Economic and Supporting Analyses for the Final 

Aircraft Drinking Water Rule 
Office of Water (4606-M) 

EPA 816-R-09-007 

October 2009 

www.epa.gov/safewater 
 

 

TABLE OF CONTENTS
 

3.	 Baseline Analysis .....................................................................................

3.1 Introduction...........................................................................................................

3.2 Industry Profile .....................................................................................................

3.1.1	 Data Sources .......................................................................................

3.1.2	 Water System Characterization...........................................................

3.1.3	 Baseline Number of Aircraft and Population Served by Aircraft per 

Year 3-4
 

3.3 Water Quality Baseline.........................................................................................

3.3.1	 2003 Data Collection Effort................................................................

3.3.2	 2004 Data Collection Effort................................................................

3.3.3	 Administrative Orders on Consent......................................................

3.3.4	 Disinfectant and Treatment Characterization for the Baseline ...........

3.3.5	 Contaminant Occurrence for the Baseline ..........................................

3.4 Uncertainties in the ADWR Baseline ...................................................................

4.	 Benefits Analysis ........................................................................................ 4

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Appendices ................................................................................................................v
 

Exhibits.....................................................................................................................vi
 

List of Acronyms .................................................................................................. viii
 

Executive Summary .................................................................................................x
 

1. Introduction................................................................................................ 1-1
 

1.1 Need for the Rule....................................................................................................... 1-1
 

1.2 Regulatory History..................................................................................................... 1-4
 

1.2.1	 1989 Total Coliform Rule ........................................................................ 1-4
 

1.2.2	 Surface Water Treatment Regulations..................................................... 1-5
 

1.2.3	 Public Notification Rule .......................................................................... 1-5
 

1.3 Summary of the Final Aircraft Drinking Water Rule ................................................ 1-5
 

1.4 Economic Rationale for the Regulation ..................................................................... 1-8
 

1.5 Document Organization ............................................................................................. 1-8
 

1.6 Calculations and Citations ......................................................................................... 1-9
 

2.	 Consideration of Regulatory Alternatives ............................................... 2-1
 

2.1 Introduction................................................................................................................ 2-1
 

2.2 Process for Development of Regulatory Alternatives ............................................... 2-2
 

2.3 Regulatory Alternatives Considered .......................................................................... 2-4
 

2.3.1	 Alternative 1 – Baseline Alternative: Existing NPDWRs ....................... 2-5
 

2.3.2	 Alternative 2 – Regulatory Requirements Similar to the AOCs .............. 2-7
 

2.3.3	 Alternative 3 – Requirements Similar to Water Supply Guidance 29 ..... 2-9
 

2.3.4	 Alternative 4 – Hybrid Approach - ADWR........................................... 2-10
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

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4.1 Introduction................................................................................................................ 4-1
 

4.2 Relative Risks – Qualitative Analysis........................................................................ 4-1
 

4.2.1 Rule Implementation Activities ............................................................... 4-2
 

4.2.2 Operator Certification Requirements ....................................................... 4-2
 

4.2.3 Routine Monitoring – Coliform Bacteria ................................................. 4-2
 

4.2.4 Repeat Monitoring – Coliform Bacteria .................................................. 4-3
 

4.2.5 Additional Routine Monitoring – Coliform Bacteria ............................... 4-3
 

4.2.6 Post Disinfection Monitoring – Coliform Bacteria .................................. 4-4
 

4.2.7 Routine Monitoring – Disinfectant Residual ........................................... 4-5
 

4.2.8 Development and Implementation of an O&M Plan ............................... 4-5
 

4.2.9 Routine Disinfection and Flushing .......................................................... 4-5
 

4.2.10 Disinfection and Flushing as Corrective Action ...................................... 4-6
 

4.2.11 Optional Supplemental Treatment ........................................................... 4-6
 

4.2.12 Sanitary Surveys/Self-Inspections ........................................................... 4-6
 

4.2.13 Public Notification ................................................................................... 4-7
 

4.2.14 Overall Relative Risk............................................................................... 4-7
 

4.3 Assessment of Potential Quantitative Relative Risk Analyses.................................. 4-8
 

4.4 Non-quantified Benefits............................................................................................. 4-9
 

5. Cost Analysis .............................................................................................. 5 
 


 

5.2 General Cost Assumptions and Methodology ........................................................... 5-2
 

5.2.1 Labor Rates .............................................................................................. 5-3
 

5.2.2 Laboratory Fees ....................................................................................... 5-4
 

5.3 Projecting and Discounting National Costs ............................................................... 5-5
 

5.4 Derivation of Costs for Air Carriers and the Agency ................................................ 5-6
 

5.4.1 Rule Implementation and Annual Administration ................................... 5-7
 

5.4.1.1 Air Carriers .................................................................................. 5-7
 

5.4.1.2 Agency ......................................................................................... 5-7
 

5.1 Introduction................................................................................................................ 5-1

5.4.1.3 Annualized Costs for Rule Implementation/Annual 

Administration ............................................................................. 5-9
 

5.4.2 Sampling Plan .......................................................................................... 5-9
 

5.4.2.1 Air Carriers .................................................................................. 5-9
 

5.4.2.2 Agency ....................................................................................... 5-10
 

5.4.2.3 Annualized Costs for Sampling Plan ......................................... 5-10
 

5.4.3 O&M Plan.............................................................................................. 5-11
 

5.4.3.1 Air Carriers ................................................................................ 5-11
 

5.4.3.2 Agency ....................................................................................... 5-11
 

5.4.3.3 Annualized Costs for O&M Plan............................................... 5-12
 

5.4.4 Coliform Monitoring .............................................................................. 5-12
 

5.4.4.1 Air Carriers ................................................................................ 5-12
 

5.4.4.2 Agency ....................................................................................... 5-15
 

5.4.4.3 Annualized Costs for Coliform Monitoring ............................... 5-15
 

5.4.5 Routine Disinfection and Flushing ........................................................ 5-16
 

5.4.5.1 Air Carrier.................................................................................. 5-16
 

5.4.5.2 Agency ....................................................................................... 5-18
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

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5.4.5.3 Annualized Costs for Routine Disinfection and Flushing .

6.	 Statutory and Administrative Requirements .......................................... 6

7.	 References ...................................

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6. 1	 Introduction.....................................................................................................

6. 2	 Executive Order 12866: Regulatory Planning and Review ...........................

6. 3	 Regulatory Flexibility Act ..............................................................................

6. 4	 Small-Air Carrier Affordability ......................................................................

6. 5	 Feasible Treatment Technologies for All Air Carriers ...................................

6. 6	 Effect of Compliance with the ADWR on the Technical, Managerial, and 

Financial Capacity of Air Carriers..................................................................

6.6.1	 Requirements of the Final ADWR................................................

6.6.2	 Air Carriers Subject to the Final ADWR ......................................

6.6.3	 Impact of the ADWR on Air Carrier Capacity .............................

6.6.4	 Derivation of the ADWR Scores ..................................................

6. 7	 Paperwork Reduction Act ...............................................................................

6. 8	 Unfunded Mandates Reform Act ....................................................................

6. 9	 Impacts on Sensitive Subpopulations .............................................................

6.9.1	 Protection of Children from Environmental Health Risks and Sa

Risks6-15
 

6. 10	 Environmental Justice .....................................................................................

6.10.1 Federalism.....................................................................................

6. 11	 Actions Concerning Regulations That Significantly Affect Energy Supply, 

Distribution, or Use.................................................................................................. 6-1

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5.4.6	 Disinfection and Flushing as Corrective Action ............................

5.4.6.1 Air Carrier..........................................................................

5.4.6.2 Agency ...............................................................................

5.4.6.3 Annualized Costs for Corrective Action Disinfection and

Flushing..............................................................................

5.4.7	 Self-Inspection and Compliance Audit..........................................

5.4.7.1 Air Carrier..........................................................................

5.4.7.2 Agency ...............................................................................

5.4.7.3 Annualized Costs for Compliance Audit ...........................

5.5	 Estimated Costs to Air Carrier Passengers ......................................................

5.6	 Non-quantified Costs and Uncertainties in Cost Estimates .............................

5.6.1	 Non-quantified Costs .....................................................................

5.6.2	 Uncertainties in Cost Estimates .....................................................

5.7	 Total Annualized Implementation and Incremental Costs for the Final ADW

5.8	 Comparison of Regulatory Alternatives ..........................................................

5.8.1	 Comparison to the final ADWR ....................................................

5.8.2	 Comparison of the proposed ADWR and final ADWR.................

5.9	 Comparison of Costs and Benefits ...................................................................

5.10	 Other Economic Measures ...............................................................................

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Page iv
 
 

 

Appendix A: ADWR Aircraft and Population Baseline 

Appendix B: Aircraft Drinking Water Sampling Data 

Appendix C: Cost Model 

Appendix D: Screening Analysis 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Page v 

Appendices
 

 

Exhibit 5.6 Air Carrier and Agency Cost Estimates for Implementation and Annual 

Administration ($Millions, 2008$) .............................................................................................. 5-9
 

Exhibit 5.7 Air Carrier Burden and Cost Estimates for Sampling Plan.................................... 5-10
 

Exhibit 5.8 Agency Burden and Cost Estimates for Sampling Plan ......................................... 5-10
 

Exhibit 5.9 Air Carrier and Agency Cost Estimates for Sampling Plan ($Millions, 2008$) .... 5-11
 

Exhibit 5.10 Air Carrier Burden and Cost Estimates for O&M Plan ....................................... 5-11
 

Exhibit 5.11 Agency Burden and Cost Estimates for O&M Plan............................................. 5-12
 

Exhibit ES.1 Total Annualized Present Value Implementation Costs for the Final ADWR 

($Millions, 2008$) ....................................................................................................................... xiv
 

Exhibit ES.2 Comparison of Total Annualized Present Value Costs by Regulatory Alternative 

($Millions, 2008$) ....................................................................................................................... xiv
 

Exhibit ES.3 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR ($Millions, 

2008$) ........................................................................................................................................... xv
 

Exhibit 1.1 Aircraft Drinking Water Monitoring Data ............................................................... 1-3
 

Exhibit 2.1 Aircraft Water System Supply and Transfer Chain ................................................. 2-2
 

Exhibit 2.2a Existing FDA Requirements for Watering Points1 and Supplemental Treatment 2-12
 

Exhibit 2.2b Alternatives Considered for the ADWR – Aircraft Water System ...................... 2-13
 

Exhibit 3.1 ADWR Aircraft and Population Baseline ................................................................ 3-5
 

Exhibit 3.2 Summary of 2003 ATA Sampling Data ................................................................... 3-7
 

Exhibit 3.3 Summary of 2004 EPA Sampling Data ................................................................... 3-7
 

Exhibit 3.4 AOCs Occurrence Baseline Data – Disinfectant Residual Samples (Years 2005-

2008) .......................................................................................................................................... 3-10
 

Exhibit 3.5 AOCs Occurrence Baseline Data – Routine Total Coliform Samples (Years 2005-

2008) .......................................................................................................................................... 3-12
 

Exhibit 5.1 Loaded Labor Rates by Standard Occupational Classification (SOC) Code (2008$)
 

...................................................................................................................................................... 5-3
 

Exhibit 5.2 Laboratory Costs (2008$) ........................................................................................ 5-5
 

Exhibit 5.3 ADWR Aircraft and Population Baseline ................................................................ 5-7
 

Exhibit 5.4 Air Carrier Burden and Cost Estimates for Implementation .................................... 5-7
 

Exhibit 5.5a Agency Burden and Cost Estimates for Implementation ....................................... 5-8
 

Exhibit 5.5b Agency Burden and Cost Estimates for Annual Administration ........................... 5-9
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibits 

Page vi 
 

 

Exhibit 5.12 Air Carrier and Agency Cost Estimates for O&M Plan ($Millions, 2008$) ....... 5-12
 

Exhibit 5.13 Air Carrier Burden and Cost Estimates for Coliform Monitoring ....................... 5-14
 

Exhibit 5.14 Agency Burden and Cost Estimates for Coliform Monitoring ............................ 5-15
 

Exhibit 5.15 Air Carrier and Agency Cost Estimates for Coliform Monitoring ($Millions, 

2008$) ........................................................................................................................................ 5-15
 

Exhibit 5.16 Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing .. 5-17
 

Exhibit 5.17 Air Carrier and Agency Cost Estimates for Routine Disinfection and Flushing 

($Millions, 2008$) ..................................................................................................................... 5-18
 

Exhibit 5.18 Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and 

Flushing...................................................................................................................................... 5-20
 

Exhibit 5.19 Air Carrier and Agency Cost Estimates for Corrective Action Disinfection and 

Flushing ($Millions, 2008$) ...................................................................................................... 5-21
 

Exhibit 5.20 Air Carrier Burden and Cost Estimates for Compliance Audit and Self-Inspection 5-

22
 

Exhibit 5.21 Agency Burden and Cost Estimates for Compliance Audit ................................. 5-22
 

Exhibit 5.22 Air Carrier and Agency Cost Estimates for Compliance Audit ($Millions, 2008$)
 

.................................................................................................................................................... 5-23
 

Exhibit 5.23 Summary of Monitoring and Disinfection and Flushing Events for All Alternatives
 

.................................................................................................................................................... 5-24
 

Exhibit 5.24 Total Annualized Present Value Implementation Costs for the Final ADWR 

($Millions, 2008$) ..................................................................................................................... 5-26
 

Exhibit 5.25 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR ($Millions, 

2008$) ........................................................................................................................................ 5-27
 

Exhibit 5.26 Total Annualized Incremental Cost: Requirements Similar to AOCs and the ADWR
 

($Millions, 2008$) ..................................................................................................................... 5-28
 

Exhibit 5.27 Comparison of Total Annualized Present Value Implementation Costs by 

Regulatory Alternative ($Millions, 2008$)................................................................................ 5-29
 

Exhibit 5.28 Comparison of Proposed and Final ADWR Total Annualized Present Value Costs 

($Millions, 2008$) ..................................................................................................................... 5-30
 

Exhibit 6.1 Estimated Impacts of the ADWR on Air Carriers’ Technical, Managerial, and 

Financial Capacity ....................................................................................................................... 6-9
 

Exhibit 6.2 Average Annual Burden Hours and Costs for the ADWR Information Collection 

Request....................................................................................................................................... 6-12
 

Exhibit 6.3 Total Annualized Costs of Regulatory Alternatives ($Millions, 2008$) ............... 6-14
 

Exhibit 6.4 Number and Percent of Air Carriers and Aircraft by Region ................................ 6-14
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

List of Acronyms 

ADWR Aircraft Drinking Water Rule 

AIDS Acquired Immune Deficiency Syndrome 

ANSI American National Standards Institute 

AOC Administrative Order on Consent 

ATA Air Transport Association 

BAT Best Available Technology 

BEA Bureau of Economic Analysis 

BMP Best Management Practice 

BLS Bureau of Labor Statistics 

BTS Bureau of Transportation Statistics 

CDC U.S. Centers for Disease Control and Prevention 

CFR Code of Federal Regulations 

CRMP Comprehensive Representative Monitoring Plan 

CWS Community Water System 

D&B Dun & Bradstreet 

DOT U.S. Department of Transportation 

EPA U.S. Environmental Protection Agency 

FAA U.S. Federal Aviation Administration 

FDA U.S. Food and Drug Administration 

GDP Gross Domestic Product 

GS General Schedule 

GWUDI Ground Water Under the Direct Influence of Surface Water 

HACCP Hazard Analysis Critical Control Point 

HPC Heterotrophic Plate Count 

ICC Interstate Carrier Conveyance 

ICR Information Collection Request 

ICWS Interstate Carrier Water Supply 

IESWTR Interim Enhanced Surface Water Treatment Rule 

LT1ESWTR Long Term 1 Enhanced Surface Water Treatment Rule 

LT2ESWTR Long Term 2 Enhanced Surface Water Treatment Rule 

MCL Maximum Contaminant Level 

MCLG Maximum Contaminant Level Goal 

MRDL Maximum Residual Disinfectant Level 

NAICS National American Industry Classification System 

NCWS Noncommunity Water System 

NPDWR National Primary Drinking Water Regulation 

NSF National Science Foundation 

NTNCWS Nontransient Noncommunity Water System 

O&M Operation and Maintenance 

OMB Office of Management and Budget 

PN Public Notification 

PWS Public Water System 

QA/QC Quality Assurance/Quality Control 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

QAPP Quality Assurance Project Plan 

RFA Regulatory Flexibility Act 

SAB Science Advisory Board 

SBA Small Business Administration 

SBREFA Small Business Regulatory Enforcement Fairness Act 

SDWA Safe Drinking Water Act 

SDWIS Safe Drinking Water Information System 

SOC Standard Occupational Classification 

SWTR Surface Water Treatment Rule 

TCR Total Coliform Rule 

TMF Technical, Managerial, and Financial 

TNCWS Transient Noncommunity Water System 

UMRA Unfunded Mandates Reform Act 

USC United States Code 

WHO World Health Organization 

WSG Water Supply Guidance 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

Executive Summary 

The United States Environmental Protection Agency (EPA) finalized National Primary 

Drinking Water Regulations (NPDWRs) for aircraft in September 2009. The primary purpose of 

the Aircraft Drinking Water Rule (ADWR) is to ensure that safe and reliable drinking water is 

provided to aircraft passengers and crew, while enabling air carriers to comply with the Safe 

Drinking Water Act (SDWA) and the NPDWRs in a feasible manner. These provisions, once 

promulgated, are expected to enhance protection of public health against illnesses attributable to 

microbiological contamination. 

Under the SDWA, interstate carrier conveyances (ICCs) that regularly serve drinking 

water to an average of at least 25 individuals daily, at least 60 days per year, are subject to the 

NPDWRs. An ICC is a carrier which conveys passengers in interstate commerce; this includes 

aircraft, trains, buses, and water vessels. As with other ICCs, aircraft obtain finished water from 

many different sources and have significant physical and operational differences from traditional 

public water systems (PWSs), making implementation of the NPDWRs difficult for this class of 

PWSs. EPA may decide to tailor existing requirements to other classes of ICCs in the future. 

The ADWR applies to all aircraft satisfying the definition of a transient non-community 

water system (TNCWS) that fly within the United States. This includes approximately 7,300 

aircraft serving routes in the United States, which together have approximately 744 million 

passengers and crew that may partake of the water at some time over the course of a year.1 

Aircraft in the following categories are not subject to the ADWR because they do not meet the 

definition of a PWS, are not under EPA’s jurisdiction, or are excluded from regulatory 

requirements under SDWA section 14112: 

Aircraft that do not serve 25 or more people for at least 60 days per year 

Aircraft without a qualifying lavatory3 or galley 

Aircraft solely used for cargo purposes 

Aircraft that fly international routes serving only one U.S. city 

Aircraft owned and operated by the U.S. military if used solely for military 

purposes, not conveying passengers in interstate commerce, and meet all of the 

other exclusion criteria under SDWA section 1411 

1

 Since a portion of passengers and crew make multiple trips each year, the actual number of passengers and crew 

exposed to aircraft drinking water is less than 744 million.

2

 Section 1411 excludes from regulation any public water system that receives all of its water from another regulated 

public water system, does not sell or treat the water, and is not a “carrier which conveys passengers in interstate 

commerce.” 

3

 A qualifying lavatory is defined as a private room with a flushing toilet and sink. Curtained-off toilet seats without 

lavatory sinks (as seen in some small, short-range aircraft) have not been included. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

This Economic and Supporting Analyses document describes the estimated annual costs 

to the air carrier industry and EPA for the final provisions. These costs include coliform 

monitoring, routine water system disinfection and flushing, reporting and recordkeeping, selfinspections/compliance audits, and planning processes. EPA has also characterized some of the 

non-quantified costs and benefits associated with this final rule. 

Summary of the Final ADWR Requirements 

In developing the ADWR, EPA evaluated four options: the existing regulations, and three 

alternatives. The analysis of several alternatives provided information that enabled the Agency 

to consider the economic and health effects of different combinations of regulatory components 

to gauge the relative efficiency and effectiveness of the regulatory alternatives. The alternatives 

considered are described in Chapter 2 and include the following: 

Alternative 1 – Existing Drinking Water Regulations 

Alternative 2 – Regulatory Requirements Similar to the Administrative Orders on 

Consent (AOCs) 

Alternative 3 – Regulatory Requirements Similar to Water Supply Guidance (WSG) 29 

Alternative 4 – Hybrid Approach - ADWR 

EPA published the proposed ADWR on April 9, 2008 (71 FR 19320). The proposed rule 

presented a hybrid approach that combined specific elements of the alternatives considered 

during rule development so as to achieve a balance between added health protection and the 

economic costs, while also providing administrative and operational flexibility for the air carriers 

in how they implement the regulatory requirements. The final rule was revised based on public 

comments received on the proposed rule. This final approach consists of regulatory components 

that are tailored to meet the unique circumstances of aircraft PWSs. Key components of the final 

rule include the following: 

•	 Routine coliform monitoring using one of four monitoring frequency options 

determined by the frequency of disinfection and flushing of the aircraft water 

system. 

•	 Two routine coliform samples are collected at the frequency chosen. If one or 

more of the routine samples are total coliform-positive but are Escherichia coli 

(E. coli)-negative the aircraft can choose to either perform repeat sampling 

(collecting three samples) or corrective action to include disinfection and flushing 

and follow-up monitoring. Special consideration is given for aircraft with a single 

water tank that is removable and is drained at least once-a-day, and there is one 

tap on the aircraft. Those aircraft may collect a single 100 mL routine sample at 

the frequency chosen. 

•	 Disinfection and flushing as corrective action must occur in the event of an E. 

coli-positive sample or if any repeat samples are total coliform-positive. If 

disinfection and flushing as corrective action is required, public access to water 

must be restricted and public notice must be posted until the water system is 

disinfected and flushed and a complete set of follow-up samples are total 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

coliform-negative. The rule specifies a maximum amount of time that can elapse 

before corrective action disinfection and flushing occurs if the water cannot be 

physically shut off or the flow of water cannot be prevented through the taps to 

prevent use for human consumption. 

•	 Disinfectant residual monitoring is not required by the final rule, but may be 

recommended in guidance as a means of promoting voluntary measures such as 

flushing and refilling with water containing a residual. 

•	 Specific training requirements for all personnel involved with the aircraft water 

system operations and maintenance provisions of the ADWR must be included in 

the aircraft operations and maintenance (O&M) plan. 

•	 Detailed disinfection and flushing procedures must be included in O&M plans. 

•	 Reporting requirements for disinfection and flushing and monitoring results, and 

compliance status. 

•	 Water system O&M plans would be incorporated into U.S. Federal Aviation 

Administration (FAA)-accepted O&M plans for aircraft. 

•	 EPA may perform compliance audits as needed. 

•	 Air carriers perform self-inspections of aircraft water systems at least every 5 

years and self-certify completion of the inspections. 

Summary of National Benefits and Costs of the Final ADWR 

National Benefits Summary 

This section summarizes the risk (and benefit) tradeoffs between compliance with 

existing NPDWRs and the regulatory alternatives considered during the rule development 

process. Evaluations include a qualitative analysis of the relative risks of the regulatory 

alternatives considered. Potential non-quantified benefits of compliance with the regulatory 

options are also discussed. 

Relative Risks—Qualitative Analysis 

The goal of the ADWR is to tailor existing NPDWRs to the unique characteristics of 

aircraft water systems. The requisite data on contaminant occurrence (both frequency and 

concentration), health effects, and water consumption are not available to support a quantitative 

analysis. Therefore, in consultation with the U.S. Food and Drug Administration (FDA) and 

FAA, EPA has used best professional judgment to qualitatively estimate the relative risk of each 

regulatory alternative compared to the baseline alternative of existing regulations for transient 

non-community PWSs using finished surface water. This assessment was made with 

contributions from a diverse group of drinking water and aircraft experts, ranging from scientists 

and engineers to administrators and regulatory experts. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

The consensus opinions resulting from the qualitative assessment of risks for each 

alternative relative to the Alternative 1 baseline of existing NPDWRs concluded that Alternative 

2, which is similar to the AOCs, has an overall lower health risk due to the dominant factor of 

periodic disinfection and flushing of the aircraft water system. The overall health risk posed by 

Alternative 3, which is similar to Water Supply Guidance 29, is also most likely less than the 

Alternative 1 baseline, though the magnitude of the difference is expected to be smaller 

compared to Alternative 2 due to the flexibility in choosing between monitoring and an O&M 

plan under Alternative 3. The regulatory components of the ADWR allow greater flexibility 

than Alternatives 2 and 3 with regard to disinfection and flushing frequencies. Thus, some 

aircraft may not perform disinfection and flushing as often as would be required under those 

alternatives. However, this is compensated for by requiring more routine monitoring in those 

situations. As a result, the expert consensus is that the overall health risk posed by the ADWR is 

most likely less than the Alternative 1 baseline, and about the same as Alternatives 2 and 3. 

Qualitative Benefits Analysis 

Increased routine disinfection and flushing required under the final ADWR is expected to 

inactivate pathogens and control biofilm which can harbor pathogens in the aircraft distribution 

system that can contribute to endemic disease. Likewise, disinfection and flushing associated 

with corrective action is also expected to inactivate or remove any pathogens that may have 

entered the distribution system, resulting in increased avoidance of illness and death. By 

reducing cases of illness contracted through exposure to aircraft PWSs, the final rule is also 

expected to reduce the occurrence of illness passed through secondary spread. EPA expects the 

addition of multiple barriers to pathogens through monitoring and disinfection and flushing to 

reduce the likelihood of outbreaks associated with aircraft PWSs. 

EPA determined that it was not feasible to perform a quantitative risk analysis for the 

proposed rule during its development. EPA continued to assess the AOC data and evaluate 

whether additional quantitative analyses were possible for the final rule. EPA has used the 

AOCs’ data to update estimates of the percentage of total coliform-positive and E. coli-positive 

samples for Alternatives 2 through 4 based on the inclusion of disinfection and flushing of the 

water systems on a routine basis – a requirement not included in the existing NPDWRs 

represented by Alternative 1. EPA determined the AOC data is still not sufficient to support a 

quantitative analysis. 

National Cost Summary 

Exhibit ES.1 presents the total annualized costs to air carriers and the Agency for 

implementing the final ADWR at 3 and 7 percent discount rates. Incremental costs of the final 

rule against the baseline (Alternative 1) are also presented. For the purposes of this analysis, 

one-time and yearly costs were projected over a 25-year time period to coincide with and allow 

comparison with other drinking water regulations. The present values of costs are calculated 

using discount rates of 3 and 7 percent based on EPA policy and Office of Information and 

Regulatory Affairs of the Office of Management and Budget (OMB) guidance. 

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Alt 1 Alt 2 Alt 3 Alt 4 (Final Rule) Alt 1 Alt 2 Alt 3 Alt 4 (Final Rule) 

3% 7% 

Implementation 0.01 0.01 0.01 0.01 0.02 0.02 0.02 0.02 

Annual Administration 0.24 0.24 0.24 0.24 0.23 0.23 0.23 0.23 

Monitoring Plan 0.002 0.002 0.001 0.002 0.004 0.004 0.002 0.003 

O&M Plan - - 0.01 0.01 - - 0.01 0.02 

Coliform Monitoring 25.37 1.67 2.23 4.93 25.02 1.65 2.20 4.86 

Disinfectant Residual 

Monitoring 3.17 0.67 - - 3.13 0.66 - -

Routine Disinfection and 

Flushing - 4.52 2.97 2.08 - 4.46 2.93 2.05 

Corrective Action Disinfection 

and Flushing - 0.05 0.05 0.05 - 0.05 0.05 0.05 

Sanitary Survey/Compliance 

Audit 0.70 - - 0.02 0.69 - - 0.02 

Turbidity Monitoring - - 12.92 - - - 12.74 -

Total 29.49 7.16 18.43 7.34 29.08 7.07 18.19 7.25 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit ES.1 Total Annualized Present Value Implementation Costs for the Final 

ADWR ($Millions, 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Implementation $ 0.002 $ 0.01 $ 0.01 $ 0.004 $ 0.01 $ 0.02 

Annual Administration $ - $ 0.24 $ 0.24 $ - $ 0.23 $ 0.23 

Sampling Plan $ 0.002 $ 0.001 $ 0.002 $ 0.002 $ 0.001 $ 0.003 

O&M Plan $ 0.01 $ 0.0001 $ 0.01 $ 0.02 $ 0.0001 $ 0.02 

Coliform Monitoring $ 4.89 $ 0.04 $ 4.93 $ 4.82 $ 0.04 $ 4.86 

Routine Disinfection and 

Flushing $ 2.08 $ - $ 2.08 $ 2.05 $ - $ 2.05 

Corrective Action 

Disinfection and Flushing $ 0.05 $ - $ 0.05 $ 0.05 $ - $ 0.05 

Compliance Audit $ 0.01 $ 0.01 $ 0.02 $ 0.01 $ 0.01 $ 0.02 

Total $ 7.04 $ 0.30 $ 7.34 $ 6.95 $ 0.30 $ 7.25 

Exhibit ES.2 Comparison of Total Annualized Present Value Costs by Regulatory 

Alternative ($Millions, 2008$)

Exhibit ES.2 presents the total annualized present value cost for each of the regulatory 

alternatives considered for this rulemaking. 

As discussed in Chapter 5, the qualitative analyses suggest that benefits are greater under 

the final rule than under Alternative 1, the baseline requirements. Exhibit ES.3 presents the cost 

savings associated with the final rule. Although it is not the least costly alternative considered 

during rule development, the final rule will likely deliver a level of desired benefits at a cost that 

is acceptable to the air carrier industry, which increases the likelihood that real benefits will 

accrue. EPA is limited by the purpose, quality, and quantity of data available in developing 

meaningful benefits analyses. Any comparison of risk between the alternatives considered for 

the final rule requires robust data, which is not currently available (see Chapter 3 for a more 

detailed description of available data). 

Page xiv 
 

 

 

 

 

 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit ES.3 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR 

($Millions, 2008$) 

Alt 4 

(Final Rule) 

Incremental 

Cost 

(Alt 4 - Alt 1) 

 Alt 1 

(Existing 

NPDWRs) 

Alt 1 

(Existing 

NPDWRs) 

Alt 4 

(Final Rule) 

3% 

Implementation 0.01 0.01 0 0.02 0.02 0 

Annual Administration 0.24 0.24 0 0.23 0.23 0 

Monitoring Plan 0.002 0.002 0 0.004 0.003 (0.001) 

O&M Plan - 0.01 0.01 - 0.02 0.02 

Coliform Monitoring 25.37 4.93 (20.44) 25.02 4.86 (20.16) 

Disinfectant Residual 

Monitoring 3.17 - (3.17) 3.13 - (3.13) 

Routine Disinfection and 

Flushing - 2.08 2.08 - 2.05 2.05 

Corrective Action 

Disinfection and Flushing - 0.05 0.05 - 0.05 0.05 

Sanitary 

Survey/Compliance Audit 0.7 0.02 (0.68) 0.69 0.02 (0.67) 

Turbidity Monitoring - - - - - -

Total $29.49 $7.34 $(22.15) $29.08 $7.25 

Page xv 

Incremental 

Cost 

(Alt 4 - Alt 1) 

$(21.83) 

7%
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

 Page xvi 
 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

1. Introduction 

This document presents an analysis of the costs, benefits, and potential impacts of the 

final ADWR. 

This chapter includes the need for the rule (Section 1.1); a regulatory history of the 

ADWR (Section 1.2); a summary of the final ADWR (Section 1.3); the economic rationale for 

regulating aircraft PWSs (Section 1.4); an outline of the document (Section 1.5); and information 

regarding supporting calculations and citations (Section 1.6). 

1.1 Need for the Rule 

The primary responsibility for regulating the quality of drinking water lies with EPA. 

The SDWA establishes this responsibility and defines the mechanisms at the Agency’s disposal 

to protect public health. EPA sets standards by identifying which contaminants should be 

regulated and by establishing the maximum levels of the contaminants allowed in drinking water. 

Under the SDWA, primary enforcement authority for the NPDWRs may be delegated to states 

and Indian Tribes; however, due to the interstate nature of aircraft travel, EPA will be 

responsible for implementation, including enforcement, of the ADWR. 

The primary purpose of the final ADWR is to ensure that safe and reliable drinking water 

is provided to aircraft passengers and crew. This entails providing air carriers with a feasible and 

effective way to comply with the SDWA and the NPDWRs. Under the SDWA, ICCs, including 

aircraft, that regularly serve drinking water to an average of at least 25 individuals daily, at least 

60 days per year, are subject to the NPDWRs. An ICC is a carrier that conveys passengers in 

interstate commerce. The classes of ICCs include aircraft, trains, buses, and water vessels. 

Aircraft obtain potable water from many different sources and have significant physical 

and operational differences from traditional, stationary PWSs, making implementation of the 

NPDWRs difficult for this class of PWSs. A significant characteristic is that they board water 

frequently from a variety of locations, and must use water transfer equipment and temporary 

connections. This rule tailors implementation of existing health-based drinking water standards 

to the unique characteristics of aircraft PWSs. EPA may address regulations for other ICCs 

subsequent to development of the ADWR. 

Public Health Concerns Related to Aircraft Drinking Water 

EPA assumes that only finished water obtained from another PWS is boarded on aircraft. 

This assumption is based on an FDA requirement that only potable water may be provided for 

drinking and culinary purposes on ICCs (21 Code of Federal Regulations (CFR) 1240.80). 

However, the opportunity exists for microbial contamination to be introduced during the act of 

Page 1-1 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

transferring the water from the supplier truck or cart to the aircraft water system, or to occur 

through a cross connection within the water system itself. 

In 1990, EPA’s Science Advisory Board (SAB), an independent panel of experts 

established by Congressional mandate, cited drinking water contamination as one of the most 

important environmental risks. The SAB indicated that disease-causing microbial contaminants 

(i.e., bacteria, protozoa, and viruses) pose a particularly high health risk due to the large 

populations that are directly exposed to them (SAB and USEPA, 1990). Information on 

waterborne disease outbreaks from the U.S. Centers for Disease Control and Prevention (CDC) 

underscores this concern. Data collected by CDC indicate that between 1971 and 2002, 757 

waterborne disease outbreaks, caused by various types of contamination, were reported (Craun 

and Calderon, 1996; Levy et al., 1998; Barwick et al., 2000; Lee et al., 2002; and Blackburn et 

al., 2004). Water contamination issues apply to all drinking water systems, and are not unique to 

aircraft water systems. 

To date, EPA has reviewed four data sources to gain a better understanding of the 

drinking water quality on domestic aircraft as represented by total coliform, Escherichia coli (E. 

coli)/fecal coliform, and chlorine residual. These data sources included: 1) a voluntary 

monitoring study completed by Air Transport Association (ATA) in Fall 2003; 2) an EPA 

compliance activity completed in 2004; 3) an EPA compliance activity under the AOCs covering 

monitoring results from 2005-2008; 4) and the Canadian Inspection Program monitoring results 

completed in 2006. In comparing the routine sampling data, the highest total coliform-positive 

rate of detection was 15 percent, while the AOCs rate observed was 3.6 percent. The data are 

discussed further in Chapter 3 and details of the AOCs are provided in Chapter 2. EPA believes 

that the mandatory quarterly disinfection and flushing requirements under the AOCs may be a 

contributing factor to the reduced total coliform rates observed in the AOCs’ data. The data 

results are reflected in Exhibit 1.1. 

Page 1-2 
 

 

 

EPA AOCs 

(2005 - 2008 – Compliance 

Activity) 1 

ATA 

(Fall 2003 - 

Voluntary) 

EPA Study 

(2004 - 

Compliance 

Activity) 

Canadian Study 

(2006 - 

Inspection 

Program) 

Samples 

Routine samples only; galley & 

lavatory samples 

• 3,512 (~58%) aircraft tested 

• 16 (~35%) air carriers 

tested 

Galley samples 

(327 aircraft 

tested) 

Galley & lavatory 

samples (327 

aircraft tested) 

Galley & lavatory 

samples (431 

aircraft tested) 

Total ColiformPositive 

3.6% (463 out of 12,794 samples) 2 

• 1.0% (47 out of 5,695 

galley samples) 

• 4.4% (413 out of 7,027 

lavatory samples) 

2.7% 15% 15.1% 

E. coli/Fecal 

ColiformPositive 

3.9% (18 out of 463 total coliformpositive samples) 

• 12.8% (6 out of 47 galley 

samples) 

• 2.9% (12 out of 413 

lavatory samples) 

0.0% 

0.6% 

(2 out of 49 total 

coliform-positive 

samples) 

(1.3% in summer 

samples) 

7.7% 

(5 out of 65 total 

coliform-positive 

samples) 

Cl2 Residual 

Non-Detects 14.4% (1,517 out of 10,557) 41% 21% NA 

1. Data collected under EPA-approved quality assurance project plans (QAPPs) and comprehensive representative 

monitoring plans (CRMPs). 

2. One total coliform-positive sample out of seven was a composite sample (of lavatory and galley sources) and two 

total coliform-positive samples out of 65 did not have a sample location. 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 1.1 Aircraft Drinking Water Monitoring Data

The effects of waterborne disease are usually acute, resulting from a single or small 

number of exposures. Most waterborne pathogens cause gastrointestinal illness with diarrhea, 

abdominal discomfort, nausea, vomiting, or other symptoms. Most such cases involve a sudden 

onset and generally are of short duration in healthy people. Some pathogens (e.g., Giardia and 

Cryptosporidium), however, may cause extended illness, lasting weeks or longer in otherwise 

healthy individuals. The infection can prove fatal for members of sensitive populations, such as 

the immuno-compromised. Other waterborne pathogens cause, or at least are associated with, 

more serious disorders such as hepatitis, particularly hepatitis A (Moore et al., 1993), peptic 

ulcers and gastric cancer (Helicobacter pylori) (Park et al., 2001, Sepulveda and Graham, 2002), 

myocarditis (group B coxsackievirus) (Kim et al., 2001), meningitis (group B coxsackievirus and 

echoviruses) (Lee and Kim, 2002, Amvrosieva et al., 2001), and other diseases. 

The final ADWR seeks to protect against contamination that has an acute rather than 

cumulative effect because of the short term exposure of consumers to the water and the transient 

nature of passengers and the crew on board a particular aircraft. In particular, the final ADWR 

seeks to protect against disease-causing microbial contaminants. Although data do not exist on 

outbreaks of illness caused by drinking water on aircraft, EPA understands that the population on 

board disperses after a flight and that even if passengers develop gastrointestinal symptoms 

within hours of deplaning, they are unlikely to contact the air carrier or any government agency 

to report the illness. 

Page 1-3 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

1.2 Regulatory History 

The SDWA, including the amendments of 1986 and 1996, requires EPA to promulgate 

the NPDWRs to protect human health from waterborne contamination. As TNCWSs, aircraft are 

subject to certain NPDWRs specific to this category of systems. The Agency published WSG 29 

in October 1986 to assist air carriers in complying with these standards (USEPA, 1986). Under 

WSG 29, an ICC water system could use an approved operation and maintenance program in lieu 

of monitoring requirements. In 2004, EPA found all aircraft water systems to be out of 

compliance with the NPDWRs. Since then, the Agency has determined that a new rule 

specifically adapted to aircraft water systems would provide a regulatory environment more 

conducive to compliance and enforcement. EPA is no longer approving operation and 

maintenance programs in lieu of monitoring while the ICC program is being revised. EPA has 

signed Administrative Orders on Consent with many air carriers that specify what monitoring 

and other activities are required until a new rule is in effect. 

Many drinking water rules for systems using surface water or ground water under the 

direct influence of surface water (GWUDI) relate to treatment of source water, but because 

aircraft must use finished water the responsibility for treating the water is borne by the water 

supplier from which aircraft obtain their water. This situation is comparable to the handling of 

traditional, stationary PWSs as consecutive systems. The ADWR adapts to aircraft water 

systems the applicable requirements from the Total Coliform Rule (TCR), the Surface Water 

Treatment Rule (SWTR), and the Public Notification Rule, the relevant sections of which are 

summarized in the subsections below. 

Monitoring for nitrates/nitrites (under the Phase II Inorganic Contaminant Rule) would 

normally apply to TNCWSs. However, aircraft board finished water that the supplier is required 

to have monitored for nitrate/nitrites, and to have applied treatment if necessary to meet the 

maximum contaminant levels (MCLs) for the contaminants. Therefore, the nitrate rule is not 

applicable to aircraft under the final ADWR and is not included in the discussion below. 

1.2.1 1989 Total Coliform Rule 

TCR (54 FR 27544, June 1989) applies to all PWSs. Because monitoring PWSs for 

every possible pathogenic organism is not feasible, coliform organisms are used as indicators of 

possible source water and distribution system contamination. Coliforms are easily detected in 

water and are used to indicate a water system’s source and distribution system vulnerability to 

pathogens. In the TCR, EPA sets a Maximum Contaminant Level Goal (MCLG) of zero for total 

coliforms. EPA also sets a monthly MCL for total coliforms and requires testing of total 

coliform-positive cultures for the presence of E. coli or fecal coliforms. E. coli and fecal 

coliforms indicate more immediate health risks from sewage or fecal contamination and are used 

as a trigger of an acute MCL violation. Under the TCR, a TNCWS using finished surface water 

and serving fewer than 1,000 persons daily would typically be required to collect one routine 

total coliform sample per month. Additional samples would be required in the event a routine 

sample is total coliform-positive. 

Page 1-4 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

1.2.2 Surface Water Treatment Regulations 

EPA has promulgated a suite of regulations to address microbial contamination of surface 

water. These regulations include the SWTR, the Interim Enhanced Surface Water Treatment 

Rule (IESWTR), the Filter Backwash Recycling Rule, and the Long Term 1 and Long Term 2 

Enhanced Surface Water Treatment Rules (LT1ESWTR and LT2ESWTR). These rules apply 

monitoring and treatment technique requirements, such as turbidity limits, among others, to 

protect the public from microbial pathogens in drinking water such as bacteria, viruses, Giardia 

lamblia, and Cryptosporidium. The monitoring and treatment technique requirements must be 

met prior to water entering the distribution system. Aircraft are not required to provide source 

water treatment or to perform monitoring of source water because these are responsibilities of the 

PWS from which the aircraft obtains finished water for boarding. However, the SWTR included 

provisions for maintaining a detectable distribution system disinfectant residual and for 

monitoring distribution system disinfectant residuals at the same time and location as used for 

total coliform monitoring. A TNCWS using surface water serving fewer than 1,000 persons 

daily would typically be required to take one disinfectant residual sample at the same time and 

location as each coliform sample. The IESWTR requires primacy states to conduct sanitary 

surveys for all surface water and GWUDI systems regardless of size at a frequency of every 3 

years for community water systems and every 5 years for noncommunity water systems. 

1.2.3 Public Notification Rule 

Public water systems must give notice to persons served for all violations of NPDWRs 

and for other situations posing a risk to public health from drinking water. The term “NPDWR 

Violations” is used in the public notification regulations to include violations of the MCL, 

Maximum Residual Disinfectant Level (MRDL), treatment technique, monitoring, and testing 

procedure requirements. Public notice requirements are divided into three tiers to take into 

account the seriousness of the violation or situation and of any potential adverse health effects 

that may be involved. Due to the transient nature of the public served by TNCWSs, public 

notice is typically provided through posting of the notice at locations where the public may 

access drinking water from the water system. 

1.3 Summary of the Final Aircraft Drinking Water Rule 

The ADWR applies to all aircraft under EPA’s jurisdiction. Aircraft water systems are 

TNCWSs that board finished water from PWSs using primarily surface water supplies or 

GWUDI. Although some aircraft board water from PWSs supplied by ground water sources, 

these aircraft are also very likely to use surface water supplies at some of their destinations and 

are therefore classified as mixed systems. Mixed systems are subject to the same requirements 

as surface water and GWUDI systems. 

As described in detail in Chapter 2, the baseline of existing regulations for TNCWSs 

using finished surface water (i.e., Alternative 1), requirements similar to two previously 

implemented approaches to regulating aircraft PWSs, and the final ADWR are presented in this 

Page 1-5 
 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

document. These alternatives were considered for development of the ADWR in compliance 

with guidelines set out in both EPA’s Guidelines for Preparing Economic Analyses (USEPA, 

2000) and Office of Management and Budget Circular A-4 (OMB, 2003). Analysis of several 

alternatives allows the Agency to consider different combinations of regulatory components in 

order to select the most efficient and cost-effective approach to regulation. The alternatives 

considered as part of the analysis include: 

Alternative 1 – Existing Drinking Water Regulations 

Alternative 2 – Regulatory Requirements Similar to the AOCs 

Alternative 3 – Regulatory Requirements Similar to Water Supply Guidance 29 

Alternative 4 – Hybrid Approach – ADWR 

The following discussion briefly summarizes the final rule, while Chapter 2 provides a 

more complete description of each of the alternatives considered for the ADWR. Although 

aircraft PWSs are not technically considered consecutive water systems4

, for the purposes of 

each alternative, they are assumed to be boarding finished water obtained from another PWS. 

Because aircraft board only finished water, for the purposes of the analyses in this document, 

aircraft are treated as equivalent to consecutive water systems. Finished water is defined in 40 

CFR 141.2 as water that is introduced into the distribution system of a PWS and is intended for 

distribution and consumption without further treatment, except as treatment necessary to 

maintain water quality in the distribution system. Prior to boarding the water, compliance with 

FDA and FAA requirements5 is expected to ensure that water from the supplier meets NPDWR 

standards and that the equipment used in transferring this water to the aircraft is maintained and 

operated so as to preserve that level of water quality. 

Final ADWR 

The final rule is a hybrid approach that combines what EPA believes are the most 

practical elements of the other alternatives with flexibility for the air carriers in how they 

implement the regulatory requirements. This final approach allows compliance with regulatory 

components that are most tailored to the unique circumstances of aircraft PWSs. Development 

of this alternative was undertaken based on the input received from stakeholders during the 

Agency’s outreach efforts, as well as public comments on the proposed rule. The final rule 

includes the following regulatory components: 

•	 Aircraft must comply with one of the following combinations of water quality 

monitoring, and disinfection and flushing of the aircraft water system in 

accordance with the manufacturer’s recommendations: 

4

 A consecutive system is defined as a public water system that receives some or all of its finished water from one 

or more wholesale systems. Delivery may be through a direct connection or through the distribution system of one 

or more consecutive systems. 

5

 Compliance with FAA and FDA regulations is required of both aircraft PWSs and water suppliers. Any FAA and 

FDA requirements are in addition to those imposed by the ADWR. 

Page 1-6 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

–	 Annual total coliform monitoring (once every twelfth month) in 

combination with routine disinfection and flushing quarterly (at least once 

every third month; four times per year). 

–	 Semi-annual total coliform monitoring (at least once every sixth month; 

two times per year) in combination with routine disinfection and flushing 

three times per year (once every fourth month). 

–	 Quarterly total coliform monitoring (once every third month; four times 

per year) in combination with semi-annual (once every sixth month; two 

times per year) routine disinfection and flushing. 

–	 Monthly total coliform monitoring (once every month; 12 times per year) 

in combination with annual or less frequent routine disinfection and 

flushing (once every twelfth month or less; one time per year or less). 

•	 If not specified by the manufacturer, aircraft select any of the four disinfection and 

flushing frequencies. 

•	 Analysis of all total coliform-positive culture media for the presence of E. coli. 

•	 An option of repeat monitoring or disinfection and flushing with follow-up total 

coliform sampling as corrective action after one or more total coliform-positive 

routine samples that are E. coli-negative. The time frame for the corrective action 

is specified unless public access to the water is prevented through shut off of the 

water system or preventing the flow of water through the taps. 

•	 Disinfection and flushing with follow-up total coliform sampling as a corrective 

action after one or more total coliform-positive repeat samples or a single E. colipositive sample. 

•	 Aircraft water system operations and maintenance plans. 

•	 Compliance audits at an interval determined by EPA. 

•	 Self-inspections conducted by the air carrier. 

•	 Public notification for an E .coli-positive sample, for more than one total coliformpositive sample if disinfection and flushing as corrective action does not occur 

within the prescribed time frame, for failure to collect required routine or repeat 

samples, or if water is boarded that is of unknown quality or does not meet the 

NPDWRs. 

Page 1-7 
 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

1.4	 Economic Rationale for the Regulation 

This section discusses the statutory authority of EPA to regulate aircraft drinking water 

systems and the economic rationale for choosing a regulatory approach. 

EPA derives its statutory authority to regulate contaminants in drinking water through the 

SDWA. Section 1412(b)(1)(A) of the SDWA requires EPA to establish NPDWRs for 

contaminants that may have an adverse public health effect; that are known to occur or that 

present a substantial likelihood of occurring once in PWSs at a frequency and level of public 

concern; and that present a meaningful opportunity for health risk reduction for persons served 

by PWSs. As noted above, ICCs are considered PWSs under the SDWA. 

Executive Order 12866, Regulatory Planning and Review, directs the Agency to provide 

an economic rationale for choosing a regulatory approach. OMB circular A-4 notes that the 

rationale for regulation is to correct market failure or other social purposes: “The major types of 

market failure include: externality, market power, and inadequate or asymmetric information. 

Correcting market failures is a reason for regulation, but it is not the only reason. Other possible 

justifications include improving the functioning of government, removing distributional 

unfairness, or promoting privacy and personal freedom.” 

The economic rationale for establishing a regulation specifically designed for aircraft 

PWSs is to correct inadequate or asymmetric information. Limited monitoring has led to a lack 

of information regarding potential risks associated with consuming water onboard aircraft. As a 

result, aircraft passengers do not receive sufficient information on drinking water quality to make 

informed decisions about drinking water on aircraft. Federal intervention can be used to close 

this gap6

. 

1.5	 Document Organization 

The remainder of the document is organized into the following chapters: 

•	 Chapter 2 reviews alternative approaches that EPA considered during rule 

development and presents the rationale for the selection of the final rule option. 

•	 Chapter 3 characterizes baseline conditions that existed before systems made 

changes to meet the AOCs’ requirements including aircraft inventory, watering 

points, average number of passengers carried, and water boarding practices. The 

chapter also includes a summary of the microbiological conditions documented by 

air carrier data submitted for compliance with the AOCs. These conditions reflect 

aircraft water quality following implementation of routine water system 

6

 Federal intervention is not the only tool available to address information gaps. Other tools include state or local 

intervention and voluntary incentives. However, due to the number of aircraft and carriers covered under this rule, 

as well as the interstate nature of the business, federal intervention is deemed the most appropriate tool to use to 

address the issue. 

Page 1-8 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

disinfection and flushing practices and corrective actions prompted by coliform 

detection in water samples. 

•	 Chapter 4 presents a discussion of the risk and benefit tradeoffs between 

compliance with existing NPDWRs and the alternatives considered during the 

regulatory development process. 

•	 Chapter 5 presents an estimate of the incremental costs and thecosts of 

implementing the final rule to air carriers and EPA. The costs of the other 

regulatory alternatives as well as the proposed rule are also presented. 

•	 Chapter 6 discusses distributional analyses performed to evaluate the effects of the 

rule on different segments of the population, and considers various executive 

orders and requirements, including the Regulatory Flexibility Act (RFA) and 

Unfunded Mandates Reform Act (UMRA). 

•	 References. 

1.6	 Calculations and Citations 

This Economic and Supporting Analyses document presents results from analyses not 

explained in detail in Chapters 1 through 6. To help the reader track the various calculations and 

analyses, the following are provided: 

•	 A reference section. 

•	 Appendices. 

–	 Appendix A – ADWR Aircraft and Population Baseline 

–	 Appendix B – Aircraft Drinking Water Sampling Data 

–	 Appendix C – Cost Model 

–	 Appendix D – Screening Analysis 

•	 Exhibits. Most tabular exhibits include a row that provides the formulas used to 

compute the contents of each column. 

•	 Sources for information that was used but not calculated within the exhibits. 

Page 1-9 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Page 1-10 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

2. Consideration of Regulatory Alternatives 

2.1 Introduction 

The NPDWRs may be promulgated as either MCLs or treatment technique requirements, 

and include monitoring and reporting components. The NPDWR promulgation process requires 

that each contaminant undergo occurrence, health risk, and cost and benefit analyses. These 

analyses describe the contaminants’ effects on public health and are used to identify the most 

appropriate public health protection measures for each contaminant. Because the goal of the 

ADWR is to tailor existing NPDWRs to the unique characteristics of aircraft water systems, EPA 

determined that additional risk assessments were not necessary. 

In the rule development process, the Water Safety Plan approach, which draws on the 

principles of the hazard analysis critical control point (HACCP), and the Multiple Barrier 

approach were used to ensure the rule adequately addresses potential contamination issues at 

each step in the aircraft water system supply and transfer chain (see Exhibit 2.1). 

In addition to the requirements described under EPA regulations, there are also numerous 

FDA and FAA regulations pertaining to water onboard aircraft. The FDA and FAA regulations 

include requirements affecting design, construction, and maintenance of watering points and 

aircraft water systems. FAA regulations address portions of the maintenance plans for aircraft 

water systems and provide existing regulatory authority to ensure the plans are implemented. 

FDA, operating under 21 CFR 1240 and 21 CFR 1250, has authority and responsibility for the 

following: 

•	 Design approval for watering points and sanitation facilities at servicing areas 

•	 Ensuring that watering points, water carts, trucks, and hoses are operated in such a 

manner as to prevent contamination of the water 

•	 Review and approval of plans and specifications for design and construction of 

aircraft water systems 

Although applicable to all regulatory alternatives discussed in this document, FDA and 

FAA regulatory requirements do not be change under the revised EPA regulations. FDA and 

FAA requirements also do not affect the comparison of the regulatory alternatives throughout 

this document (i.e., they apply equally under all alternatives). Possible revisions to FDA or FAA 

regulations may be considered separately by each agency. 

This chapter describes the process used to evaluate regulatory alternatives (Section 2.2), 

and the regulatory alternatives that were considered for the development of the ADWR (Section 

Page 2-1 
 

 

Potable 

Water

 

Potable 

Water

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

2.3). Exhibit 2.1 provides an overview of the aircraft water system supply and transfer chain, 

and identifies potential causes of contamination of the onboard drinking water. 

Exhibit 2.1 Aircraft Water System Supply and Transfer Chain 

• Improperly 

maintained water 

cabinets, carts,

trucks, and hoses

• Cross contamination of surfaces

due to hand contact, splash-back, 

cleaning rags, aerosols

Airport

Lavatory Sink

Galley

Sink / 

Coffee

Public Water System

Water

Truck

Flight to Next

Airport

Water

Cabinet

Aircraft Water System

Watering

Points

Purchased water is contaminated

• Treatment failure

• Distribution system contamination

(e.g., main break, cross connection with

backflow)

• Cross contamination

from improper

handling

• Boarded water is contaminated 

• Backflow prevention device failure

• Water quality degrades/growth of

biofilm

•Improperly designed system allows

contamination

• Cross connection with backflow

• Water line break introduces 

contamination

• Improperly 

maintained water 

cabinets, carts, 

trucks, and hoses 

• Cross contamination of surfaces 

due to hand contact, splash-back, 

cleaning rags, aerosols 

Airport 

Lavatory Sink 

Galley 

Sink / 

Coffee 

Public Water System 

Water 

Truck Potable 

Water 

Flight to Next 

Airport 

Water 

Cabinet 

Aircraft Water System 

Watering 

Points 

Purchased water is contaminated 

• Treatment failure 

• Distribution system contamination 

(e.g., main break, cross connection with

backflow) 

• Cross contamination 

from improper 

handling 

• Boarded water is contaminated 

• Backflow prevention device failure 

• Water quality degrades/growth of

biofilm 

•Improperly designed system allows

contamination 

• Cross connection with backflow 

• Water line break introduces 

contamination 

2.2 Process for Development of Regulatory Alternatives 

In November 2004, EPA announced it had initiated a rule-making process to develop 

regulations for water onboard aircraft. The Agency committed to working collaboratively with 

other federal agencies overseeing the air carrier industry, industry representatives, and the 

interested public to identify appropriate requirements to ensure safe drinking water onboard 

aircraft. As a result, EPA established the ADWR Workgroup (the Workgroup), a multidiscipline, interagency team to participate in the regulatory development process. The team 

included representatives of the following EPA Offices: Water; Research and Development; 

General Counsel; Enforcement and Compliance Assurance; Policy, Economics, and Innovation; 

EPA Regions 1-7 and 9; as well as representatives of FDA and FAA. EPA also consulted with 

CDC on an as-needed basis. The Workgroup worked collaboratively with a broad range of 

industry experts and interested stakeholders including air carrier and airport owners and 

Page 2-2 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

operators, pilots, flight attendants, passengers, fixed base operators, and environmental/public 

health interests. Although the SDWA does not regulate aircraft water systems operating outside 

the U.S., EPA is supporting an international effort led by the World Health Organization (WHO) 

to develop international guidelines for aircraft drinking water. 

Given the number and complexity of issues associated with a drinking water system 

onboard a mobile unit such as an aircraft, EPA undertook an assessment approach to identify rule 

alternatives by engaging the full range of stakeholders in the regulatory development process. In 

June 2005, EPA held a public information meeting to kick off the rulemaking process. EPA 

utilized a third-party facilitator for the meeting and for the development of a stakeholder 

assessment report. The stakeholder assessment report included recommendations for a series of 

joint education workshops to bring diverse stakeholders together to identify and understand the 

issues, and to provide input and comment on various areas of concern. A summary of the public 

information meeting can be reviewed at Docket ID No. EPA-HQ-OW-2005-0025. All 

documents in the docket are listed on the www.regulations.gov website. 

The first stakeholder workshop was held January 18 and 19, 2006, and provided an 

opportunity for stakeholders to learn about aircraft water systems and watering points, current 

regulations, and other information relevant to the rulemaking. Stakeholders were encouraged to 

share their ideas about the issues that should be considered in developing the final rule. EPA 

also presented a conceptual approach for the rule framework that draws on the principles of 

HACCP, the Multiple Barrier approach used in managing traditional PWSs, and the Water 

Safety Plan approach developed and applied by the WHO in their drinking water guidelines. A 

detailed workshop summary is available in the docket. 

In 2005, EPA began establishing AOCs with 45 air carriers potentially affected by the 

ADWR. The AOCs required monitoring of each aircraft and the reporting of information on 

existing treatment practices, data collected through previous monitoring, air carrier fleet 

information, and O&M procedures. 

The second stakeholder workshop was conducted March 28 and 29, 2007. At this 

workshop, EPA presented a framework for the Water Safety Plan regulatory development 

approach. EPA also presented preliminary monitoring data collected as of mid-March 2007 

under the air carrier AOCs. The majority of the workshop was spent soliciting stakeholder input 

on topics critical to the development of the ADWR including monitoring strategies, best 

management practices, notification to passengers and crew, reporting and recordkeeping, and 

program oversight and verification. A detailed workshop summary is available in the docket. 

Based on stakeholder input, the information compiled in the framework for the Water 

Safety Plan approach, and the preliminary monitoring data provided by the air carriers, the 

Workgroup identified and developed four regulatory alternatives. The alternatives were 

developed with consideration of several key questions, such as: 

• What health effects will the ADWR address? 

• Which contaminants should be regulated? 

Page 2-3 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

•	 Should there be monitoring requirements? 

•	 What, if any, onboard treatment options are feasible for air carriers? 

•	 Which best management practices (BMPs) should be included in the rule? 

•	 How can ADWR requirements be integrated with existing air carrier programs 

(i.e., maintenance programs for other aircraft components)? 

2.3	 Regulatory Alternatives Considered 

Based on input from the Workgroup and other stakeholders, EPA identified and 

developed four regulatory alternatives for consideration: 

•	 Alternative 1 – Existing Drinking Water Regulations 

•	 Alternative 2 – Regulatory Requirements Similar to the AOCs 

•	 Alternative 3 – Regulatory Requirements Similar to WSG 29 

•	 Alternative 4 – Hybrid Approach - ADWR 

Each alternative is described below and summarized in the matrix that follows this 

chapter (Exhibit 2.2b). The first three alternatives represent key elements of the baseline 

scenario of existing NPDWRs and two previous approaches to regulating aircraft PWSs. Each 

was carefully considered as a possible option, including evaluation of their strengths and 

weaknesses. The proposed rule was developed by combining what were perceived to be 

strengths of the other alternatives with additional insight contributed by stakeholders. The first 

three alternatives were not proposed by the Agency as rule options. 

The proposed rule was published in the Federal Register on April 9, 2008 (73 FR 19320). 

The public comment period closed on July 8, 2008, and public input was evaluated by the 

Agency during development of the final rule. 

Although aircraft PWSs are not technically considered consecutive water systems, for the 

purpose of this rule and based on FDA requirements, it is assumed aircraft are boarding potable 

(finished) drinking water that meets NPDWR standards and that the equipment used in 

transferring this water to the aircraft is maintained and operated so as to preserve that level of 

water quality. Descriptions of FDA requirements are included in Exhibit 2.2a at the end of this 

chapter to provide a full picture of the regulatory landscape under which aircraft PWSs operate. 

Because the FDA requirements are existing regulations and apply in all cases regardless of the 

final ADWR, they are not re-stated in the discussion of each alternative. However, each 

alternative also assumes that it is possible for contamination to occur during the water transfer 

Page 2-4 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

process, for water to be boarded that is in violation of a NPDWR of significance to transient 

consumers, and that water quality onboard the aircraft may deteriorate over time unless 

management of water age is included in aircraft water system operations. In addition, in each 

alternative aircraft PWSs are categorized as TNCWSs using finished surface water or finished 

ground water under the direct influence of surface water, and serving 25 to 1,000 people per day. 

This categorization is also not re-stated in the discussion of each alternative. 

2.3.1	 Alternative 1 – Baseline Alternative: Existing NPDWRs 

The baseline alternative includes the current requirements for aircraft PWSs under the 

applicable NPDWRs. Applicable regulations are those relevant to short-term rather than longterm exposure to the drinking water. Under the baseline alternative, aircraft would be required to 

comply with the regulations for coliforms, disinfectant residuals in the distribution system, and 

public notification. The subsections below describe each of these requirements. 

Coliform Bacteria 

Coliform testing of drinking water is required under the TCR and is intended to provide 

an indication of possible contamination of the water system by microbes. The existing TCR 

would apply the following requirements to aircraft PWSs: 

•	 Water from taps in lavatories and galleys would be sampled and analyzed as 

follows: 

–	 Routine monitoring: One sample would be collected per month from each 

aircraft. The sample location would be adjusted each month according to 

a written sample siting plan. Samples would be tested for total coliforms, 

and total coliform-positive sample cultures would be analyzed for either 

fecal coliform or E. coli. 

–	 Repeat monitoring: Four repeat samples would be collected within 24 

hours of notification of a total coliform-positive routine sample. The four 

sampling sites would include the original test site and three additional taps 

distributed throughout the aircraft water system. If fewer than four 

sampling sites exist onboard, then 400 mL of sample must be taken from 

available sample sites (i.e., if there is only one tap, a 400 mL sample or 

four 100 mL samples would be drawn from that tap). 

–	 Additional routine samples: In the month following a positive routine 

sample, a minimum of five routine samples must be collected. 

–	 The aircraft PWS is in violation of the monthly MCL if it has more than 

one total coliform-positive sample per month. The aircraft triggers an 

acute MCL violation if it has a repeat sample that tests positive for fecal 

coliform or E. coli, or has a routine sample that tests positive for fecal 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

coliform or E. coli that is followed by a total coliform-positive repeat 

sample. 

•	 Sanitary surveys would be conducted every 5 years. 

•	 No corrective action, such as disinfection and/or flushing the water system, is 

specified in the regulation. 

•	 Public notification requirements would apply which state the air carrier must 

notify the primacy agency within 24 hours of receiving notice of the fecal 

coliform or E. coli-positive result. In the case of a monthly MCL violation, the air 

carrier would be required to notify the public within 30 days. In the case of an 

acute violation, the air carrier would be required to notify the public within 24 

hours as described below for a violation requiring Tier 1 public notice. 

Distribution System Disinfectant Residual 

The Surface Water Treatment Rule requires systems using surface water or GWUDI to 

monitor the disinfectant residual in the distribution system. The distribution system disinfectant 

residual is used as an indicator of whether the water is adequately disinfected. The disinfectant 

residual in the distribution system is not expected to inactivate disinfectant-resistant pathogens. 

•	 Sampling frequency: Disinfectant residuals in the distribution system must be 

monitored at the same time and location as coliform samples are monitored. For 

aircraft, a single residual would be monitored each month when routine coliform 

samples are collected and additional residual measurements would be required for 

each repeat coliform sample. 

•	 Alternative sampling: The aircraft may monitor for heterotrophic bacteria using 

heterotrophic plate counts (HPCs) instead of testing for disinfectant residual. 

•	 Compliance: Disinfectant residual concentration must be detectable in the 

distribution system. If conducting a HPC instead of testing for disinfectant 

residual, a heterotrophic bacteria concentration of less than or equal to 500 

cfu/mL is considered equivalent to a detectable residual. A violation is incurred if 

the system fails to have a detectable residual in the samples for two consecutive 

months. 

•	 Public notification: Failure to meet the requirements for disinfectant residual or 

heterotrophic bacteria requires the aircraft to implement the measures of a Tier 2 

public notice (see below). 

Public Notification for Violations of NPDWRs 

The baseline requirements for coliforms where an acute violation is incurred that are 

described above would require implementation of Tier 1 public notice measures. The air carrier 

Page 2-6 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

must attempt to notify the public served within 24 hours in the form of a Tier 1 notice, which for 

TNCWSs typically means posting notice in the area where people are served, hand delivery of a 

communication, and/or broadcasting the notice using a public address system. The air carrier 

must also initiate consultation with the primacy agency as soon as practical and at least within 24 

hours after receiving notification of the test results to determine if further public notification 

steps are required. For non-acute coliform violations and for violations of the requirement for a 

disinfectant residual in the distribution system, the aircraft would provide Tier 2 public notice. 

This is also typically posted or hand delivered to users of the TNCWS, and the regulation allows 

30 days for notice to be provided. 

2.3.2	 Alternative 2 – Regulatory Requirements Similar to the AOCs 

An AOC regulatory alternative would require aircraft PWSs to implement monitoring for 

coliforms and disinfectant residuals, an operations and maintenance program that includes 

routine disinfection and flushing, disinfection and flushing as corrective action, and reporting 

procedures consistent with the requirements established under the AOCs. The requirements, or 

orders, of the AOCs were based on a finding that the air carriers were not meeting the existing 

NPDWR requirements as described in the baseline alternative. 

Under the AOCs, air carriers are required to do the following: 

•	 Supply fleet information to EPA in the EPA-specified format. 

•	 Provide EPA with a copy of the current policies and practices for boarding 

domestic water and foreign-source water using the EPA-specified format. 

•	 Provide EPA with a copy of current O&M practices. 

•	 Provide EPA with data from current or previous drinking water monitoring 

programs. 

•	 Continue with the pre-AOC monitoring program if coliform monitoring was 

occurring more than once per year. 

•	 Submit a Comprehensive Representative Monitoring Plan (CRMP) to EPA within 

30 days of the AOC’s effective date. 

