SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

ICR Title Annual Public Water System Compliance Report (Renewal) 

EPA ICR No. 1812.05, OMB Control No. 2020-0020

1. Identification of the Information Collection

1(a) Title of the Information Collection

ICR Title: Annual Public Water System Compliance Report (Renewal) 

EPA ICR No. 1812.05, OMB Control No. 2020-0020

1(b) Short Characterization/Abstract

Section 1414 (c)(3)(A) of the Safe Drinking Water Act (SDWA) requires that each state 

(a term that includes states, commonwealths and territories) that has primary enforcement 

authority under the Safe Drinking Water Act shall prepare, make readily available to the public, 

and submit to the Administrator of EPA, an annual report of violations of national primary

drinking water regulations in the state. These Annual State Public Water System Compliance 

Reports are to include violations of maximum contaminant levels, treatment requirements, 

variances and exemptions, and monitoring requirements determined to be significant by the 

Administrator after consultation with the states. To minimize a state’s burden in preparing its 

annual statutorily-required report, EPA issued guidance that explains what Section 1414(c)(3)(A) 

requires and provides model language and reporting templates. EPA also annually makes 

available to the states a computer query that generates for each state (from information states are 

already separately required to submit to EPA’s national database on a quarterly basis) the 

required violations information in a table consistent with the reporting template in EPA’s 

guidance.

Fifty-five states (including Puerto Rico, the Virgin Islands, American Samoa, Guam, the 

Commonwealth of the Northern Mariana Islands, and Navajo Nation) currently have primary

enforcement authority under the Safe Drinking Water Act. The Navajo Nation was approved for 

primacy on December 6, 2000. Currently the State of Wyoming and the District of Columbia 

neither have primary enforcement authority nor are they seeking primary authority, so the 

number of 55 states is unlikely to change over the next three years of this ICR. The cost of this 

ICR to each state with primary enforcement authority will be approximately $5,776.09 during 

each of the three years of this ICR.

The Office of Management and Budget (OMB) approved the current active ICR without 

any “Terms of Clearance.”

The “Affected Public” are the states, tribes and territories that have primary enforcement 

authority. The burden to the “Affected Public” may be found below in Table 1: Annual 

Respondent Burden and Cost - the Annual Public Water Systems Compliance Report (Renewal). 
2

The burden to the “Federal Government” is attributed entirely to work performed by federal 

employees or government contractors. This burden may be found below in Table 2: Average 

Annual EPA Burden and Cost – the Annual Public Water Systems Compliance Report. 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

As stated above, Section 1414 (c)(3)(A) of the Safe Drinking Water Act requires that 

each state that has primary enforcement authority under the Act shall prepare, make readily 

available to the public, and submit to the Administrator of EPA, an annual report of violations of 

national primary drinking water regulations in the state. The states’ reports are to include 

violations of maximum contaminant levels, treatment requirements, variances and exemptions, 

and monitoring requirements determined to be significant by the Administrator after consultation 

with the states. Section 1414(c)(3)(B) of the Safe Drinking Water Act requires EPA to prepare 

and make available to the public an annual report that summarizes and evaluates the reports 

submitted by the states pursuant to subparagraph (A). 

2(b) Practical Utility/Users of the Data

EPA summarizes the data submitted by the states and uses that information in preparing 

its annual report that provides a national overview of the compliance performance of public

water systems. In its annual national report, EPA must also use the violations data provided by

the states to make recommendations concerning the resources necessary to improve compliance 

with the Safe Drinking Water Act. 

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under Section 1414 (c)(3)(A) of 

the Safe Drinking Water.

3(a) Nonduplication

The information to be obtained under this ICR has not been collected by EPA or any 

other federal agency. States are required to report public water system violations to EPA’s 

national database on a quarterly basis, but states cannot satisfy their obligations under Section 

1414(c)(3)(A) simply by referring interested parties to EPA’s Safe Drinking Water Information 

System/Federal System (SDWIS/FED). EPA works with states to ensure they can efficiently

extract from SDWIS/FED the calendar year violations data they need to prepare a report in 

which the violations data are readily available to the public. Some states elect not to use the 

EPA-provided query to extract the essential reporting data from SDWIS/FED, and use their own 

data systems instead.
3

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (78 FR 57378) on September 18, 2013. No comments were received on 

the burden published in the Federal Register. 

