Clean Watersheds Needs Survey

Office of Wastewater Management

EPA ICR Number 0318.12

OMB CONTROL NUMBER 2040-0050

August 2010
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SUPPORTING STATEMENT

A. JUSTIFICATION

SECTION 1 IDENTIFICATION OF THE INFORMATION COLLECTION

TITLE: Clean Watersheds Needs Survey (CWNS) (Renewal) 

ICR NUMBER: 0318.12

OMB Control Number: 2040-0050

ABSTRACT:

The Clean Watersheds Needs Survey (CWNS) is required by Clean Water Act (CWA) Sections 

205(a) and 516. It is a periodic inventory of existing and projected publicly owned wastewater 

treatment works (POTWs) and other water pollution control facilities in the United States, as 

well as an estimate of how many POTWs need to be built. The CWNS is a joint effort of EPA 

and the States. The Survey records cost and technical data associated with POTWs and other 

water pollution control facilities, existing and projected, in the United States. The State 

respondents who provide this information to EPA are State agencies responsible for 

environmental pollution control. No confidential information is used, nor is sensitive 

information protected from release under the Public Information Act. EPA achieves national 

consistency in the final results through the application of uniform guidelines and validation 

techniques.
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SECTION 2 NEED FOR AND USE OF THE COLLECTION

NEED FOR THE COLLECTION:

EPA provides an estimate of POTWs construction and other water pollution control requirements 

for each State, Territory, and the District of Columbia to Congress under CWA Section 516, 

which says in part: “The Administrator in cooperation with the States, including water pollution 

control agencies and other water pollution control planning agencies, shall make (a) a detailed 

estimate of the cost of carrying out the provisions of this Act; (b) a detailed estimate, biennially

revised, of the cost of construction of all needed POTWs in each of the States.”

Further, CWA Section 604(a) states the Clean Water State Revolving Funds shall be allocated in 

accordance with CWA Section 205. CWA Section 205 provides that allotments shall be made 

only in accordance with a revised cost estimate made and submitted to Congress in accordance 

with CWA Section 516 and only after such revised cost estimate shall be approved by law 

specifically enacted hereafter.

USE OF THE COLLECTION:

In addition to CWA Section 205 uses of the data for funds allotment, Congress utilizes the data 

to assist deliberations on specific legislation and funding measures related to water pollution 

control. Additional uses of the data include:

 Local, state, and other uses of the data for NPDES permit writing, Total Maximum Daily

Load analyses, and other environmental program support

 Wastewater treatment technology and environmental measures support related to EPA’s 

Sustainable Infrastructure Initiative

 Private industry efforts to target technical support for facilities 

 Baseline data for EPA, Department of Homeland Security, and other agencies for use in 

more specialized reports and for providing program focus.

At the end of each CWNS, a report is written and published highlighting the national results of 

the survey and describing the methodology used to collect, document, and quality assure all of 

the State data included therein. The Report includes many tables and graphs. The appendices of 

the Report are detailed state-by-state and national summary tables. The Report and the detailed 

graphs and tables are publicly available at http://www.epa.gov/cwns/. 

SECTION 3 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

NONDUPLICATION: 

EPA avoids duplication of effort in a number of ways. To begin each new Survey, EPA provides 

each State their exact inventory of data from the preceding survey to update and revise, with 

EPA updating only the cost data for inflation. States also have access to technical and cost data 

contained in the CWNS data system from previous Surveys. This eliminates the need for States 

to provide information which has already been approved and ensures national consistency. 

