ENVIRONMENTAL PROTECTION AGENCY

ANNUAL PUBLIC WATER SYSTEMS COMPLIANCE REPORT

1. Identification of the Information Collection

1(a) Title of the Information Collection

Annual Public Water Systems Compliance Report, ICR Number 1812.04 (Reinstatement)

1(b) Short Characterization/Abstract

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

that includes states, commonwealths and territories) that has primary enforcement authority

under the Act shall prepare, make readily available to the public, and submit to the Administrator 

of EPA, an annual report of violations of national primary drinking water regulations in the state. 

These Annual State Public Water System Compliance Reports are to include violations of 

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

monitoring requirements determined to be significant by the Administrator after consultation 

with the states. To minimize a state’s burden in preparing its annual statutorily-required report, 

EPA issued guidance that explains what Section 1414(c)(3)(A) requires and provides model 

language and reporting templates. EPA also annually makes available to the states a computer 

query that generates for each state (from information states are already separately required to 

submit to EPA’s national database on a quarterly basis) the required violations information in a 

table consistent with the reporting template in EPA’s guidance.

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

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

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

primacy on December 6, 2000. Currently the State of Wyoming and the District of Columbia 
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neither have primary enforcement authority nor are they seeking primary authority, so the 

number of 56 states is unlikely to change over the next three years of this ICR. The cost of this 

ICR to each state with primary enforcement authority will be approximately $4,996.40 during 

each of the three years of this ICR.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

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

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

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

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

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

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

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

submitted by the states pursuant to subparagraph (A). 

2(b) Practical Utility/Users of the Data 

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

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

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

specified by the states to make recommendations concerning the resources necessary to improve 

compliance with the Safe Drinking Water Act. The information submitted by the states also 

helps EPA identify and resolve discrepancies between violations data in the states’ reports and 
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the violations data states submit quarterly to EPA’s national database.

3. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

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

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

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

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

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

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

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

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

data systems instead.

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

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

Federal Register on July 2, 2009 (74 FR 31730) No comments were received.

3(c) Consultations

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

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

following individuals: 

Name Telephone Organization 

Robert Bomberger 717-787-0127 Pennsylvania Dept of Environmental Protection
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Nancy Reilman 410-537-3729 Maryland Dept of the Environment

Joan Cockrell 601-576-7518 Mississippi Bureau of Public Water Systems

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

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

the previous year’s report. As a result, the burden hours associated with preparing a report have 

not changed. EPA’s burden hour estimates reflect input from these consultations. 

3(d) Effects of Less Frequent Collection

 Because Section 1414(c)(3)(A) requires the states to prepare these reports annually and 

to make the reports readily available to the public, states do not have the option of collecting this 

information less frequently.

3(e) General Guidelines

All of the collection activities described within this ICR fall within OMB’s General 

Guidelines. 

3(f) Confidentiality

The required information consists of violations data and other information that are a 

matter of public record. None of the information collected as part of the states’ annual public 

water systems compliance report comprises confidential business information (CBI).

3(g) Sensitive Questions

No questions of a sensitive nature are asked or answered in the states’ annual public 

water systems compliance report.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes
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The respondents of the recordkeeping and reporting requirements are states that have 

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

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

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

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

Primary enforcement authority has not been approved for the District of Columbia or for Indian 

Tribes other than the Navajo Nation. EPA has primary enforcement authority in those 

jurisdictions and is likely to retain that during the three year duration of this ICR. 

4(b) INFORMATION REQUESTED

(i) Data Items

The reporting items as required by section 1414(c)(3)(A) include:

· State name and reporting period

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

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

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

technique requirement violations, explanations of any aggregated number of 

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

year, a discussion of variance or exemption violations;

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

systems that had maximum contaminant level or treatment technique requirement 

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

· Reviewed and completed Summary of Violations chart.
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In addition to these items, States are encouraged to provide optional information as outlined EPA 

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

statutorily-mandated reports.

ii. Respondent Activities

States will need to conduct the following activities in order to complete and submit their 

Annual State Public Water Systems Compliance Report.

· Review the instructions and other necessary materials;

· Gather inventory and violations data from SDWIS/FED and from their own data 

bases; 

· Review and analyze inventory and violations data from SDWIS/FED and from 

their own data bases;

· Prepare summary of violations of variances and exemptions; and

· Prepare report and submit to EPA in hard copy or hard copy and electronic 

version, make report readily available to the public, prepare and distribute a 

summary of the report. 

