  SEQ CHAPTER \h \r 1 							

Information Collection Request for the 2011 Drinking Water
Infrastructure Needs Survey and Assessment (DWINSA)

(Supporting Statement for ROCIS)

July 2010

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

This page intentionally left blank.

Table of Contents

  TOC \o "3-3" \h \z \t "Heading 1,1,Heading 2,2,AppexTitle,1,Style
Heading 1 + After:  0 pt,1"    HYPERLINK \l "_Toc268198673"  PART A OF
THE SUPPORTING STATEMENT	  PAGEREF _Toc268198673 \h  1  

  HYPERLINK \l "_Toc268198674"  A.1	IDENTIFICATION OF THE INFORMATION
COLLECTION	  PAGEREF _Toc268198674 \h  1  

  HYPERLINK \l "_Toc268198675"  A.1.a	Title of the Information
Collection Request	  PAGEREF _Toc268198675 \h  1  

  HYPERLINK \l "_Toc268198676"  A.1.b	Short Characterization	  PAGEREF
_Toc268198676 \h  1  

  HYPERLINK \l "_Toc268198677"  A.2	NEED FOR AND USE OF THE COLLECTION	 
PAGEREF _Toc268198677 \h  3  

  HYPERLINK \l "_Toc268198678"  A.2.a	Authority and Need for the
Collection	  PAGEREF _Toc268198678 \h  3  

  HYPERLINK \l "_Toc268198679"  A.2.b	Use and Users of the Information	 
PAGEREF _Toc268198679 \h  3  

  HYPERLINK \l "_Toc268198680"  A.3	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION CRITERIA	  PAGEREF _Toc268198680 \h  5  

  HYPERLINK \l "_Toc268198681"  A.3.a	Nonduplication	  PAGEREF
_Toc268198681 \h  5  

  HYPERLINK \l "_Toc268198682"  A.3.b	Public Notice Required Prior to
ICR Submission to OMB	  PAGEREF _Toc268198682 \h  6  

  HYPERLINK \l "_Toc268198683"  A.3.c	Consultations	  PAGEREF
_Toc268198683 \h  6  

  HYPERLINK \l "_Toc268198684"  A.3.d	Effects of Less Frequent
Collection	  PAGEREF _Toc268198684 \h  6  

  HYPERLINK \l "_Toc268198685"  A.3.e	General Guidelines	  PAGEREF
_Toc268198685 \h  6  

  HYPERLINK \l "_Toc268198686"  A.3.f	Confidentiality Questions	 
PAGEREF _Toc268198686 \h  7  

  HYPERLINK \l "_Toc268198687"  A.3.g	Sensitive Questions	  PAGEREF
_Toc268198687 \h  7  

  HYPERLINK \l "_Toc268198688"  A.4	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc268198688 \h  8  

  HYPERLINK \l "_Toc268198689"  A.4.a	Respondents/NAICS Codes	  PAGEREF
_Toc268198689 \h  8  

  HYPERLINK \l "_Toc268198690"  A.4.b	Information Requested	  PAGEREF
_Toc268198690 \h  9  

  HYPERLINK \l "_Toc268198691"  A.5	INFORMATION COLLECTED: AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc268198691 \h  16  

  HYPERLINK \l "_Toc268198692"  A.5.a	Agency Activities	  PAGEREF
_Toc268198692 \h  16  

  HYPERLINK \l "_Toc268198693"  A.5.b	Collection Methodology and
Management	  PAGEREF _Toc268198693 \h  18  

  HYPERLINK \l "_Toc268198694"  A.5.c	Small Entity Flexibility	  PAGEREF
_Toc268198694 \h  22  

  HYPERLINK \l "_Toc268198695"  A.5.d	Collection Schedule	  PAGEREF
_Toc268198695 \h  23  

  HYPERLINK \l "_Toc268198696"  A.6	ESTIMATING THE BURDEN AND COST OF
THE COLLECTION	  PAGEREF _Toc268198696 \h  24  

  HYPERLINK \l "_Toc268198697"  A.6.a	Respondent Burden	  PAGEREF
_Toc268198697 \h  24  

  HYPERLINK \l "_Toc268198698"  A.6.b	Respondent Costs	  PAGEREF
_Toc268198698 \h  34  

  HYPERLINK \l "_Toc268198699"  A.6.c	Agency Burden and Cost	  PAGEREF
_Toc268198699 \h  36  

  HYPERLINK \l "_Toc268198700"  A.6.d	Estimating Respondent Universe and
Total Burden and Costs	  PAGEREF _Toc268198700 \h  39  

  HYPERLINK \l "_Toc268198701"  A.6.e	Bottom Line Burden Hours and Costs
  PAGEREF _Toc268198701 \h  39  

  HYPERLINK \l "_Toc268198702"  A.6.f	Reasons for Change in Burden	 
PAGEREF _Toc268198702 \h  43  

  HYPERLINK \l "_Toc268198703"  A.6.g	Burden Statement	  PAGEREF
_Toc268198703 \h  43  

  HYPERLINK \l "_Toc268198704"  PART B OF THE SUPPORTING STATEMENT (FOR
STATISTICAL SURVEYS)	  PAGEREF _Toc268198704 \h  45  

  HYPERLINK \l "_Toc268198705"  2011 STATE DWINSA	  PAGEREF
_Toc268198705 \h  46  

  HYPERLINK \l "_Toc268198706"  B.1	SURVEY OBJECTIVES, KEY VARIABLES AND
OTHER PRELIMINARIES	  PAGEREF _Toc268198706 \h  46  

  HYPERLINK \l "_Toc268198707"  B.1.a	Survey Objectives	  PAGEREF
_Toc268198707 \h  46  

  HYPERLINK \l "_Toc268198708"  B.1.b	Key Variables	  PAGEREF
_Toc268198708 \h  46  

  HYPERLINK \l "_Toc268198709"  B.1.c	Statistical Approach	  PAGEREF
_Toc268198709 \h  47  

  HYPERLINK \l "_Toc268198710"  B.1.d	Feasibility	  PAGEREF
_Toc268198710 \h  48  

  HYPERLINK \l "_Toc268198711"  B.2	SURVEY DESIGN	  PAGEREF
_Toc268198711 \h  48  

  HYPERLINK \l "_Toc268198712"  B.2.a	Target Population and Coverage	 
PAGEREF _Toc268198712 \h  49  

  HYPERLINK \l "_Toc268198713"  B.2.b	Sample Design	  PAGEREF
_Toc268198713 \h  49  

  HYPERLINK \l "_Toc268198714"  B.2.c	Precision Requirements	  PAGEREF
_Toc268198714 \h  56  

  HYPERLINK \l "_Toc268198715"  B.2.d	Data Collection Instrument Design	
 PAGEREF _Toc268198715 \h  58  

  HYPERLINK \l "_Toc268198716"  B.3	PRE-TESTS AND PILOT TEST	  PAGEREF
_Toc268198716 \h  58  

  HYPERLINK \l "_Toc268198717"  B.3.a	Pre-tests	  PAGEREF _Toc268198717
\h  58  

  HYPERLINK \l "_Toc268198718"  B.3.b	Pilot Test	  PAGEREF _Toc268198718
\h  59  

  HYPERLINK \l "_Toc268198719"  B.4	COLLECTION METHODS AND FOLLOW-UP	 
PAGEREF _Toc268198719 \h  59  

  HYPERLINK \l "_Toc268198720"  B.4.a	Collection Method	  PAGEREF
_Toc268198720 \h  59  

  HYPERLINK \l "_Toc268198721"  B.4.b	Survey Response and Follow-up	 
PAGEREF _Toc268198721 \h  59  

  HYPERLINK \l "_Toc268198722"  B.5	ANALYZING AND REPORTING SURVEY
RESULTS	  PAGEREF _Toc268198722 \h  59  

  HYPERLINK \l "_Toc268198723"  B.5.a	Data Preparation	  PAGEREF
_Toc268198723 \h  60  

  HYPERLINK \l "_Toc268198724"  B.5.b	Analysis	  PAGEREF _Toc268198724
\h  60  

  HYPERLINK \l "_Toc268198725"  B.5.c	Reporting Results	  PAGEREF
_Toc268198725 \h  60  

  HYPERLINK \l "_Toc268198726"  2011 NATIVE AMERICAN DWINSA	  PAGEREF
_Toc268198726 \h  61  

  HYPERLINK \l "_Toc268198727"  Introduction	  PAGEREF _Toc268198727 \h 
61  

  HYPERLINK \l "_Toc268198728"  B.1	SURVEY OBJECTIVES, KEY VARIABLES AND
OTHER PRELIMINARIES	  PAGEREF _Toc268198728 \h  61  

  HYPERLINK \l "_Toc268198729"  B.1.c	Statistical Approach	  PAGEREF
_Toc268198729 \h  61  

  HYPERLINK \l "_Toc268198730"  B.2 	SURVEY DESIGN	  PAGEREF
_Toc268198730 \h  61  

  HYPERLINK \l "_Toc268198731"  B.2.a	Target Population and Coverage	 
PAGEREF _Toc268198731 \h  61  

  HYPERLINK \l "_Toc268198732"  B.2.b	Sample Design	  PAGEREF
_Toc268198732 \h  62  

  HYPERLINK \l "_Toc268198733"  B.2.c	Precision Requirements	  PAGEREF
_Toc268198733 \h  62  

  HYPERLINK \l "_Toc268198734"  B.4	COLLECTION METHODS AND FOLLOW-UP	 
PAGEREF _Toc268198734 \h  63  

  HYPERLINK \l "_Toc268198735"  B.4.a	Collection Method	  PAGEREF
_Toc268198735 \h  63  

  HYPERLINK \l "_Toc268198736"  Appendix A    HYPERLINK \l
"_Toc268198737"  Public Notice Required Prior to ICR Submission to OMB	 
PAGEREF _Toc268198737 \h  65  

  HYPERLINK \l "_Toc268198738"  Appendix B    HYPERLINK \l
"_Toc268198739"  Data Collection Instrument and Lists of Codes	  PAGEREF
_Toc268198739 \h  67  

  HYPERLINK \l "_Toc268198740"  Appendix C    HYPERLINK \l
"_Toc268198741"  Comments and Response to Comments Received on the First
Federal Register Notice	  PAGEREF _Toc268198741 \h  91  

 List of Tables

  TOC \h \z \t "Exhibit" \c    HYPERLINK \l "_Toc268198742"  Exhibit
A-5-1 Collection Schedule	  PAGEREF _Toc268198742 \h  23  