States and EPA Regions are informed of the data and document update procedures at the CWNS 

Kickoff Meeting and via web seminars and other electronic communications. 
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The new Data Entry Portal for CWNS 2008 was developed in the EPA Enterprise Portal to

provide many features that avoid duplication of effort. The system provides ability to:

 Transfer wastewater discharge permit data from EPA’s Permit Compliance System and 

EPA’s Integrated Compliance Information System directly into the CWNS 2008 data 

system,

 Click on locations in the internet WATERS Lite Viewer mapping tool and have the location 

data transferred into the CWNS 2008 data system, 

 Incorporate data from EPA’s Impaired Waters and Clean Water State Revolving Fund 

Benefits databases, 

 Have local communities update their CWNS information, and

 Upload and comment upon documents to minimize effort related to data and document 

quality assurance reviews (EPA is scanning and posting in the system documents submitted 

in prior surveys) 

In addition to system enhancements, required data elements were reduced between CWNS 2004 

and CWNS 2008. Data quality assurance methods have also been streamlined to require less 

respondent time while preserving data quality assurance.

CONSULTATIONS

EPA, with input from an advisory CWNS Workgroup composed of State and EPA Regional 

representatives, refines the approaches and methodologies used in each Survey. The CWNS 

2012 Workgroup was established in November 2009 following an October 2009 invitation to a 

list of State environmental department commissioners provided by the Environmental Council of 

the States. Recommendations made by the CWNS 2008 Workgroup at the end of the 2008

Survey, along with recommendations from the CWNS 2012 Workgroup, informed the refined 

methods for the CWNS 2012 data collection addressed by this ICR. The CWNS 2012 

Workgroup provided input on updating the eligibility criteria, data collection/submission 

methodologies, and the CWNS Data Entry Portal. As with past surveys, the updated criteria, 

methodologies and data system guidance will be published in a detailed user manual for State 

and EPA Regional CWNS Coordinators. 

EFFECTS OF LESS FREQUENT COLLECTION

The Needs Survey was initially conducted every two years. In 1994, a survey was mandated for 

the collection of drinking water infrastructure needs. Therefore, after the completion of the 

CWNS 1992, the CWNS began being conducted every four years, alternating with the drinking 

water survey. 

Each item in the CWNS is necessary to accomplish one or more goals of the Clean Water Act 

(CWA). Failure to update the information could put EPA, States and Regions in the position of 

being unable to respond in a timely and accurate manner to the Report’s CWA mandates. The 

CWA and state revolving fund allotment formula is overdue for reauthorization by Congress and 

the needs data submitted by States may play an important role in determining the appropriation 

of funds. The Needs Survey data also play a major part in evaluating costs for regulations such 

as stormwater rules and in related reports such as the Water and Wastewater Infrastructure Gap 

Analysis Report. Additionally, the data need regular updating to support the variety of additional

uses described at the end of Section 2.
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GENERAL GUIDELINES

The Survey follows OMB’s general guidelines.

CONFIDENTIALITY 

No confidential information is used.

SENSITIVE QUESTIONS

The Needs Survey does not ask for information considered sensitive or which appears to fall 

within the types of confidential data protected from release under the Public Information Act.

SECTION 4 THE RESPONDENTS AND THE INFORMATION REQUESTED

RESPONDENTS/NAICS CODES 

The North American Industry Classification System (NAICS) information for the respondents 

affected by this collection activity are as follows:

Establishment Group Number Industry Number

Water Pollution Control 924 924110

Sewage Plants and Systems 221 221320

INFORMATION REQUESTED

The types of data that will be collected relate to wastewater infrastructure and the costs thereof, 

including publicly-owned wastewater treatment and conveyance systems that need to be built or 

upgraded to control wastewater, stormwater, nonpoint source discharges, and combined sewer /

sanitary sewer overflows.

SECTION 5 THE INFORMATION COLLECTED – AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

AGENCY ACTIVITIES

Every four years, the data are collected, reviewed and summarized over a two-year time period 

to give EPA sufficient time to complete review and verification and to prepare the final report. 

The States and Regions also review the collected data during this time. Specifically, the States 

are responsible for:

 Collecting, reviewing and updating the data on municipal wastewater treatment facilities, 

stormwater, and non-point source projects,

 Submitting proper documentation where necessary,

 Justifying certain specified categories of need that are based on construction cost curves, and

 Addressing questions about populations served anomalies.

