; EPA ICR No. 2234.01.

A.1.b	Short Characterization  tc "A.1.b	Short Characterization " \l 2 

The Environmental Protection Agency (EPA) will conduct an assessment to
estimate the capital investment needs for drinking water systems
eligible to receive Drinking Water State Revolving Fund (DWSRF) monies.
The nationwide assessment will be conducted by the Drinking Water
Protection Division (DWPD) of EPA’s Office of Ground Water and
Drinking Water (OGWDW). The data collection is authorized by Sections
1452(h) and 1452(i)(4) of the Safe Drinking Water Act (SDWA) and will be
used to estimate the cost of providing safe drinking water to consumers
over a 20-year period. The data from the report will also be used to
allot DWSRF monies among states. The focus of the 2007 DWINSA is
collecting information on systems’ needs and on the projected costs
associated with those needs. All states have committed to help EPA
administer the 2007 DWINSA with at least the minimum of activities.
Thirteen states have chosen not to participate in the statistical
portion of the survey (i.e., collecting data from systems serving 3,301
– 100,000 people). For the states that opt out of the statistical
portion of the survey, the needs of the participating states will be
used to determine the needs for systems serving 3,301 – 100,000
people. All states with systems serving more than 100,000 people will
participate in census portion of the survey. 

For the 2007 DWINSA, EPA will conduct a census of all community water
systems (CWSs) serving populations more than 100,000 and select a random
sample of CWSs that serve populations of 3,301 – 100,000. EPA will
conduct a site visit for 600 randomly selected CWSs serving 3,300 and
fewer people and will estimate infrastructure needs for not-for-profit
noncommunity water systems (NPNCWSs)  in the states and all Alaska
Native and American Indian systems based on the 1999 DWINSA. 

EPA will send the data collection instrument to all CWSs serving more
than 100,000 people and a random sample of CWSs serving between 3,301
and 100,000 people (i.e., medium and large system sample). The data
collection instrument consists of project tables in which the water
systems list all their capital improvement projects through the year
2026. The same data collection instrument will be used for CWSs serving
a population of 3,300 and fewer (i.e., small system sample); however,
the data collection instrument will be completed by an EPA site visit
contractor. 

	

The effort will involve 3,193 respondents (3,137 CWSs and 56 states),
requiring 46,030 hours at a total cost to the respondents of $1,541,361.
Section A.6, Estimating the Burden and Cost of the Collection, provides
a detailed description of the unit burden and costs for this collection.
The average water system burden per response is 7.25 hours. The average
burden per response to complete the data collection instrument is
8.20 hours per response. (This burden is higher because the small
systems do not complete the data collection instrument.)

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

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

EPA (the Agency) is conducting this DWINSA pursuant to its authority
under Sections 1452(h) and 1452(i)(4) of the SDWA. Section 1452(h)
requires that “the Administrator shall conduct an assessment of water
system capital improvements needs of all eligible public water systems
in the United States and submit a report to the Congress containing the
results of such assessment within 180 days after the date of the
enactment of the SDWA Amendments of 1996 and every 4 years
thereafter.” 

A.2.b	Use and Users of the Information  tc "A.2.b	Use and Users of the
Information " \l 2 

The results of the 2007 DWINSA will be used as a basis for allocation of
DWSRF funds among states. In addition, many water systems have empirical
data on the cost of compliance with SDWA regulations. A national
assessment will improve the Agency’s ability to gauge the real capital
cost of SDWA regulations. 

EPA will collect two types of system-specific information: (1) system
inventory and characteristics data (i.e., name and address of the
system, contact person, population served, total design capacity, number
of connections, primary source, whether the system is privately or
publicly owned, and whether the system purchases/sells water from/to
another public water system (PWS)); and (2) information on capital
improvement projects. The specific uses of each data type vary. EPA will
use system inventory and characteristics data to characterize CWSs
nationwide, and, in some cases, to model individual systems’ capital
improvement projects. EPA will use all data collected to estimate state
and national needs.

On the data collection instrument, the respondent will identify needs on
a project-by-project basis and list the “type(s) of need” that the
project will meet. EPA will collect information on the proposed
infrastructure to be installed, replaced, rehabilitated, upgraded, or
expanded. EPA will use the information to assess project reasonableness
and develop the cost models.

The respondent will also identify either a documented cost estimate for
the project or will provide adequate information so that EPA can model
the cost of the project. The information needed to model the cost will
depend on the type of need. For example, EPA may collect information on
the type and number of valves or the diameter and length of transmission
or distribution lines. EPA expects that modeling will be required to
project the capital needs for small systems, many medium systems, and
some large systems. For the 2003 DWINSA, approximately 18 percent of the
projects reported had documented costs. The costs for the remaining 82
percent of projects were modeled. 

	

The data collected by the 2007 DWINSA will likely have several secondary
uses, both inside and outside of EPA. For example, EPA will use the
information to support various program activities, such as the
development of general enforcement strategies and new regulations.
Congress may use occurrence and cost information in considering new
drinking water legislation. States have indicated to EPA that they plan
to use the data collected to help identify projects that should be
included on the state’s DWSRF priority list and to implement capacity
development strategies. The public may use information on costs
associated with SDWA compliance.	



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

The following sections verify that this information collection satisfies
the OMB’s nonduplication and consultation guidelines, and does not
duplicate another collection.

A.3.a	Nonduplication  tc "A.3.a	Nonduplication " \l 2 

To the best of EPA’s knowledge, up-to-date state-by-state information
on water system’s capital needs is not available from any other
source. Some of the data collection efforts EPA considered include the
following:

Safe Drinking Water Information System (SDWIS). Inventory data and
information on system characteristics have been collected by states and
regions and entered into the SDWIS. For the statistical sample, EPA will
pre-print the SDWIS system characteristics data (i.e., name and address
of the system, contact person, address, population served, total design
capacity, number of connections, primary source, whether the system is
privately or publicly owned, and whether the system purchases/sells
water from/to another PWS) on the 2007 DWINSA form and ask the
respondents to provide information only if the SDWIS data are inaccurate
or missing. SDWIS does not contain information on water systems’
capital needs. 

Community Water System Survey (CWSS). EPA completed a statistical survey
in 2000 that focused on the operating and financial characteristics of
CWSs. The CWSS is addressed in the ICR for National Survey of the
Financial and Operating Characteristics of Community Water Suppliers.
The CWSS had a different objective than the DWINSA. The CWSS was
designed to characterize the technical and financial aspects of CWSs. In
contrast, the DWINSA will be used to develop national estimates of
capital needs. In addition, the CWSS’s targeted precision was on a
national basis; whereas the DWINSA will provide state-by-state
estimates. It is anticipated that EPA will conduct a new CWSS 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 are
different, the burden may be reduced if only one site visit is conducted
at a system to collect data for both the CWSS and DWINSA. 

Economic Analyses (EAs) for National Primary Drinking Water Regulations.
The Agency has developed EAs (formerly referred to as Regulatory Impact
Analyses) for its National Primary Drinking Water Regulations. These
documents estimate the costs of complying with proposed regulations. The
scope of the EAs is limited to the cost associated with the
implementation of a given proposed regulation. EAs do not include an
estimate for on-going capital projects to maintain compliance with
existing regulations. Therefore, the EAs are not an adequate substitute
for the DWINSA. In addition, the EAs provide nationwide estimates. As
discussed above, EPA is conducting the DWINSA because the Agency needs a
state-by-state estimate to develop the allocation formula for the DWSRF.
Also, many EAs are several years out of date. They do not consider
currently available contaminant occurrence data, or current or emerging
treatment technology costs. 

State Needs Surveys. Several states have conducted needs surveys of
their own drinking water systems. The state results cannot be
extrapolated to the nation as a whole because the state surveys do not
use consistent methodologies and do not account for national variations
in system characteristics and needs.

American Water Works Association (AWWA) Water Industry Data Base:
Utility Profiles. Like the CWSS, this AWWA survey and associated
database focuses on financial and operating characteristics of water
systems. Moreover, the AWWA database is not statistically
representative.

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 will
request information on drinking water treatment plants operating during
the 2005 calendar year. This survey will be 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 information specific to
drinking water treatment residuals. As discussed above, EPA is
conducting the DWINSA because it requires a state-by-state estimate to
develop the allocation formula for the DWSRF. The data in this survey
will not support that effort. 

1995, 1999, and 2003 DWINSAs. Under the SDWA, EPA must conduct the
DWINSA every 4 years. The approach for the 2007 DWINSA will incorporate
some data collected during the previous assessments, as well as
“lessons learned” from the earlier assessments. In addition, the
approach for the 2007 DWINSA ensures that up-to-date data on
infrastructure needs are collected for all CWSs. Small, medium, and
large CWSs regulated by the states reported approximately 94 percent of
the national need for the 2003 DWINSA. The remaining 6 percent were for
needs associated with American Indian and Alaska Native water systems,
NPNCWSs, and recently promulgated regulations (including the new Arsenic
Rule). 

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 2 

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) requesting comment on the estimated respondent
burden and other aspects of this ICR (71FR32344). This notice is
included in Appendix A. 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 C.
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 2 

For the 2007 DWINSA, EPA assembled a workgroup that consisted of EPA
headquarter, EPA regional, and state representatives. In October 2005
and April 2006, EPA held meetings with workgroup members. The purpose of
the meetings was to gather information on state and/or regional
concerns, to discuss lessons learned during the 2003 DWINSA, and to
discuss new policies for the 2007 DWINSA. The information gathered
during the meetings was used to develop the methodology for the 2007
DWINSA. EPA also convened an informal peer input group to involve
stakeholders such as trade associations. In addition, EPA conducted a
pre-test of the data collection instrument (see B.3 for more information
on the pre-test) and a formal peer review of the 2007 DWINSA statistical
methodology and policies. Based on comments received from the peer input
group, the peer review, and the pre-test, EPA made modifications to the
data collection instrument, statistical procedures, and survey polices. 

 

Specific changes EPA will make to the statistical methodology based on
the results of the peer review include:

The survey methodology required that at least one system be selected
from each stratum that contains at least one system. Based on the
suggestions of reviewers the sampling plan will be adjusted to also
ensure that at least two systems are selected from each stratum that
contains more than one system to allow for variance calculations by
strata and maintain the precision of the estimates.

Upon completion of the data collection, EPA will consider
recommendations for alternative approaches to determining the system
weights. 

EPA will also make changes to the survey policies based on the results
of the peer review. Two of the changes that EPA will make are:  

EPA will clarify and provide more guidance to state reviewers on what
type of documentation will be acceptable for the different types of
water system projects. 

In the survey instructions, EPA will add the definition of “need” as
defined for the 2007 DWINSA.

A.3.d	Effects of Less Frequent Collection  tc "A.3.d	Effects of less
Frequent Collection " \l 2 

The 2007 DWINSA is a single collection and does not involve periodic
reporting or recordkeeping.

A.3.e	General Guidelines  tc "A.3.e	General Guidelines " \l 2 

The 2007 DWINSA does not violate any guidelines for information
collection activities specified by OMB. Specifically, the 2007 DWINSA
respondents are not required to:

Report information to EPA more often than quarterly.

Retain records for more than 3 years.

Complete the data collection instrument in fewer than 30 days.

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

Submit proprietary, trade secret, or other confidential information.

Submit more than one original and two copies of any document.

The information collection:

Is a statistical assessment designed to produce data that can be
generalized to the universe of the study (see Section B.2).

Does not provide remuneration to participants.

Will transcribe information collected into an automated format.

Is designed with small entities particularly in mind (see Part A.5.c).

Does not concern grants or grantees.

Is voluntary.

A.3.f	Confidentiality Questions  tc "A.3.f	Confidentiality and Sensitive
Questions " \l 2 

This information collection does not require the respondent to disclose
any confidential information. Respondents are not obliged to respond to
this strictly voluntary information collection. Further, respondents
could eliminate any confidential business information from their reply. 

A.3.g	Sensitive Questions  tc "A.3.g	Sensitive Questions " \l 2 

The 2007 DWINSA does not ask sensitive questions, such as those
pertaining to sexual attitudes or behavior or religious beliefs.

A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED tc "A.4	THE
RESPONDENTS AND THE INFORMATION REQUESTED" 

A.4.a	Respondents/NAICS Codes  tc "A.4.a	Respondents/NAICS Codes " \l 2 

NAICS Codes

The respondents for the 2007 DWINSA are CWSs and states. According to
40 CFR Part 141.2, a CWS is a “public water system which serves at
least 15 service connections used by year-round residents or regularly
serve at least 25 year-round residents.” The North American Industry
Classification System (NAICS) code for PWSs is 221310. State agencies
that include drinking water programs are classified as NAICS code 924110
(Administration of Air and Water Resources and Solid Waste Management
Programs) or 926130 (Regulation and Administration of Communications,
Electric, Gas, and Other Utilities). Ancillary systems (i.e., those that
supplement the function of other establishments like factories, power
plants, mobile home parks, etc.) cannot be categorized in a single NAICS
code. For ancillary systems, the NAICS code is that of the primary
establishment or industry.

Respondents

EPA will gather information from large and medium CWSs, as well as a
limited number of small water systems. Because of their variability and
significant contribution to the overall drinking water capital
investment need, EPA will survey 999 systems that serve more than 50,000
people. Systems serving more than 100,000 will be sampled with certainty
(589 systems). EPA will select a statistically representative sample of
systems serving 50,001 – 100,000 (410 systems).

There are 8,109 systems that serve populations of 3,301 – 50,000.
Surveying all of these systems would impose a large burden on
respondents, EPA, and states. Therefore, EPA will select a statistically
representative sample of systems serving 3,301 – 50,000. This will
result in 1,538 systems receiving the mailed data collection instrument.
Part B of the supporting statement describes the sampling methodology.

There are 41,398 small systems. Surveying all of these systems would
impose a large burden on respondents, EPA, and states. Therefore, EPA
will select a statistically representative sample of 600 systems serving
3,300 and fewer people. The 2007 DWINSAs will be completed by EPA site
visitors. Part B of the supporting statement describes the sampling
methodology.

EPA will not collect new needs data from NPNCWSs, Alaska Native water
systems, or American Indian water systems. 

In addition, 56 states (50 states plus the District of Columbia, Puerto
Rico, Northern Mariana Islands, American Samoa, Guam, and the U.S.
Virgin Islands) will provide support and information for the 2007
DWINSA. 

A.4.b	Information Requested  tc "A.4.b	Information Requested " \l 2 

As previously discussed, EPA will collect two types of information from
systems: (1) system inventory and characteristics; and (2) information
on capital improvement projects. EPA anticipates that respondents will
provide varying levels of information by system size category. Based on
experience from the previous three DWINSA, EPA expects larger systems to
have a good understanding of their capital needs and the costs for
meeting them. Almost all of these systems will have detailed Capital
Improvement Plans (CIPs). Most large systems will be capable of
providing accurate information on cost. Most medium systems can provide
reliable data on their needs and some can provide cost estimates for
meeting their needs. The information that respondents will be asked to
provide is generally maintained and reported as a function of the
management and operation of the water system. 