  HYPERLINK \l "_Toc268198743"  Exhibit A-6-1 Estimated Unit Burden for
Systems Serving More Than 50,000 Persons	  PAGEREF _Toc268198743 \h  25 


  HYPERLINK \l "_Toc268198744"  Exhibit A-6-2 Estimated Unit Burden for
Systems Serving 3,301 – 50,000 Persons	  PAGEREF _Toc268198744 \h  27 


  HYPERLINK \l "_Toc268198745"  Exhibit A-6-3 Estimated Unit Burden for
American Indian and Alaskan Native Village Water Systems	  PAGEREF
_Toc268198745 \h  28  

  HYPERLINK \l "_Toc268198746"  Exhibit A-6-4 Overall State/Navajo
Nation Burden Summary	  PAGEREF _Toc268198746 \h  29  

  HYPERLINK \l "_Toc268198747"  Exhibit A-6-5 State and Navajo Nation
Unit Burden for Up-Front Activities	  PAGEREF _Toc268198747 \h  29  

  HYPERLINK \l "_Toc268198748"  Exhibit A-6-6 State Unit Burden for
Systems Serving More Than 50,000 Persons	  PAGEREF _Toc268198748 \h  31 


  HYPERLINK \l "_Toc268198749"  Exhibit A-6-7 State Unit Burden for
Systems Serving 3,301 – 50,000 Persons	  PAGEREF _Toc268198749 \h  32 


  HYPERLINK \l "_Toc268198750"  Exhibit A-6-8 Navajo Nation Unit Burden
for Systems	  PAGEREF _Toc268198750 \h  34  

  HYPERLINK \l "_Toc268198751"  Exhibit A-6-9 Total Burden and Cost to
Water Systems	  PAGEREF _Toc268198751 \h  34  

  HYPERLINK \l "_Toc268198752"  Exhibit A-6-10 Total Burden and Cost to
States	  PAGEREF _Toc268198752 \h  35  

  HYPERLINK \l "_Toc268198753"  Exhibit A-6-11 Burden/Cost to EPA
(Excluding Contractor Activities)	  PAGEREF _Toc268198753 \h  37  

  HYPERLINK \l "_Toc268198754"  Exhibit A-6-12 Burden/Cost of Contractor
Activities	  PAGEREF _Toc268198754 \h  38  

  HYPERLINK \l "_Toc268198755"  Exhibit A-6-13 Bottom Line Respondent
Burden	  PAGEREF _Toc268198755 \h  39  

  HYPERLINK \l "_Toc268198756"  Exhibit A-6-14 Burden Hours and Costs
for Respondents per Year	  PAGEREF _Toc268198756 \h  39  

  HYPERLINK \l "_Toc268198757"  Exhibit A-6-15 Bottom Line Burden Hours
and Costs for EPA (including EPA’s contractor)	  PAGEREF _Toc268198757
\h  40  

  HYPERLINK \l "_Toc268198758"  Exhibit A-6-16 Disaggregated Burden by
Affected Information Collection (IC) Entities	  PAGEREF _Toc268198758 \h
 41  

  HYPERLINK \l "_Toc268198759"  Exhibit B-2-1 State Sample Sizes	 
PAGEREF _Toc268198759 \h  53  

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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 2011 Drinking Water Infrastructure Needs
Survey and Assessment (DWINSA). The Office of Management and Budget
(OMB) control number for this ICR is 2040-0274; EPA ICR No. 2234.03.

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 2011 DWINSA is
collecting information on systems’ needs and on the projected costs
associated with those needs. All states and the Navajo Nation have
committed to help EPA administer the 2011 DWINSA with at least the
minimum of activities. Sixteen states will not participate in the
statistical portion of the survey (i.e., collecting data from systems
serving 3,301 – 100,000 persons). For the states that are not included
in 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 persons. All states with systems serving more than 100,000
persons will participate in the census portion of the survey. 

For the 2011 DWINSA, there are two similar approaches EPA will take to
collect the information. One approach will collect the 20-year need for
systems that are under state primacy (e.g., 2011 State DWINSA). The term
states refer to all 50 states, the U.S. territories (Guam, U.S. Virgin
Islands, Northern Mariana Islands, and American Samoa), Puerto Rico, and
the District of Columbia. A separate collection of 20-year need will be
conducted for American Indian and Alaskan Native Village water systems
(e.g., 2011 Native American DWINSA). The method of data collection and
statistical precision is the same for the two approaches. However, to
account for differences the stratification of systems between the two
approaches and the type of systems that will EPA collect information
from will differ. 

For the 2011 State 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 estimate the infrastructure needs for CWSs serving 3,300 and fewer
persons based on the 2007 DWINSA results and the infrastructure needs
for not-for-profit noncommunity water systems (NPNCWSs)  based on the
1999 DWINSA results. The data collection instrument that EPA will send
to all water systems selected in the 2011 State DWINSA to complete
consists of project tables in which the water systems list all their
capital improvement projects for the survey period of January 1, 2011 to
December 31, 2030.

For the 2011 Native American DWINSA, EPA will conduct a census of all
CWSs and NPNCWSs serving more than 10,000 and will select a random
sample of CWSs and NPNCWSs serving 10,000 and fewer persons. These
systems will receive the same data collection instrument as the systems
selected for the 2011 State DWINSA. EPA Regions and the Navajo Nation
will use data provided by the Indian Health Service (IHS) from their
Sanitary Deficiency System (SDS) to identify potential needs and EPA
Regions and the Navajo Nation will collect additional information
through phone calls or on-site engineering reviews.

The effort for the 2011 DWINSA will involve 3,176 respondents (3,119
water systems, 56 states, and the Navajo Nation), requiring 48,751 hours
at a total cost to the respondents of $1,839,042. 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 7.55 hours. 

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.” Section 1452(i)(4) requires that “the Administrator, in
consultation with the Director of Indian Health Services and Indian
Tribes, shall, in accordance with a schedule that is consistent with the
needs survey conducted pursuant to subsection (h), prepare surveys and
assess the needs of drinking water treatment facilities to serve Indian
Tribes, including an evaluation of the public water systems that pose
the most significant threat to public health.”

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 2011 DWINSA will be used as a basis for allocation of
DWSRF funds among states and EPA Regions (for the American Indian and
Alaskan Native Village water systems). 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 three 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)); (2) information on capital
improvement projects; and (3) information on “green” and climate
readiness infrastructure 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. This will be the first time EPA
will collect information for “green” and climate readiness
infrastructure projects.

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

Respondents 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 meters or the diameter and length of transmission
or distribution lines. EPA expects that modeling will be required to
project the capital needs for some systems that serve more than 100,000
persons, many of the systems that serve 3,301 – 100,000 persons, and
almost all of the systems serving 3,300 and fewer (for the 2011 Native
American DWINSA only). For the 2007 DWINSA, approximately 19 percent of
the projects reported had documented costs; the costs for the remaining
81 percent of projects were modeled. 

The data collected by the 2011 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.	

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 systems’ 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 2011 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 2006 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. 

Economic Analyses (EAs) for National Primary Drinking Water Regulations.
The Agency has developed EAs 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.

1995, 1999, 2003, and 2007 DWINSAs. Under the SDWA, EPA must conduct the
DWINSA every 4 years. The approach for the 2011 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 2011 DWINSA ensures that up-to-date data on
infrastructure needs are collected for all CWSs. CWSs under state
primacy accounted for approximately 97 percent of the national need for
the 2007 DWINSA. The remaining 3 percent represents  needs associated
with American Indian and Alaskan Native water systems, NPNCWSs, and
recently promulgated regulations. 

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 (XXFRXXXXX). 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 

In May 2010, EPA assembled a workgroup that consisted of EPA
Headquarters, EPA Regional, tribal, and state representatives to discuss
the approach for the 2011 DWINSA.  Separate meetings were held for the
2011 State DWINSA and the 2011 Native American DWINSA. The purpose of
the meetings was to: gather information on state, Native American,
and/or regional concerns; to discuss lessons learned during the 2007
DWINSA; and to discuss new policies for the 2011 DWINSA. The 2011 Native
American DWINSA Workgroup also discussed the methodology for collecting
information from American Indian and Alaskan Native Village water
systems. The information gathered during the meetings was used to
develop the methodology for the 2011 DWINSA. 

For the 2007 DWINSA the data collection instrument and some policies
were modified substantially. Consequently, in 2007, 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
review and the pre-test, EPA made modifications to the data collection
instrument, statistical procedures, and survey polices. Since the only
significant modification to the 2011 data collection instrument was the
addition of questions and codes to gather information on “green” and
climate readiness infrastructure projects, EPA will conduct a limited
peer review of these new questions. The peer review will include experts
familiar with the operations of drinking water systems and “green”
and climate readiness issues. Based on comments received from the peer
review EPA will make any necessary modifications to the data collection
instrument and survey polices. 

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

The 2011 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 2011 DWINSA does not violate any guidelines for information
collection activities specified by OMB. Specifically, the 2011 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 2011 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 2011 DWINSA are CWSs, NPNCWSs, tribal
authorities, and states. Both CWSs and NPNCWSs are considered public
water systems. 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 serves at least 25 year-round
residents” and a NCWS is a “public water system that is not a
community water system and that regularly serves at least 25 of the same
persons over 6 months per year” (nontrasient noncommunity water
system) or is a public water system that is not a community water system
and “does not regularly serve at least 25 of the same persons over six
months per year” (transient noncommunity water system). The North
American Industry Classification System (NAICS) code for a public water
system is 221310. For government establishments providing public
administration of American Indian and Alaskan Native Village affairs,
the NAICS code is 921190 (Other General Government Support). 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

For the 2011 State DWINSA, EPA will gather information from CWSs serving
more than 3,300 persons. Because of their variability and significant
contribution to the overall drinking water capital investment need,
systems serving more than 100,000 persons will be sampled with
certainty. EPA will survey 610 systems that serve more than 100,000
persons. There are 8,281 systems that serve populations of 3,301 –
100,000. 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 – 100,000. This will
result in 2,231 systems receiving the mailed data collection instrument.
Part B of the supporting statement describes the sampling methodology.

For the 2011 Native American DWINSA, EPA will collect information from
all American Indian and Alaskan Native Village water systems serving
more than 10,000 and will select a random sample of American Indian and
Alaskan Native Village water systems serving 10,000 and fewer persons.
This will result in 278 water systems being selected as part of the 2011
Native American DWINSA. Part B of the supporting statement describes the
sampling methodology. 