•	 Submit a QAPP to EPA within 30 days of the AOC’s effective date. 

•	 Implement Period I monitoring within 15 days after written approval from EPA of 

the CRMP and QAPP. 

•	 Under Period I monitoring, implement the following: 

–	 Disinfect the aircraft water system quarterly. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

–	 Disinfect the watering points owned by the air carrier monthly and in 

accordance with an O&M plan. If the pre-AOC O&M plan required more 

frequent disinfection than monthly, continue at that higher frequency. 

–	 If the aircraft fleet consists of less than or equal to 20 aircraft, sample all 

aircraft for total coliform quarterly; if the aircraft fleet consists of more 

than 20 aircraft, sample approximately 25 percent of the fleet of aircraft 

quarterly, so that all aircraft are sampled for total coliform at least 

annually. Any total coliform-positive sample culture would be tested for 

fecal coliform or E. coli. 

–	 Perform disinfection and flushing and follow-up sampling as corrective 

action where any routine or follow-up sample is total coliform-positive. 

–	 Report monitoring results quarterly. 

–	 Submit a self-certification each quarter that affirms that the aircraft water 

system and air carrier-owned watering points are disinfected as per the 

O&M plan. 

•	 After 12 months of Period I monitoring, the air carrier was to consult with EPA 

and an agreement made, or a program prescribed by EPA in the absence of 

agreement, for a monitoring, disinfection, and reporting frequency and response 

procedure which would be implemented in months 12 through 24, or Period II, of 

the monitoring program. 

•	 During the 24 months of Monitoring Periods I and II, the air carrier was to 

conduct a study of potential confounding or contributing sources of contamination 

that are external to the aircraft, i.e., watering points. The air carrier was to submit 

the study results to EPA within 24 months of the effective date of the AOC. 

Under this alternative, all qualifying aircraft would be required to establish a program of 

sampling, routine disinfection and flushing, reporting, and a response procedure that is consistent 

with the parameters established under Monitoring Period I of the AOCs: 

•	 All personnel responsible for the O&M of aircraft water systems would receive 

training. The training would be implemented by the air carrier responsible for the 

aircraft. 

•	 Aircraft O&M and monitoring plans must be updated to reflect new schedules, 

procedures, and activities. 

•	 Aircraft must monitor for total coliforms and disinfectant residual. 

Page 2-8 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

•	 If a system tests positive for total coliforms, it must analyze the total coliformpositive culture medium for fecal coliform or E. coli. 

•	 If a system tests positive for fecal coliform or E. coli, or if it tests positive for total 

coliform in any sample, it must notify the primacy agency within 24 hours and 

must conduct disinfection and flushing procedures, including follow-up sampling, 

and must implement public notification activities. 

•	 Copies of O&M plans, monitoring plans, and monitoring data must be 

maintained. 

•	 Approximately 25 percent of the aircraft fleet must be monitored for coliforms 

and disinfectant residual quarterly, so that all aircraft are sampled at least 

annually. 

•	 Routine disinfection and flushing must be performed at least quarterly. 

•	 A self-certification that affirms that the aircraft water system was disinfected and 

flushed according to the O&M plan must be submitted each quarter. 

•	 Report monitoring results quarterly (within 10 business days of the end of a 

quarter of monitoring). 

2.3.3	 Alternative 3 – Requirements Similar to Water Supply Guidance 29 

Upon promulgation of the SDWA in 1974, EPA’s responsibilities for ensuring that safe 

drinking water was served on ICCs broadened from certifying the PWSs serving ICCs to include 

regulation of the water quality onboard the conveyances. WSG 29, signed in 1986, outlined 

EPA’s role in implementing NPDWRs with respect to Interstate Carrier Water Supplies 

(ICWSs), watering points, and ICCs, and established the coordination of this role with the FDA’s 

responsibilities in the Interstate Travel Sanitation Program. WSG 29 allowed aircraft to choose 

between monitoring for turbidity, total coliforms, and disinfectant residuals and the 

implementation of an operations and maintenance program that included disinfection and 

flushing the aircraft. It is notable that WSG 29 was written prior to promulgation of the TCR, 

the SWTR, or Phase II Chemical contaminant rule (which included revised requirements for 

nitrate). Therefore, for this alternative, the monitoring requirements have not been revised to 

reflect current requirements of the NPDWRS as described in the baseline alternative. The WSG 

29 alternative was considered primarily because it recognized the importance of disinfection and 

flushing as a treatment technique/best management practice in the operation and maintenance of 

aircraft PWSs. It also offered flexibility through a choice between monitoring and implementing 

an EPA-approved operation and maintenance program. 

Under the alternative based on WSG 29, the following would be included: 

•	 Aircraft would comply either with the monitoring and reporting requirements or 

with their EPA-approved O&M plans. 

Page 2-9 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

•	 Monitoring requirements would include daily turbidity monitoring and quarterly 

coliform monitoring. 

•	 Disinfection and flushing as corrective action would be required following a total 

coliform-positive sample. 

•	 O&M requirements for quarterly disinfection and flushing of onboard systems. 

2.3.4	 Alternative 4 – Hybrid Approach - ADWR 

EPA developed the proposed regulatory option based on input from the Workgroup, 

senior management, and stakeholders. It was developed following the March 2007 workshop 

where stakeholders and the Workgroup discussed limitations of the other alternatives and key 

provisions of a possible ADWR. EPA reviewed public comments received on the proposed rule 

and incorporated specific items during development of the final rule. The final rule addresses 

stakeholder and commenter concerns including: (1) the need for operational flexibility by 

providing several options for compliance, (2) the need to not conflict with manufacturers’ 

recommendations, (3) the need to limit the grounding of aircraft based on water system issues to 

situations that present an acute public health risk and only when public access to the water 

cannot be prevented, and (4) the need to allow for future changes in technology. 

EPA is presenting key components of the final rule: 

•	 Routine coliform monitoring using one of four monitoring frequency options 

determined by the frequency of disinfection and flushing of the aircraft water 

system. 

•	 Two routine coliform samples are collected at the frequency chosen. If one or 

more of the routine samples are total coliform-positive but are E. coli-negative, the 

aircraft can choose to either perform repeat sampling (collecting 3 samples) or 

corrective action to include disinfection and flushing and follow-up monitoring. 

Special consideration is given for aircraft with a single water tank and tap if the 

tank is removable and drained daily. Those aircraft may collect a single routine 

sample at the frequency chosen. 

•	 Disinfection and flushing as corrective action must occur in the event of an E. 

coli-positive sample or if any repeat samples are total coliform-positive. If 

disinfection and flushing as corrective action is required, public access to water 

must be restricted and public notice must be posted until the water system is 

disinfected and flushed and a complete set of follow-up samples are taken. In 

cases of total coliform-positive results, aircraft may resume serving water for 

human consumption once follow-up samples have been taken. In cases of E. colipositive results, the aircraft may not serve water for human consumption until all 

follow-up samples are total coliform-negative. The rule specifies a maximum 

amount of time that can elapse before corrective action disinfection and flushing 

Page 2-10 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

occurs if the water cannot be physically shut off or water flow through the taps 

cannot be prevented. Allowing more time for corrective action disinfection and 

flushing where public access can be prevented provides flexibility to air carriers 

for performing the procedure and minimizes the need for unscheduled events for 

which the aircraft must be taken out of service. 

•	 Disinfectant residual monitoring is not required by the final rule, but may be 

recommended in guidance as a means of promoting voluntary measures such as 

flushing and refilling with water containing a residual. 

•	 Specific training requirements for all personnel involved with the aircraft water 

system operations and maintenance provisions of the ADWR must be included in 

the aircraft O&M plan. 

•	 Detailed disinfection and flushing procedures must be included in O&M plans. 

•	 Reporting requirements for disinfection and flushing and monitoring results, and 

compliance status. 

•	 Water system O&M plans must be incorporated into FAA-accepted O&M plans 

for aircraft. 

•	 EPA may perform compliance audits as needed. 

•	 Aircraft perform self-inspections of the water system at least every 5 years and 

self-certify completion of the inspections. 

The regulatory requirements under the four alternatives are presented in summary form in 

the matrix in Exhibits 2.2a and 2.2b, below. Exhibit 2.2a includes those activities that are 

required by FDA regulations. These relate to watering points, or water transfer and delivery 

systems, which include the water source, trucks, carts, cabinets, containers, and hoses. These 

requirements are not affected by the final rule and will continue to be in effect under all 

regulatory alternatives. Exhibit 2.2b summarizes those activities related to onboard water system 

operation and maintenance. 

Page 2-11 
 

 

Requirement Existing FDA Regulations Applicable to Watering Points 

under all ADWR Alternatives 

Design approval for watering 

points 

FDA approval of watering points (21 CFR 1240.83) based on 

water supply meeting NPDWRs, and the methods/facilities for 

water delivery to conveyance are sanitary and satisfactory. 

Design approval for sanitation 

facilities at servicing areas Submit construction plans to FDA for review (21 CFR1250.62) 

Disinfect and flush watering 

points 

Operate and maintain servicing area pipes and appurtenances 

to prevent contamination of the water per FDA (21 

CFR1250.67) 

Disinfect and flush water carts 

and trucks 

Operate and maintain servicing area pipes and appurtenances 

to prevent contamination of the water per FDA (21 

CFR1250.67) [Note: no frequency or minimum criteria specified] 

Inspection of servicing area 

FDA may inspect servicing areas or may approve/disapprove 

based on inspections by state health department (21 

CFR1250.61) [Note: no inspection frequency specified] 

Supplemental Treatment Plan 

and Specifications Review and 

Approval of Design and 

Construction 

Obtain FDA approval for treatment equipment onboard the 

aircraft (21 CFR1240.90) 

1

 Watering points include transfer and delivery systems (including the water source, trucks, carts, cabinets, 

 containers, and hoses) 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 2.2a Existing FDA Requirements for Watering Points1 and Supplemental 

Treatment
 

Page 2-12 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit 2.2b Alternatives Considered for the ADWR – Aircraft Water System

Potential 

Components a

Rule Start-up – aircraft water systems 

Rule Start-up– primacy agency 

Qualified operators 

Baseline Alternative: 

Current NPDWRs1 and 

pplicable FDA and FAA 

regulations 

Assume air carrier personnel are familiar with requirements of existing regulations and have developed management systems to implement theserequirements. Assume primacy agency has developed necessary reporting and 

recordkeeping systems. PWSs using surface water or GWUDI must be 

operated by qualified personnel who meet the requirements specified by the state (40 CFR141.70). 

Regulatory 

Requirements Similar 

to the AOCs 

Read and understand regulatory requirements. Establish new reporting and recordkeeping systems. 

Personnel to be trained and training content to be included in CRMP. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

Read and understand regulatory requirements. Establish new reporting and 

recordkeeping systems. 

No new requirements. 

Hybrid A

Read and understand regu

Establish new reporting an

Operator “need-to-know” i

requirements to be include
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Potential 

Components 

Develop and implement monitoring 

plan Routine monitoring – coliform bacteria 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA 

regulations 

Develop sample siting plan 

to include sample collection 

locations (40 CFR 141.21). One total coliform sample monthly at individual aircraft, in accordance with sample siting plan (40 CFR141.21). Any total coliform-positive sample is analyzed for fecal coliform or E. coli. 

Regulatory 

Requirements Similar 

to the AOCs 

Update monitoring plans to reflect new schedules, procedures, and activities. Air carriers must sample 

approximately 25% of the aircraft fleet quarterly, so that all aircraft are sampled at least annually. Two samples must be collected from each individual aircraft – one galley and one lavatory tap sample. Any total coliformpositive sample is analyzed for fecal coliform or E. coli. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

No monitoring required if O&M plan approved by EPA. One sample 

quarterly if not implementing O&M plan. 

Hybrid A

Monitoring frequency to be included in the aircraft O&

disinfection and flushing frColiform monitoring freque

selected by the air carrier on the disinfection and flusplan: (1) annual monitoring (oncdisinfection and flushing cevery third month); (2) semi-annual monitoring routine disinfection and flumonths (three times per ye

(3) quarterly monitoring (o

disinfection and flushing cevery sixth month); (4) monthly monitoring (ondisinfection and flushing c(once every twelfth month Aircraft with a single sampremovable and drained daroutine sample each moni
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Potential 

Components 

Repeat monitoring – coliform bacteria Additional routine monitoring – coliform bacteria Post disinfection monitoring – coliform bacteria 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA 

regulations 

Repeat sampling requires 4 

samples (one upstream, one downstream, one at thesame sampling point, and one at another point if 4 taps are available) within 24hrs. Any total coliformpositive sample is analyzed 

for fecal coliform or E. coli. 

If a routine total coliform sample is positive, systems taking less than 5 routine samples per month must collect 5 routine samples in the following month per the sample siting plan or obtain a waiver (40 CFR 141.21). Any total coliform- positive sample is analyzed for fecal coliform or E. coli. Not required. 

Regulatory 

Requirements Similar 

to the AOCs 

Repeat sampling at 4 taps (tap with positive coliform sample, 1 other lavatory tap, 1 other galley tap, and 1 other tap; or total of 400 mL from available taps). If a sample tests positive for total coliforms in a routine sample, it must be analyzed for fecal coliform or E. coli. 

Not required. 

Collect 4 samples (1 

galley tap, 1 lavatory tap, the tap positive for total coliform, and 1 other tap). Any total coliform-positive sample is analyzed for fecal coliform or E. coli. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance

29 

Not specified. 

Not required. 

Not required. 

Hybrid A

If one or more routine sam

but E. coli negative, the ai

collecting a set of 3 repeat 

notification. Any total coliffor E. coli. 

Not required. 

Two follow-up samples aftand flushing, taken at the routine sample collection. 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Potential 

Components 

Routine monitoring – disinfectant residual 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA 

regulations 

One disinfectant residual sample monthly at individual aircraft per SWTR, at same location and time as coliform sample (40 CFR 141.74(b)(6)(i) and/or (c)(3)(i)). 

Regulatory 

Requirements Similar 

to the AOCs 

Annual at individual aircraft at same locations as routine coliform samples 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

Not required. 

Hybrid A

Not required. 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Potential 

Components 

Develop and implement O&M plan 

e 

f 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA

regulations 

Best Available Technology (BAT) for TCR MCLs: Implement proper maintenance of the distribution system including appropriate pipe replacement and repair procedures, main flushing programs, proper operationand maintenance of storagtanks, and continual maintenance of positive water pressure in all parts of the distribution system (40 CFR 141.63D) FAA regulations require theuse of manufacturers recommendations: - Develop and implement amaintenance and inspection program that guarantees airworthiness oaircraft (14 CFR 121.367). - Use BMPs prescribed by manufacturer’s maintenance manual (14 CFR 43). - Use maintenance schedule in accordance with manufacturer (14 CFR25.1529 Appendix H). 

Regulatory 

Requirements Similar 

to the AOCs 

Update O&M plans to 

reflect new schedules, procedures, and activities. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

O&M plan may be 

developed in lieu of required monitoring. Plan to be approved by EPA regional office with following elements: -Cover letter 

summarizing water handling procedures, maintenance schedule, and description of annual report data 

-Disinfection and 

flushing procedure as outlined in WSG 29, or equivalent procedure 

Hybrid A

O&M plans must address 

disinfection and flushing pprocedures for follow-up srequirements; procedures 

for boarding water; the colthe aircraft water system cthrough the taps can be pr
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Potential 

Components 

Routine disinfect and flush aircraft water system 

Disinfect and flush 

aircraft water system as corrective action 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA 

regulations 

Inspect, disinfect, and sanitize water system as needed to prevent spread of disease per FDA (21 CFR 1240.30). Clean, disinfect and flush aircraft water system whenever FDA deems it necessary (21 CFR 1250.81). Clean, disinfect and flush 

aircraft water system whenever FDA deems it necessary (21 CFR 1250.81). 

Regulatory 

Requirements Similar 

to the AOCs 

isinfect the aircraft ater system quarterly 

n accordance with AOC 

&M plan; if pre-AOC 

&M plan required 

ore frequent 

isinfection than 

onthly, continue at that 

igher frequency. 

ubmit self-certification 

uarterly to EPA 

ndicating that 

isinfection process 

ollowed proper 

rocedures. 

isinfection after total 

oliform-positive 

ample. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

Quarterly per O&M plan and after any service or repairs; remove aircraft from service and disinfect holding tanks if aircraft served by useprohibited watering 

points. Required after any 

service or repairs or if the aircraft opts for monitoring and has a total coliformpositive sample; no monitoring to trigger corrective action if choose O&M option. 

Hybrid A

Aircraft follow 1 of 4 frequeflushing: (1) quarterly (once every t(2) 3 times per year (one e(3) 2 times per year (once (4) once per year or less (The air carrier must select accordance with manufactis no such manufacturer recarrier selects any on of thThe frequency determines monitoring schedule as deRequired if any sample is 

repeat samples or follow-upositive but E. coli –negatMust be conducted prior to public access to the aircra72 hours after notification cannot be physically shut 

prevented, or when able if flow is prevented. Aircraft that fail to conduct 72 hours and do not physiflow through the taps musaccess to the water within 

DwiOOmdmhSqidfpD

cs
Potential 

Components 

Supplemental 

Treatment 

Sanitary survey – primacy agency Sanitary survey – water system 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA 

regulations 

Not specified. Assume primacy agency has developed and implemented a program to conduct sanitary surveys (40 CFR 142.10(b)(2)). Primacy agency conducts sanitary surveys for all noncommunity systems served by surface water or GWUDI every 5 years per IESWTR (40 CFR 141.21(d)). 

Water systems prepare for sanitary survey every 5 years per IESWTR (40 CFR 141.21(d)). 

Regulatory 

Requirements Similar 

to the AOCs 

Not specified.

Not specified. Not specified. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

Not specified.

Not specified. 

Not specified. 

Hybrid A

Not specified. (If onboard 

must be acceptable to FDA Science Foundation (NSFStandards Institute (ANSI) 

operated, and maintained manufacturer's specificatio

Compliance audits at the d

Self-inspection performed 

and self-certified to EPA. 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Potential 

Components 

Public Notification [Note: This element not costed under this ruling but covered under the Information Collection Request 

(ICR) for the final ADWR and will be incorporated into the next revision of the ICR for the PN Rule] 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA 

regulations 

- Post FDA certificates on conveyances (21 CFR 1240.20). -Per 40 CFR 141.201 Subpart Q: Each owner or operator of a PWS must give notice of all 

NPDWR violations, operating status under variances and exemptions, failure to comply with schedules established by variance or an exemption, and occurrence of a waterborne disease outbreak. 

Regulatory 

Requirements Similar 

to the AOCs 

PN required when aircraft cannot cease serving water to the public within 24 hours of receiving a total coliform-positive or fecal coliform/E. coli-positive 

result. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

ost placards at all 

aps when MCL 

xceeded. 

Hybrid A

N required whenever the 

equirements are in place. 

Pt

Pr

e
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Potential 

Components 

Reporting and Recordkeeping 

Baseline Alternative: 

Current NPDWRs1 and 

applicable FDA and FAA 

regulations 

Per 40 CFR 141 Subpart D: -Report to State results of 

monitoring conducted by private labs (non-State labs); failure to comply with NPDWRs; certification of compliance with public notification requirements including copies of all public notices; copies of records maintained on premises. 

-Maintain following records 

related to NPDWR 

compliance on premises: bacteriological analyses (5 years), chemical analyses (10 years), records of actions taken to correct compliance issues (3 years), sanitary surveys and related reports and communications (10 years), records on any variance or exemption (5 years), and copies of public notices (3 years). 

Regulatory 

Requirements Similar

to the AOCs 

Report the monitoring 

results quarterly (within 10 business days of theend of a quarter of monitoring). 

Submit a selfcertification each quarter that affirms that the aircraft water system(s) and watering points are disinfected aper the O&M plan. Air carriers must 

maintain copies of their O&M plan, monitoring plan, and monitoring data. 

Regulatory 

Requirements 

Similar to Water 

Supply Guidance 

29 

Maintain a maintenance log for each aircraft and submit an annual summary report of each aircraft’s maintenance procedures to EPA. 

Maintain records of O&M procedures for 5 years. Air carriers that 

choose to conduct 

monitoring must keep a copy of their monitoring plan and monitoring results for at least 5 years, and report monitoring results to EPA on quarterly basis along with maintenance records for any aircraft with total coliform-positive 

samples. 

Hybrid A

Report disinfection and fluresults within 10 days of thThe air carrier must providwithin 90 days of completifrom self-inspections have must report within 90 days during a compliance audit identified during a complianot been addressed within report must explain why aaddressing them. Report that a coliform sam

an O&M plan was developmonitoring frequency withpromulgation and within th

additional aircraft to the aiChanges to the routine cobe reported within 10 days which the change occurredReport inventory within 18 

subsequent changes in invof the calendar month in wReport all events requiring with the disinfection and flrequirements. Maintain the following recoyears), disinfection and flu(10 years), notices to passissues (3 years after issua

s 

plans. 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

1 NPDWR requirements for TNCWSs using surface water (serving 1,000 or fewer people). Although aircraft PWSs are not 

consecutive systems, assume the aircraft is boarding water that meets FDA requirements for potable water in compliance w

technique requirements of EPA’s regulations (source water treatment provided). Therefore, turbidity and nitrate/nitrite mon

2 As used here, the use of supplemental treatment onboard aircraft such as booster chlorination, ultraviolet disinfection, and 

serves as an additional barrier to address water quality deterioration in the aircraft water system. It does not replace the FDwatering point water supplies meet the requirements of the NPDWRs. 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

3. Baseline Analysis 

3.1 Introduction 

This chapter describes the baseline analysis that characterizes the number of aircraft 

public water systems and affected air carriers in existence as of January 2007 when the 

evaluation of potential regulatory options for aircraft water systems was initiated, as well as the 

quality of water onboard aircraft as of December 31, 2008. The baseline analysis consists of the 

following processes: 

•	 Creating an industry profile (Section 3.2) - Identifying and collecting 

information on aircraft subject to the ADWR and estimating the potentially 

affected population. 

•	 Documenting data collection efforts (Section 3.3) - Summarizing results of 

aircraft water quality data collection efforts and characterizing aircraft water 

quality. 

This chapter presents a level of detail and precision appropriate to support subsequent 

analyses and regulatory decisions under the ADWR. Uncertainties in the ADWR baseline are 

discussed in Section 3.4. 

3.2	 Industry Profile 

This section provides a characterization of aircraft water systems that is used to perform 

analyses of ADWR regulatory alternatives. Extensive effort was invested in January 2007 in 

establishing the baseline of aircraft water systems for development of the proposed rule. 

Although air carriers may have changes in their fleet and consolidations have occurred in the 

industry, there has likely not been a significant permanent change in the total number of aircraft 

or passengers, or the types of aircraft transporting the majority of passengers, particularly given 

the relatively short period of time between the proposal and final rule publications. The aircraft 

water system baseline is organized as follows: 

•	 Section 3.2.1 describes the data sources used to characterize the industry baseline. 

•	 Section 3.2.2 is a background section describing the various ways in which water 

systems can be classified and identifies distinctions that are important for this 

analysis. 

•	 Section 3.2.3 provides the baseline number of aircraft and the estimated 

population served by aircraft water systems per year. 

Page 3-1 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

3.1.1	 Data Sources 

Several data sources were used to characterize the ADWR baseline. Data from the 

AOCs, Bureau of Transportation Statistics (BTS), FAA, commercial air carrier web sites, and 

aircraft manufacturer web sites were used to create an aircraft water system and population 

baseline. BTS is the data collection and analysis arm of the U.S. Department of Transportation 

(DOT), and provides data for load factor, flights per year, and passengers per year for a number 

of large air carriers. FAA, which regulates all civil aviation in the U.S., requires that the number 

of onboard staff be based on the number of onboard passengers (14 CFR 91.533 and 14 CFR 

125.269). A number of commercial air carrier web sites provide data on seating configurations, 

including carrying capacity and number of lavatories and galleys. Standard seating 

configurations provided by aircraft manufacturer web sites were used if the information was not 

available through air carrier Web sites. Commercial air carriers are required to make their 

annual reports to shareholders available to the public. These reports provide data on load factors, 

flights per year, and fleet size. 

3.1.2	 Water System Characterization 

Categorization of water systems is important because system size, ownership, and 

consecutive/wholesale relationships affect the way in which regulatory analyses are performed. 

This section explains the classifications of water systems, as defined by EPA’s NPDWRs, and 

describes further subdivisions according to water source, size (population served), and ownership 

for regulatory analysis purposes. 

Public Water System Type 

NPDWRs apply to all PWSs.7 A PWS is defined as a system that provides water for 

human consumption through pipes or other constructed conveyances if such a system has at least 

15 service connections or regularly serves an average of at least 25 individuals per day for at 

least 60 days per year. PWSs are categorized as follows: 

•	 Community Water Systems (CWSs) are PWSs that have at least 15 service 

connections used by year-round residents or that regularly serve at least 25 yearround residents. 

•	 Non-community Water Systems (NCWSs) are PWSs that are not classified as 

CWSs. 

NCWSs are subdivided into two categories: 

•	 Non-transient Non-community Water Systems (NTNCWSs) are NCWSs that 

regularly serve at least 25 of the same people more than 6 months per year. 

7

 Some PWSs that meet specific criteria in 40 CFR 141.3 are exempt from NPDWRs. ICCs are specifically not 

exempt from NPDWRs. 

Page 3-2 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

•	 Transient Non-community Water Systems (TNCWSs) are NCWSs that do not 

regularly serve at least 25 of the same people more than 6 months per year. 

Most commercial passenger aircraft serve at least 25 individuals per day for at least 60 days per 

year. However, it is unlikely that any single aircraft regularly serves the same 25 people for 

more than six months per year. Therefore, for the purposes of the ADWR, all aircraft public 

water systems are classified as TNCWSs. 

Source Water Type 

Systems are classified by the type of source from which they draw water. Systems that 

use either surface water or GWUDI are classified as surface water systems. Ground water 

systems are, by default, systems that draw from ground water sources that are not GWUDI. 

Some systems may obtain water from both ground water and surface water sources and are 

referred to as “mixed systems.” In the Safe Drinking Water Information System (SDWIS) and 

the Baseline Handbook, a mixed system is categorized as a surface water system because it 

obtains some portion of its flow from surface water (i.e., all mixed systems are considered 

surface water systems). 

For the purposes of the ADWR baseline and subsequent analyses in this document, all 

aircraft are classified as surface water systems. Aircraft board water from a number of different 

locations across the U.S. and are likely to be served by many different public water systems, 

including surface water systems. Additionally, most large cities and municipalities where 

airports are located are served by surface water systems. For the purposes of this document, 

EPA is assuming that all aircraft board water from either mixed or surface water systems. 

Population Served 

The number of passengers per year for any aircraft is estimated by multiplying the 

carrying capacity of the aircraft, the loading factor (percentage of seats occupied) for the air 

carrier, and its yearly flight frequency. Passenger figures for all aircraft are summed to arrive at 

the yearly total number of passengers. The number of onboard staff is estimated based on FAA 

requirements (14 CFR 91.533 and 14 CFR 125.269), which provide a relationship between the 

number of required pilots and flight attendants and the number of onboard passengers. The total 

numbers of passengers and onboard staff represent all people potentially exposed to drinking 

water from an onboard water system (population served) at some time during the year. Although 

crew and some passengers take more than one flight per year, the total number of passengers and 

crew has not been adjusted to account for this difference. For purposes the ADWR, population 

figures are presented in the nine categories corresponding to the number of available sampling 

points onboard an aircraft (see Exhibit 3.1). Appendix A provides a detailed breakdown of 

aircraft data used to develop the population-served figures for onboard staff, passengers, and 

total population figures presented in Exhibit 3.1. 

Ownership 

Page 3-3 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Systems are categorized in SDWIS and in the Baseline Handbook according to three 

ownership types: “private,” “public,” and “other.” Private systems are owned by private 

corporations or individuals. Public systems are owned by public entities such as municipalities, 

counties, or special districts. The “other” category contains systems where ownership is not 

reported in SDWIS. Ownership distinctions are important to the analysis because public systems 

may have access to capital and other means of financing that may not be available to private 

systems. 

For the purposes of this document, all aircraft are classified as private ownership. 

Consecutive and Wholesale System Types 

Typical PWSs are normally categorized according to whether they produce finished 

water by monitoring and providing appropriate treatment to their source water, or obtain finished 

water from other PWS(s). Finished water is water introduced into the distribution system of a 

PWS and is intended for consumption without further treatment, except for treatment necessary 

to maintain water quality in the distribution system. Finished water is often referred to as 

potable water. A consecutive system is defined as a PWS that receives some or all of its finished 

water from one or more wholesale systems. A wholesale system is defined as a PWS that 

monitors and treats as appropriate, source water and then sells or otherwise delivers finished 

water to another PWS. Treatment applied to finished water by consecutive water systems may 

be in the form of booster disinfection or addition of corrosion control chemicals. Costs of 

treatment provided by wholesale systems are typically passed on to the consecutive systems in 

the form of water rates or fees. 

FDA requirements mandate that aircraft provide only potable water that meets EPA 

standards for drinking water (21 CFR 1240.80). Because they board only finished water, for the 

purposes of ADWR analyses, all aircraft are treated as equivalent to consecutive water systems. 

3.1.3 Baseline Number of Aircraft and Population Served by Aircraft per Year 

Number of Aircraft 

EPA estimated in January 2007 that 7,327 aircraft are subject to the final ADWR. The 

aircraft inventory presented in Exhibit 3.1 represents the baseline for rule activities that are 

applicable on an individual aircraft level (e.g., monitoring, disinfection and flushing, selfinspections, and compliance audits). Annual implementation and administration activities, as 

well as development of sampling plans and O&M plans, will occur on an individual air carrier 

basis. 

Page 3-4 
 

 

# of Available Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points # of Onboard Staff/year # of Passengers/year 

Total # of Potentially 

Affected Persons/year 

A B C=B*A D E F=D+E

1 

2 

3 

4 

5 

6 

7 

8 

> 9 

381 

2,080 

756 

421 

956 

871 

298 

809 

755 

381 

4,160 

2,268 

1,684 

4,780 

5,226 

2,086 

6,472 

9,354 

1,978,974 

8,639,938 

2,332,151 

2,510,833 

6,641,598 

3,879,569 

1,414,970 

3,765,459 

3,998,054 

24,980,980 

104,430,089 

22,935,259 

51,846,929 

158,813,021 

91,360,628 

34,239,869 

93,648,921 

126,176,568 

26,959,953 

113,070,026 

25,267,410 

54,357,762 

165,454,619 

95,240,197 

35,654,839 

97,414,380 

130,174,622 

Total 7,327 36,411 35,161,545 708,432,263 743,593,809 

Notes: 

(A) Each qualifying lavatory and galley on an aircraft is assumed to have only one sampling point. Therefore, the number of available sampling points is 

representative of the number of lavatories and galleys on an aircraft. 

(B), (D), (E) Derived from Appendix B. 

(C) Average number of sampling points used for > 9 sampling points size category. 

8 Section 1411 excludes from regulation any public water system that receives all its water from another regulated 

public water system, does not sell or treat the water, and is not a “carrier which conveys passengers in interstate 

commerce.” 

9

 A qualifying lavatory is defined as a private room with a flushing toilet and sink. Curtained-off toilet seats without 

lavatory sinks (as seen in some small, short-range aircraft) have not been included. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Aircraft in the following categories are not subject to the final ADWR because they do 

not meet the definition of a PWS, or are excluded from regulatory requirements under SDWA 

section 14118

: 

•	 Aircraft that do not serve 25 or more people for at least 60 days per year 

•	 Aircraft without a qualifying lavatory9 or galley 

•	 Aircraft solely used for cargo purposes 

•	 Aircraft that fly international routes serving only one U.S. city 

•	 Aircraft owned and operated by the U.S. military if used solely for military 

purposes, not conveying passengers in interstate commerce, and meet all of the 

other exclusion criteria under SDWA section 1411 

Exhibit 3.1 is stratified according to the number of available sampling points per aircraft. For the 

purpose of the analysis, each qualifying lavatory and galley on an aircraft is assumed to have 

only one sampling tap. The number of available sampling taps is used to characterize some of 

the information gathered in developing the baseline. It appears in several of the exhibits in this 

document for information display purposes only. The number of available taps is not used as a 

parameter in the cost model for the economic analysis for the ADWR. 

Exhibit 3.1 ADWR Aircraft and Population Baseline 

Page 3-5 
 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Population Served by Aircraft PWSs 

All onboard passengers and crew can potentially be exposed to lavatory and galley water 

on aircraft. Exposure to finished water onboard aircraft can occur via consumption of coffee, 

tea, or other beverages made with galley water;10 distributing drinking water that is from galley 

or lavatory water taps when bottled water is not available; passengers consuming water from 

lavatory taps to take medication, mix infant formula, brush teeth, wash face or hands, or through 

any subsequent hand-to-mouth contact. Columns D and E in Exhibit 3.1 present estimates of the 

population potentially exposed to drinking water onboard aircraft. These numbers are based on 

the number of flights each aircraft takes per year and the estimated number of passengers 

onboard each aircraft. These numbers have not been adjusted for passengers and crew who take 

more than one flight per year. 

3.3 Water Quality Baseline 

This section describes data collection efforts reported or processed as of December 31, 

2008. In 2003 and 2004, the ATA and EPA randomly sampled aircraft water systems to 

determine whether current regulatory efforts were adequately protecting public health. In 

addition, data processed under the AOCs from 2005 to 2008 for air carriers with an approved 

QAPP and CRMP have been compiled. Collectively, the 2003, 2004, and AOCs’ data represent 

the Agency’s understanding of existing aircraft water quality. 

3.3.1 2003 Data Collection Effort 

In October and November of 2003, ATA randomly sampled drinking water in 265 

passenger aircraft, 89 of which originated from an international airport on the last route flown 

prior to sampling. The aircraft were operated by eight U.S. air carriers, and the sampling was 

performed under a voluntary program coordinated with EPA. EPA had reviewed the final 

sample collection procedures for the study and all samples collected were, therefore, assumed to 

be valid samples. 

A summary of the ATA sampling data is presented in Exhibit 3.2. All samples met 

regulatory requirements for nitrate, nitrite, and turbidity. Of the 265 samples collected, 2.6 

percent tested positive for total coliform, but all tested negative for E. coli. A disinfectant 

residual was non-detectable in 41 percent of samples. Of the 176 aircraft originating from 

domestic locations, four (2.3 percent) samples tested positive for total coliform and 57 (32 

percent) had a non-detectable disinfectant residual.11 

10 It has not been determined that water heated in a galley coffee maker reaches temperatures high enough to kill all 

harmful microorganisms. 

11 Sampling downstream of in-line filters may affect sample results. The protocols for the 2003 data collection effort 

specified that effort should be made to avoid sampling galley taps with installed filtration devices. However, 

sufficient data is not available to determine if all samples were sampled upstream of any filtration device(s). 

Page 3-6 
 

Exhibit 3.2 Summary of 

 

. coli-positive 

32%

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

2003 ATA Sampling Data

All Samples 

N = 265 aircraft 

Samples from Aircraft Originating 

from Domestic Location 

N = 176 

# of Aircraft % Positive # of Aircraft % Positive 

A B C D 

Total Coliform-positive 7 2.6%

E 0 

 4 2.3% 

0% 0 0% 

Non-detectable Chlorine 

Residual 108 41% 57 

3.3.2 2004 Data Collection Effort 

In 2004, EPA performed two rounds of coliform and disinfectant residual sampling of 

aircraft. A total of 327 U.S. and foreign flag passenger aircraft were sampled. Exhibit 3.3 

presents a summary of the data from these two rounds of sampling. This section provides further 

discussion of these two data collection efforts. 

Exhibit 3.3 Summary of 2004 EPA Sampling Data

Round 1 

(August/September 2004) 

N = 158 aircraft 

Round 2 

(November/December 2004) 

N = 169 aircraft 

# of Aircraft % Positive # of Aircraft % Positive 

A B C D 

Total Coliform positive 20 12.7% 29 17.2% 

E. coli positive 2 1.3% 0 0.0% 

Non-detectable Chlorine 

Residual 39 24.7% 30 17.8% 

Notes: 

1) A chlorine residual sample was not taken at one aircraft with total coliform-positive sample results. 

The number of aircraft reported with non-detectable chlorine residuals does not include this aircraft. 

2) Samples collected in Rounds 1 and 2 were collected in the U.S. from U.S. aircraft traveling both 

domestically and internationally. 

First Round of 2004 Data Collection Effort 

EPA conducted a first-round of aircraft water quality sampling in August and September 

2004. EPA sampled water quality at one or more galley water taps, water fountains, and lavatory 

faucets on 158 U.S. and foreign flag passenger aircraft at seven U.S. airports. 

Page 3-7 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

All samples in the first round data collection effort met regulatory requirements for 

nitrate and nitrite. As shown in Exhibit 3.3, 12.7 percent of aircraft (20 aircraft) tested positive 

for total coliform, and 1.3 percent (two aircraft) tested positive for E. coli. Additionally, 24.7 

percent of the total number of aircraft sampled had non-detectable disinfectant residuals.12 

Second Round of 2004 Data Collection Effort 

EPA conducted a second round of aircraft water quality sampling during November and 

December 2004. EPA sampled at one or more galley water taps, water fountains, and lavatory 

faucets on 169 U.S. and foreign flag passenger aircraft at 12 U.S. airports. 

As shown in Exhibit 3.3, in the second round data collection effort, EPA found that 17.2 

percent of aircraft (29 aircraft) tested positive for total coliform. No E. coli was detected in the 

second round, and 17.8 percent of the total number of aircraft sampled had non-detectable 

disinfectant residuals. 

3.3.3	 Administrative Orders on Consent 

Under the AOCs, air carriers have adopted and implemented monitoring and routine 

water system disinfection and flushing procedures specified by EPA. Air carriers under AOCs 

must implement regular monitoring and disinfection practices for all aircraft in their fleet for two 

twelve month monitoring periods from the effective date of the AOC. A detailed discussion of 

the requirements of the AOCs is provided in Chapter 2, Section 2.3.2. A summary of the 

practices required by the AOCs is provided below: 

•	 Perform coliform and disinfectant residual monitoring of aircraft water systems. 

•	 Perform quarterly disinfection of aircraft water systems and water transfer 

equipment owned by the air carrier. 

•	 Perform repeat sampling, disinfection and flushing, and follow-up sampling as 

corrective action in the event that a routine sample is total coliform-positive. 

•	 Provide public notification or turn off the aircraft’s water in response to a total 

coliform-positive sample. 

•	 Analyze all total coliform-positive sample culture media for the presence of fecal 

coliforms or E. coli. 

•	 Conduct a study of possible sources of contamination that exist outside the 

aircraft, and supply information to EPA regarding various aspects of water 

boarding practices. 

12 Sampling downstream of in-line filters may affect sample results and sampling protocols would discourage 

sampling downstream of such filters. However, sufficient data is not available to determine if all samples were 

sampled upstream of or after the removal of any filtration device(s). 

Page 3-8 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Data Collected Under AOCs 

Each air carrier that is under an AOC is required to submit a CRMP and a QAPP. The 

CRMP describes the air carrier’s sampling and disinfection processes and protocols and is 

designed to ensure samples are collected properly and within a 12-month period. Air carriers 

that have a fleet of fewer than 20 aircraft were directed to sample all aircraft quarterly; air 

carriers with a fleet of 20 or more aircraft were directed to sample each aircraft once per year. 

The QAPP describes the air carrier’s quality assurance and quality control (QA/QC) processes 

and describes the methods used to collect and assess data. 

Under the AOCs, air carriers collected total coliform and disinfectant residual samples 

from at least one galley and lavatory on each aircraft in the first year. Air carriers continued 

collecting monitoring data during subsequent years based on the monitoring and reporting 

frequency established in their AOCs. As of December 31, 2008, EPA had processed data from 

20,156 total coliform samples and 17,267 disinfectant residual samples from 25 air carriers 

representing 78 percent of the estimated aircraft fleet under AOCs. These data may be indicative 

of the effectiveness of rule requirements as of the date of this document, but data for air carriers 

with an approved QAPP and CRMP are only available from two air carriers in 2005, five air 

carriers in 2006, eight air carriers in 2007, and 12 air carriers in 2008. Therefore, insufficient 

data is currently available to support statistical evaluation of the data. However, the data is used 

to provide an observational indication of trends. 

Appendix B summarizes the available sampling results from 2005 to 2008 for all air 

carriers, and presents the routine and repeat data collected under EPA-approved QAPPs and 

CRMPs. Of the QAPP and CRMP-approved data: during 2005, 137 (3.6 percent) of 3,819 

samples tested positive for total coliform, and only one of the 137 samples also tested positive 

for E. coli; in 2006, 143 (2.6 percent) of 5,570 samples tested positive for total coliform, and 

seven of the 143 samples also tested positive for E. coli; in 2007, 266 (4.2 percent) of 6,351 

samples tested positive for total coliform, and seven of the 266 samples also tested positive for E. 

coli; and in 2008, 255 (8.5 percent) of 2,984 samples tested positive for total coliform, and seven 

of the 255 samples also tested positive for E. coli. See Section 3.3.5 and Appendix B for 

additional details. 

Historical Data Collected 

In addition to ATA’s and EPA’s sampling efforts, a number of air carriers collected 

monitoring data for various contaminants prior to their AOC. Several air carriers submitted data 

collected within five years of their AOC to EPA. However, EPA did not analyze these data for 

the ADWR since most air carriers did not specify their procedures, analytical methods, or 

provide a QAPP. 

Page 3-9 
 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

3.3.4 Disinfectant and Treatment Characterization for the Baseline 

Of the 17,267 disinfectant residual sample events reported under the AOCs, 16,109 

disinfectant residual sample results were collected under EPA-approved QAPPs and CRMPs and 

comprise the disinfectant residual baseline for the ADWR. Under the AOCs, disinfectant 

residual results were reported as either “detect” with the residual value recorded, or “non-detect.” 

Disinfectant residual data was not provided for 2,615 coliform sample events. Disinfectant 

residual baseline data are presented for routine and repeat coliform sample collection events 

because repeat samples have no higher or lower probability of having a detectable residual than 

routine samples. Exhibit 3.4 presents processed data for disinfectant residual samples collected 

under EPA-approved QAPPs and CRMPs during routine and repeat total coliform sampling 

events for years 2005-2008. 

Exhibit 3.4 AOCs Occurrence Baseline Data – Disinfectant Residual Samples 

(Years 2005-2008)

Percent 

Disinfectant 

Residual Nondetect 

Total # of 

Disinfectant 

Residual Nondetect 

Total # of 

Disinfectant 

Residual 

Detect 

Total # of 

Disinfectant 

Residual 

Samples 

Disinfectant Residual Data by Calendar Quarter 

Unknown Calendar Qtr 0% 0 0 0 

Calendar Qtr 1 22.8% 864 2,933 3,797 

Calendar Qtr 2 9.3% 632 6,128 6,760 

Calendar Qtr 3 30.2% 813 1,879 2,692 

Calendar Qtr 4 21.6% 618 2,242 2,860 

Total 18.2% 2,927 13,182 16,109 

Disinfectant Residual Data by Sample Location 

Galley 17.3% 1,336 6,386 7,722 

Lavatory 18.9% 1,518 6,530 8,048 

Composite* 22.4% 73 253 326 

Unknown Sample Site 0.0% 0 13 13 

Total 18.2% 2,927 13,182 16,109 

For air carriers with approved QAPPs and CRMPs, 18.2 percent of the 16,109 

disinfectant residual results processed from 2005 to 2008 reported a non-detectable disinfectant 

residual. Non-detectable levels were similar in galleys (17.3%) and lavatories (18.9%), while 

22.5 percent of the composite samples were non-detects. A sample location was not identified 

for 13 samples with a detectable residual. In addition, the occurrence of non-detectable 

disinfectant residuals increased in months with warmer weather. Quarter 3 (i.e., July to 

September) had the highest percentage of samples with a non-detectable disinfectant residual 

(30.2%). 

Additional disinfectant residual information is found in Appendix B. Data in Appendix B 

indicates that a non-detectable disinfectant residual appears to not be associated with an increase 

in total coliform-positive samples. Of the 801 routine and repeat samples that were total 

Page 3-10 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

coliform-positive, 24 did not include any data on a disinfectant residual. Of the remaining 777 

total coliform-positive routine and repeat samples, 584 samples (75%) had a detectable 

disinfectant residual and 193 samples (25%) did not have a detectable disinfectant residual. 

Twenty-one (3.6%) of the 584 total coliform-positive routine and repeat samples with a 

detectable residual (the lowest measuring 0.05 mg/L) also tested positive for E. coli. Only one 

(0.5%) of the 193 total coliform-positive samples that did not have a detectable residual tested 

positive for E. coli. 

Regarding existing onboard water treatment units, seventy three samples had nondetectable disinfectant residual and were reported to have carbon filters installed on the water 

lines to the sample tap; two of those samples were total coliform-positive. For comparison, 364 

samples with detectable disinfectant residual were reported to use carbon filters; three of those 

samples were total coliform-positive. Aside from charcoal/activated carbon and particle removal 

filters in some galleys and lavatories, the majority of aircraft do not provide additional treatment 

for boarded water. 

3.3.5 Contaminant Occurrence for the Baseline 

AOCs’ sampling data under EPA-approved QAPPs and CRMPs from 2005 to 2008 

analyzed by EPA as of December 31, 2008 show that 801 (4.3 percent) of 18,724 routine and 

repeat samples tested positive for total coliform, and 22 (2.7 percent) of the 801 total coliform 

positive samples tested positive for E. coli. (An additional E. coli positive sample tested 

negative for total coliform and was omitted from the analysis.) Of the 22 samples that tested 

positive for both E. coli, 18 were routine samples and four were repeat samples. Also, nine of 

the 22 samples that were E. coli-positive were collected from galleys and 13 were collected from 

lavatories. One of the 22 samples was collected in 2005 and seven were collected in 2006, 2007, 

and 2008, respectively. The 22 E. coli-positive samples were collected from 17 different 

aircraft; three of the repeat samples were collected from the same aircraft. A disinfectant 

residual was detected in 21 of the E. coli-positive samples; one routine sample did not detect a 

disinfectant residual. Finally, last departure cities were provided for 21 of the 22 samples. 

Information on whether water was boarded at the last departure city was not reported. 

The occurrence of total coliform-positive and E. coli-positive samples have varied from 

year to year. The percent of samples that tested positive for total coliform from 2005 to 2008 

were 3.6 percent, 2.6 percent, 4.2 percent, and 8.5 percent, respectively. Of these samples, the 

percent that also tested positive for E. coli from 2005 to 2008 were 0.7 percent, 4.9 percent, 2.6 

percent, and 2.7 percent, respectively. However, data in 2005 were only available for 745 

aircraft from two air carriers (4.4 percent of all air carriers under AOCs), data in 2006 were 

available for 1,246 aircraft from five air carriers (11.1 percent of all air carriers under AOCs), 

data in 2007 were available for 1,255 aircraft from 8 air carriers (17.8 percent of all air carriers 

under AOCs), and data in 2008 were available for 1,026 aircraft from 12 air carriers (26.6 

percent of all air carriers under AOCs). All of the air carriers in these analyses were considered 

large carriers under the criteria described in the screening analysis presented in Appendix D. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 3.5 presents AOC data processed under EPA-approved QAPPs and CRMPs as of 

December 31, 2008, for routine samples collected in years 2005-2008. These data comprise the 

coliform occurrence baseline for the ADWR. As presented above, not all 25 air carriers 

provided data collected under an approved QAPP and CRMP for all four years. Repeat total 

coliform samples by nature have a higher probability of being positive since repeat samples are 

taken after a routine sample is total coliform-positive. Consequently, the occurrence baseline for 

total coliform and E. coli/fecal coliform occurrence was based on routine samples only. Exhibit 

3.5 presents data processed for routine total coliform samples collected under EPA- approved 

QAPPs and CRMPs for years 2005-2008. 

Exhibit 3.5 AOCs Occurrence Baseline Data – Routine Total Coliform Samples 

(Years 2005-2008)

 Percent TC+ 

Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # of 

TC+ 

samples 

that are 

EC+ or FC+ 

Total # of 

TC 

Samples 

Total Coliform Data by Calendar Quarter 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 

Calendar Qtr 1 3.2% 4.0% 100 4 3,145 

Calendar Qtr 2 3.5% 3.5% 198 7 5,641 

Calendar Qtr 3 4.1% 0.0% 79 0 1,930 

Calendar Qtr 4 4.1% 8.1% 86 7 2,078 

Total 3.6% 3.9% 463 18 12,794 

Total Coliform Data by Sample Location 

Galley 0.8% 12.8% 47 6 5,695 

Lavatory 5.9% 2.9% 413 12 7,027 

Composite* 14.3% 0% 1 0 7 

Unknown Sample Site 3.1% 0% 2 0 65 

Total 3.6% 3.9% 463 18 12,794 

*Composite sample of Galley and Lavatory sources 

Note: “TC+” means total coliform-positive; “EC+ or FC+” means E. coli-positive or fecal coliform-positive 

Of the 20,156 total coliform samples processed, 93 percent or 18,724 samples (12,794 

routine and 5,930 repeat samples) were from air carriers with an EPA-approved QAPP and 

CRMP. Of the 12,794 routine samples, 3.6 percent (463 samples) were positive for total 

coliform and 3.9 percent (18 samples) of the total coliform-positive samples were E. coli/fecal 

coliform-positive. Of the 463 total coliform-positive routine samples, 413 were collected in the 

lavatory, 47 were collected in the galley, and one was a composite sample of galley and lavatory 

sources; the location of the remaining two positive results are unknown. However, although the 

lavatory samples had a higher total coliform-positive occurrence rate (5.9%, or 413 of 7,027 

lavatory samples) than the galley samples (0.8%, or 47 of 5,695 galley samples), the galley 

samples have a higher E. coli/fecal coliform occurrence of 12.8 percent (6 of 47 total coliformpositive samples), compared to 2.9 percent (12 of 413 total coliform-positive samples) in the 

lavatories. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

3.4 Uncertainties in the ADWR Baseline 

Uncertainties in this baseline analysis are due to the limitation of available information. 

These uncertainties contribute to uncertainties in the cost estimates presented in Chapter 5. The 

most significant uncertainties in the ADWR baseline are related to the number of aircraft per air 

carrier that are subject to the ADWR, each aircraft’s passenger capacity, and the flight 

frequencies of charter aircraft. Where aircraft information was not provided by the air carrier on 

their Web site or annual report, or by the aircraft’s manufacturer, aircraft capacity was based on 

other similar aircraft models. This assumption may under- or over-estimate the number of 

passengers per aircraft, as it does not factor in aircraft that are ordered to fit air carriers’ specific 

requirements. Similarly, when the number of lavatories and galleys was not specified, the 

number of lavatories and galleys used was based on similar capacity aircraft. A carrying 

capacity of 25 was assumed when aircraft type was not specified and the capacity could not be 

obtained from a similar aircraft model. When two different models of an aircraft were used by 

an air carrier and the passenger carrying capacity was not differentiated between the two, an 

average carrying capacity was used. 

Aircraft that clearly did not carry at least 25 passengers, 60 days per year were not 

included in the baseline; however, there were some charter aircraft included in the baseline. 

Those charter aircraft that exhibited a strong possibility of fitting the definition of a TNCWS 

were included in the baseline. A weighted average flight frequency was calculated for the 

charter flights included in the baseline based on known flight frequencies of other chartered 

aircraft. Lastly, when only a weekly or yearly flight frequency was provided, 365 days per year 

and 52 weeks per year were assumed. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

4. Benefits Analysis 

4.1 Introduction 

Three of the alternatives considered during the ADWR development process were 

designed to provide more efficient methods for aircraft to comply with the NPDWRs than are 

allowed by the baseline regulations, without compromising public health. The baseline 

regulations were considered as the fourth alternative. The regulatory scenarios (i.e., the baseline 

and alternatives) that were considered for aircraft to achieve compliance with NPDWRs were 

designed to minimize the risk of potential adverse health outcomes from drinking water boarded 

on aircraft. 

This chapter examines the risk (and benefit) tradeoffs between compliance with existing 

NPDWRs and the other alternatives considered during the regulatory development process. This 

comparative analysis was presented in the Economic and Supporting Analysis document 

developed for the proposed rule; however, EPA has updated this discussion and included the 

final rule elements for the reader’s convenience. Evaluations include a qualitative analysis that 

compares the risks for each regulatory alternative as compared to baseline conditions. The 

qualitative analysis uses EPA’s best professional judgment, not quantitative data, to establish a 

relative risk rating for each regulatory component. Potential additional benefits analyses as well 

as non-quantified benefits of compliance with the regulatory alternatives are also discussed. 

4.2 Relative Risks – Qualitative Analysis 

From a public health perspective, full compliance with current regulations by typical 

stationary TNCWS will result in minimal risk to public health. The existing NPDWRs have all 

been vetted through separate evaluation processes that determined that the estimated public 

health risks following implementation meet or exceed EPA criteria. As part of the evaluation 

process for most NPDWRs, a quantified risk assessment is performed and quantified benefits 

calculated using traditional risk assessment analyses. 

Because aircraft water systems are mobile systems that may board water from multiple 

sources over the course of a single day, the opportunity exists for contamination of the water to 

occur during the water transfer and boarding process and for water quality in the aircraft water 

system to deteriorate due to water age (see Chapter 1 for a discussion of the public health risks 

addressed by the ADWR). As a result, some regulatory requirements appropriate for typical 

systems (such as monthly monitoring for coliforms and repeat coliform sampling) are not as 

useful for aircraft systems, and some voluntary activities (such as routine disinfection and 

flushing of a water system) warrant a regulatory requirement for aircraft. 

To perform quantified risk and benefits analyses for a regulatory alternative, a large 

amount of data are needed for parameters such as contaminant occurrence (both frequency and 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

concentration), health effects, and water consumption. Because of their unique characteristics, 

the requisite data are not available for aircraft PWSs and the populations they serve: thus EPA 

determined that a quantitative risk assessment (and associated benefits analysis) was not feasible. 

Furthermore, since the goal of the ADWR is to tailor existing NPDWRs to the unique 

characteristics of aircraft water systems, EPA determined that additional quantitative risk 

assessments (and thus benefits analyses) were not necessary. Therefore, the discussion and 

analysis in this chapter focus on the relative risks between the regulatory alternatives considered 

for the ADWR and the baseline conditions. 

4.2.1 Rule Implementation Activities 

Rule implementation activities are expected to be similar under all regulatory 

alternatives. These activities are primarily administrative in nature and include items such as 

reading and understanding the rule, training, and development of reporting and recordkeeping 

protocols. Because of the similarities in expected implementation activities under all regulatory 

alternatives, they are not expected to have an observably different effect on overall risk relative 

to current regulations. 

4.2.2 Operator Certification Requirements 

Because of potential impacts on airworthiness, all aircraft maintenance is required to be 

performed by highly trained individuals under FAA oversight. These requirements are the same 

for all regulatory alternatives considered, even in the absence of specific operator certification 

requirements. Thus, there is no expected difference in risk between the alternatives for this 

regulatory component. 

4.2.3 Routine Monitoring – Coliform Bacteria 

Current regulations require monthly monitoring for coliform bacteria in accordance with 

the TCR. Since monitoring PWSs for every possible pathogenic organism is not feasible, 

coliform organisms are used as indicators of possible source water and distribution system 

contamination. All else being equal, any reduction in the frequency of routine monitoring 

performed represents a potential increase in risk for water consumers. Relative to the monthly 

coliform sampling in the current regulations, Alternative 2 (requirements similar to the AOCs) 

proposes a decrease in routine monitoring frequency to annually, while Alternative 3 

(requirements similar to WSG 29) proposes quarterly sampling or no sampling if the air carrier is 

operating under an approved O&M plan. Thus, selection of Alternatives 2 or 3 represents a 

potential increase in health risk to consumers of water onboard aircraft. For the final rule, 

aircraft have four possible monitoring frequencies depending on the manufacturers’ 

recommended schedule for disinfection and flushing. One option requires monthly monitoring if 

disinfection and flushing frequency is once per year or less. The other three options require 

quarterly, twice annual, or annual monitoring combined with more frequent disinfection and 

flushing frequencies. Under the final rule, those aircraft that monitor monthly will not see any 

change in risk relative to current regulations. However, all other aircraft under this alternative 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

will see a potential increase in health risk due to reduced monitoring, leading to an overall 

potential increase in health risk for the routine monitoring component of the final rule. 

When considering the relative risks posed by differences in sampling frequency for 

aircraft PWSs, it is important to also consider the efficacy of sampling for these types of systems. 

Because of the numerous fill and drain operations across a wide geographic area that are 

common for aircraft water systems, the effectiveness of any sampling in identifying and 

correcting problems is limited. In many cases, due to the lag times from sampling to getting 

results, a positive coliform sample may be representative of water that has already been replaced 

(possibly several times) by clean water from a different watering point or the cause of the 

positive sample (e.g., biofilm sloughing) has already been cleared from the system. In cases 

such as these, identification of the positive sample may result in little to no impact on public 

health. On the other hand, sampling more frequently than monthly may be beneficial for 

identifying trends for a particular aircraft, airport, or water source that could lead to health risk 

reductions for that given entity. However, aircraft rely on the required use of watering points 

that meet FDA regulations to board potable (finished) water that meets all of the NPDWRs. 

Therefore, monitoring and treatment applied by the PWS supplying the watering point should 

address all but aircraft water boarding and system-related health risks. 

4.2.4 Repeat Monitoring – Coliform Bacteria 

When a PWS receives notification of a total coliform-positive routine sample, it is 

required to take repeat coliform samples. Alternatives 1 and 2 require four repeat samples to be 

collected, Alternative 3 does not specify any repeat sampling, and the final rule gives aircraft the 

option of taking three repeat samples or disinfecting and flushing the system as corrective action. 

Unlike routine sampling where more frequent sampling can point to statistical trends, 

repeat samples are more specific to identifying the extent of a particular contamination event. In 

the absence of repeat monitoring, in the final rule the aircraft would proceed directly to a 

corrective action. Within this context, repeat samples help to better define the problem and can 

lead to more cost-efficient situational response (e.g., avoiding a potentially expensive corrective 

action if repeat samples do not identify an ongoing problem). Because aircraft will either 

determine that there is no ongoing problem (all repeat samples are negative) or take corrective 

action, no change in risk relative to current regulations is expected for any of the regulatory 

alternatives under consideration. 

4.2.5 Additional Routine Monitoring – Coliform Bacteria 

Because of the small size of the population served by aircraft PWSs, they are included 

among other TNCWSs that are only required to take one monthly sample to comply with current 

TCR requirements. For any system that has a total coliform-positive sample under the TCR, that 

system must collect a minimum of five routine samples in the following month. The TCR allows 

for the primacy agency to waive the requirement to collect five routine samples the next month 

the system provides water to the public if the primacy agency has determined why the sample 

was total coliform-positive and establishes that the system has corrected the problem or will 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

correct the problem before the end of the next month the system serves water to the public. The 

written documentation must describe the specific cause of the total coliform-positive sample and 

what action the system had taken and/or will take to correct the problem. 

For aircraft systems, the additional routine monitoring requirement equates to collection 

of four additional samples in any month following a positive coliform sample under current 

regulations (Alternative 1). Alternatives 2, 3, and the ADWR do not specify any requirements 

for this additional routine monitoring. Alternatives 2 and 3 require disinfection and flushing of 

the water system immediately following any total coliform-positive sample, thus presumably 

meeting the criteria that the system has corrected the problem before the end of the next month 

water is served to the public. The final rule gives aircraft the option of disinfecting and flushing 

the system with follow-up monitoring, or performing repeat monitoring if one or more routine 

sample is total coliform-positive. If any repeat sample is total coliform-positive, the aircraft 

must disinfect and flush the system. If all repeat samples are coliform-negative, no corrective 

action is required. For Alternatives 2, 3, and the ADWR, EPA is assuming the cause of the 

positive coliform sample is either unknowingly boarding contaminated water, contamination 

during the water boarding process, or water quality deterioration due to water age. In each case, 

the practice of disinfection and flushing as corrective action, combined with frequently boarding 

water from different locations minimizes the value of additional routine samples to indicate the 

existence of an ongoing problem. This assumption may not capture all contamination problems 

coming from the aircraft tap, tank, or distribution system. However, because the final rule 

requires aircraft to either disinfect and flush, or collect repeat samples in response to a total 

coliform-positive result, any potential increase in public health risk is anticipated to be small. 

Thus, EPA assumes the lack of a requirement for additional routine monitoring under 

Alternatives 2 and 3 results in minimal change in public health risk, and no more than a potential 

slight increase in public health risk for the final rule (depending on whether the system opts to 

disinfect and flush the system or collect repeat samples) relative to the current regulations. The 

reasoning for and associated limitations on considering the magnitude of this increased risk are 

similar to those discussed under routine monitoring in section 4.2.3 above. 

4.2.6 Post Disinfection Monitoring – Coliform Bacteria 

Under Alternative 1, the existing regulations, aircraft water systems do not have any 

requirements for post disinfection coliform monitoring. Alternative 3 also does not require post 

disinfection monitoring, thus there is no change in risk relative to Alternative 1. Alternatives 2 

and the final rule do require post disinfection monitoring to verify the effectiveness of 

disinfection procedures triggered by a total coliform-positive sample result. To the extent that 

this verification prevents inadequate disinfection (and subsequent return of a contaminated water 

system to service) risks will be reduced under these two alternatives. The reduction of risk 

realized by post disinfection monitoring is expected to be valuable where the cause of the 

contaminated sample was not mitigated by the disinfection process, such as when certain taps 

required replacement, as reported by some air carriers at stakeholder meetings held during the 

development of the proposed rule. The reduction of risk realized by post disinfection coliform 

monitoring is expected to be minimal for aircraft overall. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

4.2.7 Routine Monitoring – Disinfectant Residual 

Under Alternative 1, aircraft water systems are required to take monthly disinfectant 

residual samples at the same time and place as routine and repeat coliform samples. Alternative 

2 proposes reducing this sampling to annually to correspond with the annual routine coliform 

monitoring requirements. Alternative 3 does not require disinfectant residual monitoring if the 

system opts for the operations and maintenance program or if it performs coliform monitoring. 

The final rule does not include a requirement for routine residual disinfectant monitoring. 

As with coliform monitoring, any reduction in sampling frequency for a disinfectant 

residual may result in an increased public health risk. Although some pathogens are resistant to 

disinfection (e.g., Cryptosporidium), maintenance of a disinfectant residual still provides 

important health protection within the water system. By monitoring more frequently for a 

disinfectant residual, a typical water system operator can better ensure continuity of this 

protection in the system. It is important to note, however, that while monitoring for a 

disinfectant residual is not required under the ADWR, all aircraft are required to board finished 

water that meets all NPDWRs, including disinfectant residual where applicable. Also, some 

aircraft may board water from PWSs that use ground water that may not be required to have a 

disinfectant residual. Thus, although there may be an increase in risk under the ADWR in 

relation to Alternative 1 since disinfectant residual sampling is not required, the differential in 

this risk is expected to be small. 

4.2.8 Development and Implementation of an O&M Plan 

All alternatives considered require basic O&M in compliance with FAA regulations to 

ensure airworthiness of the aircraft. FAA requires O&M practices to follow manufacturers’ 

guidelines. Any FAA requirements regarding O&M are not changed under any of the 

alternatives and will not impact relative risks. Additional O&M requirements imposed under 

EPA jurisdiction are related to the proper maintenance and upkeep of equipment and are 

consistent for Alternatives 1 and 2. For Alternative 3, aircraft have the option of following a 

more prescriptive O&M plan in lieu of monitoring. The final rule requires development of 

specific O&M plans. To the degree that more prescriptive O&M plans will better focus 

maintenance activities on issues specific to aircraft water systems and help prevent more 

problems from arising, Alternatives 3 and the final rule could result in a decrease in risk relative 

to the existing regulations captured in Alternative 1. It is expected, however, that this decrease 

would be minimal due to the O&M requirements already in place under FAA regulations. 

4.2.9 Routine Disinfection and Flushing 

The existing regulations composing Alternative 1 address routine disinfection and 

flushing of distribution systems as one of several best available technologies (BATs) identified 

in the TCR to protect the system from coliform bacteria contamination. As BATs, these are 

optional procedures a PWS may or may not implement. Because of the unique nature and 

operation of aircraft water systems, it is estimated that next to boarding only finished water that 

meets all of the NPDWRs, periodic disinfection and flushing of the water system has the biggest 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

effect on maintaining water quality and ensuring public health is protected. Disinfection and 

flushing overcomes, to a large extent, the cumulative risks from boarding water from multiple 

locations by effectively resetting the system on a regular basis. To the extent that the regulatory 

alternatives increase the frequency of disinfection and flushing events, there is expected to be a 

decrease in public health risk. Because information reported by air carriers suggests pre-AOCs’ 

disinfection and flushing frequencies varied greatly from monthly to every few years, a 

requirement specifying the frequency for disinfection and flushing, and the preventive nature of 

the activity, is expected to have the biggest effect in terms of the magnitude of change in risk. 

4.2.10 Disinfection and Flushing as Corrective Action 

Alternative 1 does not require specific corrective actions (i.e., disinfection and flushing) 

following total coliform-positive samples. However, typical water system operations practices 

suggest that aircraft would take some kind of action in response to more than one total coliformpositive routine sample, or if any sample is E. coli-positive under Alternative 1, even if the 

actions are not specified in the regulations. For Alternatives 2, 3, and the ADWR, aircraft that 

experience confirmed positive total coliform samples (one sample for Alternatives 2 and 3) or 

one E. coli sample must13 perform corrective action which includes, at a minimum, disinfection 

and flushing of the water system. Because disinfection and flushing corrective actions are 

mandatory and/or occur at frequencies greater than those typical under Alternative 1, they result 

in an overall decrease in risk for this regulatory component relative to Alternative 1. 

4.2.11 Optional Supplemental Treatment 

All three alternatives and the final rule allow for the use of appropriate supplemental 

treatment onboard aircraft. In cases where such treatment is added to an aircraft, an additional 

barrier against contamination will be provided and risks will decrease. However, because this is 

an existing option that also applies to baseline conditions, there is no change in risk for any of 

the alternatives relative to the baseline. 

4.2.12 Sanitary Surveys/Self-Inspections 

Alternative 1 requires sanitary surveys at least every 5 years. The final rule requires air 

carriers to conduct self-inspections every 5 years and certify that they were completed. These 

inspections will function in a manner similar to sanitary surveys and are expected to yield 

comparable risk reduction. EPA may conduct compliance audits to ensure proper 

implementation of rule requirements. Alternatives 2 and 3, however, do not have specific 

requirements for sanitary surveys and, to the extent that problems that would normally be 

uncovered during a sanitary survey are not found, may result in an increased risk. 

13 Corrective action is not mandated under Alternative 3. However, for analysis purposes it is assumed that aircraft 

would correct deficiencies in the same manner as under Alternatives 2 and the final ADWR. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

4.2.13 Public Notification 

Public notification requirements are similar for all regulatory alternatives considered. 

