United States Government Accountability Office

Washington, DC 20548 

November 30, 2005 

The Honorable James M. Inhofe 

Chairman, Committee on 

 Environment and Public Works 

United States Senate 

The Honorable Mike Crapo 

United States Senate 

Subject: Federal Water Requirements: Challenges to Estimating the Cost Impact on 

Local Communities

Under the Safe Drinking Water Act and the Federal Water Pollution Control Act, 

commonly referred to as the Clean Water Act, the Environmental Protection Agency 

(EPA) has responsibility for protecting public health and welfare, as well as the 

integrity of our nation’s waters. Federal water requirements under these acts affect 

facilities providing the most basic services at the local level, including drinking water 

treatment plants and distribution systems; wastewater treatment plants and 

collection systems; and storm sewer systems, which collect storm water, or the 

runoff created by rainfall and other types of wet weather. For example, depending on 

the circumstances, local communities may have to pay for installing new treatment 

technologies or taking other measures so that community-based or regional facilities 

can meet applicable water quality standards. Nationwide, there are roughly 53,000 

community drinking water systems,1

 17,000 municipal wastewater treatment plants, 

and 7,000 communities served by municipal storm sewer collection systems2

 that may 

be affected by federal water requirements. 

While recognizing the public health and environmental benefits of federal water 

requirements, communities are increasingly voicing concerns about the financial 

burden imposed by these requirements—in particular, the projected costs of more 

recent regulations and their cumulative costs over time. Over the years, EPA, water 

and community associations, and other parties have developed various estimates of 

some of the different costs related to ensuring clean water and safe drinking water. 

Additionally, the Unfunded Mandates Reform Act of 1995 requires EPA to prepare a 

written statement identifying the costs and benefits of federal mandates contained in 

 1

There are also roughly 107,000 noncommunity water systems that may be affected by federal drinking water 

requirements. About 19,000 of these systems are located at facilities such as schools, factories, and hospitals, 

which regularly serve at least 25 of the same people at least 6 months per year. The remaining noncommunity 

water systems are located at facilities, such as gas stations and campgrounds, which serve transient populations. 2

Some municipalities have separate collection systems for wastewater and storm water, and some have combined 

collection systems. Both types may be affected by federal requirements and are included in this figure. 

Page 1 GAO-06-151R Federal Water Requirements
certain regulations. However, the act does not require EPA to identify the cumulative 

costs and benefits of multiple regulations. As the Congress considers legislation to 

provide more resources to communities to address regulatory costs and aging water 

infrastructure, it is seeking a more complete understanding of the federal water 

requirements affecting local communities and the cumulative costs associated with 

implementing them. 

In this context, you asked us to determine the cumulative cost of federal water

requirements. In conducting this work, we identified some major methodological 

challenges to developing complete and reliable cost information. We subsequently 

briefed your staffs on these challenges. This report summarizes the information 

provided to your staffs during our November 17, 2005, briefing and formally transmits 

the charts presented during that briefing (see enc. I). As requested, this report 

provides information on (1) key federal water requirements that local communities 

are subject to under the Safe Drinking Water Act and the Clean Water Act, (2) the 

extent to which existing studies provide information on the cumulative cost of such 

requirements to communities, and (3) the methodological challenges to developing 

reliable cumulative cost estimates attributable to federal water requirements. 

To respond to the first objective, we identified key federal water requirements and 

verified the accuracy and completeness of the list with EPA. Under the Safe Drinking 

Water Act, we included key regulations directed at local drinking water systems and 

excluded regulations that focused on analytical methods or provided clarification to 

existing requirements. For the Clean Water Act, we included key regulations that 

typically affect local wastewater treatment plants and municipalities with combined 

or separate storm sewer systems and excluded regulations that are specific to 

particular locations or involve technical clarifications. In addition, we met with 

representatives from more than 10 associations representing water and community 

interests to obtain their views on which requirements have had, or will have, the most 

significant cost impacts on local communities. In responding to the second objective, 

we conducted Internet searches and held discussions with EPA, the Congressional 

Budget Office, the Congressional Research Service, associations, and others to 

identify studies that estimated some aspect of costs associated with federal water 

requirements. Overall, we reviewed over 25 studies published between 1988 and 2005 

and summarized their scope, methodology, and findings. For the third objective, we 

conducted site visits to four communities, which we selected on the basis of three 

criteria: diversity in community size and level of complexity, community willingness 

to participate, and diversity of geographic location. During these site visits, we met 

with community and system managers to determine what information was available 

to support cumulative cost estimates, identify challenges to developing such 

estimates, and obtain perspectives on the federal water requirements that have had 

the most significant impact on their communities. We supplemented this information 

with examples of methodological challenges identified in existing cost studies and 

perspectives gathered in interviews with EPA, associations, and others. We 

conducted our review from February 2005 to October 2005 in accordance with 

generally accepted government auditing standards. 

Page 2 GAO-06-151R Federal Water Requirements
Summary 

The key requirements of the Safe Drinking Water Act and the Clean Water Act that 

communities must meet focus on limiting the exposure of customers to contaminants 

in water supplied by community drinking water systems and ensuring that 

communities prevent pollutants from sewage and diffuse sources, such as streets and 

construction sites, from reaching surrounding water bodies. (See enc. II for a list and 

brief description of these federal water requirements.) Under the Safe Drinking 

Water Act, EPA currently regulates over 90 contaminants, such as arsenic and lead, 

and is developing regulations on several more. Generally, as required by the Safe 

Drinking Water Act, EPA’s regulations establish a limit, or “maximum contaminant 

level,” for specific contaminants and require water systems to test the water 

periodically to determine if the quality is acceptable. If contaminant levels are too 

high, water systems must install new treatment technologies or take other measures 

to address the problem, such as finding a new water source. However, if it is not 

economically or technically feasible to ascertain the level of a contaminant, EPA may 

instead establish a treatment technique to prevent known or anticipated health 

effects. Other regulations require water systems to notify the public when 

contaminant levels exceed established limits and provide annual reports summarizing 

the results of all water quality testing. The Clean Water Act requires wastewater 

treatment plants to meet minimum technology-based effluent limitations. Plants also 

may need to implement additional, more stringent limitations, including those 

necessary to meet water quality standards. In addition, EPA requires municipalities 

to develop and implement management programs that help prevent pollutants in 

runoff from reaching surrounding bodies of water. In developing these plans, 

communities must adopt certain minimum practices, such as controls to reduce or 

eliminate pollution that collects on streets. 