Fifty-six states (50 states plus the District of Columbia, Puerto Rico,
Northern Mariana Islands, American Samoa, Guam, and the U.S. Virgin
Islands) and the Navajo Nation will provide support and information for
the 2011 DWINSA. 

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

As previously discussed, EPA will collect three types of information
from systems: (1) system inventory and characteristics; (2) information
on capital improvement projects; and (3) information on “green” and
climate readiness infrastructure projects. EPA anticipates that
respondents will provide varying levels of information by system size
category. Based on experience from the previous four DWINSAs, EPA
expects larger systems (e.g., those systems serving more than 50,000
persons) 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 of these systems will be capable
of providing accurate information on cost. Most medium-sized systems
(e.g., those systems serving 3,301 to 50,000 persons) 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. American Indian and
Alaskan Native Village water systems that serve populations of 3,300 or
fewer are unlikely to be able to provide much information on needs or
costs. EPA will use data provided by the IHS from their SDS to identify
potential needs and EPA Regions will collect additional information
through phone calls or on-site engineering reviews.

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

2011 State DWINSA – Systems serving more than 3,300 persons

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 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, and Other.

For each project, 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 requirement or
if the infrastructure is for a “green” or climate readiness need
using the codes from List 3 in the Lists of Codes. EPA will use this
information to determine which needs are required or necessary because
of  SDWA regulation, state requirement, or green or climate readiness
need. If a system indicates they have projects pertaining to climate
readiness, they will be asked to provide additional information
regarding those projects on the data collection instrument. They will be
asked if the project is for source quality degradation issues, source
quantity degradation issues, or infrastructure vulnerability. They will
also be asked if data was obtained through models or by other means.

Provide design capacity when applicable—millions of gallons per day
(MGD) for treatment and pumping; millions of gallons (MG) for storage;
the diameter and number of feet of distribution or transmission lines;
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 assign 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 reasonable for replacement or rehabilitation 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 2011
DWINSA.

For respondents of the 2011 State DWINSA that reported projects in the
2007 State DWINSA, EPA will provide them a list of all the projects that
were submitted in response to the 2007 DWINSA. The respondent will be
asked to update the list, by correcting any old information (e.g., cost
estimate), deleting projects that are completed or no longer needed, and
providing appropriate documentation that support the project. These
respondents will also add any new projects that were not included in the
2007 State DWINSA. All projects must meet documentation and policy
requirements established for the 2011 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 2011 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.

2011 Native American DWINSA – American Indian and Alaskan Native
Village Water Systems 

To minimize the burden on American Indian and Alaskan Native Village
water systems, EPA Regional Offices and the Navajo Nation will use
available information from the IHS SDS. EPA Regional and Navajo Nation
personnel will complete the data collection instrument for the water
systems using the information from the IHS SDS and any additional
information collected from the respondent. Respondents will be expected
to answer very basic questions about the physical design of the plant,
system configuration, and capital needs.

The data collection instrument is attached as Appendix B.

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

2011 State DWINSA –Systems serving more than 3,300 persons

To complete the data collection instrument, the following activities are
anticipated for CWSs serving more than 3,300 persons:

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. Pipe 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 respondents may contact states (or an EPA-established
helpline) to obtain clarifying information on the data collection
instrument.

2011 Native American DWINSA – American Indian and Alaskan Native
Village Water Systems 

The 2011 Native American DWINSA methodology has been designed to
minimize the burden on American Indian and Alaskan Native Village water
systems. Their role will be limited to answering basic questions during
a phone call and providing any available documentation to the Regional
Offices or the Navajo Nation. They will:

Participate in an informational telephone call from the EPA Regional
Office or Navajo Nation. Respondents will receive a call that describes
the purpose of the DWINSA.

Answer basic questions posed by the EPA Regional Office or the Navajo
Nation. Respondents will be expected to answer very basic questions
about the physical design of the plant, system configuration, and
capital needs.

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

2011 State DWINSA – State Activities

All states have committed to help EPA administer the 2011 State DWINSA
with at least the minimum of activities. Sixteen states will not
participate in the statistical portion of the survey (i.e., collecting
data from systems serving 3,301 – 100,000 persons). 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 persons. All states that
have systems serving more than 100,000 persons 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 2011 State DWINSA. 

Participate in training and other pre-mailout efforts. This activity
includes participating in training sessions offered by EPA 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. Such data includes the 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 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 2011 State DWINSA (e.g.,
establishing system files). In addition, state management will explain
the 2011 State DWINSA to staff and allocate resources. 

State Data Collection Activities for Systems serving more than 3,300
persons

States will conduct the following activities for CWSs serving more than
3,300 persons during the data collection phase of the 2011 State DWINSA:

Telephone systems to ensure participation. To improve response rates,
states that participate in the 2011 DWINSA will telephone the water
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 allowable. Any differences of opinion
regarding the documentation of the data will be resolved by EPA and the
state. 

2011 Native American DWINSA – Navajo Nation Activities

The Navajo Nation has primary enforcement for water systems within its
tribal organization. The Navajo Nation has committed to help EPA
administer the 2011 Native American DWINSA with at least the minimum of
activities for its water systems that are selected in the 2011 Native
American DWINSA. EPA Regional Offices will provide support for all other
American Indian and Alaskan Native Village water systems. Their
activities are discussed in A.5. 

Navajo Nation Up-Front Activities

This first activity category includes the Navajo Nation “fixed
burden” for helping EPA prepare for the 2011 Native American DWINSA. 

Participate in training and other pre-mailout efforts. This activity
includes participating in training sessions offered by EPA 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. Such data include PWSID,
system name, address, telephone numbers (if any), primary source,
population served, number of service connections, whether the facility
is a NPNCWSs, and whether the system is a consecutive system, To help
with this verification activity, EPA will provide the information that
must be reviewed in electronic form.

Perform miscellaneous administrative activities. The Navajo Nation will
perform various administrative duties prior to the 2011 Native American
DWINSA (e.g., establishing system files). In addition, Navajo Nation
management will explain the 2011 Native American DWINSA to staff and
allocate resources.

Navajo Nation Data Collection Activities 

The Navajo Nation will conduct the following activities for their water
systems during the data collection phase:

Telephone systems to ensure participation. The Navajo Nation will
contact the water system operators of systems selected in the 2011
Native American DWINSA to ensure participation and to schedule time to
discuss the systems 20-year need and review the completed data
collection instrument.

Review the IHS SDS projects. The Navajo Nation will review the list of
projects extracted from the IHS SDS and incorporate appropriate projects
on to the 2011 DWINSA data collection instrument. 

Discuss 20-year need. The Navajo Nation will contact the water system
and discuss projects that have been identified, ask basic questions
about the physical design of the plant, system configuration, and
capital needs, and request additional documentation from the water
system. 

Complete the data collection instrument. Based on all the data collected
from IHS and the water system, the Navajo Nation will complete the data
collection instrument and submit it to EPA. 

Discuss results with EPA. After the data collection instrument is
submitted, EPA will perform a quality control/quality assurance check to
ensure all data are documented and allowable. Any differences of opinion
regarding the documentation of the data will be resolved by EPA and the
Navajo Nation. 

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 2011 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. EPA is revising the data
collection instrument based on lessons learned during the previous
DWINSAs and to incorporate questions on “green” and climate
readiness infrastructure projects. This task will include developing
cover letters and other materials for state use.

Train state and Navajo Nation participants. To ensure that participating
state and Navajo Nation officials understand every aspect of the 2011
DWINSA, EPA will conduct regional training sessions. The training will
help ensure consistent responses across the country, high response
rates, and efficient use of staff. 

Select 2011 DWINSA respondents. The Agency will draw state samples for
the 2011 State DWINSA, a national sample for the American Indian portion
of the 2011 Native American DWINSA, and a sample of Alaskan Native
Village water systems. 

Update data system. EPA will update the data system used for the 2007
DWINSA to store and analyze data. The system will produce the necessary
statistical reports for EPA, Congress, states, and the Navajo Nation.
The system will also allow EPA, state, and Navajo Nation offices access
to the data.

Send data collection instruments. This will include preprinting
information on the front and last page of the data collection
instrument, printing a list of projects reported in the 2007 DWINSA for
systems that are selected to participate in the 2011 State DWINSA, and
sending the data collection instrument and additional material via FedEx
directly to the selected systems for the 2011 State DWINSA. For the 2011
Native American DWINSA, data collection instruments will be sent to the
EPA Regional Offices or Navajo Nation. 

Data Collection Activities

EPA will conduct the following activities during the data collection
phase of the 2011 DWINSA:

Provide technical assistance. The Agency will maintain a helpline
primarily to provide technical assistance to water systems (unless the
state prefers to do so). The helpline will promote consistent responses
across the country.

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

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

A.5.a.ii	EPA Regional Activities for the 2011 Native American DWINSA

EPA Regional Offices will help EPA Headquarters administer the 2011
Native American DWINSA with at least the minimum of activities. Support
will be provided for all American Indian (except for those water systems
under the primacy of the Navajo Nation) and Alaskan Native Village water
systems. 

EPA Regional Offices Up-Front Activities

This first activity category includes the EPA Regional Offices “fixed
burden” for helping EPA prepare for the 2011 Native American DWINSA. 

Participate in training and other pre-mailout efforts. This activity
includes participating in training sessions offered by EPA 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. Such data include PWSID,
system name, address, telephone numbers (if any), primary source,
population served, number of service connections, whether the facility
is a NPNCWSs, and whether the system is a consecutive system, To help
with this verification activity, EPA will provide the information that
must be reviewed in electronic form.

Perform miscellaneous administrative activities. EPA Regional Offices
will perform various administrative duties prior to the 2011 Native
American DWINSA (e.g., establishing system files). In addition, EPA
Regional management will explain the 2011 Native American DWINSA to
staff and allocate resources.

EPA Regional Offices Data Collection Activities 

EPA Regional Offices will conduct the following activities for the
American Indian water systems (except those water systems under the
primacy of the Navajo Nation) and Alaskan Native Village water systems
during the data collection phase:

Telephone systems to ensure participation. EPA Regional Offices will
contact the water system operators of systems selected in the 2011
Native American DWINSA to ensure participation and to schedule time to
discuss the systems 20-year need and review the completed data
collection instrument.

Review the IHS SDS projects. EPA Regional Offices will review the list
of projects extracted from the IHS SDS and incorporate appropriate
projects on to the 2011 DWINSA data collection instrument. 