Any differences between the alternatives are minimal and not expected to have a measurable 

impact on risk relative to the baseline alternative. 

4.2.14 Overall Relative Risk 

The discussions above describe relative risks in terms of individual components of the 

regulatory alternatives and the ADWR. The overall change in risks from each alternative 

relative to the Alternative 1 baseline are a result of the complex interaction of all regulatory 

components. Based on the discussions presented above, EPA has used best professional 

judgment to qualitatively estimate the relative risk of each regulatory alternative considered. 

This assessment was made through collaboration with a wide range of drinking water and aircraft 

experts, including public health scientists, engineers, administrators, and regulatory experts. The 

consensus opinions resulting from the assessments are presented below for each alternative. 

Alternative 2: Requirements Similar to the AOCs 

Alternative 2 mirrors the requirements set forth in the AOCs. In consideration of the 

regulatory components, the expert consensus is that the dominant factor affecting risk is the 

periodic disinfection and flushing of aircraft water systems. This type of periodic maintenance is 

important in an operating environment that is as variable as that of aircraft water systems. 

Though there is currently no data on how large the marginal effect of increasing disinfection and 

flushing frequency is, any increase in periodicity for this activity is expected to yield larger 

health risk reductions compared to other regulatory components such as periodic monitoring. 

Based on all the considerations discussed above, the expert consensus is that the overall 

health risk remaining after Alternative 2 is most likely less than the baseline. 

Alternative 3: Requirements Similar to Water Supply Guidance 29 

The components of Alternative 3 are generally not as comprehensive as Alternative 2, yet 

are similar for those components that are included in both. In particular, the disinfection and 

flushing requirements are the same for a subset of aircraft in Alternative 3 (i.e., those that choose 

to comply with an O&M plan in lieu of monitoring). Based on the similarities between 

Alternatives 2 and 3, the same process and rationale were used to evaluate the two alternatives. 

Thus, the expert consensus is similar: the overall health risk posed by Alternative 3 is most likely 

less than the Alternative 1 baseline, though the magnitude of the difference is expected to be 

smaller compared to Alternative 2 due to the flexibility in choosing between monitoring and an 

O&M plan. 

ADWR 

The regulatory components of the final rule allow greater flexibility than Alternatives 2 

and 3 with regard to disinfection and flushing. Thus, some aircraft will not perform disinfection 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

and flushing as often as would be required under those alternatives. However, this is 

compensated for by requiring more routine coliform monitoring in those situations. As a result, 

the expert consensus is that the overall health risk posed by the final rule is most likely less than 

the Alternative 1 baseline, and about the same as Alternatives 2 and 3. 

4.3 Assessment of Potential Quantitative Relative Risk Analyses 

In addition to the qualitative relative risk analysis presented above, EPA has considered 

analyses for incorporating quantitative data into a relative risk analysis. However, EPA is 

limited by the purpose, quality, and quantity of data available in developing meaningful analyses. 

Any comparison of risk between the alternatives considered for the final rule requires robust data 

that would support: 1) direct comparisons of the overall baseline conditions with the overall 

conditions under each of the alternatives, or 2) comparisons of specific regulatory components 

(i.e., disinfection and flushing frequencies) that could be used to compare the baseline and all 

alternatives. See Chapter 3 for a more detailed description of available data. 

The most recent data available that may represent baseline conditions are those from 

EPA’s 2004 data collection effort. These data suggest a cumulative total coliform-positive rate 

of 15 percent for the aircraft sampled. Additional data that may inform the baseline are from the 

2003 ATA data collection effort. These data suggest a 2.3 percent rate of total coliform-positive 

samples for aircraft originating from domestic locations. Sufficient accompanying information is 

not available for either of these studies to form the basis of more complex modeling and analysis 

that could inform a quantitative relative risk estimate. In particular, information on items such as 

maintenance histories, especially disinfection and flushing histories, of the sampled aircraft are 

not available to inform an analysis. Because disinfection and flushing is a key component to 

maintaining water quality, such information is vital for assessing differences in monitoring 

results seen between these two data collection efforts as well as differences within each data set. 

In addition, each of these data collection efforts represents a small fraction of the total aircraft 

inventory, calling into question the representativeness of the data. 

The data collected under the AOCs represent all aircraft in each air carrier fleet that 

submitted data and are therefore more comprehensive than those collected under the efforts 

mentioned above. However, these data are also subject to limitations that currently prevent their 

use for a robust quantitative analysis. First, the AOCs’ data collection was not developed with 

the intent to inform risk analyses. The AOCs’ data were intended to be used for assessing 

compliance with the AOCs, and as such, the data elements collected may not provide the 

parameters necessary for relative risk analyses. However, preliminary analysis of the data 

indicates that they are more comprehensive and potentially useful for such purposes than the 

2003 and 2004 data. Related to the intent of the AOCs’ data collection, and more significant to 

the ability to use the data in a meaningful analysis, is the ongoing nature of the data collection. 

As of December 31, 2008, data have been received and analyzed for only 16 of the 45 air carriers 

currently under AOCs. In addition, as described in Chapter 3, only some of those data were 

collected under EPA-approved QAPPs and CRMPs. This small fraction of data processed to date 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

under the AOCs, while more representative than the smaller data sets collected under the 2003 

and 2004 efforts, is still not sufficient to ensure a representative analysis. 

In the absence of rigorous statistical analyses, only general observations of the data can 

be made, and only with adequate qualifiers. Because of the differences in conditions under 

which AOCs’ data were collected compared to the 2003 and 2004 data (i.e., quarterly 

disinfection and flushing is being conducted under the AOCs), comparisons of these data sets 

may inform the effectiveness of disinfection and flushing as a risk reduction strategy. 

Comparison of the total coliform-positive rate of 15 percent from the 2004 EPA data with the 

AOCs’ rate of 3.6 percent for QAPP and CRMP-approved data may indicate some effectiveness 

of the actions, specifically disinfection and flushing, required under the AOCs. However, 

consideration of the 2003 ATA data tends to argue against this assumption since the differences 

between these data results and those for the AOCs appear to be insignificant. There are many 

other factors that could explain differences in the results that need to be considered. In addition 

to the obvious uncertainties associated with the small sample sizes for each of the data sets, 

influences of items such as water handling procedures, sampling procedures, water retention 

times, and overall attentiveness to the water quality issues need to be considered. 

Considering all of the issues discussed above, EPA has determined that it is not feasible 

to perform a quantitative relative risk analysis at this time. 

4.4 Non-quantified Benefits 

In addition to the benefits associated with individual components of the ADWR, there 

may be other benefits of the final rule that cannot be quantified with the information available. 

These potential benefits are described below. 

Because EPA has no information on illnesses and subsequent deaths that may have been 

caused by drinking water onboard aircraft, it cannot determine the number of illnesses and deaths 

that would be avoided. However, increased routine disinfection and flushing required under the 

final option is expected to remove pathogens in the aircraft distribution system contributing to 

endemic disease. Disinfection and flushing associated with corrective action is also expected to 

inactivate or remove pathogens that may have entered the distribution system, resulting in 

decreased illness and greater avoidance of death. By reducing cases of illness contracted through 

exposure to aircraft water, the final option is also expected to reduce the occurrence of illness 

passed through secondary spread. EPA expects that the addition of multiple barriers to 

pathogens through monitoring and disinfection and flushing may reduce the likelihood of 

waterborne disease outbreaks associated with aircraft PWSs. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

5. Cost Analysis
 

5.1 Introduction 

This chapter presents an estimate of the national implementation and incremental costs of 

the final ADWR as well as a brief qualitative discussion comparing costs to the potential 

expected benefits of the final rule. The cost estimate, prepared by EPA, is a summation of air 

carrier costs for complying with the ADWR components and EPA costs for implementing the 

rule. Although existing air carrier industry practice may involve some activities required under 

the ADWR, all costs incurred to comply with the final ADWR are considered additional or 

incremental costs. Rule components include developing and implementing monitoring and O&M 

plans; performing routine monitoring; disinfecting and flushing the aircraft water system; selfinspections by air carriers with self-certification of their completion; compliance audits by EPA; 

and reporting and recordkeeping requirements. 

Public notification requirements are included in the ADWR; however, compliance with 

those requirements is not included in these cost estimates as it is addressed under the Information 

Collection Request for the Public Notification Rule. Because an update to the public notification 

information collection request (ICR) was published before the ADWR was final, an estimate of 

the burden associated with those costs has been included in the ICR for the final ADWR. 

The detailed descriptions and analyses presented in this chapter focus on the final rule. 

Overall implementation costs for the final rule are compared to summary costs of the other 

alternatives considered during the regulatory development process. A comparison of the final 

ADWR and the proposed rule (updated to 2008$) is also provided. Detailed costs for the 

alternatives to the ADWR are presented in Appendix C. 

Air carrier costs are estimated for different aircraft categories. The aircraft categories are 

based on the number of available sampling points on the aircraft, but the number of sampling 

points is used for information display purposes only and does not affect the cost estimates. For 

purposes of this analysis it is assumed that, on average, all air carriers spend equal time 

performing rule activities regardless of aircraft type or category. 

EPA implementation costs include staff training on ADWR requirements, providing 

technical assistance to air carriers, conducting compliance audits, reviewing monitoring reports, 

and recordkeeping. EPA estimated unit costs for these various components using a cost model, 

equipment price lists and quotes, wage rates from government sources (Bureau of Labor 

Statistics (BLS)), stakeholder input, and other relevant assumptions used in economic analyses 

performed for existing drinking water rules (e.g., the recently finalized Ground Water Rule). 

The national costs are estimated using a model specifically developed for the ADWR. 

The model uses Microsoft Excel software. The main advantage to this modeling approach is that 

it effectively captures point estimates of all cost information and presents it in a transparent 

Page 5-1 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

manner. This information forms the basis for examining impacts to air carriers and aircraft 

PWSs. 

The remainder of this chapter is organized as follows: 

•	 Section 5.2 describes the general costing and compliance assumptions used to 

estimate national implementation costs for the final ADWR. 

•	 Section 5.3 describes the methodology of projecting costs over a 25-year period 

according to the ADWR compliance schedule, estimating the present value of 

each cost, and annualizing each cost over a 25-year period. 

•	 Section 5.4 describes the methodology for developing costs for all rule activities. 

•	 Section 5.5 presents passenger cost estimates. 

•	 Section 5.6 presents a discussion of non-quantified costs and uncertainties in cost 

estimates. 

•	 Section 5.7 presents the total annualized implementation cost for the final ADWR 

as well as the annualized incremental cost for the final rule. 

•	 Section 5.8 presents a comparison of cost estimates for the final ADWR to 

estimates for other rule alternatives considered and the proposed rule. 

•	 Section 5.9 qualitatively compares the estimated costs for the final ADWR to the 

potential expected benefits. 

•	 Section 5.10 discusses other economic measures. 

5.2	 General Cost Assumptions and Methodology 

The ADWR Cost Model incorporates several baseline data elements, including the 

numbers, models, and seating capacity of aircraft; number of available sampling points per 

aircraft; and the number of flights per aircraft per year. Because many of the assumptions apply 

not to air carriers but to aircraft, where appropriate, exhibits in this chapter use aircraft estimates. 

Derivations of these baseline assumptions are discussed in Chapter 3. In addition, this section 

discusses several additional baseline costing assumptions used as inputs to the ADWR Cost 

Model including labor rates (Section 5.2.1) and laboratory fees (Section 5.2.2). 

The ADWR cost model uses the air carrier baseline water quality data submitted by air 

carriers to EPA for compliance with AOCs as described in Chapter 3, and assumptions regarding 

labor hours, laboratory costs, and labor rates to generate point estimates for air carrier costs for 

components of the final rule and each alternative. The model also includes Agency costs by rule 

Page 5-2 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

component, which are costs incurred by EPA Headquarters and Regional offices to implement 

the rule. Detailed breakouts of costs for the final rule generated by the cost model are presented 

in this chapter. See Appendix C for detailed breakouts of costs for the other alternatives that 

were considered during rule development. 

5.2.1 Labor Rates 

For costing purposes, EPA estimates the labor needs and hourly labor rates of air carrier 

employees for three labor categories: managerial, clerical, and technical (see Exhibit 5.1). EPA 

recognizes that there may be significant variation in labor rates across all air carriers. However, 

for purposes of this analysis, EPA used national-level estimates from two resources: 1) the 

Bureau of Labor Statistics Occupational Employment Survey (Air Transportation, May 2007) 

and, 2) Occupational Employment Wages for Flight Attendants (May 2005). The 2005 document 

for flight attendant wages was used because flight attendant wage data for 2006 and 2007 were 

not available. To be consistent with other costs used in the cost model, all estimates were 

converted to 2008 dollars for the analysis. The costs reflect a load factor of 1.5 to account for 

benefits paid to air carrier workers based on the BLS Employer Costs for Employee 

Compensation Report, June 2008 (BLS, 2008)14. 

Exhibit 5.1 Loaded Labor Rates by Standard Occupational Classification (SOC) 

Code (2008$) 

SOC Code Occupation Mean Hourly Wage 

Managerial 

SOC 11-3071 

Transportation, Storage, and Distribution 

Managers $65.42 

Clerical 

SOC 43-6014 Secretaries, Except Legal, Medical, and Executive $22.50 

Technical 

SOC 39-6031 Flight Attendants $41.72 

SOC 53-7061 Cleaners of Vehicles and Equipment $20.19 

SOC 53-6051 Transportation Inspectors $42.86 

SOC 51-9061 

Inspectors, Testers, Sorters, Samplers, and 

Weighers $34.27 

SOC 53-6099 Transportation Workers $28.41 

Source: Bureau of Labor Statistics (BLS) Occupational Employment Survey, May 2007, Air Transportation 481000, http://www.bls.gov/data/.
 

Flight Attendants - Occupational Employment and Wages, May 2005. Flight attendants' wage data for 2006 and 2007 not available.
 

To estimate costs for many of the rule components, EPA used the transportation inspector 

category because it was the highest-paid technical labor category. Various other technical and 

managerial rates are also included in the model based on the rule component and related 

activities. It should be noted the BLS labor rate for this labor category decreased from that 

obtained from BLS and used for cost estimates for the proposed rule. 

14 BLS Employer Costs for Employee Compensation Report, Table 9, June 2008. All workers in private industry. 

Production, transportation, and material moving. Transportation and material moving subsector. 

http://www.bls.gov/ncs/ect/home.htm 

Page 5-3 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

In developing Agency labor costs, EPA estimates the average hourly labor rate for salary, 

overhead, and benefits for Agency staff to be $50.14. To derive this figure, EPA multiplied the 

hourly compensation at General Schedule (GS)-12, Step 5 on the 2008 GS pay scale ($31.34) by 

a benefits multiplication factor of 1.6 to account for overhead and benefits as specified in the 

ICR Handbook (USEPA, 2005). 

5.2.2 Laboratory Fees 

A laboratory fee, or cost per sample, is associated with total coliform, disinfectant 

residual, and turbidity monitoring. EPA estimated the cost of monitoring based on the use of a 

commercial laboratory, as shown in Exhibit 5.2. EPA’s estimate of the cost per total coliform 

sample includes sampling burden, the analysis cost charged by the laboratory, and shipping and 

handling. Disinfectant residual sampling and turbidity monitoring are not required under the 

final rule but would be required under one or more of the alternatives evaluated. Disinfectant 

residual samples and turbidity samples would be analyzed on-site; therefore, the cost per 

disinfectant residual sample and turbidity sample includes only the sampling kit purchased by the 

air carrier and the sampling and in-house analysis burden. It is estimated that all samples 

requiring commercial laboratory analysis for each sampling event (e.g., two routine samples or 

three repeat samples) will be shipped together to a laboratory between 20-30 miles from the 

airport. The estimated burden required to collect samples reflects a national average. Individual 

air carriers may realize collection burden that is either less than or greater than this average 

depending on locations of the airports with respect to EPA-or State-certified laboratories, aircraft 

schedules, and accessibility of sampling points in a particular aircraft. No additional costs are 

assumed for installation of new sampling taps, since EPA assumes all aircraft are equipped with 

existing taps for sampling. 

Rates may vary due to regional variations in laboratory fees, the number of samples 

processed (quantity discounts), and laboratory capacity. Although laboratory costs are often 

lower for multiple samples, there are no estimates of the number of air carriers that may be able 

to take advantage of this savings. Therefore, the rate used in this analysis may over estimate the 

actual cost incurred by aircraft water systems. 

Page 5-4 
 

 

 

 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.2 Laboratory Costs (2008$)

Item Cost 

TC Coliform Sample $22.16 

Disinfectant Residual Sampling Kit $2.96 

Shipping $107.48 

Annual Equipment Replacement $219.00 

One-time Equipment Purchase (3 refrigerators) $597.00 

Portable 2100P turbidimeter and accessories $858.00 

Turbidimeter calibration kit $97.69 

Turbidimeter secondary standards $124.00 

Notes:
 

1) Estimated chlorine residual sampling kit costs from www.hach.com ($74 for 25 tests).
 

2) Assume shipping and annual equipment replacement costs are incurred by coliform monitoring. Disinfectant residual samples will be analyzed
 

immediately and will not require shipping or refrigeration.
 

3) Assume 3 coolers ($33/cooler), 9 gel packs ($4/gel pack), and 2 calibrated thermometers ($42/thermometer) purchased per air carrier. Cost of
 

cooler and gel pack from www.coleman.com. Cost of thermometer from https://www1.fishersci.com.
 

4) Assume 3 refrigerators ($199/refrigerator) purchased per air carrier twice in the 25-year evaluation period. Cost of refrigerator from
 

www.homedepot.com.
 

5) Sample analysis costs based on average costs from various EPA certified labs across the U.S.
 

6) Cost of 2100P turbidimeter, calibration kit, and secondary standards from www.hach.com
 

5.3	 Projecting and Discounting National Costs 

Costs must be expressed in common units so they can be added together to calculate total 

annual costs. For the ADWR, some activities occur once, such as preparing monitoring plans 

and O&M plans. Other activities such as self-inspections are assumed to happen once every five 

years. Because these activities do not occur instantly or simultaneously, and to make such values 

comparable, the year or years in which all costs are expended must be determined and the costs 

must be brought back to their present value. For the purposes of this analysis, one-time and 

yearly costs were projected over a 25-year time period to coincide with and allow comparison 

with other drinking water regulations. The present values of costs are calculated using discount 

rates of 3 and 7 percent based on EPA policy and OMB guidance.15 

Several adjustments are made to the cost estimates when costs are being used as part of 

the national cost estimate. A summary of these adjustments is as follows: 

•	 Project all undiscounted costs over a 25-year time horizon based on the rule 

implementation schedule. 

•	 Calculate total present value costs using 3 and 7 percent discount rates. 

•	 Annualize the costs over 25 years using the same discount rates. 

Appendix C contains results from each step above for the final rule. Exhibits C.12 

through C.14 show the nominal costs projected over the rule schedule and the present value of 

15 The choice of an appropriate discount rate is a complex and controversial issue among economists and policy 

makers. Therefore, the Agency compares streams of future national level costs and benefits using two alternative 

discount rates, 3 and 7 percent. The underlying logic for each discount rate can be found in Guidelines for 

Preparing Economic Analyses (USEPA, 2000). 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

each cost calculated to the expected year of rule implementation for the final rule as well as the 

results for Alternatives 1, 2, and 3. 

5.4 Derivation of Costs for Air Carriers and the Agency 

This section presents the methodology and unit costs used to derive national costs for air 

carriers and the Agency to perform the final ADWR-related activities, and a brief summary of 

each rule component. Chapter 2 contains a detailed summary of the ADWR requirements. This 

section is organized by rule component as follows: 

5.4.1 Rule Implementation/Annual Administration 

5.4.2 Sampling Plan 

5.4.3 O&M Plan 

5.4.4 Coliform Monitoring 

5.4.5 Routine Disinfection and Flushing 

5.4.6 Disinfection and Flushing as Corrective Action 

5.4.7 Compliance Audit and Self-Inspection 

This chapter uses baseline information presented in Chapter 3 as a starting point for 

analysis of air carriers/aircraft subject to each rule component. Exhibit 5.3 presents key baseline 

information on the number of persons served per year and the number of aircraft that is 

referenced throughout this section. These aircraft are assumed to be TNCWSs that board 

finished surface water. The aircraft inventory presented in Exhibit 5.3 represents the baseline for 

rule activities that are applicable onboard the aircraft (monitoring, and disinfection and flushing). 

Implementation and annual administration activities, development of monitoring and O&M 

plans, and compliance audits will occur on an air carrier-wide basis. Exhibit 5.3 is stratified 

according to the number of available sampling points per aircraft for data display purposes only. 

For the purposes of analyses, each qualifying lavatory and galley on an aircraft is assumed to 

have only one sampling tap. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.3 ADWR

Total # o

 Aircraft and Population Baseline 

# of Available Sampling 

Points # of Aircraft 

f Available 

Sampling Points # of Onboard Staff/year # of Passengers/year 

Total # of Potentially 

Affected Persons/year 

A B C=B*A D E F=D+E 

1 

2 

3 

4 

5 

6 

7 

8 

> 9 

381 

2,080 

756 

421 

956 

871 

298 

809 

755 

381 

4,160 

2,268 

1,684 

4,780 

5,226 

2,086 

6,472 

9,354 

1,978,974 

8,639,938 

2,332,151 

2,510,833 

6,641,598 

3,879,569 

1,414,970 

3,765,459 

3,998,054 

24,980,980 

104,430,089 

22,935,259 

51,846,929 

158,813,021 

91,360,628 

34,239,869 

93,648,921 

126,176,568 

26,959,953 

113,070,026 

25,267,410 

54,357,762 

165,454,619 

95,240,197 

35,654,839 

97,414,380 

130,174,622 

Total 7,327 36,411 35,161,545 708,432,263 743,593,809 

Notes: 

(A) Each qualifying lavatory and galley on an aircraft is assumed to have only one sampling point. Therefore, the number of available sampling points is
 

representative of the number of lavatories and galleys on an aircraft.
 

(B), (D), (E) Derived from Appendix B.
 

(C) Average number of sampling points used for 9 sampling points size category. > 
 

5.4.1 Rule Implementation and Annual Administration 

5.4.1.1 Air Carriers 

All air carriers subject to the ADWR will incur one-time costs that include time for staff 

to read the rule and become familiar with its provisions and to train employees on rule 

requirements. All 63 air carriers subject to the ADWR will perform implementation activities. 

The technical labor rate presented in section 5.2.1 is used along with estimates of labor hours to 

generate implementation costs for all air carriers. Based on previous experience with rule 

implementation, EPA estimates that each air carrier would require 4 staff persons to spend 2 

hours each for a total of 8 hours to read and understand the rule, and a total of 8 hours to train 

personnel. These unit costs are presented in Exhibit 5.4. 

Exhibit 5.4 Air Carrier Burden and Cost Estimates for Implementation

Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor Burden 

(hours) Total Cost ($) 

A B C=A*B D=B*63 E=C*63 

Read and Understand Rule $42.86 8 $ 343 504 $ 21,600 

Train Personnel $42.86 8 $ 343 504 $ 21,600 

Total 16 $ 686 1,008 $ 43,201 

Notes: 

(1) Detail may not add due to independent rounding.
 

Sources:
 

(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation 

inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
 

(B) Labor hours for start-up activities reflect EPA estimate.
 

(D), (E) National totals for all 63 U.S. air carriers subject to ADWR to perform implementation activities. Assumes all air carriers spend equal time performing 

implementation activities, regardless of fleet size or aircraft type.
 

5.4.1.2 Agency 

The Agency will incur administrative costs while implementing the ADWR. These 

implementation costs are not directly required by specific provisions of ADWR alternatives, but 

would be necessary for the Agency to ensure that the provisions of the ADWR are properly 

carried out. The Agency will need to allocate time for their staff to establish and then maintain 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

the programs necessary to comply with the ADWR, including developing and/or modifying data 

management systems to track new required air carrier reports. Agency burden estimates include 

time for rule-implementation staff to read and understand the rule. The Agency will need to 

develop a program to oversee inventory and sampling data submitted by air carriers. To manage 

data received by air carriers, the Agency will also need to modify or develop data management 

systems. In addition to training Regional staff who will be reviewing data and overseeing the 

program, the Agency will need to sponsor administrative training for air carriers, similar to a 

train-the-trainer session, to help air carriers understand their responsibilities under the rule. 

Finally, the Agency will need to provide technical assistance when air carriers request help 

implementing the rule. Time requirements for Agency activities are presented in Exhibit 5.5a 

which lists the one-time activities required to start the program following promulgation of the 

ADWR along with their respective costs and burden. Agency burden and cost estimates are 

presented as distributed evenly between the 10 EPA Regional offices. However, some of these 

tasks will be the responsibility of the EPA Headquarters office in Washington, D.C., and some 

Regions will incur more costs than others due to the number of air carriers and aircraft based in 

each Region. 

Exhibit 5.5a Agency Burden and Cost Estimates for Implementation

Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/Region) Unit Cost 

Total Labor 

Burden (hours) Total Cost ($) 

A B C=A*B D=B*10 E=C*10 

Read and Understand Rule $50.14 8 $ 401 80 $ 4,012 

Program Development $50.14 40 $ 2,006 400 $ 20,058 

Modify/Develop Data Management Systems $50.14 115 $ 5,767 1,150 $ 57,666 

Air Carrier Training and Technical Assistance $50.14 80 $ 4,012 800 $ 40,115 

Staff Training $50.14 40 $ 2,006 400 $ 20,058 

Total 283 $ 14,191 2,830 $ 141,908 

Notes: 

(1) Detail may not add due to independent rounding.
 

Sources:
 

(A) Agency labor costs from Section 5.2.1
 

(B) Labor hours for start-up activities reflect EPA estimate.
 

(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spends equal time performing 

implementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.
 

In addition to these one-time costs, the Agency will need to expend resources on 

continuing administrative activities. On an annual basis, the Agency will have to provide 

ongoing technical assistance to air carriers and to their own staff. The Agency already oversees 

laboratory certification programs for the TCR, and it is not anticipated additional costs will be 

necessary for this activity. Exhibit 5.5b lists these annual activities with their respective costs 

and burden. 

Page 5-8 
 

 

 

 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.5b Agency Burden and Cost Estimates for Annual Administration

Compliance Activity 

Labor Cost 

($/hour) 

Labor 

(hours/Region/year) Cost ($/year) 

Total Labor 

Burden 

(hours/year) Total Cost ($/year) 

A B C=A*B D=B*10 E=C*10 

Lab Certification $50.14 - $ - - $ -

Ongoing Technical Assistance $50.14 500 $ 25,072 5,000 $ 250,720 

Staff Training $50.14 16 $ 802 160 $ 8,023 

Total 516 $ 25,874 5,160 $ 258,743 

Notes: 

(1) Detail may not add due to independent rounding. 

(2) No costs are associated with lab certification under the ADWR because it is not anticipated that the Agency will need to oversee lab certification programs in
 

addition to what is being done for the Total Coliform Rule.
 

Sources:
 

(A) Agency labor costs from Section 5.2.1.
 

(B) Labor hours for start-up activities reflect EPA estimate.
 

(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spends equal time performing 

implementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.
 

5.4.1.3 Annualized Costs for Rule Implementation/Annual Administration 

Annualized costs estimates for air carriers and the Agency to perform implementation 

activities for the final rule are presented in Exhibit 5.6. 

Exhibit 5.6 Air Carrier and Agency Cost Estimates for Implementation and Annual 

Administration ($Millions, 2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Implementation $ 0.002 $ 0.01 $ 0.01 $ 0.004 $ 0.01 $ 0.02 

Annual Administration $ - $ 0.24 $ 0.24 $ - $ 0.23 $ 0.23 

Total $ 0.002 $ 0.25 $ 0.25 $ 0.004 $ 0.25 $ 0.25 

5.4.2 Sampling Plan 

5.4.2.1 Air Carriers 

Under the final rule, all air carriers subject to the ADWR will develop sampling plans to 

satisfy rule requirements. The sampling plan will include the air carrier’s monitoring frequency 

and their disinfection and flushing frequency, and is assumed to include one plan to address the 

entire aircraft fleet. EPA has estimated that each air carrier will require a total of 10 hours to 

develop sampling plans for all qualifying aircraft in their fleet, regardless of fleet size or aircraft 

type. This one-time labor burden also includes the initial submission of air carrier inventory 

information. Sampling plans will be developed in years 1 and 2 of the 25-year compliance 

period. Exhibit 5.7 presents air carrier burden and costs for sampling plan requirements. 

Page 5-9 
 

 

 

 

 

 

 

 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.7 Air Carrier Burden and Cost Estimates for Sampling Plan

Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor Burden 

(hours) Total Cost ($) 

A B C=A*B D=B*63 E=C*63 

Develop Sampling Plan per ADWR requirements and 

Report Sampling Frequency $42.86 10 $ 429 630 $ 27,001 

Total 10 $ 429 630 $ 27,001 

Notes:
 

One-time labor burden for sampling plan includes initial submission of air carrier inventory information.
 

Sources:
 

(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation 

inspectors are assumed to have a technical background, as well as some management or oversight responsibility.
 

(B) Labor hours for developing sampling plans and reporting sampling frequency reflect EPA estimate. Assumes both disinfection and flushing frequency and monitoring
 

frequency will be reported in plan.
 

(D), (E) Assume all of the 63 U.S. air carriers subject to ADWR will develop sampling plans. Assumes all air carriers spend equal time developing sampling plans,
 

regardless of fleet size or aircraft type.
 

5.4.2.2 Agency 

Agency costs for the final ADWR sampling plan requirements are assumed to be solely 

administrative. The Agency will incur costs to review air carrier sampling frequencies. EPA 

assumes the Agency will require a total of 5 hours to review each air carrier sampling frequency, 

regardless of fleet size or aircraft type. This one-time labor burden also includes reviewing the 

initial submission of air carrier inventory information. The Agency will review the sampling 

frequency in years 1 and 2 of the 25-year compliance period, as they are received from air 

carriers. Exhibit 5.8 presents Agency burden and costs for sampling plan requirements. 

Exhibit 5.8 Agency Burden and Cost Estimates for Sampling Plan

Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor Burden 

(hours) Total Cost ($) 

A B C=A*B D=B*63 E=C*63 

Review Air Carrier Sampling Plan and Frequency $50.14 4.5 $ 226 284 $ 14,216 

Total 4.5 $ 226 284 $ 14,216 

Notes:
 

One-time labor burden for sampling plan includes reviewing initial submission of air carrier inventory information.
 

Sources:
 

(A) Agency labor costs from Section 5.2.1.
 

(B) Labor hours for reviewing sampling plans and frequency reflect EPA estimate.
 

(D), (E) Assume all of the 63 U.S. air carriers subject to ADWR will develop sampling plans. Assumes Agency spends equal time reviewing air carrier sampling plans,
 

regardless of fleet size or aircraft type.
 

5.4.2.3 Annualized Costs for Sampling Plan 

Annualized costs for air carriers and the Agency to develop and review sampling 

frequencies for the final rule are presented in Exhibit 5.9. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.9 Air Carrier and Agency Cost Estimates for Sampling Plan ($Millions, 

2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Sampling Plan $ 0.002 $ 0.001 $ 0.002 0.002 $ $ 0.001 $ 0.003 

Total $ 0.002 $ 0.001 $ 0.002 0.002 $ $ 0.001 $ 0.003 

5.4.3 O&M Plan 

5.4.3.1 Air Carriers 

Under the final rule, all air carriers subject to the ADWR will need to develop water 

system O&M plans and practices with ADWR-specific requirements or update existing plans. 

EPA assumes that each air carrier will require a total of 80 hours to develop water system O&M 

plans and practices for all qualifying aircraft in their fleet, regardless of fleet size or aircraft type, 

and to submit a statement to the Agency indicating that their O&M plan has been completed. 

O&M plans and practices will be developed in years 1 and 2 of the 25-year compliance period. 

Exhibit 5.10 presents air carrier burden and costs for O&M plan requirements. 

Exhibit 5.10 Air Carrier Burden and Cost Estimates for O&M Plan

Compliance Activity 

Labor Cost 

($/hour) 

One-time Labor Burden 

(hours/air carrier) Unit Cost 

Total Labor Burden 

(hours) Total Cost ($) 

A B C=A*B D=B*63 E=C*63 

Update existing O&M manual and practices with ADWR 

specific requirements and submit statement to Agency 

indicating that O&M manual has been updated $42.86 80 $ 3,429 5,040 $ 216,005 

Total 80 $ 3,429 5,040 $ 216,005 

Sources: 

(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors are
 

assumed to have a technical background, as well as some management or oversight responsibility.
 

(B) Labor hours for developing and implementing O&M plan and submitting verification statement to Agency reflect EPA estimate.
 

(D), (E) 63 U.S. air carriers subject to ADWR will develop O&M plans. Assumes all air carriers spend equal time developing and implementing O&M plan, regardless of fleet size
 

or aircraft type.
 

5.4.3.2 Agency 

O&M plans will be reviewed by the Agency as part of compliance audits and will not 

require a separate Agency review. Therefore, EPA assumes there will be no additional cost 

associated with reviewing O&M plans. However, the Agency will require 0.5 hour per air 

carrier to review the statement submitted by the system indicating that the air carriers’ O&M 

manual has been completed. Exhibit 5.11 presents Agency burden and costs for O&M plan 

requirements. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.11 Agency Burden and Cost Estimates for O&M Plan

Compliance Activity 

Labor Cost 

($/hour) 

One-time Labor Burden 

(hours/air carrier) Unit Cost 

Total Labor Burden 

(hours) Total Cost ($) 

A B C=A*B D=B*63 E=C*63 

Review system submitted statement indicating that O&M 

manual has been updated $50.14 0.5 $ 25 32 $ 1,580 

Total 0.5 $ 25 32 $ 1,580 

Sources: 

(A) Agency labor costs from Section 5.2.1. 

(B) Labor hours for reviewing verification statement reflect EPA estimate. Assumes O&M plan review will be completed as part of compliance audits.
 

(D), (E) 63 U.S. air carriers subject to ADWR will develop O&M plans. Assumes all Regional Agency offices spend equal time reviewing and approving O&M plan, regardless of
 

fleet size or aircraft type.
 

5.4.3.3 Annualized Costs for O&M Plan 

Annualized costs estimates for air carriers and the Agency to comply with O&M plan 

requirements for the final rule are presented in Exhibit 5.12. 

Exhibit 5.12 Air Carrier and Agency Cost Estimates for O&M Plan ($Millions, 

2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

O&M Plan $ 0.01 $ 0.0001 $ 0.01 $ 0.02 $ 0.0001 $ 0.02 

Total $ 0.01 $ 0.0001 $ 0.01 $ 0.02 $ 0.0001 $ 0.02 

5.4.4 Coliform Monitoring 

5.4.4.1 Air Carriers 

Under the final rule, all air carriers subject to the ADWR are required to perform 

coliform monitoring for their aircraft. Coliform monitoring begins in year 3 and continues 

throughout the 25-year evaluation period. An air carrier’s coliform monitoring schedule is 

determined by its disinfection and flushing frequency, which should be based on manufacturer’s 

recommendations. EPA is providing significant flexibility by allowing air carriers to choose 

their monitoring frequency if there is no manufacturer’s recommended frequency. See Section 

5.4.5 for a detailed discussion on routine disinfection and flushing. For modeling purposes, EPA 

assumes 30 percent of air carriers will monitor annually, 30 percent twice annually, 30 percent 

quarterly, and 10 percent monthly, as shown in column D of Exhibit 5.13. Based on monitoring 

data collected under the AOCs for air carriers with approved QAPPs and CRMPs, EPA assumes 

that 3.6 percent of samples will be total coliform-positive (column E, Exhibit 5.13). EPA may be 

over- or under-estimating the total number of total coliform-positive samples. Appendix B 

provides a detailed breakdown of the air carrier monitoring data collected under the AOCs. 

Air carriers are assumed to collect routine coliform samples immediately prior to routine 

disinfection and flushing procedures whenever possible. This scheduling option allows any 

subsequent corrective action disinfection and flushing procedures to be performed when the 

aircraft is already out of service for the scheduled routine maintenance. The option also allows 

Page 5-12 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

the disinfection and flushing procedure to count toward both the corrective action and routine 

efforts as long as two follow-up coliform samples are collected after the disinfection and flushing 

procedure to meet the corrective action requirements. EPA evaluated the opportunities aircraft 

would have to apply this practice by comparing the frequency of routine coliform sampling to 

the associated frequency of routine disinfection and flushing for the same option. Based on this 

analysis, EPA assumes that 0 percent of aircraft monitoring annually and twice annually, 50 

percent of aircraft monitoring quarterly, and 46 percent of aircraft monitoring monthly with a 

total coliform-positive sample will collect three repeat samples within 24 hours of notification of 

a total coliform-positive routine sample as an option to immediate corrective action (column G, 

Exhibit 5.13); all other aircraft would perform immediate corrective action. Of those aircraft 

collecting repeat samples, 5.7 percent are assumed to detect an additional total coliform-positive 

(column F, Exhibit 5.13). The two follow-up samples required per aircraft that performs 

disinfection and flushing as corrective action is included in the coliform monitoring cost estimate 

(column I, Exhibit 5.13). 

EPA assumes 0.5 hour for each coliform sample collection, processing, storage, and 

shipping (column J, Exhibit 5.13). Therefore, the burden is assumed to be 1 hour for the two 

samples collected for routine sampling, 1.5 hours for the three samples collected for repeat 

sampling, and 1 hour for the two corrective action disinfection and flushing follow-up samples. 

Although the ADWR allows aircraft with a single storage tank that is removed and drained daily 

to collect only one routine sample, EPA has no data to determine the number of aircraft 

addressed by this provision, and therefore, for this analysis assumed all aircraft will collect two 

routine samples. No sample analysis burden is incurred by air carriers, since EPA assumes that 

all coliform analysis will be conducted by an outside laboratory (column M, Exhibit 5.13). EPA 

assumes each air carrier will purchase three refrigerators to store samples. Refrigerator costs are 

assumed to occur twice during the 25-year evaluation period, in years 3 and 13. Additionally, 

EPA assumes that each air carrier will purchase three coolers, nine gel packs, and two 

thermometers every year to store, transport, and measure samples. Costs for the refrigerator and 

shipping (and storage materials purchased for shipping) are solely attributed to coliform 

monitoring. Shipping costs are estimated to be approximately $107 per sample set, which 

consists of two routine samples, three repeat samples, and two follow-up samples. 

Reporting and Recordkeeping for Coliform Monitoring 

Under the final rule, air carriers are required to maintain maintenance logs and report 

monitoring results to the Agency. The maintenance logs contain information on sampling 

locations and results. EPA assumes air carriers will require 15 minutes for each of these 

recordkeeping activities per sample set. Air carriers are also required to report their water 

system inventory within 18 months of promulgation of the final rule and update that inventory 

annually. The initial submission of inventory information is assumed to be submitted as part of 

the sampling plan. EPA assumes air carriers will require 1 hour each year for annual inventory 

updates. 

Page 5-13 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit 5.13 Air Carrier Burden and Cost Estimates for Coliform Monitoring

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Routine Coliform 

Monitoring 

(samples/year) 

Routine Coliform 

Monitoring TC+ 

(samples/year) 

Additional TC+ 

(samples/year) 

Repeat 

(samples/year) 

Additional Routine 

Coliform Monitoring 

(samples/year) 

Corrective Action 

Coliform Follow-up 

Sample (postdisinfection sample) 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden (hours/year) 

Tot

Co

A B C=B*A D E=D*0.036 F G H I J K=J(D+G+H+I) 

1 381 381 2,515 91 5 95 0 129 0.5 1,369 $ 

2 2,080 4,160 13,728 494 30 518 0 702 0.5 7,474 $ 3 756 2,268 4,990 180 11 188 0 255 0.5 2,717 $ 4 421 1,684 2,779 100 6 105 0 142 0.5 1,513 $ 5 956 4,780 6,310 227 14 238 0 323 0.5 3,435 $ 6 871 5,226 5,749 207 12 217 0 294 0.5 3,130 $ 7 298 2,086 1,967 71 4 74 0 101 0.5 1,071 $ 

8 809 6,472 5,339 192 11 201 0 273 0.5 2,907 $ > 9 755 9,354 4,983 179 11 188 0 255 0.5 2,713 $ 

Total 7,327 36,411 48,358 1,741 104 1,823 0 2,474 26,328 

TC Samples TC Sampling 

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden 

(hours/year) 

Unit Shipping Cost 

($/sample set) 

Total Shipping Cost 

($/year) 

Unit Analysis Cost 

($/sample) 

Total Analysis Cost 

($/year) 

Annual Unit 

Equipment Cost ($/air 

carrier/year) 

Total Annual 

Equipment Cost 

($/year) 

Periodic 

Equipment 

Cost ($/air 

carrier) 

To

Equ

A B C=B*A M N=M(D+G+H+I) O P=O(D/2+G/3+H+I/2) Q R=Q(D+G+H+I) S T U 

1 381 381 0 - $107 $ 145,446 $22.16 $ 60,682 $ 219 $ 717 $ 597 $ 

2 2,080 4,160 0 - $107 $ 794,034 $22.16 $ 331,283 $ 219 $ 3,917 $ 597 $ 

3 756 2,268 0 - $107 $ 288,601 $22.16 $ 120,409 $ 219 $ 1,424 $ 597 $ 

4 421 1,684 0 - $107 $ 160,716 $22.16 $ 67,053 $ 219 $ 793 $ 597 $ 

5 956 4,780 0 - $107 $ 364,950 $22.16 $ 152,263 $ 219 $ 1,800 $ 597 $ 

6 871 5,226 0 - $107 $ 332,502 $22.16 $ 138,725 $ 219 $ 1,640 $ 597 $ 

7 298 2,086 0 - $107 $ 113,761 $22.16 $ 47,463 $ 219 $ 561 $ 597 $ 

8 809 6,472 0 - $107 $ 308,833 $22.16 $ 128,850 $ 219 $ 1,523 $ 597 $ 

> 9 755 9,354 0 - $107 $ 288,219 $22.16 $ 120,249 $ 219 $ 1,422 $ 597 $ 

Total 7,327 36,411 0 $ 2,797,061 $ 1,166,977 $ 13,797 $ 

Analysis 

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Maintain 

Maintenance Log 

(hours/sample set) 

Report Monitoring 

Results 

(hours/sample set) 

Report Water System 

Inventory/Changes 

(hours/air carrier) 

Report Water System 

Inventory/Changes 

Burden (hours/year) 

Labor Cost 

($/hour) 

Recordkeeping and 

Reporting Labor 

(hours/year) 

Recordkeeping 

Cost ($/year) 

Total Burden 

(hours/year) 

Total O&M Cost 

($/year) 

T

A B C=B*A W X Y Z AA 

AB=((W+X)* 

(D/2+G/3+H+I/2))+Z AC=AB*AA AD=K+M+AB AE=L+P+R+T+AC 

1 381 381 0.25 0.25 1.00 3.28 $34.27 680 $ 23,303 2,049 $ 277,070 $ 

2 2,080 4,160 0.25 0.25 1.00 17.88 $34.27 3,712 $ 127,217 11,186 $ 1,512,615 $ 

3 756 2,268 0.25 0.25 1.00 6.50 $34.27 1,349 $ 46,238 4,066 $ 549,777 $ 

4 421 1,684 0.25 0.25 1.00 3.62 $34.27 751 $ 25,749 2,264 $ 306,159 $ 

5 956 4,780 0.25 0.25 1.00 8.22 $34.27 1,706 $ 58,471 5,141 $ 695,221 $ 

6 871 5,226 0.25 0.25 1.00 7.49 $34.27 1,554 $ 53,272 4,684 $ 633,407 $ 

7 298 2,086 0.25 0.25 1.00 2.56 $34.27 532 $ 18,226 1,603 $ 216,711 $ 

8 809 6,472 0.25 0.25 1.00 6.96 $34.27 1,444 $ 49,480 4,351 $ 588,320 $ 

> 9 755 9,354 0.25 0.25 1.00 6.49 $34.27 1,347 $ 46,177 4,060 $ 549,050 $ 

Total 7,327 36,411 63 $ 448,133 39,403 5,328,330 $ $ 

Recordkeeping Totals 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) One galley and one lavatory TC sample collected per aircraft. Assume 30% of aircraft will sample annually, 30% of aircraft will sample twice annually, 30% of aircraft will sample quarterly, and 10% of aircraft will sample monthly. (E) Assume 3.6% of coliform samples will be TC+ based on AOC data. (F) Assume 0% of aircraft performing annual routine coliform monitoring, 0% of aircraft performing twice annual routine coliform monitoring, 50% of aircraft performing quarterly routine coliform monitoring, and 46% of aircraft performing monthly routine coliform mon

initial TC+ sample will perform repeat sampling. Assume 5.7% of aircraft performing repeat sampling will have at least one additional TC+ sample (based on AOC data). (G) Assume 0% of aircraft performing annual routine coliform monitoring, 0% of aircraft performing twice annual routine coliform monitoring, 50% of aircraft performing quarterly routine coliform monitoring, and 46% of aircraft performing monthly routine coliform moTC+ will collect three repeat samples within 24 hours of notification of TC+ as an option to immediate corrective action. Assume aircraft with less than three sampling points collect a total of 300mL of samples from all available sampling points. (H) Additional routine coliform monitoring not specified, assumed no additional routine coliform monitoring samples collected. (I) Assume 100% of aircraft performing annual routine coliform monitoring, 100% of aircraft performing twice annual routine coliform monitoring, 50% of aircraft performing quarterly routine coliform monitoring, and 54% of aircraft performing monthly routine coliform will collect 2 follow-up samples per aircraft that undergoes corrective action flushing and disinfecting. (J) Assume 0.5 hour for sample collection and for process, storage, and shipping of sample. (Sample set burden is 1 hour for (2) routine samples, 1.5 hours for (3) repeat samples, and 1 hour for (2) corrective action follow-up samples.) (M) Assume all analysis conducted by outside lab. (O) Estimated courier fees based on costs from various courier services in major cities. Assumed courier services required for each sample set. (Sample set consists of 2 routine samples, 3 repeat samples, and 2 corrective action follow-up samples.) Assumed airpof 20-30 miles from lab. Assumed courier would return cooler to air carrier. 100% of shipping costs incurred by TC monitoring. (Q) Average coliform analysis costs based on costs from various labs across the country. Assume all analysis conducted by outside lab. 

(S) Assume air carriers will replace coolers, gel packs, and thermometers once a year. 100% of the unit equipment cost is incurred by total coliform monitoring. (T) Coolers, gel packs, and thermometers are purchased by air carriers. The costs for this equipment are assumed to be distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only. (U) Assume each aircraft will purchase three new refrigerators. 100% of the refrigerator cost is incurred by total coliform monitoring. (V) Refrigerators are purchased by air carriers. Assume costs for 63 airlines are distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only. 

(W), (X), (Y) Based on EPA estimate. (Y) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule and update that inventory annually. The initial submission of inventory information is assumed to be submitted as part of the sampling plan. This burden refle

annual inventory updates. (Z) Assume burden for 63 airlines is distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(AA) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.(AB) Columns W and X applied on a sample set basis. Assume a sample set consists of (2) routine samples, (3) repeat samples, and (2) corrective action follow-up samples.
 

 

 

 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

5.4.4.2 Agency 

Agency costs for the final ADWR coliform monitoring requirements are assumed to be 

solely administrative. The Agency would incur costs to review aircraft monitoring results. EPA 

assumes the Agency will require 0.5 hours to review each aircraft’s coliform-positive monitoring 

results. The Agency will review aircraft coliform monitoring results beginning in year 3 of the 

25-year compliance period, as they are received electronically from air carriers. 

The Agency will need to review all fleet inventory information submitted by air carriers, 

which will include new inventory data and changes to the fleets. Air carriers must report their 

water system inventory within 18 months of promulgation of the final rule and update that 

inventory annually. The initial submission of inventory information is assumed to be reviewed 

as part of the sampling plan. EPA assumes the Agency will require 0.5 hours to review each air 

carrier’s annual inventory updates. Exhibit 5.14 presents Agency burden and costs for coliform 

monitoring. 

Exhibit 5.14 Agency Burden and Cost Estimates for Coliform Monitoring

TC Samples 

Compliance Activity 

Labor Cost 

($/hour) 

Unit labor burden 

(hours/TC+ sample or 

air carrier) 

Unit Cost ($/TC+ 

sample or air 

carrier) 

Total Labor 

Burden (hours) Total Cost ($) 

A B C=A*B D E 

Review Aircraft Monitoring Results $50.14 0.5 $ 25 870 $ 43,648 

Review Aircraft Water System Inventory Changes $50.14 0.5 $ 25 32 $ 790 

Total 1.0 $ 50 902 $ 44,437 

Sources: 

(A) Agency labor costs from Section 5.2.1. 

(B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D) Total labor burden for reviewing monitoring results = unit labor burden * total number of TC+ samples (Exhibit 5.13). Total labor burden for reviewing inventory = 

unit labor burden * 63 air carriers.
 

(E) Total cost for reviewing monitoring results = unit cost * total number of TC+ samples (Exhibit 5.13). Total cost for reviewing inventory = unit cost * total burden for 

reviewing inventory. 

(F) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule and update that inventory annually. The initial submission 

of inventory information is assumed to be reviewed as part of the sampling plan. This burden reflects only review of the annual inventory updates. 

 

5.4.4.3 Annualized Costs for Coliform Monitoring 

Annualized cost estimates for air carriers and the Agency to perform coliform monitoring 

and review results for the final rule are presented in Exhibit 5.15. 

Exhibit 5.15 Air Carrier and Agency Cost Estimates for Coliform Monitoring 

($Millions, 2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Coliform Monitoring $ 4.89 $ 0.04 $ 4.93 4.82 $ $ 0.04 $ 4.86 

Total $ 4.89 $ 0.04 $ 4.93 4.82 $ $ 0.04 $ 4.86 

Page 5-15 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

5.4.5 Routine Disinfection and Flushing 

5.4.5.1 Air Carrier 

Under the final rule, all air carriers subject to the ADWR are required to perform routine 

disinfection and flushing of their aircraft. EPA is providing air carriers with significant 

flexibility by allowing air carriers to choose their routine disinfection and flushing frequency if 

there are no manufacturer’s recommendations. Based on manufacturer’s guidelines, air carriers 

perform disinfection and flushing either quarterly, thrice annually, twice annually, or annually, 

which will determine their coliform monitoring frequencies. When the frequency is not defined 

by the water system manufacturer, air carriers will select the frequency they prefer. Section 

5.4.4 provided a detailed discussion of coliform monitoring. For modeling purposes, EPA 

assumed 30 percent of air carriers will perform disinfection and flushing quarterly, 30 percent 

thrice annually, 30 percent twice annually, and 10 percent annually (column D, Exhibit 5.16). 

Based on observation of aircraft disinfection and flushing practices, EPA assumes 5 

hours per aircraft for routine disinfection and flushing (column F, Exhibit 5.16). Unit chemical 

costs are assumed to be approximately $1.00 per application. EPA assumes air carriers currently 

perform at least periodic disinfection and flushing of the aircraft water systems as part of their 

maintenance programs; therefore, equipment costs have not been included in the estimated costs 

of the ADWR. 

Recordkeeping and Reporting 

Under the final rule, air carriers are required to record routine disinfection activities. 

EPA assumes air carriers will require 15 minutes for this recordkeeping activity per aircraft. 

Page 5-16 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit 5.16 Air Carrier Burden and Cost Estimates for Routine Disinfection and Fl

Routine Disinfection and Flushing 

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Routine Disinfection 

and Flushing 

(aircraft/year) 

Self-Certification 

(aircraft/year) 

Routine Disinfection 

and Flushing Labor 

Burden 

(hours/aircraft) 

Self Certification Labor 

Burden (hours/aircraft) 

Unit Disinfection and 

Flushing Cost ($/hour) 

Unit Self-Certification Cost 

($/hour) 

Un

A B C=B*A D E F G H I 

1 381 381 1,067 0 5 0.5 $20.19 $65.42 $ 

2 2,080 4,160 5,824 0 5 0.5 $20.19 $65.42 $ 

3 756 2,268 2,117 0 5 0.5 $20.19 $65.42 $ 

4 421 1,684 1,179 0 5 0.5 $20.19 $65.42 $ 

5 956 4,780 2,677 0 5 0.5 $20.19 $65.42 $ 

6 871 5,226 2,439 0 5 0.5 $20.19 $65.42 $ 

7 298 2,086 834 0 5 0.5 $20.19 $65.42 $ 

8 809 6,472 2,265 0 5 0.5 $20.19 $65.42 $ 

> 9 755 9,354 2,114 0 5 0.5 $20.19 $65.42 $ 

Total 7,327 36,411 20,516 0 

Recordkeeping 

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Total Cost for Self 

Certification ($/year) 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/aircraft) 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/year) 

Recordkeeping 

Labor Cost ($/hour) 

Maintain 

Maintenance Log 

for Disinfection 

Activities Costs 

($/year) 

Total Rout

Disinfection/F

Labor Bur

(hours/ye

A B C=B*A L=E*G*I M N=D*M O P=N*O Q=(D*F)+(E*G

1 381 381 $ - 0.25 267 $34.27 $ 9,141 2 2,080 4,160 $ - 0.25 1,456 $34.27 $ 49,903 

3 756 2,268 $ - 0.25 529 $34.27 $ 18,138 

4 421 1,684 $ - 0.25 295 $34.27 $ 10,101 

5 956 4,780 $ - 0.25 669 $34.27 $ 22,936 

6 871 5,226 $ - 0.25 610 $34.27 $ 20,897 

7 298 2,086 $ - 0.25 209 $34.27 $ 7,150 

8 809 6,472 $ - 0.25 566 $34.27 $ 19,409 

> 9 755 9,354 $ - 0.25 529 $34.27 $ 18,114 

Total 7,327 36,411 $0 $ 175,789 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Assume 30% of aircraft will perform routine disinfection and flushing quarterly, 30% of aircraft will perform routine disinfection and flushing thrice annually, 30% of perform routine disinfection and flushing twice annually, and 10% of aircraft will perform routine disinfection and flushing annually. (E) Self-certification submittal not required under Alternative 4 (Final Rule). (F) EPA estimate based on observation of flushing and disinfection practices. (G) Labor hours for self-certification reflects EPA estimate. (H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1. (I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1. (J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jug(M) Based on EPA estimate. 

(O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

5.4.5.2 Agency 

Under the final rule, the Agency is not required to assist air carriers with or perform 

routine disinfection or flushing. Additionally, air carriers are not required to submit their records 

to the Agency; the Agency may review these records during a compliance audit. Therefore, the 

Agency will not incur costs for routine disinfection and flushing. 

5.4.5.3 Annualized Costs for Routine Disinfection and Flushing 

Annualized cost estimates for air carriers and the Agency to perform routine disinfection 

and flushing for the final rule are presented in Exhibit 5.17. 

Exhibit 5.17 Air Carrier and Agency Cost Estimates for Routine Disinfection and 

Flushing ($Millions, 2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Routine Disinfection and 

Flushing $ 2.08 -$ $ 2.08 2.05 $ -$ $ 2.05 

Total $ 2.08 -$ $ 2.08 2.05 $ -$ $ 2.05 

5.4.6 Disinfection and Flushing as Corrective Action 

5.4.6.1 Air Carrier 

Under the final rule, EPA assumes that 100 percent of aircraft performing annual and 

twice annual coliform monitoring, 50 percent of aircraft performing quarterly coliform 

monitoring, and 54 percent of aircraft performing monthly coliform monitoring will perform 

corrective action disinfection and flushing after a positive routine total coliform sample. As 

described in Section 5.4.4, EPA assumes the remainder of aircraft with a total coliform-positive 

routine sample will collect three repeat samples within 24 hours of notification of the total 

coliform-positive routine sample result (column G, Exhibit 5.13). EPA assumes 5.7 percent of 

aircraft performing repeat sampling will have at least one additional positive total coliform 

sample and will perform corrective action. 

EPA assumes that the corrective action disinfection and flushing procedure will be 

conducted during routine disinfection and flushing events whenever possible, and therefore, 

would not incur separate costs for corrective action disinfection and flushing events other than 

the cost of collection, shipping, and analysis of two follow-up coliform samples required as part 

of corrective action. 

As a costing assumption, EPA assumes that of the aircraft with a positive routine 

coliform sample, 0 percent of the aircraft performing annual, twice annual, and quarterly 

monitoring, and 46 percent of aircraft performing monthly monitoring will not coordinate routine 

and corrective action disinfection and flushing and will incur the full cost for corrective action 

Page 5-18 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

disinfection and flushing. The estimated number of unique corrective action disinfection and 

flushing events are shown in column D, Exhibit 5.18. 

The estimated number of aircraft performing corrective action disinfection and flushing is 

based on the assumption that during routine coliform monitoring no more than one of the two 

samples would be total coliform-positive per aircraft. This assumption potentially overestimates 

the number of aircraft that need to undergo disinfection and flushing as corrective action in cases 

where both routine samples are total coliform-positive for an aircraft (i.e., an aircraft with 

positive samples from both routine monitoring sampling points is treated as two corrective 

actions in the cost model when only one disinfection and flushing event will be necessary in such 

a case). 

Based on observation of aircraft disinfection and flushing practices, EPA assumes 5 

hours per aircraft for corrective action disinfection and flushing (column F, Exhibit 5.18). Unit 

chemical costs are assumed to be approximately $1.00 per application. As noted for routine 

disinfection and flushing procedures, equipment costs are not included as they are assumed to be 

used for existing aircraft maintenance procedures. 

Page 5-19 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit 5.18 Air Carrier Burden and Cost Estimates for Corrective Action Disinfection an

Corrective Action Disinfection and Flushing 

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Unique Corrective 

Action Disinfection 

and Flushing 

(aircraft/year) 

Repeat Disinfection 

and Flushing 

(aircraft/year) 

Corrective Action 

Disinfection and 

Flushing Labor 

Burden 

(hours/aircraft) 

Unit Disinfection and 

Flushing Cost ($/hour) 

Unit Chemical Cos

($/application) 

A B C=B*A D E F G H 

1 381 381 21 0 5 $20.19 $ 

2 2,080 4,160 112 0 5 $20.19 $ 

3 756 2,268 41 0 5 $20.19 $ 4 421 1,684 23 0 5 $20.19 $ 

5 956 4,780 52 0 5 $20.19 $ 

6 871 5,226 47 0 5 $20.19 $ 

7 298 2,086 16 0 5 $20.19 $ 

8 809 6,472 44 0 5 $20.19 $ 

> 9 755 9,354 41 0 5 $20.19 $ 

Total 7,327 36,411 395 0 

Recordkeeping 

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/aircraft) 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/year) 

Recordkeeping 

Labor Cost ($/hour) 

Maintain Maintenance 

Log for Disinfection 

Activities Costs ($/year) 

Total Corrective Action 

Disinfection/Flushing 

Labor Burden 

(hours/year) 

T

A B C=B*A J K L M=K*L N=((D+E)*F)+K 

1 381 381 0.25 16 $34.27 $ 551 119 $ 

2 2,080 4,160 0.25 88 $34.27 $ 3,009 649 $ 

3 756 2,268 0.25 32 $34.27 $ 1,094 236 $ 

4 421 1,684 0.25 18 $34.27 $ 609 131 $ 

5 956 4,780 0.25 40 $34.27 $ 1,383 298 $ 

6 871 5,226 0.25 37 $34.27 $ 1,260 272 $ 

7 298 2,086 0.25 13 $34.27 $ 431 93 $ 

8 809 6,472 0.25 34 $34.27 $ 1,170 252 $ 

> 9 755 9,354 0.25 32 $34.27 $ 1,092 235 $ 

Total 7,327 36,411 $ 10,600 2,285 $ 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. 

(D) Assume 100% of aircraft performing annual routine coliform monitoring, 100% of aircraft performing twice annual routine coliform monitoring, 50% of aircraft performing quarterly routine coliform monitoring, and 54% of aircraft performing monthly routine colifo

disinfection and flushing after a positive routine total coliform sample. Assume the remainder of aircraft with a TC+ sample will perform repeat sampling. Assume 5.7% of aircraft performing repeat sampling will have at least one additional TC+ sample and will perf

with routine coliform monitoring coliform TC+ samples, assume 0% of the 100% of aircraft performing annual routine coliform monitoring coliform, 0% of the 100% of aircraft performing twice annual routine coliform monitoring, 0% of the 50% of aircraft performing 

aircraft performing monthly routine coliform monitoring will incur costs for corrective action disinfection and flushing. Remainder of aircraft performing corrective action disinfection and flushing assumed to coordinate schedule with routine disinfection and flushing 

for corrective action disinfection and flushing. Assume entire aircraft flushed if either lavatory or galley has a positive total coliform sample. Assume no more than one TC+ per aircraft.

(E) Assumes first flushing/disinfecting is successful. (F) EPA estimate based on observation of flushing and disinfection practices.(G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1.(H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs).(J) Based on EPA estimate.(K), (M) Recordkeeping burden and costs based on total number of corrective action disinfection and flushing events + repeat disinfection and flushing events. Total number of corrective action disinfection and flushing events derived from Exhibit 5.13, column I.

(L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Recordkeeping and Reporting 

Under the final rule, air carriers are required to maintain a maintenance log for corrective 

action disinfection activities. EPA assumes air carriers will require 15 minutes for this 

recordkeeping activity per event per aircraft. 

5.4.6.2 Agency 

Under the final rule, the Agency is not required to assist air carriers with or perform 

corrective action disinfection or flushing. Additionally, air carriers are not required to submit 

their maintenance logs to the Agency. Therefore, the Agency will not incur costs for corrective 

action disinfection and flushing but may include review of theses records during compliance 

audits. 

5.4.6.3 Annualized Costs for Corrective Action Disinfection and Flushing 

Annualized cost estimates for air carriers and the Agency to perform disinfection and 

flushing as corrective action for the final rule are presented in Exhibit 5.19. 

Exhibit 5.19 Air Carrier and Agency Cost Estimates for Corrective Action 

Disinfection and Flushing ($Millions, 2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Corrective Action 

Disinfection and Flushing $ 0.05 -$ $ 0.05 0.05 $ -$ $ 0.05 

Total $ 0.05 -$ $ 0.05 0.05 $ -$ $ 0.05 

5.4.7 Self-Inspection and Compliance Audit 

5.4.7.1 Air Carrier 

Under the final rule, all air carriers subject to the ADWR will undergo compliance audits 

at the Agency’s discretion, which is assumed to be once every five years, beginning in year 3 of 

the 25-year compliance period. Compliance audits will involve a detailed review of each air 

carrier’s aircraft records, including their O&M plan. EPA expects that air carriers will incur a 

recordkeeping and reporting burden while assisting Agency staff with conducting compliance 

audits and in reporting that self-inspections were completed. EPA assumes that each air carrier 

will require 24 hours to satisfy recordkeeping and reporting requirements under the compliance 

audit and self-inspection rule provision (column E, Exhibit 5.20). 

EPA anticipates that the labor burden for self-inspections is already captured under FAA 

requirements and, therefore, is not included in the cost estimate for self-inspections. EPA 

assumes that air carriers already conduct major maintenance checks, which include components 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

of self-inspections, every five years for each aircraft. Therefore, with the exception of reporting 

and recordkeeping burden, no additional costs for self-inspections are incurred by air carriers 

under the ADWR (see Exhibit 5.20). The cost model assumes that 20 percent of the air carrier 

labor cost is incurred each year, beginning in year 3 of the 25-year compliance period. 

Exhibit 5.20 Air Carrier Burden and Cost Estimates for Compliance Audit and 

Self-Inspection

Reporting and Recordkeeping Costs Associated with 

Compliance Audit of Aircraft PWS Totals 

# of Available Sampling Points # of Aircraft 

Total # of 

Available 

Sampling Points 

Unit Labor Cost 

($/hour) 

Unit labor burden 

(hours/air carrier) 

Total Labor Burden 

(hours/audit cycle) 

Total O&M Cost ($/audit 

cycle) 

Total Capital 

Cost ($) 

A B C=B*A D E F G=D*F H 

1 381 381 $42.86 24.0 78.62 $ 3,370 $ -

2 2,080 4,160 $42.86 24.0 429.23 $ 18,396 $ -

3 756 2,268 $42.86 24.0 156.01 $ 6,686 $ -

4 421 1,684 $42.86 24.0 86.88 $ 3,723 $ -

5 956 4,780 $42.86 24.0 197.28 $ 8,455 $ -

6 871 5,226 $42.86 24.0 179.74 $ 7,703 $ -

7 298 2,086 $42.86 24.0 61.50 $ 2,636 $ -

8 809 6,472 $42.86 24.0 166.95 $ 7,155 $ -

> 9 755 9,354 $42.86 24.0 155.80 $ 6,677 $ -

Total 7,327 36,411 1,512 $ 64,801 $ -

Sources: 

(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectors are assumed to have a technical
 

background, as well as some management or oversight responsibility.
 

(E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already conduct major maintenance checks, which include sanitary survey components, every 5 years
 

for each aircraft. Therefore, with the exception of reporting and recordkeeping burden, no additional costs for sanitary surveys are incurred by air carriers under the ADWR.
 

(F), (G) All aircraft undergo compliance audits once in 5 years. The Agency will review electronic data for all aircraft at the air carrier office site. Fractional costs incurred by aircraft (assuming even distribution
 

across aircraft of all sizes) are represented in the exhibt for presentation and calculation purposes only.
 

5.4.7.2 Agency 

Under the final rule, the Agency or designated agents of the Agency will perform 

compliance audits of air carriers. For purposes of this analysis, it is estimated that the Agency 

will conduct compliance audits at least every five years for each air carrier, beginning in year 3 

of the 25-year compliance period. EPA assumes that an Agency will require 16 hours to conduct 

a compliance audit for each air carrier, regardless of fleet size or aircraft type (column B, Exhibit 

5.21). Labor hours for conducting the audit include on-site and Agency recordkeeping efforts. 

The cost model assumes that 20 percent of the Agency labor cost in column E of Exhibit 5.21 is 

incurred each year, beginning in year 3 of the 25-year compliance period. 

Exhibit 5.21 Agency Burden and Cost Estimates for Compliance Audit

Compliance Activity 

Labor Cost 

($/hour) 

Unit Labor Burden 

(hours/air carrier) 

Unit Cost ($/air 

carrier) 

Total Labor Burden 

(hours/audit cycle) 

Total Labor Cost ($/audit 

cycle) 

A B C=A*B D=B*63 E=C*63 

Conducting Compliance Audit of Aircraft PWSs $50.14 16 $ 802 1,008 $ 50,545

Total 16 $ 802 1,008 $ 50,545

Sources: 

(A) Agency labor costs from Section 5.2.1. 

(B) Labor hours for conducting compliance audits reflect EPA estimate.
 

(D), (E) Total burden and O&M costs for conducting compliance audits for 63 U.S. air carriers subject to ADWR. All aircraft undergo compliance audits once in 5 years. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

5.4.7.3 Annualized Costs for Compliance Audit 

Annualized cost estimates for air carriers and the Agency to perform compliance audits 

for the final rule are presented in Exhibit 5.22. 