3(c) Consultations

To obtain comments from actual respondents regarding the annual state public water 

systems compliance report and the corresponding burden hour estimates, EPA staff consulted 

with the following individuals: 

Name Telephone Organization 

LeeAnn Tillotson 701-328-5293 North Dakota Department of Health

Eugene Pizzini 406-444-6972 Montana Department of Environmental Quality

Theresa Sabbia 603-271-2923 New Hampshire Department of Environmental 

Services

As states have now completed seventeen of these annual reports, most of them simply

generate the necessary data from SDWIS/FED, confirm the accuracy of the numbers, and update 

the previous year’s report. During the consultations, states suggested allotting the clerical 

burden for report preparation and submission to EPA to technical staff. This did not change the 

number of burden hours, only re-allotted them. As a result, the burden hours associated with 

preparing a report have not changed. EPA’s burden hour estimates reflect input from these 

consultations. 

3(d) Effects of Less Frequent Collection

Because Section 1414(c)(3)(A) of the Safe Drinking Water Act requires the states to 

prepare these reports annually and to make the reports readily available to the public, states do 

not have the option of collecting this information less frequently.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality
4

None of the information collected as part of the states’ annual public water systems 

compliance report comprises confidential business information (CBI), the required information 

consists of violations data and other information that are a matter of public record.

3(g) Sensitive Questions

The reporting or recordkeeping requirements for the states’ annual public water systems 

compliance report do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are states that have 

received primary enforcement authority under the Safe Drinking Water Act. The term “state”, in 

this context can include states, commonwealths, territories, and Indian Tribes. Currently, 

primary enforcement authority has been approved for every state except Wyoming, and for the 

U.S. Virgin Islands, Puerto Rico, American Samoa, Guam, the Navajo Nation and the Northern 

Mariana Islands. Primary enforcement authority has not been approved for the District of 

Columbia or for Indian Tribes except for the Navajo Nation. EPA has primary enforcement 

authority in those jurisdictions and is likely to retain that during the three year duration of this 

ICR. 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by Section 1414 (c)(3)(A) 

of the Safe Drinking Water Act. 

A state must make the following reports:

· State name and reporting period

· Full report, including a description of the data in the Summary of Violations 

chart, specific information on the violation categories for each rule identified on 

the chart, a list of the systems that had maximum contaminant level or treatment 

technique requirement violations, explanations of any aggregated number of 

violations, and a description of systems that were out of compliance during the 

year, a discussion of variance or exemption violations;

· Summary report, including a description of the data on violations, a list of the 

systems that had maximum contaminant level or treatment technique requirement 

violations, and a discussion of variance or exemption violations; and

· Reviewed and completed Summary of Violations chart.

In addition to these items, States are encouraged to provide optional information as outlined EPA 
5

guidance. EPA provides guidance to the States to assist them in the development of their 

statutorily-mandated reports.

Electronic Reporting

The respondents gather inventory and violations data from EPA’s SDWIS/FED or from 

their own data bases. Each year EPA provides the respondents with a computer query that 

generates for each state the required violations information in a table consistent with the 

reporting template in EPA’s guidance. States can submit their reports to EPA electronically. 

Most states do submit electronic versions of their report to EPA.

(ii) Respondent Activities

Respondent Activities

Review the instructions and other necessary materials.

Gather inventory and violations data from SDWIS/FED and from their own data bases.

Review and analyze inventory and violations data from SDWIS/FED and from their own data 

bases.

Prepare summary of violations data from SDWIS/FED and from their own data bases.

Prepare report and submit to EPA.

Make report readily available to the public and distribute a summary of the report.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Modify guidance documents as necessary and distribute to states and EPA Regional Offices

Prepare and distribute tools for states and EPA Regional Offices to use to gather data from 

SDWIS/FED.
6

Agency Activities

Answer questions from states and EPA Regional Offices.

Review Annual State Public Water System Compliance Reports and data from SDWIS/FED. 

Prepare and distribute annual report where EPA directly implements drinking water, and 

gather information from SDWIS/FED for Indian lands.

Prepare the Annual National Public Water Systems Compliance Report that summarizes and 

evaluates the annual state reports, and distribute the national report.