EPA Headquarters is responsible for:

 Managing the Survey and its data base to ensure national consistency,

 Setting national documentation standards and identifying data sources,

 Reviewing documentation to ensure its acceptability and updating records,
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 Assigning proper basis of estimates to all cost estimates and applying EPA Cost Curve 

procedures where appropriate,

 Reviewing and approving new facility data submitted by the States,

 Performing quality assurance checks on needs and population data,

 Deleting needs estimates for facilities that cannot be properly documented in accordance with 

the established list of acceptable criteria, and

 Preparing the final Report to Congress and disseminating Survey information over the 

internet (http://www.epa.gov/cwns/).

EPA Regions are responsible for:

 Promoting States’ full participation in CWNS,

 Assisting States with state-specific data collection / update methodologies,

 Assisting States in addressing States’ submissions evaluated by EPA as not meeting CWNS 

criteria, and

 Arranging Regional briefings on conduct of the data collection and results of the survey.

COLLECTION METHODOLOGY AND MANAGEMENT

EPA consistently has used current technology to complete the Survey. In 1974, the data were 

collected on 35-page questionnaires (EPA-1 Form), manually completed by the States. This 

method placed a large burden on State and EPA regional personnel and resources. In 1976, the 

EPA-1 Form was redesigned and considerably reduced in size and was made computer 

compatible. In 1983, the EPA-1 Form was reviewed and revised to two pages which were 

computer compatible. Subsequent Surveys were conducted in a similar manner. The 1986 

Survey preprinted information for States to update on one -page fact sheets which were easier to 

use than the computerized EPA-1 Form. Since 1988, the Needs Survey review and update 

process are computerized to further reduce the workload for the States and Regions in collecting 

and updating facility data. 

In response to terms of clearance of ICR (#0318.10), EPA, in partnership with States, made 

several enhancements to the database to streamline data entry, including reducing data element 

requirements and integrating with other EPA datasets. EPA has also strengthened procedures to 

ensure outdated information is removed from the database.

While reviewing data, EPA reviews supporting documentation submitted by States to ensure that 

data entered in the system meets CWNS eligibility criteria and is consistent with data in the 

documents. CWNS eligibility criteria are:

1. A description of the water quality impairment and information on the potential source. The 

problem description should include specific pollutant source information. A general 

statement about water quality impairment does not meet this criterion.

2. The location of the problem, included as a latitude/longitude point, or in the case of an 

nonpoint source (NPS) project, as a polygon (of the project location and/or the beneficial 

receiving waters).

3. One or more specific pollution control measures or BMPs used to address the problem.

4. The capital cost to implement each pollution control measure or BMP. General estimates 

for the problem area were not permitted; only site-specific data are acceptable to generate 

the costs.
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5. The source of the costs (e.g., an engineer’s estimate, facility plan, cost of comparable 

practices, estimates from equipment suppliers) for each solution.

6. The total capital costs for all pollution control measures and BMPs documented for a 

facility (all costs will be converted to January 1, 2012, dollars for CWNS 2012.)

7. For all needs entered into CWNS, if a facility / NPS project need is greater than $20 

million (January 1, 2012 dollar base), the documentation date needs to be January 1, 2006, 

or more current; for all other facility / NPS project needs, the documentation date needs to 

be January 1, 2002, or more current. 

In addition to these criteria, the CWNS user manual lists a set of document types that are preapproved for use in documenting needs and related costs. Cost curves are utilized to estimated 

costs for a small portion of documented needs that do not have well documented costs.

For CWNS 2012, EPA is offering States two options for participating: (1) the Traditional

Method and (2) the Gap Approach Option. The Gap Approach Option enables a State to 

comprehensively assess at the State level, for various facility size groupings, wastewater facility

revenues and capital and operation maintenance (O&M) expenses over 20 years. This 

comprehensive facility economic analysis supports State and EPA sustainable infrastructure 

programs. The Traditional Method enables States to assess the capital needs for each facility

within the state. This spatially comprehensive assessment of capital needs, along with current 

and projected populations receiving various levels of wastewater treatment, supports holistic 

watershed management approaches. 