While many parties, including EPA, various water and community associations, and 

private consulting firms, have developed cost estimates for different aspects of 

maintaining safe, clean water, these estimates have not provided information on the 

cumulative costs of complying with federal water requirements, primarily because 

they were not intended to do so. Some studies focus on developing a broad estimate 

of the costs of providing safe drinking water or clean water, but do not attempt to 

separate the costs associated with meeting regulatory requirements from other costs. 

For example, EPA’s 2000 Clean Watersheds Needs Survey presents the cost of 

projects needed, nationwide, to address water quality and public health problems, 

which EPA estimated to be $181.2 billion.3

 The study includes the costs of adding

capacity to accommodate population growth, replacing aging infrastructure, and 

complying with requirements in its estimates, among other costs, but it does not 

distinguish the portion of the total costs that are associated with meeting federal 

water requirements. In addition, many studies have a narrower scope, focusing on 

estimating costs for a subset of regulatory requirements and particular time periods, 

or estimate costs to different entities (e.g., states, private sector). For example, 

 3

The estimate includes current and projected abatement costs, in 2000 year dollars, for projects needed to address 

water quality or public health problems eligible for funding under the Clean Water State Revolving Fund. 

According to EPA, the quality of data informing the estimate was affected by the variation in the level of effort 

states put forth in reporting the cost data. We did not independently evaluate the estimation methodology for any

of the EPA estimates discussed in this report, nor did we evaluate the validity or the reliability of the survey and 

other data used to develop these estimates.

Page 3 GAO-06-151R Federal Water Requirements
EPA’s 2003 Drinking Water Infrastructure Needs Survey and Assessment presents an 

estimate of current and projected costs, for the time period of 2003 to 2022, for 

drinking water infrastructure investment needs, which totals $276.8 billion.4

 While 

EPA did distinguish the portion of the total cost attributable to compliance with 

regulatory requirements ($45.1 billion),5

 the estimates do not include expenditures 

prior to 2003, and only cover regulations under the Safe Drinking Water Act. (See enc. 

III for an abbreviated description of the studies we reviewed.) Similarly, although 

EPA is required to develop cost estimates for some individual regulations, by 

definition, these estimates are narrow in scope. While the estimates provide a 

measure of potential costs to comply with individual regulations, which EPA has 

estimated may reach into the hundreds of millions of dollars for some regulations,6

the estimates have been subject to criticism for both overestimating and 

underestimating actual implementation costs. Moreover, adding the projected costs 

of individual regulations together to obtain an estimate of actual cumulative cost 

impacts to communities would not provide a meaningful result because, among other 

reasons, the regulatory estimates are prospective, the range of uncertainty 

surrounding them is compounded as they are added together, and, in any event, 

estimates do not exist for all relevant federal water requirements. 

Several methodological challenges hinder new efforts to develop reliable cumulative 

cost estimates, including obtaining accurate and complete cost data, particularly for 

older requirements; accurately allocating costs (e.g., among jurisdictions that share 

costs); and establishing a causal link between community investments and federal 

water requirements. Therefore, any estimate of the cumulative costs of federal water 

regulations should be viewed in light of the following challenges and consequent data 

limitations.7

• Local communities often lack the institutional knowledge or historical records 

on the costs of treatment technologies or other operational changes. As a 

result, local officials may not be able to provide information on the costs 

associated with installing new treatment technologies or making other 

operational changes, when such changes occurred, or why they were made. 

• Even when data on the costs of treatment technologies or other operational 

changes are available, local officials often have trouble allocating costs 

attributable to federal water requirements partly because accounting systems 

generally track costs by project rather than by federal requirement. Cost 

 4

The estimate includes costs, in 2003 year dollars, for projects to protect public health, preserve the physical 

integrity of water systems, convey treated water to homes and commercial and industrial establishments, and 

ensure continued compliance with specific Safe Drinking Water Act regulations. According to EPA, there is some 

uncertainty in the estimates due to sampling error and the use of statistical cost models and regulatory economic 

analyses. 

5

The estimate includes costs, in 2003 year dollars, for projects directly attributable to specific Safe Drinking Water

Act regulations. According to EPA, there is some uncertainty in the estimates due to sampling error and the use of

statistical cost models and regulatory economic analyses. 6

Estimated costs for individual rules can vary widely, and in some instances, reach into the hundreds of millions of 

dollars. For example, EPA estimated that the Arsenic Rule would cost public water systems between $190 million 

and $227 million annually (in 1999 year dollars, annualized over 20 years using a commercial discount rate, which 

approximates 5 percent). 7

Two previous GAO reports, Regulatory Burden: Measurement Challenges and Concerns Raised by Selected

Companies, GAO/GGD-97-2 (Washington, D.C.: November 18, 1996), and Unfunded Mandates: Views Vary About 

Reform Act’s Strengths, Weaknesses, and Options for Improvement, GAO-05-454 (Washington, D.C.: March 31,

2005) presented similar limitations and concerns regarding the accuracy and completeness of regulatory cost 

estimates. 

Page 4 GAO-06-151R Federal Water Requirements
allocation is especially difficult when costs are shared by multiple, overlapping 

jurisdictions or when communities make system or program changes for 

multiple reasons, such as installing a new treatment technology that both 

meets federal requirements for safe drinking water and improves the water’s 

aesthetic quality. 

• Establishing a causal link between community investments and federal water 

requirements is also problematic in developing cost estimates. First, in some 

instances, there is no good measure of what communities would have done in 

the absence of federal water requirements that can be used as a baseline in 

developing cost estimates. Second, some investments are made in anticipation 

of potential federal requirements rather than in response to finalized ones. 

Consequently, because of the subjective judgments that would have to be 

made, it is difficult to reliably determine how far in advance of a requirement 

an investment can be made and still be attributed to that requirement. Third, 

because some states or regional entities may exercise their authority to 

establish requirements that are more stringent than the federal standards, 

some community investments may include costs beyond those fairly 

attributable to federal requirements. Identifying the federal portion of the 

costs is often not feasible because the authority and requirements of the 

multiple levels of government overlap. 

Information on the cumulative cost of federal water requirements is critical in 

determining the nature and extent of the financial burden on local communities. 

However, given the methodological challenges of obtaining accurate and complete 

cost data, accurately allocating costs, and establishing a causal link between 

community investments and federal water requirements, researchers face formidable 

obstacles in developing a reliable cumulative cost estimate. 