Discuss 20-year need. EPA Regional Offices will contact the water
systems and discuss projects that have been identified, ask basic
questions about the physical design of the plant, system configuration,
and capital needs, and request additional documentation from the water
system. 

Complete the data collection instrument. Based on all the data collected
from IHS and the water system, EPA Regional Offices will complete the
data collection instrument and submit it to EPA. 

Discuss results with EPA. After the data collection instrument is
submitted, EPA will perform a quality control/quality assurance check to
ensure all data are documented and allowable. Any differences of opinion
regarding the documentation of the data will be resolved by EPA and EPA
Regional Offices. 

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 2011 DWINSA approach and the data collection instrument with the
assistance of a workgroup. As is explained in Section A.3.c, the
workgroup includes EPA Headquarters, EPA Regional, tribal, and state
representatives. The 2011 DWINSA approach and many of the refinements to
the data collection instrument were based on experience in conducting
the 1995, 1999, 2003, and 2007 DWINSAs. In addition, EPA will conduct a
peer review of the 2011 DWINSA data collection instrument. In developing
the 2011 DWINSA, EPA will select a set of appropriate assessment
objectives that are easily answerable by knowledgeable respondents.
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 2011 DWINSA objectives.

Methodology for 2011 State DWINSA – CWSs serving more than 3,300
persons

Most systems serving more than 100,000 persons have CIPs or similar
documents that summarize their needs. Therefore, these systems 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 every CWS that serves more than 100,000
persons. Clarifying information for completing the data collection
instrument will be available from the state or EPA. The experience of
states that participated in the previous DWINSAs indicates that systems
serving 3,301 – 100,000 persons 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. 

Also, systems that participated in the 2007 DWINSA and are selected to
participate in the 2011 DWINSA will receive a copy of their projects
from the 2007 DWINSA. These systems will be able to update the
information on the list and add new projects to the data collection
instrument. States will provide technical support to the systems
participating in the 2011 DWINSA by answering their questions. EPA will
also offer a helpline for state and system personnel.

EPA will send the data collection instrument directly 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. The state will then forward the data
collection instrument and supporting documentation to EPA for review and
data entry. EPA will perform a second quality control/quality assurance
check to ensure that all data are documented and allowable. EPA will
enter the data (for systems that did not use the electronic reporting
form) into the data system. States are provided access to the data
system and are able to 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 2011 State DWINSA. 

For projects that do not have cost estimates, EPA will model the costs.

Methodology for 2011 State DWINSA – CWSs serving 3,300 and fewer
persons

Due to funding limitations, data will not be collected in the 2011 State
DWINSA from CWSs serving 3,300 and fewer persons. Their needs will be
based on data collected during the 2007 DWINSA and updated to 2011
dollars.

Methodology for American Indian and Alaskan Native Village Water Systems


EPA Regional Offices and the Navajo Nation will use EPA, IHS, and tribal
resources to establish an estimate of need for the American Indian and
Alaskan Native Village water systems. To ensure that all appropriate
systems are addressed, EPA Regional Offices and the Navajo Nation will
review the inventory data in SDWIS and provide any updates or changes to
EPA Headquarters. The EPA Regional Offices and the Navajo Nation will
collect information on the projects needed by the selected systems over
the 20-year period and complete the data collection instrument. The
information will be collected on the same data collection instrument as
will be used for the 2011 State DWINSA. 

The data collection instruments will then be forwarded to EPA for review
and data entry. EPA will perform a quality control/quality assurance
check to ensure that all data are documented and allowable. EPA will
enter the data (for systems that did not use the electronic reporting
form) into the data system. If the EPA Regional Office or the Navajo
Nation 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,
EPA Regional Office, or Navajo Nation does not provide documentation,
the project or cost estimate will be deleted from the 2011 Native
American DWINSA. 

For projects that do not have a cost, the costs for American Indian
projects will be assigned using the models developed for the overall
2011 State DWINSA. For Alaskan Native Village projects will be modeled
using the costs model with adjustments to reflect unique construction
challenges in arctic areas. 

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,
the Navajo Nation, 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, EPA Regional, and Navajo
Nation staff involved in the 2011 DWINSA. The regional training sessions
will be designed to enable state, EPA Regional, and Navajo Nation 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, treatment,
transmission, distribution, and storage.

Discussing policies and documentation requirements.

Completing the 2011 DWINSA data collection instrument. 

EPA will develop materials for distribution to state, EPA Regional, and
Navajo Nation personnel who are unable to attend regional training
sessions. 

In addition to the training sessions, EPA will provide support for a
helpline for state, EPA Regional, Navajo Nation, and water system
personnel. It is anticipated that the helpline will be used primarily to
provide information to the EPA Regions, Navajo Nation, and states and
that they 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
2011 DWINSA. The costs of projects without a cost estimate will be
modeled by EPA. 

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 Regional Offices, and Navajo Nation. EPA will
rely on the states, EPA Regional, Offices, and the Navajo Nation to help
ensure data quality. Sixteen states will not participate in the
statistical portion of the 2011 State DWINSA (i.e., collecting data from
systems serving 3,301 – 100,000 persons). However, all states that
have systems serving more than 100,000 persons will participate in the
census portion of the survey. EPA will ask the Association of State
Drinking Water Administrators (ASDWA) to communicate with the state
drinking water administrators to encourage their participation. EPA
believes that state review 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. 

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 data. 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 data 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 updated a Web-based data system for the 2007 DWINSA
that will be used for the 2011 DWINSA. The Web-based system includes a
data entry interface that allows the Agency and its contractor to input
data and allows states, EPA Regions, and the Navajo Nation 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, EPA Regions, and the Navajo Nation 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 not disclose the
identity of any respondent to the 2011 DWINSA. 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 (those serving 3,300 and fewer
persons) under states primacy will not be included in the 2011 State
DWINSA. EPA will use the results from the 2007 DWINSA adjusted to 2011
dollars. For NPNCWSs, EPA will use the 1999 DWINSA results as the
primary basis for the 2011 State DWINSA estimates. 

EPA will conduct a census of all American Indian and Alaskan Native
Village systems serving more than 10,000 and will select a random sample
of American Indian and Alaskan Native Village systems serving 10,000 and
fewer persons. Past experiences with the DWINSA has shown that many of
these systems cannot complete the data collection instrument. Instead of
mailing a data collection instrument to the water systems, EPA Regions
and the Navajo Nation will collect data and complete the data collection
instrument for the water systems.  

EPA anticipates that almost all of the systems serving 3,300 and fewer
(for the 2011 Native American DWINSA only) 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 December 1, 2010. EPA will send data collection
instruments to drinking water systems on January 2011. All systems
participating in the 2011 DWINSA will be asked to complete and return
the data collection instruments to their state 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 July 2011. Data for two-thirds of the
systems will be due within 6 months (by September 2011), and all data
will be due on November 2011. Exhibit A-5-1 summarizes the major
collection milestones.

Exhibit A-5-1 Collection Schedule

Task	Date

Information Collection Request Submitted to OMB	October 2010

EPA Selects Systems to be Included in State Samples	By September 2010

States Submit to EPA Contact Information to be Included on Return FedEx
Labels 	By December 2010

Training Sessions for States, EPA Regions, and the Navajo Nation	October
2010

Mail Out of Data Collection Instruments to Selected Systems or to EPA
Regions and the Navajo Nation	January 2011

Deadline Given to Systems to Return the Data Collection Instrument to
States	February 2011

1/3 of Sent Data Collection Instruments Returned by States, EPA Regions,
and the Navajo Nation to EPA	July 2011

2/3 of Sent Data Collection Instruments Returned by States, EPA Regions,
and the Navajo Nation to EPA	September 2011

All Sent Data Collection Instruments Returned by States, EPA Regions,
and the Navajo Nation to EPA	November 2011

No New Projects Will Be Accepted by EPA 	November 2011

No New Information on Submitted Projects Will Be Accepted by EPA	January
2012

All Information in the Data System Finalized	February 2012

Report to Congress Due	February 2, 2013



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 water system burden for the 2011 DWINSA is estimated to be
approximately 5,888 hours (approximately a total of 23,550 hours).
Exhibit A-6-9 shows the breakdown of the annual burden hours for CWSs by
system size in the 2011 State DWINSA. The basis for the burden estimates
are detailed below.

2011 State DWINSA – CWSs Serving More Than 50,000 Persons

The respondent burden for the systems serving more than 50,000 persons
consists of systems’ burden for completing the data collection
instrument. EPA estimates that the total unit burden is 10.42 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 2011 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 x 0.25) + (0.50 x 0.43)].

Complete data collection instrument. EPA estimates that technical staff
will take 3 hours to complete the infrastructure project table of the
data collection instrument. This estimate is consistent with EPA’s
experience with the previous DWINSAs. In addition, EPA estimates that 10
percent of the systems will have “green” or climate readiness
infrastructure projects and will take an additional 20 minutes (0.33
hours) to provide information on these projects. 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 4.33 hours per system. 

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

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	3.03	1.00	4.33

TOTAL	0.93	6.50	3.00	10.42



2011 State DWINSA – CWSs Serving 3,301 – 50,000 Persons

Exhibit A-6-2 shows the unit burden for 1,927 systems serving 3,301 –
50,000 persons. EPA estimates that each of these systems will take a
total of 6.81 hours to respond to the 2011 State 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 2011 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. The time required to review
system files, and collect and copy supporting documentation will vary
greatly. However, systems serving 3,301 – 50,000 persons typically
have less documentation than larger CWSs.  Therefore, EPA estimates 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 x
((0.50 x 0.25) + (0.50 x 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. In
addition, EPA estimates that 10 percent of the systems will have
“green” or climate readiness infrastructure projects and will take
an additional 20 minutes (0.33 hours) to provide information on these
projects. 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 2.5 hours per system.

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

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	2.03

2.50

TOTAL	1.10	4.72	1.00	6.81



2011 State DWINSA – CWSs serving 3,300 and fewer persons

EPA will adjust the 2007 DWINSA the need for CWSs serving 3,300 and
fewer persons to 2011 dollars for the 2011 State DWINSA. There will be
no burden for these systems. 

2011 Native American DWINSA – American Indian and Alaskan Native
Village Water Systems 

To minimize the burden on American Indian and Alaskan Native Village
water systems, EPA Regional and Navajo Nation personnel will complete
the data collection instrument for the water system using the
information from the IHS SDS and any additional information collected
from the respondent. Because the EPA Region and the  Navajo Nation are
collecting the information and completing the data collection
instrument, the burden imposed on the systems is small. EPA estimates
that the unit burden to these systems averages 3.25 hours per system.
Exhibit A-6-3 summarizes the burden for each activity.