A.4.b.i 	Data Items  tc "A.4.b.i 	Data Items " \l 3 

Medium and Large CWSs (Systems serving more than 3,300 people)

The data collection instrument asks respondents to verify or correct
system characteristic information (i.e., name and address of the system,
contact person, address, population served, total design capacity,
number of connections, primary source, whether the system is privately
or publicly owned, and whether the system purchases/sells water from/to
another PWS). It is Customary Business Practice (CBP) for the system to
maintain this information. The respondent will either indicate that the
information is correct as printed or enter the correct information in
the space provided. States will verify this information in advance of
the data collection instrument being sent to the systems. Based on
previous assessments, EPA anticipates that very few systems will need to
correct the information provided.

In addition, the respondent is asked to provide information on tables
associated with specific types of projects:

Source.

Treatment.

Finished or Treated Water Storage, Pumping, and Other.

Transmission and Distribution.

Backflow Prevention Devices/Assemblies, Flushing Hydrants, Service
Lines, Valves, and Water Meters.

For each of these projects, the respondent is asked to:

Briefly describe the needed capital projects (e.g., “routine
distribution system replacement,” “filtration plant upgrade,”
“high service pump replacement,” “corrosion control treatment,”
or “storage tank rehabilitation”). Information is collected on a
project-by-project basis because it is most commonly available to
respondents in that form, and because documentation, when available, is
usually developed on a project-by-project basis.

Provide the code that best describes the project from List 1 of the
Lists of Codes and that best describes the reason for the need from List
2. EPA will use this information to:

Develop separate cost estimates for source water treatment,
transmission, storage, distribution, and other needs. (EPA will
disaggregate the costs when projects meet multiple needs, if necessary.)


Help verify that adequate documentation of the need has been submitted.

Help determine if the project is an allowable need.

Help gauge cost-reasonableness.

Indicate if the project is to install new infrastructure to meet current
population demands, replace old infrastructure, expand or upgrade
existing infrastructure (such as treatment plants to meet current
population demands, or rehabilitate existing infrastructure). 

Indicate if the project is needed now to protect public health or not
needed now, but will be necessary to continue providing safe drinking
water over the next 20 years.

Indicate if the project is associated with a regulation, the codes for
which are listed on List 3 in the Lists of Codes. EPA will use this
information to determine which needs are required because of an SDWA
regulation or state requirement.

Provide design capacity when applicable—millions of gallons per day
(MGD) for treatment and pumping; or millions of gallons (MG) for
storage; the diameter and number of feet of distribution or transmission
lines that will be replaced or added; or the size and number of backflow
prevention devices/assemblies, flushing hydrants, service lines, valves,
and water meters. EPA will use these parameters to model project costs.

If available, provide the capital cost estimate and year and month (if
known) of the estimate. EPA will use this information to identify the
cost of the project. The year and month are important because they will
allow EPA to account for differences in the value of money over
different years and to convert all costs to a common year.

Provide inventory data on the total length of pipe in the water system.
This information will only be required for water systems that submit
pipe projects, but do not have independent documentation (i.e., planning
document, sanitary survey, or leak and break records). It is expected
that not all systems will need to provide this inventory information.
This information is necessary to allow EPA to determine that the need
reported is what is reasonably expected to be replaced or rehabilitated
in a 20-year timeframe. 

Indicate the type of documentation from List 4 of the Lists of Codes
that explains why the project is needed and, if a cost estimate is
available, indicate the documentation that explains the breakdown of the
cost. This will verify the cost for the project. NOTE: EPA does not
expect systems to develop cost estimates for the purposes of the 2007
DWINSA.

The respondent is also asked to provide his or her name, title, address,
phone number, and e-mail address. This information is requested in case
EPA or the state must contact the respondent for clarification or
explanation of any response.

The respondent is asked to attach documentation for all needs and costs
reported in the 2007 DWINSA. Systems are encouraged to provide inventory
data on their systems. Only where noted above will the inventory data be
required. 

The data collection instrument is attached as Appendix B.

Small CWSs (Systems serving 3,300 and fewer people)

As discussed above, EPA will collect data from small systems through
site visits. EPA will use the large and medium system data collection
instrument for the site visits. Contractor personnel will complete the
instrument during the site visit. EPA anticipates that most system
operators will make themselves available to accompany contractor
personnel. The operators may be asked very basic questions about the
physical design of the plant and configuration of their system. 

American Indian and Alaska Native Water Systems and NPNCWSs

EPA will base the needs of Alaska Native and American Indian water
systems and NPNCWSs on the 1999 DWINSA results. EPA conducted site
visits in 1999 to estimate the needs of these systems and EPA will
update these estimates for the 2007 DWINSA.

A.4.b.ii	Respondent Activities  tc "A.4.b.ii	Respondent Activities " \l
3 

Medium and Large CWSs (Systems serving more than 3,300 people)

To complete the data collection instrument, the following activities are
anticipated for medium and large CWSs:

Participate in an informational telephone call from the state.
Respondents will receive a call from the state describing the purpose of
the DWINSA, the information that will be requested, and the timetable
for completing and returning the data collection instrument.

Read the cover letter and data collection instructions. Respondents will
review the cover letter and instructions accompanying the data
collection instrument.

Collect and copy supporting documentation. Respondents will locate the
necessary supporting documentation in system files and copy it.

Complete the data collection instrument and inventory data. Respondents
will fill out the data collection instrument and attach supporting
documentation. Inventory data must be filled out for any pipe project
that is submitted without independent documentation of need (e.g., a
planning document). 

In addition, some systems may contact states (or an EPA-established
helpline) to obtain clarifying information on the data collection
instrument.

Small CWSs (Systems serving 3,300 and fewer people)

The 2007 DWINSA methodology has been designed to minimize the burden on
small CWSs. These systems’ role will be limited to answering basic
questions during a phone call and accompanying the 2007 DWINSA team
during the site visit. They will:

Participate in an informational/scheduling telephone call from EPA.
Respondents will receive a call from EPA to describe the purpose of the
DWINSA and to schedule the site visit.

Answer simple questions posed by the 2007 DWINSA team. Respondents will
be expected to answer very basic questions about the physical design of
the plant, system configuration, and capital needs.

State Activities

All states have committed to help EPA administer the 2007 DWINSA with at
least the minimum of activities. Region 3 (Philadelphia) will act as the
state for the District of Columbia. Region 8 (Denver) will act as the
state for Wyoming. Region 9 (San Francisco) will perform state
activities for the three Pacific Islands (Northern Mariana Islands,
American Samoa, and Guam). However, 13 states have chosen not to
participate in the statistical portion of the survey (i.e., collecting
data from systems serving 3,301 – 100,000 people). For
non-participating states, the needs of the participating states will be
used to determine an average need per strata. This will be applied to
the inventory of systems in non-participating states to estimate the
needs for systems serving 3,301 – 100,000 people. All states that have
systems serving more than 100,000 people will participate in the census
portion of the survey.

The activities described in this section represent a level of
participation that will ensure nationally consistent results. Some
states will participate at a higher level. 

State Up-Front Activities

This first activity category includes the states’ “fixed burden”
for helping EPA prepare for the 2007 DWINSA. 

Participate in training and other pre-mailout efforts. This activity
includes participating in training sessions offered to the states and
becoming familiar with the survey design and policies. In addition, it
includes activities such as reviewing the draft data collection
instrument.

Help EPA verify SDWIS data. There are several important variables for
which SDWIS data must be verified. Critical inventory data for the
statistical sample will need to be reviewed by states. Such data include
PWS identification number (PWSID), system name, address, telephone
numbers (if any), primary source, population served, number of service
connections, whether the facility is publicly or privately owned, and
whether the system is a consecutive system. In addition, states will
need to review address information to ensure the street address for each
system selected in the sample is accurate. To help states with this
verification activity, EPA will provide the information that must be
reviewed in electronic form.

Perform miscellaneous administrative activities. States will perform
various administrative duties prior to the 2007 DWINSA (e.g.,
establishing system files). In addition, state management will explain
the 2007 DWINSA to staff and allocate resources. 

State Data Collection Activities for Medium and Large CWSs (Systems
serving more than 3,300 people)

States will conduct the following activities for medium and large CWSs
during the data collection phase of the 2007 DWINSA:

Telephone systems to ensure participation. To improve response rates,
states that participate in the 2007 DWINSA will telephone the medium and
large systems early in the process to ensure that they have received the
survey package and understand how to complete the data collection
instrument.

Provide technical assistance. Participating states will provide
technical assistance to systems by answering their questions about the
data collection instrument and how needs should be represented.

Call systems that do not return the data collection instrument by a
certain date. To improve response rates, participating states will
telephone systems that have not returned their assessment by a specific
date to encourage participation.

Review completed data collection instruments and documentation. The data
collection instrument will be returned directly to the state. State
personnel will have the opportunity to review the information on the
data collection instrument, as well as any accompanying documentation. 

Discuss results with EPA. After the state reviews the submission and
documentation, the state forwards the data to EPA for review and data
entry. EPA performs a second quality control/quality assurance check to
ensure all data are documented and reasonable. Any differences of
opinion regarding the documentation of the data will be resolved by EPA
and the state. 

State Data Collection Activities for Small CWSs (Systems serving 3,300
and fewer people)

States will conduct the following activities for small CWSs during the
data collection phase of the 2007 DWINSA:

Brief contractor conducting site visits. Participating states will brief
site teams on water systems that they will visit. Some states may choose
to attend the site visit with the contractor.

A.5	INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY,
AND INFORMATION MANAGEMENT tc "A.5	INFORMATION COLLECTED\:  AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT" 

A.5.a	Agency Activities  tc "A.5.a	Agency and State Activities " \l 2 

A.5.a.i	EPA and Contractor Activities

Many of the EPA activities described here will be conducted by
contractors with EPA oversight/technical direction. For example, EPA
will oversee contractor development of the data collection methodology,
and collection and analysis of assessment data. For purposes of
describing Agency activities related to the 2007 DWINSA, contractor
effort is not distinguished from EPA effort. Separate estimates for
contractor burden and cost will be provided in Section A.6.c. In
addition, Section B.1.c describes the contractor’s role. 

Up-Front Activities

The following pre-assessment activities will be conducted:

Revise the data collection instrument/site visit protocol. EPA is
revising data collection instrument for the large and medium system
surveys, and a site visit protocol for the small CWSs, based on lessons
learned during the 1999 and 2003 DWINSAs. This task will include
developing cover letters and as well as other materials for state use.

Train state participants. To ensure that participating state officials
understand every aspect of the 2007 DWINSA, EPA will conduct regional
training sessions. The training will help ensure consistent responses
across the country, high response rates, and efficient use of state
staff. 

Select 2007 DWISNA respondents. The Agency will draw samples for the
2007 DWINSA.

Develop data system. EPA will update the data system, developed for the
2003 DWINSA, to store and analyze data. The system will produce the
necessary statistical reports for EPA, Congress, and states. The system
will also allow state offices access to the data.

Send data collection instruments. Data collection instruments will be
sent via FedEx to the selected systems. 

Develop an electronic data collection instrument. The Agency will
develop an electronic reporting form that systems serving more than
100,000 people can use to report their systems’ projects. It is
anticipated that this form will reduce the burden for systems completing
the form, states reviewing the form, and the Agency performing data
entry. 

Data Collection Activities

EPA will conduct the following activities during the data collection
phase of the 2007 DWINSA:

Provide technical assistance. The Agency will maintain a helpline
primarily to provide technical assistance to large and medium systems
(unless the state prefers to do so). The helpline will help ensure
consistent responses across the country.

Perform site visits. To ensure consistency, the site visits to small
CWSs will be conducted by an EPA contractor (accompanied by state or
regional personnel, if they wish to participate). As indicated above,
site visit teams will complete the large and medium system survey
instrument during the site visits.

Review returned data collection instruments. EPA will review the
completed data collection instruments to ensure that all data are
documented and reasonable.

Maintain the data. EPA will enter DWINSA data into the data system and
perform quality control/quality assurance checks of data entry.

A.5.b	Collection Methodology and Management  tc "A.5.b	Collection
Methodology and Management " \l 2 

This section discusses the steps that EPA has taken to ensure that the
information being collected will be accurate, reliable, and retrievable.
This methodology was developed using experience gained in conducting the
previous DWINSAs. EPA has incorporated into this methodology comments
and advice from EPA staff involved with those assessments. 

Development of Data Collection Instrument

Appendix B contains the data collection instrument. EPA has developed
the 2007 DWINSA approach and the data collection instrument with the
assistance of a workgroup. As is explained in Section A.3.c, the
committee includes EPA headquarter, EPA regional, and state
representatives. The 2007 DWINSA approach and data collection instrument
will be refined through testing with water systems and consultations
with outside groups. EPA’s basic approach and many of the refinements
to it were based on experience in conducting the 1995, 1999, and 2003
DWINSAs. In addition, EPA conducted a peer review of the 2007 DWINSA
policies and statistical approach. In developing the 2007 DWINSA, EPA
will select a set of appropriate assessment objectives that are easily
answerable by knowledgeable respondents. EPA’s pre-test of the data
collection instrument is described in Section B.3.a. Section B.2.c.ii
describes the steps taken to ensure that the data collection instrument
will be an effective tool for retrieving the information EPA needs to
meet the 2007 DWINSA objectives.

Methodology for Large and Medium CWSs (Systems serving more than 3,300
people)

Most systems serving more than 50,000 people have CIPs or similar
documents that summarize their needs. These systems, therefore, are
generally able to provide accurate information on their needs, and for
some needs, accurate estimates on the associated cost. A data collection
instrument will be sent to each of these systems. Clarifying information
for completing the data collection instrument will be available from the
state or EPA. Also, systems that participated in the 2003 DWINSA will be
able to obtain a copy of their 2003 DWINSA data from the state and
upload that data to the electronic form. After uploading the data, the
system can update the projects (i.e., change parameters, delete projects
that have been started, and add new projects identified since 2003). 

The experience of states that participated in the previous DWINSAs
indicates that systems serving 3,301 – 50,000 people can reliably
complete a data collection instrument, if technical support is
available. Most of these systems could provide reliable data on the
needs, and a large portion could provide cost estimates for meeting
those needs. The states will provide technical support to these systems
by answering their questions. EPA will provide classroom training to
states that may want to collect the needs for systems through site
visits. EPA will also offer a helpline for EPA regional, state, and
system personnel.

EPA will send the data collection instrument to the systems. Respondents
will send the completed data collection instruments to the state. The
state will review all data and provide a quality control/quality
assurance function. Next, the state will forward data to EPA for review
and data entry. EPA performs a second quality control/quality assurance
check to ensure that all data are documented and reasonable. EPA will
enter the data (for systems that did not use the electronic reporting
form). If the state chooses, it may verify that the data have been
entered into the data system. Projects or cost estimates that are not
documented will be identified in the data system as lacking
documentation. If the system or state does not provide documentation,
the project or cost estimate will be deleted from the 2007 DWINSA. 