Agency Comments and Our Evaluation 

We requested comments on a draft of this report from the Administrator of the EPA 

or his designee. On November 9, 2005, we obtained oral comments from officials 

with EPA's Office of Water, including the Director of the Office of Ground Water and 

Drinking Water, the Deputy Director of the Municipal Support Division of the Office 

of Wastewater Management, and the Associate Director of the Water Permits Division 

of the Office of Wastewater Management. They generally agreed with our findings 

and provided some technical comments, which we have incorporated into this report 

where appropriate. 

- - - - - 

We are sending a copy of this report to EPA. Copies will be made available to others 

upon request. This report will also be available at no charge on GAO’s Web site at 

http://www.gao.gov. 

Page 5 GAO-06-151R Federal Water Requirements
If you have any questions about this report or need additional information, please 

contact me at (202) 512-3841 or by e-mail at stephensonj@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found on the last 

page of this report. Key contributors to this report include Ellen Crocker, Mark 

Braza, Nancy Crothers, Laura Gatz, Alyssa Hundrup, Richard Johnson, and Mehrzad 

Nadji. 

John B. Stephenson 

Director, Natural Resources 

 and Environment 

Enclosures - 3 

Page 6 GAO-06-151R Federal Water Requirements
Enclosure I

Page 7 GAO-06-151R Cost of Federal Water Requirements

Federal Water Requirements: Challenges to 

Estimating the Cost Impact on Local Communities

A Briefing for Congressional Requesters
Enclosure I

Page 8 GAO-06-151R Cost of Federal Water Requirements

Objectives

• Local concerns about the cumulative impact of federal water 

requirements prompted the original request.

• Revised objectives:

• What key federal water requirements are local communities 

subject to under the Safe Drinking Water Act (SDWA) and the 

Clean Water Act (CWA)?

• To what extent do existing studies provide information on the 

cumulative cost of such requirements to communities? 

• What are the methodological challenges to developing reliable 

cumulative estimates of costs attributable to federal water 

requirements?
Enclosure I

Page 9 GAO-06-151R Cost of Federal Water Requirements

Scope and Methodology

To meet our review objectives, we

• identified key federal water requirements,

• interviewed major stakeholders,

• reviewed cost studies, and

• conducted site visits to selected communities.
Enclosure I

Page 10 GAO-06-151R Cost of Federal Water Requirements

Background

Figure 1: Local-Level Facilities Subject to Federal Water Requirements 

under SDWA
Enclosure I

Page 11 GAO-06-151R Cost of Federal Water Requirements

Background

Figure 2: Local-Level Facilities Subject to Federal Water Requirements under 

CWA
Enclosure I

Page 12 GAO-06-151R Cost of Federal Water Requirements

Background

• Local-level facilities subject to federal water requirements:

• 53,000 community drinking water systems

• 17,000 municipal wastewater treatment plants

• 7,000 communities served by combined sewer systems 

and separate storm sewer systems
Enclosure I

Page 13 GAO-06-151R Cost of Federal Water Requirements

Background

• Typical types of operational changes that may be required to 

comply with federal water requirements:

• Installing new treatment technologies

• Adding new chemicals during treatment

• Identifying a new source of drinking water (e.g., drilling a new

well)

• Adopting best management practices, such as sweeping 

parking lots and streets
Enclosure I

Page 14 GAO-06-151R Cost of Federal Water Requirements

Key Requirements Local Communities Are 

Subject to under SDWA and CWA

• SDWA – Most drinking water requirements set limits on 

contaminants; EPA currently regulates over 90.

Figure 3: Drinking Water Standards, as Applied to Drinking Water Systems

• If it is not economically or technically feasible to ascertain the level of a 

contaminant, EPA may instead establish a treatment technique.
Enclosure I

Page 15 GAO-06-151R Cost of Federal Water Requirements

Key Requirements Local Communities Are 

Subject to under SDWA and CWA

Figure 4: Key CWA 

Requirements 

Included in National 

Pollutant Discharge 

Elimination System 

Permits for Municipal 

Facilities
Enclosure I

Page 16 GAO-06-151R Cost of Federal Water Requirements

Key Requirements Local Communities Are 

Subject to under SDWA and CWA

Municipal Separate Storm Sewer 

System (MS4) 

Combined Sewer System

Storm water regulations require 

municipalities to

•obtain a NPDES permit for all 

discharges from MS4s and

•develop a storm water management 

program.

The Combined Sewer Overflow Policy 

requires municipalities to

•adopt nine minimum control measures 

and

•develop a long-term control plan.

Table 1: Key CWA Requirements Included in NPDES Permits for Municipal 

Separate Storm Sewer Systems and Municipalities with Combined Sewer 

Overflows
Enclosure I

Page 17 GAO-06-151R Cost of Federal Water Requirements

Key Requirements Local Communities Are 

Subject to under SDWA and CWA

• Community and water associations’ views on the requirements 

that are having the most significant cost impact on communities:

• Safe Drinking Water Act

• Arsenic Rule 

• Disinfectants and Disinfection Byproducts Rule

• Radionuclides Rule

• Clean Water Act

• Total Maximum Daily Load Program

• Storm water regulations

• Combined Sewer Overflow Policy
Enclosure I

Page 18 GAO-06-151R Cost of Federal Water Requirements

Extent to Which Existing Studies Provide 

Cumulative Cost Information

Figure 5: Some Studies Focus More Broadly on the Costs of Providing Safe 

Water or Clean Water, Rather than on Regulatory Costs Alone
Enclosure I

Page 19 GAO-06-151R Cost of Federal Water Requirements

Extent to Which Existing Studies Provide 

Cumulative Cost Information

• Other studies estimate costs for

• a subset of regulatory requirements, particular time periods, 

or

• entities other than local communities (e.g., states, private 

sector).
Enclosure I

Page 20 GAO-06-151R Cost of Federal Water Requirements

Extent to Which Existing Studies Provide 

Cumulative Cost Information

• EPA is required to develop cost estimates for some regulations, 

but these estimates

• focus only on single regulations,

• are prospective, 

• have been subject to criticism for both overestimating and 

underestimating actual implementation costs, and

• do not provide a meaningful measure of actual cumulative 

compliance costs when added together.
Enclosure I

Page 21 GAO-06-151R Cost of Federal Water Requirements

Extent to Which Existing Studies Provide 

Cumulative Cost Information

(EPA cost estimates continued)