Exhibit 5.22 Air Carrier and Agency Cost Estimates for Compliance Audit 

($Millions, 2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Compliance Audit $ 0.01 $ 0.01 $ 0.02 $ 0.01 $ 0.01 $ 0.02 

Total $ 0.01 $ 0.01 $ 0.02 $ 0.01 $ 0.01 $ 0.02 

5.5	 Estimated Costs to Air Carrier Passengers 

EPA assumes that air carriers will pass on some or all of the costs of a new regulation to 

their passengers in the form of ticket price increases. EPA estimates that 708.4 million 

passengers travel each year on aircraft that are affected by the ADWR (column E, Exhibit 5.3). 

Exhibit 5.24 in Section 5.7 estimates air carriers’ total annualized cost of the ADWR to be $7.04 

million using a 3 percent discount rate, and $6.95 million using a 7 percent discount rate. The 

cost passed on to passengers can be roughly estimated by dividing the air carriers’ annualized 

costs incurred by the number of passengers traveling each year. Based on this approximation, 

EPA estimates that passengers could face a relatively negligible increase of one cent per ticket. 

5.6	 Non-quantified Costs and Uncertainties in Cost Estimates 

5.6.1	 Non-quantified Costs 

Although EPA has estimated the majority of costs of the final ADWR, there are some 

costs that the Agency was not able to quantify, such as: 

•	 Air carrier costs due to unanticipated flight interruptions from aircraft water 

system corrective action maintenance needs. This includes the direct costs related 

to transporting an aircraft to a maintenance facility for the performance of 

disinfection and flushing corrective action events and any indirect costs of 

schedule disruptions or delays if an aircraft must be unexpectedly taken out of 

service. 

•	 Passenger costs due to flight cancellations or delays related to unanticipated 

aircraft water system maintenance triggered solely by water quality issues. 

•	 Air carrier costs to provide bottled water and any antiseptic hand gels or wipes 

due to lack of onboard tap water during an acute coliform violation. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

•	 Air carrier customer service response to customer concerns following public 

notification that the water onboard an aircraft is not to be used for human 

consumption. 

EPA has attempted to minimize costs by building flexibility into the ADWR, including 

various alternatives from which air carriers select compliance scenarios that best meet their flight 

schedules and other routine aircraft operations and maintenance needs. The final rule also 

includes provisions that minimize situations in which an aircraft is taken out of service solely 

due to drinking water system water quality issues, but which are necessary to protect consumers 

from water of unacceptable quality when the system cannot be physically shut-off or the flow 

through the taps cannot be prevented. 

Exhibit 5.23 presents the number of monitoring and disinfection and flushing events per 

year for all of the alternatives considered during rule development and the final ADWR. EPA 

assumes coliform monitoring and routine disinfection and flushing of the water system would 

not disrupt service because the air carrier would incorporate these tasks into the aircraft 

operations and maintenance program. Only the unanticipated corrective action disinfection and 

flushing events shown in Column E of the exhibit reflect the events that the Agency anticipates 

could result in disruption to air carrier schedules for all regulatory alternatives. Alternative 1 

does not have such events because the current regulations to not specify a corrective action for 

contaminated water systems, although it is anticipated some action is taken by the air carrier to 

correct the problem. 

Exhibit 5.23 Summary of Monitoring and Disinfection and Flushing Events for All 

Alternatives

Rule Alternative 

Monitoring Disinfection and Flushing 

Routing Monitoring 

Coliform Sampling 

Events/year 

Disinfectant Residual 

Monitoring Sampling 

Events/year 

Total number of 

sampling events/year 

Routine Disinfection 

and Flushing 

Events/year 

Corrective Action 

Disinfection and 

Flushing Events/year 

Total number of 

disinfection and 

flushing events/year 

A B C=A+B D E F=D+E 

Alt 1 87,924 87,924 175,848 - - -

Alt 2 7,708 7,708 15,416 29,308 528 29,836 

Alt 3 14,654 - 14,654 29,308 528 29,836 

Alt 4 (Final Rule) 25,436 - 25,436 20,516 395 20,911 

(E) The number of potential unanticipated corrective action disinfection and flushing events is shown for the 

Alternatives, all other disinfection and flushing events, whether based on a routine schedule or in response to 

monitoring results, would occur during scheduled water system operations and maintenance. 

Of the corrective action disinfection and flushing events noted in Column E, an unknown 

percentage will not disrupt service because the aircraft will either prevent public access to the 

water by shutting-off the system or preventing water flow through the taps, thereby obtaining 

more flexibility with the corrective action disinfection and flushing schedule, or will perform the 

action within the maximum time frame specified by the rule. In addition, of the alternatives that 

would require disinfection and flushing, Alternative 4 (the final rule) has the least number of 

estimated unanticipated disruption events (an estimated maximum of 395 corrective action 

disinfection and flushing events/year). 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

 EPA does not have sufficient data to quantify the disruption to air carriers; however, 

EPA believes that the disruption cost per event would be lower for the final rule compared to 

Alternatives 1-3 due to the significant flexibility offered to air carriers in choosing monitoring 

frequencies under the final rule. EPA assumes that the increased flexibility of the final rule will 

allow air carriers to schedule routine monitoring and disinfection and flushing to coincide with 

existing routine maintenance checks. This will in turn decrease potential disruption to air carrier 

flight schedules and thus decrease air carrier burden and cost for complying with ADWR 

monitoring and disinfection and flushing requirements. Therefore, if disruption costs were 

included in the quantified costs of the rule, the costs for the final rule would likely decrease with 

respect to other alternatives. 

5.6.2	 Uncertainties in Cost Estimates 

Many factors contribute to uncertainty in the national cost estimates including: 

•	 Percent of aircraft that will be subject to each total coliform monitoring option. 

•	 Expected results from total coliform monitoring. 

•	 Estimated time for air carrier management to read, understand, and decide how to 

best comply with the ADWR; and to develop a training program, train staff, and 

oversee compliance. 

•	 Percent of aircraft that will collect routine total coliform samples while aircraft are 

out of service for routine maintenance. 

•	 Labor burden necessary for self-inspections above what is necessary for FAArelated inspections. 

•	 Labor burden and costs associated with correcting significant deficiencies that are 

identified during self-inspections above what is necessary for FAA-related 

inspections. 

For simplicity, EPA assumed for this analysis that all air carriers subject to the final rule 

will spend equal management time on ADWR requirements, regardless of fleet size or aircraft 

type. Assuming equal burden for all air carriers to comply with these rule management and 

oversight requirements could result in an over- or under-estimate of the costs presented. 

Regarding the expected results for coliform monitoring, EPA assumed that during routine 

coliform monitoring, each total coliform-positive sample would prompt an action by the air 

carrier. This assumption potentially over-estimates the number of aircraft that need to undergo 

disinfection and flushing as corrective action or repeat monitoring in cases where more than one 

routine sample is total coliform-positive in a given monitoring period. For example, an aircraft 

with positive samples from both routine sampling points is treated as two corrective actions or 

repeat sample collection events in the cost model when only one disinfection and flushing event 

would be necessary in such a case. Also, the number of sample results that prompt corrective 

action or repeat sampling may decrease over time as air carriers correct problems that lead to 

total coliform-positive samples. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

In developing costs for air carriers to comply with the self-inspection requirements, EPA 

assumed that with the exception of reporting and record-keeping burden, no additional costs for 

self-inspections are incurred by air carriers. Labor burden for self-inspections, which involves a 

thorough review and inspection of an aircraft water system as well as addressing any 

deficiencies, is already captured under current FAA requirements and therefore is not included in 

the cost estimate for this rule. Additionally, EPA has assumed that deficiencies noted during 

self-inspections will be addressed during routine maintenance, and so has not accounted for costs 

associated with corrective actions stemming from deficiencies noted during self-inspections. 

This assumption potentially under-estimates air carrier burden for self-inspections. 

5.7	 Total Annualized Implementation and Incremental Costs for the Final 

ADWR 

Exhibit 5.24 presents the itemized and total annualized implementation costs to air 

carriers and the Agency for the final ADWR at 3 and 7 percent discount rates. Note that portions 

of Exhibit 5.24 have been presented in sections throughout this chapter, but are being repeated 

here for convenience. 

Exhibit 5.24 Total Annualized Present Value Implementation Costs for the Final 

ADWR ($Millions, 2008$)

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Implementation $ 0.002 $ 0.01 $ 0.01 $ 0.004 $ 0.01 $ 0.02 

Annual Administration $ - $ 0.24 $ 0.24 $ - $ 0.23 $ 0.23 

Sampling Plan $ 0.002 $ 0.001 $ 0.002 0.002 $ $ 0.001 $ 0.003 

O&M Plan $ 0.01 $ 0.0001 $ 0.01 $ 0.02 $ 0.0001 $ 0.02 

Coliform Monitoring $ 4.89 $ 0.04 $ 4.93 $ 4.82 $ 0.04 $ 4.86 

Routine Disinfection and 

Flushing $ 2.08 $ - $ 2.08 $ 2.05 $ - $ 2.05 

Corrective Action 

Disinfection and Flushing $ 0.05 $ - $ 0.05 $ 0.05 $ - $ 0.05 

Compliance Audit $ 0.01 $ 0.01 $ 0.02 $ 0.01 $ 0.01 $ 0.02 

Total $ 7.04 $ 0.30 $ 7.34 $ 6.95 $ 0.30 $ 7.25 

Exhibit 5.25 presents the annualized incremental costs for the final rule at 3 and 7 percent 

discount rates. The incremental costs represent the difference in total costs between the baseline 

(i.e., the existing NPDWRs) and the final rule provisions. EPA notes that the cost of the 

proposed ADWR was significantly less than the current regulatory requirements of the 

NPDWRs. The current NPDWR requirements, considered to be the baseline against which to 

compare the set of regulatory requirements of the final ADWR, would continue to apply to the 

aircraft water system industry if the requirements of the ADWR were not promulgated. The 

reduction in cost (i.e., the incremental savings of the ADWR compared to the regulatory 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

baseline) is the result of tailoring the current regulations for transient non-community public 

water systems to the specific operational characteristics of aircraft drinking water systems. 

EPA estimates that the total annualized incremental savings of this ADWR is $22.15 

million at a 3 percent discount rate and $21.83 million at a 7 percent discount rate, as presented 

in Exhibit 5.25. The incremental savings represent the difference in total annualized 

implementation costs between the baseline (i.e., the existing NPDWRs) and the final rule 

provisions. 

Exhibit 5.25 Total Annualized Incremental Cost: Existing NPDWRs and the ADWR 

($Millions, 2008$)

 Alt 1 

(Existing 

NPDWRs) 

Alt 4 

(Final Rule) 

Incremental 

Cost 

(Alt 4 - Alt 1) 

Alt 1 

(Existing 

NPDWRs) 

Alt 4 

(Final Rule) 

Incremental 

Cost 

(Alt 4 - Alt 1) 

3% 7% 

Implementation 0.01 0.01 0 0.02 0.02 0 

Annual Administration 0.24 0.24 0 0.23 0.23 0 

Monitoring Plan 0.002 0.002 0 0.004 0.003 (0.001) 

O&M Plan - 0.01 0.01 - 0.02 0.02 

Coliform Monitoring 25.37 4.93 (20.44) 25.02 4.86 (20.16) 

Disinfectant Residual 

Monitoring 3.17 - (3.17) 3.13 - (3.13) 

Routine Disinfection and 

Flushing - 2.08 2.08 - 2.05 2.05 

Corrective Action 

Disinfection and Flushing - 0.05 0.05 - 0.05 0.05 

Sanitary 

Survey/Compliance Audit 0.7 0.02 (0.68) 0.69 0.02 (0.67) 

Turbidity Monitoring - - - - - -

Total $29.49 $7.34 $(22.15) $29.08 $7.25 $(21.83) 

The regulatory baseline does not reflect the AOCs, which are interim enforcement actions 

applying to 45 air carriers. As discussed earlier in this document, in 2004, EPA found all aircraft 

that were public water systems to be out of compliance with the NPDWRs. EPA subsequently 

placed 45 air carriers under Administrative Orders on Consent (AOCs) that will remain in effect 

until the tailored aircraft drinking water regulations are final. The air carrier AOCs combine 

sampling, best management practices, corrective action, public notification, and reporting and 

recordkeeping to ensure public health protection. With respect to sampling under the AOCs, air 

carriers with greater than 20 aircraft were required to sample 25 percent of their fleet quarterly, 

while air carriers with 20 or fewer aircraft were required to sample the entire fleet quarterly. 

Because the majority of the air carriers are currently subject to the requirements of the AOCs, 

EPA notes that if the AOCs were considered to be an alternative baseline, the incremental cost of 

the final ADWR would be $0.18 million at the 3 percent discount rate and $0.18 million at the 7 

percent discount rate, Exhibit 5.26. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.26 Total Annualized Incremental Cost: Requirements Similar to AOCs 

and the ADWR ($Millions, 2008$)

Alt 2 

(AOCs) 

Alt 4 

(Final Rule) 

Incremental 

Cost 

(Alt 4-Alt 2) 

Alt 2 

(AOCs) 

Alt 4 

(Final Rule) 

Incremental 

Cost 

(Alt 4-Alt 2) 

3% 7% 

Implementation 0.01 0.01 0 0.02 0.02 0 

Annual Administration 0.24 0.24 0 0.23 0.23 0 

Monitoring Plan 0.002 0.002 0 0.004 0.003 (0.001) 

O&M Plan - 0.01 0.01 - 0.02 0.02 

Coliform Monitoring 1.67 4.93 3.26 1.65 4.86 3.21 

Disinfectant Residual 

Monitoring 0.67 - (0.67) 0.66 - (0.66) 

Routine Disinfection and 

Flushing 4.52 2.08 (2.44) 4.46 2.05 (2.41) 

Corrective Action 

Disinfection and Flushing 0.05 0.05 0 0.05 0.05 0 

Sanitary 

Survey/Compliance Audit - 0.02 0.02 - 0.02 0.02 

Turbidity Monitoring - - - - - -

Total 7.16 7.34 0.18 7.07 7.25 0.18 

5.8 Comparison of Regulatory Alternatives 

5.8.1 Comparison to the final ADWR 

Exhibit 5.27 provides a summary of the annualized present value costs for implementing 

each regulatory alternative considered during the regulatory development process at 3 and 7 

percent discount rates. EPA used the same process for developing cost estimates for all 

regulatory alternatives. Unit costs were multiplied by the number of air carriers or aircraft 

performing various components of each alternative, and results were summed for all 

components. 

The $7.3 million implementation cost for the final rule (which includes both the costs to 

air carriers and EPA) lies between the least costly and most costly alternatives. The cost of the 

final rule is approximately one-fourth of the costs incurred by air carriers and the Agency under 

the baseline. As a result of tailoring NPDWRs to the specific operational characteristics of 

aircraft drinking water systems, the costs for the final rule are slightly higher than those under 

Alternative 2 – requirements similar to the AOCs; however EPA made several assumptions 

about the frequency of disinfection and flushing and monitoring in order to estimate the 

implementation costs. If all of the air carriers followed the quarterly disinfection and flushing 

frequency, as was required under the AOCs, the difference between the two alternatives would 

be negligible. 

 EPA believes the increased flexibility of the final rule will reduce non-quantified costs 

to the air carriers such as for unanticipated disinfection and flushing events, and will provide the 

maximum protection with the least disruption to air carriers, thus making it the least costly 

alternative. 

Page 5-28 
 

 

 

 

 

 

 

 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 5.27 Comparison of Total Annualized Present Value Implementation 

Costs by Regulatory Alternative ($Millions, 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 (Final Rule) Alt 1 Alt 2 Alt 3 Alt 4 (Final Rule) 

3% 7% 

Implementation 0.01 0.01 0.01 0.01 0.02 0.02 0.02 0.02 

Annual Administration 0.24 0.24 0.24 0.24 0.23 0.23 0.23 0.23 

Monitoring Plan 0.002 0.002 0.001 0.002 0.004 0.004 0.002 0.003 

O&M Plan - - 0.01 0.01 - - 0.01 0.02 

Coliform Monitoring 25.37 1.67 2.23 4.93 25.02 1.65 2.20 4.86 

Disinfectant Residual 

Monitoring 3.17 0.67 - - 3.13 0.66 - -

Routine Disinfection and 

Flushing - 4.52 2.97 2.08 - 4.46 2.93 2.05 

Corrective Action Disinfection 

and Flushing - 0.05 0.05 0.05 - 0.05 0.05 0.05 

Sanitary Survey/Compliance 

Audit 0.70 - - 0.02 0.69 - - 0.02 

Turbidity Monitoring - - 12.92 - - - 12.74 -

Total 29.49 7.16 18.43 7.34 29.08 7.07 18.19 7.25 

5.8.2 Comparison of the proposed ADWR and final ADWR 

As discussed in Chapter 2 of this document, a collaborative rule development process 

was used for the proposed ADWR. This process provided an opportunity for stakeholders to 

inform the Agency about existing operations and maintenance practices for aircraft water 

systems and to convey concerns regarding existing regulations applicable to aircraft water 

systems, public health issues, fleet operations issues that are unique to the air carrier industry, 

and potential rule alternatives. Public comment was received on the proposed rule, and 

modifications have been incorporated into the final ADWR. This document presents a discussion 

of the final ADWR with comparison to the three alternatives considered when developing the 

ADWR. Some of the modifications to the proposed rule that are incorporated into the final rule 

affected the estimated cost of the regulation; other changes had no net effect on cost but may 

have affected non-quantified costs. This section provides a discussion of the cost of the elements 

of the final ADWR compared to the proposed rule, and summarizes the assumptions that have 

been incorporated into the cost estimates. 

The total annualized present value costs at 3 percent and 7 percent discount rates for the 

rule provisions are shown in Exhibit 5.28 for the proposed and final rules. The costs reported for 

the final rule are from Exhibit 5.24; the costs for the proposed rule include adjustments for the 

general cost assumptions and methodology described in Section 5.2, with all costs adjusted to 

2008 dollars. 

As noted in Section 5.2.1, the labor rate for the technical labor category used for air 

carrier cost estimates decreased from that used for cost estimates for the proposed rule – this 

affected all cost estimates that apply a labor rate for air carrier technical staff. Because this 

decreased labor rate has been incorporated into the cost estimates for all of the alternatives and 

the final ADWR, as well as the proposed rule costs presented in Exhibit 5.28, it does not affect 

the comparison of the rule options and final rule. It is notable, however, to explain the 

approximately $25,000 decreased cost estimate presented for the proposed rule in this document 

Page 5-29 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

compared to the Economic and Supporting Analysis Document for the Proposed ADWR 

(USEPA, 2008a). 

The final ADWR includes an extension of the compliance dates to 18 months after rule 

promulgation for the coliform sampling plan, operations and maintenance plans, and the aircraft 

inventory; the proposed rule specified a six-month timeframe for these requirements. In 

addition, the final rule adjusts the timeframe for beginning to conduct sampling and other 

compliance requirements to 24 months after final rule promulgation from 12 months specified in 

the proposed rule. These delays in compliance dates have a slight effect on the timing of the 

costs represented by the 25-year compliance period captured by these estimates. 

The discussion below summarizes the other changes made for the final ADWR and the 

Agency’s assumptions that affected the cost of those changes. Some of the final rule provisions 

and cost estimate parameters affected all, or nearly all, aspects of the cost estimates for the 

regulation. 

Exhibit 5.28 Comparison of Proposed and Final ADWR Total Annualized Present 

Value Costs ($Millions, 2008$)

Proposed 

ADWR * 

Final 

ADWR 

Proposed 

ADWR * 

Final 

ADWR 

3% 7% 

Implementation 0.01 0.01 0.01 0.02 

Annual Administration 0.25 0.24 0.25 0.23 

Monitoring Plan 0.002 0.002 0.004 0.003 

O&M Plan 0.01 0.01 0.02 0.02 

Coliform Monitoring 5.50 4.93 5.57 4.86 

Routine Disinfection and Flushing 2.21 2.08 2.23 2.05 

Corrective Action Disinfection and Flushing 0.13 0.05 0.13 0.05 

Compliance Audit 0.02 0.02 0.02 0.02 

Total 8.13 7.34 8.24 7.25 

* For the proposal, the total annualized present value cost at a 3% discount rate is less than at a 7% discount rate by 

a small amount. Changes in the implementation schedule (later implementation) for the final rule result in a larger 

calculated difference in present value costs, which results in total annualized present value costs slightly greater at a 

3% discount rate than at a 7% rate. 

Implementation 

This category addresses air carrier one-time costs for reading and understanding the rule, 

becoming familiar with its provisions, and training employees on the rule. Based on public 

comment that air carriers would typically have more than one person responsible for this task, 

the final ADWR provides a burden allowance for each air carrier to read and understand the rule 

of 8 hours per carrier, increased from 2 hours per carrier in the proposed rule. The Agency 

assumes, on average, each air carrier will have four staff persons who will need to read and 

understand the rule at 2 hours estimated burden for each person. The 8 hours per air carrier for 

staff training is unchanged from the proposed rule. 

Page 5-30 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

The Agency burden estimates for implementation include reading and understanding the 

rule, program development, modifying existing database systems, and providing air carrier 

training and technical assistance and staff training. The estimate of Agency hourly burden for 

each item is unchanged from the proposed rule. 

Annual Administration 

The Annual Administration category addresses the Agency’s rule implementation and 

enforcement activities that must occur on an ongoing basis; air carriers do not have costs in this 

category. Implementation activity estimates include ongoing technical assistance to air carriers 

and staff training events. The assumptions for this category are unchanged from the proposed 

rule. 

Monitoring Plan 

The air carrier coliform monitoring plan will include the selected monitoring frequency 

and the respective routine disinfection and flushing frequency. The estimated burden 

assumptions applied to the final rule are unchanged from the proposed rule, including the 

assumption that air carriers will prepare one plan to address the entire aircraft fleet. 

Operations and Maintenance Plan 

All air carriers subject to the ADWR will need to develop or update existing O&M plans 

and practices with ADWR-specific requirements and submit a statement to the Agency that the 

plan is completed. The air carrier operations and maintenance plans are reviewed by the Agency 

during compliance audits; Agency review of the statement submitted by the air carrier is 

captured in this category. No estimated burden assumptions or requirements have changed that 

affect this estimate. 

Coliform Monitoring 

The coliform monitoring category includes cost estimates for routine sampling and repeat 

sampling; follow-up coliform monitoring is captured under corrective action disinfection and 

flushing estimates. Each aircraft routine coliform monitoring schedule is determined by the 

routine disinfection and flushing frequency that should be based on manufacturer’s 

recommendations. Several provisions in the final rule and their related assumptions affect the 

estimated cost for this category. Those provisions include addition of a fourth routine 

disinfection and flushing/coliform monitoring frequency option, reduction of the number of 

repeat samples to three in the final rule from four in the proposed rule, and allowing repeat 

sampling if more than one routine sample is total coliform-positive but E. coli-negative. The 

proposed rule limited the option of repeat sampling to situations when more than one routine 

sample was total coliform-positive. Assumptions pertaining to the amount of time it would take 

to implement each of the items, such as collecting a water sample or Agency oversight, are 

unchanged from the proposed rule. 

The assumptions of the percentage of aircraft that would select each of the monitoring 

frequency options have been adjusted to incorporate the fourth option that is included in the final 

Page 5-31 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

rule. For the final rule, the Agency assumed 10 percent of the aircraft would select monthly 

monitoring with routine disinfection and flushing one time per year or less; 30 percent would 

select monitoring quarterly with routine disinfection and flushing twice per year; 30 percent 

would select monitoring twice per year with routine disinfection and flushing three times per 

year; and 30 percent would select annual monitoring with routine disinfection and flushing on a 

quarterly basis. The proposed rule assumed 10 percent of the aircraft would monitor monthly, 45 

percent quarterly, and 45 percent annually. 

The final ADWR utilized the coliform monitoring findings of the AOCs analyzed as of 

December 31, 2008, in the estimates of the percentage of routine and repeat samples that will be 

total coliform-positive and E. coli-positive. A discussion of the AOCs’ data is found in Chapter 

3 of this document. For the final rule, a routine sample total coliform-positive rate of 3.6 percent 

and a repeat sample total coliform-positive rate of 5.7 percent are assumed based on the AOCs 

results for data collected under EPA-approved air carrier QAPPs and CRMPs. The proposed 

rule applied a routine sample rate of 3.1 percent based on data available at the time, and a repeat 

sample rate of 50 percent. 

The final ADWR estimates assume that whenever possible, an aircraft will perform 

routine coliform monitoring immediately prior to initiating routine disinfection and flushing 

procedures while the aircraft is out of service for the later. In such a case, if a routine coliform 

sample is total-coliform positive, the Agency assumes the air carrier will perform disinfection 

and flushing procedures and collect follow-up samples as a response to the sample results instead 

of opting for repeat sampling. As described below, the Agency assumes the disinfection and 

flushing event would count toward routine requirements and corrective action requirements as 

long as follow-up samples are collected. For example, an aircraft on quarterly routine 

disinfection and flushing is assumed to collect the required annual coliform sample during one of 

the periods the aircraft is out of service for the quarterly event. Of the routine coliform sample 

results that are assumed to occur when routine disinfection and flushing is not immediately 

available, the cost estimates assume 50 percent of the aircraft will perform repeat sampling in 

lieu of unscheduled disinfection and flushing with follow-up sampling. This assumption of the 

percentage of repeat sampling affects both the repeat sample and follow-up sample cost 

estimates; although the follow-up sample costs are included in the corrective action disinfection 

and flushing category (see Section 5.4.4.1 for details on these assumptions). 

Routine Disinfection and Flushing 

The addition of the fourth option for routine disinfection and flushing frequencies in the 

final rule adjusted the assumptions for the percentage of aircraft that would select each option. 

The new twice-yearly routine disinfection and flushing frequency was assigned to 30 percent of 

the aircraft, which decreased the number of aircraft assumed to select either thrice-annually or 

semi-annually disinfection and flushing from 45 percent under the proposed rule options. 

Corrective Action Disinfection and Flushing 

As described for coliform monitoring, assumptions pertaining to the number of corrective 

action disinfection and flushing events that would be incurred were recalculated based on 

whether the aircraft was anticipated to already be scheduled for immediate disinfection and 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

flushing. The Agency assumed, based on comments received during the public comment period 

for the proposed rule, that air carriers would seek to minimize the number of times unanticipated 

disinfection and flushing events would occur and would take advantage of the ability to perform 

this action as part of the routine disinfection and flushing activities. Also, the estimated 

reduction in the repeat sample coliform-positive rate to 5.7 percent in the final rule affected the 

anticipated costs for this category because fewer events were expected to be triggered by repeat 

sample results. 

Compliance Audit and Self-Inspections 

The final ADWR does not incorporate any changes regarding air carrier or Agency 

responsibilities or schedules for the self-inspection and compliance audit provisions over the 

proposed rule. 

5.9 Comparison of Costs and Benefits 

The qualitative analyses suggest that benefits are greater under the final rule than under 

the baseline requirements represented by Alternative 1. The final rule will likely deliver a level 

of desired benefits at a cost that is acceptable to the air carrier industry, which increases the 

likelihood that real benefits will accrue. Additionally, the final rule represents an approach that 

accomplishes the goals of the traditional drinking water rules, but is specifically tailored to this 

unique industry and setting. As a result, the final rule is expected to have a substantially lower 

cost than a less-tailored approach – only about one-fourth the cost of the Alternative 1 (the 

baseline). 

EPA is limited by the purpose, quality, and quantity of data available in developing 

meaningful benefits analyses. In the absence of additional statistical analyses, only general 

observations of the data can be made, and only with adequate qualifiers. Any comparison of risk 

between the alternatives considered for the final rule requires robust data that would support: 1) 

direct comparisons of the overall baseline conditions with the overall conditions under each of 

the alternatives, or 2) comparisons of specific regulatory components (i.e., disinfection and 

flushing frequencies) that could be used to compare the baseline and all alternatives. See 

Chapter 3 for a more detailed description of baseline data. 

5.10 Other Economic Measures 

The lack of a quantitative risk assessment prevents the use of other economic measures, 

specifically, a break-even analysis and measure of cost-effectiveness based on the value of 

changes in health conditions. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

6. Statutory and Administrative Requirements 

6. 1 Introduction 

As part of the rulemaking process, EPA is required to address the direct and indirect 

burdens that the ADWR may place on certain types of businesses and populations. This chapter 

presents the analyses performed by EPA in accordance with the following 12 Federal mandates: 

1)	 Executive Order 12866: Regulatory Planning and Review 

2)	 The Regulatory Flexibility Act 

3)	 Analysis of small air carrier affordability to determine variance technologies in 

accordance with Section 1415(e)(1) of the 1996 SDWA Amendments 

4)	 Feasible technologies available to all air carriers as required by Section 

1412(b)(4)(E) of the 1996 SDWA Amendments 

5)	 Technical, financial, and managerial capacity assessment as required by Section 

1420(d)(3) of the 1996 Amendments to SDWA 

6)	 Paperwork Reduction Act (a separate Information Collection Request document 

contains the complete analysis) 

7)	 Unfunded Mandates Reform Act of 1995 

8)	 Impacts on sensitive subpopulations as required by Section 1412(b)(3)(c)(i) of the 

1996 SDWA Amendments 

9)	 Executive Order 13045 (Protection of Children from Environmental Health Risks 

and Safety Risks) 

10)	 Executive Order 12898 (Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations). 

11)	 Executive Order 13132 (Federalism). 

12)	 Executive Order 13211 (Actions Concerning Regulations That Significantly 

Affect Energy Supply, Distribution, or Use) 

Many of the requirements and executive orders listed above call for an explanation of 

why the rule is necessary, the statutory authority for the rule, and the primary objectives that the 

rule is intended to achieve (refer to Chapter 1 for more information regarding the objectives of 

the rule). More specifically, they are designed to assess the financial and health effects of the 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

rule on small air carriers and examine how much additional capacity air carriers will need to 

meet ADWR requirements. 

6. 2 Executive Order 12866: Regulatory Planning and Review 

Under Executive Order 12866, [58 Federal Register 51735; October 4, 1993] this action 

is a “significant regulatory action” because it raises novel legal or policy issues. Accordingly, 

EPA submitted this action to OMB for review under Executive Order 12866 and any changes 

made in response to OMB recommendations have been documented in the docket for this action. 

This document represents an analysis of potential costs and benefits associated with this 

action. An economic rationale for the rule is required by Executive Order 12866, which states: 

“[E]ach agency shall identify the problem that it intends to address (including, where 

applicable, the failures of the private markets or public institutions that warrant new 

agency action) as well as assess the significance of that problem.” (Section 1, b(1)) 

Federal regulation of aircraft drinking water systems is necessary as a result of the 

information gap that exists with regard to the safety or quality of the drinking water. Because of 

limited monitoring, there is a lack of information on the potential risks associated with drinking 

and using the water onboard aircraft. As a result, aircraft passengers do not receive sufficient 

information on drinking water quality to make informed decisions about drinking water on 

aircraft. Federal intervention can be used to close this gap. 

6. 3 Regulatory Flexibility Act 

The RFA generally requires an agency to prepare a regulatory flexibility analysis for any 

rule subject to public notice and comment requirements under the Administrative Procedure Act 

or other statute, unless the Agency certifies that the rule will not have a significant economic 

impact on a substantial number of small entities (5 United States Code (U.S.C.) 603(a)). Small 

entities include small businesses, small organizations, and small governmental jurisdictions. The 

RFA provides the following default definitions for each type of small entity: (1) a small business 

as defined by the Small Business Administration’s (SBA) regulations at 13 CFR 121.201; (2) a 

small governmental jurisdiction that is a government of a city, county, town, school district, or 

special district with a population of less than 50,000; and (3) a small organization that is any 

“not-for-profit enterprise that is independently owned and operated and is not dominant in the 

field.” 

U.S. aircraft subject to the final ADWR may be owned and operated by businesses. 

Therefore, the screening analysis for the ADWR uses the following definition for small entities: 

A “small business” is any firm that is independently owned and operated and is not dominant in 

its field of operation (Small Business Act, 15 U.S.C. 632). The SBA definitions of small 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

businesses use categories are defined by National American Industry Classification System 

(NAICS) codes. EPA has determined that the following businesses would be affected by the 

ADWR based on the NAICS: 

• 481111 – Scheduled passenger air transportation 

• 481211 – Nonscheduled chartered passenger air transportation 

SBA defines a small business for air carriers (NAICS codes 481111 and 481211) as having 

fewer than 1,500 employees (13 CFR 121.201). EPA used this SBA standard definition as an 

alternative to the definition EPA has used for small stationary PWSs (“a PWS that serves 10,000 

of fewer people”). This is because the air carrier is the business entity rather than the individual 

aircraft water system. The Agency requested but did not receive comments on the use of this 

alternative definition of small entity. 

EPA conducted a screening analysis to determine if the ADWR would have a significant 

economic impact on a substantial number of small entities. Chapter 3 of this document provides 

data on air carriers potentially subject to the ADWR, and Chapter 5 discusses actions that air 

carriers would need to take to comply with the rule and their associated costs. Using information 

from these two chapters, along with additional information from Dun & Bradstreet (D&B) 

reports, EPA conducted a quantitative analysis of small entity impacts resulting from the rule. 

Based on EPA’s screening level analysis of small entities presented in Appendix D, EPA 

has estimated that 30 of the 63 air carriers subject to this final rule are small businesses. These 

30 air carriers represent 48 percent of the universe of air carriers subject to the final rule, and all 

will be subject to the various provisions. Therefore, EPA has determined that a substantial 

number of small entities will be impacted by this rule. 

In evaluating whether this rule will have a significant impact on these small entities, EPA 

first determined the present value costs of the rule for these air carriers. EPA followed the same 

methodology as was used to develop the average annualized costs for the rule overall. EPA 

estimates a total annual implementation cost for all small air carriers of $524,380 at a 3 percent 

discount rate and $521,110 at a 7 percent discount rate. EPA also determined the average annual 

rule cost per small air carrier of $17,543 (annualized at 3 percent). 

EPA estimates the average annual incremental rule cost for small entities (the difference 

between the final rule and the existing NPDWRs (presented as Alternative 1)) is a reduction of 

$258,599 at a 3 percent discount rate for compliance with the ADWR. Because the majority of 

the air carriers are currently subject to the requirements of the AOCs, EPA notes that if the 

AOCs were considered to be an alternative baseline, the incremental average annual rule cost 

between the final rule and requirements similar to those of the AOCs, (presented as Alternative 

2) is a reduction of $32,188 (i.e., cost savings). 

Recognizing the variation of company sizes within this group, EPA has estimated the 

average annual incremental cost for small air carriers with fewer than 500 employees and for 

small air carriers with 500 or more employees. For the 17 air carriers with fewer than 500 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

employees, the annual incremental cost between the ADWR and Alternative 1 for each air carrier 

is a reduction of $78,042 at a 3 percent discount rate, and the annual incremental average rule 

cost between the ADWR and Alternative 2 is a reduction of $7,781 at a 3 percent discount rate. 

For the 13 small air carriers with 500 or more employees, the incremental cost between the 

ADWR and Alternative 1 for each air carrier is a reduction of $230,712 at a 3 percent discount 

rate, and the incremental average rule cost between the ADWR and Alternative 2 is a reduction 

of $20,104 at a 3 percent discount rate. 

The final rule has been shown to offer a cost reduction over the existing regulations (i.e., 

baseline), and so the annualized incremental costs are negative. Therefore, EPA has not 

compared the average annual incremental costs to small entities against the average annual 

revenue of the small entities as is normally done for this analysis. 

Based on this analysis, EPA certifies that the final ADWR will not have a significant 

impact on a substantial number of small entities; therefore, the Agency did not develop an Initial 

Regulatory Flexibility Analysis for the rule. 

6. 4	 Small-Air Carrier Affordability 

Section 1415(e)(1) of SDWA does not apply to the final ADWR since small air carriers 

are not required to install compliance technologies and, therefore, primacy agencies do not need 

to grant variances to small air carriers in lieu of complying with an MCL. 

6. 5	 Feasible Treatment Technologies for All Air Carriers 

Section 1412(b)(4)(E) of the 1996 SDWA Amendments requires that feasible 

technologies and treatment techniques are available for entities to comply with a NPDWR. The 

only treatment technique required under the ADWR is disinfection and flushing of aircraft water 

systems. Because this process is simple, affordable, and well within the existing technical 

capabilities of aircraft maintenance technicians it is considered a feasible treatment technique for 

all aircraft. 

6. 6	 Effect of Compliance with the ADWR on the Technical, Managerial, and 

Financial Capacity of Air Carriers 

Section 1420(d)(3) of SDWA, as amended, requires that, in promulgating a NPDWR, the 

Administrator shall include an analysis of the likely effect of compliance with the regulation on 

the technical, managerial, and financial (TMF) capacity of regulated entities. The following 

analysis fulfills this statutory obligation by identifying the incremental impact that the ADWR 

will have on the TMF of regulated air carriers. Analyses presented in this document reflect only 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

the impact of new or revised requirements, as established by the ADWR; the impacts of 

previously established requirements are not considered. 

Overall capacity is defined in Guidance on Implementing the Capacity Development 

Provisions of the Safe Drinking Water Act Amendments of 1996 (USEPA, 1998) as the ability to 

plan for, achieve, and maintain compliance with applicable drinking water standards. Capacity 

encompasses three components: technical, managerial, and financial. Technical capacity is the 

operational ability of an air carrier to meet SDWA requirements. Key issues of technical 

capacity include: 

•	 Source water adequacy—Do air carriers have a reliable source of water with 

adequate quantity? Is the source generally of good quality and adequately 

protected? 

•	 Infrastructure adequacy—Can the air carrier provide water that meets SDWA 

standards? What is the condition of its infrastructure, including water fill ports, 

storage tanks, and pipes? Does the air carrier have an improvement plan? 

•	 Technical knowledge and implementation—Do the personnel conducting 

monitoring and disinfection have sufficient knowledge of applicable standards? 

Can the personnel effectively implement this technical knowledge? Do the 

personnel understand the air carrier’s technical and operational characteristics? 

Does the air carrier have an effective O&M program? 

Managerial capacity is the ability of an air carrier’s managers to make financial, 

operating, and staffing decisions that enable the air carrier to achieve and maintain compliance 

with SDWA requirements. Key issues include: 

•	 Ownership accountability—Are the owners clearly identified? Can they be held 

accountable for the air carrier? 

•	 Staffing and organization—Are the operators and managers clearly identified? Is 

the air carrier properly organized and staffed? Do personnel understand the 

management aspects of regulatory requirements and air carrier operations? Do 

they have adequate expertise to manage air carrier drinking water operations (i.e., 

to disinfect and flush aircraft and monitor for total coliform to meet the ADWR 

requirements)? Do personnel have the necessary certifications and training? 

•	 Effective external linkages—Does the air carrier interact well with customers, 

regulators, and other entities? 

Financial capacity is an air carrier’s ability to acquire and manage sufficient financial resources 

to allow the air carrier to achieve and maintain compliance with SDWA requirements. Key 

issues include: 

•	 Revenue sufficiency – Do revenues cover costs? 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

•	 Creditworthiness – Is the air carrier financially healthy? Does it have access to 

capital? 

•	 Fiscal management and controls – Are adequate books and records maintained? 

Are appropriate budgeting, accounting, and financial planning methods used? 

Does the air carrier manage its revenues effectively? 

6.6.1	 Requirements of the Final ADWR 

This capacity analysis is presented only for the final rule, although EPA took similar 

considerations into account in the selection of the proposed rule option over the other 

alternatives. This process led to the incorporation of more flexibility to enable air carriers to 

better coordinate rule activities with existing O&M activities. 

The final ADWR establishes five requirements that may affect the TMF capacity of 

affected air carriers: 

1. Developing the aircraft water system O&M manual 

2. Developing a coliform sampling plan 

3. Monitoring for total coliform 

4. Disinfection and flushing of aircraft 

5. Taking corrective action for total coliform-positive samples 

In addition, personnel from air carriers regulated under the ADWR will need to familiarize 

themselves with the rule and its requirements. Air carriers must also perform recordkeeping and 

reporting activities related to monitoring, disinfection and flushing, public notification, 

inventory, and self-inspections. Where applicable, the impacts of recordkeeping and reporting 

are considered as a part of the individual rule components. 

6.6.2	 Air Carriers Subject to the Final ADWR 

The ADWR will apply to all aircraft that serve water to an average of 25 or more people daily for 

at least 60 days per year. EPA estimates that the ADWR may affect 7,327 aircraft (see Exhibit 6.5). 

While most will not, some air carriers may require increased TMF capacity to comply with the new 

requirements for their aircraft, or will need to tailor their compliance approaches to match their capacities. 

Refer to section 6.6.4 for a detailed discussion of changes in TMF capacity. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

6.6.3 Impact of the ADWR on Air Carrier Capacity 

The estimates presented in Exhibit 6.1 reflect the anticipated impact of the final ADWR 

on air carrier capacity based on the expected measures that air carriers will be required to adopt. 

The extent of the expected impact of a particular requirement on air carrier capacity is estimated 

using a scale of 0-5, where 0 represents a requirement that is not expected to have any impact, 1 

represents a requirement that is expected to have a minimal impact, and 5 represents a 

requirement that is expected to have a very significant impact on air carrier capacity. Criteria 

used to develop the scores and associated impacts are discussed further in section 6.6.4. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit 6.1 Estimated Impacts of the ADWR on Air Carriers’ Technical, Managerial, and Fina

(0 = no impact, 1 = minimal impact, and 5 = very significant impact)

Requirement 

Number and 

Percent of Air 

Carriers 

Technical Capacity Managerial Capacity Financia

Source Water 

Adequacy

Infrastructure

Adequacy

Technical 

Knowledge & 

Implementation

Ownership 

Accountability

Staffing &

Organization

Effective External

Linkages

Revenue 

Sufficiency

Familiarization with requirements of the rule 63 (100%) 0 0 1 1 1 1 1 

Updating O&M plan 63 (100%) 0 0 1 1 1 1 1 

Developing a sampling plan 63 (100%) 0 0 1 1 1 1 0 

Monitoring for total coliform 63 (100%) 0 2 2 2 2 2 2 Disinfection & flushing of aircraft 63 (100%) 0 1 0 1 2 1 1 

Corrective action for total coliformpositive samples 10 (16%) 0 1 1 1 2 1 1 

Note: To analyze the impact of these requirements on air carrier capacity, the requirements believed to have the most impact on affected 

monitoring for total coliform), were analyzed first. These initial analyses were then used as the basis against which the relative impacts orequirements were assessed. The impact estimates developed for each requirement were also compared to the Ground Water Rule and 

ensure cross-rule consistency and enable cross-rule comparisons. Source: Number and percent of air carriers impacted by each requirement are derived from the ADWR Cost Model. Impact on capacity 

previous regulations based on the cost and number of air carriers that require additional capacity to comply with each requirement, as de
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

6.6.4 Derivation of the ADWR Scores 

To analyze the impact compliance with all new requirements will have on the technical, 

managerial, and financial capacity of air carriers (and assign scores in accordance with the 

process described in Section 6.6.3 above), it is necessary to complete the following steps: 

1. Determine the type and number of air carriers to which the regulation applies. 

2. List all of the requirements of the regulation. 

3. Determine the type and number of air carriers to which each requirement applies. 

4. Evaluate the impact of each requirement on the capacity of affected air carriers. 

The determination of the universe of affected air carriers and the evaluation of the 

capacity impact of individual requirements requires the use of cost and technical information 

contained in economic analyses developed for other rules, information collection requests, and 

other supporting documentation for the rule. These data sources are also used to develop a 

qualitative description of the expected response of affected air carriers to each requirement. 

Within these sub-categories, a professional with extensive water system experience 

reviewed the costs, number of air carriers affected, and complexity of each requirement. After 

estimating the technical, managerial, and financial impacts within each sub-category, the 

professional assigned the scores using best professional judgment. Costs were considered 

cumulatively for each requirement for small and large air carriers. This score reflects the 

additional capacity that air carriers will need to develop to comply with each requirement. 

These scores were reviewed by the EPA Rule Manager and other EPA staff cognizant of 

small air carrier issues to ensure that they accurately reflect the cumulative impact of the rule 

requirements on air carrier capacity. Any disagreements over the assignments were discussed. 

The EPA Rule Manager and other EPA staff discussed the rationale for the disagreement and 

evaluate whether the assignments need to be adjusted. EPA adjusted the assignments only after 

review of the rule support documents and an analysis of the expected air carrier response to the 

rule requirements. 

Most regulated air carriers will likely not face more than a minimal challenge to their 

technical, managerial, and financial capacity as a result of efforts to familiarize themselves with 

the ADWR requirements (Exhibit 6.1). All air carriers subject to the rule should have existing 

O&M plans. EPA expects air carriers to spend 80 hours developing their O&M plans with 

ADWR specific requirements. Air carriers will need to develop a sampling plan, which is 

expected to take 10 hours. Since the sampling locations are likely to be the similar types of 

aircraft and the sampling frequency is either monthly, quarterly, twice annually, or annually, the 

sampling plan should be relatively simple to develop and should not require a high technical skill 

level. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

EPA is providing air carriers the flexibility of choosing one of four monitoring and 

disinfection schedules that can most easily be integrated into air carriers’ current O&M 

schedules if there are no manufacturer’s recommendations specifying a frequency. Air carriers 

already have the infrastructure and technical knowledge for disinfecting and flushing aircraft, but 

may need to adjust their O&M schedules to accommodate additional disinfection events. While 

air carriers are required by existing regulations and AOCs to monitor for total coliform, some 

may need to invest in a modest amount of additional monitoring equipment, including 

refrigerators, coolers, gel packs, and thermometers. 

Aircraft that receive one or more routine total coliform-positive samples followed by a 

repeat total coliform-positive sample, or that receive a single E. coli-positive sample result must 

perform corrective action, which consists of disinfection and flushing and follow-up coliform 

monitoring. In addition, air carriers must perform recordkeeping activities, assumed to include 

the completion of a maintenance log for disinfection and flushing events. Corrective actions do 

not require different technical skills and are expected to occur infrequently (i.e., a maximum of 

3.6 percent of routine samples). Therefore, corrective actions are expected to have limited 

impact on air carriers. 

Overall, EPA assumes that air carriers will have the technical, financial, and managerial 

capacity to implement ADWR requirements based on the scale and complexity of their 

operations. The nature of their operations generally assures that they have access to the technical 

and managerial expertise to carry out all activities required by the final ADWR. 

6. 7	 Paperwork Reduction Act 

The information collection requirements for the ADWR have been submitted for 

approval to OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. The information 

collected as a result of this rule will allow EPA to determine appropriate requirements for 

specific air carriers and evaluate compliance with the rule. 

The Paperwork Reduction Act requires EPA to estimate the burden on air carriers and 

primacy agencies of complying with the rule. Burden means the total time, effort, and financial 

resources required to generate, maintain, retain, disclose, or provide information to or for a 

Federal agency. This burden includes the time needed to conduct these activities: 

• Review instructions. 

• Develop, acquire, install, and employ technology and systems for the purposes of 

collecting, validating, verifying, processing, maintaining, and disclosing 

information. 

• Adjust the existing ways to comply with any previously applicable instructions 

and requirements. 

• Train personnel to respond to information collected. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

• Search data sources. 

• Complete and review the collection of information. 

• Transmit or otherwise disclose the information. 

For the first three years after publication of the final ADWR in the Federal Register, 

information requirements are associated with implementation activities, sampling and O&M 

plans, submittal of fleet inventory, self-inspections, monitoring, and disinfection and flushing 

activities. The information collection requirements are mandatory under Part 141 of the 

NPDWRs. The calculation of ADWR information collection burden and costs can be found in 

the Information Collection Request for the Aircraft Drinking Water Rule (USEPA, 2009). 

The total burden associated with ADWR requirements over the three years covered by 

the Information Collection Request is 62,291 hours, an average of 20,764 hours per year. The 

total cost over the three-year clearance period is $7.54 million, an average of $2.5 million per 

year (simple average over three years). The average burden per response (i.e., the amount of 

time needed for each activity that requires a collection of information) is 0.3 hours; the average 

cost per response is $41. 

Exhibit 6.2 provides a summary of the results of the Information Collection Request 

calculations. 

Exhibit 6.2 Average Annual Burden Hours and Costs for the ADWR Information 

Collection Request

 Average 

Annual 

Burden 

(Hours) 

Average 

Annual Labor 

Costs 

Average 

Annual O&M 

Costs 

Average 

Annual 

Capital Costs 

Average 

Annual Costs 

Air Carriers 17,583 $632,262 $1,719,536 $1,393 $2,353,191 

Agency 3,180 $159,214 - - $159,214 

Total 20,764 $791,746 $1,719,536 $1,393 $2,512,405 

Note: Data represent burden and cost for only the 3-year Information Collection Request clearance period. Data are 

based on nominal (or undiscounted) values. Detail may not add due to independent rounding. 

Source: Information Collection Request for the Aircraft Drinking Water Rule (USEPA, 2009). 

6. 8 Unfunded Mandates Reform Act 

The UMRA of 1995, Public Law 104-4, consists of four Titles and numerous sections. 

Sections 202 and 205 of Title II, entitled “Regulatory Accountability and Reform,” are relevant 

to the ADWR and are discussed in this section. Under Section 202 of the UMRA, EPA 

generally must prepare a written statement, including a cost-benefit analysis, for proposed and 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

final rules with “Federal mandates” that may result in expenditures by the private sector of $100 

million or more in any one year. 

Section 205 generally requires EPA to identify and consider a reasonable number of 

regulatory alternatives and adopt the least costly, most cost-effective, or least burdensome 

alternative that achieves the objectives of the rule before promulgating a rule for which a written 

statement is needed under Section 202. The provisions of Section 205 do not apply when they 

are inconsistent with applicable law. Moreover, Section 205 allows EPA to adopt an alternative 

other than the least costly, most cost-effective, or least burdensome alternative if the 

Administrator publishes with the final rule an explanation why that alternative was not adopted. 

EPA has determined that this rule does not contain a Federal mandate that may result in 

expenditures of $100 million or more for the private sector in any one year. Under the final rule, 

the likely compliance scenario is expected to result in total annualized costs to air carriers of 

$7.04 million using a 3 percent discount rate, or $6.95 million using a 7 percent discount rate. 

Thus, the ADWR is not subject to the requirements of section 202 and 205 of the UMRA. 

Social Benefits and Costs 

The social benefits are those that are accrued primarily by the public through increased 

protection from illness and potential death that would have been caused by exposure to microbial 

pathogens in drinking water. Although EPA did not assign a monetary value to the reductions in 

illness, a qualitative analysis of the public health benefits is included in Chapter 4. Additional 

benefits may include reduced risks to sensitive subpopulations, reduced outbreak risks, and 

reduced risk-averting behavior (e.g., purchasing bottled water). In addition, certain non-healthrelated benefits may exist, such as enhanced aesthetic water quality. 

Measuring the social costs of the final rule requires considering regulatory alternatives, 

calculating regulatory compliance costs, and estimating any disproportionate impacts. Chapter 5 

of this document details the cost analysis performed for the ADWR. EPA considered several 

regulatory alternatives and numerous methods to identify aircraft most at risk to microbial 

contamination. Chapter 2 provides a detailed discussion of these alternatives. EPA chose the 

final rule because it provided substantial benefits at an acceptable level of costs, and 

incorporated significant flexibility for air carriers to comply with the rule. In addition, the 

Workgroup (described in Chapter 2) supported the proposed regulatory option, which 

incorporated feedback from two stakeholder meetings, and the final rule incorporates several 

changes to accommodate suggestions by commenters on the proposed rule. Exhibit 6.3 

summarizes the annualized costs estimated for each regulatory alternative evaluated during the 

rule development process using a 3 percent and 7 percent discount rate, respectively. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit 6.3 Total Annualized Costs of Regulatory Alternatives ($Millions, 2008$)

Alt 1 Alt 2 Alt 3 Final 

Rule Alt 1 Alt 2 Alt 3 Final Rule 

3% 7% 

Total 29.49 7.16 18.43 7.34 29.08 7.07 18.19 7.25

 Note: Detail may not add due to independent rounding. 

Source: Exhibit 5.25. 

Disproportionate Budgetary Effects 

After exploring possible disproportionate effects of the ADWR on geographic areas and 

groups of customers, EPA determined that the ADWR will not have any disproportionate 

budgetary effects. Only one segment of the private economy is directly affected by this rule— 

the air carrier industry. All air carriers with aircraft subject to the rule will incur some costs. 

As seen in Exhibit 6.4, compliance costs and other effects of the ADWR will be greater 

in certain regions, but aircraft owned by private companies do not rely on or impact a region’s 

financial resources. Also, the ADWR is a national mandate and applies uniformly to all air 

carriers that meet the definition of a TNCWS. Regulated air carriers are expected to pass some 

or all of the increased costs onto their customers, which are not necessarily from the same region 

where the air carrier is based. The final rule is not expected to affect urban and rural customers 

disproportionately. 

Exhibit 6.4 Number and Percent of Air Carriers and Aircraft by Region

EPA 

Region 

Number of Air 

Carriers With 

Headquarters in 

Region 

Percent of Total 

Air Carriers Number of Aircraft 

Percent of Total 

Aircraft 

1 1 1.6% 7 0.1% 

2 3 4.8% 597 8.1% 

3 1 1.6% 36 0.5% 

4 14 22.2% 1,317 18.0% 

5 16 25.4% 1,638 22.4% 

6 8 12.7% 2,457 33.5% 

7 2 3.2% 28 0.4% 

8 2 3.2% 314 4.3% 

9 13 20.6% 741 10.1% 

10 3 4.8% 192 2.6% 

Total 63 100% 7,327 100% 

Source: Air carrier Web sites as of January 2007 and Exhibit 5.3. 

Macroeconomic Effects 

Under UMRA Section 202, EPA is required to estimate the potential macroeconomic 

effects of the regulation. Although, as noted previously, the ADWR is not subject to UMRA 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

requirements, EPA did evaluate these potential effects. These include effects on productivity, 

economic growth, full employment, and creation of Gross Domestic Product (GDP) (USEPA, 

2000). Macroeconomic effects tend to be measurable in nationwide econometric models only if 

the economic impact of the regulation reaches 0.25 percent to 0.5 percent of GDP. In the third 

quarter of 2008, real GDP was $14,413 billion (U.S. Department of Commerce Bureau of 

Economic Analysis (BEA), 2008); thus, a rule would have to cost at least $36 billion annually to 

have a measurable effect. A regulation with a smaller aggregate effect is unlikely to have any 

measurable impact, unless it is highly focused on a particular geographic region or economic 

sector. The ADWR should not have a measurable effect on the national economy; the total 

annualized costs for the final rule range from $7.25 million to $7.34 million using a 3 and 7 

percent discount rate, respectively. Using these annualized figures as a measure, the annual costs 

of the ADWR is an insignificant fraction of a $36 billion annual cost that would be considered a 

measurable macroeconomic impact. Thus, annualized ADWR costs measured as a percentage of 

the national GDP will only decline over time as GDP grows. 

6. 9 Impacts on Sensitive Subpopulations 

EPA’s Office of Water has historically considered risks to sensitive subpopulations, 

including children, when establishing drinking water assessments, advisories or other guidance, 

and standards. Maximizing health protection for sensitive subpopulations requires minimizing 

exposure to contaminated drinking water. The health effects of waterborne illnesses on sensitive 

subpopulations are much more severe and debilitating than on the general population. These 

sensitive subpopulations include pregnant women, the young, the elderly (especially those 

weakened by other conditions), the malnourished and disease-impaired (especially those with 

diabetes), and a broad category of those with compromised immune systems, such as Acquired 

Immune Deficiency Syndrome (AIDS) patients, people with lupus or cystic fibrosis, transplant 

recipients, and individuals undergoing chemotherapy (Rose, 1997). Immunocompromised 

individuals are a growing proportion of the population with the relatively new and severe 

problem magnified by the AIDS epidemic and the escalation in organ and tissue transplantations. 

In total, these subgroups represent almost 20 percent of the population of the United States. 

The duration, severity, and cost of waterborne illnesses are often much larger in 

immunocompromised individuals. Similarly, infectious diseases are a major problem for the 

elderly because immune function declines with age. As a result, waterborne diseases may 

increase the possibility of significantly higher mortality rates in the elderly than in the general 

population. Potential health benefits of the ADWR to both sensitive subpopulations and the 

general public are discussed in greater detail in Chapter 4 of this document. 

6.9.1 Protection of Children from Environmental Health Risks and Safety Risks 

Executive Order 13045 (62 FR 19885, April 23, 1997) applies to any rule initiated after 

April 21, 1998, that (1) is determined to be “economically significant” as defined under 

Executive Order 12866; and (2) concerns an environmental, health, or safety risk that EPA has 

reason to believe may have a disproportionate effect on children. If the regulatory action meets 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

both criteria, EPA must evaluate the environmental, health, or safety effects of the planned rule 

on children, and explain why the planned regulation is preferable to other potentially effective 

and reasonably feasible alternatives considered by the Agency. 

The final ADWR is not subject to the Executive Order because it not is economically 

significant as defined in Executive Order 12866. Nevertheless, EPA expects that the ADWR 

will provide additional protection to children since they also travel in aircraft and may consume 

drinking water onboard planes. Further, young children are more susceptible than adults to some 

waterborne illnesses and the risk of mortality resulting from diarrhea is often greatest in the very 

young and elderly (Rose, 1997; Gerba et al., 1996). Since viral and bacterial illnesses often 

disproportionately affect children, the benefits of the rule accrue disproportionately to children. 

6. 10 Environmental Justice 

Executive Order 12898 (59 FR 7629) establishes a Federal policy for incorporating 

environmental justice into Federal agency missions by directing agencies to identify and address 

disproportionately high adverse human health or environmental effects of its programs, policies, 

and activities on minority and low-income populations. This Executive Order does not apply to 

the final ADWR since air carrier customers have a choice whether to board an aircraft and 

passengers do not necessarily represent minority or low-income populations. Furthermore, since 

the rule applies to all air carriers that meet the definition of a TNCWS, passengers served by 

regulated air carriers receive equal protection from contaminated aircraft water systems. 

6.10.1 Federalism 

Executive Order 13132, “Federalism” (64 FR 43255; August 10, 1999), requires EPA to 

develop an accountable process to ensure “meaningful and timely input by State and local 

officials in the development of regulatory policies that have Federalism implications.” “Policies 

that have Federalism implications” are defined in the executive order to include regulations that 

have “substantial direct effects on the States, on the relationship between the national 

government and the States, or on the distribution of power and responsibilities among the various 

levels of government.” 

The ADWR will be implemented by EPA, in coordination with other federal agencies 

including the FDA and FAA. The ADWR will not have Federalism implications because it will 

not impose any direct compliance costs on State or local governments. 

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Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

6. 11	 Actions Concerning Regulations That Significantly Affect Energy Supply, 

Distribution, or Use 

Executive Order 13211, “Actions Concerning Regulations That Significantly Affect 

Energy Supply, Distribution, or Use” (66 FR 28355; May 22, 2001), provides that agencies shall 

prepare and submit to the Administrator of the Office of Information and Regulatory Affairs, 

OMB, a statement of Energy Effects for certain actions identified as “significant energy actions.” 

Section 4(b) of Executive Order 13211 defines “significant energy actions” as “any action by an 

agency (normally published in the Federal Register) that promulgates or is expected to lead to 

the promulgation of a final rule or regulation, including notices of inquiry, advance notices of 

proposed rulemaking, and notices of proposed rulemaking: (1)(i) that is a significant regulatory 

action under Executive Order 12866 or any successor order, and (ii) is likely to have a significant 

adverse effect on the supply, distribution, or use of energy; or (2) that is designated by the 

Administrator of the Office of Information and Regulatory Affairs as a significant energy 

action.” 

The Executive Order 13211 does not apply to the ADWR since none of the final rule 

requirements involve installation of treatment or other components that use a measurable amount 

of energy. 

Page 6-17 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

7. References 

Amvrosieva, T.V., L.P. Titov, M. Mulders, T. Hovi, O.V. Dyakonova, V.I. Votyakov, Z.B. 

Kvacheva, V.F. Eremin, R.M. Sharko, S.V. Orlova, O.N. Kazinets, and Z.F. Bogush. 

2001. Viral water contamination as the cause of aseptic meningitis outbreak in Belarus. 

Central European J Public Health 9(3): 154-157. 

Barwick, R.S., D.A. Levy, G.F. Craun, M.J. Beach, and R.L. Calderon. 2000. Surveillance for 

waterborne-disease outbreaks - United States, 1997-1998. Morbidity and Mortality 

Weekly Report 49(SS04):1-35. 

Blackburn, B.G., G.F. Craun, J.S. Yoder, V. Hill, R.L. Calderon, N. Chen, S. H. Lee, D.A. Levy, 

and M. J. Beach. 2004. Surveillance for waterborne-disease outbreaks associated with 

drinking water --- United States, 2001--2002. Morbidity and Mortality Weekly Report 

53(SS08):23-45. 

Bureau of Economic Analysis. 2008. http://www.bea.gov/national/Index.htm. 

Bureau of Labor Statistics (BLS). 2007. www.bls.gov/data/. 

Craun, G.F. and R. Calderon. 1996. Microbial risks in groundwater systems: epidemiology of 

waterborne outbreaks. In: Under the Microscope: Examining Microbes in Groundwater. 

Boston: Proceedings of the Groundwater Foundation’s 12th Annual Fall Symposium. 

Dun & Bradstreet. Small Business Solutions. Company Profile Reports. 

www.smallbusiness.dnb.com. 

Gerba, C.P., J.B. Rose, and C.N. Haas. 1996. Sensitive subpopulations: who is at the greatest 

risk? International Journal of Food and Microbiology. 30:113-123. 

Kim, K.S., G. Hufnagel, N.M. Chapman, and S. Tracy. 2001. The group B coxsackieviruses 

and myocarditis. Rev. Med. Virol. 11(6):355-68. 

Lee, S.H. and S.J. Kim. 2002. Detection of infectious enteroviruses and adenoviruses in tap 

water in urban areas in Korea. Water Research 36(1):248-256. 

Lee, S.H., D.A. Levy, G.F. Craun, M.J. Beach, and R.L. Calderon. 2002. Surveillance for 

waterborne disease outbreaks, United States, 1999–2000. Morbidity and Mortality 

Weekly Report, Surveillance Summaries 51(SS08):1-28. 

Levy, D.A., M.S. Bens, G.F. Craun, R.L. Calderon, and B.L. Herwaldt. 1998. Surveillance for 

Waterborne Disease Outbreaks - United States, 1995-1996. MMWR 47(55-5):1-34. 

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Moore, A.C., B.L. Herwaldt, G.F. Craun, R.L. Calderon, A.K. Highsmith, and D.D. Juranek. 

1993. Surveillance for waterborne disease outbreaks - United States, 1991-1992. 

MMWR. 42(SS-5):1-22 (November 19). 

Office of Management and Budget, Circular A-4, September 2003. 

Park, S.R., W.G. Mackay, and D.C. Reid. 2001. Helicobacter sp. recovered from drinking water 

biofilm sampled from a water distribution system. Water Research 35(6):1624-1626. 

Rose, J.B. 1997. Environmental ecology of cryptosporidium and public health implications. 

Annual Review of Public Health. 18:135-161. 

SAB and USEPA. 1990. Reducing risk: setting priorities and strategies for environmental 

protection. Washington, DC: U.S. EPA Science Advisory Board. SAB-EC 

Sepulveda, A.R. and D.Y. Graham. 2002. Role of Helicobacter pylori in gastric carcinogenesis. 

Gastroenterol. Clin. North America 31(2):517-535. 

USEPA. 1986. Water Supply Guidance 29: “Plan for Implementation of the Safe Drinking 

Water Act on Interstate Carrier Conveyance” 

USEPA. 1993. Executive Order 12866, Regulatory Planning and Review. In Federal Register, 

Vol. 58, page 51735, September 30, 1993. 

USEPA. 1996. Economic analysis of Federal regulations under Executive Order 12866. Office 

of Management and Budget. January 11, 1996. 

USEPA. 1998. Guidance on Implementing the Capacity Development Provisions of the Safe 

Drinking Water Act Amendments of 1996. 

USEPA. 1999. Interim Guidance for EPA Rulewriters for the RFA as amended by the SBREFA. 

USEPA. 2000. Guidelines for Preparing Economic Analyses. U.S. EPA Office of the 

Administrator. EPA/240-R-00-003. September 2000. 

USEPA. 2005. ICR Handbook: EPA’s Guide to Writing Information Collection Requests 

Under the Paperwork Reduction Act of 1995. Revised November 2005. Office of 

Environmental Information, Collection Strategies Division. p. A-36. 

USEPA. 2008a. Economic and Supporting Analysis Document for the Proposed Aircraft 

Drinking Water Rule. EPA 816-D-08-002. April 2008. 

USEPA. 2008b. Elements of the Proposed Aircraft Drinking Water Rule. In Federal Register, 

Vol. 73, No. 69, page 19320. April 9, 2008. 

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USEPA. 2009. Information Collection Request for the Aircraft Drinking Water Rule. OMB 

Draft. March 2009. 

US Food and Drug Administration (FDA). 2005. Title 21 – Food and Drugs, Chapter 1 – Food 

and Drug Administration, Part 1250 – Interstate Conveyance Sanitation. 

www.accessdata.fda.gov/. 