Methodology for Small CWSs (Systems serving 3,300 and fewer people)

Based on state experience with past needs surveys, the 1995 and 1999
DWINSA, and other experience in dealing with small CWSs, EPA know it is
unlikely that small CWSs can reliably complete the data collection
instrument. Therefore, EPA will collect data from these systems through
site visits. To ensure consistency, the site visits will be conducted by
an EPA contractor accompanied by state or EPA regional personnel, if
they wish to participate. To help reduce costs, systems will be
clustered together by county or clusters of counties. Unlike previous
DWINSAs, the statistical pull for small systems will not require that
all states have at least one cluster of small systems. In addition, at
least 25 percent of the sample selected will be in counties with high
levels of arsenic to ensure the collection of information regarding
small system needs related to compliance with the new Arsenic Standard. 

Methodology for American Indian and Alaska Native Water Systems and
NPNCWSs

Estimates for the American Indian and Alaska Native water systems and
NPNCWSs will be based on needs reported in the 1999 DWINSA and updated
to 2007 dollars. 

Data Quality

It is crucial that the results of the DWINSA be as uniform as possible
across the country. Toward this end, EPA will take the following steps: 

EPA will establish a uniform set of assumptions or criteria for state,
EPA regions, EPA headquarters, and contractor staff to evaluate data
submitted by systems. 

EPA will provide training to all those involved in the DWINSA to ensure
that the assumptions and procedures are clear and understood. 

EPA will provide quality assurance reviews of each data collection
instrument submitted to ensure compliance with DWINSA polices and
accuracy of data. 

Among the most important steps in quality assurance is training. EPA
will provide training sessions for state and EPA regional officials
involved in the DWINSA. The regional training sessions will be designed
to enable state staff to review completed data collection instruments
and respond to questions from systems on the data collection instrument.
The training will emphasize the following elements:

Identifying the capital improvements associated with source,
transmission, storage, treatment, and distribution.

Estimating and reviewing construction cost estimates.

Completing the 2007 DWINSA data collection instrument. 

EPA will develop materials for distribution to state personnel who are
unable to attend regional training sessions. 

In addition to the training sessions, EPA will provide support for a
helpline for state and water system personnel. It is anticipated that
the helpline will be used primarily to provide information to the EPA
regions and states and that the states will provide technical support to
the systems. However, the helpline will be available to systems in
states that have chosen not to provide their own technical assistance.
Helpline staff will refer questions that raise a policy or technical
issue to EPA staff. 

Data quality will be assured by implementing the following mechanisms
throughout the gathering and processing phases of the information
collection:

Adequate documentation. EPA has requested documentation of needs and
costs, when available, to ensure the accuracy and reliability of the
data. Acceptable forms of documentation of needs and costs are listed on
List 4 of the Lists of Codes. EPA will not accept needs or costs without
adequate documentation. EPA will make it very clear to respondents that
they are not expected to develop cost estimates for the purposes of the
2007 DWINSA. The costs of projects without a cost estimate will be
modeled. 

Provide inventory data on the total length of pipe in the water system.
This information will only be required for water systems that submit
projects for rehabilitation or replacement of pipe that are not
independently documented (i.e., planning document, sanitary survey, or
leak and break records). It is expected that not all systems will need
to provide this information. This information is necessary to allow EPA
to determine that the need reported is reasonable for a 20-year
timeframe.

Receipt control. The primary objective of the receipt control system
will be to ensure that completed forms submitted by respondents (or
forwarded by states) are logged in promptly and given proper chain of
custody. A second objective is to provide states with the data needed to
monitor cumulative receipts by date to identify potential problems with
the response rate. Such response rate problems could necessitate action.
See Section B.2.c.ii for EPA’s method for improving the response rate.
States that receive data collection instruments from respondents will be
trained in receipt control.

Data review by states. EPA will rely on the states to help ensure data
quality. States that receive 1-percent of the DWSRF allocation formula
were given the option to “opt-out” of participating in certain
aspects of the DWISNA. Thirteen states have chosen not to participate in
the statistical portion of the survey (i.e., collecting data from
systems serving 3,301 – 100,000 people). However, all states that have
systems serving more than 100,000 people will participate in the census
portion of the survey. It is anticipated that the majority of states
will support EPA in this effort. EPA will ask the Association of State
Drinking Water Administrators (ASDWA) to communicate with the state
drinking water administrators to encourage their participation. Staff
from Region 9 will perform the state activities for systems in the three
Pacific Islands, staff from EPA Region 3 will act as the state for the
District of Columbia, and staff from EPA Region 8 will act as the state
for Wyoming. 

EPA believes that state participation is essential in ensuring
nationally consistent results because the states have more frequent
communications with systems and possess a better understanding of each
particular system’s needs. Therefore, state personnel will have the
opportunity to review the information on the form, as well as any
accompanying documentation. When necessary, the states will contact the
system to ask for clarifying information. In addition, EPA has improved
states’ ability to submit modifications through the Web site. 

Data entry. For data collection instruments submitted in hard copy form,
the EPA contractor will screen the completed data collection instruments
for legibility, completeness, and internal consistency, prior to entry
into the DWINSA database. Reviewers will also assign comment codes to
projects to describe any changes made to the data collection
instruments. Data from the data collection instruments will be keyed
into the database only after they have passed the initial screening. As
data are keyed, an automatic data entry program will provide reasonable
bounds checking and data verification. The program will signal the data
entry operator, if an entry is out of the allowable range or is an
invalid entry. For data collection instruments submitted electronically,
the EPA contractor will follow the same review procedures as those
submitted in hard copy. 

Data systems. EPA developed a web-based database system for the 2003
DWINSA that will be used for the 2007 DWINSA. The web-based system
includes a data entry interface that allows the Agency and its
contractors to input data and allows states to access, download, verify,
and suggest modifications to their data (www.DWNeeds.com). EPA will use
a commercial “off the shelf” program, Microsoft Access, to manage
the information. The data system will provide the following functions:

Data entry through the user interface or batch upload.

Data verification through bounds checking.

A password-protected data modification interface.

Data access for states for review and verification of their data.

Predefined summary and statistical reports.

Cost reasonableness ranges. EPA will develop “cost reasonableness
ranges” to help verify the accuracy of the data and identify projects
for further review.

Public Access to Data

The Agency’s policy is to make the fullest possible disclosure of
information without unjustifiable expense or unnecessary delay to the
requester. Once the final Report to Congress has been submitted, the
public will be given access to assessment data in accordance with
EPA’s policies and procedures for Freedom of Information Act (FOIA)
requests. However, as a matter of policy, EPA will neither disclose the
identity of any respondent to this questionnaire, nor the identity of
any participating water system. EPA will develop standard report formats
for providing data to the public. 

 

 tc " " \l 2 

A.5.c	Small Entity Flexibility  tc "A.5.c	Small Entity Flexibility " \l
2 

In designing the 2007 DWINSA methodology, EPA has taken small systems’
relatively limited technical capabilities and financial resources into
account. EPA’s experience with the previous DWINSAs has shown that
small systems lack the resources and technical ability to complete the
data collection instruments. Small CWSs regulated by the states will be
included in the 2007 DWINSA and assessed by site visitors. EPA will use
the 1999 DWINSA results as the primary basis for the 2007 DWINSA
estimates for NPNCWSs, and Alaska Native and American Indian water
systems. 

	EPA anticipates that many small and medium systems will not be able to
provide information on all needs and capital costs. For projects without
a documented cost, EPA will model a cost. 

A.5.d	Collection Schedule  tc "A.5.d	Collection Schedule " \l 2 

	The current schedule assumes EPA will receive OMB approval for data
collection by November 1, 2006. EPA will send data collection
instruments to drinking water systems on January 18, 2007. All systems
participating in the 2007 DWINSA will be asked to complete and return
the data collection instruments within 1 month of receipt.

	To facilitate efficient data entry at EPA headquarters, EPA will ask
the states to submit data for one-third of the systems within 3 months
after data collection begins, or by April 18, 2007. Data for two-thirds
of the systems will be due within 6 months (by July 18, 2007), and all
data will be due on October 18, 2007. Exhibit A-5-1 summarizes the major
collection milestones.

Exhibit A-5-1 Collection Schedule

Task	Date

Information Collection Request Submitted to OMB	August 2006

EPA Selects Systems to be Included in State Samples	August 2006

States Submit to EPA Contact Information to be Included on Return FedEx
Labels 	September 2006

Training Sessions for States and Regions	September - November 2006

Mail Out of Data Collection Instruments to Selected Systems	January 18,
2007

Deadline Given to Systems to Return the Data Collection Instrument to
States	February 18, 2007

1/3 of Sent Data Collection Instruments Returned by States to EPA	April
18, 2007

2/3 of Sent Data Collection Instruments Returned by States to EPA	July
18, 2007

All Sent Data Collection Instruments Returned by States to EPA	October
18, 2007

No New Projects Will Be Accepted by EPA 	October 18, 2007

No New Information on Submitted Projects Will Be Accepted by EPA
December 18, 2007

All Information in the Data System Finalized	February 18, 2008

Report to Congress Due	February 2, 2009

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

A.6.a	Respondent Burden  tc "A.6.a	Respondent Burden " \l 2 

A.6.a.i	Burden to Public Water Systems  tc "A.6.a.i	Burden to Public
Water Systems " \l 3 

The annual CWS burden for the 2007 DWINSA is estimated to be
approximately 5,689 hours (approximately a total of 22,757 hours).
Exhibit A-6-14 shows the breakdown of the annual burden hours for large,
medium, and small CWSs. The bases for the burden estimates are detailed
below.

	

Systems Serving More Than 50,000 People

The respondent burden for the systems serving more than 50,000 people
consists of systems’ burden for completing the data collection
instrument. EPA estimates that the total unit burden is 10.39 hours per
system. Exhibit A-6-1 summarizes the unit burden, broken down by
activity and labor category. 

Participate in informational phone call. Each informational call should
last about 15 minutes (0.25 hours). EPA anticipates that management
staff will take the call at half of the systems and technical staff will
take the call at the other half. Thus, the unit burdens are 0.125 hours
for management staff and 0.125 hours for technical staff.

Read cover letter/data collection instructions. EPA made the following
assumptions in estimating the burden for reviewing the cover letter and
data collection instructions: 

A manager will receive the 2007 DWINSA and read the cover letter. The
estimated time for managers to review the cover letter is 30 minutes
(0.50 hours). 

Technical staff will read the cover letter and data collection
instructions. EPA estimates that the burden for this activity is 1 hour
per system.

	Thus, the total unit burden is 1.5 hours per system [(0.50) + (1.0)].

Collect and copy supporting documentation. Time required to review
system files, and collect and copy supporting documentation will vary
greatly. EPA estimates that it will take 1.5 hours at 30 percent of the
systems, 2.5 hours at 30 percent of the systems, 4 hours at 30 percent
of the systems, and 16 hours at 10 percent of the systems. Thus, the
average time per system is as follows:

(1.5 x 0.30) + (2.5 x 0.30) + (4 x 0.30) + (16 x 0.10) = 4.0 hrs/system

Call for technical assistance. Many systems will call states for
technical assistance. In developing the burden estimate for this
activity, EPA made the following assumptions:

The number of requests for assistance will equal 100 percent of the
number of systems. (This estimate accounts for the fact that some
systems will call more than once, while some will not call at all.)

Each call will be placed by technical staff.

About 50 percent of the questions will be “straightforward” and
require a single phone call averaging 15 minutes (0.25 hours).

About 50 percent of the questions will require the state to perform
research and call the system back. In this case, EPA estimates that the
total burden for the two calls is 26 minutes (0.43 hours).

	Thus, the total unit burden is 20.5 minutes (0.34 hours) per system
[0.50(0.25) + 0.50(0.43)].

 

Complete data collection instrument. EPA estimates that technical staff
will take 3 hours to complete the data collection instrument. This
estimate is consistent with EPA’s experience with the previous
DWINSAs. Management is expected to take 18 minutes (0.30 hours) to
review the completed data collection instrument for accuracy. Clerical
staff is anticipated to take 1 hour to provide support to the technical
and managerial staff. Thus, the total unit burden is approximately 4.30
hours per system. 

Exhibit A-6-1 Estimated Unit Burden for Systems Serving More Than 50,000
People 

Activity	Estimated Burden (hours)

	Management	Technical	Clerical	Total

Participate in informational phone call	0.125	0.125

0.25

Read cover letter/data collection instructions	0.50	1.00

1.50

Collect and copy supporting documentation

2.00	2.00	4.00

Call for technical assistance

0.34

0.34

Complete data collection instrument	0.30	3.00	1.00	4.30

TOTAL	0.93	6.47	3.00	10.39



Systems Serving 3,301 – 50,000 People

Exhibit A-6-2 shows the unit burden for 1,538 systems serving 3,301 –
50,000 people. EPA estimates that each of these systems will take a
total of 6.78 hours to respond to the 2007 DWINSA.

Participate in informational phone call. Each informational call should
last about 15 minutes (0.25 hour). EPA anticipates that management staff
will take the call at half of the systems and technical staff will take
the call at the other half. Thus, the unit burdens are 0.125 hours for
management staff and 0.125 hour for technical staff.

Read cover letter/data collection instructions. EPA used the following
assumptions to estimate the burden for reviewing the cover letter and
data collection instructions:

A manager will receive the 2007 DWINSA and read the cover letter. The
estimated time for managers to review the cover letter is 30 minutes
(0.50 hours). 

Technical staff will read the cover letter and data collection
instructions. EPA estimates that the burden for this activity is 1 hour
per system.

Thus, the total unit burden is 1.5 hours per system [(0.50) + (1.0)].

Collect and copy supporting documentation. Systems serving 3,301 –
50,000 people typically have less documentation than larger CWSs.
However, the time required to review system files, and collect and copy
supporting documentation will vary greatly. EPA estimate that it will
take 1.0 hour at 50 percent of the systems, 2.0 hour at 25 percent of
the systems, and 4.0 hours at 25 percent of the systems. Thus, the
average time per system is as follows:

(1.0 x 0.5) + (2.0 x 0.25) + (4.0 x 0.25) = 2.0 hrs/system

Call for technical assistance. Many systems will call EPA or the
contractor for technical assistance. In developing the burden estimate
for this activity, EPA made the following assumptions:

The number of requests for assistance will equal 150 percent of the
number of systems. (This estimate accounts for the fact that some
systems will call more than once.)

Each call will be placed by technical staff.

About 50 percent of the questions will be “straightforward” and
require a single phone call averaging 15 minutes (0.25 hours) in
duration.

About 50 percent of the questions will require the state to perform
research and call the system back. In this case, EPA estimates that the
total burden for the two calls will be 30 minutes (0.50 hours).

Thus, the total unit burden is 34 minutes (0.56 hours) per system
[1.5(.50(0.25) +. 50(0.50))].