5(b) Collection Methodology and Management

EPA asks States with primary enforcement authority to submit their Annual State Public 

Water System Compliance Reports in electronic (WordPerfect compatible) and hard-copy 

format. Section 1414(c)(3)(A) requires that both the Annual State Public Water Systems 

Compliance Reports and the State-prepared summaries be accessible to the public. In its 

guidance, EPA recommends that States and EPA Regions use one or more of the following 

mechanisms for making the reports and summaries readily available: 

· Publish an official notice in newspapers regarding the availability of the report or 

summary;

· Conduct a press conference, issue a press release, or incorporate a notice into 

standard press conferences to announce report availability;

· Prepare notices for distribution in public libraries and other public buildings;

· Provide copies of the report for review at public offices and locations, libraries, 

web sites, state/local departments of health, etc; and

· Include notices of availability in local, state and EPA web sites.

Additionally, EPA’s national report, which will summarize the data collected from the states, 

will be posted on the Internet. 

5(c) Small Entity Flexibility

None of the states, commonwealths, or territories affected by this ICR is small entities as 

defined by the Regulatory Flexibility Act.

5(d) Collection Schedule

States with primary enforcement authority have six months after the end of each calendar 

year to prepare their Annual State Public Water Systems Compliance Reports, which are due to 

EPA on the first of July. Each report covers violations that occurred in a previous calendar year. 

6. Estimating the Burden and Cost of the Collection
7

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the states with primacy for the section of the Safe Drinking 

Water Act included in this ICR. The individual burdens are expressed under standardized 

headings believed to be consistent with the concept of burden under the Paperwork Reduction 

Act. Where appropriate, specific tasks and major assumptions have been identified. Responses 

to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to the states over the next three years from these 

recordkeeping and reporting requirements is estimated to be 4,400 ( Total Labor Hours from 

Table 1). The recordkeeping hours shown in Table 1 are zero. The reporting requirement hours 

shown in Table 1 are 4,400. These hours are based on Agency studies, Agency knowledge and 

experience with the Annual State Public Water System Compliance Reports, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $84.88 ($40.42 + 110%) 

Technical $73.40 ($34.95+ 110%)

Clerical $38.03 ($18.11+ 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

December 2009-January 2011, Table 6. Full-time State Government workers: Mean and Median 

Hourly, Weekly, and Annual Earnings and Mean Weekly and Annual Hours. The rates are from 

column 1,”Hourly Mean Earnings.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by state government.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The only type of state costs associated with the information collection activity in the Safe 

Drinking Water Act is labor costs. There are no capital/startup or operation and maintenance 

costs. 
8

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

The average annual cost for capital/startup and operation and maintenance costs to the 

state over the next three years of the ICR is estimated to be zero. 

6(c) Estimating Agency Burden and Cost

Table 2 Annual Agency Burden and Costs – Annual Public Water Systems Compliance 

Report presents the estimate Agency burden hours and costs associated with the information 

collection activities under this ICR. Other direct cost (copying, printing, telephone, and mailing 

expenses) are also included.

The average annual Agency cost during the three years of the ICR is estimated to be 

$119,740.61.

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to federal government employees. [These rates can be obtained 

from the OPM web site, http//www.opm.gov/oca/payrates/index/htm.] Details upon which this 

estimate is based appear below in Table 2: Average Annual Agency Burden and Costs, Public 

Water Systems Compliance Report.

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three years, fifty-five

existing respondents will be subject to the standard. It is estimated that no additional 

respondents will become subject in the next three years. EPA does not anticipate any additional 

states, territories, or tribes will obtain primacy in the next three years. The total number of 

annual responses per year is fifty-five, as each state is required to develop and submit one annual 

report.

The total annual labor costs are 4,400. The total annual capital/startup and O&M costs to 

the regulated entities are zero. Details regarding these estimates may be found below in Table 1. 

Annual Respondent Burden and Cost, Annual Public Water Systems Compliance Report.

Table 1. Annual Respondent Burden and Cost

Annual Public Water Systems Compliance Report
9

Information 

Collection Activity

Hours and Costs Per Respondent Total Hours and Costs

Mgr. 

$84.88/

Hour

Tech.