Table 2: Examples of EPA’s Cost Estimates

Rule EPA’s Cost Estimate Uncertainty in Estimate

Phase V 

Synthetic 

Organic 

Chemicals 

and Inorganic 

Chemicals 

Rule 

Total annualized cost to public 

water systems for waste 

disposal and treatment 

(excludes monitoring costs):

$1 million - $128 million

(1989 dollars, annualized at 3% 

over 20 years)

•This range attempts to account for some of the 

uncertainty in the estimates (e.g., the actual unit 

costs for treatment and waste disposal) 

•The range does not account for other 

uncertainties, (i.e., the extent to which some of 

the contaminants covered by the regulation occur 

in drinking water)

Arsenic Rule Total annualized treatment 

costs to public water systems:

$190 million - $227 million

(1999 dollars, annualized at 

approximately 5% over 20 

years) 

•This range attempts to account for some of the 

uncertainty in making an estimate (e.g., 

uncertainty in the actual levels of arsenic in 

source water)

•The range does not account for the uncertainty 

that some systems would make more costly 

changes, such as adopting a more expensive 

treatment technology, or less costly changes, 

such as finding a new source of water

Note: We did not independently evaluate the methodology used to construct this range of estimates, nor did 

we evaluate the validity or the reliability of the prior survey and other data used as inputs into the model.
Enclosure I

Page 22 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

Methodological challenges hindering new efforts to develop 

reliable cumulative cost estimates:

• obtaining accurate and complete cost data, particularly for 

older requirements

• accurately allocating costs (e.g., among jurisdictions that 

share costs)

• establishing a causal link between community investments 

and federal water requirements
Enclosure I

Page 23 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

Challenge 1: Obtaining Accurate and Complete Cost Data

• There is a lack of institutional knowledge or historical records on 

the costs of compliance efforts. 

• Example: One community could not provide cost data on 

past operational changes because some records were not 

readily available. 

A key official with over 20 years of experience said that 

even with project cost information, it would be difficult to 

determine how much of the cost was incurred as a result of 

federal requirements. 
Enclosure I

Page 24 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

Challenge 2: Accurately Allocating Costs

• Costs are sometimes shared by multiple, overlapping jurisdictions.

Figure 6: Example of Cost-Sharing among Multiple, Overlapping 

Jurisdictions in One Community We Visited
Enclosure I

Page 25 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

(Challenge 2 continued)

• Communities generally track costs by project rather than by 

federal requirement; projects may involve system or program 

changes that serve multiple purposes or impose indirect but 

related costs.

• Example: One city decided to upgrade its treatment to reduce 

nitrogen levels to meet upcoming NPDES requirements when 

it expanded its wastewater treatment capacity to serve a 

growing population.

• Example: A county upgraded the biological, or secondary, 

treatment in its wastewater facility in response to a federal 

requirement. Indirect but related costs: (1) building more 

storage space to handle the additional sludge and (2) 

installing odor controls on the sludge storage tanks to comply 

with the Clean Air Act.
Enclosure I

Page 26 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

• For some requirements, there is no good baseline measure of 

what communities would have done in the absence of such 

requirements.

• Example: To meet federal storm water requirements, the 

cities in one county are required to sweep streets once a 

month. The problem in allocating costs is determining what 

the cities would have done in the absence of the federal 

requirement. Some cities would have swept their streets 

anyway.

Challenge 3: Establishing a Causal Link between Community 

Investments and Federal Water Requirements
Enclosure I

Page 27 GAO-06-151R Cost of Federal Water Requirements

(Challenge 3 continued)

• Some investments are made in anticipation of federal 

requirements.

Figure 7: General Process for Development of a Regulation and Points 

Where Communities May Decide to Take an Action That Incurs Costs

Methodological Challenges to Developing 

Reliable Estimates
Enclosure I

Page 28 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

(Challenge 3 continued)

• Example: One community decided to upgrade the biosolids

program at its wastewater facility before there was a specific 

federal requirement covering the use or disposal of biosolids. 

A community official told us that the change was made in 

anticipation of the federal requirement.

• Example: When another community constructed a new 

wastewater facility to accommodate population growth, it 

opted to install a filter, not because it was needed to meet any

existing NPDES permit limits, but because it anticipated that 

future federal requirements could necessitate more advanced 

treatment.
Enclosure I

Page 29 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

(Challenge 3 continued)

• Some states or regional entities may exercise their authority to establish requirements that are more stringent than the federal criteria (e.g., water quality standards, storm water requirements).

Figure 8: Authority for Establishing Water Quality Standards and Effluent Limits
Enclosure I

Page 30 GAO-06-151R Cost of Federal Water Requirements

Methodological Challenges to Developing 

Reliable Estimates

(Challenge 3 continued)

Figure 9: Multiple Regulatory 

Layers Affect the Impact of 

Federal Water Requirements on 

Communities
Enclosure II

Key Federal Requirements Local Communities Are Subject to under the Safe

Drinking Water Act 

Title Date

promulgated 

or proposeda

Local-level systems covered Principal requirements 

Disinfection 

Byproduct 

Regulations 

Trihalomethanes

Rule 

November 29, 

1979 

Community water systems that

serve 10,000 or more people and 

add a disinfectant to their treatment 

process 

Establishes a maximum contaminant 

level (MCL) and associated monitoring

and reporting requirements for total

trihalomethanes 

Stage 1 Disinfectants 

and Disinfection

Byproducts Rule

December 16, 

1998 

Community water systems and 

nontransient, noncommunity water 

systems that treat their water with a 

chemical disinfectant; certain 

requirements for one disinfectant 

apply to transient noncommunity 

water systems.