Page 7-3 
Appendix A 

ADWR Aircraft and Population Baseline
 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit A.1 Background Calculations for ADWR Aircraft and Population Baseline (as of January 2007)

Code for Airline Name Aircraft Models Number of Aircraft Flights/Year/Aircraft Flights/Year Carrying Capacity (passengers/aircraft) Load Factor Estimated # of passengers/aircraft Total # of passengers/year Onboard staff/aircraft Total # of Onboard staff/year 

A B C D E=C*D F G H=F*G I=E*H J K=E*J 

Total Available Sampling Points = 1 

1 Beechjet 400A 1 514 514 8 0.798 6 3,286 2 1,029 

1 Hawker 700A 1 514 514 8 0.798 6 3,286 2 1,029 

10 ATR 72 - Super ATR 41 1,752 71,818 66 0.744 49 3,526,545 3 215,454 

10 SAAB 340B (SF3) 30 1,752 52,550 34 0.744 25 1,329,296 3 157,649 

11 Beechcraft KingAir 90 1 514 514 6 0.798 5 2,464 2 1,029 

14 CRJ 200 94 1,840 172,936 50 0.772 39 6,675,326 3 518,808 31 Dash 8 (Q100 and Q200) 8 4,563 36,500 37 0.798 30 1,078,124 3 109,500 

49 1 1,864 1,864 25 0.798 20 37,201 3 5,592 

52 CRJ 200 122 2,050 250,124 50 0.793 40 9,917,399 3 750,371 

58 CRJ 200 35 888 31,089 50 0.777 39 1,207,823 3 93,268 

58 Dash 8 Q100 38 888 33,754 37 0.777 29 970,399 3 101,263 

58 Dash 8 Q200 9 888 7,994 37 0.777 29 229,831 3 23,983 

Totals 381 660,172 24,980,980 1,978,974 

Total Available Sampling Points = 2 

1 Jetstream 41 1 514 514 14 0.798 11 5,750 2 1,029 

2 Embraer ERJ-145 (ERJ) 36 1,557 56,057 50 0.746 37 2,090,939 3 168,172 3 CRJ 200 70 2,186 153,000 50 0.708 35 5,416,200 3 459,000 

10 CRJ 700-701ER 25 1,752 43,791 70 0.744 52 2,280,656 4 175,166 

10 ERJ 145LR 108 1,752 189,179 50 0.744 37 7,037,452 3 567,536 

11 Falcon 20F 13 514 6,688 9 0.798 7 48,051 2 13,376 

13 LearJet 35 1 514 514 8 0.798 6 3,286 2 1,029 

14 ATR 72-210 12 1,840 22,077 66 0.772 51 1,124,863 3 66,231 

14 CRJ 200 18 1,840 33,115 40 0.772 31 1,022,603 3 99,346 

14 CRJ 700 32 1,840 58,872 70 0.772 54 3,181,432 4 235,487 

15 Cessna Citation Encore 15 609 9,128 7 0.798 6 51,008 2 18,256 

15 Cessna Citation Sovereign 14 609 8,519 8 0.798 6 54,408 2 17,039 

15 Gulfstream 200 24 609 14,604 9 0.798 7 104,931 2 29,209 

15 Raytheon Hawker 400XP 38 609 23,124 7 0.798 6 129,220 2 46,247 

16 Jetstream 3100 2 1,864 3,728 19 0.798 15 56,545 2 7,456 

17 Dash 8 Q100 7 3,031 21,216 37 0.473 18 371,301 2 42,432 

19 ERJ 145LR 63 1,612 101,571 50 0.721 36 3,661,650 3 304,714 21 CRJ 200/700 150 1,967 295,000 53 0.730 39 11,485,333 3 885,000 

22 ERJ 145 140 466 65,205 50 0.833 42 2,715,808 3 195,616 

22 ERJ 145XR 104 466 48,438 50 0.833 42 2,017,458 3 145,315 

23 ATR–72 12 777 9,321 66 0.780 51 479,867 4 37,286 

23 CRJ 100/200 141 777 109,527 50 0.780 39 4,271,545 3 328,580 

25 ERJ 135 30 1,443 43,277 37 0.786 29 1,258,583 3 129,831 

25 ERJ 145 140 1,443 201,959 50 0.786 39 7,937,007 3 605,878 

25 ERJ 145XR 96 1,443 138,486 50 0.786 39 5,442,519 3 415,459 27 Beechjet 400A/Hawker 400XP 200 514 102,890 7 0.798 6 574,973 2 205,781 

27 Cessna Citation X 1 514 514 8 0.798 6 3,286 2 1,029 

27 Raytheon Hawker 800XP 1 514 514 8 0.798 6 3,286 2 1,029 

28 Dash 8 (Q200) 18 1,557 28,029 37 0.746 28 773,647 3 84,086 

30 CRJ 700 15 1,864 27,959 66 0.798 53 1,473,146 4 111,838 

33 CRJ 700 (CR7) 20 2,294 45,882 70 0.748 52 2,402,400 4 183,529 

33 Dash 8 Q200 (DH8) 28 2,294 64,235 37 0.748 28 1,777,776 3 192,706 

33 Dash 8 Q400 (DH4) 20 2,294 45,882 74 0.748 55 2,539,680 4 183,529 

35 Cessna Citation VII 1 514 514 8 0.798 6 3,286 2 1,029 

35 LearJet 31A 3 514 1,543 8 0.798 6 9,857 2 3,087 

35 LearJet 35A 2 514 1,029 8 0.798 6 6,571 2 2,058 

35 LearJet 45 2 514 1,029 8 0.798 6 6,571 2 2,058 

35 LearJet 60 3 514 1,543 8 0.798 6 9,857 2 3,087 

36 CRJ 200/100 61 2,693 164,272 50 0.746 37 6,127,343 3 492,816 37 CRJ 200 2 2,078 4,156 50 0.693 35 144,000 3 12,468 

41 CRJ 200/440 126 858 108,072 47 0.827 39 4,200,656 3 324,216 

44 CRJ 200 124 1,904 236,096 50 0.766 38 9,042,477 3 708,288 

44 CRJ 440 1 1,904 1,904 44 0.766 34 64,172 3 5,712 

51 Fairchild 328JETs 10 5,955 59,550 32 0.634 20 1,208,150 3 178,650 

52 CRJ 700ER 64 2,050 131,212 80 0.793 63 8,324,112 4 524,849 52 Embraer Brasilia 120ER (EM2) 62 2,050 127,112 30 0.793 24 3,023,994 3 381,336 

58 Dash 8 Q300 12 888 10,659 50 0.777 39 414,111 3 31,978 

60 Falcon 20 12 420 5,045 12 0.798 10 48,326 2 10,089 

Totals 2,080 2,826,558 104,430,089 8,639,938 Total Available Sampling Points = 3 

60 LearJet 1 420 420 8 0.798 6 2,685 2 841 

1 Gulfstream III 1 514 514 13 0.798 10 5,339 2 1,029 

5 B737-400 Combi (73Q) 1 1,301 1,301 72 0.765 55 71,649 4 5,203 

10 ERJ 135LR 39 1,752 68,315 37 0.744 28 1,880,563 3 204,944 

10 ERJ 140LR 59 1,752 103,348 44 0.744 33 3,383,190 3 310,043 11 B737-200 2 514 1,029 56 0.798 45 45,998 3 3,087 

12 B737-300 3 793 2,379 138 0.784 108 257,422 5 11,897 

15 Boeing Business Jet 3 609 1,826 18 0.798 14 26,233 2 3,651 

15 Cessna Citation Excel/XLS 112 609 68,154 7 0.798 6 380,859 2 136,308 

15 Cessna Citation V Ultra 69 609 41,988 7 0.798 6 234,637 2 83,976 

15 Cessna Citation X 72 609 43,813 8 0.798 6 279,815 2 87,627 

15 Falcon 2000EX 50 609 30,426 10 0.798 8 242,895 2 60,852 

15 Raytheon Hawker 1000 1 609 609 9 0.798 7 4,372 2 1,217 

15 Raytheon Hawker 800XP 82 609 49,899 6 0.798 5 239,009 2 99,797 

19 ERJ 135LR 17 1,612 27,408 37 0.721 27 731,168 3 82,224 

19 ERJ 140LR 15 1,612 24,184 44 0.721 32 767,203 3 72,551 

20 SAAB 340B 36 514 18,520 34 0.798 27 502,690 3 55,561 

22 ERJ 135 30 466 13,973 37 0.833 31 430,650 3 41,918 

23 CRJ 700 27 777 20,973 70 0.780 55 1,145,138 4 83,893 

25 B727-200 30 1,443 43,277 37 0.786 29 1,258,583 3 129,831 

27 Embraer Legacy 1 514 514 13 0.798 10 5,339 2 1,029 

36 CRJ 700ER 15 2,693 40,395 64 0.746 48 1,928,606 3 121,184 

36 CRJ 900 38 2,693 102,333 86 0.746 64 6,565,297 4 409,333 37 SAAB 340 52 2,078 108,052 34 0.693 24 2,545,920 3 324,156 

Totals 756 813,650 22,935,259 2,332,151
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Code for Airline Name Aircraft Models Number of Aircraft Flights/Year/Aircraft Flights/Year Carrying Capacity (passengers/aircraft) Load Factor Estimated # of passengers/aircraft Total # of passengers/year Onboard staff/aircraft Total # of Onboard staff/year 

A B C D E=C*D F G H=F*G I=E*H J K=E*J 

Total Available Sampling Points = 4 

4 B717-200 85 2,093 177,870 117 0.735 86 15,295,963 4 711,481 

15 Gulfstream 450 6 609 3,651 14 0.798 11 40,806 2 7,302 

15 Gulfstream 550 7 609 4,260 14 0.798 11 47,607 2 8,519 

19 ERJ 170LR 52 1,612 83,837 70 0.721 50 4,231,240 3 251,510 

24 Gulfstream G-IV 1 514 514 15 0.798 12 6,160 2 1,029 

32 B717-200 11 1,962 21,577 123 0.891 110 2,364,680 5 107,885 

34 A320 87 1,479 128,688 150 0.820 123 15,828,563 5 643,438 

34 Embraer 190 9 1,479 13,313 102 0.820 84 1,113,458 4 53,250 

37 Avro RJ 85 23 2,078 47,792 69 0.693 48 2,285,280 3 143,377 

41 Avro RJ 85 16 858 13,723 69 0.827 57 783,101 4 54,894 

46 ERJ 170 16 674 10,790 70 0.721 50 544,571 3 32,370 

48 Embraer 170 40 674 26,975 110 0.721 79 2,139,387 4 107,900 

52 CRJ 900 11 2,050 22,552 88 0.793 70 1,573,777 4 90,208 

54 A319 25 1,472 36,794 138 0.792 109 4,021,476 5 183,972 

57 Embraer 170 18 888 15,989 72 0.777 56 894,479 4 63,955 

58 CRJ 700 14 888 12,436 70 0.777 54 676,381 4 49,743 

Totals 421 620,761 51,846,929 2,510,833 

Total Available Sampling Points = 5 

1 A319 Executive 1 514 514 72 0.798 57 29,570 4 2,058 

5 B737-200 Combi (73M) 7 1,301 9,106 111 0.765 85 773,210 4 36,423 

6 MD 87 2 770 1,539 130 0.798 104 159,740 5 7,696 

7 B737-200 10 3,249 32,490 127 0.798 101 3,294,031 5 162,450 8 A319 37 1,362 50,383 124 0.798 99 4,985,497 4 201,532 

18 B727-200 (coach) 10 514 5,145 173 0.798 138 710,502 5 25,723 

23 MD 88 120 777 93,214 142 0.780 111 10,324,414 5 466,071 

29 A318 7 1,582 11,073 114 0.806 92 1,017,406 4 44,291 29 A319 48 1,582 75,927 132 0.806 106 8,078,054 5 379,636 

38 B737-800 9 514 4,630 173 0.798 138 639,452 5 23,150 

39 B717 22 1,367 30,083 88 0.716 63 1,895,473 4 120,332 

41 A319-100 66 858 56,609 124 0.827 103 5,805,162 5 283,046 

41 A320-200 73 858 62,613 148 0.827 122 7,663,608 5 313,066 

43 B737-200 5 514 2,572 80 0.798 64 164,278 4 10,289 

43 B737-300 2 514 1,029 100 0.798 80 82,139 4 4,116 

45 B737-800 2 514 1,029 170 0.798 136 139,636 5 5,145 

47 MD 87 1 514 514 135 0.798 107 55,238 5 2,572 

50 B737-800 1 1,864 1,864 189 0.798 151 281,237 5 9,320 

53 B737-300 194 2,291 444,376 137 0.730 100 44,442,051 4 1,777,504 

53 B737-500 25 2,291 57,265 122 0.730 89 5,100,017 4 229,060 

53 B737-700 249 2,291 570,359 137 0.730 100 57,041,601 4 2,281,436 

54 A321 6 1,472 8,831 198 0.792 157 1,384,786 6 52,984 

57 A319 54 888 47,966 120 0.777 93 4,472,395 4 191,866 

61 B737-200 Advanced 1 514 514 27 0.798 22 11,089 3 1,543 

63 B737-400 3 514 1,543 150 0.798 120 184,813 5 7,717 

63 B737-800 1 514 514 189 0.798 151 77,621 5 2,572 

Totals 956 1,571,705 158,813,021 6,641,598 

Total Available Sampling Points = 6 

4 B737-700 23 2,093 48,130 137 0.735 101 4,846,413 4 192,519 

5 B737-400 (734) 40 1,301 52,033 144 0.765 110 5,731,902 5 260,163 

5 B737-700 (73G) 22 1,301 28,618 124 0.765 95 2,714,693 4 114,472 

7 B737-700 8 3,249 25,992 124 0.798 99 2,572,976 4 103,968 

8 A320 56 1,362 76,255 150 0.798 120 9,127,762 5 381,277 

18 B727-200 (VIP) 6 514 3,087 59 0.798 47 145,386 3 9,260 

22 B737-500 63 466 29,342 114 0.833 95 2,786,419 4 117,370 

22 B737-700 36 466 16,767 124 0.833 103 1,731,910 5 83,836 

23 B737-200 17 777 13,205 100 0.780 78 1,030,018 4 52,821 23 B737-800 71 777 55,152 150 0.780 117 6,452,759 5 275,759 

23 MD 90 16 777 12,429 150 0.780 117 1,454,143 5 62,143 

26 B727-200 2 514 1,029 170 0.798 136 139,636 5 5,145 

26 B737-300 2 514 1,029 134 0.798 107 110,066 5 5,145 

38 B727-200 9 514 4,630 60 0.798 48 221,775 3 13,890 

38 B727-400 2 514 1,029 68 0.798 54 55,854 4 4,116 

39 MD 81/82 10 1,367 13,674 111 0.716 79 1,081,869 4 54,696 39 MD 88 2 1,367 2,735 143 0.716 102 280,013 5 13,674 

41 B757-200 46 858 39,455 182 0.827 151 5,938,516 5 197,275 

41 DC 9-30 68 858 58,325 100 0.827 83 4,823,448 4 233,299 

41 DC 9-40 8 858 6,862 110 0.827 91 624,211 4 27,447 

41 DC 9-50 29 858 24,874 125 0.827 103 2,571,324 5 124,369 

43 B737-400 1 514 514 72 0.798 57 29,570 4 2,058 

43 B757-200 2 514 1,029 82 0.798 65 66,943 4 4,116 

47 B737-400 3 514 1,543 144 0.798 115 177,420 5 7,717 

56 A319 55 1,065 58,587 120 0.820 98 5,764,957 4 234,348 

56 A320-200 97 1,065 103,326 147 0.820 121 12,454,927 5 516,630 

56 B737-300 64 1,065 68,174 123 0.820 101 6,876,021 4 272,696 

56 B737-500 30 1,065 31,957 108 0.820 89 2,830,070 4 127,826 

57 A320 20 888 17,765 142 0.777 110 1,960,124 5 88,827 

57 B737-400 40 888 35,531 144 0.777 112 3,975,462 5 177,654 

59 A320-212 1 1,864 1,864 142 0.798 113 211,300 5 9,320 

59 A320-214 9 1,864 16,776 168 0.798 134 2,249,896 5 83,878 

60 DC 9-30 13 420 5,465 74 0.798 59 322,847 4 21,860 

Totals 871 857,181 91,360,628 3,879,569
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Code for Airline Name Aircraft Models Number of Aircraft Flights/Year/Aircraft Flights/Year Carrying Capacity (passengers/aircraft) Load Factor Estimated # of passengers/aircraft Total # of passengers/year Onboard staff/aircraft Total # of Onboard staff/year 

A B C D E=C*D F G H=F*G I=E*H J K=E*J 

Total Available Sampling Points = 7 

5 B737-800 (738) 15 1,301 19,512 160 0.765 122 2,388,293 5 97,561 

5 B737-900 (739) 12 1,301 15,610 172 0.765 132 2,053,932 5 78,049 5 MD 80 (MD-82/MD-83) 26 1,301 33,821 140 0.765 107 3,622,244 5 169,106 6 MD 83 13 770 10,005 150 0.798 120 1,198,047 5 50,024 8 B737-300 35 1,362 47,660 133 0.798 106 5,058,301 5 238,298 8 B757-200 13 1,362 17,702 190 0.798 152 2,683,997 6 106,213 

12 B737-800 12 793 9,517 175 0.784 137 1,305,766 5 47,586 

12 B757-200 6 793 4,759 197 0.784 154 734,959 6 28,552 

16 B727-200 5 1,864 9,320 149 0.798 119 1,104,860 5 46,599 

22 B737-300 48 466 22,356 124 0.833 103 2,309,213 5 111,781 

26 B727-200 2 514 1,029 170 0.798 136 139,636 5 5,145 

26 B727-200 3 514 1,543 147 0.798 117 181,116 5 7,717 

47 B737-200 3 514 1,543 100 0.798 80 123,208 4 6,173 

47 B757-200 5 514 2,572 193 0.798 154 396,320 6 15,434 

47 MD 83 1 514 514 161 0.798 129 66,122 5 2,572 

57 A321 28 888 24,872 169 0.777 131 3,265,952 5 124,358 

57 B737-300 40 888 35,531 126 0.777 98 3,478,529 4 142,123 

57 B757-200 31 888 27,536 193 0.777 150 4,129,373 5 137,682 

Totals 298 285,402 34,239,869 1,414,970 

Total Available Sampling Points = 8 

9 B737-800 77 917 70,611 142 0.819 116 8,211,903 5 353,054 

9 B757-223 143 917 131,134 184 0.819 151 19,761,441 5 655,672 9 MD 80 327 917 299,867 130 0.819 106 31,926,834 5 1,499,335 

23 B737-332 21 777 16,313 128 0.780 100 1,628,640 4 65,250 

23 B757-200 121 777 93,991 199 0.780 155 14,589,294 6 563,946 

40 B757-200ER 5 69 345 278 0.798 222 76,566 7 2,415 

42 B757-200ER 3 514 1,543 223 0.798 178 274,755 6 9,260 

55 B737-800 5 1,864 9,320 162 0.798 129 1,205,302 5 46,599 

56 B757-200 97 1,065 103,326 172 0.820 141 14,573,111 5 516,630 

57 B767-200 10 888 8,883 203 0.777 158 1,401,074 6 53,296 

Totals 809 735,333 93,648,921 3,765,459 

> 9 Total Available Sampling Points 

12 B757-300 4 793 3,172 247 0.784 194 614,332 6 19,034 

22 B737-800 103 466 47,973 155 0.833 129 6,193,983 5 239,863 

22 B737-900 12 466 5,589 167 0.833 139 777,497 5 27,945 

22 B757-200 41 466 19,096 175 0.833 146 2,783,703 5 95,479 

23 B767-300 24 777 18,643 250 0.780 195 3,635,357 6 111,857 

41 B757-300 16 858 13,723 224 0.827 185 2,542,241 6 82,341 

41 DC 10-30 12 858 10,293 273 0.827 226 2,323,767 7 72,048 

62 DC 10 9 1,864 16,776 273 0.798 218 3,656,082 7 117,429 

9 A300-605R 34 917 31,179 267 0.819 219 6,817,968 7 218,252 

22 B757-300 17 466 7,918 216 0.833 180 1,424,635 6 47,507 

32 B-767-300 1 1,962 1,962 252 0.891 225 440,428 7 13,731 

32 B767-300ER 3 1,962 5,885 252 0.891 225 1,321,284 7 41,192 

32 B767-300ER 4 1,962 7,846 259 0.891 231 1,810,649 7 54,923 

32 B767-300ER 7 1,962 13,731 264 0.891 235 3,229,806 7 96,115 23 B767-400ER 21 777 16,313 285 0.780 222 3,626,269 7 114,188 

23 B777-200 8 777 6,214 268 0.780 209 1,299,034 7 43,500 40 B767-300ER 3 69 207 215 0.798 172 35,529 6 1,242 

9 B767-223ER 16 917 14,672 158 0.819 129 1,898,636 5 73,362 

22 B767-200ER 10 466 4,658 174 0.833 145 675,072 5 23,288 

12 Lockheed L-1011 4 793 3,172 283 0.784 222 703,870 7 22,207 

22 B767-400ER 35 466 16,301 235 0.833 196 3,191,075 6 97,808 22 B777-200ER 18 466 8,384 283 0.833 236 1,976,332 7 58,685 41 A330-200 9 858 7,719 243 0.827 201 1,551,306 6 46,317 56 B767-300 35 1,065 37,283 213 0.820 175 6,511,780 6 223,696 62 MD 11 8 1,864 14,912 400 0.798 319 4,761,685 9 134,205 

9 B767-323ER 58 917 53,187 212 0.819 174 9,234,824 6 319,124 

41 B747-200 3 858 2,573 353 0.827 292 751,181 8 20,585 42 DC 10-30 5 514 2,572 380 0.798 303 780,320 9 23,150 

23 B767-232 14 777 10,875 204 0.780 159 1,730,430 6 65,250 

23 B767-300ER 59 777 45,830 214 0.780 167 7,650,003 6 274,982 

41 A330-300 11 858 9,435 298 0.827 246 2,325,186 7 66,044 

56 B777-200 52 1,065 55,391 367 0.820 301 16,669,459 8 443,130 41 B747-400 16 858 13,723 403 0.827 333 4,573,764 9 123,511 57 A330-300 9 888 7,994 226 0.777 176 1,403,835 6 47,966 

9 B777-200IGW 44 917 40,349 247 0.819 202 8,162,334 7 282,443 

56 B747-400 30 1,065 31,957 347 0.820 285 9,092,909 8 255,652 

Totals 755 607,507 126,176,568 3,998,054 

Total All Sampling Point Categories 7,327 8,978,269 708,432,263 35,161,545 

Source: See Section 3.2.1 for data sources. Aircraft and population baseline data as of January 2007. 

Notes: (G) Weighted average of available load factors (0.798) used for aircraft without publicly available load factor data. (I), (K) - Load factor (G) used to determine number of passengers and staff onboard. Weighted average of available load factors (0.798) used for aircraft without publically available load factor data. (J) FAA Requirement (14CFR 91.533 and 14CFR 125.269). Number of onboard staff/aircraft based based on estimated number of passengers/aircraft (H). (H<=19, 2 pilots), (19<H<51, 2 pilots, 1 flight attendant), (50<H<101, 2 pilots, 2 flight attendants), and one additional flight attendant for every 50 passenger
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit A.2 ADWR Aircraft and Population Baseline (as of January 2007)

# of Available Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points # of Onboard Staff/year # of Passengers/year 

A B C=B*A D E 

1 2 3 4 5 6 7 8 > 9 

381 

2,080 

756 421 956 871 298 809 755 

381 

4,160 2,268 1,684 4,780 5,226 2,086 6,472 9,354 

1,978,974 8,639,938 2,332,151 2,510,833 6,641,598 3,879,569 1,414,970 3,765,459 3,998,054 

24,980,980 

104,430,089 

22,935,259 51,846,929 

158,813,021 

91,360,628 34,239,869 93,648,921 

126,176,568 

Total 7,327 36,411 35,161,545 708,432,263 Source: See Section 3.2.1 for data sources. Aircraft and population baseline data as of January 2007. 

Notes: (A) Each qualifying lavatory and galley on an aircraft is assumed to have only one sampling point. Therefore, the number of available sarepresentative of the number of lavatories and galleys on an aircraft. (B), (D), (E) Derived from Appendix B. (C) Average number of sampling points used for > 9 sampling points size category. 
Appendix B 

Aircraft Drinking Water Sampling Data
 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Aircraft Drinking Water Sampling Data 

Source of Data 

Aircraft drinking water sampling data was collected as part of the Administrative Orders on Consent (AOC). AOCs were established by Office of Enforcement and Compliance Assistance (OECA) with 45 air carriers. EPA has processed sampling data from 25 of the 45 air carriers as of December 31, 2008. Samples were taken from 2005 to 2008. Data for air carriers with an approved quality assurance project plan (QAPP) and comprehensive representative monitoring plan (CRMP) are only available for 2 air carriers in 2005, 5 air carriers in 2006, 8 air carriers in 2007, and 12 air carriers in 2008. A description of the sampling process used and other details can be found in the AOCs. Only data collected under approved QAPPs and CRMPs was used for the Occurrence Baseline for the final ADWR. 

Features of the Data (based on AOCs) 

Total number of airlines under AOCs is 45. Total estimated number of aircraft is 6,046. Each aircraft is a Transient Non-Community Water System (TNCWS). The source of the water is considered to be finished surface water or ground water under the direct influence of surface water received from a PWS. Each aircraft system's data covers, in-part or full, 4 quarters (1 year) each for Monitoring Period. Data re

presents different 

years: 2005 to 2008. 
Exhibit Number Exhibit Title Page Number 

B.1 Monitoring Period for Year 2005: Sampling Data for All Airlines B-3 

B.2 Monitoring Period for Year 2006: Sampling Data for All Airlines B-5 

B.3 Monitoring Period for Year 2007: Sampling Data for All Airlines B-7 

B.4 Monitoring Period for Year 2008: Sampling Data for All Airlines B-9 

B.5 Montioring Period for All Years (2005-2008): Sampling Data for All Airlines B-11 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Page B-2Page B-2 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.1 Montioring Period for Year 2005: Sampling Data for All Airlines

Routine Samples Repeat Samples

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 2 2.7% 1.5% 65 1 2,402 5.5% 129 50 2,352 12.5% 0.0% 47 0 375 

Calendar Qtr 3 0.0% 0.0% 0 0 30 0.0% 0 0 30 16.7% 0.0% 8 0 48 

Calendar Qtr 4 1.8% 0.0% 14 0 773 3.2% 17 241 532 1.4% 0.0% 3 0 215 

Total 2.5% 1.3% 79 1 3205 5.0% 146 291 2,914 9.1% 0.0% 58 0 638 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Approv

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 2 2.7% 1.5% 65 1 2,402 5.5% 129 50 2,352 12.5% 0.0% 47 0 375 

Calendar Qtr 3 0.0% 0.0% 0 0 22 0.0% 0 0 22 16.7% 0.0% 8 0 48 

Calendar Qtr 4 1.8% 0.0% 14 0 757 2.1% 11 241 516 1.4% 0.0% 3 0 215 

Total 2.5% 1.3% 79 1 3181 4.8% 140 291 2,890 9.1% 0.0% 58 0 638 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Unappr

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 2 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 3 0.0% 0.0% 0 0 8 0.0% 0 0 8 0.0% 0.0% 0 0 8 

Calendar Qtr 4 0.0% 0.0% 0 0 16 37.5% 6 0 16 0.0% 0.0% 0 0 16 

Total 0.0% 0.0% 0 0 24 25.0% 6 0 24 0.0% 0.0% 0 0 24 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.1 Montioring Period for Year 2005: Sampling Data for All Airlines

All Samples

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 2 4.0% 0.9% 112 1 2,777 5.0% 137 54 2,723 

Calendar Qtr 3 10.3% 0.0% 8 0 78 0.0% 0 0 78 

Calendar Qtr 4 1.7% 0.0% 17 0 988 4.1% 29 284 704 

Total 3.6% 0.7% 137 1 3843 4.7% 166 338 3,505 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 2 4.0% 0.9% 112 1 2,777 5.0% 137 54 2,723 

Calendar Qtr 3 11.4% 0.0% 8 0 70 0.0% 0 0 70 

Calendar Qtr 4 1.7% 0.0% 17 0 972 3.3% 23 284 688 

Total 3.6% 0.7% 137 1 3819 4.6% 160 338 3,481 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 2 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 3 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 4 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Total 0.0% 0.0% 0 0 0 0.0% 0 0 0 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.2 Montioring Period for Year 2006: Sampling Data for All Airlines

Routine Samples Repeat Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 24 8.3% 2 0 24 0.0% 0.0% 0 0 24 

Calendar Qtr 1 2.0% 0.0% 21 0 1,070 5.0% 38 308 762 1.5% 0.0% 4 0 260 

Calendar Qtr 2 4.0% 9.1% 33 3 823 14.0% 78 265 558 4.8% 9.5% 42 4 880 

Calendar Qtr 3 5.5% 1.9% 53 1 969 44.4% 326 234 735 2.9% 0.0% 32 0 1,098 

Calendar Qtr 4 2.7% 0.0% 15 0 565 45.4% 206 111 454 1.7% 0.0% 12 0 714 

Totals 3.5% 3.3% 122 4 3451 25.7% 650 918 2,533 3.0% 4.4% 90 4 2976 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Approv

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 2.0% 0.0% 20 0 1,024 3.8% 27 308 716 1.6% 0.0% 4 0 252 

Calendar Qtr 2 3.5% 12.0% 25 3 722 12.2% 56 263 459 4.8% 9.8% 41 4 846 

Calendar Qtr 3 2.6% 0.0% 18 0 702 44.6% 213 224 478 1.9% 0.0% 16 0 864 

Calendar Qtr 4 1.9% 0.0% 9 0 484 44.9% 168 110 374 1.5% 0.0% 10 0 676 Totals 2.5% 4.2% 72 3 2932 22.9% 464 905 2,027 2.7% 5.6% 71 4 2638 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Unappr

Unknown Calendar Qtr 0.0% 0.0% 0 0 24 8.3% 2 0 24 0.0% 0.0% 0 0 24 

Calendar Qtr 1 2.2% 0.0% 1 0 46 23.9% 11 0 46 0.0% 0.0% 0 0 8 

Calendar Qtr 2 7.9% 0.0% 8 0 101 22.2% 22 2 99 2.9% 0.0% 1 0 34 

Calendar Qtr 3 13.1% 2.9% 35 1 267 44.0% 113 10 257 6.8% 0.0% 16 0 234 

Calendar Qtr 4 7.4% 0.0% 6 0 81 47.5% 38 1 80 5.3% 0.0% 2 0 38 

Total 9.6% 2.0% 50 1 519 36.8% 186 13 506 5.6% 0.0% 19 0 338 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.2 Montioring Period for Year 2006: Sampling Data for All Airlines 

All Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 48 4.2% 2 0 48 

Calendar Qtr 1 1.9% 0.0% 25 0 1,330 5.8% 57 352 978 

Calendar Qtr 2 4.4% 9.3% 75 7 1,703 8.7% 124 281 1,422 Calendar Qtr 3 4.1% 1.2% 85 1 2,067 39.0% 634 441 1,626 

Calendar Qtr 4 2.1% 0.0% 27 0 1,279 51.7% 604 111 1,168 

Totals 3.3% 3.8% 212 8 6427 27.1% 1,421 1,185 5,242 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 1.9% 0.0% 24 0 1,276 4.5% 42 352 924 

Calendar Qtr 2 4.2% 10.6% 66 7 1,568 7.7% 101 263 1,305 Calendar Qtr 3 2.2% 0.0% 34 0 1,566 38.2% 512 224 1,342 

Calendar Qtr 4 1.6% 0.0% 19 0 1,160 52.7% 553 110 1,050 

Totals 2.6% 4.9% 143 7 5570 26.1% 1,208 949 4,621 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 48 4.2% 2 0 48 

Calendar Qtr 1 1.9% 0.0% 1 0 54 27.8% 15 0 54 

Calendar Qtr 2 6.7% 0.0% 9 0 135 19.7% 23 18 117 Calendar Qtr 3 10.2% 2.0% 51 1 501 43.0% 122 217 284 

Calendar Qtr 4 6.7% 0.0% 8 0 119 43.2% 51 1 118 Total 8.1% 1.4% 69 1 857 34.3% 213 236 621 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.3 Montioring Period for Year 2007: Sampling Data for All Airlines

Routine Samples Repeat Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 44 0.0% 0 38 6 0.0% 0.0% 0 0 0 

Calendar Qtr 1 1.7% 4.5% 22 1 1,312 29.4% 310 258 1,054 1.0% 0.0% 7 0 670 

Calendar Qtr 2 2.7% 0.0% 45 0 1,698 13.4% 179 361 1,337 5.0% 0.0% 13 0 262 

Calendar Qtr 3 3.8% 2.2% 45 1 1,177 27.1% 266 196 981 12.1% 0.0% 36 0 297 

Calendar Qtr 4 7.0% 11.1% 63 7 901 11.7% 89 141 760 8.1% 0.0% 41 0 509 

Total 3.4% 5.1% 175 9 5132 20.4% 844 994 4,138 5.6% 0.0% 97 0 1738 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Approv

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 1.8% 0.0% 21 0 1,158 19.7% 177 258 900 1.1% 0.0% 7 0 666 

Calendar Qtr 2 2.7% 0.0% 42 0 1,529 3.9% 46 361 1,168 5.0% 0.0% 13 0 258 

Calendar Qtr 3 3.9% 0.0% 43 0 1,105 22.1% 201 196 909 12.5% 0.0% 36 0 289 

Calendar Qtr 4 7.5% 11.1% 63 7 837 5.2% 36 141 696 8.1% 0.0% 41 0 509 

Total 3.7% 4.1% 169 7 4629 12.5% 460 956 3,673 5.6% 0.0% 97 0 1722 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Unappr

Unknown Calendar Qtr 0.0% 0.0% 0 0 44 0.0% 0 38 6 0.0% 0.0% 0 0 0 

Calendar Qtr 1 0.6% 100.0% 1 1 154 86.4% 133 0 154 0.0% 0.0% 0 0 4 

Calendar Qtr 2 1.8% 0.0% 3 0 169 78.7% 133 0 169 0.0% 0.0% 0 0 4 Calendar Qtr 3 2.8% 50.0% 2 1 72 90.3% 65 0 72 0.0% 0.0% 0 0 8 

Calendar Qtr 4 0.0% 0.0% 0 0 64 82.8% 53 0 64 0.0% 0.0% 0 0 0 

Total 1.2% 33.3% 6 2 503 82.6% 384 38 465 0.0% 0.0% 0 0 16 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.3 Montioring Period for Year 2007: Sampling Data for All Airlines

All Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 44 0.0% 0 38 6 

Calendar Qtr 1 1.5% 3.4% 29 1 1,982 37.0% 632 272 1,710 Calendar Qtr 2 3.0% 0.0% 58 0 1,960 12.5% 197 389 1,571 Calendar Qtr 3 5.5% 1.2% 81 1 1,474 28.3% 345 254 1,220 Calendar Qtr 4 7.4% 6.7% 104 7 1,410 8.0% 95 224 1,186 

Total 4.0% 3.3% 272 9 6870 22.3% 1,269 1,177 5,693 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 1.5% 0.0% 28 0 1,824 32.2% 499 272 1,552 

Calendar Qtr 2 3.1% 0.0% 55 0 1,787 4.3% 60 389 1,398 

Calendar Qtr 3 5.7% 0.0% 79 0 1,394 23.9% 272 254 1,140 

Calendar Qtr 4 7.7% 6.7% 104 7 1,346 3.7% 42 224 1,122 

Total 4.2% 2.6% 266 7 6351 16.7% 873 1,139 5,212 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 44 0.0% 0 38 6 

Calendar Qtr 1 0.6% 100.0% 1 1 158 84.2% 133 0 158 

Calendar Qtr 2 1.7% 0.0% 3 0 173 79.2% 137 0 173 

Calendar Qtr 3 2.5% 50.0% 2 1 80 91.3% 73 0 80 

Calendar Qtr 4 0.0% 0.0% 0 0 64 82.8% 53 0 64 

Total 1.2% 33.3% 6 2 519 82.3% 396 38 481 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.4 Montioring Period for Year 2008: Sampling Data for All Airlines

Routine Samples Repeat Samples

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 6.0% 6.7% 60 4 995 23.8% 225 50 945 13.7% 0.0% 63 0 459 

Calendar Qtr 2 6.7% 4.5% 66 3 988 22.7% 217 33 955 10.4% 0.0% 44 0 424 

Calendar Qtr 3 17.8% 0.0% 18 0 101 24.2% 24 2 99 10.2% 0.0% 5 0 49 

Calendar Qtr 4 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Total 6.9% 4.9% 144 7 2084 23.3% 466 85 1,999 12.0% 0.0% 112 0 932 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Approv

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 6.1% 6.8% 59 4 963 23.2% 212 50 913 13.7% 0.0% 63 0 459 

Calendar Qtr 2 6.7% 4.5% 66 3 988 22.7% 217 33 955 10.4% 0.0% 44 0 424 

Calendar Qtr 3 17.8% 0.0% 18 0 101 24.2% 24 2 99 10.2% 0.0% 5 0 49 

Calendar Qtr 4 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Total 7.0% 4.9% 143 7 2052 23.0% 453 85 1,967 12.0% 0.0% 112 0 932 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP Total Coliform and Chlorine Residual Data for Airlines with Unappr

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 1 3.1% 0.0% 1 0 32 40.6% 13 0 32 3.1% 0.0% 1 0 32 

Calendar Qtr 2 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 3 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Calendar Qtr 4 0.0% 0.0% 0 0 0 0.0% 0 0 0 0.0% 0.0% 0 0 0 

Total 3.1% 0.0% 1 0 32 40.6% 13 0 32 3.1% 0.0% 1 0 32 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.4 Montioring Period for Year 2008: Sampling Data for All Airlines 

Unknown Calendar Qtr Calendar Qtr 1 Calendar Qtr 2 Calendar Qtr 3 Calendar Qtr 4 Total Unknown Calendar Qtr Calendar Qtr 1 Calendar Qtr 2 Calendar Qtr 3 Calendar Qtr 4 Total Unknown Calendar Qtr Calendar Qtr 1 Calendar Qtr 2 Calendar Qtr 3 Calendar Qtr 4 Total 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ 

samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual 

Non-detect 

Total # of 

CL2 

Residual 

Non-detect 

Total # of 

Disinfection 

Unknown 

Total # of 

CL2 

Residual 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

8.5% 3.3% 123 4 1,454 24.8% 336 101 1,353 7.8% 2.7% 110 3 1,412 25.0% 334 78 1,334 

15.3% 0.0% 23 0 150 20.7% 29 10 140 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

8.5% 2.7% 256 7 3016 24.7% 699 189 2,827 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

8.6% 3.3% 122 4 1,422 24.5% 323 101 1,321 7.8% 2.7% 110 3 1,412 25.0% 334 78 1,334 

15.3% 0.0% 23 0 150 20.7% 29 10 140 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

8.5% 2.7% 255 7 2984 24.5% 686 189 2,795 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

0.0% 0.0% 0 0 0 0.0% 0 0 0 

All Samples
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.5 Montioring Period for All Years (2005-2008): Sampling Data for All Airlines

Routine Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual Nondetect 

Total # of CL2 

Residual Nondetect 

Total # of 

Disinfection 

Unknown 

Total # of CL2 

Residual 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 68 6.7% 2 38 30 Calendar Qtr 1 3.1% 4.9% 103 5 3,377 20.8% 573 616 2,761 Calendar Qtr 2 3.5% 3.3% 209 7 5,911 11.6% 603 709 5,202 Calendar Qtr 3 5.1% 1.7% 116 2 2,277 33.4% 616 432 1,845 Calendar Qtr 4 4.1% 7.6% 92 7 2,239 17.9% 312 493 1,746 Total 3.7% 4.0% 520 21 13,872 18.2% 2,106 2,288 11,584 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 3.2% 4.0% 100 4 3,145 16.4% 416 616 2,529 Calendar Qtr 2 3.5% 3.5% 198 7 5,641 9.1% 448 707 4,934 Calendar Qtr 3 4.1% 0.0% 79 0 1,930 29.0% 438 422 1,508 Calendar Qtr 4 4.1% 8.1% 86 7 2,078 13.6% 215 492 1,586 Total 3.6% 3.9% 463 18 12,794 14.4% 1,517 2,237 10,557 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 68 6.7% 2 38 30 

Calendar Qtr 1 1.3% 33.3% 3 1 232 67.7% 157 0 232 

Calendar Qtr 2 4.1% 0.0% 11 0 270 57.8% 155 2 268 

Calendar Qtr 3 10.7% 5.4% 37 2 347 52.8% 178 10 337 

Calendar Qtr 4 3.7% 0.0% 6 0 161 60.6% 97 1 160 

Total 5.3% 5.3% 57 3 1,078 57.4% 589 51 1,027 

Total Coliform and Chlorine Residual Data for All Airlines by Region 

Region 2 5.4% 16.7% 12 2 222 23.4% 51 4 218 

Region 4 4.6% 2.1% 189 4 4,119 13.6% 553 55 4,064 

Region 5 1.8% 1.1% 95 1 5,379 4.4% 142 2,122 3,257 

Region 6 Region 6 6.2% 5.0% 160 8 2,585 30.8% 796 0 2,585 Region 9 4.0% 12.8% 47 6 1,166 50.5% 564 49 1,117 

Region 10 4.2% 0.0% 17 0 401 0.0% 0 58 343 

Total 3.7% 4.0% 520 21 13,872 18.2% 2,106 2,288 11,584 

Total Coliform and Chlorine Residual Data for All Airlines by Sample Location 

Galley 0.9% 12.7% 55 7 6,224 18.3% 1,056 451 5,773 

Lavatory 6.1% 3.0% 462 14 7,576 18.0% 1,046 1,780 5,796 

Composite* 14.3% 0.0% 1 0 7 66.7% 4 1 6 

Unknown Sample Site 3.1% 0.0% 2 0 65 0.0% 0 56 9 

Total 3.7% 4.0% 520 21 13,872 18.2% 2,106 2,288 11,584 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP by Sample Location 

Galley 0.8% 12.8% 47 6 5,695 14.1% 743 425 5,270 

Lavatory 5.9% 2.9% 413 12 7,027 14.6% 770 1,755 5,272 

Composite* 14.3% 0.0% 1 0 7 66.7% 4 1 6 

Unknown Sample Site 3.1% 0.0% 2 0 65 0.0% 0 56 9 

Total 3.6% 3.9% 463 18 12,794 14.4% 1,517 2,237 10,557 

*Composite sample of 

Galley and Lavatory sources. 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.5 Montioring Period for All Years (2005-2008): Sampling Data for All Airlines 

Repeat Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual Nondetect 

Total # of CL2 

Residual Nondetect 

Total # of 

Disinfection 

Unknown 

Total # of CL2 

Residual 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 24 0.0% 0 0 24 

Calendar Qtr 1 5.3% 0.0% 74 0 1,389 35.3% 452 109 1,280 

Calendar Qtr 2 7.5% 2.7% 146 4 1,941 10.2% 189 93 1,848 

Calendar Qtr 3 5.4% 0.0% 81 0 1,492 32.2% 392 273 1,219 

Calendar Qtr 4 3.9% 0.0% 56 0 1,438 31.7% 416 126 1,312 

Total 5.7% 1.1% 357 4 6,284 25.5% 1,449 601 5,683 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 5.4% 0.0% 74 0 1,377 35.3% 448 109 1,268 

Calendar Qtr 2 7.6% 2.8% 145 4 1,903 10.1% 184 77 1,826 

Calendar Qtr 3 5.2% 0.0% 65 0 1,250 31.7% 375 66 1,184 

Calendar Qtr 4 3.9% 0.0% 54 0 1,400 31.6% 403 126 1,274 

Total 5.7% 1.2% 338 4 5,930 25.4% 1,410 378 5,552 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 24 0.0% 0 0 24 

Calendar Qtr 1 0.0% 0.0% 0 0 12 33.3% 4 0 12 

Calendar Qtr 2 2.6% 0.0% 1 0 38 22.7% 5 16 22 

Calendar Qtr 3 6.6% 0.0% 16 0 242 48.6% 17 207 35 

Calendar Qtr 4 5.3% 0.0% 2 0 38 34.2% 13 0 38 

Total 5.4% 0.0% 19 0 354 29.8% 39 223 131 

Total Coliform and Chlorine Residual Data for All Airlines by Region 

Region 2 10.3% 0.0% 7 0 68 28.3% 17 8 60 

Region 4 14.0% 0.0% 156 0 1,114 21.4% 233 23 1,091 

Region 5 2.4% 0.0% 18 0 742 9.2% 56 132 610 

Region 6 Region 6 3.7% 3.1% 128 4 3,466 32.6% 1,057 225 3,241 Region 9 9.2% 0.0% 35 0 381 23.8% 86 20 361 Region 10 2.5% 0.0% 13 0 513 0.0% 0 193 320 Total 5.7% 1.1% 357 4 6,284 25.5% 1,449 601 5,683 

Total Coliform and Chlorine Residual Data for All Airlines by Sample Location 

Galley 1.3% 8.6% 35 3 2,715 24.4% 611 208 2,507 

Lavatory 9.0% 0.3% 290 1 3,227 26.9% 765 379 2,848 

Composite* 9.6% 0.0% 32 0 334 21.6% 69 14 320 Unknown Sample Site 0.0% 0.0% 0 0 8 50.0% 4 0 8 

Total 5.7% 1.1% 357 4 6,284 25.5% 1,449 601 5,683 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP by Sample Location 

Galley 1.1% 10.3% 29 3 2,547 24.2% 593 95 2,452 

Lavatory 9.1% 0.4% 277 1 3,045 26.9% 748 269 2,776 

Composite* 9.6% 0.0% 32 0 334 21.6% 69 14 320 Unknown Sample Site 0.0% 0.0% 0 0 4 0.0% 0 0 4 

Total 5.7% 1.2% 338 4 5,930 25.4% 1,410 378 5,552 

*Composite sample of 

Galley and Lavatory sources. 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit B.5 Montioring Period for All Years (2005-2008): Sampling Data for All Airlines 

All Samples 

Percent TC+ Of the TC+ 

samples, 

percent EC+ 

or FC+ 

Total # of 

TC+ samples 

Total # TC+ 

samples that 

are EC+ or 

FC+ 

Total # of TC 

Samples 

Percent CL2 

Residual Nondetect 

Total # of CL2 

Residual Nondetect 

Total # of 

Disinfection 

Unknown 

Total # of CL2 

Residual 

Samples 

Total Coliform and Chlorine Residual Data for All Airlines 

Unknown Calendar Qtr 0.0% 0.0% 0 0 92 3.7% 2 38 54 

Calendar Qtr 1 3.7% 2.8% 177 5 4,766 25.4% 1,025 725 4,041 

Calendar Qtr 2 4.5% 3.1% 355 11 7,852 11.2% 792 802 7,050 

Calendar Qtr 3 5.2% 1.0% 197 2 3,769 32.9% 1,008 705 3,064 

Calendar Qtr 4 4.0% 4.7% 148 7 3,677 23.8% 728 619 3,058 

Total 4.4% 2.9% 877 25 20,156 20.6% 3,555 2,889 17,267 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 0 0.0% 0 0 0 

Calendar Qtr 1 3.8% 2.3% 174 4 4,522 22.8% 864 725 3,797 

Calendar Qtr 2 4.5% 3.2% 343 11 7,544 9.3% 632 784 6,760 

Calendar Qtr 3 4.5% 0.0% 144 0 3,180 30.2% 813 488 2,692 

Calendar Qtr 4 4.0% 5.0% 140 7 3,478 21.6% 618 618 2,860 

Total 4.3% 2.7% 801 22 18,724 18.2% 2,927 2,615 16,109 

Total Coliform and Chlorine Residual Data for Airlines with Unapproved QAPP & CRMP 

Unknown Calendar Qtr 0.0% 0.0% 0 0 92 3.7% 2 38 54 

Calendar Qtr 1 1.2% 33.3% 3 1 244 66.0% 161 0 244 

Calendar Qtr 2 3.9% 0.0% 12 0 308 55.2% 160 18 290 

Calendar Qtr 3 9.0% 3.8% 53 2 589 52.4% 195 217 372 

Calendar Qtr 4 4.0% 0.0% 8 0 199 55.6% 110 1 198 

Total 5.3% 3.9% 76 3 1,432 54.2% 628 274 1,158 

Total Coliform and Chlorine Residual Data for All Airlines by Region 

Region 2 6.6% 10.5% 19 2 290 24.5% 68 12 278 

Region 4 6.6% 1.2% 345 4 5,233 15.2% 786 78 5,155 

Region 5 1.8% 0.9% 113 1 6,121 5.1% 198 2,254 3,867 

Region 6 Region 6 4.8% 4.2% 288 12 6,051 31.8% 1,853 225 5,826 Region 9 5.3% 7.3% 82 6 1,547 44.0% 650 69 1,478 

Region 10 3.3% 0.0% 30 0 914 0.0% 0 251 663 Total 4.4% 2.9% 877 25 20,156 20.6% 3,555 2,889 17,267 

Total Coliform and Chlorine Residual Data for All Airlines by Sample Location 

Galley 1.0% 11.1% 90 10 8,939 20.1% 1,667 659 8,280 

Lavatory 7.0% 2.0% 752 15 10,803 21.0% 1,811 2,159 8,644 

Composite* 9.7% 0.0% 33 0 341 22.4% 73 15 326 Unknown Sample Site 2.7% 0.0% 2 0 73 23.5% 4 56 17 

Total 4.4% 2.9% 877 25 20,156 20.6% 3,555 2,889 17,267 

Total Coliform and Chlorine Residual Data for Airlines with Approved QAPP & CRMP by Sample Location 

Galley 0.9% 11.8% 76 9 8,242 17.3% 1,336 520 7,722 

Lavatory 6.9% 1.9% 690 13 10,072 18.9% 1,518 2,024 8,048 

Composite* 9.7% 0.0% 33 0 341 22.4% 73 15 326 Unknown Sample Site 2.9% 0.0% 2 0 69 0.0% 0 56 13 

Total 4.3% 2.7% 801 22 18,724 18.2% 2,927 2,615 16,109 

*Composite sample of 

Galley and Lavatory sources. 
Appendix C
 

Cost Model
 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Section 

Number 

Section Title Exhibit Title Exhibit 

Number 

C.0 Assumptions 

Implementation

C.1 and Annual 

Administration 

Assumptions C.0 

Air Carrier Burden and Cost Estimates for Implementation (2008$) C.1a 

Agency Burden and Cost Estimates for Implementation (2008$) C.1b 

Agency Burden and Cost Estimates for Annual Administrative Activities (2008$) C.1c 

C.2 Monitoring Plan 

Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 1 C.2a 

Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 2 C.2b 

Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 3 C.2c 

Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 1 C.2d 

Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 2 C.2e 

Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternative 3 C.2f 

C.3 Coliform 

Monitoring 

Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1 C.3a 

Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2 C.3b 

Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3 C.3c 

Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1 C.3d 

Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2 C.3e 

Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3 C.3f 

C.4 

Disinfectant 

Residual 

Monitoring 

Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1 C.4a 

Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2 C.4b 

Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3 C.4c 

Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1 C.4d 

Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2 C.4e 

Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3 C.4f 

C.5 Turbidity 

Monitoring 

Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1 C.5a 

Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2 C.5b 

Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3 C.5c 

Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1 C.5d 

Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2 C.5e 

Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3 C.5f 

C.6 Nitrate/Nitrite 

Monitoring 

Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1 C.6a 

Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2 C.6b 

Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3 C.6c 

Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1 C.6d 

Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2 C.6e 

Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3 C.6f 

C.7 O&M Plan 

Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 1 C.7a 

Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 2 C.7b 

Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternative 3 C.7c 

Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 1 C.7d 

Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 2 C.7e 

Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 3 C.7f 

C.8 

Routine 

Disinfection and 

Flushing 

Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1 C.8a 

Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2 C.8b 

Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3 C.8c 

Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1 C.8d 

Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2 C.8e 

Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3 C.8f 

C.9 

Corrective 

Action 

Disinfection and 

Flushing 

Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 

1 C.9a 

Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 

2 C.9b 

Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 

3 C.9c 

C.10 

Sanitary 

Survey/Complia 

nce Audit 

Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1 C.10a 

Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 2 C.10b 

Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 3 C.10c 

Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1 C.10d 

Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 2 C.10e 

Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 3 C.10f 

Page C-1
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Section 

Number 

Section Title Exhibit Title Exhibit 

Number 

C.11 Rule Schedule Rule Schedule C.11 

C.12 Nominal Costs 

Nominal Rule Activity Costs for Alternative 1, by Year C.12a 

Nominal Air Carrier Activity Costs for Alternative 1, by Year C.12b 

Nominal Agency Activity Costs for Alternative 1, by Year C.12c 

Nominal Rule Activity Costs for Alternative 2, by Year C.12d 

Nominal Air Carrier Activity Costs for Alternative 2, by Year C.12e 

Nominal Agency Activity Costs for Alternative 2, by Year C.12f 

Nominal Rule Activity Costs for Alternative 3, by Year C.12g 

Nominal Air Carrier Activity Costs for Alternative 3, by Year C.12h 

Nominal Agency Activity Costs for Alternative 3, by Year C.12i 

Nominal Rule Activity Costs for Alternative 4 (Final Rule), by Year C.12j 

Nominal Air Carrier Activity Costs for Alternative 4 (Final Rule), by Year C.12k 

Nominal Agency Activity Costs for Alternative 4 (Final Rule), by Year C.12l 

C.13 Present Value 

at 3 Percent 

Present Value of Rule Activity Costs for Alternative 1 at 3 Percent, by Year C.13a 

Present Value of Air Carrier Activity Costs for Alternative 1 at 3 Percent, by Year C.13b 

Present Value of Agency Activity Costs for Alternative 1 at 3 Percent, by Year C.13c 

Present Value of Rule Activity Costs for Alternative 2 at 3 Percent, by Year C.13d 

Present Value of Air Carrier Activity Costs for Alternative 2 at 3 Percent, by Year C.13e 

Present Value of Agency Activity Costs for Alternative 2 at 3 Percent, by Year C.13f 

Present Value of Rule Activity Costs for Alternative 3 at 3 Percent, by Year C.13g 

Present Value of Air Carrier Activity Costs for Alternative 3 at 3 Percent, by Year C.13h 

Present Value of Agency Activity Costs for Alternative 3 at 3 Percent, by Year C.13i 

Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year C.13j 

Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year C.13k 

Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 3 Percent, by Year C.13l 

C.14 Present Value 

at 7 Percent 

Present Value of Rule Activity Costs for Alternative 1 at 7 Percent, by Year C.14a 

Present Value of Air Carrier Activity Costs for Alternative 1 at 7 Percent, by Year C.14b 

Present Value of Agency Activity Costs for Alternative 1 at 7 Percent, by Year C.14c 

Present Value of Rule Activity Costs for Alternative 2 at 7 Percent, by Year C.14d 

Present Value of Air Carrier Activity Costs for Alternative 2 at 7 Percent, by Year C.14e 

Present Value of Agency Activity Costs for Alternative 2 at 7 Percent, by Year C.14f 

Present Value of Rule Activity Costs for Alternative 3 at 7 Percent, by Year C.14g 

Present Value of Air Carrier Activity Costs for Alternative 3 at 7 Percent, by Year C.14h 

Present Value of Agency Activity Costs for Alternative 3 at 7 Percent, by Year C.14i 

Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year C.14j 

Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year C.14k 

Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 7 Percent, by Year C.14l 

C.15 Summary 

Summary of Rule Costs (Millions of 2008$) C.15a 

Summary of Rule Costs (Millions of 2008$), Alternative 1 C.15b 

Summary of Rule Costs (Millions of 2008$), Alternative 2 C.15c 

Summary of Rule Costs (Millions of 2008$), Alternative 3 C.15d 

Summary of Rule Costs (Millions of 2008$), Alternative 4 (Final Rule) C.15e 

Page C-2
C.0 Assumptions
 

Page C-3
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

C.0 Assumptions 

Alt 1 (Current Regulations) Alt 2 (AOCs) Alt 3 (WSG 29) Alt 4 (F

Implementation & Annual Administration 

Identical for all alternatives 

Monitoring Plan Develop Sample Siting Plan to include sample 

collection locations (all air carriers). 

Develop QAPP, Develop Montoring Plan (all air carriers). 

Develop Monitoring Plan (50% of air carriers). Develop Sampling Plan per ADWR requirem

Agency (all air carriers). 

O&M Plan Not required Not required 50% of air carriers will develop O&M plans in 

lieu of required monitoring. 

Update existing O&M manual and practices statement to Agency indicating that O&M ma

Coliform Monitoring 1) One TC sample collected monthly/aircraft. 

2) 15% TC+. 3) 4% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling. 4) Four repeat samples collected within 24 hours of notification of TC+. 5) Four additional coliform samples collected per aircraft with routine coliform monitoring TC+ (assume no waivers). 6) No post disinfection monitoring samples collected. 

1) One galley and one lavatory TC sample collected annually/aircraft. 2) 3.6% TC+. 3) 5.7% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling. 4) Four repeat samples collected within 24 hours of notification of TC+. 5) No additional colform samples collected. 6) Four corrective action follow-up samples collected per aircraft with positive routine coliform monitoring sample that undergoes corrective action disinfection and flushing. 

1) One TC sample collected quarterly/aircraft not implementing O&M plan. Assuming 50% of aircraft implement O&M plan. 2) 3.6% TC+. 3) 5.7% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling. 4) Repeat monitoring not specified, assumed no repeat monitoring samples. 4) No additional coliform samples collected. 5) No corrective action follow-up samples collected. 

1) One galley and one lavatory TC sample cannually, 30% quarterly, and 10% monthly. 2) 3.6% TC+. 3) 5.7% of aircraft performing repeat samplirepeat sampling. 4) 0% of aircraft performing annual routine ctwice annual routine coliform monitoring, 50coliform monitoring, and 46% of aircraft perfwith TC+ will collect three repeat samples woption to immediate corrective action. 5) No additional coliform samples collected. 6) Two corrective action follow-up samples taction flushing and disinfecting. 

Disinfectant Residual Monitoring 

Collected monthly at same locations as routine coliform monitoring samples. 

Collected annually at 1 lavatory and 1 galley on each aircraft. 

Not required Not required 

Turbidity Monitoring Not required Not required Daily/aircraft. Assuming 50% of aircraft 

implement O&M plan. 

Not required 

Nitrate/Nitrite Monitoring Not required Not required Not required Not required 

Routine Disinfection & Flushing 

1) Not required 2) Self-certification not required 

1) Quarterly/aircraft 2) Quarterly self-certification 

1) Quarterly/aircraft 2) Self-certification not required 

1) 30% quarterly, 30% thrice annually, 30% 2) Self-certification not required 

Corrective Action Disinfection & Flushing 

Not required After TC+ After TC+ 1) 100% of aircraft performing annual routin

performing twice annual routine coliform moroutine coliform monitoring, and 54% of aircmonitoring perform corrective action disinfecAssume the remainder of aircraft will perform 2) EPA assumes the corrective action disinfconducted during routine disinfection and flutherefore, would not incur separate costs for events other than the cost of collection, shipsamples required as part of corrective action3) EPA assumes that of the aircraft with a pothe aircraft performing annual, twice annual, aircraft performing monthly monitoring will ncost for corrective action disinfection and flu

Sanitary Survey/Compliance Audit 

EPA performs surveys. Only recordkeeping burden for aircraft. 

Not required Not required EPA performs compliance audit. Aircraft con

deficiencies. 
C.1 Implementation and 

Annual Administration
 

Page C-5
Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor B

(hours) 

A B C=A*B D=B*63 

Read and Understand Rule $42.86 8 $ 343 Train Personnel $42.86 8 $ 343 

16 $ 686 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.1a Air Carrier Burden and Cost Estimates for Implementation (2008$

Total Notes: (1) Detail may not add due to independent rounding. (2) Air carrier burden and cost estimates for Implementation activities are assumed to be identical for Alternatives 1-3 and the Final Rule.Sources:(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor cainspectors are assumed to have a technical background, as well as some management or oversight responsibility.(B) Labor hours for start-up activities reflect EPA estimate.(D), (E) National totals for all 63 U.S. air carriers subject to ADWR to perform implementation activities. Assumes all air carriers spend equaimplementation activities, regardless of fleet size or aircraft type.
40 2,006 $ 

283 14,191 $ 2,

400 

830 

800 

Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/Region) Unit Cost 

Total Labor 

Burden (hours) 

A B C=A*B D=B*10 

Read and Understand Rule $50.14 8 $ 401 80 

Program Development $50.14 40 2,006 $ 400 

Modify/Develop Data Management Systems $50.14 115 5,767 $ 1,150 

Air Carrier Training and Technical Assistance $50.14 80 4,012 $ 

Staff Training $50.14 

Notes: (1) Detail may not add due to independent rounding. 

(2) Agency burden and cost estimates for Implementation activities are assumed to be identical for Alternatives 1-3 and the Final Rule. 

Sources:(A) Agency labor costs from Section 5.2.1(B) Labor hours for start-up activities reflect EPA estimate.

(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spenimplementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.1b Agency Burden and Cost Estimates for Implementation (2008$) 

Total 
16 $ 802 160 

516 25,874 $ 5,160 

Compliance Activity 

Labor Cost 

($/hour) 

Labor 

(hours/Region/year) Cost ($/year) 

Total Labor 

Burden 

(hours/year) 

A B C=A*B D=B*10 

Lab Certification $50.14 - $ - - Ongoing Technical Assistance $50.14 500 25,072 $ 5,000 

Staff Training $50.14 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.1c Agency Burden and Cost Estimates for Annual Administrative Activities 

Total 

Notes: (1) Detail may not add due to independent rounding. (2) Agency burden and cost estimates for annual administrative activities are assumed to be identical for Alternatives 1-3 and the Final Rule

(3) No costs are associated with lab certification under the ADWR because it is not anticipated that the Agency will need to oversee lab certiaddition to what is being done for the Total Coliform Rule.

Sources:(A) Agency labor costs from Section 5.2.1.(B) Labor hours for start-up activities reflect EPA estimate.

(D), (E) National totals for Agency (EPA Regions) to implement ADWR for 63 U.S. air carriers subject to ADWR. Assumes each region spenimplementation activities, regardless of number of air carriers headquartered in their region, air carrier fleet size or aircraft type.
C.2 Monitoring Plan
 

Page C-9
Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor Bur

(hours) 

A B C=A*B D=B*63 

Develop Sample Siting Plan to include sample collection locations $42.86 10 $ 429 

Total 10 $ 429 

Sources: 

(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor categor

inspectors are assumed to have a technical background, as well as some management or oversight responsibility.

(B) Labor hours for developing sampling siting plans reflect EPA estimate.(D), (E) Assume all 63 U.S. air carriers subject to ADWR will develop sample siting plans. Assumes all air carriers spend equal time developing anregardless of fleet size or aircraft type.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.2a Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alterna
Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor Bu

(hours) 

A B C=A*B D=B*63 

Develop QAPP $42.86 10 $ 429 

ng Plan $42.86 10 $ 429 

20 $ 857 

Develop Monitori 

Total 

Sources: 

(A) Air carrier labinspectors are as

(B) Labor hours f(D), (E) Assume monitoring plans,

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.2b Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Altern

or costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor categ

sumed to have a technical background, as well as some management or oversight responsibility.

or developing QAPP and monitoring plans reflect EPA estimate.

all 63 U.S. air carriers subject to ADWR will develop QAPPs and monitoring plans. Assumes all air carriers spend equal time de

 regardless of fleet size or aircraft type.
Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor Bu

(hours) 

A B C=A*B D=B*(63/2

ring Plan $42.86 10 $ 429

10 $ 429 

Develop Monito

Total 

Sources: 

(A) Air carrier lainspectors are a

(B) Labor hours

r

) 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.2c Air Carrier Burden and Cost Estimates for Monitoring Plan (2008$), Alterna

bor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor categor

ssumed to have a technical background, as well as some management or oversight responsibility.

 for developing monitoring plans reflect EPA estimate.

(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop monitoring plans. Assumes all air carriers spend equal time developregardless of fleet size or aircraft type.
Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor B

(hours) 

A B C=A*B D=B*63 

Review Air Carrier Sample Siting Plan $50.14 5 $ 251Total 5 $ 251 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing sample siting plan reflect EPA estimate.(D), (E) Assume all 63 U.S. air carriers subject to ADWR will develop sample siting plans. Assumes Agency spends equal time reviewing air carregardless of fleet size or aircraft type.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.2d Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternat
Total 5 $ 251 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing QAPP and monitoring plan reflect EPA estimate.(D), (E) Assume all 63 U.S. air carriers subject to ADWR will develop QAPPs and monitoring plans. Assumes Agency spends equal time reviemonitoring plans, regardless of fleet size or aircraft type.

wi

Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor B

(hours)

A B C=A*B D=B*63

Review Air Carrier QAPP $50.14 5 $ 251

Review Air Carrier Monitoring Plan $50.14 5 $ 251 

u

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.2e Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alterna
Compliance Activity 

Labor Cost 

($/hour) 

One-time labor burden 

(hours/air carrier) Unit Cost 

Total Labor

(hour

A B C=A*B D=B*(6

Review Air Carrier Monitoring Plan $50.14 5 $ 251Total 5 $ 251 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing monitoring plans reflect EPA estimate.(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop monitoring plans. Assumes Agency spends equal time reviewing air 

regardless of fleet size or aircraft type.

 Bu

s) 3/2

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.2f Agency Burden and Cost Estimates for Monitoring Plan (2008$), Alternativ
C.3 Coliform Monitoring
 

Page C-16
7,327 36,411 87,924 13,189 528 52,754 211,018 0 175,848 6,027,042 $ 0 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) One TC sample collected monthly per aircraft. (E) Assume 15% of coliform samples will be TC+. (F) Assume 4% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling. (G) Four repeat samples collected within 24 hours of notification of TC+. (H) Four additional routine coliform monitoring samples collected per aircraft with positive routine coliform monitoring sample in the month following notification of TC+. Assume no systems receive waiver. (I) Post disinfection monitoring not specified, assumed no follow-up samples collected. (J) Assume 0.5 hour for sample collection and for process, storage, and shipping of sample. (Sample set burden is 0.5 hour for (1) routine samples, 2 hours for (4) repeat samples, and 0 hour for (0) corrective action follow-up samp(M) Assume all analysis conducted by outside lab. (O) Estimated courier fees based on costs from various courier services in major cities. Assumed courier services required for each sample set. (Sample set consists of 1 routine samples, and 4 repeat samples. Assumed airport disreturn cooler to air carrier. 100% of shipping costs incurred by TC monitoring, since residual samples are analyzed immediately and do not require shipping, turbidity samples are not required under Alt. 1, and the space required to (Q) Average coliform analysis costs based on costs from various labs across the country. Assume all analysis conducted by outside lab.(S) Assume air carriers will replace coolers, gel packs, and thermometers once a year. 100% of the unit equipment cost is incurred by total coliform monitoring, since residual samples are immediately read and will not require shipp(T) Coolers, gel packs, and thermometers are purchased by air carriers. The costs for this equipment are assumed to be distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(U) Assume each air carrier will purchase three new refrigerators. 100% of the refrigerator cost is incurred by total coliform monitoring, since disinfectant residual monitoring does not require the use of a refrigerator. (V) Refrigerators are purchased by air carriers. Assume costs for 63 airlines are distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(W), (X), (Y) Based on EPA estimate.(Y) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, this reporting burden is captured in Year 3 and follows the same schedule as coliform monitoring.(Z) Assume burden for 63 airlines is distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(AA) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.(AB) Columns W and X applied on a sample set basis. Assume a sample set consists of (1) routine sample, (4) repeat samples, and (0) corrective action follow-up samples.

les.) 

tance of 20-30 miles f

ship annual nitrate/nitr

ing in a cooler.