Participate in an informational telephone call from the EPA Regional
Office or the Navajo Nation. Respondents will receive a call that
describes the purpose of the DWINSA. The telephone call should take
approximately 15 minutes (0.25 hours). Most American Indian and Alaskan
Native Village water systems are staffed by one technical person;
therefore, the entire burden falls with the technical labor category.

Answer basic questions posed by the EPA Regional Office or the Navajo
Nation. Respondents will be expected to answer very basic questions
about the physical design of the plant, system configuration, and
capital needs. EPA estimates that the burden to assist the EPA Regional
Office or Navajo Nation is 2 hours for half of the systems selected and
3 hours for the remaining systems. Thus, the average burden per system
is as follows:

[(2 x 0.5) + (3 x 0.5)] = 2.5 hrs /system

Collect and copy supporting documentation. Respondents will locate the
necessary supporting documentation in system files and copy it. It is
anticipated that these systems will have little onsite documentation and
that the EPA Regional or Navajo Nation personnel will develop the
documentation; therefore, the burden to the system is relatively small.
EPA estimates that 25 percent of the systems will not have any
documentation, 50 percent will need 30 minutes (0.50 hours), and 25
percent will need 1.0 hour. Thus, the average time per system is as
follows:

[(0.0 x 0.25) + (0.5 x 0.50) + (1.0 x 0.25)] = 0.5 hrs/system

Exhibit A-6-3 Estimated Unit Burden for American Indian and Alaskan
Native Village Water Systems

Activity	Estimated Burden (hours)

	Management	Technical	Clerical	Total

Participate in informational phone call

0.25

0.25

Answer questions posed by EPA Regional or Navajo Nation personnel

2.5

2.5

Collect and copy supporting documentation 

0.5

0.5

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 and the Navajo Nation will play an important role
in conducting the DWINSA—they will help EPA ensure that the 2011
DWINSA is completed and administered consistently nationwide. Note the
burden incurred by the EPA Regional Offices for supporting the 2011
Native American DWINSA is not discussed in this section; however, they
have the same role as the Navajo Nation. EPA Regional Offices’ burden
is discussed in section A.6.c.  Most state/Navajo Nation activities will
either involve using and reviewing data directly or facilitating EPA’s
use and review of data. For example, states and the Navajo Nation will
review SDWIS inventory information for the statistical sample and verify
that it is correct. States will help ensure a high response rate by
telephoning systems serving more than 3,300 persons before the 2011
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. To minimize the burden on American Indian water systems,
Navajo Nation personnel will complete the data collection instrument for
the water system using the information from the IHS SDS and any
additional information collected from the respondent. 

Given varying time and resource constraints, some states will
participate in the 2011 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 2007
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 2011 DWINSA, and other factors.
Exhibit A-6-4 summarizes the burden estimates for each of the activity
categories.

Exhibit A-6-4 Overall State/Navajo Nation Burden Summary

Activity Category	Estimated Burden

Up-Front Activities (States & Navajo Nation)	110 hours, plus 0.2
hours/system

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

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

Navajo Nation Burden for Systems	7.42 hours per system



Up-Front Burden

This activity category includes the state “fixed burden” for helping
EPA prepare for the 2011 DWINSA. The total burden for these activities
is 110 hours per state/Navajo Nation, 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 the Navajo Nation
and is not expected to depend on the number of systems. 

Help EPA verify SDWIS data. Based on past 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 and the Navajo Nation.

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

Activity	Estimated Burden

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

Help EPA verify SDWIS data	0.2 hours/system

Perform miscellaneous administrative activities	30 hours/state & Navajo
Nation

TOTAL	110 hours/state & Navajo Nation, plus 0.2 hours/system



State Burden for CWSs Serving More Than 50,000 Persons 

This section estimates the state burden for helping EPA conduct the 2011
State DWINSA for systems serving more than 50,000 persons 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 persons is
summarized in Exhibit A-6-6, 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 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.)

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 hour to answer.

Therefore, the state burden for providing technical assistance is
estimated at about 30 minutes (0.50 hours) per request [0.5 x 0.25 +
0.25 x 0.50 + 0.25 x 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 a few 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 2011 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 2011 DWINSA.
The time required for this review is difficult to estimate. States that
generate their own documentation for the 2011 DWINSA or add projects for
distribution or transmission projects are required to ensure that the
total pipe inventory section on the 2011 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 the 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 x 1.0].

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

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 CWSs Serving 3,301 – 50,000 Persons 

This section estimates the state burden for helping EPA conduct the 2011
State DWINSA for systems serving 3,301 – 50,000 persons 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 systems serving 3,301 – 50,000 persons 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.)

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 hour to answer.

Therefore, the state burden is estimated at about 45 minutes (0.75
hours) per request [1.5 x ((0.5 x 0.25) + (0.25 x 0.50) + (0.25 x
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 2011 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 2011 DWINSA and the
burden for this review is difficult to estimate. States that generate
their own documentation for the 2011 DWINSA or add projects for
distribution or transmission projects are required to ensure that the
total pipe inventory section on the 2011 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
Persons 

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 CWSs Serving 3,300 and Fewer Persons

The 2011 State DWINSA will use the 2007 DWINSA need for CWSs serving
3,300 and fewer persons adjusted to 2011 dollars. There will be no state
burden for these CWSs.

Navajo Nation Burden 

This section estimates the burden for the Navajo Nation to conduct the
2011 Native American DWINSA for systems under their primacy. Activities
include telephoning systems to ensure participation, gathering
information about the systems’ 20-year need, completing the data
collection instrument for the system, and discussing the results with
EPA. The Navajo Nation’s burden for activities associated with the
water systems is summarized in Exhibit A-6-7, which follows the activity
descriptions.

Contact selected water systems. The Navajo Nation will contact select
systems to explain the 2011 DWINSA and to schedule a time for a longer
discussion about the water systems 20-year need. The telephone call
should take approximately 15 minutes (0.25 hours). 

Gather Information from IHS and water systems. To minimize the burden on
American Indian water systems, Navajo Nation personnel will complete the
data collection instrument for selected water systems under their
primacy. EPA estimates that the Navajo Nation will use information from
the IHS SDS, any information they have on file regarding infrastructure
improvements, and additional information they collect from the water
system. EPA estimates that the burden to obtain information for half of
the systems selected is 2 hours and 10 minutes (0.17 hours) and 3 hours
and 10 minutes (0.17 hours) for the remaining systems. Thus, the average
burden per system is as follows:

[(2.17 x 0.5) + (3.17 x 0.5)] = 2.67 hrs /system

Complete the data collection. The Navajo Nation will complete the data
collection instrument based on the information they collected from IHS
and the water system. It is anticipated that these systems will have
little onsite documentation and that the Navajo Nation personnel will
develop the documentation of need for the system. EPA estimates the
average time per system is 4 hours.

Discuss results with EPA. To estimate the Navajo Nation 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 Navajo Nation 1 hour to resolve.

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

Exhibit A-6-8 Navajo Nation Unit Burden for Systems

Activity	Estimated Burden (hours per system)

Participate in informational phone call	0.25

Gather information on projects from IHS and water system	2.67

Complete data collection instrument	4

Discuss results with EPA	0.5

TOTAL	7.42



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 $796,729, 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 multiplied by
the  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 systems serving 50,000 and fewer persons and $31.26 in
2003 dollars for systems serving more than 50,000 persons. This rate has
been inflated to 2009 dollars using the Employment Cost Index. The
inflated rate is $31.30 for systems serving 50,000 and fewer persons and
$37.56 for systems serving more than 50,000 persons. 

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 Persons	0.93	6.50	3.00	914	9,523	$37.56
$357,684

Systems Serving 3,301 – 50,000 Persons 	1.10	4.72	1.00	1,927	13,123
$31.30	$410,750

American Indian and Alaskan Native Village Water Systems 	0	3.25	0	278
904	$31.30	$28,295

TOTAL	2.02	14.46	4.00	3,119	23,550

$796,729

Note:	The average burden per response is 7.55 hours (23,550/3,119). 

	Numbers may not add due to rounding.

A.6.b.ii	Cost to States and the Navajo Nation tc "	A.6.b.ii	Cost to
Primacy Agencies " \l 3 

Exhibit A-6-10 shows the annual costs to states and the Navajo Nation.
The cost burden for EPA Regional Offices is discussed in section A.6.c.
As previously discussed, all states and the Navajo Nation have committed
to help EPA administer the 2011 DWINSA with at least the minimum of
activities; specifically, the states and Navajo Nation will assist in
surveying 2,881 systems.  Based on EPA’s projection that all states
and the Navajo Nation will participate in the DWINSA, the cost to states
and the Navajo Nation is $1,042,313. The labor costs are based on an
average full time equivalent (FTE) cost of $86,029 including overhead,
which equates to approximately $41.36 per hour. This rate, which has
been inflated to year 2009 dollars, is based on the rate used in the
2007 DWINSA and is consistent with the rates used in ICRs recently
developed by the Agency.

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

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

Activity	Number of States/ Systems	Unit Burden	Total Burden

(hours)	Hourly Rate	Total Cost

Up-front	57	110 hours/state & Navajo Nation	6,270	$41.36	$259,327

	2,881	0.20 hours/system	576	$41.36	$23,823

State burden for systems serving more than 50,000 persons assessment	914
6.58 hours/system	6,014	$41.36	$248,739

State burden for systems serving 3,301 – 50,000 persons assessment
1,927	6.25 hours/system	12,044	$41.36	$498,140

Navajo Nation burden for systems	40	7.42 hours/system	297	$41.36	$12,284

TOTAL	25,201

$1,042,313



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, EPA Regions, and IHS, and is summarized in
Exhibit A-6-11. EPA will also bear the cost of contractor activities as
detailed in Exhibit A-6-11. Both exhibits distribute burden/costs among
Fiscal Years 2010, 2011, 2012, and 2013, 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 $157,629.
Assuming 2,080 hours per year, this equates to $75.78 per hour.

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) providing support to the 2011
State DWINSA. Assuming 2,080 hours per year, this equates to 2,912
hours.

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) providing support to the 2011
Native American DWINSA. Assuming 2,080 hours per year, this equates to
2,914 hours.

The average salary and benefits (i.e., PC&B) of the 2.8 FTEs is at the
GS 11, Step 5 level of $112,524. Assuming 2,080 hours per year, this
equates to $54.10 per hour.