Builds upon and expands the 

Trihalomethanes Rule; establishes 

standards for three disinfectants, two 

groups of organic disinfection

byproducts, and two inorganic 

disinfection byproducts 

Stage 2 Disinfectants 

and Disinfection

Byproducts

Proposed 

August 18,

2003 

Community water systems and 

nontransient, noncommunity water 

systems that add a disinfectant

other than ultraviolet light or deliver 

water treated with a disinfectant 

other than ultraviolet light 

Would augment the Stage 1 

Disinfectants and Disinfection 

Byproducts Rule in part in response to 

new information concerning the health 

effects of disinfection byproducts;

requires systems to evaluate their 

distribution systems to identify locations 

with high disinfection byproduct

concentrations (locations will then be

used by the systems as the sampling 

sites for disinfection byproduct

compliance monitoring); alters method 

of calculating compliance with 

disinfection byproduct MCLs to reduce 

exposure to peak disinfection byproduct 

concentrations 

Microbial 

Contaminant 

Regulations

Surface Water 

Treatment Rule 

June 29, 

1989 

Public water systems that use 

surface water or ground water 

under the direct influence of

surface water 

Establishes maximum level contaminant 

goals for Giardia lamblia, viruses, and

Legionella, and establishes treatment 

technique requirements to protect 

against the health effects of exposure to 

these contaminants (by establishing 

criteria under which filtration is required, 

as well as disinfection requirements)

Total Coliform Rule June 29,

1989 

Public water systems Sets an MCL, monitoring requirements 

(which are based on the population

served), and analytical requirements for

total coliform bacteria; requires routine

monitoring by all public water systems, 

periodic sanitary surveys for small 

systems, and additional monitoring for 

systems that detect coliform

contamination 

Page 31 GAO-06-151R Cost of Federal Water Requirements
Enclosure II

Interim Enhanced 

Surface Water 

Treatment Rule 

December 16, 

1998 

Public water systems that serve 

more than 10,000 people and use 

surface water or ground water 

under the direct influence of

surface water 

Requires large systems to control 

microbial contaminants, particularly

Cryptosporidium; sets a maximum 

contaminant level goal for

Cryptosporidium; and builds on the 

treatment technique requirements of the

Surface Water Treatment Rule

Filter Backwash

Recycling Rule 

June 8, 2001 Public water systems that use 

surface water or ground water 

under the direct influence of

surface water, use direct or

conventional filtration processes, 

and recycle certain process waters 

Adds further protections to ensure 

treatment processes effectively remove

Cryptosporidium by requiring systems

to review their recycle practices and, 

where appropriate, make any necessary 

changes to recycle practices that may 

compromise microbial control 

Long Term 1 

Enhanced Surface 

Water Treatment 

Rule 

January 14, 

2002 

Public water systems that serve 

fewer than 10,000 and use surface 

water or ground water under the 

direct influence of surface water 

Requires small systems to improve 

control of microbial contaminants, 

particularly Cryptosporidium, by

strengthening filtration requirements and 

addressing risk trade-offs with

disinfection byproducts; builds on the

treatment technique requirements 

established for large systems in the 

Interim Enhanced Surface Water 

Treatment Rule 

Ground Water Rule Proposed 

May 10, 2000 

Public water systems that use 

ground water 

Establishes treatment techniques for 

systems using groundwater; specifies 

the appropriate use of disinfection in 

ground water, requires surveys and 

assessments, and requires any system

with significant deficiencies to take 

corrective actions 

Long Term 2 

Enhanced Surface 

Water Treatment 

Rule 

Proposed 

August 11,

2003 

Public water systems that use 

surface water or ground water 

under the direct influence of

surface water 

Builds upon the treatment techniques for 

Cryptosporidium that were established

for large systems by the Interim

Enhanced Surface Water Treatment 

Rule and for small systems by the Long 

Term 1 Enhanced Surface Water 

Treatment Rule; requires source water 

monitoring for Cryptosporidium, 

additional Cryptosporidium treatment for 

filtered systems, and inactivation of 

Cryptosporidium by unfiltered systems 

Other Contaminant 

Regulations

Fluoride Rule April 2, 1986 Community water systems Sets an MCL for fluoride 

Phase I - Synthetic

Organic Chemicals 

Rule 

July 8, 1987 Community water systems and 

nontransient, noncommunity water 

systems

Establishes MCLs for eight volatile

synthetic organic chemicals 

Phase II - Synthetic 

Organic Chemicals 

and Inorganic 

Chemicals Rules 

January 30, 

1991 

Primarily community water systems 

and nontransient, noncommunity 

water systems 

Establish MCLs for 26 synthetic organic 

chemicals and 7 inorganic chemicals 

Lead and Copper

Rule 

June 7, 1991 Community water systems and 

nontransient, noncommunity water 

systems 

Establishes maximum contaminant level 

goals for lead and copper and 

establishes “action levels” that, when 

exceeded, trigger treatment technique 

requirements (including corrosion 

control treatment, public education, and, 

under some circumstances, source 

water treatment and lead service line 

Page 32 GAO-06-151R Cost of Federal Water Requirements
Enclosure II

replacement)

Phase V - Synthetic 

Organic Chemicals 

and Inorganic 

Chemicals Rule 

July 17, 1992 Community water systems and 

nontransient, noncommunity water 

systems 

Establishes MCLs for 18 synthetic 

organic chemicals and 5 inorganic

chemicals 

Information 

Collection Rule

May 14, 1996 Large public water systems 

(surface water systems serving at 

least 100,000 and ground water 

systems serving at least 50,000) 

Required systems to collect and report 

information on the occurrence of 

disinfectant residuals, disinfection 

byproducts, and disease-causing 

microorganisms in drinking water and on

the effectiveness of various treatment 

technologies to reduce levels of these 

contaminants; this data collection effort 

is complete and no longer imposes 

requirements on systems. 

Radionuclides Rule December 7, 

2000 

Community water systems Sets an MCL for uranium and revises

monitoring requirements for other 

radionuclides 

Arsenic Rule January 22, 

2001 

Community water systems and 

nontransient, noncommunity water 

systems

Establishes a new MCL for arsenic 

Radon Rule Proposed 

November 2, 

1999 

Community water systems that use

ground water or mixed ground 

water and surface water 

Proposes two options: (1) developing a 

multimedia mitigation program at the

state level to reduce radon in indoor air 

or (2) developing a local program to 

reduce radon in water to a greater 

extent 

Customer

Awareness 

Regulations

Consumer 

Confidence Reports 

Rule 

August 19,

1998 

Community water systems Requires systems to prepare and 

provide to their customers annual 

confidence reports on the quality of the

water delivered by the systems 

Public Notification 

Rule 

May 4, 2000 Public water systems Requires systems to notify the people it

serves of (1) violations of drinking water 

regulations, (2) applicable variances and 

exemptions from the regulations, and (3)

other situations posing a risk to public 

health from the drinking water;

establishes minimum requirements 

regarding the form, manner, frequency, 

and content of the public notification 

Notes:

Public water system is a water system that regularly supplies drinking water to at least 15 service connections or 25 

people daily for at least 60 days a year. A public water system is either a “community water system” or a 

“noncommunity water system.” 

Community water system is a public water system that serves at least 15 service connections used by year-round 

residents or regularly serves at least 25 year-round residents.