Complete data collection instrument. EPA estimates that technical staff
will take 2 hours to complete the data collection instrument. This
estimate is consistent with EPA experience with the previous DWINSAs.
Management is expected to take 28 minutes (0.47 hours) to review the
completed data collection instrument for accuracy. Thus, the total unit
burden is approximately 2.47 hours per system.

Exhibit A-6-2 Estimated Unit Burden for Systems Serving 3,301 – 50,000
People

Activity	Estimated Burden (hours)

	Management	Technical	Clerical	Total

Participate in informational phone call	0.125	0.125

0.25

Read cover letter/data collection instructions	0.50	1.00

1.50

Collect supporting documentation

1.00	1.00	2.00

Call for technical assistance

0.56

0.56

Complete data collection instrument	0.47	2.00

2.47

TOTAL	1.10	4.69	1.00	6.78



Small Systems (Systems serving 3,300 and fewer people)

EPA will conduct site visits at 600 small CWSs. Because EPA is
conducting site visits to these CWSs, the burden imposed on the systems
is small. EPA estimates that the unit burden to small CWSs averages 3.25
hours per system. Exhibit A-6-3 summarizes the burden for each activity.

Participate in informational/scheduling telephone call. The telephone
call to discuss and schedule the site visit should take approximately 15
minutes (0.25 hours). Most small CWSs are staffed by one technical
person; therefore, the entire burden falls with the technical labor
category.

Accompany survey team/answer questions. EPA does not expect that small
CWS personnel will accompany the survey team for the entire site visit;
however, EPA anticipates that system staff will make themselves
available to answer very basic questions about the system configuration.
EPA estimates that the burden to assist the survey team is 2 hours for
half of the small CWSs selected and 4 hours for the remaining 300
systems. Thus, the average burden per system is as follows:

[(2 x 0.5) + (4 x 0.5)] = 3.0 hrs /system

Exhibit A-6-3 Estimated Unit Burden for Small CWSs

Activity	Estimated Burden (hours)

	Management	Technical	Clerical	Total

Participate in informational phone call

0.25

0.25

Accompany data collection team/answer questions

3.00

3.00

TOTAL	0	3.25	0	3.25



	

A.6.a.ii	Burden to Primacy Agencies  tc "A.6.a.ii  Burden to Primacy
Agencies " \l 3 

Participating states will play an important role in conducting the
DWINSA—they will help EPA ensure that the 2007 DWINSA is administered
consistently nationwide. Most state activities will either involve using
and reviewing data directly or facilitating EPA’s use and review of
data. For example, states will review SDWIS inventory information for
the statistical sample and verify that it is correct. They will help
ensure a high response rate by telephoning systems serving more than
3,300 people before the 2007 DWINSA mailout and by making reminder calls
to the systems that have not returned their data collection instruments
by a specified date. States will help ensure data quality by answering
systems’ questions on the data collection instrument and by reviewing
completed data collection instruments and accompanying documentation for
completeness and accuracy. 

Given varying time and resource constraints, some states will wish to
participate in the 2007 DWINSA more fully than others. The burden and
cost estimates presented below represent a level of participation that
EPA believes will ensure nationally consistent results. EPA encourages
all states to participate at least at this level. The unit burden
estimates are consistent with what was found to be true in the 2003
DWINSA. 

The reader should note that the burden will vary widely by state, even
for the same set of activities. A state’s actual burden depends on the
number of drinking water systems in the state, the size and
sophistication of those systems, the extent to which the state goes
beyond the minimum requirements for the 2007 DWINSA, and other factors.
Exhibit A-6-4 summarizes the burden estimates for each of the activity
categories.

Exhibit A-6-4 Overall State Burden Summary

Activity Category	Estimated Burden

Up-Front Activities	110 hours, plus 0.2 hours/system

State Burden for Systems Serving More Than 50,000 People Assessment	6.58
hours per system

State Burden for Systems Serving 3,301 – 50,000 People Assessment	6.25
hours per system

State Burden for Small CWS Assessment	0.5 hours per system



Up-Front Burden

This activity category includes the state “fixed burden” for helping
EPA prepare for the 2007 DWINSA. The total burden for these activities
is 110 hours per state, plus 0.2 hour per system assessed. Exhibit A-6-5
summarizes this burden. 

Participate in training and other pre-mailout efforts. The burden for
this activity is estimated at 80 hours per state and is not expected to
depend on the number of systems in the state.

Help EPA verify SDWIS data. Based on state experience EPA estimates that
verifying SDWIS data for systems in the sample will require
approximately 12 minutes (0.2 hours) per system.

Perform miscellaneous administrative activities. The burden for these
activities should be 30 hours per state.

Exhibit A-6-5 State Unit Burden for Up-Front Activities

Activity	Estimated Burden

Participate in training and other pre-mailout activities	80 hours/state

Help EPA verify SDWIS data	0.2 hours/system

Perform miscellaneous administrative activities	30 hours/state

TOTAL	110 hours/state, plus 0.2 hours/system



State Burden for Systems Serving More Than 50,000 People 

This section estimates the state burden for helping EPA conduct the 2007
DWINSA in systems serving more than 50,000 people assessment by
providing technical assistance where needed, calling systems that do not
return the data collection instrument on time, reviewing the completed
data collection instrument and documentation, and discussing the results
with EPA. Although most of these systems will be able to answer the
questions on the data collection instrument, states will provide them
with clarifying information as necessary. The state burden for
activities associated with the systems serving more than 50,000 people
is summarized in Exhibit A-6-6, which follows the activity descriptions.

Telephone systems to ensure participation. EPA estimate that this
preliminary phone call will take about 15 minutes (0.25 hours) per
system.

Provide technical assistance. In developing a burden estimate for this
analysis, EPA made the following assumptions:

The number of requests for technical assistance will equal 100 percent
of the number of systems. (This estimate accounts for the fact that some
systems make such requests more than once.)

Of those that do require technical assistance, about 50 percent of their
questions will be “straightforward,” requiring only 15 minutes (0.25
hours) to answer.

About 25 percent of their questions will entail limited research and
follow-up, requiring 30 minutes (0.50 hours) to answer, including time
to call EPA with questions.

About 25 percent of their questions will require the state to perform
some research, and will require 1.0 hours to answer.

Therefore, the state burden for providing technical assistance is
estimated at about 30 minutes (0.50 hours) per request [0.5(0.25) +
0.25(0.50) + 0.25(1.0)]. This is an average. Some states may choose to
provide a much higher or lower level of technical assistance than
anticipated by EPA.

Call back systems that do not return the data collection instrument by a
certain date. EPA assumes that the number of these “reminder” calls
will equal 100 percent of the systems. This assumes that most (but not
all) will need at least one reminder call and some will need two or
three. The average time for these calls is 20 minutes (0.33 hours) per
system. This does not include answering technical questions, which is
accounted for above. Rather, it includes locating the correct contact
person and obtaining a brief report on the status of the 2007 DWINSA
response.

Review completed data collection instruments and documentation. The data
collection instrument will be returned directly to the state for review.
For some systems, this documentation is expected to be quite voluminous,
and reviewing it will be the most burdensome part of the 2007 DWINSA.
The time required for this review is difficult to estimate. States that
generate their own documentation for the 2007 DWINSA or add projects for
distribution or transmission projects are required to ensure that the
total pipe inventory section on the 2007 DWINSA is completed. Based on
discussions with the states concerning their level of effort in previous
assessments, EPA estimates that, on average, states will take 5.0 hours
to review each submission. This estimate includes the time required to
make follow-up phone calls and gather additional information as
necessary.

Discuss results with EPA. To estimate the state burden for resolving
questions on completed data collection instruments, EPA made the
following assumptions:

EPA will have questions on 50 percent of the completed data collection
instruments. Some of these questions will actually apply to all systems.


Each question will take the state 1 hour to resolve.

Therefore, the burden per system is 0.5 times 1 hour, or 0.5 hours per
system [0.50(1.0)].

Exhibit A-6-6 State Unit Burden for Systems Serving More Than 50,000
People 

Activity	Estimated Burden

(hours per system)

Call to ensure participation	0.25

Provide Technical Assistance	0.50

Call back systems that do not return the data collection instrument by a
certain date	0.33

Review completed assessment forms and documentation	5.00

Discuss results with EPA	0.50

TOTAL	6.58



State Burden for Systems Serving 3,301 – 50,000 People 

This section estimates the state burden for helping EPA conduct the
systems serving 3,301 – 50,000 people for the 2007 DWINSA by
telephoning systems to ensure participation, calling back systems that
did not return the data collection instrument on time, reviewing the
completed data collection instrument and the accompanying documentation,
and discussing the results with EPA. The state burden for activities
associated with the systems serving 3,301 – 50,000 people is
summarized in Exhibit A-6-7, which follows the activity descriptions.

Telephone systems to ensure participation. EPA estimates that this
preliminary phone call will take about 15 minutes (0.25 hours) per
system.

Provide technical assistance. In developing a burden estimate for this
analysis, EPA made the following assumptions:

The number of requests for technical assistance will equal 150 percent
of the number of systems. (This estimate accounts for the fact that some
systems make such requests more than once while some will not call at
all.)

Of those that do require technical assistance, about 50 percent of their
questions will be “straightforward,” requiring only 15 minutes (0.25
hours) to answer.

About 25 percent of their questions will entail limited research and
follow-up, requiring 30 minutes (0.50 hours) to answer, including time
to call EPA with questions.

About 25 percent of their questions will require the state to perform
some research, and will require 1.0 hours to answer.

Therefore, the state burden is estimated at about 45 minutes (0.75
hours) per request [1.5(0.5(0.25) + 0.25(0.50) + 0.25(1.0))]. This is an
average. Some states may choose to provide a much higher or lower level
of technical assistance than anticipated by EPA.

Call back systems that do not return the data collection instrument by a
certain date. It is assumed that the number of these “reminder”
calls will equal 100 percent of the systems. This assumes that most (but
not all) will need at least one reminder call and some will need two or
three. The average time for these calls is 30 minutes (0.50 hours) per
system. This does not include answering technical questions, which is
accounted for above. Rather, it includes locating the correct contact
person and obtaining a brief report on the status of the 2007 DWINSA
response.

Review completed data collection instruments and documentation. The data
collection instrument will be returned directly to the state for review.
For states, this is the most burdensome part of the 2007 DWINSA, and the
burden for this review is difficult to estimate. States that generate
their own documentation for the 2007 DWINSA or add projects for
distribution or transmission projects are required to ensure that the
total pipe inventory section on the 2007 DWINSA is completed. For this
ICR, EPA assumes that this activity takes states an average of 4.25
hours per system. 

Discuss results with EPA. To estimate the state burden for resolving
questions on completed data collection instruments, EPA made the
following assumptions:

EPA will have questions on 50 percent of the completed data collection
instruments. Some of these questions will actually apply to all systems.

Each question will take the state 1 hour to resolve.

Therefore, the burden per system is 0.5 times 1 hour, or 0.50 hours per
system. 

Exhibit A-6-7 State Unit Burden for Systems Serving 3,301 – 50,000
People 

Activity	Estimated Burden

(hours per system)

Telephone systems to ensure participation	0.25

Provide Technical Assistance	0.75

Call back systems that do not return the data collection instrument by a
certain date	0.50

Review completed data collection instruments and documentation	4.25

Discuss results with EPA	0.50

TOTAL	6.25



	

State Burden for Small CWSs (Systems serving 3,300 and fewer people)

This section estimates state burden for briefing the EPA contractor on
systems that will be visited. The state burden for small CWSs is
summarized in Exhibit A-6-8, which follows the activity descriptions.

Brief contractor conducting site visits. States should take about 30
minutes (0.50 hours) per system to brief the contractor on individual
systems. States may choose to accompany the site visitor on the site
visit, but it is not required. 

Exhibit A-6-8 State Unit Burden for Small Systems

Activity	Estimated Burden

(hours per system)

Brief contractor conducting site visits	0.50

TOTAL	0.50



	

A.6.b	Respondent Costs  tc "A.6.b	Respondent Costs " \l 2 

A.6.b.i	Costs to Public Water Systems  tc "A.6.b.i  Costs to Public
Water Systems " \l 3 

Exhibit A-6-9 summarizes the burden and costs to water systems. Total
costs are estimated at $701,206, which consists solely of labor costs.
There are no operation and maintenance (O&M) costs or capital costs
associated with the collection. 

PWS labor costs are based on the number of burden hours times an average
hourly wage rate, including overhead. The average hourly wage rate is
the rate taken from a 2003 EPA document entitled Labor Costs for
National Drinking Water Rules. The quoted rate was $26.05 in 2003
dollars for small systems and systems serving 3,301 – 50,000 people
and $31.26 in 2003 dollars for systems serving more than 50,000 people.
This rate has been inflated to 2005 dollars using the Employment Cost
Index. The inflated rate is $28.24 for small systems and systems serving
3,301 – 50,000 people and $33.88 for systems serving more than 50,000
people. 

Exhibit A-6-9 Total Burden and Cost to Water Systems

Respondent	Unit Burden (hours)	

Total

Responses	

Total Hours	

Hourly Rate	Total Cost

	Management	Technical	Clerical





Systems Serving More Than 50,000 People	0.93	6.47	3.00	999	10,380	$33.88
$351,661

Systems Serving 3,301 – 50,000 People 	1.10	4.69	1.00	1,538	10,428
$28.24	$294,477

Small CWSs	0.00	3.25	0.00	600	1,950	$28.24	$55,068

TOTAL	2.02	14.40	4.00	3,137	22,757

$701,206



Note:	The average burden per response is 7.25 hours (22,757/3,137). The
average burden for those systems 	completing a data collection
instrument is 8.20 hours [(10,380+10,428)/(999+1,538)].

	Numbers may not add due to rounding.

A.6.b.ii	Cost to States  tc "	A.6.b.ii	Cost to Primacy Agencies " \l 3 

Exhibit A-6-10 shows the annual costs to states. As discussed above, all
states have committed to help EPA administer the 2007 DWINSA with at
least the minimum of activities. Based on EPA’s projection that all
states will participate in the DWINSA, the cost to states is $840,155.
EPA will assess a total of 3,137 systems in the states. The labor costs
are based on an average full time equivalent (FTE) cost of $75,088
including overhead, which equates to approximately $36.10 per hour. This
rate, which has been inflated to year 2005 dollars, is based on the rate
($65,255) suggested by the workgroup that developed the State Workload
Model in 2001 and is consistent with the rates used in ICRs recently
developed by DWPD.

There are no O&M or capital costs for states under this ICR.