Indian Health Service

Over the 4-year period, IHS Headquarters will expend a total of 0.1 FTEs
(e.g., an average of 0.03 FTEs per year over the 4 years). Assuming
2,080 hours per year, this equates to 208 hours.

The average salary and benefits (i.e., PC&B) of the FTEs is at the GS
13, Step 5 level of $157,629. Assuming 2,080 hours per year, this
equates to $75.78 per hour.

EPA Contractor(s)

Over the 4-year period, the EPA contractor(s) will expend a total of
36,510 hours of direct labor.

The EPA contractor(s) will provide this professional labor at a total
hourly rate, including all applicable indirect costs, of $78.06.	

Based on these assumptions, EPA estimates that the total burden/cost to
EPA and IHS for the DWINSA over the 4-year period is 48,368 hours and
$3,622,264. Over the 3-year ICR, the average annual hours would be
16,123 hours per year and $1,207,421 per year.  Exhibits A-6-11 and
A-6-12, however, provide greater detail on the estimated yearly
expenditures for the actual 4-year effort 

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

Fiscal Year	EPA Headquarters	EPA Regions	IHS	Total

	Hours	Cost	Hours	Cost	Hours	Cost	Total Hours	Total Cost

FY 2010	892	$67,596	1,594	$86,235	60	$4,547	2,546	$158,378

FY 2011	2,020	$153,076	2,334	$126,269	64	$4,850	4,418	$284,195

FY 2012	2,020	$153,076	1,452	$78,553	64	$4,850	3,536	$236,479

FY 2013	892	$67,596	446	$24,129	20	$1,516	1,358	$93,241

TOTAL	5,824	$441,344	5,826	$315,186	208	$15,763	11,858	$772,293



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

Activities	FY 10	FY 11	FY 12	FY 13	Total

	Hours	Cost	Hours	Cost	Hours	Cost	Hours	Cost	Hours	Cost

Planning	5,100	$398,106	2,000	$156,120	1,500	$117,090	300	$23,418	8,900
$694,734

Survey Design	200	$15,612	0	$0	0	$0	0	$0	200	$15,612

Peer Review	140	$10,928	0	$0	0	$0	0	$0	140	$10,928

Modeling	0	$0	282	$22,013	1,994	$155,652	960	$74,938	3,236	$252,602

Data Development	300	$23,418	800	$62,448	300	$23,418	300	$23,418	1,700
$132,702

Survey Production	500	$39,030	945	$73,767	0	$0	0	$0	1,445	$112,797

Data Analysis	0	$0	11,729	$915,566	2,533	$197,726	0	$0	14,262	$1,113,292

Report Writing	0	$0	208	$16,236	1,459	$113,890	700	$54,642	2,367
$184,768

Statistical Analysis	0	$0	94	$7,338	656	$51,207	750	$58,545	1,500
$117,090

Tech Assistance	0	$0	960	$74,938	200	$15,612	200	$15,612	1,360	$106,162

Training	500	$39,030	900	$70,254	0	$0	0	$0	1,400	$109,284

Total	6,740	$526,124	17,918	$1,398,679	8,642	$674,595	3,210	$250,573
36,510	$2,849,971

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, NPNCWSs (in the 2011 Native
American DWINSA), states, and the Navajo Nation. This ICR estimates that
the number of CWS and NPNCWSs respondents is 3,119. In addition to the
CWS and NPNCWSs respondents, this ICR assumes 56 states (50 states plus
the District of Columbia and the U.S. Territories) and the Navajo
Nation. Therefore, the total number of respondents is 3,176. The total
costs and burden for these respondents are detailed in Exhibits A-6-13
and A-6-14.

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, NPNCWSs, states, and the Navajo Nation for this collection. The
total burden is 48,751 hours at a cost of $1,839,042. 

Exhibit A-6-13 Bottom Line Respondent Burden 

Respondent Type	Burden Hours	Total Cost

Water Systems	23,550	$796,729

States and Navajo Nation	25,201	$1,042,313

TOTAL	48,751	$1,839,042



Over the 3-year ICR, the average annual burden would be 16,250 hours and
the average annual cost would be $613,014 per year.   However, Exhibit
A-6-14 summarizes more specifically the estimated burden hours and costs
for CWSs, NPNCWSs, states, and the Navajo Nation for each year of the
4-year survey. It is estimated that the CWSs and NPNCWSs will complete
the data collection instrument in 2011. It is estimated that states and
the Navajo Nation will conduct the Up-Front Activities in 2010 and the
Data Collection Activities in 2011. 

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

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

	2010	2011	2012	2013	2010	2011	2012	2013

Water systems	0	23,550	0	0	$0 	$796,729	$0 	$0 

States and the Navajo Nation	6,846	18,355	0	0	$283,151	$759,163	0	$0 

TOTAL	6,846	41,905	0	0	$283,151	$1,555,892	0	$0 

Average per Respondent	2.16	13.19	0	0	$89 	$490	0	$0 



Exhibit A-6-15 summarizes the bottom line burden hours and costs for EPA
for this collection. The total burden for EPA (including EPA Regional
Offices), IHS, and EPA’s contractor is 48,368 hours at a cost of
$3,622,264.

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

Respondent Type	Burden Hours	Total Costs

EPA	11,650	$756,530

IHS	208	$15,763

Contractor	36,510	$2,849,971

TOTAL	48,368	$3,622,264



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, tribal owned CWSs and NPNCWSs, state government agencies and
tribal authorities (the Navajo Nation). 

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 Persons	Publicly Owned CWSs	771 	10.42	 8,033 
$37.56	 $ 301,719 	 $391 

	Private/Investor Owned CWSs	 105 

 1,094 

 $ 41,091 



State Owned CWSs	 38 

 396 

 $ 14,874 



Tribal Owned CWSs & NPNCWSs	 - 

 - 

 $ - 



Subtotal	 914 

 9,523 

 $ 357,684 

	Serving 3,301 to 50,000 Persons	Publicly Owned CWSs	 1,727 	6.69	
11,761 	 $31.30	 $ 368,119 	$209

	Private/Investor Owned CWSs	 173 

 1,178 

 $ 36,871 



State Owned CWSs	 27 

 184 

 $ 5,759 



Tribal Owned CWSs & NPNCWSs	 67 

 218 

 $ 6,823 



Subtotal	 1,994 

 13,341 

 $ 417,572 

	Serving 3,300 and Fewer Persons	Publicly Owned CWSs	 - 	3.25	 - 	
$31.30	 $ - 	$102 

	Private/Investor Owned CWSs	 - 

 - 

 $ - 



State Owned CWSs	 - 

 - 

 $ - 



Tribal Owned CWSs & NPNCWSs	211 

686

 $ 21,472 



Subtotal	 211 

 686 

 $ 21,472 

	Total Water System Respondents

	Publicly Owned CWSs	 2,498 	 7.92 	 19,794 

 $ 669,838 	 $ 268 

	Private/Investor Owned CWSs	 278 	 8.17 	 2,272 

 $ 77,962 	 $ 280 

	State Owned CWSs	 65 	 8.92 	 580 

 $ 20,633 	 $ 317 

	Tribal Owned CWSs & NPNCWSs	 278 	 3.25 	 904 

 $ 28,295 	 $ 102 

	Subtotal	 3,119 	7.55 	 23,550 

 $ 796,728 	 $ 255 

Total State Government Respondents 	 56 	 442.61 	24,786	$ 41.36	
$1,025,149 	 $ 18,306 

Total Tribal Authority Respondents	 1 	 415.00 	415

 $ 17,164 	 $ 27,164 

Total Respondents	3,176 	 15.35 	48,751

 $ 1,839,042 	$ 579

Note: Numbers may not total due to rounding. 

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 2011 DWINSA is estimated to be 48,751 hours, of which 23,550
hours are attributable to water systems and 25,201 hours to states and
the Navajo Nation. 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 15.35 hours per response. Respondent burden for the water system
is 7.55 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.

Please send comments on the Agency’s need for this information,
accuracy of the burden estimates, and any suggested methods for
minimizing respondent burden, including the use of automated collection
techniques to Director, Office of Environmental Information, Collection
Strategies Division, U.S. Environmental Protection Agency (2822T), Ariel
Rios Building, 1200 Pennsylvania Ave., N.W., Washington, D.C. 20460; and
to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17th Street, NW, Washington, DC 20503,
Attention: Desk Officer for EPA. Please include the EPA ICR number and
OMB control number in any correspondence.	

This page intentionally left blank.

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 2011 State 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 is proposing the same methodology for collecting data
for CWSs serving more than 3,300 persons as was used in the 2007 DWINSA.
No revision to that methodology has taken place. Due to budgetary
constraints, EPA is not currently proposing to collect additional data
from CWSs serving 3,300 and fewer. For the 2011 Native American DWINSA,
EPA proposes a national sample for American Indian systems and a
separate sample for Alaskan Native Village water systems. EPA also
proposes EPA Regions and the Navajo Nation collect the information for
these systems. 



2011 STATE DWINSA

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 2011 DWINSA is to collect information from
water systems 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, Navajo Nation, or EPA Regional
specific estimates of water systems’ 20-year need. EPA has established
policies to ensure that the overarching goals of the survey are met: 

Estimate the total national 20-year need. 

Estimate the total 20-year need for each participating state/Navajo
Nation/EPA Region. 

Provide complete and accurate data to Congress. 

Provide a tool to fairly distribute DWSRF capitalization funds to states
and the Tribal Set-Aside (TSA) Program. 

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” include raw water
source, transmission, source water treatment, storage, distribution,
pumping stations, and other needs. EPA will also collect information on
“green” and climate readiness infrastructure projects.

EPA will use the information from the DWINSA to project capital
investment requirements of drinking water systems. The information will
be used to allot DWSRF monies among states and as part of an allotment
formula for the DWSRF TSA Program. 

EPA is proposing the same methodology as used in previous DWINSAs. No
significant changes were made for the 2011 State DWINSA from the
approach used in 2007. The sampling design will be discussed in detail
below. The sampling design for the 2011 Native American DWINSA is
discussed in a separate section 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 2011 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; reason for
need; documentation of need and cost (if necessary); if the project is a
new project or to replace, rehabilitate or expand  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, state requirement, or is for
“green” or climate readiness; design capacity of source, storage,
and treatment projects; length and diameter of pipe projects; diameter
for projects such as water meters; cost of the project; and date of the
cost estimate. For most of these variables, respondents will choose the
appropriate “documentation,” “type of need,” “reason for
need” or “regulation or requirement” from a Lists of Codes. EPA
will also collect information on “green” and climate readiness
infrastructure projects. For each project, the respondent will identify
if it is considered a “green” project or if it is a climate
readiness infrastructure project by selecting a code from List 3 in the
Lists of Codes. In addition, the data collection instrument includes
additional questions for systems that include climate readiness projects
in their data collection instrument. 