Under the “Traditional Method” of documenting water pollution control needs, states submit 

capital needs for all facilities in the state: 

• Wastewater Treatment Plants

• Separate Sewer Systems

• Combined Sewer Systems 

• Stormwater Management

• Decentralized Wastewater Treatment

• Nonpoint Source (NPS) Control

For each need, states submit one or more supporting documents (Facility Plan, Engineer’s 

Estimate,...). Revenue and O&M needs data are NOT collected in the Traditional Method.

Under the “Gap Approach” to documenting water pollution control needs, states submit capital 

& O&M needs and revenues for a sample of these facilities:

• Wastewater Treatment Plants

• Separate Sewer Systems

• Combined Sewer Systems

For these sampled facilities, revenues are submitted and asset condition analysis data is used to 

estimate capital and O&M needs. Results from the sample set of facilities are extrapolated to 

provide State level estimates at +/- 10% accuracy. Average sample rates are:

• 10-25% for facilities serving less than 10,000 people 

• 30-60% for facilities serving between 10,000 and 100,000 people

• 100% (census survey) for the largest 3% of facilities in each state
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Since in CWNS the Gap Approach is only applicable to Wastewater Treatment Plants, Separate 

Sewer Systems, and Combined Sewer Systems, States selecting the Gap Approach will use the 

Traditional Method for all other facilities (Stormwater Management, Decentralized Wastewater 

Treatment, NPS Control).

SMALL ENTITY FLEXIBILITY

Collection of information associated with the Needs Survey does not involve small businesses. 

The primary respondents are the States, usually the State Water Pollution Control Agency or the 

Department of Environmental Protection. EPA allows States to submit simplified forms for their 

data from communities of 10,000 and less.

COLLECTION SCHEDULE

The CWNS 2012 data entry period will be December 15, 2010 through October 26, 

2012. Data quality assurance and analysis activities will be performed November 

2012 through February 2013. The Report will be developed and submitted to OMB 

for review in Summer 2013.

SECTION 6 ESTIMATING THE BURDEN AND COST OF THE 

COLLECTION

ESTIMATING RESPONDENT COSTS

The average cost to States of staff compensation and benefits is estimated to be $40.32 per hour 

(Department of Labor, May 2008), the annual State burden hour estimate of 7,183 hours equates 

to overall State costs of $289,598. The average cost to Local Facilities of staff compensation and 

benefits is estimated to be $42.17 per hour (Department of Labor, May 2008), the annual 

wastewater facility burden hour estimate of 1,932 hours equates to overall wastewater facility

costs of $81,468. There are no additional costs beyond costs associated with the above burden 

hour estimate.
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Burden for State Government and Local Facility Participation in Data Collection

This table summarizes burden estimates across all States. It results from summing the values in tables in the following three pages.

1) Obtain access & training 

for the Data Entry Portal

(DEP)

2.8 157 $6,312 157 $6,312

2) Manage others' access to

the DEP

1.4 78 $3,156 78 $3,156

3) Working with primary 

data suppliers

30.9 1,728 $69,661 1,728 $69,661

4) Compiling data from data

suppliers

26.0 1,457 $58,734 1,457 $58,734

5) Data Entry & Document 

Submission

50.5 2,830 $114,087 1,932 $81,468 4,761 $195,555

6) Data Quality Assurance 

Activities

16.7 934 $37,648 934 $37,648

Annual Totals 128.3 7,183 $289,598 1,932 $81,468 9,115 $371,066

3-Year Totals 384.8 21,548 $868,795 5,796 $244,404 27,343 $1,113,199

Total

Hours

TOTAL 

Respondent 

ACTIVITY Costs / Year

State Local Facilities State / Local Totals

LABOR 

Hours / 

Respondent /

Year

TOTAL 

Respondent

Hours / Year 

TOTAL 

Labor

Costs/Yr. 

[at $40.32 / 

hr.]