Transient noncommunity water system is a public water system that does not regularly serve at least 25 of the same

people at least 6 months per year (e.g., gas stations, campgrounds). 

Page 33 GAO-06-151R Cost of Federal Water Requirements
Enclosure II

Nontransient noncommunity water system is a public water system that regularly supplies water to at least 25 of the 

same people at least 6 months per year (e.g., schools, factories, office buildings, and hospitals that have their own 

water systems).

 a

 Date of proposal is given for rules not yet finalized.

Page 34 GAO-06-151R Cost of Federal Water Requirements
Enclosure II

Key Federal Requirements Local Communities Are Subject to under the Clean

Water Act 

NPDES program areas 

and requirements 

Date

promulgated 

Municipal systems/facilities 

covered 

Key requirements 

Secondary treatment 

standards 

Secondary Treatment 

Standards 

August 17,

1973 (as 

amended) 

Publicly owned treatment works 

(POTW)a

Establish required levels of effluent 

quality based on the quality 

achievable by secondary, or 

biological, treatment 

Water quality and 

technology-based 

permitting 

Surface Water Toxics

Control Program and 

Water Quality Planning 

and Management 

Program (governing 

regulation for the Total 

Maximum Daily Load 

Program) 

July 24, 1992 States are directly covered; 

POTWs discharging to impaired

waters are indirectly affected.

b

Specifies that states must submit 

their lists of impaired waters, 

including waters targeted for total 

maximum daily load (TMDL) 

development to EPA every 2 years 

and provide documentation to 

support the states’ determinations; 

eventually, POTWs could be

required to meet more stringent 

limits on the discharge of some

pollutants. 

Monitoring 

Requirements for 

Publicly Owned 

Treatment Works and 

Other Treatment Works

Treating Domestic

Sewage 

 August 4, 1999 POTWs and other treatment works 

treating domestic sewage 

Require monitoring for certain toxic 

and other pollutants; the extent of 

pollutant monitoring required varies

by POTW size. 

Effluent Limitations

Guidelines, 

Pretreatment Standards, 

and New Source

Performance Standards

for the Landfills Point 

Source Category 

January 19, 

2000 

Municipalities that (1) own or operate

new or existing hazardous or 

nonhazardous landfill facilities

regulated, respectively, under Subtitle 

C and Subtitle D of the Resource 

Conservation and Recovery Act and 

(2) collect and discharge landfill 

generated wastewater to surface 

waters of the United States (unless 

the landfills are directly associated 

with other industrial or commercial 

facilities)

Establish technology-based effluent

limitations for wastewater 

discharges associated with the

operation and maintenance of 

these landfill facilities 

NPDES – Final 

Regulations to Establish

Requirements for 

Cooling Water Intake

Structures at Phase II 

Existing Facilities

July 9, 2004 Facilities (including municipally 

owned facilities) existing prior to

January 17, 2002, that (1) are point

sources; (2) as their primary activity

both generate and transmit electric

power or generate electric power for 

sale to another entity for

transmission; (3) use or propose to

use one or more cooling water intake 

structures with a total design intake

flow of 50 million gallons per day or 

more to withdraw water from waters

of the United States; and (4) use 25

Establish national performance

standards based on the best 

available technology to protect

aquatic organisms from being killed 

or injured by cooling water intake 

structures

Page 35 GAO-06-151R Cost of Federal Water Requirements
Enclosure II

percent of water withdrawn 

exclusively for cooling water 

Combined sewer

overflows 

Combined Sewer 

Overflow Control Policy, 

Codified by the 

Consolidated 

Appropriations Act for 

Fiscal Year 2001 

April 19, 1994 Combined sewer systems that

overflow as a result of wet weather 

events 

Establishes a consistent national 

approach for controlling discharges 

from combined sewer overflows to 

the nation’s waters; among other 

things, municipalities must 

implement minimum technologybased controls and develop longterm combined sewer overflow

plans to meet water quality 

standards. 

Municipal separate 

storm sewer systems 

Permit Application 

Regulations for Storm

Water Discharges 

(Phase I Storm Water 

Regulations) 

November 16, 

1990 

Discharges from large and medium

municipal separate storm sewer 

systems (those serving more than 

100,000 people) 

Require large and medium

municipal separate sewer systems 

to obtain NPDES permits for storm

water discharges and set forth the 

required components of municipal 

storm water quality management 

plans 

Regulations for Revision 

of the Water Pollution 

Control Program

Addressing Storm Water 

Discharges (Phase II 

Storm Water 

Regulations) 

December 8, 

1999 

Discharges from small municipal 

separate storm sewer systems (those 

serving less than 100,000 people) 

Extend storm water requirements to

smaller municipal separate storm

sewer systems 

National pretreatment 

program 

General Pretreatment 

Regulations for Existing 

and New Sources 

June 26, 1978, 

as amended 

January 28, 

1981 

POTWs Require most major POTWs to

develop a locally run pretreatment 

program to ensure that 

nondomestic users of the municipal 

system have controls in place to 

prevent the introduction into

POTWs of pollutants that will 

interfere with operations or pass 

through the POTW untreated 

Biosolids (sewage 

sludge) 

Standards for Use or 

Disposal 

February 19, 

1993 

POTWs and other treatment works 

treating domestic sewage sludge 

Establish requirements for the final

use and disposal of sewage sludge;

numerical limits on the pollutant 

concentrations in sewage sludge; 

management practices; and, in

some cases, operational 

requirements 

 a

 A POTW is a state or municipally owned system or device used to store, treat, recycle, or reclaim municipal sewage

or liquid industrial wastes. The term includes treatment plants. b

 If a state lists a water body as impaired, it must eventually develop, for each pollutant causing an impairment, a 

TMDL—the amount of the pollutant that the water body can receive, taking into account seasonal variations and a 

margin of safety, and still meet water quality standards. To implement a TMDL, states allocate pollutant loadings 

among specific sources, such as local wastewater treatment plants, and incorporate the loads into the state’s water 

quality management plans and NPDES permits.

Page 36 GAO-06-151R Cost of Federal Water Requirements
Enclosure III 

Summary of Selected Cost Studies

Title Description

EPA studies 

Drinking Water Infrastructure

Needs Survey and Assessment: 

Third Report to Congress, EPA, 

2005. 