The principal variable of interest is total projected capital needed for
each water system in the 2011 DWINSA for the time period 2011 – 2030.
The total capital need for all systems in each state/Navajo Nation/EPA
Region (to be derived from the statistical sample of systems) is the key
variable that decision-makers at EPA use to allocate funds to states and
the TSA Program 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) on a
project-by-project basis. 

Information on type of need will be used to disaggregate total capital
needs for EPA’s Report to Congress. Information on the reason for 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, state requirements, and/or
identify if the project is “green” or for a climate readiness need. 

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 2011 State DWINSA is being designed to achieve a desired level of
precision for state-level estimates of total capital needs for systems
serving more than 3,300 persons. EPA proposes a survey of a statistical
sample to estimate total capital needs. This statistical approach
minimizes burden while achieving the desired level of precision. 

The 2011 State DWINSA design divides CWSs serving populations of more
than 3,300 into two groups: CWSs serving populations of more than
100,000, and systems serving populations of 3,301 – 100,000. EPA
proposes to sample with certainty systems serving more than 100,000
persons. These systems have the largest capital needs and they have the
staff to respond efficiently to the 2011 State DWINSA. EPA proposes to
draw a random sample of systems serving 3,301 – 100,000 persons. 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. 

EPA is designing and conducting the 2011 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 2011 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. EPA convened a
workgroup (see Section A.5.b) to comment on the proposed data collection
and its feasibility. The data collection instrument to be used for the
2011 DWINSA is generally the same form as used for the past DWINSA. For
those assessments, 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 Agency recognizes that most systems serving fewer
than 50,000 persons and some that serve 50,000 or more may not have cost
data or documentation of costs for some projects. In those cases, the
2011 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 2011 DWINSA. In addition, EPA (or states) will
provide systems with a helpline to assist them in completing the data
collection instrument.

EPA has developed cost models for most of the infrastructure needs
included in the 2011 DWINSA based on the size and capacity of a project.
These cost models were developed during the 2007 DWINSA and will be used
again for the 2011 DWINSA. New cost models may be developed for weak
cost models, influential cost models, and new technology.

The time frame for the 2011 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 2013. 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.

The sample design for the 2011 State DWINSA is stratified random
sampling within each state. In cases where the state is not
participating in the data collection for systems serving 3,301 –
100,000 persons, EPA will only be able to provide state specific results
for systems serving more than 100,000 persons and systems serving 3,300
and fewer persons (using the results from the 2007 DWINSA). EPA will
include an overall national result for the systems serving 3,301 –
100,000 persons using the average need by strata of the systems in
states that are participating in the full 2011 State DWINSA. 

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 sources of supply (surface and ground). Systems
serving more than 100,000 persons 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 2011 DWINSA’s data quality objectives. 

EPA’s precision target for the 2011 State DWINSA  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 persons 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.

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

The target population for the 2011 State DWINSA is the number of 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 2011 State DWINSA is designed to produce
estimates of the capital need of systems serving more than 3,300 persons
for each participating state. In non- participating states, EPA will be
able to provide state specific results for systems serving 100,000 or
more persons. EPA will include an overall national result for the
systems serving 3,301 – 100,000 persons using the average need by
strata of the systems in participating states and the total number of
systems by strata in the non-participating state. The 2011 State DWINSA
is designed to produce estimates of the capital need of systems serving
3,300 and fewer persons for the nation as a whole using the results of
the 2007 DWINSA. 

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 2011 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 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 2011 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 2011 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 2011
DWINSA design anticipates substantial state/Navajo Nation/EPA Region
involvement in the 2011 DWINSA process. They, for example, will be
checking the sample frame of systems that will be used to determine the
final sample. In EPA’s experience, they often have in-house data
systems with very accurate data. Even if these data are not transmitted
to SDWIS, they are available and can be used by states/Navajo Nation/EPA
Regions to check the sample frame. 

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

Exhibit B-2-1 at the end of this subsection shows the preliminary sample
sizes for the 2011 State DWINSA. As shown on this exhibit, the sampling
design will be implemented to achieve state-level precision targets for
CWSs serving more than 3,300 persons. 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 2007 DWINSA) 

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

α 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 system serving more than
100,000 strata in the sample design.)

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 2007 DWINSA.

Exhibit B-2-1 State Sample Sizes

State	Total Number Of Systems Serving More Than 3,300 Persons 	Estimated
Sample Size For Systems Serving More Than 3,300 Persons

Alaska *	                               19 	                            
      1 

Alabama	                             348 	                              
131 

Arkansas	                             181 	                             
   83 

American Samoa	                                 1 	                     
             1 

Arizona	                             130 	                              
  39 

California	                             688 	                           
   169 

Colorado	                             169 	                             
   61 

Connecticut	                               57 	                         
       36 

District of Columbia	                                 1 	               
                   1 

Delaware *	                               30 	                          
        3 

Florida	                             387 	                              
128 

Georgia	                             237 	                              
  66 

Guam	                                 3 	                               
   3 

Hawaii *	                               30 	                            
      2 

Iowa	                             138 	                                
53 

Idaho *	                               50 	                             
     1 

Illinois	                             460 	                             
   98 

Indiana	                             214 	                              
  82 

Kansas	                             117 	                               
 65 

Kentucky	                             259 	                             
 141 

Louisiana	                             231 	                            
    65 

Massachusetts	                             253 	                        
        73 

Maryland	                               59 	                            
    26 

Maine 	                               35 	                              
  25 

Michigan	                             303 	                             
   63 

Minnesota	                             181 	                            
    91 

Missouri	                             216 	                             
 121 

Northern Mariana Islands	                                 2 	           
                       2 

Mississippi	                             202 	                          
    105 

Montana *	                               35 	                           
       1 

North Carolina	                             274 	                       
         80 

North Dakota *	                               32 	                      
          -   

Nebraska *	                               43 	                          
        2 

New Hampshire *	                               39 	                     
             1 

New Jersey	                             242 	                           
     61 

New Mexico *	                               60 	                        
          1 

Nevada *	                               34 	                            
      4 

New York	                             362 	                             
   50 

Ohio	                             320 	                                
90 

Oklahoma	                             165 	                             
   86 

Oregon	                             116 	                               
 54 

Pennsylvania	                             349 	                         
       83 

Puerto Rico	                             118 	                          
      58 

Rhode Island *	                               28 	                      
            3 

South Carolina *	                             159 	                     
             9 

South Dakota *	                               45 	                      
            2 

Tennessee	                             288 	                            
  158 

Texas	                             986 	                              
138 

Utah 	                             109 	                                
50 

Virginia	                             157 	                             
   56 

Virgin Islands	                                 2 	                     
             2 

Vermont *	                               34 	                           
     -   

Washington	                             213 	                           
     58 

Wisconsin	                             181 	                            
    58 

West Virginia *	                             110 	                      
            1 

Wyoming *	                               27 	                           
     -   

Total	                          9,529 	                           2,841 

*Sixteen states will not participate in the statistical portion of the
survey (i.e., collecting data from systems serving 3,301 – 100,000
persons). However, those states that have systems that serve more than
100,000 people will participate in the census portion of the survey
(i.e., collecting date from systems serving more than 100,000 persons).
For those 16 states, the number in the “Estimated Sample Size for
Systems Serving More Than 3,300 Persons” represents the total number
of systems in the state that serve more than 100,000 persons.

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 2007 DWINSA, EPA evaluated several classification schemes. This
analysis showed that the stratification scheme selected for the 2011
State DWINSA (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 2011State DWINSA’s overall precision is not
reduced. The proposed strata for systems serving more than 3,300 persons
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

	

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 eight 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 3,125. 

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 the 2011 State DWINSA 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. EPA
also set the precision level for the estimate of need for each of the
strata to be 95 percent confident that its estimate of need is within 30
percent of the actual need.

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. 

Particular emphasis will be placed on maximizing response rates.
Standard methods that have proved effective in other surveys of water
systems 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 2011 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 surveys 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 water systems. In addition, the
data collection instrument design, content, and format were reviewed by
states that participated in the 1995, 1999, and 2003, and 2007 DWINSAs. 

Items being asked are those that owners or operators of systems 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 believes that the average water
system respondent can complete the data collection instrument in
approximately 7.55 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/Navajo Nation/EPA Regional Office 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 water systems. These
organizations believe that the 2011 DWINSA is important and that a high
level of participation by all water systems is essential to its success.
Because of the substantial commitment being made by states and water
systems to the 2011 DWINSA, EPA believes that response rates will be
higher than most surveys of similar respondents. To ensure success,
states and organizations representing water systems are taking the
following steps. 

Participation of the states/Navajo Nation/EPA Regions. Because the
DWINSA will be used to allocate DWSRF funds to states and TSA monies to
the Navajo Nation and EPA Regions, each entity has a strong interest in
achieving a high response rate. EPA believes that their participation
will be a key factor in guaranteeing high response rates and low item
non-response. Personnel who work with water systems every day are in a
strong position to encourage systems to complete the 2011 DWINSA form.
These states, the Navajo Nation, and EPA Regions have committed to
assisting EPA in achieving a high response rate by participating in
follow-up activities. The states, the Navajo Nation, and EPA Regions
also will be available for technical assistance for any system that has
questions about the 2011 DWINSA. 

Participation of Organizations Representing Water Systems. EPA
anticipates public support of organizations representing water systems.
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
2011 DWINSA can be helpful in many ways to minimize non-sampling errors.
For example,

In past DWINSAs, national water associations sent letters to each system
in their membership, stressing the importance of  surveying  drinking
water infrastructure needs. These letters, along with the letter from
the states, helped convince  water systems to respond.  EPA will seek
similar support from these associations for the 2011 Survey effort.

