Information Collection Request for the 2011 Drinking Water 

Infrastructure Needs Survey and Assessment (DWINSA)

(Supporting Statement for ICRAS and ROCIS)

December 2010

Prepared by:

The Cadmus Group, Inc.

57 Water Street

Watertown, MA 02472

Prepared for:

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water

Drinking Water Protection Division
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ICR for 2011 DWINSA i December 8, 2010

Table of Contents

PART A OF THE SUPPORTING STATEMENT...................................................................................1

A.1 IDENTIFICATION OF THE INFORMATION COLLECTION....................................................1

A.1.a Title of the Information Collection Request.....................................................................1

A.1.b Short Characterization......................................................................................................1

A.2 NEED FOR AND USE OF THE COLLECTION...........................................................................3

A.2.a Authority and Need for the Collection.............................................................................3

A.2.b Use and Users of the Information ....................................................................................3

A.3 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA.............5

A.3.a Nonduplication.................................................................................................................5

A.3.b Public Notice Required Prior to ICR Submission to OMB..............................................6

A.3.c Consultations....................................................................................................................6

A.3.d Effects of Less Frequent Collection.................................................................................6

A.3.e General Guidelines...........................................................................................................7

A.3.f Confidentiality Questions.................................................................................................7

A.3.g Sensitive Questions..........................................................................................................7

A.4 THE RESPONDENTS AND THE INFORMATION REQUESTED.............................................9

A.4.a Respondents/NAICS Codes .............................................................................................9

A.4.b Information Requested ...................................................................................................10

A.5 INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, 

AND INFORMATION MANAGEMENT....................................................................................17

A.5.a Agency Activities...........................................................................................................17

A.5.b Collection Methodology and Management ....................................................................19

A.5.c Small Entity Flexibility ..................................................................................................23

A.5.d Collection Schedule........................................................................................................24

A.6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION .......................................25

A.6.a Respondent Burden ........................................................................................................25

A.6.b Respondent Costs...........................................................................................................35

A.6.c Agency Burden and Cost................................................................................................37

A.6.d Estimating Respondent Universe and Total Burden and Costs......................................40

A.6.e Bottom Line Burden Hours and Costs ...........................................................................40

A.6.f Reasons for Change in Burden.......................................................................................44

A.6.g Burden Statement...........................................................................................................44

PART B OF THE SUPPORTING STATEMENT (FOR STATISTICAL SURVEYS) .....................45

2011 STATE DWINSA ..............................................................................................................................47

B.1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES ......................47

B.1.a Survey Objectives ..........................................................................................................47

B.1.b Key Variables.................................................................................................................47

B.1.c Statistical Approach .......................................................................................................48

B.1.d Feasibility.......................................................................................................................49

B.2 SURVEY DESIGN........................................................................................................................49

B.2.a Target Population and Coverage ....................................................................................50

B.2.b Sample Design ...............................................................................................................50
ICR for 2011 DWINSA ii December 8, 2010

B.2.c Precision Requirements..................................................................................................57

B.2.d Data Collection Instrument Design ................................................................................59

B.3 PRE-TESTS AND PILOT TEST...................................................................................................59

B.3.a Pre-tests..........................................................................................................................59

B.3.b Pilot Test ........................................................................................................................60

B.4 COLLECTION METHODS AND FOLLOW-UP ........................................................................60

B.4.a Collection Method..........................................................................................................60

B.4.b Survey Response and Follow-up....................................................................................60

B.5 ANALYZING AND REPORTING SURVEY RESULTS............................................................61

B.5.a Data Preparation.............................................................................................................61

B.5.b Analysis..........................................................................................................................61

B.5.c Reporting Results...........................................................................................................61

2011 NATIVE AMERICAN DWINSA .....................................................................................................63

Introduction.................................................................................................................................................63

B.1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES ......................63

B.1.c Statistical Approach .......................................................................................................63

B.2 SURVEY DESIGN........................................................................................................................63