The purpose of this study was to estimate the national infrastructure needs for public 

drinking water systems. EPA conducted a survey to project the estimated costs, for the 

time period of 2003 to 2022, for the approximately 75,000 public water systems eligible 

to receive assistance from the Drinking Water State Revolving Fund. The assessment 

includes costs needed to protect public health, preserve the physical integrity of water 

systems, convey treated water to homes and commercial and industrial establishments,

and ensure continued compliance with specific Safe Drinking Water Act regulations. EPA

also conducted similar surveys in 1995 and 1999. 

Report to Congress: Impacts and 

Control of CSOs and SSOs, EPA, 

2004. 

This report documents the extent of human health and environmental impacts caused by

municipal combined sewer overflows (CSO) and sanitary sewer overflows (SSO), 

including the location of discharges causing such impacts, the volume of pollutants

discharged, the resources spent by municipalities to address these impacts and the

projected costs to reduce CSOs and SSOs, and the technologies used by municipalities 

to address these impacts. EPA reported expenditures, primarily for infrastructure 

investments such as sewer system replacement and rehabilitation, going back to 1970 

and projected future needs over a 20-year period. 

Clean Watersheds Needs Survey 

2000: Report to Congress, EPA, 

2003. 

The purpose of this study was to estimate the total national need for water quality 

programs and projects under the Clean Water Act. EPA conducted a survey to estimate 

the costs for needs that existed as of January 1, 2000; had an indeterminate future time

frame; and were eligible for Clean Water State Revolving Fund assistance. EPA 

collected documentation from facilities involved with water quality management, such as

wastewater treatment plants and municipal separate storm sewer systems. The 

assessment includes projected costs for wastewater treatment, collection, and 

conveyance; CSO correction; storm water management programs; and nonpoint source 

pollution control. EPA conducted a similar assessment in 1996 and has collected 

information about Clean Water Act needs since 1972.

Community Water System Survey 

2000, EPA, 2002. 

This report summarized information from a survey of a nationally representative sample 

of community drinking water systems on their financial and operating characteristics. The 

survey collected information from water systems on such characteristics as the source of

their water; the size of their system; and the capital expenditures they made over a 5-

year period. EPA conducted similar surveys in 1976, 1982, 1986, and 1995. 

The Clean Water and Drinking

Water Infrastructure Gap Analysis, 

EPA, 2002. 

The purpose of this study was to estimate the gap between projected clean water and 

drinking water investment needs, over the 20-year period from 2000 to 2019, including 

needs related to regulatory compliance, and levels of spending at the time the analysis 

was conducted. The scope of the report includes both capital and operations and 

maintenance costs for all clean water and drinking water services. The analysis used 

the clean water and drinking water needs surveys (see above) as a starting point and 

then made adjustments, based on several alternative assumptions. 

The National Costs of the Total 

Maximum Daily Load Program

(Draft Report), EPA, 2001. 

This report estimates the national costs of developing and implementing the Total

Maximum Daily Load (TMDL) Program, under the Clean Water Act. EPA calculated the 

annual costs to states and EPA for listing impaired waters and developing TMDLs. EPA 

also estimated the annual costs to pollutant sources—such as industrial dischargers and 

wastewater treatment plants—to implement the TMDLs for the approximately 20,000

impaired waters that were identified at the time of the study. 

A Retrospective Assessment of

the Costs of the Clean Water Act: 

1972 to 1997, prepared for EPA by 

George Van Houtven, Smita 

Brunnermeier, and Mark Buckley, 

Center for Economics Research, 

2000. 

This study estimates the nationwide costs of water pollution abatement expenditures by 

both public and private entities under the Clean Water Act. The analysis focuses on the 

incremental annual costs of requirements under the Clean Water Act between 1972 and 

1997. 

Estimates of the Total Benefits

and Total Costs Associated with 

Implementation of the 1986 

Amendments to the Safe Drinking 

The purpose of this study was to estimate the total benefits and costs for all of the 

drinking water regulations specified in the 1986 Amendments to the Safe Drinking Water 

Act. The regulations included in the analysis cover: volatile organic chemicals, fluoride, 

the surface water treatment rule, the total coliform rule, the lead and copper rule, phase 

Page 37 GAO-06-151R Federal Water Requirements
Enclosure III 

Water Act, prepared for EPA by

Wade Miller Associates, Inc., 

1990. 

II inorganic and synthetic organic chemicals, radionuclides, disinfection requirements, 

phase V inorganic and synthetic organic chemicals, and arsenic. The study presented 

aggregate national-scale costs for implementing these rules on an annual basis in 

addition to providing cost-benefit comparisons for the regulations at the individual water 

system level and at the household level. Similar studies were conducted in 1987 and 

1989. 

Environmental Investments: The 

Cost of a Clean Environment: A 

Summary, EPA, 1990. 

This summary report presents data on environmental pollution control costs from 1972 

through 1987 and then projects the costs for each subsequent year to the year 2000 

under a number of different scenarios. Cost estimates are included for actions taken 

pursuant to each of the major federal environmental pollution control statutes (including 

the Clean Water Act and Safe Drinking Water Act). Separate costs were developed for

each of the various environmental media, including air, water, land, and useful chemicals 

(such as pesticides). Cost estimates were also broken down by the economic sector that 

would directly incur the cost, including EPA, other federal agencies, state and local 

government, and the private sector. This report summarizes data presented in a much

more detailed report also issued in 1990 entitled Environmental Investments: The Cost of

a Clean Environment, Report of the Administrator of the Environmental Protection

Agency to the Congress of the United States. 

The Municipal Sector Study: 

Impacts of Environmental

Regulations on Municipalities, 

EPA, 1988. 

This study examined the impacts of 22 environmental regulations that municipalities

have to comply with, including 11 drinking water regulations, 3 wastewater treatment

regulations, and 1 storm water management regulation. EPA calculated the impacts by 

looking at the projected increases in user charges (e.g., charges for water and sewer 

services) per household, and the ability of municipalities to raise needed capital to 

comply with the additional requirements. 

Studies by other federal 

agencies

Draft 2005 Report to Congress on 

the Costs and Benefits of Federal 

Regulations, Office of 

Management and Budget, 2005. 

This report provides an estimate of the total costs and benefits of regulations reviewed

by the Office of Management and Budget (OMB), including a 10-year retrospective of

major federal regulations reviewed by OMB, a historical examination of the trends in

federal regulatory activity, and discussion of the implementation of the Information 

Quality Act. OMB’s estimates are based on cost estimates found in the agencies’ 

regulatory impact analyses. Federal regulations, including those under the Clean Water 

Act and Safe Drinking Water Act, were included if, in general, they were projected to 

have the potential for a significant impact.a

 OMB issues similar reports on a yearly basis.