In the past DWINSAs, the largest association representing water systems
serving populations greater than 3,300—AWWA— provided support
through its national organization. To improve the response rate, the
AWWA enlisted the support of its state affiliates (called
“Sections”) to conduct telephone follow-up calls to encourage
response. AWWA assisted in past DWINSAs to help achieve the overall
response rate of 94 percent. EPA will seek similar support from AWWA in
support of the 2011 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) water systems. 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 2011 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 2011 DWINSA is based on matrices that request a list of capital
projects that the system plans for the period 2011 through 2030. For
each project listed, the system is asked to provide: type of need;
reason for need; documentation of need and cost (if necessary); if the
project is for new infrastructure or to replace, rehabilitate or expand
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, state requirement, or is for
“green” or climate readiness; design capacity of source, storage,
and treatment projects; length and diameter of pipe projects; diameter
for projects such as meters; cost of the project; and date of the cost
estimate. EPA will also collect information on “green” and climate
readiness infrastructure projects. For most of these variables,
respondents will choose the appropriate “documentation,” “type of
need,” “reason for 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. 

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 

For the 2007 DWINSA the data collection instrument and some policies
were modified substantially. Since the only significant modification to
the 2011 data collection instrument was the addition of questions and
codes to gather information on “green” and climate readiness
infrastructure projects, EPA will conduct a limited peer review of these
new questions, however, EPA will not conduct a pre-test of the 2011
DWINSA data collection instrument. 

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 were both non-participating states and because most of
their systems did not 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 2007
DWINSA state 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 water systems, it has been
decided that no pilot test for the 2011 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, 2003, and 2007 DWINSAs. EPA believes these procedures are
well tested and have proven to be successful; therefore, it is not
necessary to repeat this testing step. 

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 is a mail survey. The 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.

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 2011 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, 96, and 93 percent were achieved in the 1995, 1999, 2003, and
2007 surveys, respectively. In the first four surveys, EPA conducted the
following proposed activities to achieve that high response rate. 

Seek Support from the Respondent Population. This is a national survey
of infrastructure needs for drinking water systems.  EPA will work to
bring to the attention of water systems, as well as all national
organizations representing these systems, the importance of the DWINSA
results. As with the previous four surveys,  all national organizations
will be contacted by EPA to seek their endorsement of the DWINSA and to
communicate to their members the importance of a high response rate to
their members. As discussed in Section B.2.c, in past surveys,
organizations have provided access to their newsletters and magazines to
publicize and endorse participation in the DWINSA; for the 2011 Survey,
EPA will seek similar efforts by these organizations.

Follow-up by States and Respondent Peer Groups. Since a majority of
participating states have indicated their willingness to participate in
follow-up activities, EPA has requested that  state personnel, most of
whom are personally familiar with the respondents, conduct follow-up 
procedures including the use of reminder letters and telephone calls. 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-up calls), EPA
is planning to shift to a second approach of peer-group follow-up by
members of a trade association, such as AWWA. 

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 water systems will be weighted so that stratum estimates
can be summed to prepare state-level estimates for the 2011 State DWINSA
and national estimates for the 2011 Native American DWINSA.

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

EPA will prepare a report that tabulates the results of the 2011 DWINSA
and explains the precision of the estimates of total capital needs.
Examples of statistics that will be produced include:

Total capital needs by state/Navajo Nation/EPA Region and by types of
need.

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

Standard errors calculated for key statistics.

The analysis will be similar to that of previous DWINSAs.

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

The 2011 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 made available to all
participants in the 2011 DWINSA and the public through EPA’s Safe
Drinking Water website. 

Desktop computer access to state/Navajo Nation data on the DWINSA Web
site without modeled project costs (each state/Navajo Nation can access
only its own data).

Desktop computer access to the entire data system (EPA only).

A report providing the cost models used to develop costs for the 2011
DWINSA will be made available to EPA and the public through EPA’s Safe
Drinking Water Web site.

2011 NATIVE AMERICAN DWINSA

Introduction

In the following paragraphs, we present information on the survey of
American Indian and Alaskan Native Village water systems. This
discussion includes only those sections of Part B where the approach is
different from the approach being used for the 2011 State DWINSA as
previously discussed.

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

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

The 2011 Native American DWINSA is designed to estimate the total
capital needs of American Indian systems for the nation as a whole and
for Alaskan Native Village systems. EPA proposes a survey of a
statistical sample to estimate total capital needs. This statistical
approach minimizes burden while achieving the desired level of
precision. 

However, a mail survey is not an effective approach to the collection of
data from these water systems. Experience with mail surveys for these
systems suggests that total non-response and item non-response would be
very high. Also, EPA believes that the absence of knowledgeable
respondents at these systems limits the general reliability of the
responses. The best way to gather information from these systems is
through direct contact by the EPA Regions or the Navajo Nation. 

B.2 	SURVEY DESIGN 

The design for the 2011 Native American DWINSA, like that for the 2011
State DWINSA, is stratified random sampling. The stratification
variables for these systems are the same as those for other systems:
size of population served and primary source of supply. However, unlike
the 2011 State DWINSA, the 2011 Native American DWINSA will select two
separate samples: 1) American Indian systems in the continental U.S.,
and 2) Alaskan Native Village systems. Stratification variables for both
samples include population size (populations of: 25 – 500; 501 –
1,000; 1,001 – 3,300; 3,301 – 10,000; and populations of more than
10,000), and primary sources of supply (surface and ground). Systems
serving more than 10,000 persons are selected with certainty.

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

The target population is CWSs and not-for-profit noncommunity water
systems (NPNCWSs) that have been designed as Native American. A CWS is a
public water system that serves at least 15 service connections used by
year-round residents or regularly serves at least 25 year-round
residents. A NCWSs is a “public water system that is not a community
water system and that regularly serves at least 25 of the same persons
over 6 months per year” (nontransient noncommunity water system) or is
a public water system that is not a community water system and “does
not regularly serve at least 25 of the same persons over six months per
year” (transient noncommunity water system). (40 CFR 141.2)

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

B.2.b.ii	Sample Size

The procedures proposed for designing a sample size for the 2011 Native
American DWINSA is the same as that proposed for 2011 State DWINSA.
Equations 1, 2, and 3 still apply, except that a national sample size
will be selected instead of state-by-state samples and data from the
1999 DWINSA will be used instead of data from the 2007 DWINSA for the
standard deviation of the variable of interest.

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

As with the design for the 2011 State DWINSA, the sample design for the
2011 Native American DWINSA is stratified on the basis of (1) size
(number of persons served by the CWS or NPNCWS), and (2) primary source
(ground water and surface water). 

The proposed strata are as follows:

Size of Population Served	Source	Sample Methodologies

25 – 1,000	Ground	Random sample. 

25 – 1,000	Surface

	1,001 – 3,300	Ground

	1,001 – 3,300	Surface

	3,301 – 10,000	Ground

	3,301 – 10,000	Surface

	More than 10,000	Ground	Sampled with certainty

More than 10,000	Surface

	

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

As indicated above, all systems serving populations of more than 10,000
will be sampled with certainty. 

For systems serving 25 – 10,000 persons, all systems will be allocated
to six strata based on population served and primary source. The sample
size for each stratum 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 is 90 percent,
EPA will draw a sample of 220 American Indian water systems and 89
Alaskan Native Village water systems. 

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 the 2011 Native American DWINSA will be
implemented at the national level for American Indian water system and
for the State of Alaska for Alaskan Native Village water systems.
EPA’s goal is to be 95 percent confident that the margin of error,
when estimating the total capital needs facing these systems nationally
(for American Indian water systems) and at the state (for Alaskan Native
Village water systems), will be plus or minus 10 percent of the total
need for these systems. 

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 the 2011 Native American DWINSA is
for the EPA Region or the Navajo Nation to first preliminarily fill out
the data collection instrument for each system in the sample based on
information obtained from IHS and the water systems records.  The Navajo
Nation or EPA Region will then contact each system and interview the
respondent to identify possible additional projects and to concur on the
final set of identified infrastructure investment needs.   By having the
EPA Regions and the Navajo Nation conducting the survey in this manner
for American Indian and Alaskan Native Village water systems, the
information collection burden on these water system respondents will be
minimized. This page intentionally left blank.

Appendix A 

Public Notice Required Prior to ICR Submission to OMBThis page
intentionally left blank.

Appendix B

Data Collection Instrument and Lists of CodesThis page intentionally
left blank.

Appendix C

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

This page intentionally left blank.

 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.”

 NPNCWSs are also eligible for DWSRF funding.

 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. 

 See Exhibit A-6-9.

 List 1 of the List of Codes are the same for the 2011 State DWINSA and
the 2011 Native American DWINSA, except the 2011 Native American DWINSA
will have 5 extra Type of Need codes. This is consistent with the codes
used for systems serving 3,300 and fewer persons in the 2007 DWINSA.
Both List of Codes are included in Appendix B. 

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

 Fifty-seven includes the 50 states plus the District of Columbia,
Puerto Rico, Northern Mariana Islands, American Samoa, Guam, the U.S.
Virgin Islands, and the Navajo Nation. 

 The total number of systems in the 2011 DWINSA is 3,119 systems. The
number of systems shown is the number of total systems selected for the
2011 DWINSA minus the American Indian and Alaskan Native Village systems
supported by the EPA Regional offices; the burden for these systems is
addressed in the Agency burden section in A.6.c.  The number, however,
includes the 40 American Indian water systems to be surveyed by the
Navajo Nation primacy agency.

 Hourly rates are from U. S. Office of Personnel Management, 2010
General Schedule (GS) Locality Pay Tables
(http://opm.gov/flsa/oca/10tables/indexGS.asp) and overhead rates are
from Information Collection Request for Public Water Supply Program,
December 20, 1993.

 For this ICR, the number of responses is calculated at 3,176 (914
systems serving more than 50,000 people, 1,994 systems serving 3,301 –
50,000 people, 211 serving 3,300 and fewer people, 1 tribal authority,
and 56 states and U.S. Territories). The burden per response is
calculated as the total respondent burden (48,751) divided by the number
of responses (3,176). 

 See Exhibit A-6-9.

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Techniques (New York: John Wiley & Sons), 1977. 

 For the purposes of the 2011 DWINSA, purchased surface water systems
are included with ground water systems. This design yields lower
within-stratum variance.

ICR for 2011 DWINSA 	  PAGE  iv 	July 29, 2010

ICR for 2011 DWINSA 	  PAGE  26 	July 26, 2010

ICR for 2011 DWINSA 	  PAGE  38 	July 26, 2010

ICR for 2011 DWINSA 	  PAGE  40 	July 26, 2010

ICR for 2011 DWINSA 	  PAGE  42 	July 26, 2010

ICR for 2011 DWINSA 	  PAGE  92 	July 26, 2010