A B C=B*A D=12*B E=D*0.15 F=E*0.04 G=E*4 H=G*4 I J K=J(D+G+H+I) L=K*AA M N=M(D+G+H+I) 

1 381 381 4,572 686 27 2,743 10,973 - 0.5 9,144 313,403 $ 0 - 2 2,080 4,160 24,960 3,744 150 14,976 59,904 - 0.5 49,920 1,710,966 $ 0 - 

3 756 2,268 9,072 1,361 54 5,443 21,773 - 0.5 18,144 621,870 $ 0 - 4 421 1,684 5,052 758 30 3,031 12,125 - 0.5 10,104 346,306 $ 0 - 

5 956 4,780 11,472 1,721 69 6,883 27,533 - 0.5 22,944 786,386 $ 0 - 6 871 5,226 10,452 1,568 63 6,271 25,085 - 0.5 20,904 716,467 $ 0 - 

7 298 2,086 3,576 536 21 2,146 8,582 - 0.5 7,152 245,129 $ 0 - 

8 809 6,472 9,708 1,456 58 5,825 23,299 - 0.5 19,416 665,467 $ 0 - 

> 9 755 9,354 9,060 1,359 54 5,436 21,744 - 0.5 18,120 621,048 $ 0 - 

Total 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3a Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1 

TC Samples TC Sampling Analys

Corrective Action 

Coliform Follow-

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Routine Coliform 

Monitoring 

(samples/year) 

Routine Coliform 

Monitoring TC+ 

(samples/year) 

Additional TC+ 

(samples/year) 

Repeat 

(samples/year) 

Additional 

Routine Coliform 

Monitoring 

(samples/year) 

up Sample (postdisinfection 

sample) 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Sampling 

Cost ($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden 

(hours/year) 

U

C
AC=

4,004 $ 

21,858 $ 

7,945 $ 

B=((W+X)* 

+G/4+H/4))+Z AB*A

137,2

749,1

272,2

$34.27 $34.27 $34.27 $34.27 4,424 $ $34.27 10,046 $ 

AA 

A

A Q R=Q(D+G+H+I) S T U V W X Y Z (D A AD=K

$22.16 405,307 $ 219 $ 717 $ 597 $ 1,956 0.25 0.25 1.00 3.28 26 $22.16 2,212,700 $ 219 $ 3,917 $ 597 $ 10,677 0.25 0.25 1.00 17.88 61 

$22.16 804,231 $ 219 $ 1,424 $ 597 $ 3,881 0.25 0.25 1.00 6.50 91 

$22.16 447,859 $ 219 $ 793 $ 597 $ 2,161 0.25 0.25 1.00 3.62 151,633 

$22.16 1,016,991 $ 219 $ 1,800 $ 597 $ 4,907 0.25 0.25 1.00 8.22 344,326 

1 2 3 4 5 6 $22.16 926,568 $ 219 $ 1,640 $ 597 $ 4,471 0.25 0.25 1.00 7.49 $34.27 9,153 313,711 $ 

7 $22.16 317,012 $ 219 $ 561 $ 597 $ 1,530 0.25 0.25 1.00 2.56 $34.27 3,132 107,332 $ 8 $22.16 860,613 $ 219 $ 1,523 $ 597 $ 4,153 0.25 0.25 1.00 6.96 $34.27 8,501 291,380 $ > 9 $22.16 803,167 $ 219 $ 1,422 $ 597 $ 3,876 0.25 0.25 1.00 6.49 $34.27 7,934 271,931 $ Total $ 7,794,448 $ 13,797 $ 37,611 63 $ 2,638,990 2

hours/year) Cost 

Labor Recor

($/yea

dkeep

ling Points Cost ($/sample) Cost ($/year) carrier/year) ($/year) carrier) ($) set) set) (hours/air carrier) (hours/year) /hour) (

or Cost 

($ r) (hour

ab

and Reporting 

Analysis Recordkeeping 

# of Available 

Samp

Unit Analysis Total Analysis 

Annual Unit 

Equipment Cost 

($/air 

Total Annual 

Equipment Cost 

Periodic 

Equipment 

Cost ($/air 

Total Periodic 

Equipment Cost 

Maintain 

Maintenance Log 

(hours/sample 

Report 

Monitoring 

Results 

(hours/sample 

Report Water 

System 

Inventory/Changes 

Report Water 

System 

Inventory/Changes 

Burden L

Recordkeeping 

ing Total 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3a Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 1 (cont'd) 
ear) 

Monitoring 

(samples/year) 

monitoring) 

(samples/year) 

Burden 

(hours/sample) 

Burden 

(hours/year) 

Total Sampling 

Cost ($/year) 

Burden 

(hours/sample) 

B

(ho

H I J K=J(D+G+H+I) L=K*AA M N=M

110 0 110 0.5 491 $ 16,819 0 

Sampling 

Points # of Aircraft 

Available 

Sampling Points 

Monitoring 

(samples/year) 

Monitoring TC+ 

(samples/year) 

Additional TC+ (samples/year) 

Repeat

(samples/y

A B C=B*A D E=D*0.036 F=E*0.057 G=E*4 

1 381 381 762 27 2 2 2,080 4,160 4,160 150 9 599 0 599 0.5 2,679 $ 91,822 0 

3 756 2,268 1,512 54 3 218 0 218 0.5 974 $ 33,374 0 4 421 1,684 842 30 2 121 0 121 0.5 542 $ 18,585 0 5 956 4,780 1,912 69 4 275 0 275 0.5 1,231 $ 42,203 0 6 871 5,226 1,742 63 4 251 0 251 0.5 1,122 $ 38,450 0 7 298 2,086 596 21 1 86 0 86 0.5 384 $ 13,155 0 

8 809 6,472 1,618 58 3 233 0 233 0.5 1,042 $ 35,713 0 

> 9 755 9,354 1,510 54 3 217 0 217 0.5 972 $ 33,330 0 

Total 7,327 36,411 14,654 528 30 2,110 0 2,110 9,437 323,451 $ 

TC Sampling 

 Routine 

orm 

Corrective Action 

Coliform Follow-up 

Sample (postdisinfection Sampling Labor Total Sampling Analysis Labor Tota

Additional Colif 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. 

(D) One galley and one lavatory TC sample collected annually per aircraft. 

(E) Assume 3.6% of coliform samples will be TC+ based on AOC data. (F) Assume 5.7% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling (based on AOC data). (G) Four repeat samples collected within 24 hours of notification of TC+. Assume aircraft with less than four sampling points collect a total of 400mL of samples from all available sampling points. (H) Additional routine coliform monitoring not specified, assumed no additional routine coliform monitoring samples collected. (I) Four follow-up samples collected per aircraft with positive routine coliform monitoring sample that undergoes corrective action disinfection and flushing. (J) Assume 0.5 hour for sample collection and for process, storage, and shipping of sample. (Sample set burden is 1 hour for (2) routine samples, 2 hours for (4) repeat samples, and 2 hour for (4) corrective action follow-up samples.) (M) Assume all analysis conducted by outside lab. 

(O) Estimated courier fees based on costs from various courier services in major cities. Assumed courier services required for each sample set. (Sample set consists of 2 routine samples, 4 repeat samples, and 4 corrective action follow-up sampleslab. Assumed courier would return cooler to air carrier. 100% of shipping costs incurred by TC monitoring, since residual samples are analyzed immediately and do not require shipping.

(Q) Average coliform analysis costs based on costs from various labs across the country. Assume all analysis conducted by outside lab.(S) Assume air carriers will replace coolers, gel packs, and thermometers once a year. 100% of the unit equipment cost is incurred by total coliform monitoring, since residual samples are immediately read and will not require shipping in a cooler.(T) Coolers, gel packs, and thermometers are purchased by air carriers. The costs for this equipment are assumed to be distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(U) Assume each aircraft will purchase three new refrigerators. 100% of the refrigerator cost is incurred by total coliform monitoring, since disinfectant residual monitoring does not require the use of a refrigerator.(V) Refrigerators are purchased by air carriers. Assume costs for 63 airlines are distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(W), (X), (Y) Based on EPA estimate.(Y) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, this reporting burden is captured in Year 3 and follows the same schedule as coliform monitoring.(Z) Assume burden for 63 airlines is distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(AA) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.(AB) Columns W and X applied on a sample set basis. Assume a sample set consists of (2) routine samples, (4) repeat samples, and (4) corrective action follow-up samples.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3b Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2 

TC Samples 

# of Available Total # of Routine Coliform Routine Coliform 
A Q R=Q(D+G+H+I) S T U V W X Y Z AA 

AB=((W+X)* 

(D/2+G/4+H+I/4))+ 

Z A

1 $22.16 21,751 $ 219 $ 717 $ 597 $ 1,956 0.25 0.25 1.00 3.28 $34.27 221 $ 2 $22.16 118,748 $ 219 $ 3,917 $ 597 $ 10,677 0.25 0.25 1.00 17.88 $34.27 1,208 

$ 

3 $22.16 43,160 $ 219 $ 1,424 $ 597 $ 3,881 0.25 0.25 1.00 6.50 $34.27 439 

$ 

4 $22.16 24,035 $ 219 $ 793 $ 597 $ 2,161 0.25 0.25 1.00 3.62 $34.27 244 $ 

5 $22.16 54,579 $ 219 $ 1,800 $ 597 $ 4,907 0.25 0.25 1.00 8.22 $34.27 555 

$ 

6 $22.16 49,726 $ 219 $ 1,640 $ 597 $ 4,471 0.25 0.25 1.00 7.49 $34.27 506 

$ 

7 $22.16 17,013 $ 219 $ 561 $ 597 $ 1,530 0.25 0.25 1.00 2.56 $34.27 173 $ 

8 $22.16 46,186 $ 219 $ 1,523 $ 597 $ 4,153 0.25 0.25 1.00 6.96 $34.27 470 $ 

> 9 $22.16 43,103 $ 219 $ 1,422 $ 597 $ 3,876 0.25 0.25 1.00 6.49 $34.27 438 

$ 

Total $ 418,302 $ 13,797 $ 37,611 63 $ 

Analysis Recordkeeping 

# of Available 

Sampling 

Points 

Unit Analysis 

Cost ($/sample) 

Total Analysis 

Cost ($/year) 

Annual Unit 

Equipment Cost 

($/air carrier/year) 

Total Annual 

Equipment Cost 

($/year) 

Periodic 

Equipment 

Cost ($/air 

carrier) 

Total Periodic 

Equipment Cost 

($) 

Maintain 

Maintenance Log 

(hours/sample set) 

Report Monitoring 

Results 

(hours/sample set) 

Report Water 

System 

Inventory/Changes 

(hours/air carrier) 

Report Water System 

Inventory/Changes 

Burden (hours/year) 

Labor Cost 

($/hour) 

Recordkeeping 

and Reporting 

Labor 

(hours/year) 

Rec

Co

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3b Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 2 (cont'd) 
0.5 

0.5 

0.5 

0.5 

0.5 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) One TC sample collected quarterly per aircraft not implementing O&M plan. Assuming 50% of aircraft implement O&M plan. (E) Assume 3.6% of coliform samples will be TC+ based on AOC data. (F) Assume 5.7% of aircraft with initial TC+ samples will have at least one additional TC+ during repeat sampling (based on AOC data). (G) Repeat monitoring not specified in Water Supply Guidance 29, assumed no repeat monitoring samples. (H) Additional routine coliform monitoring not specified, assumed no additional routine coliform monitoring samples collected. (I) Post disinfection monitoring not specified, assumed no follow-up samples collected. (J) Assume 0.5 hour for sample collection and for process, storage, and shipping of sample. (Sample set burden is 0.5 hour for (1) routine samples, 0 hours for (0) repeat samples, and 0 hour for (0) corrective action follow-up samples.) (M) Assume all analysis conducted by outside lab. (O) Estimated courier fees based on costs from various courier services in major cities. Assumed courier services required for each sample set. (Sample set consists of 1 routine sample.) Assumed airport distance of 20-30 miles from lab. Assumed shipping costs incurred by TC monitoring, since quarterly turbidity samples will not take up a significant amount of space, and residual samples are analyzed immediately and do not require shipping, and nitrate/nitrite monitoring is not required unde(Q) Average coliform analysis costs based on costs from various labs across the country. Assume all analysis conducted by outside lab.(S) Assume air carriers will replace coolers, gel packs, and thermometers once a year. 100% of the unit equipment cost is incurred by total coliform monitoring, since quarterly turbidity samples will not take up a significant amount of space, residual sshipping in a cooler, and nitrate/nitrite monitoring is not required under Alt.3.(T) Coolers, gel packs, and thermometers are purchased by air carriers. The costs for this equipment are assumed to be distributed evenly across the 7,327 aircraft. Fr oses only.(U) Assume each aircraft will purchase three new refrigerators. 100% of the refrigerator cost is incurred total coliform monitoring, since quarterly turbidity samples will n nfectant residual monitoring does nomonitoring is not required under Alt.3.

(V) Refrigerators are purchased by air carriers. Assume costs for 63 airlines are distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation p

(W), (X), (Y) Based on EPA estimate.(Y) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, this reporting burden is captured in oliform monitoring.(Z) Assume burden for 63 airlines is distributed evenly across the 7,327 aircraft. Fractional burden is shown for calculation purposes only.(AA) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.(AB) Columns W and X applied on a sample set basis. Assume a sample set consists of (1) routine samples, (0) repeat samples, (0) corrective action follow-up samples

urposes only.

 Year 3 and follows the same schedule as c

actional burden is shown for calculation purp

ot take up a significant amount of space, disi

A B C=B*A D = 4*B*0.5 E=D*0.036 F=E*0.057 G H I J K=J(D+G+H+I) L=K*AA M 

1 381 381 762 27 2 0 0 -

0.5 

381 $ 13,058 0 

2 2,080 4,160 4,160 150 9 0 0 -

0.5 

2,080 $ 71,290 0 

3 756 2,268 1,512 54 3 0 0 -

0.5 

756 $ 25,911 0 

4 421 1,684 842 30 2 0 0 -

0.5 

421 $ 14,429 0 

5 956 4,780 1,912 69 4 0 0 - 956 $ 32,766 0 6 871 5,226 1,742 63 4 0 0 - 871 $ 29,853 0 

7 298 2,086 596 21 1 0 0 - 298 $ 10,214 0 

8 809 6,472 1,618 58 3 0 0 - 809 $ 27,728 0 

> 9 755 9,354 1,510 54 3 0 0 - 755 $ 25,877 0 

Total 7,327 36,411 14,654 528 30 0 0 0 7,327 251,127 $ 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3c Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3 

TC Samples TC Sampling 

# of Available 

Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Routine Coliform 

Monitoring 

(samples/year) 

Routine Coliform 

Monitoring TC+ 

(samples/year) 

Additional TC+ (samples/year) 

Repeat 

(samples/year) 

Additional Routine 

Coliform Monitoring 

(samples/year) 

Corrective Action 

Coliform Follow-up 

Sample (postdisinfection sample) 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Sampling 

Cost ($/year) 

Analysis Labor 

Burden 

(hours/sample) 
A Q R=Q(D+G+H+I) S T U V W X Y Z AA 

AB=((W+X)* 

(D+H)+Z A

1 $22.16 16,888 $ 219 $ 717 $ 597 $ 1,956 0.25 0.25 1.00 3.28 $34.27 384 $ 

2 $22.16 92,196 $ 219 $ 3,917 $ 597 $ 10,677 0.25 0.25 1.00 17.88 $34.27 2,098 $ 

3 $22.16 33,510 $ 219 $ 1,424 $ 597 $ 3,881 0.25 0.25 1.00 6.50 $34.27 763 $ 4 $22.16 18,661 $ 219 $ 793 $ 597 $ 2,161 0.25 0.25 1.00 3.62 $34.27 425 $ 

5 $22.16 42,375 $ 219 $ 1,800 $ 597 $ 4,907 0.25 0.25 1.00 8.22 $34.27 964 $ 6 $22.16 38,607 $ 219 $ 1,640 $ 597 $ 4,471 0.25 0.25 1.00 7.49 $34.27 878 $ 

7 $22.16 13,209 $ 219 $ 561 $ 597 $ 1,530 0.25 0.25 1.00 2.56 $34.27 301 $ 

8 $22.16 35,859 $ 219 $ 1,523 $ 597 $ 4,153 0.25 0.25 1.00 6.96 $34.27 816 $ 

> 9 $22.16 33,465 $ 219 $ 1,422 $ 597 $ 3,876 0.25 0.25 1.00 6.49 $34.27 761 $ 

Total $ 324,769 $ 13,797 $ 37,611 63 $ 

Analysis Recordkeeping 

# of Available 

Sampling 

Points 

Unit Analysis 

Cost ($/sample) 

Total Analysis 

Cost ($/year) 

Annual Unit 

Equipment Cost 

($/air carrier/year) 

Total Annual 

Equipment Cost 

($/year) 

Periodic 

Equipment 

Cost ($/air 

carrier) 

Total Periodic 

Equipment Cost 

($) 

Maintain 

Maintenance Log 

(hours/sample set) 

Report Monitoring 

Results 

(hours/sample set) 

Report Water 

System 

Inventory/Changes 

(hours/air carrier) 

Report Water 

System 

Inventory/Changes 

Burden (hours/year) 

Labor Cost 

($/hour) 

Recordkeeping 

and Reporting 

Labor 

(hours/year) 

Rec

Co

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3c Air Carrier Burden and Cost Estimates for Coliform Monitoring (2008$), Alternative 3 (cont'd) 
Compliance Activity A B C=A*B D 

Review Aircraft Monitoring Results $50.14 0.5 $ 25 6

Review Aircraft Water System Inventory/Changes $50.14 0.5 $ 25 

Total 0.5 $ 25 6

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3d Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Alte

TC Samples 

Labor Cost 

($/hour) 

Unit labor burden 

(hours/TC+ sample) 

Unit Cost ($/TC+ 

sample) 

Total Lab

Burden (ho

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. (D) Total labor burden = unit labor burden * total number of TC+ samples (Exhibit C.3a). Total labor burden for reviewing inventory = unit lab(E) Total cost = unit cost * total number of TC+ samples (Exhibit C.3a). Total cost for reviewing inventory = unit cost * total burden for review(F) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, burden aaircraft water system inventory/changes is captured in Year 3 and follows the same schedule as coliform monitoring. 
Compliance Activity A B C=A*B D 

Review Aircraft Monitoring Results $50.14 0.5 $ 25 26Review Aircraft Water System Inventory/Changes $50.14 0.5 $ 25 3Total 0.5 $ 25 26

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. (D) Total labor burden = unit labor burden * total number of TC+ samples (Exhibit C.3b). Total labor burden for reviewing inventory = unit labcarriers. (E) Total cost = unit cost * total number of TC+ samples (Exhibit C.3b). Total cost for reviewing inventory = unit cost * total burden for review(F) Air carriers must report their water system inventory within 18 months of promulgation of the Final Rule. For modeling purposes, burden areviewing aircraft water system inventory/changes is captured in Year 3 and follows the same schedule as coliform monitoring. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.3e Agency Burden and Cost Estimates for Coliform Monitoring (2008$), Altern

TC Samples 

Labor Cost 

($/hour) 

Unit labor burden 

(hours/TC+ sample) 

Unit Cost ($/TC+ 

sample) 

Total Labor 

Burden (hours
C.4 Residual Monitoring
 

Page C-25
A B C=B*A D=12*B E F=E*D G H I=H*D J K=J*D L 

1 381 381 4,572 0.5 2,286 78,351 $ 0.25 1,143 $ - - $2.

2 2,080 4,160 24,960 0.5 12,480 427,741 $ 0.25 6,240 $ - - $2.

8 809 6,472 9,708 0.5 4,854 166,367 $ 0.25 2,427 $ - -

> 9 755 9,354 9,060 0.5 4,530 155,262 $ 0.25 2,265 $ - -

Total 7,327 36,411 87,924 43,962 1,506,761 $ 21,981 $ -

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Disinfectant residual sample needed for each routine coliform monitoring sample. Disinfectant residual samples collected monthly, at same locations as routine coliform monitoring samples. (E) Assume one hour for sample collection and for process, storage, and shipping of sample. (H) Based on EPA estimate. (J) Assume disinfectant residual samples will be analyzed immediately and will not require shipping. (L) Cost of disinfectant residual sampling kit (see Exhibit 5.2). (N) Assume air carrier will replace coolers, gel packs, and thermometers once a year. Unit equipment cost is not incurred by disinfectant residual monitoring, since disinfectant residual monitoring samples are analyzed immediately and will not require shipping or storage. (P) Assume each air carrier will purchase three new refrigerators. Refrigerator cost is not incurred by disinfectant residual monitoring since residual samples are analyzed immediately and will not require shipping or storage. (R), (S), (T) Based on EPA estimate. EPA estimates that aircraft will not have significant inventory changes. (U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. (Z) Assumed that if a refrigerator is purchased, it purchased two times (in years years 3 and 13) in the 25-year evaluation period. 

M=L*D N 

96 13,533 $ -96 73,882 $ -

3 756 2,268 9,072 0.5 4,536 155,468 $ 0.25 2,268 $ - - $2.96 26,853 $ -4 421 1,684 5,052 0.5 2,526 86,577 $ 0.25 1,263 $ - - $2.96 14,954 $ -5 956 4,780 11,472 0.5 5,736 196,597 $ 0.25 2,868 $ - - $2.96 33,957 $ -6 871 5,226 10,452 0.5 5,226 179,117 $ 0.25 2,613 $ - - $2.96 30,938 $ -7 298 2,086 3,576 0.5 1,788 61,282 $ 0.25 894 $ - - $2.96 10,585 $ -

$2.96 28,736 $ -

$2.96 26,818 $ -

Disinfectant 

Residual Samples Disinfectant Residual Sampling Analysis 

# of Available 

Sampling Points # of Aircraft 

Total # of Available 

Sampling Points 

Disinfectant 

Residual 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Sampling 

Cost ($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden 

(hours/year) 

Unit Shipping 

Cost ($/year) 

Total Shipping 

Cost ($/year) 

Unit Analysis

Cost ($/sampl

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4a Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1 

e)

Total Analysis 

 Cost ($/year) c

Annual Unit 

Equipment 

Cost ($/air 

arrier/year) 

$ 260,255
Sampling Points Cost ($/year) ($/air carrier) ($) (hours/sample) (hours/sample) (hours/sample) ($/hour) (hours/year) Cost ($/year) (hours/year) 

A O P Q R S T U V=(R+S+T)*D W=U*V X=F+I+V

1 $ - $ - $ - 0.25 0.25 0.00 $34.27 2,286 $ 78,351 5,715 

2 $ - $ - $ - 0.25 0.25 0.00 $34.27 12,480 427,741 $ 31,200 

3 $ - $ - $ - 0.25 0.25 0.00 $34.27 4,536 155,468 $ 11,340 4 $ - $ - $ - 0.25 0.25 0.00 $34.27 2,526 $ 86,577 6,315 

5 $ - $ - $ - 0.25 0.25 0.00 $34.27 5,736 196,597 $ 14,340 

6 $ - $ - $ - 0.25 0.25 0.00 $34.27 5,226 179,117 $ 13,065 7 $ - $ - $ - 0.25 0.25 0.00 $34.27 1,788 $ 61,282 4,470 

8 $ - $ - $ - 0.25 0.25 0.00 $34.27 4,854 166,367 $ 12,135 

> 9 $ - $ - $ - 0.25 0.25 0.00 $34.27 4,530 155,262 $ 11,325 Total $ - $ - $ 1,506,761 109,905

Analysis Recordkeeping 

# of Available 

Total Annual 

Equipment 

Periodic 

Equipment Cost 

Total Periodic 

Equipment Cost 

Maintain 

Maintenance Log 

Report 

Monitoring 

Results 

Report Water 

System 

Inventory/Changes Labor Cost 

Recordkeeping 

Labor Recordkeeping Total Burden 

--------

-

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4a Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 1 (cont'd) 

Totals 

Total O&M Cost 

($/year) 

Total Capital Cost 

($) 

 Y=G+K+M+O+W Z=Q 

$ 170,235 $$ 929,365 $$ 337,788 $$ 188,107 $$ 427,150 $$ 389,171 $$ 133,149 $$ 361,469 $$ 337,341 $ -$ 3,273,776 $
# of Available 

Sampling 

Points # of Aircraft 

Total # of 

Available 

Sampling Points 

Disinfectant 

Residual 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Sampling 

Cost ($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden (hours/year) 

Unit Shipping 

Cost ($/year) 

Total Shipping 

Cost ($/year) 

Unit Analysis 

Cost ($/sample) 

A B C=B*A D E F=E*D G H I=H*D J K=J*D L 

1 381 381 762 0.5 381 $ 13,058 0.25 191 $ - - $2.9

2 2,080 4,160 4,160 0.5 2,080 71,290 $ 0.25 1040 $ - - $2.93 756 2,268 1,512 0.5 756 $ 25,911 0.25 378 $ - - $2.9

4 421 1,684 842 0.5 421 $ 14,429 0.25 211 $ - - $2.9

5 956 4,780 1,912 0.5 956 $ 32,766 0.25 478 $ - - $2.9

6 871 5,226 1,742 0.5 871 $ 29,853 0.25 436 $ - - $2.9

7 298 2,086 596 0.5 298 $ 10,214 0.25 149 $ - - $2.9

8 809 6,472 1,618 0.5 809 $ 27,728 0.25 405 $ - - $2.9

> 9 755 9,354 1,510 0.5 755 $ 25,877 0.25 378 $ - - $2.9

Total 7,327 36,411 14,654 7,327 251,127 $ 3664 $ -

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Disinfectant residual sample collected annually at 1 lavatory and 1 galley on each aircraft. (E) Assume one hour for sample collection and for process, storage, and shipping of sample. (H) Based on EPA estimate. (J) Assume disinfectant residual samples will be analyzed immediately and will not require shipping. (L) Cost of disinfectant residual sampling kit (see Exhibit 5.2). (N) Assume air carriers will replace coolers, gel packs, and thermometers once a year. Unit equipment cost is not incurred by disinfectant residual monitoring since disinfectant residual monitoring samples are analyzed immediately and will not requor storage. (P) Assume air carriers will purchase three new refrigerators. Refrigerator cost is not incurred by disinfectant residual monitoring since disinfectant residual samples are analyzed immediately and will not require shipping or storage. (R), (S), (T) Based on EPA estimate. EPA estimates that aircraft will not have significant inventory changes. (U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. (Z) Assumed that if a refrigerator is purchased, it purchased two times (in years years 3 and 13) in the 25-year evaluation period. 

Residual Samples Disinfectant Residual Sampling Analysis 

6 

An

quip

car

$ $ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4b Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2 

Disinfectant 

Total Analysis 

Cost ($/year) 

E

M=L*D 

2,256 

6 12,314 

6 4,476 

6 2,492 

6 5,660 

6 5,156 

6 1,764 

6 4,789 

6 4,470 

$ 43,376
Points ($/year) ($/air carrier) ($) (hours/sample) (hours/sample) s (hours/sample) ($/hour) (hours/year) Cost ($/year) (hours/year) 

A O P Q R S T U V=(R+S+T)*D W=U*V X=F+I+V

1 $ - $ - $ - 0.25 0.25 0.00 $34.27 381 $ 13,058 953 2 $ - $ - $ - 0.25 0.25 0.00 $34.27 2,080 $ 71,290 5,200 3 $ - $ - $ - 0.25 0.25 0.00 $34.27 756 $ 25,911 1,890 

4 $ - $ - $ - 0.25 0.25 0.00 $34.27 421 $ 14,429 1,053 5 $ - $ - $ - 0.25 0.25 0.00 $34.27 956 $ 32,766 2,390 6 $ - $ - $ - 0.25 0.25 0.00 $34.27 871 $ 29,853 2,178 7 $ - $ - $ - 0.25 0.25 0.00 $34.27 298 $ 10,214 745 8 $ - $ - $ - 0.25 0.25 0.00 $34.27 809 $ 27,728 2,023 

> 9 $ - $ - $ - 0.25 0.25 0.00 $34.27 755 $ 25,877 1,888 

Total $ - $ - $ 251,127 18,318 

Analysis Recordkeeping 

# of Available 

Sampling 

Total Annual 

Equipment Cost 

Periodic 

Equipment Cost 

Total Periodic 

Equipment Cost 

Maintain 

Maintenance Log 

Report Monitoring 

Results 

Report Water 

System 

Inventory/Change Labor Cost 

Recordkeeping 

Labor Recordkeeping Total Burden 

Total Capital Cost ($) 

Z=Q 

$ -

$ -

$ -

$ -

$ -

$ -$ -

$ -

$ -

$ -

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4b Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 2 (cont'd) 

Totals 

Total O&M Cost 

($/year) 

Y=G+K+M+O+W 

$ 28,372

$ 154,894

$ 56,298

$ 31,351

$ 71,192

$ 64,862$ 22,192

$ 60,245

$ 56,224

$ 545,629
Residual Samples Disinfectant Residual Sampling Residual Analysis 

# of Available 

Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Disinfectant 

Residual 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Sampling 

Cost ($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden (hours/year) 

Unit Shipping 

Cost ($/year) 

Total Shipping 

Cost ($/year) 

Unit Analysis 

Cost ($/sample)

A B C=B*A D E F=E*D G H I=H*D J K=J*D L 

1 381 381 - 0.5 - $ - 0.25 0 $ - - $2.92 2,080 4160 - 0.5 - $ - 0.25 0 $ - - $2.93 756 2268 - 0.5 - $ - 0.25 0 $ - - $2.9

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Disinfectant residual sampling not required under Alt. 3. (E) Assume one hour for sample collection and for process, storage, and shipping of sample. (H) Based on EPA estimate. (J) Shipping costs are not incurred by disinfectant residual monitoring since disinfectant residual monitoring is not required under Alt. 3. (L) Cost of disinfectant residual sampling kit (see Exhibit 5.2). (N) Assume air carriers will replace coolers, gel packs, and thermometers once a year. Unit equipment cost is not incurred by disinfectant residual monitoring since disinfectant residual monitoring is not required under Alt. 3. (P) Assume air carriers will purchase three new refrigerators. Refrigerator cost is not incurred by disinfectant residual monitoring since disinfectant residual monitoring is not required under Alt. 3. (R), (S), (T) Based on EPA estimate. EPA estimates that aircraft will not have significant inventory changes. (U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. (Z) Assumed that if a refrigerator is purchased, it purchased two times (in years years 3 and 13) in the 25-year evaluation period. 

4 421 1684 - 0.5 - $ - 0.25 0 $ - - $2.9

5 956 4780 - 0.5 - $ - 0.25 0 $ - - $2.9

6 871 5226 - 0.5 - $ - 0.25 0 $ - - $2.9

7 298 2086 - 0.5 - $ - 0.25 0 $ - - $2.9

8 809 6472 - 0.5 - $ - 0.25 0 $ - - $2.9

> 9 755 9354 - 0.5 - $ - 0.25 0 $ - - $2.9Total 7,327 36,411 0 0 $ - 0 $ -

Disinfectant 

6 6 6 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4c Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3 

Total Analysis 

Cost ($/year) 

M=L*D 

- - - 

6 - 6 - 6 - 

6 - 

6 - 6 - 

$ -
# of Available 

Sampling 

Points 

Total Annual 

Equipment Cost 

($/year) 

Periodic 

Equipment Cost 

($/air carrier) 

Total Periodic 

Equipment Cost 

($) 

Maintain 

Maintenance Log 

(hours/sample) 

Report Monitoring 

Results 

(hours/sample) 

Reporty Water 

System 

Inventory/Changes 

(hours/sample) 

Labor Cost 

($/hour) 

Recordkeeping 

Labor 

(hours/year) 

Recordkeeping 

Cost ($/year) 

Total Burden 

(hours/year) 

A O P Q R S T U V=(R+S+T)*D W=U*V X=F+I+V

1 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

2 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

3 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

4 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

5 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

6 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

7 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

8 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

> 9 $ - $ - $ - 0.25 0.25 0.00 $34.27 - $ - -

Total $ - $ - $ - 0 

Residual Analysis Recordkeeping 

$ -$ -

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4c Air Carrier Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$), Alternative 3 (cont'd) 

Totals 

Total O&M Cost 

($/year) 

Total Capital Cost 

($) 

Y=G+K+M+O+W Z=Q 

$ - $ -

$ - $ -

$ - $ -

$ - $ -

$ - $ -

$ - $ -

$ - $ -

$ - $ -

$ -$ -
Compliance Activity A B C=A*B D=B*7,32

Review Aircraft Monitoring Results $50.14 0.5 $ 25 3

Review Aircraft Water System Inventory/Changes $50.14 0.5 $ 25 

Total 0.5 $ 25 3

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D) Total labor burden = unit labor burden * total number of aircraft subject to ADWR . 

(E) Total cost = unit cost * total number of aircraft subject to ADWR . 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4d Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$

Disinfectant Residual Samples 

Labor Cost 

($/hour) 

Unit labor burden 

(hours/aircraft) 

Unit Cost 

($/aircraft) 

Total Lab

Burden (ho
($/hour) (h

A 

$50.14 

Compliance Activity 

ours/aircraft) ($/aircraft) Burden (hours

B C=A*B D=B*7,327 

Review Aircraft Monitoring Results 0.5 $ 25 3,66

Review Aircraft Water System Inventory/Changes $50.14 0.5 $ 25 -

Total 0.5 $ 25 3,66

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D) Total labor burden = unit labor burden * total number of aircraft subject to ADWR . 

(E) Total cost = unit cost * total number of aircraft subject to ADWR . 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4e Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$)

Disinfectant Residual Samples 

Labor Cost Unit labor burden Unit Cost Total Labor 
Compliance Activity A B C=A*B D 

Review Aircraft Monitoring Results $50.14 0.5 $ 25 

Review Aircraft Water System Inventory/Changes $50.14 0.5 $ 25 

Total 0.5 $ 25 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D), (E) Disinfectant Residual sampling not required under Alt. 3. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.4f Agency Burden and Cost Estimates for Disinfectant Residual Monitoring (2008$

Disinfectant Residual Samples 

Unit labor burden 

(hours/aircraft) 

Unit Cost 

($/aircraft) 

Total Labo

Burden (ho

Labor Cost 

($/hour) 
C.5 Turbidity Monitoring
 

Page C-35
Turbidity Samples Turbidity Sampling Analysis 

# of 

Available 

Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Turbidity 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Turbidity Sampling Cost 

($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden 

(hours/year) 

Unit Shipping 

Cost ($/sample) 

Total Shipping 

Cost ($/year) 

Total 

Cost 

A B C=B*A D E F=E*D G=F*T H I=H*D J K=J*D L

1 381 381 - 0.13 - $ - 0.13 - $ - - $ 

2 2,080 4,160 - 0.13 - $ - 0.13 - $ - - $ 

3 756 2,268 - 0.13 - $ - 0.13 - $ - - $ 

4 421 1,684 - 0.13 - $ - 0.13 - $ - - $ 

5 956 4,780 - 0.13 - $ - 0.13 - $ - - $ 

6 871 5,226 - 0.13 - $ - 0.13 - $ - - $ 

7 298 2,086 - 0.13 - $ - 0.13 - $ - - $ 

8 809 6,472 - 0.13 - $ - 0.13 - $ - - $ 

> 9 755 9,354 - 0.13 - $ - 0.13 - $ - - $ 

Total 7,327 36,411 - - $ - - $ - $ 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Turbidity sampling not required under Alt 1. (E) Assume 7.5 minutes for sample collection and in-house processing and storage of sample. (H) Based on EPA estimate. (R), (S) Based on EPA estimate. (T) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5a Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1 
Analysis Recordkeeping Totals 

# of 

Available 

Sampling 

Points 

Annual Unit 

Equipment Cost -

Secondary 

Standards ($/air 

carrier/year) 

Total Annual 

Equipment Cost 

($/year) 

Periodic 

Equipment Cost 

($/air carrier) 

Periodic 

Equipment 

Cost ($) 

Maintain 

Maintenance Log 

(hours/sample) 

Report Monitoring 

Results 

(hours/sample) 

Labor Cost 

($/hour) 

Recordkeeping 

Labor 

(hours/year) 

Recordkeeping 

Cost ($/year) 

Total Burden 

(hours/year) 

Total O&M Cost 

($/year) 

A N O P Q R S T U=(R+S)*D V=T*U W=F+I+U X=G+K+L+O+V 

1 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - 

2 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - 3 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - 4 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - 5 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - 6 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - 7 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - 8 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - > 9 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ - Total $ - -$ $ - - $ - 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5a Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 1 (cont'd) 
Turbidity Samples Turbidity Sampling Analysis 

# of 

Available 

Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Turbidity 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Turbidity 

Sampling Cost 

($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden 

(hours/year) 

Unit Shipping 

Cost ($/sample) 

Total Shipping 

Cost ($/year) 

A B C=B*A D E F=E*D G=F*T H I=H*D J K=J*D 

1 381 381 - 0.13 - $ - 0.13 - $ - - 

2 2,080 4,160 - 0.13 - $ - 0.13 - $ - - 

3 756 2,268 - 0.13 - $ - 0.13 - $ - - 

4 421 1,684 - 0.13 - $ - 0.13 - $ - - 

5 956 4,780 - 0.13 - $ - 0.13 - $ - - 

6 871 5,226 - 0.13 - $ - 0.13 - $ - - 

7 298 2,086 - 0.13 - $ - 0.13 - $ - - 

8 809 6,472 - 0.13 - $ - 0.13 - $ - - 

> 9 755 9,354 - 0.13 - $ - 0.13 - $ - - 

Total 7,327 36,411 - - $ - - $ - 

Notes: (C) Average number of available sampling points used for> 9 sampling points size category. 

(D) Turbidity sampling not required under Alt 2. (E) Assume 7.5 minutes for sample collection and in-house processing and storage of sample. (H) Based on EPA estimate. (R), (S) Based on EPA estimate. (T) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5b Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2 
 Unit 

t Cost -

dary Total Annu

# of 

Available 

Sampling 

Points 

Annual

Equipmen

Secon

Standards ($/air 

carrier/year) 

al 

Equipment Cost 

($/year) 

Periodic 

Equipment Cost 

($/air carrier) 

Periodic 

Equipment 

Cost ($) 

Maintain 

Maintenance Log 

(hours/sample) 

Report 

Monitoring 

Results 

(hours/sample) 

Labor Cost 

($/hour) 

Recordkeeping 

Labor 

(hours/year) 

Recordkeeping 

Cost ($/year) 

Total Burden 

(hours/year) 

Total O

($/

A N O P Q R S T U=(R+S)*D V=T*U W=F+I+U X=G+K

1 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 2 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 3 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 4 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 5 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 6 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 7 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 8 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ 

> 9 $ - $ - $ - -$ 0.25 0.25 $34.27 - $ - - $ Total $ - $ - $ - - $ 

Analysis Recordkeeping To

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5b Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 2 (cont'd) 
D 

------

--

Notes: (C) Average number of available sampling points used for> 9 sampling points size category. 

(D) One turbidity sample collected daily per aircraft not implementing O&M plan. Assuming 50% of aircraft implement O&M plan. (E) Assume 7.5 minutes for sample collection and in-house processing and storage of sample. (H) Based on EPA estimate. (J) Estimated courier fees based on costs from various courier services in major cities. Assumed airport distance of 20-30 miles from lab. Assumed courier would return cooler to air carrier. monitoring since the space taken up by turbidity sample is negligible. 100% of the courier cost is incurred by coliform monitoring.(M), (N) Assume air carrier will replace calibration kits and secondary standards once a year.(P) Assume each air carrier will purchase one turbidimeter every five years.(R), (S) Based on EPA estimate. (T) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1.(U) Assume air carriers perform reporting and recordkeeping activities on a monthly basis for each aircraft.

# of Available 

Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Turbidity 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total Turbidity 

Sampling Cost 

($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden 

(hours/year) 

Unit Shipping 

Cost ($/sample) 

Total Shipping 

Cost ($/year) 

A B C=B*A D=365*B*0.5 E F=E*D G=F*T H I=H*D J K=J*

1 381 381 69,533 0.13 8,692 297,896 $ 0.13 8,692 $ -2 2,080 4,160 379,600 0.13 47,450 1,626,309 $ 0.13 47,450 $ -3 756 2,268 137,970 0.13 17,246 591,101 $ 0.13 17,246 $ -4 421 1,684 76,833 0.13 9,604 329,171 $ 0.13 9,604 $ -5 956 4,780 174,470 0.13 21,809 747,477 $ 0.13 21,809 $ -6 871 5,226 158,958 0.13 19,870 681,017 $ 0.13 19,870 $ -

7 298 2,086 54,385 0.13 6,798 233,000 $ 0.13 6,798 $ -8 809 6,472 147,643 0.13 18,455 632,540 $ 0.13 18,455 $ -

> 9 755 9,354 137,788 0.13 17,223 590,319 $ 0.13 17,223 $ - -

Total 7,327 36,411 1,337,178 167,147 5,728,829 $ 167,147 $ 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5c Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3 

Turbidity Samples Turbidity Sampling Analysis 
g Standa

carrier/year) 

Cost 

($/year) 

Equipment Cost 

($/air carrier) 

Equipment 

Cost ($) 

Maintenance Log 

(hours/sample) 

Results 

(hours/sample) 

Labor Cost 

($/hour) 

Labor 

(hours/year) 

Recordkeeping 

Cost ($/year) 

Total Burden 

(hours/year) 

Tot

N O P Q R S T U=(R+S)*B*12 V=T*U W=F+I+U X=G

$ 124 $ 726 $ 858 $ 2,811 0.25 0.25 $34.27 2,286 $ 78,351 19,669 $ 

Samplin rds ($/air Equipment 

Points

A 

1 2 $ 124 $ 3,965 $ 858 $ 15,345 0.25 0.25 $34.27 12,480 427,741 $ 107,380 

$ 

3 $ 124 $ 1,441 $ 858 $ 5,577 0.25 0.25 $34.27 4,536 155,468 $ 39,029 

$ 

4 $ 124 $ 802 $ 858 $ 3,106 0.25 0.25 $34.27 2,526 $ 86,577 21,734 $ 

5 $ 124 $ 1,822 $ 858 $ 7,053 0.25 0.25 $34.27 5,736 196,597 $ 49,354 

$ 

6 $ 124 $ 1,660 $ 858 $ 6,426 0.25 0.25 $34.27 5,226 179,117 $ 44,965 

$ 

7 $ 124 $ 568 $ 858 $ 2,198 0.25 0.25 $34.27 1,788 $ 61,282 15,384 $ 8 $ 124 $ 1,542 $ 858 $ 5,968 0.25 0.25 $34.27 4,854 166,367 $ 41,765 

$ 

> 9 $ 124 $ 1,439 $ 858 $ 5,570 0.25 0.25 $34.27 4,530 155,262 $ 38,977 

$ 

Total $ 13,966 $ 54,054 $ 1,506,761 378,256 

$ 

ble 

Annu

Equipm

Seco ual Periodic Periodic Maintain 

Report 

Monitoring Recordkeeping 

al Unit 

ent Cost -

ndary Total Ann

nalysis Recordkeeping 

# of Availa

A

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5c Air Carrier Burden and Cost Estimates for Turbidity Monitoring (2008$), Alternative 3 (cont'd) 
Compliance Activity 

($/hour) (hours/aircraft) ($/aircraft) (hours) 

A B C=A*B D 

Review Aircraft Monitoring Results $50.14 0.5 $ 25 

Total 0.5 $ 25 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D), (E) Turbidity monitoring not required under Alt 1. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5d Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alter

Turbidity Monitoring 

Labor Cost Unit labor burden Unit Cost Total Labor Bu
Total 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D), (E) Turbidity monitoring not required under Alt 2. 

Compliance Activity 

($/hour) (hours/aircraft) ($/aircraft) (hours) 

A B C=A*B D 

Review Aircraft Monitoring Results $50.14 0.5 $ 25

0.5 $ 25 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5e Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Altern

Turbidity Monitoring 

Labor Cost Unit labor burden Unit Cost Total Labor Burd
($/hour) (hours/aircraft) ($/aircraft) (hours) 

Compliance Activity A B C=A*B D=B*(7,327/2

Review Aircraft Monitoring Results $50.14 0.5 $ 25 2

Total 0.5 $ 25 2

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D) Total labor burden = unit labor burden * (total number of aircraft subject to ADWR/2)*12 monthly reports . 

(E) Total cost = unit cost * (total number of aircraft subject to ADWR/2)*12 monthly reports . 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.5f Agency Burden and Cost Estimates for Turbidity Monitoring (2008$), Alte

Turbidity Monitoring 

Labor Cost Unit labor burden Unit Cost Total Labor B
C.6 Nitrate/Nitrite Monitoring
 

Page C-45
Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Nitrate/Nitrite 

(samples/year) 

Burden 

(hours/sample) 

Burden 

(hours/year) 

Sampling Cost 

($/year) 

Burden 

(hours/sample) 

Burden 

(hours/year) 

Unit Shipping 

Cost ($/year) 

Total Shipp

Cost ($/ye

A B C=B*A D E F=E*D G H I=H*D J K=J*D 

1 381 381 - - $ - 0 - $ - 

2 2,080 4,160 - - $ - 0 - $ - 

3 756 2,268 - - $ - 0 - $ - 

4 421 1,684 - - $ - 0 - $ - 

5 956 4,780 - - $ - 0 - $ - 

1 

1 

1 

1 

1 

1 

1 

> 9 755 9,354 -

1 

- $ - 0 - $ - 

Total 7,327 36,411 0 0 $ - 0 $ 

Notes: (C) Average number of available sampling points used for> 9 sampling points size category. 

(D) Nitrate/nitrite sampling not required under Alt 1. (E) Assume one hour for sample collection and for process, storage, and shipping of sample. (H) Assume all analysis conducted by outside lab. (S), (T) Based on EPA estimate. (U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

1 

6 871 5,226 - - $ - 0 - $ - 

7 298 2,086 - - $ - 0 - $ - 

8 809 6,472 - - $ - 0 - $ - 

Nitrate/Nitrite Samples Nitrate/Nitrite Sampling Analysis 

# of Available Sampling Labor Total Sampling 

Total 

Nitrate/Nitrite Analysis Labor Total Analysis 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6a Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1 
Analysis Recordkeeping 

# of Available 

Sampling 

Points 

Total Analysis 

Cost ($/year) 

Annual Unit 

Equipment Cost 

($/year) 

Total Annual 

Equipment Cost 

($/year) 

One-time 

Equipment 

Cost ($) 

Total One-time 

Equipment Cost 

Maintain 

Maintenance Log 

(hours/sample) 

Report Monitoring 

Results 

(hours/sample) 

Labor Cost 

($/hour) 

Recordkeeping 

Labor 

(hours/year) 

Recordkeeping 

Cost ($/year) 

To

(h

A N=D*(L+M) O P=O*B Q R=Q*B S T U V=(S+T)*D W=U*V 

1 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 

2 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 

3 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 

4 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 5 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 6 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 

7 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 8 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - > 9 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 

Total $ - $ - $ - $ - 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6a Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 1 (co
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6b Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2 

Nitrate/Nitrite Samples Nitrate/Nitrite Sampling Analysis 

# of Available 

Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Nitrate/Nitrite 

(samples/year) 

Sampling Labor 

Burden 

(hours/sample) 

Total Sampling 

Burden 

(hours/year) 

Total 

Nitrate/Nitrite 

Sampling Cost 

($/year) 

Analysis Labor 

Burden 

(hours/sample) 

Total Analysis 

Burden 

(hours/year) 

Unit Shipping 

Cost ($/year) 

Total Shipp

Cost ($/yea

A B C=B*A D E F=E*D G H I=H*D J K=J*D 

1 381 381 - 1 - $ - 0 - $ - - 

2 2,080 4,160 - 1 - $ - 0 - $ - - 3 756 2,268 - 1 - $ - 0 - $ - - 

4 421 1,684 - 1 - $ - 0 - $ - - 

5 956 4,780 - 1 - $ - 0 - $ - - 

6 871 5,226 - 1 - $ - 0 - $ - - 

7 298 2,086 - 1 - $ - 0 - $ - - 

8 809 6,472 - 1 - $ - 0 - $ - - 

> 9 755 9,354 - 1 - $ - 0 - $ - - 

Total 7,327 36,411 0 0 $ - 0 $ -

Notes: (C) Average number of available sampling points used for> 9 sampling points size category. (D) Nitrate/nitrite sampling not required under Alt 2. (E) Assume one hour for sample collection and for process, storage, and shipping of sample. (H) Assume all analysis conducted by outside lab. (S), (T) Based on EPA estimate. (U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 
Analysis Recordkeeping 

# of Available 

Sampling 

Points 

Total Analysis 

Cost ($/year) 

Annual Unit 

Equipment Cost 

($/year) 

Total Annual 

Equipment Cost 

($/year) 

One-time 

Equipment 

Cost ($) 

Total One-time 

Equipment Cost 

Maintain 

Maintenance Log 

(hours/sample) 

Report Monitoring 

Results 

(hours/sample) 

Labor Cost 

($/hour) 

Recordkeeping 

Labor (hours/year) 

Recordkeeping 

Cost ($/year) 

Tot

(ho

A N=D*(L+M) O P=O*B Q R=Q*B S T U V=(S+T)*D W=U*V X

1 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 2 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 3 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 4 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 5 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 6 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 7 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 8 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - > 9 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - Total $ - $ - $ - $ - 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6b Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 2 (co
Points # of Aircraft Sampling Points (samples/year) (hours/sample) (hours/year) ($/year) (hours/sample) (hours/year) Cost ($/year) Cost ($/year

A B C=B*A D E F=E*D G H I=H*D J K=J*D 

1 381 381 - 1 - $ - 0 - $ - - 

Total 7,327 36,411 0 0 $ - 0 $ -

Notes: (C) Average number of available sampling points used for> 9 sampling points size category. (D) Nitrate/nitrite sampling not required under Alt 3. (E) Assume one hour for sample collection and for process, storage, and shipping of sample. (H) Assume all analysis conducted by outside lab. (S), (T) Based on EPA estimate. (U) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

2 2,080 4,160 - 1 - $ - 0 - $ - -

3 756 2,268 - 1 - $ - 0 - $ - -

4 421 1,684 - 1 - $ - 0 - $ - -

5 956 4,780 - 1 - $ - 0 - $ - -

6 871 5,226 - 1 - $ - 0 - $ - -

7 298 2,086 - 1 - $ - 0 - $ - -

8 809 6,472 - 1 - $ - 0 - $ - -

> 9 755 9,354 - 1 - $ - 0 - $ - - 

Nitrate/Nitrite Samples Nitrate/Nitrite Sampling Analysis 

# of Available 

Sampling Total # of Available Nitrate/Nitrite 

Sampling Labor 

Burden 

Total Sampling 

Burden 

Total 

Nitrate/Nitrite 

Sampling Cost 

Analysis Labor 

Burden 

Total Analysis 

Burden Unit Shipping Total Shippin

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6c Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3 
Points Cost ($/year) ($/year) ($/year) Cost ($) Equipment Cost (hours/sample) (hours/sample) ($/hour) Labor (hours/year) Cost ($/year) (hour

A N=D*(L+M) O P=O*B Q R=Q*B S T U V=(S+T)*D W=U*V X=F

1 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 2 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 

3 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 

4 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 

5 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 

6 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 

7 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 

8 - $ - $ - -$ $ - 0.25 0.25 $34.27 - $ - 

> 9 - $ - $ - $ - $ - 0.25 0.25 $34.27 - $ - 

Total $ - $ - $ - $ - 

Analysis Recordkeeping 

# of Available 

Sampling Total Analysis 

Annual Unit 

Equipment Cost 

Total Annual 

Equipment Cost 

One-time 

Equipment Total One-time 

Maintain 

Maintenance 

Log 

Report 

Monitoring 

Results Labor Cost Recordkeeping Recordkeeping Total 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6c Air Carrier Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alternative 3 (co
Compliance Activity 

($/hour) (hours/airc

A B 

Review Aircraft Monitoring Results $50.14 

Total 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D), (E) Nitrate/nitrite monitoring not required under Alt 1. 

raft) ($/aircraft) Burden (ho

C=A*B D 

0.5 $ 25

0.5 $ 25 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6d Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Al

Nitrate&Nitrite Monitoring 

Labor Cost Unit labor burden Unit Cost Total Lab
Compliance Activity A 

Review Aircraft Monitoring Results $50.14 Total Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. (D), (E) Nitrate/nitrite monitoring not required under Alt 2. 

($/hour) (hours/aircraft) ($/aircraft) Burden (hours

B C=A*B 

0.5 $ 25

0.5 $ 25 -

D 

-

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6e Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alte

Nitrate&Nitrite Monitoring 

Labor Cost Unit labor burden Unit Cost Total Labor 
Compliance Activity A B C=A*B D 

Review Aircraft Monitoring Results $50.14 0.5 $ 25 

Total 0.5 $ 25 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft monitoring results reflect EPA estimate. 

(D), (E) Nitrate/nitrite monitoring not required under Alt 3. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.6f Agency Burden and Cost Estimates for Nitrate/Nitrite Sampling (2008$), Alt

Nitrate&Nitrite Monitoring 

Labor Cost 

($/hour) 

Unit labor burden 

(hours/aircraft) 

Unit Cost 

($/aircraft) 

Total Labo

Burden (hou
C.7 O&M Plan
 

Page C-55
specific requirements $42.86 8

Total 80 

Sources: 

0 

(A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was

ight responsib

 the highest-paid technical labor ca

inspectors are assumed to have a technical background, as well as some management or overs ility. 

(B) Labor hours for developing and implementing O&M plan reflect EPA estimate. (D), (E) O&M plans not required under Alt 1. 

Compliance Activity 

Labor Cost 

($/hour) 

One-time Labor Burden 

(hours/air carrier)

A B 

Update existing O&M manual and practices with ADWR 

C=A*B 

$ 3,429

D 

otal Labo

(hou

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.7a Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alterna

 Unit Cost 

T

$ 3,429
Update existing O&M manual and practices with ADWR 

specific requirements $42.86 80

Total 80Sources: (A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it ware assumed to have a technical background, as well as some management or oversight responsibility(B) Labor hours for developing and implementing O&M plan reflect EPA estimate. (D), (E) O&M plans not required under Alt 2. 

as the hi

. 

ghest-paid technical labor categor

D 

Compliance Activity 

Labor Cost 

($/hour) 

One-time Labor Burden 

(hours/air carrier)

A B 

Total Labor B

(hours) 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.7b Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternativ

 Unit Cost 

C=A*B 

$ 3,429

$ 3,429
Compliance Activity ($/hour) (hours/air carrier) Unit Cost (hours) 

A B C=A*B D=B*(63/2)

Total 80 3,429 $ 2,5

Sources: (A) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highare assumed to have a technical background, as well as some management or oversight responsibility.(B) Labor hours for developing and implementing O&M plan reflect EPA estimate.(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop O&M plans in lieu of required monitoand implementing O&M plan, regardless of fleet size or aircraft type.

est-paid technical labor categor

ring. Assumes all air carriers sp

Update existing O&M manual and practices with ADWR specific requirements $42.86 80 3,429 $ 2,5

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.7c Air Carrier Burden and Cost Estimates for O&M Plan (2008$), Alternativ

Labor Cost One-time Labor Burden Total Labor Burd
Total 10 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing and approving O&M plan reflect EPA estimate. (D), (E) O&M plans not required under Alt 1. 

10 

C=A*B 

$ 501

Compliance Activity 

Labor Cost 

($/hour) 

One-time Labor Burden 

(hours/air carrier)

A B 

Review and approve O&M manual and practices $50.14 

Total Labor Bu

(hours) 

D 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.7d Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 

 Unit Cost 

$ 501
Total 10

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing and approving O&M plan reflect EPA estimate. (D), (E) O&M plans not required under Alt 2. 

10 

C=A*B 

$ 501

otal Labor 

(hour

D 

Compliance Activity 

Labor Cost 

($/hour) 

One-time Labor Burden 

(hours/air carrier)

A B 

Review and approve O&M manual and practices $50.14 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.7e Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 

Unit Cost 

T

$ 501
Total 10 $ 501 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing and approving O&M plan reflect EPA estimate.(D), (E) Assume 50% of the 63 U.S. air carriers subject to ADWR will develop O&M planreviewing and approving O&M plan, regardless of fleet size or aircraft type.

s in lieu of required monitoring. Assumes all Regional Age

Compliance Activity 

Labor Cost 

($/hour) 

One-time Labor Burden 

(hours/air carrier) Unit Cost 

Total Labor Bu

(hours) 

A B C=A*B D=B*(63/2

Review and approve O&M manual and practices $50.14 10 $ 501

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.7f Agency Burden and Cost Estimates for O&M Plan (2008$), Alternative 
C.8 Routine Disinfection and Flushing
 

Page C-62
Points # of Aircraft Sampling Points (aircraft/year) (aircraft/year) (hours/aircraft) (hours/aircraft) Cost ($/hour) Cost ($/hour) ($/applica

A B C=B*A D E F G H I J 

1 381 381 - - 5 0.5 $20.19 $65.42 $ 

2 2,080 4,160 - - 5 0.5 $20.19 $65.42 $ 

tion) 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. 

(D) Routine disinfection and flushing not required under Alt 1. (E) Self-certification submittal not required under Alt 1. (F) EPA estimate based on observation of flushing and disinfection practices. (G) Labor hours for self-certification reflects EPA estimate. (H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1. (I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1. (J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs). (M) Based on EPA estimate. (O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

3 756 2,268 - - 5 0.5 $20.19 $65.42 $ 

4 421 1,684 - - 5 0.5 $20.19 $65.42 $ 

5 956 4,780 - - 5 0.5 $20.19 $65.42 $ 

6 871 5,226 - - 5 0.5 $20.19 $65.42 $ 

7 298 2,086 - - 5 0.5 $20.19 $65.42 $ 

8 809 6,472 - - 5 0.5 $20.19 $65.42 $ 

> 9 755 9,354 - - 5 0.5 $20.19 $65.42 $ 

Total 7,327 36,411 - -

Routine Disinfection and Flushing 

# of Available 

Sampling 

Total # of 

Available 

Routine 

Disinfection and 

Flushing 

SelfCertification 

Routine 

Disinfection 

and Flushing 

Labor Burden 

Self 

Certification 

Labor Burden 

Unit 

Disinfection 

and Flushing Unit Self-Certification Unit Chemical Cos

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8a Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1 
Sampling 

Points 

Certification 

($/year) 

Activities Burden 

(hours/aircraft) 

Activities Burden 

(hours/year) 

Labor Cost 

($/hour) 

Activities 

Costs ($/year) 

Labor Burden 

(hours/year) 

Total O&M Cost

($/year) 

A L=E*G*I M N=D*M O P=N*O Q=(D*F)+(E*G) + N R=K+L+P 

---------

S 

1 $ - 0.25 - $34.27 $ - - $ 

2 $ - 0.25 - $34.27 $ - - $ 3 $ - 0.25 - $34.27 $ - - $ 4 $ - 0.25 - $34.27 $ - - $ 5 $ - 0.25 - $34.27 $ - - $ 6 $ - 0.25 - $34.27 $ - - $ 7 $ - 0.25 - $34.27 $ - - $ 8 $ - 0.25 - $34.27 $ - - $ > 9 $ - 0.25 - $34.27 $ - - $ Total $0 $ - 0 $ -

Recordkeeping Totals 

# of Available 

Total Cost for 

Self 

Maintain Maintenance 

Log for Disinfection 

Maintain Maintenance 

Log for Disinfection Recordkeeping 

Maintain 

Maintenance 

Log for 

Disinfection 

Total Routine 

Disinfection/Flushing 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8a Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 1 (cont'd) 

Total Capital 

Cost ($) 

$ -
Points # of Aircraft Sampling Points (aircraft/year) (aircraft/year) (hours/aircraft) (hours/aircraft) Cost ($/hour) ($/hour) ($/ap

A B C=B*A D=B*4 E=B*4 F G H I 

1 381 381 1,524 1524 5 0.5 $20.19 $65.42 $ 

2 2,080 4,160 8,320 8320 5 0.5 $20.19 $65.42 $ 

3 756 2,268 3,024 3024 5 0.5 $20.19 $65.42 $ 4 421 1,684 1,684 1684 5 0.5 $20.19 $65.42 $ 5 956 4,780 3,824 3824 5 0.5 $20.19 $65.42 $ 6 871 5,226 3,484 3484 5 0.5 $20.19 $65.42 $ 7 298 2,086 1,192 1192 5 0.5 $20.19 $65.42 $ 8 809 6,472 3,236 3236 5 0.5 $20.19 $65.42 $ > 9 755 9,354 3,020 3020 5 0.5 $20.19 $65.42 $ 

Total 7,327 36,411 29,308 29,308 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. 

Routine Disinfection and Flushing 

# of Available 

Sampling Total # of Available 

Routine 

Disinfection and 

Flushing Self-Certification 

Routine Disinfection 

and Flushing Burden 

Self Certification 

Labor Burden 

Unit Disinfection 

and Flushing 

Unit SelfCertification Cost Unit 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8b Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2 

(D) Quarterly routine disinfection and flushing required per aircraft. 

(E) Aircraft is required to submit self-certification quarterly. (F) EPA estimate based on observation of flushing and disinfection practices. (G) Labor hours for self-certification reflects EPA estimate. (H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1. (I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1. (J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs). (M) Based on EPA estimate. (O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 
# of Available 

Sampling 

Points 

Total Cost for 

Self 

Certification 

($/year) 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/aircraft) 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/year) 

Recordkeeping 

Labor Cost 

($/hour) 

Log for 

Disinfection 

Activities 

Costs ($/year) 

Total Routine 

Disinfection/Flushing

Labor Burden 

(hours/year) 

A L=E*G*I M N=D*M O P=N*O Q=(D*F)+(

1 $ 49,847 0.25 381 $34.27 13,058 $ 

2 $ 272,129 0.25 2,080 $34.27 71,290 $ 

3 $ 98,909 0.25 756 $34.27 25,911 $ 

4 $ 55,080 0.25 421 $34.27 14,429 $ 5 $ 125,075 0.25 956 $34.27 32,766 $ 6 $ 113,954 0.25 871 $34.27 29,853 $ 7 $ 38,988 0.25 298 $34.27 10,214 $ 

8 $ 105,843 0.25 809 $34.27 27,728 $ > 9 $ 98,778 0.25 755 $34.27 25,877 $ 

Total $958,602 $ 251,127 168,521

E*G) + N 

8,763 

47,840 

17,388 

9,683 

21,988 

20,033 

6,854 

18,607 

17,365 

R=K+L+P 

$ 218,413

$ 1,192,386

$ 433,386

$ 241,344

$ 548,039

$ 499,312

$ 170,832

$ 463,769

$ 432,813

S 

Total 

Capital 

Cost ($) 

-

Recordkeeping 

Maintain 

Maintenance 

Totals 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8b Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 2 (cont'd) 

Total O&M 

Cost ($/year) 

$ 4,200,295 $
# of Available 

Sampling 

Points # of Aircraft 

Total # of 

Available 

Sampling 

Points 

Routine 

Disinfection and 

Flushing 

(aircraft/year) 

SelfCertification 

(aircraft/year) 

Routine 

Disinfection and 

Flushing Burden 

(hours/aircraft) 

Self Certification 

Labor Burden 

(hours/aircraft) 

Unit 

Disinfection 

and Flushing 

Cost ($/hour) 

Unit SelfCertification Cost 

($/hour) 

Unit Chemical 

Costs 

($/app

A B C=B*A D = 4*B E F G H I 

1 381 381 1,524 0 5 0.5 $20.19 $65.42 $ 

2 2,080 4,160 8,320 0 5 0.5 $20.19 $65.42 $ 

3 756 2,268 3,024 0 5 0.5 $20.19 $65.42 $ 

4 421 1,684 1,684 0 5 0.5 $20.19 $65.42 $ 

lication) 

J 

1

1

1

1

1

1

1

1

1

7,327 36,411 29,308 0 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Quarterly routine disinfection and flushing per aircraft. Routine disinfection and flushing also required after any aircraft service or repairs. Asssame quarter as required routine disinfection and flushing. 

(E) Self-certification submittal not required under Alternative 3. (F) EPA estimate based on observation of flushing and disinfection practices. (G) Labor hours for self-certification reflects EPA estimate. (H) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1. (I) Based on costs for transportation, storage, and distribution managers from Exhibit 5.1. (J) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs(M) Based on EPA estimate. (O) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

ume aircraft service an

 $12 per 4 gallon jugs)

5 956 4,780 3,824 0 5 0.5 $20.19 $65.42 $ 

6 871 5,226 3,484 0 5 0.5 $20.19 $65.42 $ 

7 298 2,086 1,192 0 5 0.5 $20.19 $65.42 $ 

8 809 6,472 3,236 0 5 0.5 $20.19 $65.42 $ 

> 9 755 9,354 3,020 0 5 0.5 $20.19 $65.42 $ 

Total 

Routine Disinfection and Flushing 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8c Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3 
# of Available 

Sampling 

Points 

Total Cost for 

Self 

Certification 

($/year) 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/aircraft) 

Maintain Maintenance 

Log for Disinfection 

Activities Burden 

(hours/year) 

Recordkeeping 

Labor Cost 

($/hour) 

Log for 

Disinfection 

Activities 

Costs ($/year) 

Tot

Disinfection/Flushing

Labor Burden 

(hours/year) 

al Routine 

A L=E*G*I M N=D*M O P=N*O Q=(D*F)+(E*G) + N 

1 $ - 0.25 381 $34.27 13,058 $ 8

2 $ - 0.25 2,080 $34.27 71,290 $ 433 $ - 0.25 756 $34.27 25,911 $ 154 $ - 0.25 421 $34.27 14,429 $ 85 $ - 0.25 956 $34.27 32,766 $ 206 $ - 0.25 871 $34.27 29,853 $ 187 $ - 0.25 298 $34.27 10,214 $ 68 $ - 0.25 809 $34.27 27,728 $ 16> 9 $ - 0.25 755 $34.27 25,877 $ 15

Total $0 $ 251,127 153,867

,001 

,680 ,876 

,841 

,076 ,291 

,258 

,989 ,855 

$ 168,566

$ 920,257$ 334,478$ 186,263$ 422,964$ 385,357$ 131,844$ 357,927$ 334,035

Recordkeeping 

Maintain 

Maintenance 

Totals 

-$ 

Total Capital 

Cost ($) 

S 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8c Air Carrier Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), Alternative 3 

Total O&M Cost 

($/year) 

R=K+L+P 

$ 3,241,692
Compliance Activity 

($/hour) (hours/aircraft) ($/aircraft) (hours/year) 

A B C=A*B 

Review Aircraft Self-Certification $50.14 0.5 $ 25 -Total 0.5 $ 25 -

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft self-certification reflect EPA estimate. 

(D) Total labor burden = unit labor burden * number of aircraft submitting self-certification (Ex. C8a). (E) Total cost = unit cost * number of aircraft submitting self-certification (Ex. C8a). 

D 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8d Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), 

Routine Disinfection and Flushing 

Labor Cost Unit labor burden Unit Cost Total Labor Burden 
Compliance Activity 

($/hour) (hours/aircraft) ($/aircraft) (hours/year) 

A B C=A*B D 

Review Aircraft Self-Certification $50.14 0.5 $ 25 14,6

Total 0.5 $ 25

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft self-certification reflect EPA estimate. 

(D) Total labor burden = unit labor burden * number of aircraft submitting self-certification (Ex. C8b). (E) Total cost = unit cost * number of aircraft submitting self-certification (Ex. C8b). 

14,654 

54 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8e Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$), 

Routine Disinfection and Flushing 

Labor Cost Unit labor burden Unit Cost Total Labor Burden 
Total 0.5 $ 25

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for reviewing aircraft self-certification reflect EPA estimate. (D) Total labor burden = unit labor burden * number of aircraft submitting self-certification (Ex. C8c). (E) Total cost = unit cost * number of aircraft submitting self-certification (Ex. 8c). 