Exhibit A-6-10 Total Burden and Cost to States

Activity	Number of states/

Systems*	

Unit Burden	Total

Burden	Hourly Rate	Total Cost

Up-front	56	110 hours/state	6,160	$36.10	$222,376

	3,137	0.20 hours/system	627	$36.10	$22,635

State burden for systems serving more than 50,000 people assessment	999
6.58 hours/system	6,573	$36.10	$237,285

State burden for systems serving 3,301 – 50,000 people assessment
1,538	6.25 hours/system	9,613	$36.10	$347,029

State burden for small CWS assessment	600	0.50

hours/system	300	$36.10	$10,830

TOTAL	23,273

$840,155



A.6.c	Agency Burden and Cost  tc "A.6.c	Agency Burden and Cost " \l 2 

The Agency burden and cost reflects the burden and cost directly
incurred by EPA headquarters and EPA regions, summarized in Exhibit
A-6-11. EPA will also bear the cost of contractor activities. Exhibit
A-6-11 details the burden/cost of contractor activities. Both exhibits
distribute burden/costs among Fiscal Years 2006, 2007, 2008, and 2009,
reflecting that Agency and contractor activities will vary substantially
over the 4-year period.

EPA made the following assumptions in developing its estimate of Agency
and contractor burden and cost:

EPA Headquarters

Over the 4-year period, EPA Headquarters will expend a total of 2.8 FTEs
(e.g., an average of 0.7 FTEs per year over the 4 years). Assuming 2,080
hours per year, this equates to 5,824 hours.

The average salary and benefits (i.e., personnel compensation and
benefits [PC&B]) of the FTEs is at the GS 13, Step 5 level of $140,262.
Assuming 2,080 hours per year, this equates to $67.43 per hour.

  SEQ CHAPTER \h \r 1 EPA Regional Offices

Over the 4-year period, EPA Regions will expend a total of 1.4 FTEs
(i.e., an average of 0.35 FTE per year). Assuming 2,080 hours per year,
this equates to 2,912 hours.

The average salary and benefits (i.e., PC&B) of the 1.4 FTEs is at the
GS 11, Step 5 level of $99,862. Assuming 2,080 hours per year, this
equates to $48.01 per hour.

EPA Contractor(s)

Over the 4-year period, the EPA contractor(s) will expend a total of
49,780 hours of direct labor.

The EPA contractor(s) will provide this professional labor at a total
hourly rate, including all applicable indirect costs, of $68.00. 

Based on these assumptions, EPA estimates that the total burden/cost to
EPA of the DWINSA over the 4-year period is 58,516 hours and $3,917,558.
Exhibits A-6-11 and A-6-12 follow, providing greater detail.

Exhibit A-6-11 Burden/Cost to EPA (Excluding Contractor Activities)

Fiscal Year	EPA Headquarters	EPA Regions	Total

	Hours	Cost	Hours	Cost	Total Hours	Total Cost

FY 2006	892	$60,148	446	$21,412	1,338	$81,560

FY 2007	2,020	$136,209	1,010	$48,490	3,030	$184,699

FY 2008	2,020	$136,209	1,010	$48,490	3,030	$184,699

FY 2009	892	$60,148	446	$21,412	1,338	$81,560

TOTAL	5,824	$392,714	2,912	$139,804	8,736	$532,518



Exhibit A-6-12 Burden/Cost of Contractor Activities

Activities	FY 06	FY 07	FY 08	FY 09	Total

	Hours	Cost	Hours	Cost	Hours	Cost	Hours	Cost	Hours	Cost

Planning	2,000	$136,000	5,159	$350,812	3,200	$217,600	300	$20,400	 
=SUM(B3,D3,F3,H3) \# "#,##0"  10,659 	  =SUM(C3,E3,G3,I3) \#
"$#,##0;($#,##0)"  $724,812 

Assessment Design	200	$13,600	0	$0	0	$0	0	$0	  =SUM(B4,D4,F4,H4) \#
"#,##0"   200 	  =SUM(C4,E4,G4,I4) \# "$#,##0;($#,##0)"  $13,600 

Peer Review	280	$19,040	0	$0	0	$0	0	$0	  =SUM(B5,D5,F5,H5) \# "#,##0"  
280 	  =SUM(C5,E5,G5,I5) \# "$#,##0;($#,##0)"  $19,040 

Modeling	334	$22,712	982	$66,776	960	$65,280	960	$65,280	 
=SUM(B6,D6,F6,H6) \# "#,##0"  3,236 	  =SUM(C6,E6,G6,I6) \#
"$#,##0;($#,##0)"  $220,048 

Data Base Development	862	$58,616	1,000	$68,000	1,000	$68,000	1,000
$68,000	  =SUM(B7,D7,F7,H7) \# "#,##0"  3,862 	  =SUM(C7,E7,G7,I7) \#
"$#,##0;($#,##0)"  $262,616 

Assessment Production	0	$0	945	$64,260	0	$0	0	$0	  =SUM(B8,D8,F8,H8) \#
"#,##0"   945 	  =SUM(C8,E8,G8,I8) \# "$#,##0;($#,##0)"  $64,260 

Site Visits	0	$0	12,000	$816,000	0	$0	0	$0	  =SUM(B9,D9,F9,H9) \#
"#,##0"  12,000 	  =SUM(C9,E9,G9,I9) \# "$#,##0;($#,##0)"  $816,000 

Data Analysis	0	$0	9,629	$654,772	2,533	$172,244	0	$0	 
=SUM(B10,D10,F10,H10) \# "#,##0"  12,162 	  =SUM(C10,E10,G10,I10) \#
"$#,##0;($#,##0)"  $827,016 

Report Writing	0	$0	208	$14,144	1,459	$99,212	700	$47,600	 
=SUM(B11,D11,F11,H11) \# "#,##0"  2,367 	  =SUM(C11,E11,G11,I11) \#
"$#,##0;($#,##0)"  $160,956 

Statistical Analysis	0	$0	94	$6,392	656	$44,608	750	$51,000	 
=SUM(B12,D12,F12,H12) \# "#,##0"  1,500 	  =SUM(C12,E12,G12,I12) \#
"$#,##0;($#,##0)"  $102,000 

Tech Assistance	0	$0	960	$65,280	200	$13,600	200	$13,600	 
=SUM(B13,D13,F13,H13) \# "#,##0"  1,360 	  =SUM(C13,E13,G13,I13) \#
"$#,##0;($#,##0)"  $92,480 

Training	389	$26,452	820	$55,760	0	$0	0	$0	  =SUM(B14,D14,F14,H14) \#
"#,##0"  1,209 	  =SUM(C14,E14,G14,I14) \# "$#,##0;($#,##0)"  $82,212 

TOTAL	  =SUM(ABOVE)  4,065 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $276,420
	  =SUM(ABOVE)  31,797 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $2,162,196 	
 =SUM(ABOVE)  10,008 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $680,544 	 
=SUM(ABOVE)  3,910 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $265,880 	 
=SUM(ABOVE)  49,780 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $3,385,040 

A.6.d	Estimating Respondent Universe and Total Burden and Costs	  tc
"A.6.d	Estimating Respondent Universe and Total Burden and Costs	 " \l 2


		

Respondents for this ICR include CWSs and states. This ICR estimates
that the number of CWS respondents is 3,137. In addition to the CWS
respondents, this ICR assumes 56 states (50 states plus the District of
Columbia and U.S. Territories). Therefore, the total number of
respondents is 3,193. The total costs and burden for these respondents
are detailed in Exhibits A-6-9 and A-6-10.

A.6.e	Bottom Line Burden Hours and Costs  tc "A.6.e	Bottom Line Burden
Hours and Costs " \l 2 

Exhibit A-6-13 summarizes the bottom line burden hours and costs for
CWSs and states for this collection. The total burden for CWSs and
states is 46,030 hours at a cost of $1,541,361.

Exhibit A-6-13 Bottom Line Respondent Burden 

Respondent Type	Burden Hours	Total Cost

Community Water Systems	22,757	$701,206

States	23,273	$840,155

TOTAL	  =SUM(ABOVE) \# "#,##0"  46,030 	  =SUM(ABOVE) \#
"$#,##0;($#,##0)"  $1,541,361 



Exhibit A-6-14 summarizes the burden hours and costs for CWSs and states
per year. It is estimated that the CWSs will complete the data
collection instrument in 2007. It is estimated that states will incur
half of the burden associated with the 2007 DWINSA in 2007. The
remaining half is assumed to be incurred evenly in 2006 and 2008.

Exhibit A-6-14 Burden Hours and Costs for Respondents per Year

Respondent

Type	Total Hour Burden (per year)	Total Cost (per year)

	2006	2007	2008	2009	2006	2007	2008	2009

CWSs	0	22,757	0	0	$0	$701,206	$0	$0

States	5,818	11,637	5,818	0	$210,039	$420,077	$210,039	$0

TOTAL	  =B3+b4 \# "#,##0"  5,818 	  =c3+c4  34,394 	  =d3+d4  5,818 	 
=e3+e4  0 	  =f3+f4 \# "$#,##0"  $210,039 	  =g3+g4 \# "$#,##0" 
$1,121,283 	  =h3+h4 \# "$#,##0;($#,##0)"  $210,039 	  =i3+i4 \#
"$#,##0;($#,##0)"  $0 

Average per Respondent	1.82	10.77	1.82

$66	$351	$66

	

Exhibit A-6-15 summarizes the bottom line burden hours and costs for EPA
for this collection. The total burden for EPA (including its contractor)
is 58,516 hours at a cost of $3,917,558.

  SEQ CHAPTER \h \r 1 Exhibit A-6-15 Bottom Line Burden Hours and Costs
for EPA (including its contractor)

Respondent Type	Burden Hours	Total Costs

EPA	8,736	$532,518

Contractor	49,780	$3,385,040

TOTAL	  =SUM(ABOVE) \# "#,##0"  58,516 	  =SUM(ABOVE) \# "$#,##0" 
$3,917,558 



Exhibit A-6-16 shows the bottom line hour and dollar burden estimate by
the Information Collection (IC) Entities.  IC Entities covered by this
ICR include, publicly-owned CWSs, privately/investor owned CWSs, state
owned CWSs, and state government agencies. 

  SEQ CHAPTER \h \r 1 Exhibit A-6-16 Disaggregated Burden by Affected
Information Collection (IC) Entities



Total Number Of IC Entities	Burden Per Response	Total Hour Burden	Hourly
Rate	Total Cost	Cost Per Response

Water Systems Respondents 

Serving More than 50,000 People	Publicly Owned CWSs	837	10.39	9,008 	$  
  33.88 	$305,195 	$ 352

	Private/Investor Owned CWSs	123 

1,278 

$43,298 



State Owned CWSs	9 

94 

$3,168 



Subtotal	999 

10,380 

$351,661 

	Serving 3,301 to 50,000 People	Publicly Owned CWSs	1,368 	6.78	9,275 	$
    28.24 	$261,927 	$191

	Private/Investor Owned CWSs	145 

983 

$27,763 



State Owned CWSs	25 

170 

$4,787 



Subtotal	1,538 

10,428 

$294,477 

	Serving 3,300 and Fewer People	Publicly Owned CWSs	285 	3.25	926 	$    
28.24 	$26,157 	$92

	Private/Investor Owned CWSs	305 

991 

$27,993 



State Owned CWSs	10 

33 

$918 



Subtotal	600 

1,950 

$55,068 











State Government Respondents 	56 	415.59	23,273	$     36.10 	$840,155
$15,003

Total Water System Respondents

	Publicly Owned CWSs	2,520 	7.62	19,209

$593,280 	$235

	Private/Investor Owned CWSs	573 	5.68	3,252

$99,053 	$173

	State Owned CWSs	44 	6.72	296

$8,873 	$202

	Total CWSs Subtotal	3,137 	7.25	22,757

$701,206 	$224

Total Respondents	3,193 	14.42	46,030

$1,541,361 	$483



A.6.f	Reasons for Change in Burden  tc "A.6.f	Reasons for Change in
Burden " \l 2 

This ICR does not modify an existing ICR.

A.6.g	Burden Statement  tc "A.6.g	Burden Statement " \l 2 

The public reporting burden for collections included in this ICR is
detailed above. The total public reporting burden over the 4-year length
of the 2007 DWINSA is estimated to be 46,030 hours, of which 22,757
hours are attributable to CWSs and 23,273 hours to states. These
estimates include time for gathering information as well as developing
and maintaining records. Public reporting burden for this collection of
information is estimated to average 14.42 hours per response. Respondent
burden for completing the data collection instrument is 8.20 hours.

Burden means the total time, effort, or financial resources expended by
people to generate, maintain, retain, disclose, or provide information
to or for a Federal agency. This includes the time needed to review
instructions, adjust the existing ways to comply with any previously
applicable instructions and requirements, train personnel to respond to
the information collection request, 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 request for information collection 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 No.
EPA-HQ-OW-2006-0486 which is available for online viewing at
www.regulations.gov, or in person at the public viewing at the Water
Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301
Constitution Ave., NW, Washington, DC. The EPA Docket Center Public
Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday,
excluding legal holidays.  The telephone number for the Reading Room is
(202) 566-1744, and the telephone number for the Water Docket is (202)
566-2426.  An electronic version of the public docket is available 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. Also, you can send comments to the Office of Information
and Regulatory Affairs, Office of Management and Budget, 725 17th
Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. 
Please include the EPA Docket ID No. EPA-HQ-OW-2006-0486 in any
correspondence.



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PART B OF THE SUPPORTING STATEMENT (FOR STATISTICAL SURVEYS)

INTRODUCTION TO PART B

	The Environmental Protection Agency (EPA) proposes to conduct the
following type of statistical survey for the 2007 Drinking Water
Infrastructure Needs Survey and Assessment (DWINSA). EPA proposes a mail
assessment of community water systems (CWSs) serving populations of more
than 3,300. EPA will send site visitors to collect data from CWSs
serving 3,300 or fewer people. EPA is proposing the same methodology for
collecting data for CWSs serving more than 3,300 people, as was used in
the 2003 DWINSA. EPA is also proposing the same approach used in 1999 to
collect data from CWSs serving 3,300 or fewer people. 







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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 2 

The primary objective of the 2007 DWINSA is to collect information from
CWSs on the infrastructure they need to continue to provide safe
drinking water to consumers. These data are used to produce a national
estimate as well as state-specific estimates of water systems’ 20-year
need.  EPA has established policies to ensure that the overarching goals
of the survey are met. These polices are provided to the states and help
EPA:  

Estimate the total national 20-year need. 

Estimate the total 20-year need for each participating state. 

Provide complete and accurate data to Congress. 

Provide a tool to fairly distribute DWSRF capitalization funds to
states. 

Maintain the credibility of the DWINSA findings. 

EPA proposes to collect information on the cost of systems’
infrastructure needs; if cost data are not available from systems, EPA
proposes to collect information that will enable the Agency to model
costs. In the data collection instrument, the respondent will identify
needs on a project-by-project basis and list the “type(s) of need”
that the project will meet. The “types of need” includes raw water
source, transmission, source water treatment, storage, distribution,
pumping stations, and other needs.

EPA will use the information from the DWINSA to project capital
investment requirements of drinking water systems. The information will
be used to allot Drinking Water State Revolving Fund (DWSRF) monies
among states and as part of an allotment formula for the American Indian
and Alaska Native DWSRF set-aside program. 