$73.40/

Hour

Clerica

l

$38.03/

Hour

Labor

Hours/

Year

Labor

Cost/

Year ($)

Capital/

Startup

Cost ($)*

O & M 

Cost ($)*

Number of 

Respondents

Total,

Hours/

Year

Total,

Cost/Year ($)

Review instructions 

and other necessary 

materials

4 4 293.58 N/A N/A 55 220 16,146.90

Gather inventory 

and violations data 

from SDWIS/FED 

and State databases

4 4 293.58 N/A N/A 55 220 16,146.90

Review and analyze 

data 24 24 1,761.48 N/A N/A 55 1,320 96,881.40

Prepare summary of 

violations of 

variances and 

exemptions

4 4

293.58 N/A N/A 55 220 16,146.90

Prepare report and 

submit to EPA 4 36 40 2,981.75 N/A N/A 55 2,200 163,996.25

Make report 

available to public 4 4

152.12 N/A N/A 55 220 8,366.60

Total 4 72 4 80 5,776.09 55 4400 317,684.95

“*” There are no capital/startup costs or operation & maintenance costs associated with this information collection activity.

The average annual Agency burden and cost over next three years is estimated to be

2,601 labor hours at a cost of $119,740.61. See Table 2. Annual Agency Burden and Cost, 

Annual Public Water Systems Compliance Report below. 

Table 2. Annual Agency Burden and Cost

Annual Public Water Systems Compliance Report 
10

Information 

Collection Activity

Agency Hours and Costs Total Hours and Costs

Mgr. 

$62.27/

Hour

Technical

$46.21/

Hour

Clerical

$25.01/ 

Hour

Agency

Hours/

Year

Labor

Cost/

Year ($)

Capital/

Startup

Cost ($)*

O& M 

Cost 

($)*

Number of 

Respondents

Total

Hours/

Year

Total

Cost/Year 

($)

Modify guidance as 

necessary and 

distribute to states 

and EPA Regions

1 24 25 1,171.26 N/A N/A 1 25 1,171.26

Prepare and 

distribute tools for 

gathering data from 

SDWIS/FED

1 16 17 801.60 N/A N/A 12 204 9,619.20

Answer questions 

from states and 

EPA Regional 

Offices

40 40 1,848.32 N/A N/A 12 480 22,179.84

Provide support for

Indian Land 

reporting

120 120 5,544.96 N/A N/A 9 1080 49,904.64

Review state 

reports and data 

from SDWIS/FED

40 40 1,848.32 N/A N/A 12 480 22,179.84

Prepare and 

distribute annual 

report where EPA 

directly implements 

drinking water

4 80 12 96 4,245.82 N/A N/A 2 192 8,491.65

Prepare and 

distribute national 

summary report

4 120 16 140 6,194.18 N/A N/A 1 140 6,194.18

Total 10 440 28 478 21,654.46 49 2601 119,740.61

“*” There are no capital/startup costs or operation & maintenance costs associated with this information collection activity.

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 (above), respectively, and summarized below. 

(i) Respondent Tally
11

The total annual labor hours are 4,400. Details regarding these estimates may be found in 

Table 1. Annual Respondent Burden and Cost, Annual Public Water Systems Compliance 

Report. Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average $5,776.09 per response.

The total annual capital/startup and O&M costs to the regulated entity are zero with the 

details in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

2,601 labor hours at a cost of $119,740.61. See Table 2. Annual Agency Burden and Cost, 

Annual Public Water Systems Compliance Report.

6(f) Reasons for Change in Burden

There is no change in burden from the most recently approved. This is due to two 

considerations. First, the requirements under SDWA have not changed over the past three years 

and are not anticipated to change over the next three years. Secondly, the number of states, 

territories or tribes with primacy has not changed, and is not anticipated to change over the next 

three years, so there is no significant change in the overall burden. There was a small reallocation of hours between technical staff and clerical staff, but the overall burden hours 

remained the same.

6(g) Burden Statement

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

is estimated to average 80 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; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.An agency may not conduct or sponsor, and a person is not required to respond 

to, a collection of information unless it displays a valid OMB Control Number. The OMB 

Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

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

use of automated collection techniques, EPA has established a public docket for this ICR under 
12

Docket ID Number EPA-HQ-OECA-2013-0667. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

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

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

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center 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 docket center is (202) 566-1752. 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 

Number EPA-HQ-OECA-2013-0667 and OMB Control Number 2020-0020 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.