Compliance Activity 

($/hour) (hours/aircraft) ($/aircraft) (hours/year) 

A B C=A*B D 

Review Aircraft Self-Certification $50.14 0.5 $ 25

-

-

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.8f Agency Burden and Cost Estimates for Routine Disinfection and Flushing (2008$)

Routine Disinfection and Flushing 

Labor Cost Unit labor burden Unit Cost Total Labor Burden 
C.9 Corrective Action 

Disinfection and Flushing
 

Page C-72
Available 

mpling Points 

Flushi

(aircraft/

C=B*A D 

381 

ng 

year) 

and Flu

(aircraft/

E 

-

4,160 -2,268 -

1,684 -

4,780 -

shing 

year) 

Labor Burden 

(hours/aircraft) 

and Flushing 

Cost ($/hour) ($/ap

F G 

- 5 $20.19 $ 

- 5 $20.19 $ - 5 $20.19 $ 

- 5 $20.19 $ 

- 5 $20.19 $ 

Costs 

plication) 

infection

Costs

 and

 ($/y

D+E)*(F*G))+

Dis

H I=((

1

11

1 $0 

1 $0 

 Chemical Total Correctiv

0.25 -

0.25 -

1 $0 0.25 -

 Flushing 

ear) 

Activitie

(hours/

(D+E)*H) J

$0 

$0 $0 

ection 

urden 

raft) 

for Disinfection 

Activities Burden 

(hours/year) 

e Action Log for Disinf R

s B

airc

K=(D+E)*J 

0.25 -

0.25 -0.25 -

ecordkeeping 

Labor Cost 

($/hour) 

Log for Disinfection 

Activiti

($/y

Disinfection/Flus

L M=

$34.27 $ $34.27 $ 

$34.27 $ 

es Costs 

ear) 

Labor Burde

(hours/year) 

K*L N=((D+E)*F)+

-

-

-

-

-

-

-

Sa

Total # of Disinfection and Disinfe

pling 

ints # of Aircraft 

A B 

381 

# of Available ction and Flushing Disinfection Unit

Sam

Po

2,080 

1 

Total 7,327 36,411 - - $0 

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Corrective action disinfection and flushing not required under Alt 1. (E) Assumes first flushing/disinfecting is successful. (F) EPA estimate based on observation of flushing and disinfection practices. (G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1. (H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs). (J) Based on EPA estimate. (L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

23 756 

4 421 $34.27 $ 

5 956 $34.27 $ 

6 871 5,226 - - 5 $20.19 $ $34.27 $ 

7 298 2,086 - - 5 $20.19 $ 1 $0 0.25 - $34.27 $ 

8 809 6,472 - - 5 $20.19 $ 1 $0 0.25 - $34.27 $ -

> 9 755 9,354 - - 5 $20.19 $ 1 $0 0.25 - $34.27 $ -

Maintain Maintenance Maintenance Log 

Maintain 

Maintain Maintenance 

Total Correcti

Action 

Corrective Action Disinfection and Flushing Recordkeeping 

Corrective 

Action Repeat 

Corrective 

Action 

Disinfection Unit 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.9a Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 1 
tal coliform sample. Assu

(C) Average number of available sampling points used for > 9 sampling points size category. (D) Corrective action disinfection and flushing required after positive total coliform sample. Assume entire aircraft flushed if either lavatory or galley has a positive tomore than one TC+ per aircraft. (E) Assumes first flushing/disinfecting is successful. (F) EPA estimate based on observation of flushing and disinfection practices. (G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1. (H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs). (J) Based on EPA estimate. (L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

0.25 14 $34.27 $ 466

me 

0.25 15 $34.27 $ 499

755 9,354 54 0 5 $20.19 $ 1 $5,547 

7,327 36,411 528 0 $53,830 2

Notes: 

 of Available 

Sampling 

Points # of Aircraft 

Total # of Available 

Sampling Points 

Disinfection and 

Flushing 

(aircraft/year) 

Disinfection and 

Flushing 

(aircraft/year) 

Flushing Labor 

Burden 

(hours/aircraft) 

Unit Disinfection 

and Flushing 

Cost ($/hour) 

Unit Chemical 

Costs 

($/application) 

Recordkeeping 

Labor Cost 

($/hour) 

Log for Disinfection 

Activities Costs 

($/year) 

Disinfection/Flus

Labor Burden 

(hours/year) 

A B C=B*A D E F G H L M=K*L N=((D+E)*F

381 381 27 0 5 $20.19 $ 1 $34.27 $ 235

2,080 4,160 150 0 5 $20.19 $ 1 $15,281 0.25 37 $34.27 $ 1,283

Disinfection and 

Flushing Costs 

($/year) 

Burden 

(hours/aircraft 

) 

Activities 

Burden 

(hours/year) 

I=((D+E)*(F*G))+(D 

+E)*H) J K=(D+E)*J 

$2,799 0.25 7 

#

1

)+

23 756 2,268 54 0 5 $20.19 $ 1 $5,554 0.25 14 $34.27 $ 466

4 421 1,684 30 0 5 $20.19 $ 1 $3,093 0.25 8 $34.27 $ 260

5 956 4,780 69 0 5 $20.19 $ 1 $7,024 0.25 17 $34.27 $ 590

6 871 5,226 63 0 5 $20.19 $ 1 $6,399 0.25 16 $34.27 $ 537

7 298 2,086 21 0 5 $20.19 $ 1 $2,189 0.25 5 $34.27 $ 184

8 809 6,472 58 0 5 $20.19 $ 1 $5,944 

> 9 

Total 

Corrective Action Repeat Disinfection and Action Activities Disinfection Maintain Maintenance Action 

Total Corrective 

Log for 

Disinfection 

Maintenance 

Log for 

Corrective Action Disinfection and Flushing Recordkeeping 

Corrective Action 

Maintain 

Maintenance Maintain 

Total Correctiv

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.9b Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 2 
# of Available 

Sampling 

Points # of Aircraft 

Available 

Sampling 

Points 

Disinfection and 

Flushing 

(aircraft/year) 

Disinfection 

and Flushing 

(aircraft/year) 

Flushing Labor 

Burden 

(hours/aircraft) 

Unit Disinfection 

and Flushing 

Cost ($/hour) 

Unit Chemic

Costs 

($/applicatio

A B C=B*A D E F G H N=((D+E)*F)+

381 381 27 0 5 $20.19 $ 5

e 

ar) 

Disinfection/Flushin

Labor Burden 

(hours/year) 

ties 

en 

rcraft) 

Ac

(hours/year) ($/hour) 

enanc

ection

Activities Costs ($/ye

Disinfection 

tivities Burden 

Recordkeeping 

Labor Cost 

Maintain Maint

Log for Disinf

al 

n) 

Action Disinfection 

and Flushing 

Costs ($/year) 

Activi

Burd

(hours/ai

I=((D+E)*(F*G))+(D 

+E)*H) J K=(D+E)*J L M=K*L 

1 $2,799 0.25 7 $34.27 $ 23

1 $15,281 0.25 37 $34.27 $ 1,28

1 

2 2,080 4,160 150 0 5 $20.19 $ 3

3 756 2,268 54 0 5 $20.19 $ 1 $5,554 0.25 14 $34.27 $ 4664 421 1,684 30 0 5 $20.19 $ 1 $3,093 0.25 8 $34.27 $ 260

5 956 4,780 69 0 5 $20.19 $ 1 $7,024 0.25 17 $34.27 $ 5906 871 5,226 63 0 5 $20.19 $ 1 $6,399 0.25 16 $34.27 $ 5377 298 2,086 21 0 5 $20.19 $ 1 $2,189 0.25 5 $34.27 $ 184

809 6,472 58 0 5 $20.19 $ 1 $5,944 0.25 15 $34.27 $ 499 306 

755 9,354 54 0 5 $20.19 $ 1 $5,547 0.25 14 $34.27 $ 466 285 

7,327 36,411 528 0 $53,830 2,77

Notes: (C) Average number of available sampling points used for > 9 sampling points size category. (D) Corrective action disinfection and flushing required after positive total coliform sample. Assume entire aircraft flushed if either lavatory or galley has a positive total coliform sample. Assume no more than one TC+ per aircraft. (E) Assumes first flushing/disinfecting is successful. (F) EPA estimate based on observation of flushing and disinfection practices. (G) Based on costs for cleaners of vehicles and equipment from Exhibit 5.1. (H) Chemicals used for disinfection cost approximately $1 per application (based on 12.5% chlorine solution from Harcros Chemicals, which costs $12 per 4 gallon jugs). (J) Based on EPA estimate. (L) Based on technical labor costs for inspectors, testers, sorters, samplers, and weighers, from Exhibit 5.1. 

K 

144 786 286 

159 361 329 

113 

8 > 9 

Total 

Total # of Corrective Action Repeat 

Corrective Action 

Disinfection and 

Total Corrective 

Action 

ance 

or 

tion Mai

Maintain 

Total Corrective ntenance Log for 

Mainten

Log f

Disinfec

Corrective Action Disinfection and Flushing 

ain 

Recordkeeping 

Maint

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.9c Air Carrier Burden and Cost Estimates for Corrective Action Disinfection and Flushing (2008$), Alternative 3 
C.10 Sanitary Survey/
 

Compliance Audit
 

Page C-76
190.50 

1,040.00 

378.00 210.50 478.00 435.50 149.00 404.50 

$ 

$ $ 

$ 

$ $ 

$ 

$ 

> 9 755 9,354 $42.86 0.5 377.50 Total 7,327 36,411 3,664 

Sources: 

(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Transportation inspectobackground, as well as some management or oversight responsibility. (E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already conduct major maintenance checks, which include saniTherefore, with the exception of reporting and recordkeeping burden, no additional costs for sanitary surveys are incurred by air carriers under the ADWR. 

(F), (G) All aircraft undergo sanitary surveys once in 5 years. 

rs ar

tary s

e assumed to 

urvey compon

# o Aircraft 

Total # of 

Available 

Sampling Points 

Unit Labor Cost

($/hour) 

B C=B*A D 

# of 

 Unit labor burden 

(hours/aircraft) 

Total Labor Burden (hours/SS 

cycle) 

E F=B*E 

f Available Sampling Points 

A 

1 381 381 $42.86 0.5 2 2,080 4,160 $42.86 0.5 

3 756 2,268 $42.86 0.5 4 421 1,684 $42.86 0.5 

5 956 4,780 $42.86 0.5 

6 871 5,226 $42.86 0.5 

7 298 2,086 $42.86 0.5 

8 809 6,472 $42.86 0.5 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.10a Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1 

Reporting and Recordkeeping costs associated with 

Sanitary Survey of Aircraft PWS Total

Total O

$ 

$ 
# rcraft Sampling Points ($/hour) 

D 

# of Ai

B C=B*A 

Total # of 

Available Unit Labor Cost Unit labor burden 

(hours/aircraft) 

Total Labor Burde

(hours/year) 

E F 

381 381 $42.86 0.5 

 of Available Sampling Points 

A 

Total 7,327 36,411 

Sources: 

(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paid technical labor category. Tranassumed to have a technical background, as well as some management or oversight responsibility.

(E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already conduct major maintenance checks, every 5 years for each aircraft. Therefore, with the exception of reporting and recordkeeping burden, no additional costs for sanitary surveys are incurred (F), (G) Sanitary surveys not specified under Alternative 2. Assume no sanitary surveys conducted.

sportation i

which inclu

by air carrie

1 

2 2,080 4,160 $42.86 0.5 

3 756 2,268 $42.86 0.5 4 421 1,684 $42.86 0.5 5 956 4,780 $42.86 0.5 6 871 5,226 $42.86 0.5 7 298 2,086 $42.86 0.5 8 809 6,472 $42.86 0.5 > 9 755 9,354 $42.86 0.5 

Reporting and Recordkeeping costs associated with 

Sanitary Survey of Aircraft PWS 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.10b Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 
-

> 9 755 9,354 $42.86 0.5 -

Total 7,327 36,411 -

Sources: 

(D) Air carrier labor costs from Exhibit 5.1. EPA used the transportation inspector category because it was the highest-paassumed to have a technical background, as well as some management or oversight responsibility.

(E) Labor burden reflects EPA estimate for reporting and recordkeeping only. EPA assumes that air carriers already condevery 5 years for each aircraft. Therefore, with the exception of reporting and recordkeeping burden, no additional costs f(F), (G) Sanitary surveys not specified under Alternative 3. Assume no sanitary surveys conducted.

id technical labor category. Transportation i

uct major maintenance checks, which inclu

or sanitary surveys are incurred by air carrie

nsde 

rs 

-------

# o of Aircr# 

B 

2,080 4,160 

756 2,268 421 1,684 

aft Sampling Points (

C=B*A 

381 381 

f Available Sampling Points $/hour) (hours/aircraft) (hours/year) 

A D E F=B*E 

1 $42.86 0.5 2 $42.86 0.5 3 $42.86 0.5 4 $42.86 0.5 5 956 4,780 $42.86 0.5 6 871 5,226 $42.86 0.5 7 298 2,086 $42.86 0.5 8 809 6,472 $42.86 0.5 

Reporting and Recordkeeping costs associated with 

Sanitary Survey of Aircraft PWS 

Available Unit 

Total # of 

Labor Cost Unit labor burden 

Total Labor 

Burden 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.10c Air Carrier Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 3 
ampling Points 

C=B*A 

381 

4,160 

2,268 

Available Cost 

($/hour) 

Aircr

D 

$50.14 

$50.14 

$50.14 

# of Available 

 # of Aircraft S

B 

381 

2,080 

756 

421 1,684 

aft Distribution 

System 

Documentation/File 

Review 

Report 

Development Data Entry Travel 

Unit labor burden 

(hours/aircraft) 

Unit Cost 

Sampling Points ($/aircraft) 

A 

1 

2 

3 

E F G H I J=E+F+G+H+I K=D*J 

0.6 1.5 5.2 0.8 1.8 10 496 $ 

0.6 1.5 5.2 0.8 1.8 10 496 $ 

0.6 1.5 5.2 0.8 1.8 10 496 $ 

4 $50.14 0.6 1.5 5.2 0.8 1.8 10 496 $ 

5 956 4,780 $50.14 0.6 1.5 5.2 0.8 1.8 10 496 $ 

6 871 5,226 $50.14 0.6 1.5 5.2 0.8 1.8 10 496 $ 

Total Lab

(hours/S

L=

(C) Average number of available sampling points used for> 9 sampling points size categ

(D) Agency labor costs from Section 5.2.1.(E)-(I) Labor hours reflect sanitary survey estimates used in Ground Water Rule for tran ystems servi

ory. 

sient noncommunity water s ng less than 500 people.

(L), (M) National totals for Agency to conduct sanitary surveys for 7,327 aircraft subject to ADWR once every 5 years. Assumes Agency spends equal time conducting sanitary surveys of each aircraft, rega

Total 7,327 36,411 

7 298 2,086 $50.14 0.6 1.5 5.2 0.8 1.8 10 496 $ 

8 809 6,472 $50.14 0.6 1.5 5.2 0.8 1.8 10 496 $ 

> 9 755 9,354 $50.14 0.6 1.5 5.2 0.8 1.8 10 496 $ 

Conducting Sanitary Surveys of Aircraft PWSs 

Total # of Unit Labor Review/Inspect Report 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.10d Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 1 
Compliance Activity 

Labor Cost 

($/hour) 

Unit labor burden 

(hours/air carrier) 

A B 

anitary Survey of aircraft PWSs $50.14 

Total 16 Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for conducting sanitary survey reflect EPA estimate.(D), (E) Sanitary survey requirements are not specified for Alt. 2. Assumed no sanitary surveys conducted.

16 

C=A*B 

$ 802

D 

- $ - $ 

Total Labor Burden 

(hours/SS cycle) To

Conducting S

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.10e Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternativ

Unit Cost ($/air 

carrier) 

$ 802
anitary Survey of aircraft PWSs $50.14 16 

16 

Conducting S

Total 

Sources: (A) Agency labor costs from Section 5.2.1. (B) Labor hours for conducting sanitary survey reflect EPA estimate.(D), (E) Sanitary survey requirements are not specified for Alt. 3. Assumed no sanitary surveys conducte

Compliance Activity 

Labor Cost 

($/hour) 

Unit labor burden 

(hours/air carrier) 

A B C=A*B 

$ 802 - $ 

- $ 

Total Labor Burden 

(hours/SS cycle) 

D 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.10f Agency Burden and Cost Estimates for Sanitary Survey (2008$), Alternative 

Unit Cost ($/air 

carrier) 

$ 802

d.
C.11 Rule Schedule
 
Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

1 50% 50% 50% 2 50% 50% 50% 3 100% 100% 100% 100% 100% 100% 

4 100% 100% 100% 100% 100% 100% 

5 100% 100% 100% 100% 100% 100% 

6 100% 100% 100% 100% 100% 100% 

7 100% 100% 100% 100% 100% 100% 

8 100% 100% 100% 100% 100% 100% 

9 100% 100% 100% 100% 100% 100% 

10 100% 100% 100% 100% 100% 100% 11 100% 100% 100% 100% 100% 100% 12 100% 100% 100% 100% 100% 100% 13 100% 100% 100% 100% 100% 100% 14 100% 100% 100% 100% 100% 100% 15 100% 100% 100% 100% 100% 100% 16 100% 100% 100% 100% 100% 100% 17 100% 100% 100% 100% 100% 100% 18 100% 100% 100% 100% 100% 100% 19 100% 100% 100% 100% 100% 100% 20 100% 100% 100% 100% 100% 100% 21 100% 100% 100% 100% 100% 100% 22 100% 100% 100% 100% 100% 100% 23 100% 100% 100% 100% 100% 100% 24 100% 100% 100% 100% 100% 100% 25 100% 100% 100% 100% 100% 100% 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR. 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.11 Rule Schedule
C.12 Nominal Costs
 

Page C-85
Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Di

F

1 $ 0.09 $ - $ 0.02 $ - $ - $ - $ - $ - $ - $ 

2 $ 0.09 $ - $ 0.02 $ - $ - $ - $ - $ - $ - $ 

3 $ - $ 0.26 $ - $ 27.71 $ 3.46 $ - $ - $ - $ - $ 

4 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

5 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

6 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

7 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

8 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

9 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

10 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

11 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

12 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

13 $ - $ 0.26 $ - $ 27.71 $ 3.46 $ - $ - $ - $ - $ 

14 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

15 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

16 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

17 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

18 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

19 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

20 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

21 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

22 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

23 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

24 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

25 $ - $ 0.26 $ - $ 27.67 $ 3.46 $ - $ - $ - $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12a Nominal Rule Activity Costs for Alternative 1, by Year
Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

2 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

3 $ - $ - $ - $ 27.38 $ 3.27 $ - $ - -$ $ - $ 

4 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

5 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

6 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

7 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

8 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

9 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

10 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

11 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

12 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

13 $ - $ - $ - $ 27.38 $ 3.27 $ - $ - -$ $ - $ 

14 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

15 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

16 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

17 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

18 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

19 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

20 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

21 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

22 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

23 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

24 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

25 $ - $ - $ - $ 27.34 $ 3.27 $ - $ - -$ $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12b Nominal Air Carrier Activity Costs for Alternative 1, by Year
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12c Nominal Agency Activity Costs for Alternative 1, by Year 

Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.07 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

2 $ 0.07 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

3 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

4 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

5 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

6 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

7 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

8 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

9 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

10 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

11 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

12 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

13 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

14 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

15 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

16 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

17 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - $ - $ - $ 

18 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

19 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

20 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

21 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

22 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

23 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

24 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - -$ $ - $ 

25 $ - $ 0.26 $ - $ 0.33 $ 0.18 $ - $ - $ - $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12d Nominal Rule Activity Costs for Alternative 2, by Year

Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine 

Disinfection & 

Flushing 

CA D

F

1 $ 0.09 $ - $ 0.02 $ - $ - $ - $ - $ - $ - $ 

2 $ 0.09 $ - $ 0.02 $ - $ - $ - $ - $ - $ - $ 

3 $ - $ 0.26 $ - $ 1.85 $ 0.73 $ - $ - $ - $ 4.94 $ 

4 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

5 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

6 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

7 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

8 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

9 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

10 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

11 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

12 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

13 $ - $ 0.26 $ - $ 1.85 $ 0.73 $ - $ - $ - $ 4.94 $ 

14 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

15 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

16 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

17 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

18 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

19 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

20 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

21 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

22 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

23 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

24 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

25 $ - $ 0.26 $ - $ 1.82 $ 0.73 $ - $ - $ - $ 4.94 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.

2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

2 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

3 $ - $ - $ - $ 1.84 $ 0.55 $ - $ - -$ $ 4.20 $ 

4 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

5 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

6 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

7 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

8 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

9 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

10 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

11 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

12 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

13 $ - $ - $ - $ 1.84 $ 0.55 $ - $ - -$ $ 4.20 $ 

14 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

15 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

16 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

17 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - $ - $ 4.20 $ 

18 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

19 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

20 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

21 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

22 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

23 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

24 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - -$ $ 4.20 $ 

25 $ - $ - $ - $ 1.80 $ 0.55 $ - $ - $ - $ 4.20 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12e Nominal Air Carrier Activity Costs for Alternative 2, by Year
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12f Nominal Agency Activity Costs for Alternative 2, by Year 

Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.07 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

2 $ 0.07 $ - $ 0.01 $ - $ - $ - $ - -$ $ - $ 

3 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

4 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

5 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

6 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

7 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

8 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

9 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

10 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

11 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

12 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

13 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

14 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

15 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

16 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - $ - $ 0.73 $ 

17 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

18 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

19 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

20 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

21 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

22 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

23 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

24 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - $ - $ 0.73 $ 

25 $ - $ 0.26 $ - $ 0.01 $ 0.18 $ - $ - -$ $ 0.73 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine 

Disinfection & 

Flushing 

CA D

F

1 $ 0.09 $ - $ 0.01 $ - $ - $ - $ - $ 0.06 $ - $ 

2 $ 0.09 $ - $ 0.01 $ - $ - $ - $ - $ 0.06 $ - $ 

3 $ - $ 0.26 $ - $ 2.47 $ - $ 14.13 $ - $ - $ 3.24 $ 

4 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

5 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

6 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

7 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

8 $ - $ 0.26 $ - $ 2.43 $ - $ 14.13 $ - $ - $ 3.24 $ 

9 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

10 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

11 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

12 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

13 $ - $ 0.26 $ - $ 2.47 $ - $ 14.13 $ - $ - $ 3.24 $ 

14 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

15 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

16 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

17 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

18 $ - $ 0.26 $ - $ 2.43 $ - $ 14.13 $ - $ - $ 3.24 $ 

19 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

20 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

21 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

22 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

23 $ - $ 0.26 $ - $ 2.43 $ - $ 14.13 $ - $ - $ 3.24 $ 

24 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

25 $ - $ 0.26 $ - $ 2.43 $ - $ 14.08 $ - $ - $ 3.24 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12g Nominal Rule Activity Costs for Alternative 3, by Year
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12h Nominal Air Carrier Activity Costs for Alternative 3, by Year 

Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - $ 0.05 $ - $ 

2 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - $ 0.05 $ - $ 

3 $ - $ - $ - $ 2.46 $ - $ 13.03 $ - -$ $ 3.24 $ 

4 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

5 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

6 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

7 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

8 $ - $ - $ - $ 2.42 $ - $ 13.03 $ - -$ $ 3.24 $ 

9 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

10 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

11 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

12 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

13 $ - $ - $ - $ 2.46 $ - $ 13.03 $ - -$ $ 3.24 $ 

14 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

15 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

16 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - $ - $ 3.24 $ 

17 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

18 $ - $ - $ - $ 2.42 $ - $ 13.03 $ - -$ $ 3.24 $ 

19 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

20 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

21 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

22 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

23 $ - $ - $ - $ 2.42 $ - $ 13.03 $ - -$ $ 3.24 $ 

24 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - $ - $ 3.24 $ 

25 $ - $ - $ - $ 2.42 $ - $ 12.98 $ - -$ $ 3.24 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12i Nominal Agency Activity Costs for Alternative 3, by Year 

Year Implementation 

Annual 

Administration Monitoring Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.07 $ - $ 0.00 $ - $ - $ - $ - $ 0.01 $ - $ 

2 $ 0.07 $ - $ 0.00 $ - $ - $ - $ - $ 0.01 $ - $ 

3 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

4 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

5 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

6 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

7 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

8 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

9 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

10 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

11 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

12 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

13 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

14 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

15 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

16 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

17 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - $ - $ - $ 

18 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

19 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

20 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

21 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

22 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

23 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

24 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - -$ $ - $ 

25 $ - $ 0.26 $ - $ 0.01 $ - $ 1.10 $ - $ - $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.

2) Values in millions of 2008 dollars.

3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Year Implementation 

Annual 

Administration Sampling Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.09 $ - $ 0.02 $ - $ - $ - $ - $ 0.11 $ - $ 

2 $ 0.09 $ - $ 0.02 $ - $ - $ - $ - $ 0.11 $ - $ 

3 $ - $ 0.26 $ - $ 5.41 $ - $ - $ - -$ $ 2.27 $ 

4 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

5 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

6 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

7 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

8 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

9 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

10 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

11 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

12 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

13 $ - $ 0.26 $ - $ 5.41 $ - $ - $ - -$ $ 2.27 $ 

14 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

15 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

16 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

17 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - $ - $ 2.27 $ 

18 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

19 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

20 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

21 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

22 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

23 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

24 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

25 $ - $ 0.26 $ - $ 5.37 $ - $ - $ - $ - $ 2.27 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12j Nominal Rule Activity Costs for Alternative 4 (Final Rule), by Year
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12k Nominal Air Carrier Activity Costs for Alternative 4 (Final Rule), by Year 

Year Implementation 

Annual 

Administration Sampling Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - $ 0.11 $ - $ 

2 $ 0.02 $ - $ 0.01 $ - $ - $ - $ - $ 0.11 $ - $ 

3 $ - $ - $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

4 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

5 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

6 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

7 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

8 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

9 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

10 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

11 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

12 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

13 $ - $ - $ - $ 5.37 $ - $ - $ - -$ $ 2.27 $ 

14 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

15 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

16 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

17 $ - $ - $ - $ 5.33 $ - $ - $ - $ - $ 2.27 $ 

18 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

19 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

20 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

21 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

22 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

23 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

24 $ - $ - $ - $ 5.33 $ - $ - $ - -$ $ 2.27 $ 

25 $ - $ - $ - $ 5.33 $ - $ - $ - $ - $ 2.27 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.12l Nominal Agency Activity Costs for Alternative 4 (Final Rule), by Year 

Year Implementation 

Annual 

Administration Sampling Plan Monitoring - TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine Disinfection 

& Flushing 

CA Dis

Fl

1 $ 0.07 $ - $ 0.01 $ - $ - $ - $ - $ 0.00 $ - $ 

2 $ 0.07 $ - $ 0.01 $ - $ - $ - $ - $ 0.00 $ - $ 

3 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

4 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

5 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

6 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

7 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

8 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

9 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

10 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

11 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

12 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

13 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

14 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

15 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

16 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

17 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - $ - $ - $ 

18 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

19 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

20 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

21 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

22 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

23 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

24 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - -$ $ - $ 

25 $ - $ 0.26 $ - $ 0.04 $ - $ - $ - $ - $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Values in millions of 2008 dollars.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
C.13 Present Value at 3 Percent
 

Page C-98
-$ -$ -$ $ 

-$ -$ -$ $ 

1 $ 0.09 $ - $ 0.02 -$ $ - 

2 0.09 $ $ - $ 0.02 -$ $ - 

3 -$ $ 0.24 -$ $ 26.12 $ 3.26 -$ -$ -$ $ 

4 -$ $ 0.24 -$ $ 25.32 $ 3.16 -$ -$ -$ $ 

5 -$ $ 0.23 -$ $ 24.59 $ 3.07 -$ -$ -$ $ 

6 -$ $ 0.22 -$ $ 23.87 $ 2.98 -$ -$ -$ $ 

7 -$ $ 0.22 -$ $ 23.18 $ 2.90 -$ -$ -$ $ 

8 -$ $ 0.21 -$ $ 22.50 $ 2.81 -$ -$ -$ $ 

9 -$ $ 0.20 -$ $ 21.84 $ 2.73 -$ -$ -$ $ 

10 -$ $ 0.20 -$ $ 21.21 $ 2.65 -$ -$ -$ $ 

11 -$ $ 0.19 $ - $ 20.59 $ 2.57 -$ -$ -$ $ 

12 -$ $ 0.19 -$ $ 19.99 $ 2.50 -$ -$ -$ $ 

13 -$ $ 0.18 -$ $ 19.44 $ 2.43 -$ -$ -$ $ 

14 -$ $ 0.18 -$ $ 18.84 $ 2.35 -$ -$ -$ $ 

15 -$ $ 0.17 -$ $ 18.29 $ 2.29 -$ -$ -$ $ 

16 -$ $ 0.17 -$ $ 17.76 $ 2.22 -$ -$ -$ $ 

17 -$ $ 0.16 -$ $ 17.24 $ 2.15 -$ -$ -$ $ 

18 -$ $ 0.16 -$ $ 16.74 $ 2.09 -$ -$ -$ $ 

19 -$ $ 0.15 -$ $ 16.25 $ 2.03 -$ -$ -$ $ 

20 -$ $ 0.15 -$ $ 15.78 $ 1.97 -$ -$ -$ $ 

21 -$ $ 0.14 -$ $ 15.32 $ 1.91 -$ -$ -$ $ 

22 -$ $ 0.14 -$ $ 14.88 $ 1.86 $ - -$ -$ $ 

23 -$ $ 0.14 -$ $ 14.44 $ 1.80 -$ -$ -$ $ 

24 -$ $ 0.13 -$ $ 14.02 $ 1.75 -$ -$ -$ $ 

25 -$ $ 0.13 -$ $ 13.61 $ 1.70 -$ -$ -$ $ 

lized $ 0.01 $ 0.24 $ 0.00 $ 25.37 $ 3.17 -$ -$ -$ $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M 

Plan 

Routine 

Disinfectio

Flushing 

Year 

I

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13a Present Value of Rule Activity Costs for Alternative 1 at 3 Percent, by 

mplementati 

on 

Annual 

Administration 

Monitoring

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant 

Residual 

Total PV $ 0.18 $ 4.13 $ 0.04 $ 441.85 $ 55.20 -$ $ - -$ $ 

Annua 
1 $ 0.02 $ - $ 0.01 -$ $ - $ - -$ -$ 

$ 

2 $ 0.02 $ - $ 0.01 -$ $ - $ - -$ -$ 

$ 

3 $ - $ - -$ $ 25.81 $ 3.09 $ - -$ -$ 

$ 

4 $ - $ - -$ $ 25.02 $ 3.00 $ - -$ -$ 

$ 

5 $ - $ - -$ $ 24.29 $ 2.91 $ - -$ -$ 

$ 

6 $ - $ - -$ $ 23.59 $ 2.82 $ - -$ -$ 

$ 

7 $ - $ - -$ $ 22.90 $ 2.74 $ - -$ -$ 

$ 

8 $ - $ - -$ $ 22.23 $ 2.66 $ - -$ -$ 

$ 

9 $ - $ - -$ $ 21.58 $ 2.58 $ - -$ -$ 

$ 

10 $ - $ - -$ $ 20.96 $ 2.51 $ - -$ -$ 

$ 

11 $ - $ - -$ $ 20.34 $ 2.44 $ - -$ $ - 

$ 

12 $ - $ - -$ $ 19.75 $ 2.37 $ - -$ -$ 

$ 

13 $ - $ - -$ $ 19.20 $ 2.30 $ - -$ -$ 

$ 

14 $ - $ - -$ $ 18.62 $ 2.23 $ - -$ -$ 

$ 

15 $ - $ - -$ $ 18.08 $ 2.16 $ - -$ -$ 

$ 

16 $ - $ - -$ $ 17.55 $ 2.10 $ - -$ -$ 

$ 

17 $ - $ - -$ $ 17.04 $ 2.04 $ - -$ -$ 

$ 

18 $ - $ - -$ $ 16.54 $ 1.98 $ - -$ -$ 

$ 

19 $ - $ - -$ $ 16.06 $ 1.92 $ - -$ -$ 

$ 

20 $ - $ - -$ $ 15.59 $ 1.87 $ - -$ -$ 

$ 

21 $ - $ - -$ $ 15.14 $ 1.81 $ - -$ -$ 

$ 

22 $ - $ - -$ $ 14.70 $ 1.76 $ - -$ $ - 

$ 

23 $ - $ - -$ $ 14.27 $ 1.71 $ - -$ -$ 

$ 

24 $ - $ - -$ $ 13.85 $ 1.66 $ - -$ -$ 

$ 

25 $ - $ - -$ $ 13.45 $ 1.61 $ - -$ -$ 

$ 

otal 

$ - $ - -$ -$ 

$ 

zed $ 0.00 $ - $ 0.00 $ 25.07 $ 3.00 $ - -$ -$ 

$ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

nual 

istration 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13b Present Value of Air Carrier Activity Costs for Alternative 1 at 3 Percent

Year Implementation 

An

Admin

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M 

Rou

isinfeD

Plan 

Flus

TPV $ 0.04 $ 0.03 $ 436.57 $ 52.26 

Annuali 
-$ -$ -$ 

$ 

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M 

Plan 

Routin

Disinfec

& Flush

-$ -$ -$ 

$ 

-$ -$ -$ 

$ 

zed $ 0.01 $ 0.24 $ 0.00 $ 0.30 $ 0.17 -$ -$ -$ 

$ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

2 $ 0.07 $ - $ 0.01 -$ -$ 

3 $ - $ 0.24 -$ $ 0.31 $ 0.17 -$ -$ -$ 

$ 

4 $ - $ 0.24 -$ $ 0.30 $ 0.17 -$ -$ -$ 

$ 

5 $ - $ 0.23 -$ $ 0.29 $ 0.16 -$ -$ -$ 

$ 

6 $ - $ 0.22 -$ $ 0.29 $ 0.16 -$ -$ -$ 

$ 

7 $ - $ 0.22 -$ $ 0.28 $ 0.15 -$ -$ -$ 

$ 

8 $ - $ 0.21 -$ $ 0.27 $ 0.15 -$ -$ -$ 

$ 

9 $ - $ 0.20 -$ $ 0.26 $ 0.15 -$ -$ -$ 

$ 

10 $ - $ 0.20 -$ $ 0.25 $ 0.14 -$ -$ -$ 

$ 

11 $ - $ 0.19 -$ $ 0.25 $ 0.14 $ - -$ -$ 

$ 

12 $ - $ 0.19 -$ $ 0.24 $ 0.13 -$ -$ -$ 

$ 

13 $ - $ 0.18 -$ $ 0.23 $ 0.13 -$ -$ -$ 

$ 

14 $ - $ 0.18 -$ $ 0.23 $ 0.13 -$ -$ -$ 

$ 

15 $ - $ 0.17 -$ $ 0.22 $ 0.12 -$ -$ -$ 

$ 

16 $ - $ 0.17 -$ $ 0.21 $ 0.12 -$ -$ -$ 

$ 

17 $ - $ 0.16 -$ $ 0.21 $ 0.11 -$ -$ -$ 

$ 

18 $ - $ 0.16 -$ $ 0.20 $ 0.11 -$ -$ -$ 

$ 

19 $ - $ 0.15 -$ $ 0.19 $ 0.11 -$ -$ -$ 

$ 

20 $ - $ 0.15 -$ $ 0.19 $ 0.10 -$ -$ -$ 

$ 

21 $ - $ 0.14 -$ $ 0.18 $ 0.10 -$ -$ -$ 

$ 

22 $ - $ 0.14 -$ $ 0.18 $ 0.10 $ - -$ -$ 

$ 

23 $ - $ 0.14 -$ $ 0.17 $ 0.10 -$ -$ -$ 

$ 

24 $ - $ 0.13 -$ $ 0.17 $ 0.09 -$ -$ -$ 

$ 

25 $ - $ 0.13 -$ $ 0.16 $ 0.09 -$ -$ -$ 

$ 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13c Present Value of Agency Activity Costs for Alternative 1 at 3 Percent, b

Year 

-

1 $ 0.07 $ - $ 0.01 $ - -$ 

Implementation 

Annual 

Administration 

Monitoring 

Plan 

Monitoring 

TC 

Monitoring -

Disinfectant 

Residual 

Total PV $ 0.14 $ 4.13 $ 0.02 $ 5.28 $ 2.93 

Annuali 
Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M 

Plan 

1 $ 0.09 $ - $ 0.02 -$ $ - $ - -$ $ - $ 

2 $ 0.09 $ - $ 0.02 -$ $ - $ - -$ $ - 

$ 

3 $ - $ 0.24 $ - $ 1.75 $ 0.69 -$ -$ $ - $ 

4 $ - $ 0.24 $ - $ 1.66 $ 0.67 -$ -$ $ - $ 

5 $ - $ 0.23 $ - $ 1.61 $ 0.65 -$ -$ $ - $ 

6 $ - $ 0.22 $ - $ 1.57 $ 0.63 -$ -$ $ - $ 

7 $ - $ 0.22 $ - $ 1.52 $ 0.61 -$ -$ $ - $ 

8 $ - $ 0.21 $ - $ 1.48 $ 0.59 -$ -$ $ - $ 

9 $ - $ 0.20 $ - $ 1.43 $ 0.58 -$ -$ $ - $ 

10 $ - $ 0.20 $ - $ 1.39 $ 0.56 -$ $ - $ - $ 

11 $ - $ 0.19 $ - $ 1.35 $ 0.54 -$ -$ $ - $ 12 $ - $ 0.19 $ - $ 1.31 $ 0.53 -$ -$ $ - $ 13 $ - $ 0.18 $ - $ 1.30 $ 0.51 -$ -$ $ - $ 14 $ - $ 0.18 $ - $ 1.24 $ 0.50 -$ -$ $ - $ 15 $ - $ 0.17 $ - $ 1.20 $ 0.48 -$ -$ $ - $ 

16 $ - $ 0.17 $ - $ 1.17 $ 0.47 -$ -$ $ - $ 17 $ - $ 0.16 $ - $ 1.13 $ 0.45 -$ -$ $ - $ 18 $ - $ 0.16 $ - $ 1.10 $ 0.44 -$ -$ $ - $ 19 $ - $ 0.15 $ - $ 1.07 $ 0.43 -$ -$ $ - $ 20 $ - $ 0.15 $ - $ 1.04 $ 0.42 -$ -$ $ - $ 21 $ - $ 0.14 $ - $ 1.01 $ 0.40 -$ -$ $ - $ 22 $ - $ 0.14 $ - $ 0.98 $ 0.39 -$ -$ $ - $ 23 $ - $ 0.14 $ - $ 0.95 $ 0.38 -$ -$ $ - $ 24 $ - $ 0.13 $ - $ 0.92 $ 0.37 -$ -$ $ - $ 25 $ - $ 0.13 $ - $ 0.89 $ 0.36 -$ -$ $ - $ 

zed $ 0.01 $ 0.24 $ 0.00 $ 1.67 $ 0.67 -$ -$ $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

-$ -$ $ -

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13d Present Value of Rule Activity Costs for Alternative 2 at 3 Percent, by Y

Year Implementation 

Annual 

Administration 

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant 

Residual 

Routi

isinfec

& Flush

D

Total PV $ 0.18 $ 4.13 $ 0.04 $ 29.05 $ 11.64 $ 7

Annuali 
-$ -$ -$ 

ed $ 0.00 $ - $ 0.00 $ 1.66 $ 0.50 -$ -$ -$ $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

2 $ 0.02 $ - $ 0.01 -$ -$ -$ -$ -$ $ 

3 $ - $ - -$ $ 1.73 $ 0.51 -$ -$ -$ $ 4 $ - $ - -$ $ 1.65 $ 0.50 -$ -$ -$ $ 5 $ - $ - -$ $ 1.60 $ 0.48 -$ -$ -$ $ 6 $ - $ - -$ $ 1.55 $ 0.47 -$ -$ -$ $ 7 $ - $ - -$ $ 1.51 $ 0.46 -$ -$ -$ $ 

8 $ - $ - -$ $ 1.47 $ 0.44 -$ -$ -$ $ 9 $ - $ - -$ $ 1.42 $ 0.43 -$ -$ -$ $ 

10 $ - $ - -$ $ 1.38 $ 0.42 -$ -$ -$ $ 11 $ - $ - -$ $ 1.34 $ 0.41 $ - -$ -$ $ 12 $ - $ - -$ $ 1.30 $ 0.39 -$ -$ -$ $ 13 $ - $ - -$ $ 1.29 $ 0.38 -$ -$ -$ $ 14 $ - $ - -$ $ 1.23 $ 0.37 -$ -$ -$ $ 15 $ - $ - -$ $ 1.19 $ 0.36 -$ -$ -$ $ 

16 $ - $ - -$ $ 1.16 $ 0.35 -$ -$ -$ $ 17 $ - $ - -$ $ 1.12 $ 0.34 -$ -$ -$ $ 18 $ - $ - -$ $ 1.09 $ 0.33 -$ -$ -$ $ 19 $ - $ - -$ $ 1.06 $ 0.32 -$ -$ -$ $ 20 $ - $ - -$ $ 1.03 $ 0.31 -$ -$ -$ $ 21 $ - $ - -$ $ 1.00 $ 0.30 -$ -$ -$ $ 22 $ - $ - -$ $ 0.97 $ 0.29 $ - -$ -$ $ 23 $ - $ - -$ $ 0.94 $ 0.28 -$ -$ -$ $ 24 $ - $ - -$ $ 0.91 $ 0.28 -$ -$ -$ $ 25 $ - $ - -$ $ 0.89 $ 0.27 -$ -$ -$ $ 

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M

Plan

-$ -$ -$ 

Year 

1 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13e Present Value of Air Carrier Activity Costs for Alternative 2 at 3 Percent

Implementation 

Annual 

Administration 

Monitoring 

Plan 

Monitoring

TC 

Monitoring -

 - Disinfectant 

Residual 

Routin

Disinfecti

Flushin

$ 0.02 $ - $ 0.01 -$ $ - $ 

Total PV $ 0.04 $ - $ 0.03 $ 28.83 $ 8.71 $ 6

Annualiz 
- -$ $ - $ - 

9 $ - $ - $ -

Annualized $ 0.01 $ 0.24 $ 0.00 $ 0.01 $ 0.17 -$ $ - $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

3 -$ $ - $ -

1 2 

$ 0.07 $ - $ 0.01 -$ $ $ 

$ 0.07 $ - $ 0.01 -$ -$ -$ $ - $ - $ 

3 $ - $ 0.24 -$ $ 0.01 $ 0.17 -$ $ - $ - $ 

4 $ - $ 0.24 -$ $ 0.01 $ 0.17 -$ $ - $ - $ 

5 $ - $ 0.23 -$ $ 0.01 $ 0.16 -$ $ - $ - $ 

6 $ - $ 0.22 -$ $ 0.01 $ 0.16 -$ $ - $ - $ 

7 $ - $ 0.22 -$ $ 0.01 $ 0.15 -$ $ - $ - $ 

8 $ - $ 0.21 -$ $ 0.01 $ 0.15 -$ $ - $ - $ 

9 $ - $ 0.20 -$ $ 0.01 $ 0.15 -$ $ - $ - $ 

10 $ - $ 0.20 -$ $ 0.01 $ 0.14 -$ $ - $ - $ 

11 $ - $ 0.19 -$ $ 0.01 $ 0.14 -$ $ - $ - $ 

12 $ - $ 0.19 -$ $ 0.01 $ 0.13 -$ $ - $ - $ 

13 $ - $ 0.18 -$ $ 0.01 $ 0.13 -$ $ - $ - $ 

14 $ - $ 0.18 -$ $ 0.01 $ 0.13 -$ $ - $ - $ 

15 $ - $ 0.17 -$ $ 0.01 $ 0.12 -$ $ - $ - $ 

16 $ - $ 0.17 -$ $ 0.01 $ 0.12 -$ $ - $ - $ 

17 $ - $ 0.16 -$ $ 0.01 $ 0.11 -$ $ - $ - $ 

18 $ - $ 0.16 -$ $ 0.01 $ 0.11 -$ $ - $ - $ 

19 $ - $ 0.15 -$ $ 0.01 $ 0.11 -$ $ - $ - $ 

20 $ - $ 0.15 -$ $ 0.01 $ 0.10 -$ $ - $ - $ 

21 $ - $ 0.14 -$ $ 0.01 $ 0.10 -$ $ - $ - $ 

22 $ - $ 0.14 -$ $ 0.01 $ 0.10 -$ $ - $ - $ 

23 $ - $ 0.14 -$ $ 0.01 $ 0.10 -$ $ - $ - $ 

24 $ - $ 0.13 -$ $ 0.01 $ 0.09 -$ $ - $ - $ 

25 $ - $ 0.13 -$ $ 0.01 $ 0.0 $ 

ant

al 

 Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring 

O&M 

Year Plan 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13f Present Value of Agency Activity Costs for Alternative 2 at 3 Percent, by 

Implementation 

Annual 

Administration 

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfect

Residu

Rou

Disinf

& Flu

Total PV $ 0.14 $ 4.13 $ 0.02 $ 0.21 $ 2.9 $ 
$ - -$ $ 

1 0.09$ $ - $ 0.01 -$ -$ 0.06 $ - 2 0.09$ $ - $ 0.01 -$ $ - -$ -$ $0.06 $ - 

3 -$ $ 0.24 -$ $ 2.33 $ - $ 13.32 -$ -$ $ 3.

4 -$ $ 0.24 -$ $ 2.22 $ - $ 12.89 -$ -$ $ 2.

5 -$ $ 0.23 -$ $ 2.16 $ - $ 12.51 -$ -$ $ 2.

6 -$ $ 0.22 -$ $ 2.10 $ - $ 12.15 -$ -$ $ 2.

7 -$ $ 0.22 -$ $ 2.04 $ - $ 11.79 -$ -$ $ 2.

8 -$ $ 0.21 -$ $ 1.98 $ - $ 11.49 -$ -$ $ 2.

9 -$ $ 0.20 -$ $ 1.92 $ - $ 11.12 -$ -$ $ 2.

10 -$ $ 0.20 -$ $ 1.86 $ - $ 10.79 -$ -$ $ 2.

11 -$ $ 0.19 -$ $ 1.81 $ - $ 10.48 -$ -$ $ 2.

12 -$ $ 0.19 -$ $ 1.76 $ - $ 10.17 -$ -$ $ 2.

13 -$ $ 0.18 -$ $ 1.73 $ - $ 9.91 -$ -$ $ 2.

14 -$ $ 0.18 -$ $ 1.66 $ - $ 9.59 -$ -$ $ 2.

15 -$ $ 0.17 -$ $ 1.61 $ - $ 9.31 -$ -$ $ 2.

16 -$ $ 0.17 -$ $ 1.56 $ - $ 9.04 -$ -$ $ 2.

17 -$ $ 0.16 -$ $ 1.52 $ - $ 8.77 -$ -$ $ 2.

18 -$ $ 0.16 -$ $ 1.47 $ - $ 8.55 -$ -$ $ 1.

19 -$ $ 0.15 -$ $ 1.43 $ - $ 8.27 -$ -$ $ 1.

20 -$ $ 0.15 -$ $ 1.39 $ - $ 8.03 -$ -$ $ 1.

21 -$ $ 0.14 -$ $ 1.35 $ - $ 7.80 -$ -$ $ 1.

22 -$ $ 0.14 -$ $ 1.31 $ - $ 7.57 -$ -$ $ 1.

23 -$ $ 0.14 -$ $ 1.27 $ - $ 7.38 -$ -$ $ 1.

24 -$ $ 0.13 -$ $ 1.23 $ - $ 7.13 -$ -$ $ 1.

25 -$ $ 0.13 -$ $ 1.20 $ - $ 6.93 -$ -$ $ 1.

zed 0.01$ $ 0.24 $ 0.00 $ 2.23 $ - $ 12.92 -$ $0.01 $ 2.

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Nitrate/ 

Nitrite 

Monitoring 

-

Monitoring -

Disinfectant 

Residual 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13g Present Value of Rule Activity Costs for Alternative 3 at 3 Percent, by 

Year 

Implement 

ation 

Annual 

Administration 

Monitoring 

Plan 

Monitoring 

TC 

Turbidity 

Monitoring

O&M 

Plan 

Routine 

Disinfection 

Flushing 

Total PV $ 0.18 $ 4.13 $ 0.02 $ 38.88 $ - $ 224.99 -$ $0.12 $ 51.

Annuali 
$ - $ - -$ 

$ -

1 0.02$ $ 0.01 -$ -$ 0.05$ $ 

2 0.02$ $ 0.01 -$ $ - -$ -$ 0.05$ $ 

3 -$ $ - -$ $ 2.31 $ - $ 12.28 -$ -$ $ 

4 -$ $ - -$ $ 2.21 $ - $ 11.88 -$ -$ $ 2

5 -$ $ - -$ $ 2.15 $ - $ 11.53 -$ -$ $ 2

6 -$ $ - -$ $ 2.09 $ - $ 11.20 -$ -$ $ 2

7 -$ $ - -$ $ 2.03 $ - $ 10.87 -$ -$ $ 2

8 -$ $ - -$ $ 1.97 $ - $ 10.60 -$ -$ $ 2

9 -$ $ - -$ $ 1.91 $ - $ 10.25 -$ -$ $ 2

10 -$ $ - -$ $ 1.85 $ - $ 9.95 -$ -$ $ 211 -$ $ - -$ $ 1.80 $ - $ 9.66 -$ -$ $ 212 -$ $ - -$ $ 1.75 $ - $ 9.38 -$ -$ $ 213 -$ $ - -$ $ 1.72 $ - $ 9.14 -$ -$ $ 214 -$ $ - -$ $ 1.65 $ - $ 8.84 -$ -$ $ 215 -$ $ - -$ $ 1.60 $ - $ 8.58 -$ -$ $ 2

16 -$ $ - -$ $ 1.55 $ - $ 8.33 -$ -$ $ 17 -$ $ - -$ $ 1.51 $ - $ 8.09 -$ -$ $ 18 -$ $ - -$ $ 1.46 $ - $ 7.88 -$ -$ $ 19 -$ $ - -$ $ 1.42 $ - $ 7.62 -$ -$ $ 20 -$ $ - -$ $ 1.38 $ - $ 7.40 -$ -$ $ 21 -$ $ - -$ $ 1.34 $ - $ 7.19 -$ -$ $ 22 -$ $ - -$ $ 1.30 $ - $ 6.98 -$ -$ $ 23 -$ $ - -$ $ 1.26 $ - $ 6.80 -$ -$ $ 24 -$ $ - -$ $ 1.23 $ - $ 6.58 -$ -$ $ 

25 -$ $ - -$ $ 1.19 $ - $ 6.38 -$ -$ $ 

ized 0.00$ $ - $ 0.00 $ 2.22 $ - $ 11.91 -$ 0.01$ $ 2Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Nitrate/ 

Nitrite 

Monitoring 

-

Monitoring -

Disinfectant 

Residual 

t Annual 

Administration 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13h Present Value of Air Carrier Activity Costs for Alternative 3 at 3 Percent

Year 

Implemen

ation 

Monitoring 

Plan 

Monitoring 

TC 

Turbidity 

Monitoring

O&M 

Plan 

Routine 

isinfectio

Flushin

D 

Total PV $ 0.04 $ - $ 0.01 $ 38.66 $ - $ 207.39 -$ $ 0.11 $ 5

Annual 
-$ $ -$ 

$ 

-$ 

$ 

Routine 

Disinfection 

& Flushing 

Dis

& F

-$ 

-$ 

-$ 

1 0.07$ $ - $ 0.00 -$ - -$ $ 0.01 

2 0.07$ $ - $ 0.00 -$ -$ -$ -$ $ 0.01 

3 -$ $ 0.24 -$ $ 0.01 -$ $ 1.04 -$ -$ -$ 

$ 

4 -$ $ 0.24 -$ $ 0.01 -$ $ 1.01 -$ -$ -$ 

$ 

5 -$ $ 0.23 -$ $ 0.01 -$ $ 0.98 -$ -$ -$ 

$ 

6 -$ $ 0.22 -$ $ 0.01 -$ $ 0.95 -$ -$ -$ 

$ 

7 -$ $ 0.22 -$ $ 0.01 -$ $ 0.92 -$ -$ -$ 

$ 

8 -$ $ 0.21 -$ $ 0.01 -$ $ 0.90 -$ -$ -$ 

$ 

9 -$ $ 0.20 -$ $ 0.01 -$ $ 0.87 -$ -$ -$ 

$ 

10 -$ $ 0.20 -$ $ 0.01 -$ $ 0.84 -$ -$ -$ 

$ 

11 -$ $ 0.19 -$ $ 0.01 -$ $ 0.82 -$ -$ -$ 

$ 

12 -$ $ 0.19 -$ $ 0.01 -$ $ 0.80 -$ -$ -$ 

$ 

13 -$ $ 0.18 -$ $ 0.01 -$ $ 0.77 -$ -$ -$ 

$ 

14 -$ $ 0.18 -$ $ 0.01 -$ $ 0.75 -$ -$ -$ 

$ 

15 -$ $ 0.17 -$ $ 0.01 -$ $ 0.73 -$ -$ -$ 

$ 

16 -$ $ 0.17 -$ $ 0.01 -$ $ 0.71 -$ -$ -$ 

$ 

17 -$ $ 0.16 -$ $ 0.01 -$ $ 0.69 -$ -$ -$ 

$ 

18 -$ $ 0.16 -$ $ 0.01 -$ $ 0.67 -$ -$ -$ 

$ 

19 -$ $ 0.15 -$ $ 0.01 -$ $ 0.65 -$ -$ -$ 

$ 

20 -$ $ 0.15 -$ $ 0.01 -$ $ 0.63 -$ -$ -$ 

$ 

21 -$ $ 0.14 -$ $ 0.01 -$ $ 0.61 -$ -$ -$ 

$ 

22 -$ $ 0.14 -$ $ 0.01 -$ $ 0.59 -$ -$ -$ 

$ 

23 -$ $ 0.14 -$ $ 0.01 -$ $ 0.58 -$ -$ -$ 

$ 

24 -$ $ 0.13 -$ $ 0.01 -$ $ 0.56 -$ -$ -$ 

$ 

25 -$ $ 0.13 -$ $ 0.01 $ 0.54 -$ -$ -$ 

$ 

-$ -$ 

0

-$ 

$ 

-$ 

$ 

Annuali zed 0.01$ $ 0.24 $ 0.00 $ 0.01 $ 1.01 $ 0.00 Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

g -

Monitoring -

Disinfectant 

Residual g 

Nitrate/ 

Nitrite 

Year Monitoring 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13i Present Value of Agency Activity Costs for Alternative 3 at 3 Percent, by Ye

Impleme 

ntation 

Annual 

Administration 

Monitoring M

Plan 

onitorin

TC 

Turbidity

Monitorin

O&M 

Plan 

Total PV $ 0.14 $ 4.13 $ 0.01 $ 0.21 $ 17.6 $ 0.02 
$ - -$ -$ 

$ - -$ -$ 

10 $ - -$ -$ $

1 0.09$ -$ 0.02$ -$ 0.11$ $ - $ 

2 0.09$ -$ 0.02$ -$ 0.11$ $ - $ 

3 -$ 0.24$ -$ 5.$ - $ 2.14 $ 

4 -$ 0.24$ -$ $ 4.92 $ - -$ -$ -$ $ 2.08 $ 

5 -$ 0.23$ -$ $ 4.77 $ - -$ -$ -$ $ 2.02 $ 

6 -$ 0.22$ -$ $ 4.63 $ - -$ -$ -$ $ 1.96 $ 

7 -$ 0.22$ -$ $ 4.50 $ - -$ -$ -$ $ 1.90 $ 

8 -$ 0.21$ -$ $ 4.37 $ - -$ -$ -$ $ 1.85 $ 

9 -$ 0.20$ -$ $ 4.24 $ - -$ -$ -$ $ 1.79 $ 

10 -$ 0.20$ -$ $ 4.12 $ - -$ -$ -$ $ 1.74 $ 

11 -$ 0.19$ -$ $ 4.00 $ - -$ -$ -$ $ 1.69 $ 

12 -$ 0.19$ -$ $ 3.88 $ - -$ -$ -$ $ 1.64 $ 

13 -$ 0.18$ -$ $ 3.79 $ - -$ -$ -$ $ 1.59 $ 

14 -$ 0.18$ -$ $ 3.66 $ - -$ -$ -$ $ 1.55 $ 

15 -$ 0.17$ -$ $ 3.55 $ - -$ -$ -$ $ 1.50 $ 

16 -$ 0.17$ -$ $ 3.45 $ - -$ -$ -$ $ 1.46 $ 

17 -$ 0.16$ -$ $ 3.35 $ - -$ -$ -$ $ 1.41 $ 

18 -$ 0.16$ -$ $ 3.25 $ - -$ -$ -$ $ 1.37 $ 

19 -$ 0.15$ -$ $ 3.16 $ - -$ -$ -$ $ 1.33 $ 

20 -$ 0.15$ -$ $ 3.06 $ - -$ -$ -$ $ 1.29 $ 

21 -$ 0.14$ -$ $ 2.97 $ - -$ -$ -$ $ 1.26 $ 

22 -$ 0.14$ -$ $ 2.89 $ - -$ -$ -$ $ 1.22 $ 

23 -$ 0.14$ -$ $ 2.80 $ - -$ -$ -$ $ 1.18 $ 

24 -$ 0.13$ -$ $ 2.72 $ - -$ -$ -$ $ 1.15 $ 

25 -$ 0.13$ -$ $ 2.64 $ - -$ -$ -$ $ 1.12 $ 

.84 $ - -$ -$ 

.93 $ - -$ -$ 

Annuali zed 0.01$ 0.24$ 0.00$ 4$ 0.01$ $ 2.08 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

 -

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13j Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 3 Percen

Year 

Implement 

ation 

Annual 

Administrat 

ion 

Sampling 

Plan 

Monitoring

TC 

O&M 

Plan 

Routine 

Disinfection & i

D

Flushing 

Total PV $ 0.18 $ 4.13 $ 0.04 $ 85 $ 0.21 $ 36.23 $ 
02 -$ 

nt 

Annual 

Administrati 

on 

$ - -$ -$ $ 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

1 

Year 

0.$ 0.01$ -$ 0.11 $ - 

2 0.02$ -$ 0.01$ -$ $ - -$ -$ 0.10$ $ - 

3 -$ -$ -$ $ 5.06 $ - -$ -$ -$ $ 2.14 4 -$ -$ -$ $ 4.88 $ - -$ -$ -$ $ 2.08 5 -$ -$ -$ $ 4.73 $ - -$ -$ -$ $ 2.02 6 -$ -$ -$ $ 4.60 $ - -$ -$ -$ $ 1.96 7 -$ -$ -$ $ 4.46 $ - -$ -$ -$ $ 1.90 

8 -$ -$ -$ $ 4.33 $ - -$ -$ -$ $ 1.85 

9 -$ -$ -$ $ 4.21 $ - -$ -$ -$ $ 1.79 

10 -$ -$ -$ $ 4.08 $ - -$ -$ -$ $ 1.74 

11 -$ -$ -$ $ 3.96 $ - -$ -$ -$ $ 1.69 12 -$ -$ -$ $ 3.85 $ - -$ -$ -$ $ 1.64 13 -$ -$ -$ $ 3.76 $ - -$ -$ -$ $ 1.59 14 -$ -$ -$ $ 3.63 $ - -$ -$ -$ $ 1.55 15 -$ -$ -$ $ 3.52 $ - -$ -$ -$ $ 1.50 

16 -$ -$ -$ $ 3.42 $ - -$ -$ -$ $ 1.46 17 -$ -$ -$ $ 3.32 $ - -$ -$ -$ $ 1.41 18 -$ -$ -$ $ 3.22 $ - -$ -$ -$ $ 1.37 19 -$ -$ -$ $ 3.13 $ - -$ -$ -$ $ 1.33 20 -$ -$ -$ $ 3.04 $ - -$ -$ -$ $ 1.29 21 -$ -$ -$ $ 2.95 $ - -$ -$ -$ $ 1.26 22 -$ -$ -$ $ 2.86 $ - -$ -$ -$ $ 1.22 23 -$ -$ -$ $ 2.78 $ - -$ -$ -$ $ 1.18 

24 -$ -$ -$ $ 2.70 $ - -$ -$ -$ $ 1.15 

25 -$ -$ -$ $ 2.62 $ - -$ -$ -$ $ 1.12 

4 -$ .13 $ - -$ $ 

zed 0.00$ $

Notes: 

Annuali 

- 0.00$ $ 4.89 $ - -$ -$ 0.01$ $ 2.08 

1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13k Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 3 Pe

Impleme

ation

Sampling 

Plan 

Monitoring -

TC 

O&M 

Plan 

Routine 

Disinfection & D

Flushing 

Total PV $ 0.0 $ 0.03 $ 85 - $ 0.21 $ 36.23 
- $ - -$ -$ $ 0.00 $ - $ 

g -

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/ Nitrite 

Monitoring 

O&M 

Plan 

Routine 

Disinfection & 

Flushing 

CA 

& 

1 0.07$ -$ 0.01$ $ 

2 0.07$ -$ 0.01$ -$ $ - -$ -$ $ 0.00 $ - $ 

3 -$ $ 0.24 -$ $ 0.04 $ - -$ -$ -$ $ - $ 

4 -$ $ 0.24 -$ $ 0.04 $ - -$ -$ -$ $ - $ 

5 -$ $ 0.23 -$ $ 0.04 $ - -$ -$ -$ $ - $ 

6 -$ $ 0.22 -$ $ 0.04 $ - -$ -$ -$ $ - $ 

7 -$ $ 0.22 -$ $ 0.04 $ - -$ -$ -$ $ - $ 

8 -$ $ 0.21 -$ $ 0.04 $ - -$ -$ -$ $ - $ 

9 -$ $ 0.20 -$ $ 0.04 $ - -$ -$ -$ $ - $ 

10 -$ $ 0.20 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

11 -$ $ 0.19 $ - $ 0.03 $ - -$ -$ -$ $ - $ 

12 -$ $ 0.19 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

13 -$ $ 0.18 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

14 -$ $ 0.18 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

15 -$ $ 0.17 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

16 -$ $ 0.17 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

17 -$ $ 0.16 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

18 -$ $ 0.16 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

19 -$ $ 0.15 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

20 -$ $ 0.15 -$ $ 0.03 $ - -$ -$ -$ $ - $ 

21 -$ $ 0.14 -$ $ 0.02 $ - -$ -$ -$ $ - $ 

22 -$ $ 0.14 -$ $ 0.02 $ - $ - -$ -$ $ - $ 

23 -$ $ 0.14 -$ $ 0.02 $ - -$ -$ -$ $ - $ 

24 -$ $ 0.13 -$ $ 0.02 $ - -$ -$ -$ $ - $ 

25 -$ $ 0.13 -$ $ 0.02 $ - -$ -$ -$ $ - $ 

Total PV 0.14$ $ 4.13 0.01$ $ 0.71 $ - -$ -$ $ 0.00 $ - $ 

Annual ized 0.01$ $ 0.24 0.00$ $ 0.04 $ - -$ -$ $ 0.00 $ - $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.13l Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 3 Perc

Year 

Implement 

ation 

Annual 

Administrat 

ion 

Sampling 

Plan 

Monitorin

TC 
C.14 Present Value Costs at 7 Percent
 
1 0.09 $ -$ $ 0.02 $ - $ - $ - -$ -$ $ - 

2 0.09 $ -$ $ 0.02 $ - $ - $ - -$ -$ $ - 3 -$ 0.23$ $ - $ 24.20 $ 3.02 $ - -$ -$ $ - 4 -$ 0.21$ $ - $ 22.59 $ 2.82 $ - -$ -$ $ - 5 -$ 0.20$ $ - $ 21.11 $ 2.64 $ - -$ -$ $ - 6 -$ 0.18$ $ - $ 19.73 $ 2.47 $ - -$ -$ $ - 7 -$ 0.17$ $ - $ 18.44 $ 2.30 $ - -$ -$ $ - 

8 -$ 0.16$ $ - $ 17.23 $ 2.15 $ - -$ -$ $ - 9 -$ 0.15$ $ - $ 16.11 $ 2.01 $ - -$ -$ $ - 

10 -$ 0.14$ $ - $ 15.05 $ 1.88 $ - -$ -$ $ - 

11 -$ 0.13$ $ - $ 14.07 $ 1.76 $ - -$ -$ $ - 

12 -$ 0.12$ $ - $ 13.15 $ 1.64 $ - -$ -$ $ - 

13 -$ 0.11$ $ - $ 12.30 $ 1.54 $ - -$ -$ $ - 

14 -$ 0.11$ $ - $ 11.48 $ 1.43 $ - -$ -$ $ - 

15 -$ 0.10$ $ - $ 10.73 $ 1.34 $ - -$ -$ $ - 

16 -$ 0.09$ $ - $ 10.03 $ 1.25 $ - -$ -$ $ - 

17 -$ 0.09$ $ - $ 9.37 $ 1.17 $ - -$ -$ $ - 

18 -$ 0.08$ $ - $ 8.76 $ 1.09 $ - -$ -$ $ - 

19 -$ 0.08$ $ - $ 8.19 $ 1.02 $ - -$ -$ $ - 

20 -$ 0.07$ $ - $ 7.65 $ 0.96 $ - -$ -$ $ - 

21 -$ 0.07$ $ - $ 7.15 $ 0.89 $ - -$ -$ $ - 

22 -$ 0.06$ $ - $ 6.68 $ 0.84 $ - -$ -$ $ - 

23 -$ 0.06$ $ - $ 6.25 $ 0.78 $ - -$ -$ $ - 

24 -$ 0.05$ $ - $ 5.84 $ 0.73 $ - -$ -$ $ - 

25 -$ 0.05$ $ - $ 5.46 $ 0.68 $ - -$ -$ $ - 

$ - -$ -$ $ - 

Annuali zed $ 0.02 0.23$ $ 0.00 $ 25.02 $ 3.13 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

$ - -$ -$ $ - 

ng -

tant 

al 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14a Present Value of Rule Activity Costs for Alternative 1 at 7 Percent, by 

Year 

Implementa

tion 

Annual 

Administra 

tion 

Monitoring 

Plan 

Monitoring -

TC 

Monitori

Disinfec

Residu

Turbidity 

Monitoring 

Nitrate/ Nitrite 

Monitoring 

O&M 

Plan 

Routine 

Disinfection & 

Flushing 

Total PV $ 0.18 $ 2.73 $ 0.04 $ 291.57 $ 36.42 
$ - $ - -$ $ - 

$ - $ - -$ $ - 

Turbidity 

Monitoring 

Nitrate/ Nitrite 

Monitoring 

O&M 

Plan 

Routine 

Disinfection & 

Flushing 

1 

Year 

0.02$ -$ $ 0.01 -$ $ - 

2 0.02$ -$ $ 0.01 -$ $ - 3 -$ -$ -$ $ 23.91 $ 2.86 $ - $ - -$ $ - 4 -$ -$ -$ $ 22.32 $ 2.67 $ - $ - -$ $ - 5 -$ -$ -$ $ 20.86 $ 2.50 $ - $ - -$ $ - 6 -$ -$ -$ $ 19.49 $ 2.33 $ - $ - -$ $ - 7 -$ -$ -$ $ 18.22 $ 2.18 $ - $ - -$ $ - 8 -$ -$ -$ $ 17.03 $ 2.04 $ - $ - -$ $ - 9 -$ -$ -$ $ 15.91 $ 1.91 $ - $ - -$ $ - 