B.2.a Target Population and Coverage ....................................................................................63

B.2.b Sample Design ...............................................................................................................64

B.2.c Precision Requirements..................................................................................................65

B.4 COLLECTION METHODS AND FOLLOW-UP ........................................................................65

B.4.a Collection Method..........................................................................................................65
ICR for 2011 DWINSA iii December 8, 2010

List of Appendices

APPENDIX A - Public Notice Required Prior to ICR Submission to OMB

APPENDIX B - Data Collection Instrument and Lists of Codes

APPENDIX C - Comments and Response to Comments Received on the First Federal Register Notice
ICR for 2011 DWINSA iv December 8, 2010

List of Tables

Exhibit A-5-1 Collection Schedule.............................................................................................................24

Exhibit A-6-1 Estimated Unit Burden for Systems Serving More Than 50,000 Persons...........................26

Exhibit A-6-2 Estimated Unit Burden for Systems Serving 3,301 – 50,000 Persons.................................28

Exhibit A-6-3 Estimated Unit Burden for American Indian and Alaskan Native Village Water Systems.29

Exhibit A-6-4 Overall State/Navajo Nation Burden Summary...................................................................30

Exhibit A-6-5 State and Navajo Nation Unit Burden for Up-Front Activities ...........................................30

Exhibit A-6-6 State Unit Burden for Systems Serving More Than 50,000 Persons...................................32

Exhibit A-6-7 State Unit Burden for Systems Serving 3,301 – 50,000 Persons.........................................33

Exhibit A-6-8 Navajo Nation Unit Burden for Systems.............................................................................35

Exhibit A-6-9 Total Burden and Cost to Water Systems............................................................................35

Exhibit A-6-10 Total Burden and Cost to States ........................................................................................36

Exhibit A-6-11 Burden/Cost to EPA (Excluding Contractor Activities) and IHS......................................38

Exhibit A-6-12 Burden/Cost of Contractor Activities................................................................................39

Exhibit A-6-13 Bottom Line Respondent Burden ......................................................................................40

Exhibit A-6-14 Burden Hours and Costs for Respondents per Year ..........................................................40

Exhibit A-6-15 Bottom Line Burden Hours and Costs for EPA (including EPA’s contractor) and IHS ...41

Exhibit A-6-16 Disaggregated Burden by Affected Information Collection (IC) Entities.........................42

Exhibit B-2-1 State Sample Sizes...............................................................................................................54
ICR for 2011 DWINSA 1 December 8, 2010

PART A OF THE SUPPORTING STATEMENT

A.1 IDENTIFICATION OF THE INFORMATION COLLECTION

A.1.a Title of the Information Collection Request

The title of this information collection request (ICR) is Information Collection Request for the 2011 

Drinking Water Infrastructure Needs Survey and Assessment (DWINSA)1

A.1.b Short Characterization 

. The Office of Management and 

Budget (OMB) control number for this ICR is 2040-0274; EPA ICR No. 2234.03.

The Environmental Protection Agency (EPA) will conduct an assessment to estimate the capital 

investment needs for drinking water systems eligible to receive Drinking Water State Revolving Fund 

(DWSRF) monies. The nationwide assessment will be conducted by the Drinking Water Protection 

Division (DWPD) of EPA’s Office of Ground Water and Drinking Water (OGWDW). The data collection 

is authorized by Sections 1452(h) and 1452(i)(4) of the Safe Drinking Water Act (SDWA) and will be 

used to estimate the cost of providing safe drinking water to consumers over a 20-year period. The data 

from the report will also be used to allot DWSRF monies among states. 

While the focus of the 2011 DWINSA is collecting information on systems’ needs and on the projected 

costs associated with those needs, EPA also uses the surveying effort to identify and report on emerging 

trends and issues potentially impacting infrastructure investment needs of the Nation’s drinking water 

systems. Issues of current interest include: the industry’s employment of sustainable infrastructure 

planning methods and policies, infrastructure investments to increase security deployment of “green”

infrastructure projects, and considerations of climate changes or variability (i.e., climate readiness) in

infrastructure investment planning.