Future Investment in Drinking

Water and Wastewater 

Infrastructure, Congressional 

Budget Office, 2002. 

This study provides background information on the nation’s water systems; presents 

estimates of future costs for water infrastructure under two scenarios, a low-cost case 

and high-cost case; and discusses broad policy options for the federal government to 

support water infrastructure development. The cost estimates are for the annual 

infrastructure funding needs of drinking water and wastewater systems for the period

2000 to 2019. These needs include capital costs and operations and maintenance 

costs, which include costs related to regulatory compliance. 

The Safe Drinking Water Act: A 

Case Study of an Unfunded 

Federal Mandate, Congressional 

Budget Office, 1995. 

This study looked at the costs and benefits of treating drinking water according to the 

standards set under the Safe Drinking Water Act as a case study of federal mandates. 

Among other things, the study examined whether the act, at the time the analysis was 

completed, had imposed large costs on households, had costs that exceed benefits, and 

had imposed a large fiscal burden on municipalities. 

Studies by other entities

Impact of Unfunded Federal 

Mandates and Cost Shifts on U.S. 

Cities: A Preliminary Report on

Costs in 59 Cities, The United 

States Conference of Mayors, 

2005. 

This report provides information on the survey the U.S. Conference of Mayors conducted

to collect cost information on several federal mandates and requirements, including the 

Safe Drinking Water Act and the Clean Water Act. A total of 59 cities provided 

information on their recurring annual costs and any one-time costs associated with the 

mandate for the most recent fiscal year for which the information was available. The U.S.

Conference of Mayors also conducted a similar survey in 1993. 

 a

 All final rules promulgated by an Executive branch agency were included if the rule met any one of the following

measures: rules designated as “economically significant” under section 3(f)(1) of Executive Order 12866; rules 

designated as “major” under 5 U.S.C. 804(2); and rules designated as meeting the threshold under 2 U.S.C. 1532. 

Page 38 GAO-06-151R Federal Water Requirements
Enclosure III 

Unfunded Mandates: A Snapshot 

Survey, National Association of

Counties, 2005. 

The purpose of this report was to provide information on the impact of unfunded 

mandates on county governments. The Association collected cost information for 10

federal mandates, including the Safe Drinking Water Act and the Clean Water Act, by 

surveying member counties from across the country on their estimated costs to comply 

with each of the mandates for fiscal years 2003, 2004, and projected 2005. The 

Association also conducted a similar survey in 1993. 

Safe Drinking Water Act: Costs of 

Compliance, Robert S. Raucher 

and John Cromwell, Mercatus

Center, George Mason University, 

2004. 

This paper examines the national costs associated with federal drinking water 

regulations issued as a result of the 1996 Safe Drinking Water Act amendments. 

Building on EPA’s cost estimates published for each individual regulation and other 

available research, the study presents cost estimates for each major national rule

finalized under the act since the 1996 amendments. The cost estimates are then 

aggregated, along with estimates for regulations issued before 1996, to come up with a 

total cost estimate for drinking water regulations issued since 1986. 

The Cost of Regulations

Implementing the Clean Water

Act, Joseph M. Johnson, Mercatus 

Center, George Mason University, 

2004. 

The purpose of this study was to estimate the cost of implementing water pollution 

control regulations under the Clean Water Act between 1972 and 2001. Cost estimates 

were developed for both the government (including state and local) and the private 

sector. Estimates were largely based on government and private expenditure data 

collected through the U.S. Census Bureau’s Pollution Abatement and Control 

Expenditures survey. 

Census Data Shed Light on U.S. 

Water and Wastewater Costs, 

Scott J. Rubin, American Water 

Works Association Journal, April, 

2005. 

This study analyzes U.S. Census Bureau data from the Public Use Microdata Areas to 

estimate the cost of water and wastewater service for households with various 

characteristics, such as annual household income, type of housing unit, and size of the

housing unit. 

Dawn of the Replacement Era:

Reinvesting in Drinking Water 

Infrastructure, American Water

Works Association, 2001. 

This report estimates the funding that may be needed over a 30-year period, nationwide,

for the replacement of worn-out drinking water pipes and associated drinking water 

infrastructure. The estimate is based on an analysis of 20 utilities geographically

distributed throughout the nation. 

The AMSA 2002 Financial Survey:

A National Survey of Municipal

Wastewater Management

Financing and Trends, Association

of Metropolitan Sewerage

Agencies, 2002. 

The purpose of this study was to report on current practices in financing and managing 

public wastewater treatment agencies across the nation. The Association of

Metropolitan Sewerage Agencies, an association that represents public wastewater 

treatment agencies, surveyed a sample of its membership on general utility information, 

such as the size of service area and the volume of treatment; financial information, such 

as capital improvement needs; rate information, including the rate structure used; and 

staffing and salary information, such as number of staff and licensing requirements. The 

2002 survey updates and expands on eight previous surveys conducted since 1981. 

Clean and Safe Water for the 21st

Century: A Renewed Commitment 

to Water and Wastewater 

Infrastructure, Water Infrastructure 

Network, 2000. 

This report discusses the value of clean and safe drinking water and wastewater; 

provides a historic and future perspective on investments to water and wastewater

infrastructure systems; estimates the cost of building, operating, and maintaining needed

drinking water and wastewater facilities over a 20-year period; and discusses the federal

role in financing water and wastewater infrastructure projects. 

Implementing a Regulatory 

Budget: Estimating the Mandated 

Private Expenditure of the Clean 

Air Act and Safe Drinking Water 

Act Amendments, Harvey S. 

James, Center for the Study of

American Business, Washington 

University, Working Paper 161, 

August 1996. 

This study examines the various problems that arise in measuring regulatory costs and, 

in that light, proposes a feasible methodology for carrying out a regulatory budget. The 

methodology was then applied to the recent amendments of the Clean Air Act and the 

Safe Drinking Water Act to assess the feasibility of administering a regulatory budget. In

conducting the study, the author estimated the compliance costs of the Clean Air and 

Safe Drinking Water Acts, which for the Safe Drinking Water Act included compiling data 

from EPA and American Water Works Association estimates for the rules authorized by 

the 1986 amendments. 

Note: We did not include studies specific to state and local entities in our review.

(360591) 

Page 39 GAO-06-151R Federal Water Requirements
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