10 -$ -$ -$ $ 14.87 $ 1.78 $ - $ - -$ $ - 11 - $ -$ -$ $ 13.90 $ 1.66 $ - $ - -$ $ - 12 -$ -$ -$ $ 12.99 $ 1.56 $ - $ - -$ $ - 13 -$ -$ -$ $ 12.16 $ 1.45 $ - $ - -$ $ - 14 -$ -$ -$ $ 11.35 $ 1.36 $ - $ - -$ $ - 15 -$ -$ -$ $ 10.60 $ 1.27 $ - $ - -$ $ - 16 -$ -$ -$ $ 9.91 $ 1.19 $ - $ - -$ $ - 17 -$ -$ -$ $ 9.26 $ 1.11 $ - $ - -$ $ - 18 -$ -$ -$ $ 8.66 $ 1.04 $ - $ - -$ $ - 19 -$ -$ -$ $ 8.09 $ 0.97 $ - $ - -$ $ - 20 -$ -$ -$ $ 7.56 $ 0.91 $ - $ - -$ $ - 21 -$ -$ -$ $ 7.07 $ 0.85 $ - $ - -$ $ - 22 -$ -$ $ - $ 6.60 $ 0.79 $ - $ - -$ $ - 23 -$ -$ -$ $ 6.17 $ 0.74 $ - $ - -$ $ - 

24 -$ -$ -$ $ 5.77 $ 0.69 $ - $ - -$ $ - 25 -$ -$ -$ $ 5.39 $ 0.65 $ - $ - -$ $ - 

9 $ - $ - -$ $ - 

Annuali zed 0.00$ -$ $ 0.00 $ 24.72 $ 2.96 $ - $ - -$ $ - 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14b Present Value of Air Carrier Activity Costs for Alternative 1 at 7 Percent, b

Annual Monitoring -

Implement Administrat Monitoring Monitoring - Disinfectant 

ation ion Plan TC Residual 

Total PV $ 0.04 $ - $ 0.03 $ 288.09 $ 34.4 
-$ -$ -$ $ - $ 

-$ -$ -$ $ - $ -$ -$ -$ $ - $ 

-$ -$ -$ $ - $ 

2 0.07$ -$ $ 0.01 -$ $ - 

3 -$ 0.23$ -$ $ 0.29 $ 0.16 

4 -$ 0.21$ -$ $ 0.27 $ 0.15 

5 -$ 0.20$ -$ $ 0.25 $ 0.14 -$ -$ -$ $ - $ 

6 -$ 0.18$ -$ $ 0.24 $ 0.13 -$ -$ -$ $ - $ 

7 -$ 0.17$ -$ $ 0.22 $ 0.12 -$ -$ -$ $ - $ 

1 0.07$ -$ $ 0.01 -$ $ - 

 Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M 

Plan 

Routine 

Disinfection & 

Flushing 

CA 

8 -$ 0.16$ -$ $ 0.21 $ 0.11 -$ -$ -$ $ - $ 

9 -$ 0.15$ -$ $ 0.19 $ 0.11 -$ -$ -$ $ - $ 

10 -$ 0.14$ -$ $ 0.18 $ 0.10 -$ -$ -$ $ - $ 

11 -$ 0.13$ -$ $ 0.17 $ 0.09 -$ -$ -$ $ - $ 

12 -$ 0.12$ -$ $ 0.16 $ 0.09 -$ -$ -$ $ - $ 

13 -$ 0.11$ -$ $ 0.15 $ 0.08 -$ -$ -$ $ - $ 

14 -$ 0.11$ -$ $ 0.14 $ 0.08 -$ -$ -$ $ - $ 

15 -$ 0.10$ -$ $ 0.13 $ 0.07 -$ -$ -$ $ - $ 

16 -$ 0.09$ -$ $ 0.12 $ 0.07 -$ -$ -$ $ - $ 

17 -$ 0.09$ -$ $ 0.11 $ 0.06 -$ -$ -$ $ - $ 

18 -$ 0.08$ -$ $ 0.10 $ 0.06 -$ -$ -$ $ - $ 

19 -$ 0.08$ -$ $ 0.10 $ 0.05 -$ -$ -$ $ - $ 

20 -$ 0.07$ -$ $ 0.09 $ 0.05 -$ -$ -$ $ - $ 

21 -$ 0.07$ -$ $ 0.09 $ 0.05 -$ -$ -$ $ - $ 

22 -$ 0.06$ -$ $ 0.08 $ 0.04 -$ -$ -$ $ - $ 

23 -$ 0.06$ -$ $ 0.07 $ 0.04 -$ -$ -$ $ - $ 

24 -$ 0.05$ -$ $ 0.07 $ 0.04 -$ -$ -$ $ - $ 

25 -$ 0.05$ -$ $ 0.07 $ 0.04 -$ -$ -$ $ - $ 

Total PV 

Annual 

-$ -$ -$ $ - $ 

-$ -$ -$ $ - $ 

ized 0.01$ $ 0.23 $ 0.00 $ 0.30 $ 0.17 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14c Present Value of Agency Activity Costs for Alternative 1 at 7 Percent, by 

Year 

Implement 

ation 

Annual 

Administra 

tion 

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant

Residual 

$ 0.14 $ 2.73 $ 0.02 $ 3.48 $ 1.94 
$ - -$ -$ 

Turbidity 

Monitoring 

Nitrate/ Nitrite 

Monitoring 

O&M 

Plan 

1 0.09$ -$ $ 0.02 -$ $ - $ - 

2 0.09$ -$ $ 0.02 -$ $ - $ - -$ -$ $ - 3 -$ $ 0.23 -$ $ 1.62 $ 0.64 $ - -$ -$ $ 4.31 

4 -$ $ 0.21 -$ $ 1.48 $ 0.60 $ - -$ -$ $ 4.03 

5 -$ $ 0.20 -$ $ 1.39 $ 0.56 $ - -$ -$ $ 3.76 

6 -$ $ 0.18 -$ $ 1.29 $ 0.52 $ - -$ -$ $ 3.52 

7 -$ $ 0.17 -$ $ 1.21 $ 0.49 $ - -$ -$ $ 3.29 

8 -$ $ 0.16 -$ $ 1.13 $ 0.45 $ - -$ -$ $ 3.07 

9 -$ $ 0.15 -$ $ 1.06 $ 0.42 $ - -$ -$ $ 2.87 

10 -$ $ 0.14 -$ $ 0.99 $ 0.40 $ - -$ -$ $ 2.68 

11 -$ $ 0.13 -$ $ 0.92 $ 0.37 $ - -$ -$ $ 2.51 

12 -$ $ 0.12 -$ $ 0.86 $ 0.35 $ - -$ -$ $ 2.34 

13 -$ $ 0.11 -$ $ 0.82 $ 0.32 $ - -$ -$ $ 2.19 

14 -$ $ 0.11 -$ $ 0.75 $ 0.30 $ - -$ -$ $ 2.05 

15 -$ $ 0.10 -$ $ 0.70 $ 0.28 $ - -$ -$ $ 1.91 

16 -$ $ 0.09 -$ $ 0.66 $ 0.26 $ - -$ -$ $ 1.79 

17 -$ $ 0.09 -$ $ 0.61 $ 0.25 $ - -$ -$ $ 1.67 

18 -$ $ 0.08 -$ $ 0.57 $ 0.23 $ - -$ -$ $ 1.56 

19 -$ $ 0.08 -$ $ 0.54 $ 0.22 $ - -$ -$ $ 1.46 

20 -$ $ 0.07 -$ $ 0.50 $ 0.20 $ - -$ -$ $ 1.36 

21 -$ $ 0.07 -$ $ 0.47 $ 0.19 $ - -$ -$ $ 1.28 

22 -$ $ 0.06 -$ $ 0.44 $ 0.18 $ - -$ -$ $ 1.19 

23 -$ $ 0.06 -$ $ 0.41 $ 0.16 $ - -$ -$ $ 1.11 

24 -$ $ 0.05 -$ $ 0.38 $ 0.15 $ - -$ -$ $ 1.04 

25 -$ $ 0.05 -$ $ 0.36 $ 0.14 $ - -$ -$ $ 0.97 

7.68 $ - -$ -$ $ 51.99

al 

0.02$ $ 0.23 $ 0.00 $ 1.65 $ 0.66 $ - -$ -$ $ 4.46

$ 0.18 $ 2.73 $ 0.04 $ 19.18 $ 

Annuized 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14d Present Value of Rule Activity Costs for Alternative 2 at 7 Percent, by Y

Year 

Implemen A

tation 

Annual 

dministrati 

on 

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant 

Residual 

Routine 

Disinfection &

Flushing 

Total PV 
$ - -$ -$ $

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M 

Plan 

1 0.02$ $ - $ 0.01 -$ $ - - 

2 0.02$ $ - $ 0.01 -$ $ - $ - -$ -$ $ - 

3 -$ $ - -$ $ 1.61 $ 0.48 $ - -$ -$ $ 3.64 -$ $ - -$ $ 1.47 $ 0.45 $ - -$ -$ $ 3.45 -$ $ - -$ $ 1.37 $ 0.42 $ - -$ -$ $ 3.26 -$ $ - -$ $ 1.28 $ 0.39 $ - -$ -$ $ 2.97 -$ $ - -$ $ 1.20 $ 0.36 $ - -$ -$ $ 2.8

8 -$ $ - -$ $ 1.12 $ 0.34 $ - -$ -$ $ 2.69 -$ $ - -$ $ 1.05 $ 0.32 $ - -$ -$ $ 2.4

10 -$ $ - -$ $ 0.98 $ 0.30 $ - -$ -$ $ 2.2

11 -$ $ - -$ $ 0.92 $ 0.28 $ - -$ -$ $ 2.1

12 -$ $ - -$ $ 0.86 $ 0.26 $ - -$ -$ $ 2.0

13 -$ $ - -$ $ 0.82 $ 0.24 $ - -$ -$ $ 1.8

14 -$ $ - -$ $ 0.75 $ 0.23 $ - -$ -$ $ 1.7

15 -$ $ - -$ $ 0.70 $ 0.21 $ - -$ -$ $ 1.6

16 -$ $ - -$ $ 0.65 $ 0.20 $ - -$ -$ $ 1.5

17 -$ $ - -$ $ 0.61 $ 0.18 $ - -$ -$ $ 1.4

18 -$ $ - -$ $ 0.57 $ 0.17 $ - -$ -$ $ 1.3

19 -$ $ - -$ $ 0.53 $ 0.16 $ - -$ -$ $ 1.2

20 -$ $ - -$ $ 0.50 $ 0.15 $ - -$ -$ $ 1.1

21 -$ $ - -$ $ 0.47 $ 0.14 $ - -$ -$ $ 1.0

22 -$ $ - -$ $ 0.44 $ 0.13 $ - -$ -$ $ 1.0

23 -$ $ - -$ $ 0.41 $ 0.12 $ - -$ -$ $ 0.9

24 -$ $ - -$ $ 0.38 $ 0.12 $ - -$ -$ $ 0.8

25 -$ $ - -$ $ 0.36 $ 0.11 $ - -$ -$ $ 0.8

$ -

lized 0.00$ $ - $ 0.00 $ 1.63 $ 0.49 $ - -$ -$ $ 3.8

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13`) in the 25-year evaluation period.

5 $ - -$ -$ 

Total PV 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14e Present Value of Air Carrier Activity Costs for Alternative 2 at 7 Percent, 

Year 

Implementa 

tion 

Annual 

Administration 

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant 

Residual 

Routine 

Disinfection & 

Flushing 

$ 0.04 $ 0.03 $ 19.04 $ 5.7 $ 44.2

Annua 
- $ - $ - $

- $ - $ - $

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

O&M 

Plan 

1 0.07 $ $ - $ 0.01 -$ $ - $ -

2 0.07 $ $ - $ 0.01 -$ $ - $ -

3 - $ $ 0.23 $ - $ 0.01 $ 0.16 $ - $ - $ - $ 0.64 $ 

4 - $ $ 0.21 $ - $ 0.01 $ 0.15 $ - $ - $ - $ 0.60 $ 

5 - $ $ 0.20 $ - $ 0.01 $ 0.14 $ - $ - $ - $ 0.56 $ 

6 - $ $ 0.18 $ - $ 0.01 $ 0.13 $ - $ - $ - $ 0.52 $ 

7 - $ $ 0.17 $ - $ 0.01 $ 0.12 $ - $ - $ - $ 0.49 $ 

8 - $ $ 0.16 $ - $ 0.01 $ 0.11 $ - $ - $ - $ 0.46 $ 

9 - $ $ 0.15 $ - $ 0.01 $ 0.11 $ - $ - $ - $ 0.43 $ 

10 - $ $ 0.14 $ - $ 0.01 $ 0.10 $ - $ - $ - $ 0.40 $ 

11 - $ $ 0.13 $ - $ 0.01 $ 0.09 $ - $ - $ - $ 0.37 $ 

12 - $ $ 0.12 $ - $ 0.01 $ 0.09 $ - $ - $ - $ 0.35 $ 

13 - $ $ 0.11 $ - $ 0.01 $ 0.08 $ - $ - $ - $ 0.33 $ 

14 - $ $ 0.11 $ - $ 0.01 $ 0.08 $ - $ - $ - $ 0.30 $ 

15 - $ $ 0.10 $ - $ 0.01 $ 0.07 $ - $ - $ - $ 0.28 $ 

16 - $ $ 0.09 $ - $ 0.00 $ 0.07 $ - $ - $ - $ 0.27 $ 

17 - $ $ 0.09 $ - $ 0.00 $ 0.06 $ - $ - $ - $ 0.25 $ 

18 - $ $ 0.08 $ - $ 0.00 $ 0.06 $ - $ - $ - $ 0.23 $ 

19 - $ $ 0.08 $ - $ 0.00 $ 0.05 $ - $ - $ - $ 0.22 $ 

20 - $ $ 0.07 $ - $ 0.00 $ 0.05 $ - $ - $ - $ 0.20 $ 

21 - $ $ 0.07 $ - $ 0.00 $ 0.05 $ - $ - $ - $ 0.19 $ 

22 - $ $ 0.06 $ - $ 0.00 $ 0.04 $ - $ - $ - $ 0.18 $ 

23 - $ $ 0.06 $ - $ 0.00 $ 0.04 $ - $ - $ - $ 0.17 $ 

24 - $ $ 0.05 $ - $ 0.00 $ 0.04 $ - $ - $ - $ 0.16 $ 

25 - $ $ 0.05 $ - $ 0.00 $ 0.04 $ - $ - $ - $ 0.14 $ 

$ 

$ 

CA D

lized $ 0.01 $ 0.23 $ 0.00 $ 0.01 $ 

ua 

$ 0.14 $ 2.73 $ 0.02 $ 0.14 $ 

Ann

0.17 $ - $ - $ -

1.94 $ - $ - $ -

0.66 $ 

7.74 $ 

$ 

Not1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

es: 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14f Present Value of Agency Activity Costs for Alternative 2 at 7 Percent, by Y

Year 

Implementa 

tion 

Annual 

Administration

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant 

Residual 

Routine 

Disinfection &

Flushing 

Total PV $ 
1 0.09$ -$ $ 0.01 -$ $ - $ - -$ $ 0.06 -$ $ - 

2 0.09$ -$ $ 0.01 -$ $ - $ - -$ $ 0.06 -$ $ - 

3 -$ $ 0.23 -$ $ 2.16 $ - $ 12.35 -$ -$ $ 2.83 $ 0

4 -$ $ 0.21 -$ $ 1.98 $ - $ 11.49 -$ -$ $ 2.65 $ 0.

5 -$ $ 0.20 -$ $ 1.85 $ - $ 10.74 -$ -$ $ 2.47 $ 0.

6 -$ $ 0.18 -$ $ 1.73 $ - $ 10.04 -$ -$ $ 2.31 $ 0.

7 -$ $ 0.17 -$ $ 1.62 $ - $ 9.38 -$ -$ $ 2.16 $ 0

8 -$ $ 0.16 -$ $ 1.51 $ - $ 8.80 -$ -$ $ 2.02 $ 0

9 -$ $ 0.15 -$ $ 1.41 $ - $ 8.20 -$ -$ $ 1.89 $ 0

10 -$ $ 0.14 -$ $ 1.32 $ - $ 7.66 -$ -$ $ 1.76 $ 0

11 -$ $ 0.13 -$ $ 1.24 $ - $ 7.16 -$ -$ $ 1.65 $ 0

12 -$ $ 0.12 -$ $ 1.16 $ - $ 6.69 -$ -$ $ 1.54 $ 0.

13 -$ $ 0.11 -$ $ 1.10 $ - $ 6.28 -$ -$ $ 1.44 $ 0.

14 -$ $ 0.11 -$ $ 1.01 $ - $ 5.84 -$ -$ $ 1.35 $ 0.

15 -$ $ 0.10 -$ $ 0.94 $ - $ 5.46 -$ -$ $ 1.26 $ 0.

16 -$ $ 0.09 -$ $ 0.88 $ - $ 5.10 -$ -$ $ 1.17 $ 0

17 -$ $ 0.09 -$ $ 0.82 $ - $ 4.77 -$ -$ $ 1.10 $ 0

18 -$ $ 0.08 -$ $ 0.77 $ - $ 4.47 -$ -$ $ 1.03 $ 0

19 -$ $ 0.08 -$ $ 0.72 $ - $ 4.17 -$ -$ $ 0.96 $ 0

20 -$ $ 0.07 -$ $ 0.67 $ - $ 3.89 -$ -$ $ 0.90 $ 0

21 -$ $ 0.07 -$ $ 0.63 $ - $ 3.64 -$ -$ $ 0.84 $ 0

22 -$ $ 0.06 -$ $ 0.59 $ - $ 3.40 -$ -$ $ 0.78 $ 0.

23 -$ $ 0.06 -$ $ 0.55 $ - $ 3.19 -$ -$ $ 0.73 $ 0.

24 -$ $ 0.05 -$ $ 0.51 $ - $ 2.97 -$ -$ $ 0.68 $ 0

25 -$ $ 0.05 -$ $ 0.48 $ - $ 2.78 -$ -$ $ 0.64 $ 0

$ - -$ 

lized 0.02$ $ 0.23 0.00 $ $ 2.20 $ - $ 12.74 -$ $ 0.01 2.93 $ $ 0.

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Monitoring -

Disinfectant 

Residual 

Nitrate/ 

Nitrite 

Year Monitoring 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14g Present Value of Rule Activity Costs for Alternative 3 at 7 Percent, by Year 

Implement 

ation 

Annual 

Adminis

tration 

 Monitoring 

Plan 

Monitoring -

TC 

Turbidity 

Monitoring 

Routine 

O&M Disinfection CA Disinfecti

Plan & Flushing & Flushing 

Total PV $ 0.18 $ 2.73 $ 0.02 $ 25.66 $ 148.47 $ 0.12 $ 34.15 $ 0.

Annua 
2 0.02$ -$ $ 0.01 -$ $ - $ - -$ $ 0.05 $ - $ 

3 -$ -$ -$ $ 2.14 $ - $ 11.38 -$ -$ $ 2.83 $ 

4 -$ -$ -$ $ 1.97 $ - $ 10.59 -$ -$ $ 2.65 $ 

5 -$ -$ -$ $ 1.84 $ - $ 9.90 -$ -$ $ 2.47 $ 

6 -$ -$ -$ $ 1.72 $ - $ 9.25 -$ -$ $ 2.31 $ 

7 -$ -$ -$ $ 1.61 $ - $ 8.65 -$ -$ $ 2.16 $ 

8 -$ -$ -$ $ 1.51 $ - $ 8.12 -$ -$ $ 2.02 $ 

9 -$ -$ -$ $ 1.41 $ - $ 7.55 -$ -$ $ 1.89 $ 

10 -$ -$ -$ $ 1.32 $ - $ 7.06 -$ -$ $ 1.76 $ 

11 -$ -$ -$ $ 1.23 $ - $ 6.60 -$ -$ $ 1.65 $ 

12 -$ -$ -$ $ 1.15 $ - $ 6.17 -$ -$ $ 1.54 $ 

13 -$ -$ -$ $ 1.09 $ - $ 5.79 -$ -$ $ 1.44 $ 

14 -$ -$ -$ $ 1.00 $ - $ 5.39 -$ -$ $ 1.35 $ 

15 -$ -$ -$ $ 0.94 $ - $ 5.03 -$ -$ $ 1.26 $ 

16 -$ -$ -$ $ 0.88 $ - $ 4.70 -$ -$ $ 1.17 $ 

17 -$ -$ -$ $ 0.82 $ - $ 4.40 -$ -$ $ 1.10 $ 

18 -$ -$ -$ $ 0.77 $ - $ 4.13 -$ -$ $ 1.03 $ 

19 -$ -$ -$ $ 0.72 $ - $ 3.84 -$ -$ $ 0.96 $ 

20 -$ -$ -$ $ 0.67 $ - $ 3.59 -$ -$ $ 0.90 $ 

21 -$ -$ -$ $ 0.62 $ - $ 3.35 -$ -$ $ 0.84 $ 

22 -$ -$ -$ $ 0.58 $ - $ 3.13 -$ -$ $ 0.78 $ 

23 -$ -$ -$ $ 0.55 $ - $ 2.94 -$ -$ $ 0.73 $ 

24 -$ -$ -$ $ 0.51 $ - $ 2.74 -$ -$ $ 0.68 $ 

25 -$ -$ -$ $ 0.48 $ - $ 2.56 -$ -$ $ 0.64 $ 

Monitoring -

Disinfectant 

Residual 

$ -

-$ 

lized 0.00$ -$ $ 0.00 $ 2.19 $ - $ 11.74 -$ $ 0.01 $ 2.93 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

$ - -$ 

Year 

1 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14h Present Value of Air Carrier Activity Costs for Alternative 3 at 7 Percent, 

Implementa 

tion 

Annual 

Administra 

tion 

Monitoring 

Plan 

Monitoring -

TC 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring 

O&M 

Plan 

Routine 

Disinfection & 

Flushing 

CA 

0.02$ -$ $ 0.01 $ - $ - -$ $ 0.05 $ - $ 

Total PV $ 0.04 $ 0.01 $ 25.52 $ 136.86 $ 0.10 $ 34.15 $ 

Annua 
-$ $ 0.01 $ -

-$ $ 0.01 $ -

itrate/Nitrite 

Monitoring 

Disinfection & 

Flushing 

O&M 

Plan 

N

Routine 

$ 

$ 

CA 

2 0.07$ -$ $ 0.00 -$ $ - $ -

3 -$ 0.23$ -$ $ 0.01 $ - $ 0.96 -$ -$ $ - $ 

4 -$ 0.21$ -$ $ 0.01 $ - $ 0.90 -$ -$ $ - $ 

5 -$ 0.20$ -$ $ 0.01 $ - $ 0.84 -$ -$ $ - $ 

6 -$ 0.18$ -$ $ 0.01 $ - $ 0.79 -$ -$ $ - $ 

7 -$ 0.17$ -$ $ 0.01 $ - $ 0.73 -$ -$ $ - $ 

8 -$ 0.16$ -$ $ 0.01 $ - $ 0.69 -$ -$ $ - $ 

9 -$ 0.15$ -$ $ 0.01 $ - $ 0.64 -$ -$ $ - $ 

10 -$ 0.14$ -$ $ 0.01 $ - $ 0.60 -$ -$ $ - $ 11 -$ 0.13$ -$ $ 0.01 $ - $ 0.56 -$ -$ $ - $ 12 -$ 0.12$ -$ $ 0.01 $ - $ 0.52 -$ -$ $ - $ 13 -$ 0.11$ -$ $ 0.01 $ - $ 0.49 -$ -$ $ - $ 14 -$ 0.11$ -$ $ 0.01 $ - $ 0.46 -$ -$ $ - $ 15 -$ 0.10$ -$ $ 0.01 $ - $ 0.43 -$ -$ $ - $ 

16 -$ 0.09$ -$ $ 0.00 $ - $ 0.40 -$ -$ $ - $ 17 -$ 0.09$ -$ $ 0.00 $ - $ 0.37 -$ -$ $ - $ 18 -$ 0.08$ -$ $ 0.00 $ - $ 0.35 -$ -$ $ - $ 19 -$ 0.08$ -$ $ 0.00 $ - $ 0.33 -$ -$ $ - $ 20 -$ 0.07$ -$ $ 0.00 $ - $ 0.30 -$ -$ $ - $ 21 -$ 0.07$ -$ $ 0.00 $ - $ 0.28 -$ -$ $ - $ 22 -$ 0.06$ -$ $ 0.00 $ - $ 0.27 -$ -$ $ - $ 23 -$ 0.06$ -$ $ 0.00 $ - $ 0.25 -$ -$ $ - $ 24 -$ 0.05$ -$ $ 0.00 $ - $ 0.23 -$ -$ $ - $ 25 -$ 0.05$ -$ $ 0.00 $ - $ 0.22 -$ -$ $ - $ 

1 0.07$ -$ $ 0.00 -$ $ - $ -

1 $ - $ 

4 $ - $ 

- $ - $ 

$ - $ 

$ - $ 

Annua lized 0.01$ 0.23$ $ 0.00 0.0$ 1.00 $ 0.00 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14i Present Value of Agency Activity Costs for Alternative 3 at 7 Percent, by 

Year 

Implement

tion 

Annual 

a Administra 

tion 

Total PV $ 0.14 $ 2.73 $ 0.01 $ 0.1 $ 

Monitoring 

Plan 

Monitoring -

TC 

Monitoring -

Disinfectant 

Residual 

Turbidity

Monitoring

11.61 0.02 
$ - $ - -$ 

$ - $ - -$ 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/ 

Nitrite 

Monitoring 

1 $ 

Year ti

25 -$ 0.05$ -$ $ 1.06 $ - $ - -$ -$ $ 0.45 $ 

0.09 - $ $ 0.02 -$ $ 0.11 $ - $ 

2 0.09$ -$ $ 0.02 -$ $ 0.10 $ - $ 

3 -$ 0.23$ -$ $ 4.73 $ - $ - -$ -$ $ 1.98 $ 

4 -$ 0.21$ -$ $ 4.39 $ - $ - -$ -$ $ 1.85 $ 

5 -$ 0.20$ -$ $ 4.10 $ - $ - -$ -$ $ 1.73 $ 

6 -$ 0.18$ -$ $ 3.83 $ - $ - -$ -$ $ 1.62 $ 

7 -$ 0.17$ -$ $ 3.58 $ - $ - -$ -$ $ 1.51 $ 

8 -$ 0.16$ -$ $ 3.35 $ - $ - -$ -$ $ 1.41 $ 

9 -$ 0.15$ -$ $ 3.13 $ - $ - -$ -$ $ 1.32 $ 

10 -$ 0.14$ -$ $ 2.92 $ - $ - -$ -$ $ 1.23 $ 11 -$ 0.13$ -$ $ 2.73 $ - $ - -$ -$ $ 1.15 $ 12 -$ 0.12$ -$ $ 2.55 $ - $ - -$ -$ $ 1.08 $ 13 -$ 0.11$ -$ $ 2.40 $ - $ - -$ -$ $ 1.01 $ 14 -$ 0.11$ -$ $ 2.23 $ - $ - -$ -$ $ 0.94 $ 15 -$ 0.10$ -$ $ 2.08 $ - $ - -$ -$ $ 0.88 $ 

16 -$ 0.09$ -$ $ 1.95 $ - $ - -$ -$ $ 0.82 $ 17 -$ 0.09$ -$ $ 1.82 $ - $ - -$ -$ $ 0.77 $ 18 -$ 0.08$ -$ $ 1.70 $ - $ - -$ -$ $ 0.72 $ 19 -$ 0.08$ -$ $ 1.59 $ - $ - -$ -$ $ 0.67 $ 20 -$ 0.07$ -$ $ 1.49 $ - $ - -$ -$ $ 0.63 $ 21 -$ 0.07$ -$ $ 1.39 $ - $ - -$ -$ $ 0.59 $ 22 -$ 0.06$ -$ $ 1.30 $ - $ - -$ -$ $ 0.55 $ 23 -$ 0.06$ -$ $ 1.21 $ - $ - -$ -$ $ 0.51 $ 

24 -$ 0.05$ -$ $ 1.13 $ - $ - -$ -$ $ 0.48 $ 

$ - $ - -$ 

lized $ 

Notes: 

Annua 

0.02 0.23$ $ 0.00 $ 4.86 $ - $ - $ - $ 0.02 $ 2.05 $ 

1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14j Present Value of Rule Activity Costs for Alternative 4 (Final Rule) at 7 Perce

Implemen

on 

Annual 

Administra

tion 

ta Sampling 

Plan 

Monitoring -

TC 

O&M 

Plan 

Routine 

Disinfection & 

Flushing 

CA 

Total PV $ 0.18 $ 2.73 $ 0.04 $ 56.65 $ 0.21 $ 23.91 $ 
-$ 

Annu

dminis

tion 

nta A

al 

tra 

1 0.02$ $ 0.01 -$ $ - $ - -$ $ 0.11 $ - $ 

2 0.02$ -$ $ 0.01 -$ $ - $ - -$ $ 0.10 $ - $ 

3 -$ -$ -$ $ 4.69 $ - $ - -$ -$ $ 1.98 $ 4 -$ -$ -$ $ 4.35 $ - $ - -$ -$ $ 1.85 $ 5 -$ -$ -$ $ 4.06 $ - $ - -$ -$ $ 1.73 $ 6 -$ -$ -$ $ 3.80 $ - $ - -$ -$ $ 1.62 $ 7 -$ -$ -$ $ 3.55 $ - $ - -$ -$ $ 1.51 $ 

8 -$ -$ -$ $ 3.32 $ - $ - -$ -$ $ 1.41 $ 9 -$ -$ -$ $ 3.10 $ - $ - -$ -$ $ 1.32 $ 

10 -$ -$ -$ $ 2.90 $ - $ - -$ -$ $ 1.23 $ 11 -$ -$ -$ $ 2.71 $ - $ - -$ -$ $ 1.15 $ 12 -$ -$ -$ $ 2.53 $ - $ - -$ -$ $ 1.08 $ 13 -$ -$ -$ $ 2.38 $ - $ - -$ -$ $ 1.01 $ 14 -$ -$ -$ $ 2.21 $ - $ - -$ -$ $ 0.94 $ 15 -$ -$ -$ $ 2.07 $ - $ - -$ -$ $ 0.88 $ 

16 -$ -$ -$ $ 1.93 $ - $ - -$ -$ $ 0.82 $ 17 -$ -$ -$ $ 1.80 $ - $ - -$ -$ $ 0.77 $ 18 -$ -$ -$ $ 1.69 $ - $ - -$ -$ $ 0.72 $ 19 -$ -$ -$ $ 1.58 $ - $ - -$ -$ $ 0.67 $ 20 -$ -$ -$ $ 1.47 $ - $ - -$ -$ $ 0.63 $ 21 -$ -$ -$ $ 1.38 $ - $ - -$ -$ $ 0.59 $ 22 -$ -$ -$ $ 1.29 $ - $ - -$ -$ $ 0.55 $ 23 -$ -$ -$ $ 1.20 $ - $ - -$ -$ $ 0.51 $ 24 -$ -$ -$ $ 1.12 $ - $ - -$ -$ $ 0.48 $ 25 -$ -$ -$ $ 1.05 $ - $ - -$ -$ $ 0.45 $ 

-$ $ - $ - -$ 

lized 0.00$ -$ $ 0.00 $ 4.82 $ - $ - -$ $ 0.02 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.

2.05 $ 

3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitr

Monitoring 

ite 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14k Present Value of Air Carrier Activity Costs for Alternative 4 (Final Rule) at 7 Pe

Year 

Impleme

tion

Total PV $ 0.04

Sampling Monitoring -

Plan TC 

$ 0.03 $ 56.18

O&M 

Plan 

Routine 

Disinfection & 

Flushing 

CA 

$ 0.21 $ 

Annua 

23.91 $ 
$ - $ 

$ - $ 

$ - $ 

Routine 

Disinfection & 

Flushing 

CA 

$ - $ - -$ 

$ - $ - -$ - $ 

$ - $ - -$ 

$ - $ - -$ 

$ - $ - -$ 

Monitoring -

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring 

2 0.07$ -$ $ 0.01 -$ $ 0.00 

3 -$ 0.23$ -$ $ 0.04 -$ 

4 -$ 0.21$ -$ $ 0.04 $ - $ - -$ -$ $ - $ 

5 -$ 0.20$ -$ $ 0.03 $ - $ - -$ -$ $ - $ 

6 -$ 0.18$ -$ $ 0.03 $ - $ - -$ -$ $ - $ 

7 -$ 0.17$ -$ $ 0.03 $ - $ - -$ -$ $ - $ 

8 -$ 0.16$ -$ $ 0.03 $ - $ - -$ -$ $ - $ 

9 -$ 0.15$ -$ $ 0.03 $ - $ - -$ -$ $ - $ 

10 -$ 0.14$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

11 -$ 0.13$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

12 -$ 0.12$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

13 -$ 0.11$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

14 -$ 0.11$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

15 -$ 0.10$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

16 -$ 0.09$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

17 -$ 0.09$ -$ $ 0.02 $ - $ - -$ -$ $ - $ 

18 -$ 0.08$ -$ $ 0.01 $ - $ - -$ -$ $ - $ 

19 -$ 0.08$ -$ $ 0.01 $ - $ - -$ -$ $ - $ 

20 -$ 0.07$ -$ $ 0.01 $ - $ - -$ -$ $ - $ 

21 -$ 0.07$ -$ $ 0.01 $ - $ - -$ -$ $ - $ 

22 -$ 0.06$ -$ $ 0.01 $ - $ - -$ -$ $ - $ 

23 -$ 0.06$ -$ $ 0.01 -$ $ - $ 

24 -$ 0.05$ -$ $ 0.01 -$ $ 

$ - $ - -$ - $ 

1 0.07$ -$ $ 0.01 -$ $ 0.00 

25 -$ 0.05$ -$ $ 0.01 -$ $ 

$ - $ - -$ 

$ - $ - -$ 

Annua 

PV $ 0.14 $ 2.73 $ 0.01 $ 0.47

- $ 

- $ 

lized 0.01$ 0.23$ $ 0.00 $ 0.04 $ 0.00 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR.2) Present values in millions of 2008 dollars, discounted to Y1.3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit C.14l Present Value of Agency Activity Costs for Alternative 4 (Final Rule) at 7 Per

Year 

Implemen

tion 

Annual 

ta Administra 

tion 

Sampling 

Plan 

Monitoring -

TC 

Total 

$ 

O&M 

Plan 

$ 0.00
C.15 Summary
 

Page C-124
 

 

 

 

 

 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15a Summary of Rule Costs (Millions of 2008$) 

Summary of Implementation and Annual Administration Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Implementation 0.01 0.01 0.01 0.01 0.02 0.02 0.02 0.02 

Annual Administration 0.24 0.24 0.24 0.24 0.23 0.23 0.23 0.23 

Total 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25 

Summary of Annualized Monitoring Plan Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Monitoring Plan 0.002 0.002 0.001 0.002 0.004 0.004 0.002 0.003 

Total 0.002 0.002 0.001 0.002 0.004 0.004 0.002 0.003 

Summary of Annualized Monitoring Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Coliform Monitoring 25.37 1.67 2.23 4.93 25.02 1.65 2.20 4.86 

Total 25.37 1.67 2.23 4.93 25.02 1.65 2.20 4.86 

Summary of Annualized Monitoring Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Disinfectant Residual 

Monitoring 3.17 0.67 - - 3.13 0.66 - -

Total 3.17 0.67 - - 3.13 0.66 - -

Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Turbidity Monitoring - - 12.92 - - - 12.74 -

Total - - 12.92 - - - 12.74 -

Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Nitrate/Nitrite Monitoring - - - - - - - -

Total - - - - - - - -

Summary of Annualized O&M Plan Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

O&M Plan - - 0.01 0.01 - - 0.01 0.02 

Total - - 0.01 0.01 - - 0.01 0.02 

Page C-125
 

 

 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15a Summary of Rule Costs (Millions of 2008$) 

Summary of Annualized Disinfection and Flushing Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Routine Disinfection and 

Flushing - 4.52 2.97 2.08 - 4.46 2.93 2.05 

Total - 4.52 2.97 2.08 - 4.46 2.93 2.05 

Summary of Annualized Disinfection and Flushing Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Corrective Action 

Disinfection and Flushing - 0.05 0.05 0.05 - 0.05 0.05 0.05 

Total - 0.05 0.05 0.05 - 0.05 0.05 0.05 

Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Sanitary Survey/ Compliance 

Audit 0.70 - - 0.02 0.69 - - 0.02 

Total 0.70 - - 0.02 0.69 - - 0.02 

Summary of Annualized ADWR Costs (Millions of 2008$) 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 1 Alt 2 Alt 3 Alt 4 

3% 7% 

Total 29.49 7.16 18.43 7.34 29.08 7.07 18.19 7.25 

Page C-126
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15b Summary of Rule Costs (Millions of 2008$), Alternative 1 

Summary of Implementation and Annual Administration Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Implementation $ 0.002 $ 0.01 $ 0.01 $ 0.004 $ 0.01 $ 0.02 

Annual Administration -$ $ 0.24 $ 0.24 -$ $ 0.23 $ 0.23 

Total $ 0.002 $ 0.25 $ 0.25 $ 0.004 $ 0.25 $ 0.25 

Summary of Annualized Monitoring Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Monitoring Plan $ 0.002 $ 0.001 $ 0.002 $ 0.002 $ 0.001 $ 0.004 

Total $ 0.002 $ 0.001 $ 0.002 $ 0.002 $ 0.001 $ 0.004 

Summary of Annualized Coliform Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Coliform Monitoring $ 25.07 $ 0.30 $ 25.37 $ 24.72 $ 0.30 $ 25.02 

Total $ 25.07 $ 0.30 $ 25.37 $ 24.72 $ 0.30 $ 25.02 

Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Disinfectant Residual 

Monitoring $ 3.00 $ 0.17 $ 3.17 $ 2.96 $ 0.17 $ 3.13 

Total $ 3.00 $ 0.17 $ 3.17 $ 2.96 $ 0.17 $ 3.13 

Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Turbidity Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Nitrate/Nitrite Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized O&M Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

O&M Plan -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Page C-127
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15b Summary of Rule Costs (Millions of 2008$), Alternative 1 

Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Routine Disinfection and 

Flushing -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized Corrective Action Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Corrective Action 

Disinfection and Flushing -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Sanitary Survey/ 

Compliance Audit $ 0.03 $ 0.67 $ 0.70 $ 0.03 $ 0.66 $ 0.69 

Total $ 0.03 $ 0.67 $ 0.70 $ 0.03 $ 0.66 $ 0.69 

Summary of Annualized ADWR Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Total $ 28.11 $ 1.38 $ 29.49 $ 27.71 $ 1.37 $ 29.08

Page C-128
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15c Summary of Rule Costs (Millions of 2008$), Alternative 2 

Summary of Implementation and Annual Administration Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Implementation $ 0.002 $ 0.01 $ 0.01 $ 0.004 $ 0.01 $ 0.02 

Annual Administration -$ $ 0.24 $ 0.24 -$ $ 0.23 $ 0.23 

Total $ 0.002 $ 0.25 $ 0.25 $ 0.004 $ 0.25 $ 0.25 

Summary of Annualized Monitoring Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Monitoring Plan $ 0.002 $ 0.001 $ 0.002 $ 0.002 $ 0.001 $ 0.004 

Total $ 0.002 $ 0.001 $ 0.002 $ 0.002 $ 0.001 $ 0.004 

Summary of Annualized Coliform Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Coliform Monitoring $ 1.66 $ 0.01 $ 1.67 $ 1.63 $ 0.01 $ 1.65 

Total $ 1.66 $ 0.01 $ 1.67 $ 1.63 $ 0.01 $ 1.65 

Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Disinfectant Residual 

Monitoring $ 0.50 $ 0.17 $ 0.67 $ 0.49 $ 0.17 $ 0.66 

Total $ 0.50 $ 0.17 $ 0.67 $ 0.49 $ 0.17 $ 0.66 

Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Turbidity Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Nitrate/Nitrite Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized O&M Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

O&M Plan -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Page C-129
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15c Summary of Rule Costs (Millions of 2008$), Alternative 2 

Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Routine Disinfection and 

Flushing $ 3.85 $ 0.67 $ 4.52 $ 3.80 $ 0.66 $ 4.46 

Total $ 3.85 $ 0.67 $ 4.52 $ 3.80 $ 0.66 $ 4.46 

Summary of Annualized Corrective Action Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Corrective Action 

Disinfection and Flushing $ 0.05 -$ $ 0.05 $ 0.05 -$ $ 0.05 

Total $ 0.05 -$ $ 0.05 $ 0.05 -$ $ 0.05 

Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Sanitary Survey/ 

Compliance Audit -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized ADWR Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Total $ 6.06 $ 1.10 $ 7.16 $ 5.98 $ 1.09 $ 7.07

Page C-130
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15d Summary of Rule Costs (Millions of 2008$), Alternative 3 

Summary of Implementation and Annual Administration Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Implementation $ 0.002 $ 0.01 $ 0.01 $ 0.004 $ 0.01 $ 0.02 

Annual Administration -$ $ 0.24 $ 0.24 -$ $ 0.23 $ 0.23 

Total $ 0.002 $ 0.25 $ 0.25 $ 0.004 $ 0.25 $ 0.25 

Summary of Annualized Monitoring Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Monitoring Plan $ 0.001 $ 0.0004 $ 0.001 $ 0.001 $ 0.001 $ 0.002 

Total $ 0.001 $ 0.0004 $ 0.001 $ 0.001 $ 0.001 $ 0.002 

Summary of Annualized Coliform Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Coliform Monitoring $ 2.22 $ 0.01 $ 2.23 $ 2.19 $ 0.01 $ 2.20 

Total $ 2.22 $ 0.01 $ 2.23 $ 2.19 $ 0.01 $ 2.20 

Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Disinfectant Residual 

Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Turbidity Monitoring $ 11.910 $ 1.01 $ 12.92 $ 11.74 $ 1.00 $ 12.74 

Total $ 11.91 $ 1.01 $ 12.92 $ 11.74 $ 1.00 $ 12.74 

Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Nitrate/Nitrite Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized O&M Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

O&M Plan $ 0.01 $ 0.001 $ 0.01 $ 0.01 $ 0.001 $ 0.01 

Total $ 0.01 $ 0.001 $ 0.01 $ 0.01 $ 0.001 $ 0.01 

Page C-131
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15d Summary of Rule Costs (Millions of 2008$), Alternative 3 

Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Routine Disinfection and 

Flushing $ 2.97 -$ $ 2.97 $ 2.93 -$ $ 2.93 

Total $ 2.97 -$ $ 2.97 $ 2.93 -$ $ 2.93 

Summary of Annualized Corrective Action Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Corrective Action 

Disinfection and Flushing $ 0.05 -$ $ 0.05 $ 0.05 -$ $ 0.05 

Total $ 0.05 -$ $ 0.05 $ 0.05 -$ $ 0.05 

Summary of Annualized Sanitary Survey/Compliance Audit Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Sanitary Survey/ 

Compliance Audit -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized ADWR Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Total $ 17.17 $ 1.27 $ 18.43 $ 16.93 $ 1.26 $ 18.19

Page C-132
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15e Summary of Rule Costs (Millions of 2008$), Alternative 4 (Final Rule) 

Summary of Implementation and Annual Administration Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Implementation $ 0.002 $ 0.01 $ 0.01 $ 0.004 $ 0.01 $ 0.02 

Annual Administration -$ $ 0.24 $ 0.24 -$ $ 0.23 $ 0.23 

Total $ 0.002 $ 0.25 $ 0.25 $ 0.004 $ 0.25 $ 0.25 

Summary of Annualized Sampling Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Sampling Plan $ 0.002 $ 0.001 $ 0.002 $ 0.002 $ 0.001 $ 0.003 

Total $ 0.002 $ 0.001 $ 0.002 $ 0.002 $ 0.001 $ 0.003 

Summary of Annualized Coliform Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Coliform Monitoring $ 4.89 $ 0.04 $ 4.93 $ 4.82 $ 0.04 $ 4.86 

Total $ 4.89 $ 0.04 $ 4.93 $ 4.82 $ 0.04 $ 4.86 

Summary of Annualized Disinfectant Residual Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Disinfectant Residual 

Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized Turbidity Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Turbidity Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized Nitrate/Nitrite Monitoring Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Nitrate/Nitrite Monitoring -$ -$ -$ -$ -$ -$ 

Total -$ -$ -$ -$ -$ -$ 

Summary of Annualized O&M Plan Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

O&M Plan $ 0.01 $ 0.0001 $ 0.01 $ 0.02 $ 0.0001 $ 0.02 

Total $ 0.01 $ 0.0001 $ 0.01 $ 0.02 $ 0.0001 $ 0.02 

Page C-133
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Exhibit C.15e Summary of Rule Costs (Millions of 2008$), Alternative 4 (Final Rule) 

Summary of Annualized Routine Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Routine Disinfection and 

Flushing $ 2.08 -$ $ 2.08 $ 2.05 -$ $ 2.05 

Total $ 2.08 -$ $ 2.08 $ 2.05 -$ $ 2.05 

Summary of Annualized Corrective Action Disinfection and Flushing Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Corrective Action 

Disinfection and Flushing $ 0.05 -$ $ 0.05 $ 0.05 -$ $ 0.05 

Total $ 0.05 -$ $ 0.05 $ 0.05 -$ $ 0.05 

Summary of Annualized Compliance Audit Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Compliance Audit $ 0.01 $ 0.01 $ 0.02 $ 0.01 $ 0.01 $ 0.02 

Total $ 0.01 $ 0.01 $ 0.02 $ 0.01 $ 0.01 $ 0.02 

Summary of Annualized ADWR Costs (Millions of 2008$) 

Air Carriers Agency Total Air Carriers Agency Total 

3% 7% 

Total $ 7.04 $ 0.30 $ 7.34 $ 6.95 $ 0.30 $ 7.25

Page C-134
Page C-135
Appendix D 

Screening Analysis 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

D.1 Introduction and General Approach 

EPA has conducted a screening analysis to consider the economic impact of the final rule 

on small entities that own or operate air carriers. This analysis has been completed using the 

methodology described in the Regulatory Flexibility Act (RFA) as amended by the Small 

Business Regulatory Enforcement Fairness Act (SBREFA) of 1996 (5 U.S.C. §601 et seq.). 

The remaining sections of this document include the following information: 

• Section D.2—Definition of a Small Business 

• Section D.3—Screening Analysis of Small Entities 

• Section D.4—Baseline Information 

• Section D.5—Cost Information 

• Section D.6—Revenue Information 

• Section D.7—Results of Screening Analysis 

D.2 Definition of a Small Business 

U.S. aircraft are owned and operated exclusively by businesses. Therefore, the screening 

analysis for the ADWR uses the following definition for small entities: A “small business” is any 

firm that is independently owned and operated and is not dominant in its field of operation 

(Small Business Act, 15 U.S.C. 632). The RFA references this definition of “small business” 

and defines small entities as including “small businesses,” “small governments,” and “small 

organizations” (5 U.S.C. 601). 

The Small Business Administration’s (SBA) definitions of small businesses use 

categories are defined by National American Industry Classification System (NAICS) codes. 

For example, in the manufacturing sector, the SBA generally defines small businesses in terms of 

number of employees, but in the agriculture, mining, electric, gas, and sanitary services sectors, 

the SBA generally defines small businesses in terms of number of employees or annual receipts 

(ranging from $0.5 million for crops to $25 million for certain types of pipelines). 

EPA has determined that the following businesses would be affected by the Aircraft 

Drinking Water Rule (ADWR) based on the NAICS: 

• 481111 – Scheduled passenger air transportation 

• 481211 – Nonscheduled chartered passenger air transportation 

SBA defines a small business for air carriers (NAICS codes 481111 and 481211) as 

having fewer than 1,500 employees (13 CFR 121.201). 

D.3 Screening Analysis of Small Entities 

The screening analysis determines whether the ADWR will impose a significant 

economic impact on a substantial number of small entities. The Interim Guidance for EPA 

Page D-1 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

Rulewriters for the RFA as amended by the SBREFA (USEPA 1999) suggests using 1 percent of 

revenue as a threshold for determining if a cost impact of a regulation is “significant,” although 

additional factors may be considered. If the compliance costs for a new regulation are greater 

than 1 percent of sales or revenues for 100 or more entities and for more than 20 percent of all 

affected small entities, then in most cases there would be a significant impact. If more than 100 

entities experience economic impacts of 3 percent of their revenues or greater, then in most cases 

there would be a significant impact. Since there are fewer than 100 entities considered in this 

analysis, it is more meaningful to consider the percent of costs compared to revenue. 

Based on information available on the internet, industries, and from best professional 

judgment, EPA estimated costs associated with implementing the various components of the 

ADWR. Chapter 5 of this EA provides details on labor rates and estimated costs to air carriers. 

Revenue data (year 2005) for small businesses were obtained from Dun & Bradstreet 

(D&B) reports, which present an estimate of annual sales. Data were based on individual 

companies, rather than the parent company, using the conservative assumption that parent 

companies will not supplement the finances of their subsidiaries. 

The revenue of small air carriers does not reflect the low and sometimes negative profits 

of numerous air carriers in recent years, which may be influenced by a variety of factors. The 

following air carriers filed for Chapter 11 or Chapter 7 bankruptcy between 2004 and 2006 (Air 

Transport Association 2006): 

•	 U.S. Airways 

•	 Comair, Independence Air 

•	 Atlas Air 

•	 ERA Aviation 

•	 Delta Airlines 

•	 Florida Coastal Airlines 

•	 Northwest 

•	 Southeast 

•	 Aloha 

•	 TransMeridian 

•	 American Trans Air 

•	 Great Plains 

•	 Mesaba Airlines 

Several issues that affect air carrier profitability are summarized below: 

•	 The air carrier industry must accommodate a high tax burden, which can affect the 

profitability of businesses. 

•	 The air carrier industry is a heavily regulated industry. U.S. Federal Aviation 

Administration (FAA) requirements cover, among other things, retirement of older 

aircraft, security measures, collision avoidance systems, airborne windshear 

avoidance systems, noise abatement and other environmental concerns, commuter 

Page D-2 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

aircraft safety, and increased inspections and maintenance procedures in older 

aircraft. 

•	 In general, air carriers have limited pricing power due to the substantial price 

competition in the air carrier industry, especially in domestic markets. 

•	 Although many air carriers continue to cut benefits as labor agreements are 

renegotiated, benefits of air carrier employees have increased rapidly. 

•	 Crude oil prices have continued to rise dramatically. 

•	 World events (e.g., war, pandemic illnesses, terrorist attacks) and economic health 

affect numbers of air carrier passengers and, therefore, air carriers’ revenue and 

profit. 

In spite of these issues, air carriers have voiced a continuous commitment to ensure that 

drinking water on aircraft is safe for the public. 

D.4 Baseline Information 

Air carriers were considered individually, including those owned by a parent company. 

Air carriers subject to the rule usually operate aircraft serving 30 or more passengers. Aircraft 

that carry fewer than 30 passengers generally are not capable of taking water onboard, except 

chartered aircraft. 

Of the approximately 63 air carriers that may be subject to the ADWR, 30 are small 

businesses. These 30 air carriers represent 48 percent of the universe of air carriers subject to the 

final rule, and all will be subject to the various provisions. Therefore, EPA has determined that a 

substantial number of small entities will be impacted by the ADWR. 

Although each aircraft will be regulated as a separate water system, the economic impact 

of the rule is considered for air carriers in this analysis. The rationale for using this approach 

considers that one-time costs (e.g., developing a monitoring plan) will apply to the entire air 

carrier fleet and that revenue information is only available for air carriers. 

D.5 Revenue information 

Revenue information for most small air carriers was available from the private database, 

D&B. Revenue data were obtained from D&B in July 2006 and adjusted to 2008$. When 

revenue information was not available for a specific air carrier, EPA used the median revenue 

from air carriers included in this analysis. The average revenue for small air carriers subject to 

the ADWR is $106.6 million, and the median revenue is $57.2 million. One air carrier is a 

subsidiary of a large company and provides various services related to private jets. Although the 

company has fewer than 1,500 employees, it has substantially higher revenues than other small 

air carriers. Removing this company decreases the average revenue to $84.3 million. 

Page D-3 
 

 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule	 October 2009 

D.6 Cost Information 

Because many air carriers have been experiencing financial difficulties in recent years, 

EPA has made an effort to minimize the impact of the rule on these businesses. Air carriers have 

the flexibility to choose one of four disinfection/monitoring schedules that can be integrated into 

their current operations and maintenance (O&M) schedule. In addition, air carriers are only 

required to monitor for total coliform, similar to other transient noncommunity water systems 

(TNCWS) that obtain treated water from a parent system (i.e., consecutive systems do not have 

to monitor for nitrates and turbidity). 

As part of the regulatory development process, EPA has identified related existing 

programs and practices, and has determined how the new regulatory requirements can be 

integrated with them to avoid duplicative burden (e.g., inspections). Aircraft water systems have 

many different on-going programs and practices for assessing and correcting deficiencies and 

risks associated with the drinking water supply and related security and sanitation issues 

including: 

•	 U.S. Food and Drug Administration’s (FDA) regulations for Interstate Conveyance 

Sanitation (USFDA 2005); 

•	 FAA Airworthiness Standards: Transport Category Airplanes (Airworthiness 

maintenance and inspection program); 

•	 Vulnerability assessments/security program; 

•	 FDA sanitary surveys of watering points and servicing areas; 

•	 FDA approval and certification of watering points; 

•	 FDA certification of aircraft sanitation systems including potable water, sewage, and 

galleys. 

To estimate costs for small air carriers, EPA followed the same methodology as was used 

to develop the annualized implementation and incremental costs for the rule overall, as described 

in Chapter 5 of this EA. Exhibits D.1 and D.2 show present value costs by rule activity, 

annualized over 25 years using 3 and 7 percent discount rates, respectively. Total annual costs 

for all small air carriers are estimated to be $524,380 and $521,110, annualized at a 3 and 7 

percent discount rate, respectively. Average annual rule costs associated with the 30 individual 

small air carriers is approximately $17,543 (annualized at 3 percent). 

Page D-4 
Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit D.1 Total Present Value Implementation Costs for Small Air carriers, Annualized at 3 

Years 

Year Implementation 

Annual 

Administration Sampling Plan Monitoring - TC 

Monitoring - 

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine 

Disinfection & 

Flushing 

CA Disinfection 

& Flushing C

1 10,286 $ $ - $ 6,429 $ - $ - $ - $ - $ 51,430 $ - $ - $ 

2 $ 9,986 $ - $ 6,241 $ - $ - $ - $ - $ 49,932 $ - $ - $ 

3 $ - $ - $ - $ 383,523 $ - $ - $ - $ - $ 153,552 $ 3,446 $ 

4 $ - $ - $ - $ 355,962 $ - $ - $ - $ - $ 149,079 $ 3,345 $ 

5 $ - $ - $ - $ 345,595 $ - $ - $ - $ - $ 144,737 $ 3,248 $ 

6 $ - $ - $ - $ 335,529 $ - $ - $ - $ - $ 140,522 $ 3,153 $ 

7 $ - $ - $ - $ 325,756 $ - $ - $ - $ - $ 136,429 $ 3,061 $ 

8 $ - $ - $ - $ 316,268 $ - $ - $ - $ - $ 132,455 $ 2,972 $ 

9 $ - $ - $ - $ 307,056 $ - $ - $ - $ - $ 128,597 $ 2,886 $ 

10 $ - $ - $ - $ 298,113 $ - $ - $ - $ - $ 124,852 $ 2,802 $ 

11 $ - $ - $ - $ 289,430 $ - $ - $ - $ - $ 121,215 $ 2,720 $ 

12 $ - $ - $ - $ 281,000 $ - $ - $ - $ - $ 117,685 $ 2,641 $ 

13 $ - $ - $ - $ 285,377 $ - $ - $ - $ - $ 114,257 $ 2,564 $ 

14 $ - $ - $ - $ 264,869 $ - $ - $ - $ - $ 110,929 $ 2,489 $ 

15 $ - $ - $ - $ 257,155 $ - $ - $ - $ - $ 107,698 $ 2,417 $ 

16 $ - $ - $ - $ 249,665 $ - $ - $ - $ - $ 104,561 $ 2,346 $ 

17 $ - $ - $ - $ 242,393 $ - $ - $ - $ - $ 101,516 $ 2,278 $ 

18 $ - $ - $ - $ 235,333 $ - $ - $ - $ - $ 98,559 $ 2,212 $ 

19 $ - $ - $ - $ 228,479 $ - $ - $ - $ - $ 95,688 $ 2,147 $ 

20 $ - $ - $ - $ 221,824 $ - $ - $ - $ - $ 92,901 $ 2,085 $ 

21 $ - $ - $ - $ 215,363 $ - $ - $ - $ - $ 90,196 $ 2,024 $ 

22 $ - $ - $ - $ 209,090 $ - $ - $ - $ - $ 87,568 $ 1,965 $ 

23 $ - $ - $ - $ 203,000 $ - $ - $ - $ - $ 85,018 $ 1,908 $ 

24 $ - $ - $ - $ 197,088 $ - $ - $ - $ - $ 82,542 $ 1,852 $ 

25 $ - $ - $ - $ 191,347 $ - $ - $ - $ - $ 80,138 $ 1,798 $ 

Total PV $ 20,272 $ - $ 12,670 $ 6,239,216 $ - $ - $ - $ 101,361 $ 2,600,694 $ 58,357 $ 

Annualized $ 1,164 $ - $ 728 $ 358,305 $ - $ - $ - $ 5,821 $ 149,352 $ 3,351 $ 

Notes: 1) Public notification is not covered under ADWR, but is covered under PNR. 2) Present values in 2008 dollars, discounted to Y1. 3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.
Notes: 

$ 1,708 $ - $ 1,067 $ 353,651 -$ -$ $ - $ 8,538 $ 147,263 $ 3,304 $ 

Annualized 

1) Public notification is not covered under ADWR, but is covered under PNR. 

2) Present values in 2008 dollars, discounted to Y1. 3) Assume refrigerators are purchased two times (in years 3 and 13) in the 25-year evaluation period.

$ - $ - $ - $ 76,684 -$ -$ $ - $ - $ 32,116 $ 721 $ 

Year Implementation 

Annual 

Administration 

Sampling 

Plan Monitoring - TC 

Monitoring - 

Disinfectant 

Residual 

Turbidity 

Monitoring 

Nitrate/Nitrite 

Monitoring O&M Plan 

Routine 

Disinfection 

& Flushing 

CA Disinfection 

& Flushing C

1 10,286 $ $ - $ 6,429 $ - -$ -$ $ - $ 51,430 $ - $ - $ 

2 $ 9,613 $ - $ 6,008 $ - -$ -$ $ - $ 48,065 $ - $ - $ 

3 $ - $ - $ - $ 355,384 -$ -$ $ - $ - $ 142,286 $ 3,193 $ 

4 $ - $ - $ - $ 317,515 -$ -$ $ - $ - $ 132,977 $ 2,984 $ 

5 $ - $ - $ - $ 296,743 -$ -$ $ - $ - $ 124,278 $ 2,789 $ 

6 $ - $ - $ - $ 277,330 -$ -$ $ - $ - $ 116,148 $ 2,606 $ 

7 $ - $ - $ - $ 259,187 -$ -$ $ - $ - $ 108,549 $ 2,436 $ 

8 $ - $ - $ - $ 242,231 -$ -$ $ - $ - $ 101,448 $ 2,276 $ 

9 $ - $ - $ - $ 226,384 -$ -$ $ - $ - $ 94,811 $ 2,127 $ 

10 $ - $ - $ - $ 211,574 -$ -$ $ - $ - $ 88,609 $ 1,988 $ 

11 $ - $ - $ - $ 197,732 -$ -$ $ - $ - $ 82,812 $ 1,858 $ 

12 $ - $ - $ - $ 184,797 -$ -$ $ - $ - $ 77,394 $ 1,737 $ 

13 $ - $ - $ - $ 180,659 -$ -$ $ - $ - $ 72,331 $ 1,623 $ 

14 $ - $ - $ - $ 161,409 -$ -$ $ - $ - $ 67,599 $ 1,517 $ 

15 $ - $ - $ - $ 150,849 -$ -$ $ - $ - $ 63,177 $ 1,418 $ 

16 $ - $ - $ - $ 140,981 -$ -$ $ - $ - $ 59,044 $ 1,325 $ 

17 $ - $ - $ - $ 131,757 -$ -$ $ - $ - $ 55,181 $ 1,238 $ 

18 $ - $ - $ - $ 123,138 -$ -$ $ - $ - $ 51,571 $ 1,157 $ 

19 $ - $ - $ - $ 115,082 -$ -$ $ - $ - $ 48,197 $ 1,081 $ 

20 $ - $ - $ - $ 107,553 -$ -$ $ - $ - $ 45,044 $ 1,011 $ 

21 $ - $ - $ - $ 100,517 -$ -$ $ - $ - $ 42,097 $ 945 $ 

22 $ - $ - $ - $ 93,941 -$ -$ $ - $ - $ 39,343 $ 883 $ 

23 $ - $ - $ - $ 87,796 -$ -$ $ - $ - $ 36,769 $ 825 $ 

24 $ - $ - $ - $ 82,052 -$ -$ $ - $ - $ 34,364 $ 771 $ 

25 

$ 19,899 $ - $ 12,437 $ 4,121,296 $ - -$ $ - $ 99,495 $ 1,716,144 $ 38,509 $ 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Exhibit D.2 Total Present Value Implementation Costs for Small Air carriers, Annualized at 7 

Years 

Total PV 
 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

EPA estimates that the average annual incremental rule cost (the difference between the 

final rule and Alternative 1, compliance with the existing NPDWRs), is a reduction in cost of 

$258,599 at a 3 percent discount rate, and the average annual incremental rule costs between the 

final rule and Alternative 2, compliance with requirements similar to the Administrative Orders 

on Consent (AOCs), is a reduction in cost of $32,188 at a 3 percent discount rate. These results, 

shown in Exhibit D.3, demonstrate a cost savings for small entities by choosing the final rule 

over compliance with either the existing NPDWRs or compliance with requirements similar to 

the AOCs, which are the first two alternatives, respectively. 

Page D-7 
Small Air Carriers Experiencing Costs >1% of their Revenues 

Number -  Percent 0.00% Small Air Carriers Experiencing Costs >3% of their Revenues Number -  Percent 0.00% Source: Derived from the ADWR Cost Model. Average rule costs in 2008$. Note: Average revenue for small air carriers based on 2005 data. 

Exhibit D3: Results of the Screening Analysis for Alternatives 1, 2, and 4 

Total Number of Aircraft Owned by Small Air Carriers 514

Total Number of Small Air Carriers 30Average Revenues for Small Air Carriers $106,576,591 

Average Rule Costs for Small Air Carriers 

Alt 1 

(Existing 

NPDWRs) 

 $276,142

Alt 2 

(Similar to 

AOCs) 

$49,731 

Alt 4 

(Final ADWR) 

$17,543 

Economic and Supporting Analyses Document for the Final Aircraft Drinking Water Rule 

Alt 4 - Alt1 

 $(258,599) 

Average Cost/Revenue 0.26% 0.05% 0.02% 
 

 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule October 2009 

Recognizing the variation of sized companies within this group, EPA has estimated the 

average annual incremental cost for small air carriers with fewer than 500 employees and for 

small air carriers with 500 or more employees. The number of employees was taken from the 

baseline and from 2006 Bureau of Transportation Statistics (BTS) data1

. For air carriers with 

fewer than 500 employees, the incremental cost between the final rule and Alternative 1 is a 

reduction of $78,042 at a 3 percent discount rate, and the incremental average rule cost between 

the final rule and Alternative 2 is a reduction of $7,781 at a 3 percent discount rate (Exhibit D4). 

For air carriers with 500 or more employees, the incremental cost between the final rule and 

Alternative 1 is a reduction of $230,712 at a 3 percent discount rate, and the incremental average 

rule cost between the final rule and Alternative 2 is a reduction of $20,104 at a 3 percent 

discount rate (Exhibit D5). 

1

 Employee data from ATA Execujet was not available from any source. Since the air carrier only has one aircraft, 

EPA assumed that ATA Execujet has fewer than 500 employees. 

Page D-9 
- 

0.00% 

- 

0.00% 

Alt 4 - Alt1 

 $(78,042) 

Average Cost/Revenue 0.12% 0.02% 0.01% Small Air Carriers w/< 500 employees Experiencing Costs >1% of their Revenues Number Percent Small Air Carriers w/< 500 employees Experiencing Costs >3% of their Revenues Number Percent Source: Derived from the ADWR Cost Model. Average rule costs in 2008$ at 3% discount rate. Note: Average revenue for small air carriers based on 2005 data. 

129 

17

Total Number of Small Air Carriers w/< 500 employeesAverage Revenues for Small Air Carriers500 employees 

 w/< 

Exhibit D4: Results of the Screening Analysis for Small Air Carriers with Fewer than 500 

Total Number of Aircraft Owned by Small Air Carriers w/< 500 employees 

$72,903,528 

Average Rule Costs for Small Air Carriers w/< 500 employees 

Alt 1 

(Existing 

NPDWRs) 

$86,751 

Alt 2 

(Similar to 

AOCs) 

$16,490 

Alt 4 

(Final ADWR) 

$8,709 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 
Exhibit D5: Results of the Screening Analysis for Small Air Carriers with 500 or More E

Total Number of Aircraft Owned by Small Air Carriers w/ >500 Employees 385 Total Number of Small Air Carriers w/ >500 Employees 13Average Revenues for Small Air Carriers w/ >500 Employees $151,063,274 Average Rule Costs for Small Air Carriers w/ >500 Employees 

Alt 1 

(Existing 

NPDWRs) 

 $259,752 

Alt 2 

(Similar to 

AOCs) 

$49,144 

Alt 4 

(Final ADWR) 

$29,040 

Economic and Supporting Analyses for the Final Aircraft Drinking Water Rule 

Alt 4 - Alt1 

 $(230,712) 

Average Cost/Revenue 0.17% 0.03% 0.02% 

Small Air Carriers w/ >500 Employees Experiencing Costs >1% of their Revenues Number -  Percent 0.00% Small Air Carriers w/ >500 Employees Experiencing Costs >3% of their Revenues Number -  Percent 0.00% Source: Derived from the ADWR Cost Model. Average rule costs in 2008$ at 3% discount rate. Note: Average revenue for small air carriers based on 2005 data.