EPA’s primary goal is to achieve the most accurate survey possible. The two sources of potential 

inaccuracy in the survey result from “measurement error” in determining the need for each individual 

infrastructure investment and “sampling error” in estimating the needs of all water systems from a 

representative sub-sample of those systems. EPA strives to reduce “measurement error” by relying on the 

information and judgment of those individuals most familiar and directly responsible for the 

infrastructure, the owners and operators of water systems, and assuring that their estimates of investment 

needs are within the context of the industry’s best engineering practices. EPA addresses the “sampling 

error” by identifying and specifying statistical precision targets for the survey and determining the 

necessary sample and sub-sample sizes to achieve those targets. It is important to note that while greater 

statistical precision can be achieved by increasing the size of the sample to be surveyed, the additional 

burden that a larger sample size creates for collecting data and assuring its quality can result in 

substantially increasing the potential for measurement errors, perhaps reducing the overall accuracy of the 

survey. In determining the most appropriate survey approach, EPA strives to create a balance between 

achieving statistical precision and avoiding measurement errors as well as to minimize the burden placed 

on the states, water systems, and the Agency in conducting the surveying effort.

 

1 EPA’s previous assessments of infrastructure need in 1995 and 1999 were called “needs surveys” because the 

assessment relied primarily on survey methods. In 2003, EPA relied in part on surveys but also on analysis of 

previous survey data. Accordingly, the term “assessment” is more appropriate. Hereinafter, these studies will be 

referred to as “assessments.”
ICR for 2011 DWINSA 2 December 8, 2010

All states and the Navajo Nation have committed to help EPA administer the 2011 DWINSA with at least 

the minimum of activities. Fifteen states will not participate in the statistical portion of the survey (i.e., 

collecting data from systems serving 3,301 – 100,000 persons). For the states that are not included in the 

statistical portion of the survey, the needs of the participating states will be used to determine the needs 

for systems serving 3,301 – 100,000 persons. All states with systems serving more than 100,000 persons

will participate in the census portion of the survey. 

For the 2011 DWINSA, there are two similar approaches EPA will take to collect the information. One 

approach will collect the 20-year need for systems that are under state primacy (e.g., 2011 State 

DWINSA). The term “states” refers to all 50 states, the U.S. territories (Guam, U.S. Virgin Islands, 

Northern Mariana Islands, and American Samoa), Puerto Rico, and the District of Columbia. A separate 

collection of 20-year need will be conducted for American Indian and Alaskan Native Village water 

systems (e.g., 2011 Native American DWINSA). The method of data collection and statistical precision is 

the same for the two approaches. However, to account for differences the stratification of systems 

between the two approaches and the type of systems that EPA will collect information from will differ. 

For the 2011 State DWINSA, EPA will conduct a census of all community water systems (CWSs) serving 

populations more than 100,000 and select a random sample of CWSs that serve populations of 3,301 –

100,000. EPA will estimate the infrastructure needs for CWSs serving 3,300 and fewer persons based on 

the 2007 DWINSA results and the infrastructure needs for not-for-profit noncommunity water systems 

(NPNCWSs) 2

For the 2011 Native American DWINSA, EPA will conduct a census of all CWSs and NPNCWSs serving 

more than 10,000 and will select a random sample of CWSs and NPNCWSs serving 10,000 and fewer 

persons. These systems will receive the same data collection instrument as the systems selected for the 

2011 State DWINSA. EPA Regions and the Navajo Nation will use data provided by the Indian Health 

Service (IHS) from their Sanitary Deficiency System (SDS) to identify potential needs and EPA Regions 

and the Navajo Nation will collect additional information through phone calls or on-site engineering 

reviews.

based on the 1999 DWINSA results. The data collection instrument that EPA will send to 

all water systems selected in the 2011 State DWINSA to complete consists of project tables in which the 

water systems list all their capital improvement projects for the survey period of January 1, 2011 to 

December 31, 2030.