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

Information Management

5(a) Agency Activities 

During the lifetime of this ICR, EPA Headquarters activities associated with the Annual 

State Public Water Systems Compliance Report consist of the following:

· Modify guidance documents as necessary and distribute to states and EPA 

Regional Offices;
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· Prepare and distribute tools for states and EPA Regional Offices to use to gather 

data from SDWIS/FED (annual activity);

· Answer questions from states and EPA Regional Offices (annual activity);

· Provide support for Indian Land reporting (annual activity); and

· Review Annual State Public Water System Compliance Reports, and data from 

SDWIS/FED, prepare the Annual National Public Water Systems Compliance 

Report that summarized and evaluates the annual state reports, and distribute the 

national report.

EPA Regional Offices will need to complete the following activities to prepare Annual 

State Public Water Systems Compliance Reports for states that do not have primary enforcement 

authority, to gather public water system compliance data for Indian lands, and to assist the states 

as they prepare their reports: 

· Assist EPA Headquarters in the development and distribution of any necessary

guidance materials;

· Assist EPA Headquarters in the development and distribution of tools for 

gathering data from SDWIS/FED (annual activity);

· Provide general guidance to all states in the Region for completing the Annual 

state Public Water Systems Compliance Report;

· Gather information from SDWIS/FED for each Indian land in the Region;

· Prepare a summary of variances and exemptions violations in each Indian land in 

the Region;

· Gather and submit to EPA Headquarters inventory and violations information 
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from SDWIS/FED for each Indian land in the Region, information about 

enforcement and compliance assistance activities related to the Safe Drinking 

Water Act on Indian lands in the Region, and information about financial 

assistance related to implementation of the Safe Drinking Water Act on Indian 

lands in the Region;

· Prepare Annual State Public water Systems Compliance Report for each State in 

the Region that does not have primary enforcement authority and submit it to 

EPA Headquarters in hard copy or hard copy and electronic version, make report 

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

5(b) Collection Methodology and Management

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

Water System Reports to in electronic (WordPerfect compatible) and hard-copy format. Section 

1414(c)(3)(A) requires that both the Annual State Public Water Systems Compliance Reports 

and the State-prepared summaries be accessible to the public. In its guidance, EPA recommends 

that States and EPA Regions use one or more of the following mechanisms for making the 

reports and summaries readily available: 

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

summary;

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

standard press conferences to announce report availability;

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

· Provide copies of the report for review at public offices and locations, libraries, 
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web sites, state/local departments of health, etc; and

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

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

will be posted on the Internet. 

5(c) Small Entity Flexibility

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

as defined by the Regulatory Flexibility Act.

5(d) Collection Schedule

Each Annual State Public Water Systems Compliance Report covers violations that 

occurred in a calendar year. States with primary enforcement authority have six months after the 

end of each calendar year to prepare their Reports, which are due to EPA on the first of July. 

6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden

Table 1: presents the burden hours and costs per respondent as well as for all respondents 

during each year covered by this ICR. Preparing an Annual State Public Water Systems 

Compliance Report involves reviewing and describing information on public water systems 

violations. EPA encourages states to rely on SDWIS/FED data for this purpose, as the states are 

already obligated to provide data to SDWIS/FED on a quarterly basis. EPA further facilitates

this process by providing a set of computer queries to the states every year that extracts from 

SDWIS/FED the violations data each state needs to prepare its annual report. Some states prefer 

to extract data from their own databases. Each state must also prepare a narrative describing any 

violations of variances or exemptions. The burden for each state of preparing an Annual State 
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Public Water System Compliance Report is estimated to be 208 hours.

6(b) Estimating Respondent Costs

Based on the Bureau of Labor website for State and Local governments 

(http//www.bls.gov/ococg/cgs042.htm), EPA estimates an average hourly labor rate (hourly rate 

plus overhead factor of 1.6) of $68.46 for managerial staff, $54.69 for technical staff, and 

$38.01 for clerical staff. Table 1: Annual Respondent Burden, presents a summary of the 

estimated respondent average annual cost associated with this ICR. No capital or operations and 

maintenance costs are incurred by respondents under this ICR. This ICR does not require

continuous monitoring. 

6(c) Estimating Agency Burden and Cost

Table 2: Annual Agency Burden, presents the estimated Agency burden hours and costs 

associated with the information collection activities under this ICR. Other direct costs (copying, 

printing, telephone, and mailing expenses) are also included.

Based on the GSA pay schedule, EPA estimates an average hourly labor rate (hourly rate 

plus the standard government overhead factor of 1.6) of $60.45 for managerial staff, $46.21 for 

technical staff, and $25.08 for clerical staff.

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

Responding to this ICR by preparing an Annual State Public Water Systems Report is a 

statutory requirement for the 55 states with primary enforcement authority and for all 10 EPA 

Regions. EPA’s burden estimate assumes all states and 10 EPA Regions will prepare reports.