EPA is proposing the same methodology as used in previous DWINSAs. Two
changes were made for the 2007 DWINSA from the approach used in 2003.
Data will be collected from systems serving 3,300 or fewer people. Data
was not collected from these systems in the 2003 DWINSA. Data will be
collected from a random sample of systems serving 50,001 – 100,000
people. These systems were selected with certainty in 2003. The sampling
design will be discussed in detail below. 

B.1.b	Key Variables  tc "B.1.b	Key Variables " \l 2 

Several key variables are available from the Safe Drinking Water
Information System (SDWIS). To ensure accuracy, the 2007 DWINSA will
verify these data by asking respondents to confirm existing information
(pre-printed on the data collection instrument), or correct it. These
variables include population served, total design capacity, number of
service connections, primary source of supply, ownership type (private
or public), and whether the system purchases water from, or sells water
to, another public water system (PWS). 

Information on capital needs will be collected from respondents on a
project-by-project basis. For each project, respondents will be asked to
provide the following types of information: type of need; documentation
of need and cost (if necessary); if the project is a new project or
rehabilitation of existing infrastructure; if the project is needed now
to protect public health or if it is needed over the next 20 years to
continue to provide safe drinking water; the federal regulation or state
requirement if the project is to meet a current regulation or state
requirement; design capacity of source, storage, and treatment projects;
cost of the project; and date of the cost estimate. For most of these
variables, respondents will choose the appropriate “documentation,”
“type,” or “regulation or requirement” from a lists of codes. 

The principal variable of interest is total projected capital needed for
each CWS in the 2007 DWINSA for the time period 2007 – 2026. The total
capital need for all systems in each state (to be derived from the
statistical sample of systems) is the key variable that decision-makers
at EPA use to allocate funds to states based on need.

The method of data collection has been designed to minimize burden on
respondents while ensuring that information is collected in a consistent
manner. Collecting information on a project-by-project basis, for
example, will be particularly helpful in reducing burden since most
respondents develop Capital Improvement Plans (CIPs) in this manner. 

Information on type of need will be used to disaggregate total capital
needs for EPA’s Report to Congress. Information on documentation of
need will be used to verify the public health benefit of the need.
Information on the date of the cost estimate will be used to provide a
consistent basis for cost estimates across systems. Information on a
regulation or requirement will be used to determine the reported project
costs related to Federal regulations or state requirements. 

If a system cannot provide cost estimates, additional data are necessary
so that the Agency can impute costs. Each of these variables will be
described in greater detail later in this document.

B.1.c	Statistical Approach  tc "B.1.c	Statistical Approach " \l 2 

The 2007 DWINSA is being designed to achieve a desired level of
precision for state-level estimates of total capital needs for medium
and large CWSs. It also is being designed to estimate the total capital
needs of small systems for the nation as a whole. EPA proposes a survey
of a statistical sample to estimate total capital needs for CWSs serving
populations of more than 3,300. This statistical approach minimizes
burden while achieving the desired level of precision. 

	

Medium and Large CWSs

The 2007 DWINSA design divides CWSs serving populations of more than
3,300 into two groups: large CWSs (serving populations of more than
50,000), and medium-sized systems (serving populations of 3,301 –
50,000). EPA proposes to sample with certainty systems serving more than
100,000 people. These systems have the largest capital needs, and they
have the staff to respond efficiently to the 2007 DWINSA. EPA proposes
to draw a random sample of medium systems (serving 3,301 – 100,000
people). This methodology can reduce burden and still achieve the DWINSA
data quality objectives. To meet the state-level precision targets, EPA
will first determine the total sample size for each state to meet the
target level of precision. EPA will then allocate the sample to strata
in order to maximize the efficiency of their design. 

	

Small CWSs

The objective of the 2007 DWINSA is to develop state-level estimates of
total capital needs for CWSs. For large and medium systems, as explained
above, this objective is achieved by selecting samples that are
allocated across various strata in the population to achieve an overall
precision level for each state. Several barriers prevent us from
developing state-level estimates for systems serving populations 3,300
and fewer:

First, a mail survey is not an effective approach to collection of data
from these small CWSs. State experience with mail surveys for small CWSs
suggests that total non-response and item non-response would be very
high with a mail survey. Also, states believe that the absence of
knowledgeable respondents at small CWSs limits the general reliability
of the responses. Therefore, the 2007 DWINSA workgroup recommended, and
EPA agrees, that the best way to gather information from small CWSs is
through site visits made by EPA contractors. This will minimize total
non-response, eliminate item non-response, and significantly improve the
reliability of data collected.

Second, if EPA assumes that all data collected from small CWSs will
require site visits, then the number of such visits is constrained by
the budget allocated for the 2007 DWINSA. EPA’s current budget
provides for approximately 600 site visits. Including small CWSs in the
state-level design proposed for the medium and large systems, however,
would require approximately 22,000 site visits. Thus, the statistical
design for medium and large systems cannot be applied to small CWSs.

Given this dilemma, the EPA workgroup committee recommended that EPA
adopt a different approach for small CWSs, one that focused on
national-level estimates. The direct sample estimates of total capital
needs at the national level will be used to infer the total capital
needs for small CWSs in each state. The workgroup preferred this
approach.

EPA is designing and conducting the 2007 DWINSA with the assistance of a
contractor:

Contractor

The Cadmus Group, Inc. 

57 Water Street

Watertown, MA 02472 

(617) 673-7000

	Contractor Roles

Technical oversight for all contractor activities

Oversight of data collection instrument design and testing.

Oversight of statistical sample design

Training

Mailings; logistics

Technical support for respondents and states

Model development

Data processing

Statistical sample design



B.1.d	Feasibility  tc "B.1.d	Feasibility " \l 2 

The 2007 DWINSA data collection instrument has been designed with the
capabilities of the typical respondent in mind. To fully assess
feasibility, the Agency undertook the following steps. First, EPA
convened a workgroup (see Section A.5.b) to comment on the proposed data
collection and its feasibility. Second, EPA met with individual CWS
operators and discussed the proposed survey. System operators were asked
to comment on all proposed data elements and the feasibility of
collecting information by a mail survey. The data collection instrument
was pre-tested, as described in Section B.3.a. 

The Agency recognizes that some medium CWSs (and a few large CWSs) may
not have cost data or documentation of costs for some projects. In those
cases, the 2007 DWINSA data collection instrument requests other
readily-available information that EPA can use to model costs. EPA will
make it very clear to respondents that they are not expected to develop
cost estimates for the purposes of the 2007 DWINSA. In addition, EPA (or
states) will provide large and medium CWSs with a helpline to assist
them complete the data collection instrument.

Unlike the medium and large systems, the DWINSA will not be
self-administered by small CWSs; rather, EPA contractors, accompanied by
state personnel if state personnel participate in this portion of the
2007 DWINSA, will visit the small CWSs. Prior to the visit, the
contractors will have access to all state records on the system (e.g.,
the results of recent sanitary surveys and inspections). The contractors
will spend approximately 3 hours with the system owner or operator,
requesting information that will be helpful in estimating system
infrastructure needs. The contractor will then conduct a physical
inspection of the system to confirm information provided by the owner or
operator.

The EPA contractor will focus attention on the capital needs associated
with treatment of source water, transmission, storage, and distribution.
Capital needs associated with treatment will be modeled using methods
similar to those currently used by EPA in the development of economic
analyses. (In these analyses, data on occurrence of contaminants and
cost estimates for treatment of source water to remove contaminants
yield the cost of compliance with regulations that require the removal
of contaminants from finished water.)

Reliance on site visits to small CWSs was strongly recommended by the
EPA workgroup to avoid problems that have faced every state survey of
small CWS infrastructure needs:

Total non-response. Since many systems have not clearly identified
responsible parties, and since responsible parties often are unwilling
to respond to data collection instruments, it is difficult to use a mail
survey to obtain the necessary information. Working with participating
state regulatory agencies and representatives of small CWSs should
minimize non-response problems.

Item non-response. System owners and operators often are not
knowledgeable about the capital needs of their systems. Unlike larger
systems, who may maintain CIPs, small CWSs lack information to answer
questions. Since 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 mobile home park
owners, volunteers from homeowners associations, and others who are not
water supply professionals. State drinking water administrators clearly
prefer the judgments of EPA contractor engineers, accompanied by their
own staff, for reliable information on capital needs.

Finally, employing site visits will substantially reduce the burden on
small CWSs. Total burden on the systems, on average, will be about 1
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 2007 DWINSA.

Sufficient contract funds have been identified to complete the 2007
DWINSA. 

The time frame for the 2007 DWINSA is acceptable to the users of data
within the Office of Ground Water and Drinking Water (OGWDW) and
sufficient to complete a report to Congress by its anticipated due date
of early 2009. The schedule also is acceptable to other users of the
data. 	

B.2	SURVEY DESIGN

This section contains a detailed description of the statistical survey
design including a description of the sampling frame, sample
identification, precision requirements, data collection instrument,
pre-test, collection methods, and follow-up procedures.

Medium and Large CWSs

The sample design for the DWINSA is stratified random sampling within
each state. Stratification increases the precision of estimates compared
with a simple random sample of the target population of systems. In
stratified samples, the target population is divided into
non-overlapping groups, known as strata, from which separate samples are
drawn. The goal of stratified sampling is to choose sample sizes within
each stratum in a manner designed to obtain maximum precision in the
overall estimate for the population. Stratification variables for this
study include: population size (populations of: 3,301 – 10,000; 10,001
– 25,000; 25,001 – 50,000; 50,001 – 100,000; and populations of
more than 100,000), and primary source of supply (surface and ground).
Systems serving more than 100,000 people are selected with certainty.
The size of each state’s sample of systems serving populations of
3,301 – 100,000 is set to meet the DWINSA’s data quality objectives.


EPA’s precision target is to be 95 percent confident that the true
need lies within an interval, the upper and lower bounds of which do not
exceed 10 percent of the sample mean (or estimated need). Once the total
size of the sample of systems serving more than 3,300 people has been
determined for each state, the number of samples to be taken in each
stratum within each state will be allocated in a manner that minimizes
the variance of the estimated total capital costs. EPA will use a Neyman
allocation to determine the number of systems to select from each
stratum. The Neyman allocation is described in detail in Section
B.2.b.ii.

Small CWSs

The 2007 DWINSA design for small CWSs, like that for medium and large
systems, is stratified random sampling. The stratification variables for
small CWSs are the same as those for other systems: size of population
served and primary source of supply.

Unlike the medium and large systems, the design for small CWSs is driven
by a significant budgetary constraints: EPA cannot afford to complete
more than approximately 600 site visits. EPA’s objective in sampling
is to achieve the maximum level of precision on a national basis without
exceeding that budgetary constraint. Precision targets will be discussed
in Section B.2.c, below.

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

The target population is CWSs in the nation. A CWS is a PWS 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). The
DWINSA is being designed to produce estimates of the capital need of
medium and large systems for each state. It is being designed to produce
estimates of the capital need of small systems for the nation as a
whole. 

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

This section describes the sample design. It includes a description of
the sampling frame, target sample size, stratification variables, and
sampling method. The sampling design employed is a stratified random
sample of CWSs. The strata employed in the design are discussed in
Section B.2.b.iii. Neyman allocation is used to efficiently allocate the
sample of water systems among the strata.

B.2.b.i	Sampling Frame  tc "B.2.b.i	Sampling Frame " \l 3 

	

The sampling frame is developed from SDWIS. SDWIS is a centralized
database for information on PWSs, including their compliance with
monitoring requirements, maximum contaminant levels (MCLs), and other
requirements of the Safe Drinking Water Act (SDWA) Amendments of 1996.
The following information will be extracted from SDWIS for the
statistical survey and verified by participating states:

	

Name of system

Contact person

Address of system

Population served

Total design capacity

Number of connections 

Primary source (surface water or ground water)

PWS identification number (PWSID)

Ownership type 

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

From these data, EPA will develop the frame from which EPA will (1)
calculate summary statistics (e.g., number of systems per state in
pre-defined strata) for use in calculating sample size, and (2) randomly
choose systems within the design strata to take part in the 2007 DWINSA.

Justification for the Use of SDWIS

The following criteria are often used in assessing a proposed sampling
frame:

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.

The units of observation for this medium and large system survey are
CWSs, a subset of PWSs. SDWIS is the ideal choice for a sample frame
because of its inclusive coverage of all units of observation for the
2007 DWINSA. 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.

In previous surveys where SDWIS was used as a sample frame, there have
been criticisms of its utility. 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 the 2007 DWINSA are rare. The audits show
that systems are misclassified by population or source in less than 1
percent of all cases. 

To mitigate any potential problems with the sample frame, the 2007
DWINSA design anticipates substantial state involvement in the 2007
DWINSA process. Participating states, for example, will be checking the
sample frame of systems that will be used to determine the final sample.
In EPA’s experience, states often have in-house data systems with very
accurate data, particularly on medium- and large-sized CWSs. Even if
these data are not transmitted to SDWIS, they are available to states
and can be used by states to check the sample frame. 

B.2.b.ii	Sample Size  tc "B.2.b.ii	Sample Size " \l 3 

Medium and Large CWSs

Exhibit B-2-1 at the end of this subsection shows the preliminary sample
sizes for the 2007 DWINSA. As shown on this exhibit, the sampling design
will be implemented to achieve state-level precision targets for medium
and large CWSs. Precision targets are discussed in Section B.2.c. 

The task of determining the sample size for each stratum requires two
steps. The first step determines the sample size for each state that
achieves the precision targets for that state. The second step allocates
the sample across the relevant strata in the state. The strata are
described in section B.2.b.iii. 

The first step in determining the sample size is calculating the total
number of samples required at the state level to meet the precision
requirements. The sample size is given by:

 

Where:	n0g	=	the sample size (prior to the finite population correction)

	Ngh	=	the total number of systems in the hth stratum in the gth state
(taken from SDWIS)

	sgh	=	the standard deviation of the variable of interest for the hth
stratum in the gth state (estimated using data from the 2003 DWINSA) 

	H	=	the number of strata defined in the sample design for the gth state


	Vg	=	the desired sampling variance for the total medium and large
system capital needs estimate for state g.

 . d is the half-width of the desired confidence interval (0.10 for the
Assessment). Zα is the value of a standard normal distribution for a
confidence level of 1- α, (1.96 for the Assessment). 

	

Because the number of water systems is known and finite, the following
population correction is applied:

 

The second step allocates the total sample to each of the strata EPA
will randomly draw this number of samples from each of these strata. The
Neyman allocation formula is used for the allocation:

 

(Because systems serving populations more than 100,000 are to be sampled
with certainty, H is reduced by the number of large-system strata in the
sample design for the large and medium systems.)

In order to implement these sample size and sample allocation equations,
EPA needs estimates for Vg, Ngh, sgh, and mean total capital needs by
stratum. Information on mean total capital needs by stratum and sgh were
estimated using data from the 2003 DWINSA.