LABOR 

Hours / 

Respondent 

/ Year

TOTAL 

Respondent

Hours / Year 

[5,124 

Respondents / 

Year]

TOTAL 

Labor

Costs/Yr. 

[at $42.17 /

hr.]
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This table summarizes burden estimates for the estimated 49 States that will select the Traditional Method.

1) Obtain access & training for the

Data Entry Portal (DEP)

2.7 130 $5,238 130 $5,238

2) Manage others' access to the 

DEP

1.3 65 $2,619 65 $2,619

3) Working with primary data 

suppliers

27.8 1,364 $55,003 1,364 $55,003

4) Compiling data from data

suppliers

27.8 1,364 $55,003 1,364 $55,003

5) Data Entry & Document 

Submission

55.7 2,728 $110,006 0.33 1,470 $61,993 4,198 $171,999

6) Data Quality Assurance 

Activities

17.2 844 $34,049 844 $34,049

Annual Totals 132.6 6,496 $261,918 0.33 1,470 $61,993 7,966 $323,911

3-Year Totals 398 19,488 $785,755 1.00 4,410 $185,978 23,898 $971,734

ACTIVITY

State Local Facilities State / Local Totals

LABOR 

Hours / 

Respondent /

Year

TOTAL 

Respondent 

Hours/Year 

[49 

Respondents /

Year]

LABOR 

Hours / 

Respondent 

/ Year

TOTAL 

Respondent

Hours / Year 

[4,144 

Respondents /

Year]

TOTAL 

Respondent

Costs / Year

TOTAL 

Labor 

Costs/Yr. 

[at $42.17 / 

hr.]

Total 

Hours

TOTAL 

Labor 

Costs / Yr.

[at $40.32 / 

hr.]
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This table summarizes burden estimates for wastewater collection and treatment facilities the estimated 7 States that will select the 

Gap Approach Option.

1) Obtain access & training 

for the Data Entry Portal

(DEP)

3.7 26 $1,041 26 $1,041

2) Manage others' access to

the DEP

1.8 13 $520 13 $520

3) Working with primary data 

suppliers

50.7 355 $14,308 355 $14,308

4) Compiling data from data

suppliers

12.0 84 $3,382 84 $3,382

5) Data Entry & Document 

Submission

12.0 84 $3,382 0.67 449 $18,942 533 $22,324

6) Data Quality Assurance

Activities

12.0 84 $3,382 84 $3,382

Annual Totals 92.2 645 $26,015 0.67 449 $18,942 1,094 $44,958

3-Year Totals 277 1,936 $78,046 2.00 1,348 $56,826 3,283 $113,993

Total

Hours

TOTAL 

Labor 

Costs / Yr.

[at $40.32 /

ACTIVITY hr.]

State Local Facilities State / Local Totals

LABOR 

Hours /

Respondent /

Year

TOTAL 

Respondent

Hours / Year

[7 Respondents /

Year]

LABOR 

Hours / 

Respondent 

/ Year

TOTAL 

Respondent

Hours / Year

[674 

Respondents /

Year] 

TOTAL 

Respondent 

Costs / Year

TOTAL 

Labor

Costs/Yr. 

[at $42.17 /

hr.]
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This table summarizes burden estimates for other facilities (Stormwater Management, Decentralized Wastewater Treatment, NPS 

Control) in the estimated 7 States that will select the Gap Approach Option.

1) Obtain access & training 

for the Data Entry Portal

(DEP)

0.1 1 $33 1 $33

2) Manage others' access to

the DEP

0.1 0 $17 0 $17

3) Working with primary

data suppliers

1.2 9 $350 9 $350

4) Compiling data from data

suppliers

1.2 9 $350 9 $350

5) Data Entry & Document 

Submission

2.5 17 $699 0.67 13 $533 30 $1,232

6) Data Quality Assurance 

Activities

0.8 5 $216 5 $216

Annual Totals 5.9 41 $1,665 0.67 13 $533 54 $2,198

3-Year Totals 18 124 $4,994 2.00 38 $1,599 162 $6,593

ACTIVITY

State Local Facilities State / Local Totals

LABOR 

Hours / 

Respondent /

Year

TOTAL 

Respondent

Hours/Year 

[7 Respondents

/ Year]

LABOR 

Hours / 

Respondent / 

Year

TOTAL 

Respondent

Hours / Year 

[114 

Respondents / 

Year]

TOTAL 

Respondent 

Costs / Year

TOTAL 

Labor

Costs/Yr. 