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculation for the respondents and the 
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Agency are shown in Tables 1 and 2, respectively and summarized below.

6(f) Reasons for Change in Burden

The decrease in burden from the most recently approved ICR is due to a miscalculation 

of the number of states submitting reports. Wyoming was counted in the previous ICR as a 

respondent although it doesn’t have primacy for the drinking water program and the US EPA 

submits its annual report. The number of respondents should be fifty-five entities, which 

includes 49 states, 5 territories and one tribe. Federal approval to implement the drinking water 

program is call primary enforcement authority or “primacy.”

6(g) Burden Statement: The annual public reporting and recordkeeping burden for this 

collection of information is estimated to average 80 hours per response. Burden means the total 

time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose 

or provide information to or for a Federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing and maintaining information, and 

disclosing and providing information; adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of 

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

transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a 

person is not required to respond to, a collection of information unless it displays a currently

valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 

CFR part 9 and 48 CFR chapter 15. 
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To comment on the Agency's need for this information, the accuracy of the provided 

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

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

Docket ID Number EPA-HQ-OECA-2009-0280, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Enforcement and Compliance Docket in the 

EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, 

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

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

Room is (202) 566-1744, and the telephone number for the Enforcement and Compliance Docket 

is (202) 566-1752. An electronic version of the public docket is available at 

www.regulations.gov. This site can be used to submit or view public comments, access the 

index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in the 

Docket ID Number identified above. Also, you can send comments to the Office of Information 

and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, 

D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number 

EPA-HQ-OECA-2009-0280 and OMB Control Number 2020-0020 in any correspondence.

Part B of the Supporting Statement

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

information.
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Table 1. Annual Respondent Burden and Cost

Annual Public Water Systems Compliance Report, EPA ICR Number 1812.04 OMB 

Control Number 2020-0020

Information 

Collection Activity

Hours and Costs Per Respondent Total Hours and Costs

Mgr. 

$68.46/

Hour

Tech.

$54.96/

Hour

Cler.

$38.01/

Hour

Labor

Hours/

Year

Labor

Cost/

Year ($)

Capital/

Startup

Cost ($)*

O & M 

Cost ($)*

Number of 

Respondents

Total,

Hours/

Year

Total,

Cost/Year 

($)**

Review instructions 

and other necessary 

materials

4 4 218.36 0 0

55 22012,010

Gather inventory 

and violations data 

from SDWIS/FED 

and State databases

4 4 218.36 0 0

55 22012,010

Review and analyze 

data

24 24 1,310.14 0 0

55 1,320

72,058

Prepare summary of 

violations of 

variences and 

exemptions

4 4

218.36 0 055 22012,010

Prepare report and 

submit to EPA

4 28 8 40 2,106.43 0 0

55 2,200115,854

Make report 

available to public

4 4

152.04 0 055 2208,362

Total 4 64 12 80 4,223.69 0 0

55 4400232,303

* Same as the Capital/Startup and Operation & Maintenance Costs addressed in Section 6(b).

** Includes Labor Cost, Capital/Startup and O&M Cost.
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Table 2. Annual Agency Burden and Cost

Annual Public Water Systems Compliance Report, EPA ICR Number 1812.04 OMB 

Control Number 2020-0020

Information 

Collection Activity

Agency Hours and Costs Total Hours and Costs

Mgr. 

$60.45/

Hour

Tech.

$46.21/

Hour

Cler. 

$25.08/ 

Hour

Agency

Hours/

Year

Labor

Cost/

Year ($)

Capital/

Startup

Cost ($)

O& M 

Cost 

($)*

Number of 

Respondents

Total

Hours/

Year

Total

Cost/Year ($)

Modify guidance as 

necessary and 

distribute to states 

and EPA Regions

1 24 25 1,164 1 25 1,164

Prepare and 

distribute tools for 

gathering data from 

SDWIS/FED

1 16 17 796 12 204 9,552

Answer questions 

from states and 

EPA Regional 

Offices

40 40 1,840 12 480 22,080

Provide support for 

Indian Land 

reporting

120 120 5,520 9 1080 49,680

Review state 

reports and data 

from SDWIS/FED

40 40 2,080 12 480 24,960

Prepare and 

distribute annual 

report where EPA 

directly implements 

drinking water

4 80 12 96 4,220 2 192 8,440

Prepare and 

distribute national 

summary report

4 120 16 140 6,160 1 140 6,160

Total 10 440 28 478

15,620

49 2601 122,036

* O&M costs include photocopying, postage, and telephone.