Exhibit B-2-1 State Sample Sizes

State	Total Number Of Medium And Large Systems	Estimated Sample Size For
Medium And Large Systems

Alaska	                                           21 	                  
                        16 

Alabama	                                         354 	                  
                      137 

Arkansas	                                         174 	                 
                         82 

American Samoa	                                             1 	         
                                   1 

Arizona	                                         127 	                  
                        28 

California	                                         676 	               
                         194 

Colorado	                                         159 	                 
                         39 

Connecticut	                                           60 	             
                             46 

District of Columbia	                                             1 	   
                                         1 

Delaware *	                                           26 	              
                              3 

Florida	                                         382 	                  
                      108 

Georgia	                                         224 	                  
                        57 

Guam	                                             3 	                   
                         3 

Hawaii *	                                           30 	                
                            2 

Iowa	                                         135 	                     
                     40 

Idaho *	                                           45 	                 
                           1 

Illinois	                                         462 	                 
                         83 

Indiana	                                         213 	                  
                      100 

Kansas	                                         120 	                   
                       41 

Kentucky	                                         266 	                 
                       102 

Louisiana	                                         224 	                
                          87 

Massachusetts	                                         247 	            
                              57 

Maryland	                                           55 	                
                          20 

Maine *	                                           35 	                 
                           1 

Michigan	                                         306 	                 
                         55 

Minnesota	                                         160 	                
                          56 

Missouri	                                         207 	                 
                         82 

Northern Mariana Islands	                                             2 
                                             2 

Mississippi	                                         197 	              
                          148 

Montana *	                                           34 	               
                             1 

North Carolina	                                         272 	           
                               47 

North Dakota **	                                           31 	         
                                  -   

Nebraska	                                           44 	                
                          21 

New Hampshire *	                                           37 	         
                                   2 

New Jersey	                                         227 	               
                           57 

New Mexico *	                                           60 	            
                                1 

Nevada	                                           35 	                  
                        11 

New York	                                         355 	                 
                         56 

Ohio	                                         314 	                     
                     79 

Oklahoma	                                         160 	                 
                         53 

Oregon	                                         109 	                   
                       43 

Pennsylvania	                                         341 	             
                             75 

Puerto Rico	                                         122 	              
                            56 

Rhode Island *	                                           28 	          
                                  2 

South Carolina	                                         167 	           
                               46 

South Dakota *	                                           42 	          
                                  1 

Tennessee	                                         282 	                
                        114 

Texas	                                         968 	                    
                    109 

Utah *	                                         105 	                   
                         7 

Virginia	                                         164 	                 
                         45 

Virgin Islands	                                             3 	         
                                   3 

Vermont	                                           34 	                 
                         12 

Washington	                                         199 	               
                           50 

Wisconsin	                                         177 	                
                          51 

West Virginia *	                                         110 	          
                                  3 

Wyoming **	                                           27 	              
                             -   

Total	                                       9,359 	                    
                  2,537 

*Eleven states have chosen not to participate in the statistical portion
of the survey (i.e., collecting data from systems serving 3,301 –
100,000 people). They will however participate in the census portion of
the survey (i.e., collecting date from systems serving more than 100,000
people). The number in the “Estimated Sample Size for Medium and Large
Systems” represents the total number of systems in the state that
serve more than 100,000 people.

** Two states have chosen not to participate in the statistical portion
of the survey (i.e., collecting data from systems serving 3,301 –
100,000 people). In addition, these states do not have any systems that
serve more than 100,000 people.

 

Small CWSs

The total small system sample is set at 600 by available resources. EPA
will allocate the sample among six strata to produce the most efficient
estimate of small sample need, given this sample size. Section B.2.b.iii
discusses the how the sample will be stratified. The sample for systems
serving 3,300 or fewer people is allocated among source water and
population-served strata using a Neyman allocation. Within each ground
water stratum, the sample is divided proportionately between systems in
states with and without a substantial occurrence of arsenic. This method
was chosen because the data on the variance in system need by arsenic
occurrence are not available. 

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

The objective of stratification is to increase the efficiency of the
sampling design (thereby reducing the number of samples required at any
level of precision) by the creation of independent strata. Stratified
sampling may produce a gain in precision in the estimates of the
characteristics of the target population as compared to simple random
sampling. In stratified sampling, the target population (i.e., CWSs) is
divided into non-overlapping strata that are internally homogeneous, in
that the measurements vary little from one unit to another (i.e., the
within strata variance is minimized). If the within-stratum variance is
relatively small, then a precise estimate of the variable of interest
can be obtained with a relatively small number of samples. Each of the
strata estimates can be combined to obtain a precise estimate for the
target population. If the strata are constructed correctly, the target
population estimate can be achieved with greater precision and with
fewer samples than the estimate obtained from simple random sampling.

EPA’s drinking water programs have historically evaluated CWSs based
on (1) size (number of persons served), and (2) primary source (ground
water and surface water). Using total capital need information obtained
from the 2003 DWINSA, EPA evaluated several classification schemes. This
analysis showed that the stratification scheme selected for the 2007
DWINSA medium and large system sample (10 strata based on size and
source) was reasonable. Some states may have a different number of
strata; this accommodated using their data as it is currently organized.
Varying strata will be permitted only when the 2007 DWINSA’s overall
precision is not reduced. The proposed strata for medium and large
systems are as follows: 

Size of Population Served	Source	Sample Methodologies

3,301 – 10,000	Ground	Random sample. 

3,301 – 10,000	Surface

	10,001 – 25,000	Ground	Random sample. In some states the number of
strata will be reduced based on analysis of optimal stratum boundaries.
Specifically, in some states systems serving between 10,001 and 50,000
will be in one group rather than two. 

10,001 – 25,000	Surface

	25,001 – 50,000	Ground

	25,001 – 50,000	Surface

	50,001 – 100,000	Ground	Random sample

50,001 – 100,000	Surface

	More than 100,000	Ground	Sampled with certainty

More than 100,000	Surface

			

EPA’s sample design for small CWSs is also stratified based on the
size of the population served and the source water of the system. In
addition to source and population served, at least 25 percent of the
counties selected will be in counties with high levels of arsenic. This
is to ensure the collection of data regarding necessary infrastructure
needs for systems serving 3,300 or fewer people affected by the Arsenic
Rule. In 2003, infrastructure costs related to the arsenic regulation
were determined using the Economic Analysis for the final rule. The
workgroup decided this information was outdated and new estimates are
necessary. 

The proposed strata are as follows:

Water Source	Population Served

Surface Water Systems 	25 – 1,000

	1.001 – 3,300

Ground Water Systems	25 – 1,000

	1.001 – 3,300



	

B.2.b.iv	Sampling Method  tc "B.2.b.iv     	Sampling Method " \l 3 

As indicated above, all CWSs serving populations of more than 100,000
will be sampled with certainty. 

For systems serving 3,301 – 100,000 persons, all CWSs will be
allocated to 10 strata, based on population served and primary source.
The sample size for each stratum in each state will be determined by the
sampling strategy outlined above. The sampling method will be an equal
probability random sample within each stratum. Anticipating a level of
non-response, EPA will over-sample to achieve the desired number of
completed data collection instruments. Since the expected response rate
for systems serving 3,301 – 100,000 persons is 90 percent, EPA will
draw a sample of 2,857. 

All CWSs serving populations of 3,300 or fewer will be allocated to six
strata, based on population served, primary source, and arsenic
occurrence. The sample size for each stratum will be determined by the
sampling strategy outlined above. The sampling method will be a
two-stage probability proportional to size random sample within each
stratum. Past response rates for these systems exceeded 90 percent. EPA
will over sample to account for non-response, and will draw a sample of
600. 

	

B.2.b.v	Multi-Stage Sampling  tc "B.2.b.v		Multi-Stage Sampling " \l 3 

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 2 

B.2.c.i	Precision Targets  tc "B.2.c.i		Precision Targets " \l 3 

The sampling design for large and medium systems will be implemented at
the state level. EPA’s goal is to be 95 percent confident that the
margin of error, when estimating the total capital needs facing these
systems in each state, will be plus or minus 10 percent of the total
need for these systems. For example, if the total need for these systems
in a state is estimated to be $2 billion, EPA will be 95 percent
confident that the actual total need is between $1.8 billion and $2.2
billion.

The size of the small system sample is driven by budget constraints, not
precision targets. EPA estimates that the sample size of 600 will allow
it to estimate the national capital need of these systems with a 95
percent confidence interval equal to plus or minus 15 percent of the
national small systems need. This precision level will be less than the
level for estimates developed for medium and large systems, but it will
not materially reduce the overall precision for total cost estimates at
the state level. Small CWS costs are a small portion of total system
costs in each state. Thus, the lack of precision for these systems will
not significantly reduce the overall precision of the state-level
estimates.

B.2.c.ii	Nonsampling Error  tc ".2.c.ii		Nonsampling Error " \l 3 

EPA has developed an assessment approach that will employ 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 contractor (The
Cadmus Group, Inc.) in formulating a strategy to reduce non-sampling
error.

	

Particular emphasis will be placed on maximizing response rates.
Standard methods that have proved effective in other surveys of CWSs
will be used, including the following:

States will review the sample of systems to receive the mail data
collection instrument and will ensure that the best person to receive
the data collection instrument is determined in advance.

EPA and the states will coordinate in the production of a cover letter
for the 2007 DWINSA. EPA’s opinion (shared by state drinking water
administrators, trade associations, and PWSs) is that surveys on state
letterhead will be better received than letters on EPA letterhead.
Therefore, states can use state-level cover letters signed by a senior
state official instead of the EPA letter.

The data collection instrument design, content, and format have been
reviewed by organizations representing CWSs. In addition, the data
collection instrument design, content, and format were reviewed by
states that participated in the 1995, 1999, and 2003 DWINSAs. 

The data collection instrument design, content, and format will be
pre-tested to ensure that all questions are properly stated and can be
answered by all systems in the mail survey.

Items being asked are those that owners or operators of systems serving
populations greater than 3,300 should know. EPA does not ask for items
that require monitoring, research, or calculations on the part of the
respondent.

The data collection instrument design is limited to 12 pages. By
limiting the information requested, EPA believe that the average
respondent can complete the data collection instrument in approximately
4 hours.

Toll-free phone numbers will be provided to help respondents with
questions or problems. In addition, respondents will be encouraged to
call state personnel who will be trained to answer questions. 

Pre-paid return envelopes will be provided to respondents to make
returning the data collection instrument convenient.

Standard methods to reduce other sources of non-sampling error also will
be used.

EPA expects complete coverage of the target population using SDWIS,
supplemented by state agency review of all systems.

Data will be 100 percent independently keyed and verified.

The data collection instrument is pre-coded to improve accuracy by
eliminating unnecessary processing steps. 

Supplementing these standard methods, EPA proposes several unique steps
to eliminate non-sampling error, which have been developed in concert
with organizations representing the states and CWSs. These organizations
believe that the 2007 DWINSA is important and that a high level of
participation by all CWSs is essential to its success. Because of the
substantial commitment being made by states and CWSs to the 2007 DWINSA,
EPA believes that response rates will be higher than most surveys of
similar respondents. To ensure success, states and organizations
representing CWSs are taking the following steps. 

Participation of the states. Because the DWINSA will be used to allocate
DWSRF funds to states, each state has a strong interest in achieving a
high response rate. EPA believes that state participation will be a key
factor in guaranteeing high response rates and low item non-response.
State personnel who work with CWSs every day are in a strong position to
encourage systems to complete the 2007 DWINSA form. These states have
committed to assisting EPA in achieving a high response rate by
participating in follow-up activities. The states also will be available
for technical assistance for any system that has questions about the
2007 DWINSA. All states have already agreed to participate in the 2007
DWINSA. 

Participation of Organizations Representing CWSs. EPA anticipates public
support of organizations representing CWSs. The prior assessments were
supported by groups such as the American Water Works Association (AWWA),
the National Association of Water Companies (NAWC), and the Association
of Metropolitan Water Agencies (AMWA). 

This support by the organizations representing the respondents for the
2007 DWINSA can be helpful in many ways to minimize non-sampling errors.
For example,

These associations are likely to agree to prepare a letter for each
system in their membership, stressing the importance of the 2007 DWINSA
of drinking water infrastructure needs. This letter, along with the
letter from the states, should make systems more likely to respond.

In the past DWINSAs, the largest association representing CWSs serving
populations greater than 3,300—AWWA— provide support of its national
organization behind the DWINSA. To improve the response rate, the AWWA
enlisted of the support of its state affiliates (called “Sections”)
in telephone follow-up to encourage response. AWWA assisted in past
DWINSAs to help achieve the overall response rate of 94 percent. EPA
hopes to secure similar AWWA support for the 2007 DWINSA. 

Communications Strategy. EPA has developed a comprehensive
communications strategy that will inform likely respondents of the need
for their participation. This strategy includes articles in magazines,
newsletters, and bulletins of all major organizations that represent (or
communicate with) CWSs. This includes publications of all of the
organizations mentioned above, plus the state and local affiliates of
these organizations. The strategy is designed to develop widespread
peer-group support for participation in the 2007 DWINSA.

B.2.d	Data Collection Instrument Design  tc "B.2.d	Data Collection
Instrument Design " \l 2 

Questions about system characteristics (name, population served, number
of connections, and other customary business information) will be
pre-printed on all data collection instruments. The respondent needs
only to enter accurate information if any pre-printed information is not
correct.

The 2007 DWINSA is based on matrices that request a list of capital
projects that the system plans for the period 2007 through 2026. For
each project listed, the system is asked to provide: type of need;
documentation of need and cost (if necessary); if the project is for new
infrastructure or rehabilitation of existing infrastructure; if the
project is needed now to protect public health or if it is needed over
the next 20 years to continue to provide safe drinking water; the
federal regulation or state requirement if the project is to meet a
current regulation or state requirement; design capacity of source,
storage, and treatment projects; cost of the project; and date of the
cost estimate. For most of these variables, respondents will choose the
appropriate “documentation,” “type of need,” or “regulation or
requirement,” from the Lists of Codes. All matrices have been designed
to be concise, to avoid jargon, and to avoid ambiguous words or
instructions. Terms and formats have been standardized to the extent
possible. There is no intentional bias in the ordering of the items. 



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B.3	PRE-TESTS AND PILOT TEST tc "B.3	PRETESTS AND PILOT TEST" 

B.3.a	Pre-tests  tc "B.3.a	Pretests " \l 2 

EPA conducted two pre-tests of the data collection instrument for the
2007 DWINSA. The 2007 DWINSA pre-tests were conducted by EPA’s
contractor, The Cadmus Group, Inc. The pre-tests gathered feedback on
the effectiveness of the data collection instrument, highlighted
imprecise, ambiguous, or redundant questions, and indicated where
further inquiry is needed. A pre-test was held in both Maine (four
participants) and Montana (three participants). These states were chosen
because they are both “opt-out” states, and because most of their
systems will not need to participate in the 2007 DWINSA. Also, the
contractor conducting the pre-tests has offices in both these states and
by conducting the pre-test in these states they were able to reduce
costs. The names of the seven systems were provided to EPA by the state
2007 DWINSA contacts. Based on the comments received EPA made
modifications to the data collection instrument. 