The effort for the 2011 DWINSA will involve 3,215 respondents (3,158 water systems, 56 states3

, and the 

Navajo Nation), requiring 48,995 hours at a total cost to the respondents of $1,847,525. Section A.6, 

Estimating the Burden and Cost of the Collection, provides a detailed description of the unit burden and 

costs for this collection. The average water system burden per response is 7.51 hours.4

 

2 NPNCWSs are also eligible for DWSRF funding.

3 Fifty-six states include the 50 states plus the District of Columbia, Puerto Rico, Northern Mariana Islands, 

American Samoa, Guam, and the U.S. Virgin Islands. 

4 See Exhibit A-6-9.
ICR for 2011 DWINSA 3 December 8, 2010

A.2 NEED FOR AND USE OF THE COLLECTION

A.2.a Authority and Need for the Collection 

EPA (the Agency) is conducting this DWINSA pursuant to its authority under Sections 1452(h) and 

1452(i)(4) of the SDWA. Section 1452(h) requires that “the Administrator shall conduct an assessment of 

water system capital improvements needs of all eligible public water systems in the United States and 

submit a report to the Congress containing the results of such assessment within 180 days after the date of 

the enactment of the SDWA Amendments of 1996 and every 4 years thereafter.” Section 1452(i)(4) 

requires that “the Administrator, in consultation with the Director of Indian Health Services and Indian 

Tribes, shall, in accordance with a schedule that is consistent with the needs survey conducted pursuant to 

subsection (h), prepare surveys and assess the needs of drinking water treatment facilities to serve Indian 

Tribes, including an evaluation of the public water systems that pose the most significant threat to public 

health.”

A.2.b Use and Users of the Information 

The results of the 2011 DWINSA will be used as a basis for allocation of DWSRF funds among states

and EPA Regions (for the American Indian and Alaskan Native Village water systems). In addition, many 

water systems have empirical data on the cost of compliance with SDWA regulations. A national 

assessment will improve the Agency’s ability to gauge the real capital cost of SDWA regulations. 

EPA will collect three types of system-specific information: (1) system inventory and characteristics data 

(i.e., name and address of the system, contact person, population served, total design capacity, number of 

connections, primary source, whether the system is privately or publicly owned, and whether the system 

purchases/sells water from/to another public water system (PWS)); (2) information on capital 

improvement projects; and (3) information on “green” and climate readiness infrastructure projects. The 

specific uses of each data type vary. EPA will use system inventory and characteristics data to 

characterize CWSs nationwide, and, in some cases, to model individual systems’ capital improvement 

projects. EPA will use all data collected to estimate state and national needs. This will be the first time 

EPA will collect information for “green” and climate readiness infrastructure projects.

Respondents will identify needs on a project-by-project basis and list the “type(s) of need” that the project 

will meet on the data collection instrument. EPA will collect information on the proposed infrastructure to 

be installed, replaced, rehabilitated, upgraded, or expanded. EPA will use the information to assess 

project allowability.

Respondents will also identify either a documented cost estimate for the project or will provide adequate 

information so that EPA can model the cost of the project. The information needed to model the cost will 

depend on the type of need. For example, EPA may collect information on the type and number of meters

or the diameter and length of transmission or distribution lines. EPA expects that modeling will be 

required to project the capital needs for some systems that serve more than 100,000 persons, many of the 

systems that serve 3,301 – 100,000 persons, and almost all of the systems serving 3,300 and fewer (for 

the 2011 Native American DWINSA only). For the 2007 DWINSA, approximately 19 percent of the 

projects reported had documented costs; the costs for the remaining 81 percent of projects were modeled. 