[at $40.32 /

hr.]

Total

Hours

TOTAL 

Labor 

Costs / Yr. 

[at $42.17 /

hr.]
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ESTIMATED AGENCY BURDEN AND COSTS

The annualized estimate for the total cost to the Federal Government is $929,320; to include 

$90,000 for CWNS system maintenance at EPA’s computing facility, $535,000 for contractor 

support, and $304,320 in EPA employee compensation and benefits cost. 

Contract Management 0.30 $38,040 $10,000 $48,040

Regional Assistance to States 0.35 $44,380 $44,380

Plan, Implement, & Manage Survey 0.30 $38,040 $30,000 $68,040

Provide Logistics Support 0.05 $6,340 $15,000 $21,340

Refine Modeling Approaches 0.05 $6,340 $30,000 $36,340

Provide Data Entry Portal support 0.15 $19,020 $205,000 $90,000 $314,020

Provide Technical Support 0.15 $19,020 $40,000 $59,020

Workgroup Facilitation & Support 0.10 $12,680 $20,000 $32,680

Review, Q/A, and Reconcile Data 0.10 $12,680 $110,000 $122,680

Market and promote CWNS 0.30 $38,040 $15,000 $53,040

Prepare Final Report 0.45 $57,060 $25,000 $82,060

Develop & Maintain Web Reports 0.10 $12,680 $35,000 $47,680

Annual Totals 2.40 $304,320 $535,000 $90,000 $929,320

3-Year Totals 7.20 $912,960 $1,605,000 $270,000 $2,787,960

TOTAL 

AGENCY 

ACTIVITY Costs / Year

AGENCY

Labor

Hours / 

Year [FTE]

AGENCY

Labor Costs

/ Year 

[$126.8K /

FTE]

CONTRACT 

Costs / Year

AGENCY

Computing 

Facility 

Costs / Year

REASONS FOR CHANGE IN BURDEN

There is an increase of 308 hours in the total estimated respondent burden compared with that 

identified in the ICR currently approved by OMB. The 308 hour increase is the net result of a 

decrease of 52 State burden hours combined with an increase of 360 hours in Local Facility

burden hours. These changes are estimated impacts of 7 States selecting the Gap Approach 

Option. In this option, total state effort is projected to decrease slightly due to the sampling 

design (the greater State effort per facility is slightly more than offset by entering data for a 

sampled portion rather than for all facilities). For Local Facilities, the projected increased 

burden results from the extra per facility effort being slightly more than the burden saved by 

switching from a census to a sampling approach.
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BURDEN STATEMENT

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 1.55 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements which have subsequently changed; train personnel to be able to respond to a 

collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information.

To comment on the Agency's need for this information, the accuracy of the provided burden 

estimates, and any suggested methods for minimizing respondent burden, including the use of 

automated collection techniques, EPA has established a public docket for this ICR under Docket 

ID No. EPA-HQ-OW-2003-0019, which is available for public viewing at the Water Docket in 

the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, 

Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 

p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading 

Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An 

electronic version of the public docket is available through http://www.regulations.gov. Use 

www.regulations.gov to submit or view public comments, access the index listing of the contents 

of the public docket, and to access those documents in the public docket that are available 

electronically. Once in the system, select “search,” then key in the docket ID number identified 

above. Also, you can send comments to the Office of Information and Regulatory Affairs, 

Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: 

Desk Officer for EPA. Please include the EPA Docket ID No. EPA-HQ-OW-2003-0019 and 

OMB control number 2040-0050 in any correspondence.