B.3.b	Pilot Test  tc "B.3.b	Pilot Test " \l 2 

To eliminate unnecessary burden on states and CWSs, it has been decided
that no pilot test for the 2007 DWINSA will be conducted. A pilot test
was conducted for the 1995 DWINSA and consisted of 60 CWSs from New York
and Texas. The procedures for mailing the data collection instruments
and collecting the data are the same as those used for the 1995, 1999,
and 2003 DWINSAs. EPA believes these procedures are well tested and have
proven to be successful; therefore, it is not necessary repeat this
testing step. 



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B.4	COLLECTION METHODS AND FOLLOW-UP tc "B.4	COLLECTION METHODS AND
FOLLOW-UP" 

B.4.a	Collection Method  tc "B.4.a	Collection Method " \l 2 

The proposed collection method for medium and large systems is a mail
survey. The study data collection instrument and lists of codes will be
mailed to all systems in the sample. State drinking water agencies will
begin follow-up if the mail data collection instrument has not been
returned in 30 days. For a complete description of the follow-up
procedures proposed to increase the response rate, see section B.2.c.ii.

The proposed collection method for small systems is to visit to each
small system in the sample. An EPA contractor, accompanied by state
personnel that choose to participate, will interview the owner or
operator and fill in the data collection instrument for all costs except
treatment costs. (Costs of treatment will be modeled, using methods
similar to those used by the OGWDW for regulatory impact analyses for
new regulations.)

B.4.b	Survey Response and Follow-up  tc "B.4.b	Survey Response and
Follow-up " \l 2 

The target response rate (defined as the ratio of responses to eligible
respondents) for the 2007 DWINSA is 90 percent. EPA realizes that this
is an ambitious target, but EPA believes that there are special
circumstances that warrant such a target. Also, overall response rates
of 94, 97, and 96 percent were achieved in the 1995, 1999, and 2003
surveys, respectively. In the first three surveys, EPA conducted the
following proposed activities to achieve that high response rate. 

Support from the Respondent Population. This is a national survey of
infrastructure needs for drinking water systems. The medium and large
systems, as well as all national organizations representing these
systems, understand the importance of the DWINSA results. All national
organizations have endorsed the DWINSA and have communicated the
importance of a high response rate to their members. As discussed in
Section B.2.c, organizations have provided access to their newsletters
and magazines to publicize and endorse participation in the DWINSA. EPA
will ask national organizations representing smaller CWSs (e.g., the
National Rural Water Association (NRWA) and AWWA) to help communicate
the importance of a high response rate to their members.

Follow-up by States and Respondent Peer Groups. Since a majority of
participating states have indicated their willingness to participate in
follow-up activities, these procedures will be implemented by state
personnel, most of whom are personally familiar with the respondents.
Procedures that states will use include reminder letters and telephone
follow-up. In states that elect not to participate in follow-up, the EPA
contractor will conduct these activities. If the follow-up fails after
three attempts (one reminder letter plus two telephone follow-ups), EPA
will shift to a second approach: peer-group follow-up by members of a
trade association, such as AWWA. Procedures to be used by the
association include a reminder letter followed by telephone calls. Such
involvement is likely to improve the 2007 DWINSA’s response rate.

Recruitment by States and Respondent Peer Groups of Small Systems. In
participating states, scheduling of site visits will be conducted by
state personnel, most of whom are personally familiar with the
respondents. If state personnel cannot schedule a visit with a system in
the sample, EPA will turn to respondent peer groups.



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B.5	ANALYZING AND REPORTING SURVEY RESULTS tc "B.5	ANALYZING AND
REPORTING SURVEY RESULTS" 

B.5.a	Data Preparation  tc "B.5.a	Data Preparation " \l 2 

State personnel will check all cost data and documentation to ensure
that it is consistent with state and national standards. States will
then send the completed and reviewed data collection instruments to EPA
for a second round of review by EPA contractor staff. 

Once data have been checked, the contractor will key and verify the
data. Senior data entry staff will be used for the verification process
to improve quality control. Editing will include automated logic and
range checks and checks for missing data. Missing cost data will be
modeled, using other information provided by the respondents on the data
collection instrument. When modeling is insufficient, missing data will
be imputed using the standard methods such as cell means and regression.
The sample of CWSs will be weighted so that stratum estimates can be
summed to prepare state-level estimates.

B.5.b	Analysis  tc "B.5.b	Analysis " \l 2 

EPA will prepare a report that tabulates the results of the 2007 DWINSA
and explains the precision of the state-level estimates of total capital
needs. Examples of statistics that will be produced include:

Eligible capital needs by state and by types of need.

Total capital needs by state and by types of need.

Total capital needs by domains within the total population, e.g.,
systems serving populations greater than 100,000.

Mean and median statistics on total capital needs (by type of need) for
systems of various sizes. (These data will be of particular interest to
participating respondents who will receive a short summary of these
statistics.)

Standard errors calculated for key statistics.

The analysis will be similar to that done for previous DWINSAs.

B.5.c	Reporting Results  tc "B.5.c	Reporting Results " \l 2 

The 2007 DWINSA results will be made available to EPA and the public
through:

A printed report that is submitted to Congress on drinking water
infrastructure needs. This report will be distributed to all
participants in the 2007 DWINSA and all interested offices at EPA. 

Micro-computer access to state data (each state can access only its own
data).

Micro-computer access to the entire database (EPA only).

A report containing all technical information (data collection
instrument, sampling plan, response rates, and variances) will be
prepared and distributed. Record layouts, codes, and complete file
documentation will be developed for data users (both micro-computer and
mainframe users).

 

Appendix A 

Public Notice Required Prior to ICR Submission to OMB



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Appendix B

Data Collection Instrument and Lists of Codes



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Appendix C

Comments and Response to Comments Received on the First Federal Register
Notice



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In response to the first Federal Register document published June 5,
2006, EPA received one set of comments from the American Water Works
Association (AWWA). The following is a summary of the comments and
EPA’s response.

AWWA suggested that EPA set objectives for the Needs Survey. More detail
of the general objectives of the 2007 DWINSA has been added to the
objectives discussion in the final ICR.

They also point out that although a precision target is set at 95% +/-
10%, this does not address accuracy of the data collected and ask that
EPA report their accuracy. Although precision can be measured, the
accuracy of each water system’s response to the 2007 DWINSA is not
quantifiable. EPA believes that the most accurate assessment of the
drinking water infrastructure needs is to rely on the information and
judgment of the owners and operators of water systems within the context
of historic best engineering practices. EPA strives to further achieve
the most accurate data possible by enlisting the assistance of the state
coordinators to contact the system and work with them to ensure they
list all required projects.

AWWA indicated that the policy that needs associated with recently
promulgated rules not be reported on the questionnaires but be added to
the national needs based on the regulatory impact analysis (RIA) will
result in underestimating the need associated with the Long-Term 2
Enhanced Surface Water Treatment Rule (LT2ESWTR). EPA sought input on
this issue from the state coordinators as well as a technical expert
group comprised of AWWA and AMWA membership. The group and EPA agreed
that although some large systems may be planning for investments
associated with additional treatment for Cryptosporidium, the rule does
not require source water monitoring to be completed for many years. As
such, all systems cannot be expected to be aware of their infrastructure
needs to meet the new ruling. However, systems will be aware of any need
associated with covering or treating uncovered finished water
reservoirs, and as this requirement is in the near term (April 2009),
planning will likely have taken place by the time of the 2007 DWINSA.
Therefore, there is a policy to allow systems to report needs associated
with uncovered finished water reservoirs, but does not allow needs
associated with additional treatment for cryptosporidium. The costs
estimated in the EA for addressing uncovered reservoirs will, therefore,
be separated out and not be added to the national needs; whereas the
other EA cost estimates, including those for treatment works, will be
added, in total, to the national base. The 2007 DWINSA’s Report to
Congress will note the approach and how it impacts the 2007 DWINSA
results.  We expect that by the time of the 2011 DWINSA, systems will
have incorporated to a fuller extent their LT2ESWTR compliance needs
into their infrastructure planning documents and individual projects for
these types of needs can be accepted from surveyed systems. This
approach worked out with the technical expert group was endorsed by the
State and Regional Needs Survey Coordinators Workgroup and by an
independent peer review of the 2007 DWINSA methodologies.

AWWA expressed concern that the original notice did not provide
sufficient information for a respondent to address the burden estimate.
They were also unable to assess the statistical viability of the
assessment as the final samples were not included in Exhibit B-2-1. In
the public review and comment process for ICRs, the initial review is
only of the information provided in the Federal Register notice;
primarily the intended purpose of the information collection effort and
its estimates of burden. EPA provided a rough and incomplete draft of
the actual ICR in the public docket only to provide the reviewer with
some further background and context to the information provided in the
actual Notice. In the next opportunity for public comment of this ICR,
reviewers will be provided the full and complete ICR document for
consideration..

 

AWWA was concern that the burden estimate was likely too low. EPA has
reviewed the assumptions made regarding burden and believes they are
sound. EPA’s estimates of burden are based on the experience of three
previous DWINSAs and the input of survey respondents and state
coordinators during those efforts and after in reviews to determine the
strengths and weaknesses of those DWINSAs. The burden estimate was
revised substantially from the estimate from the last DWINSA primarily
taking into account greater efforts to ensure consistency across systems
and states in determining long-term infrastructure rehabilitation and
replacement needs.

AWWA indicated that it was not clear from the survey instrument that the
agency is only concerned with needs associated with the SDWA compliance.
In fact this is not the case. EPA is collecting data on capital
improvement needs to continue to ensure adequate supplies of safe
drinking water, a goal that includes, but is not limited to regulatory
compliance. EPA does ask the respondent to identify whether a need is
associated with a regulation. EPA will continue to make clear in the
DWINSA’s Report to Congress that it attempts to capture infrastructure
needs for this broader goal.

AWWA also commented on several parts of the draft questionnaire (not a
part of the original notice) that discuss system inventory. AWWA was
concern that providing system inventory information would be too
burdensome for many of the surveyed water system operators. It will be
made further clear that in the final questionnaire that the inventory
tables are simply provided as a helpful tool for the system to assess
any asset investment needs that are not yet part of their formal
planning documents.

AWWA also expressed concern that the Needs Survey should not be fielded
at the same time as the Community Water System Survey (CWSS). Although
EPA understands the concern with respect to the impact this may have on
response rate, the decision to conduct these surveys concurrently was
primarily to accommodate data collection for small systems. The survey
design is based on EPA contractors collecting data in the field from 600
small systems. This was accomplished by combining the small system data
collection efforts for both the 2007 DWINSA and the CWSS. Adequate cost
savings were realized from this combination of efforts to allow EPA to
collect data from 600 systems for both surveys. For systems serving 3300
to 100,000, the 2007 DWINSA and CWSS will attempt to mutually exclude
selected systems from each other survey. Systems serving over 100,000
will be sampled by both surveys, but we believe these size systems are
capable and interested in participating in both surveys.

AWWA was concerned that sampling only 400 small water systems would not
be adequately representative of the large number of these sized systems.
As noted above, the sampling frame has been expanded from 400 small
systems to 600.  It should also be noted that the 2007 DWINSA’s
objective for small systems is to obtain results
statistically-significant only at the national level. For medium and
larger systems, the objective is to obtain results statistically
significant at the state as well as national levels. A relatively
smaller number of small systems are needed to provide
statistically-significant results only at the national level. 

 EPA’s previous assessments of infrastructure need in 1995 and 1999
were called “needs surveys” because the assessment relied primarily
on survey methods. In 2003, EPA relied in part on surveys but also on
analysis of previous survey data. Accordingly, the term “assessment”
is more appropriate. Hereinafter, these studies will be referred to as
“assessments.”

 The term states refer to all 50 states, as well as the U.S. territories
(Guam, U.S. Virgin Islands, Northern Mariana Islands, and American
Samoa), Puerto Rico, and the District of Columbia. 

 NPNCWSs are also eligible for DWSRF funding.

 Medium systems refer to systems serving between 3,301 and 50,000
people. 

 Large systems refer to systems serving more than 50,000 people. 

 Fifty-six states include the 50 states plus the District of Columbia,
Puerto Rico, Northern Mariana Islands, American Samoa, Guam, and the
U.S. Virgin Islands. For several of these entities, primacy activities
are actually implemented by EPA Regional offices. However, as a
simplifying assumption, they are included with the states for respondent
calculations under this ICR.

 See Exhibit A-6-9.

 States include Regional offices that act as the primacy agency for
drinking water programs in Wyoming, District of Columbia, U.S. Virgin
Islands, Guam, American Samoa, and the Northern Mariana Islands. 

 The DWSRF defines small systems as those with populations of 10,000 or
fewer, a different threshold than that listed in the typical drinking
water regulation (i.e., systems serving 3,300 or fewer persons). In the
final Report to Congress resulting from this survey, the results will be
presented in different formats to accommodate various definitions of
small system.

 In states and territories where the EPA region acts as the primacy
agency, EPA regional officers will perform the activities identified in
this ICR as “State Activities.” This should have no net impact on
burden; burden for EPA regions acting as primacy agencies will be
reflected in estimates for states rather than for the Agency.

 Region 9 will perform state functions for the three Pacific Island
territories, Region 3 will perform these functions for the District of
Columbia, and Region 8 will perform these functions for Wyoming. For
simplicity, however, EPA is including the burden for these states in
this ICR.

 According to the ICR Handbook, an employee is paid an average of 2,080
hours in 1 year.

 The State Workload Model is a spreadsheet model used by states/primacy
agencies to estimate resource needs for implementation of the SDWA. 

 Hourly rates are from U. S. Office of Personnel Management, 2006
General Schedule (GS) Locality Pay Tables and overhead rates are from
Information Collection Request for Public Water Supply Program, December
20, 1993.

 For several of these entities, primacy activities are actually
implemented by EPA Regional offices. However, as a simplifying
assumption, they are included with the states for respondent
calculations under this ICR.

 For this ICR, the number of responses is calculated at 3,193 (999 large
systems, 1,538 medium systems, 600 small systems, and 56 states and U.S.
Territories). The burden per response is calculated as the total
respondent burden (46,030) divided by the number of responses (3,193). 

 See Exhibit A-6-9.

 J. Neyman, “On the Two Different Aspects of the Representative
Method: The Method of Stratified Sampling and the Method of Purposive
Selection,” Journal of the Royal Statistical Society, Vol. 97 (1934),
pp. 558-606; as cited in William G. Cochran, Sampling Techniques (New
York: John Wiley & Sons), 1977. 

 For the purposes of the 2007 DWINSA, purchased surface water systems
are included with ground water systems. This design yields lower
within-stratum variance.

 For purposes of burden calculation, EPA assumes 100 percent response. 

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Proceedings of the Section on Survey Research Methods, August, 1987, pp.
792-796. 

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