The data collected by the 2011 DWINSA will likely have several secondary uses, both inside and outside 

of EPA. For example, EPA will use the information to support various program activities, such as the 
ICR for 2011 DWINSA 4 December 8, 2010

development of general enforcement strategies and new regulations. Congress may use occurrence and 

cost information in considering new drinking water legislation. States have indicated to EPA that they 

plan to use the data collected to help identify projects that should be included on the state’s DWSRF 

priority list and to implement capacity development strategies. The public may use information on costs 

associated with SDWA compliance.
ICR for 2011 DWINSA 5 December 8, 2010

A.3 NONDUPLICATION, CONSULTATIONS, AND OTHER 

COLLECTION CRITERIA

The following sections verify that this information collection satisfies the OMB’s nonduplication and 

consultation guidelines, and does not duplicate another collection.

A.3.a Nonduplication 

To the best of EPA’s knowledge, up-to-date state-by-state information on water systems’ capital needs is 

not available from any other source. Some of the data collection efforts EPA considered include the 

following:

• Safe Drinking Water Information System (SDWIS). Inventory data and information on system 

characteristics have been collected by states and regions and entered into the SDWIS. For the 

statistical sample, EPA will pre-print the SDWIS system characteristics data (i.e., name and 

address of the system, contact person, address, population served, total design capacity, number 

of connections, primary source, whether the system is privately or publicly owned, and whether 

the system purchases/sells water from/to another PWS) on the 2011 DWINSA form and ask the 

respondents to provide information only if the SDWIS data are inaccurate or missing. SDWIS 

does not contain information on water systems’ capital needs. 

• Community Water System Survey (CWSS). EPA completed a statistical survey in 2006 that 

focused on the operating and financial characteristics of CWSs. The CWSS is addressed in the 

ICR for National Survey of the Financial and Operating Characteristics of Community Water 

Suppliers. The CWSS had a different objective than the DWINSA. The CWSS was designed to 

characterize the technical and financial aspects of CWSs. In contrast, the DWINSA will be used 

to develop national estimates of capital needs. In addition, the CWSS’s targeted precision was on 

a national basis; whereas the DWINSA will provide state-by-state estimates. 

• Economic Analyses (EAs) for National Primary Drinking Water Regulations. The Agency 

has developed EAs for its National Primary Drinking Water Regulations. These documents 

estimate the costs of complying with proposed regulations. The scope of the EAs is limited to the 

cost associated with the implementation of a given proposed regulation. EAs do not include an 

estimate for on-going capital projects to maintain compliance with existing regulations. 

Therefore, the EAs are not an adequate substitute for the DWINSA. In addition, the EAs provide 

nationwide estimates. As discussed above, EPA is conducting the DWINSA because the Agency 

needs a state-by-state estimate to develop the allocation formula for the DWSRF. Also, many 

EAs are several years out of date. They do not consider currently available contaminant 

occurrence data or current or emerging treatment technology costs. 

• State Needs Surveys. Several states have conducted needs surveys of their own drinking water 

systems. The state results cannot be extrapolated to the nation as a whole because the state 

surveys do not use consistent methodologies and do not account for national variations in system 

characteristics and needs.

• 1995, 1999, 2003, and 2007 DWINSAs. Under the SDWA, EPA must conduct the DWINSA 

every 4 years. The approach for the 2011 DWINSA will incorporate some data collected during 

the previous assessments, as well as “lessons learned” from the earlier assessments. In addition, 
ICR for 2011 DWINSA 6 December 8, 2010

the approach for the 2011 DWINSA ensures that up-to-date data on infrastructure needs are 

collected for all CWSs. CWSs under state primacy accounted for approximately 97 percent of the 

national need for the 2007 DWINSA. The remaining 3 percent represents needs associated with 

American Indian and Alaskan Native water systems, NPNCWSs, and recently promulgated 

regulations. 

A.3.b Public Notice Required Prior to ICR Submission to OMB 

To comply with the 1995 Amendments to the Paperwork Reduction Act (PRA), EPA solicited public 

comment on this ICR for a 60-day period before it was submitted to OMB. Specifically, EPA published a 

notice in the Federal Register (FR) requesting comment on the estimated respondent burden and other 

aspects of this ICR (75FR55324). This notice is included in Appendix A. Before submission to OMB, 

EPA considered any comments received and determined if any adjustments were needed to the burden 

and cost calculations or to the supporting statement for this ICR. Comments received and EPA’s 

responses are included in Appendix C. An additional Federal Register notice will be published when this 

ICR is submitted to OMB. The public comment period for this additional notice is 30 days.

A.3.c Consultations 

In May 2010, EPA assembled a workgroup that consisted of EPA Headquarters, EPA Regional, tribal, 

and state representatives to discuss the approach for the 2011 DWINSA. Separate meetings were held for 

the 2011 State DWINSA and the 2011 Native American DWINSA. The purposes of the meetings were to 

gather information on state, Native American, and/or regional concerns; to discuss lessons learned during 

the 2007 DWINSA; and to discuss new policies for the 2011 DWINSA. The 2011 Native American 

DWINSA Workgroup also discussed the methodology for collecting information from American Indian 

and Alaskan Native Village water systems. The information gathered during the meetings was used to 

develop the methodology for the 2011 DWINSA. 

For the 2007 DWINSA the data collection instrument and some policies were modified substantially. 

Consequently, in 2007, EPA conducted a pre-test of the data collection instrument (see B.3 for more 

information on the pre-test) and a formal peer review of the 2007 DWINSA statistical methodology and 

policies. Based on comments received from the peer review and the pre-test, EPA made modifications to 

the data collection instrument, statistical procedures, and survey polices. Since the only significant 

modification to the 2011 data collection instrument was the addition of questions and codes to gather 

information on “green” and climate readiness infrastructure projects, EPA conducted a limited peer 

review of these new questions. The peer review included experts familiar with the operations of drinking 

water systems and “green” and climate readiness issues. Based on comments received from the peer 

review EPA developed an addendum to the survey instructions that provides additional explanation on 

why EPA is collecting information on “green” and climate readiness infrastructure projects as well as an 

explanation on what EPA means by “green” and climate readiness infrastructure projects. 

A.3.d Effects of Less Frequent Collection 

The 2011 DWINSA is a single collection and does not involve periodic reporting or recordkeeping.
ICR for 2011 DWINSA 7 December 8, 2010

A.3.e General Guidelines 

The 2011 DWINSA does not violate any guidelines for information collection activities specified by 

OMB. Specifically, the 2011 DWINSA respondents are not required to:

• Report information to EPA more often than quarterly.

• Retain records for more than 3 years.

• Complete the data collection instrument in fewer than 30 days.

• Maintain or provide information in a format other than that in which it is customarily maintained.

• Submit proprietary, trade secret, or other confidential information.

• Submit more than one original and two copies of any document.

The information collection:

• Is a statistical assessment designed to produce data that can be generalized to the universe of the 

study (see Section B.2).

• Does not provide remuneration to participants.

• Will transcribe information collected into an automated format.

• Is designed with small entities particularly in mind (see Part A.5.c).

• Does not concern grants or grantees.

• Is voluntary.

A.3.f Confidentiality Questions 

This information collection does not require the respondent to disclose any confidential information. 

Respondents are not obliged to respond to this strictly voluntary information collection. Further, 

respondents could eliminate any confidential business information from their reply. 

A.3.g Sensitive Questions 

The 2011 DWINSA does not ask sensitive questions, such as those pertaining to sexual attitudes or 

behavior or religious beliefs.
ICR for 2011 DWINSA 8 December 8, 2010

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ICR for 2011 DWINSA 9 December 8, 2010

A.4 THE RESPONDENTS AND THE INFORMATION REQUESTED

A.4.a Respondents/NAICS Codes 

NAICS Codes

The respondents for the 2011 DWINSA are CWSs, NPNCWSs, tribal authorities, and states. Both CWSs 

and NPNCWSs are considered public water systems. According to 40 CFR Part 141.2, a CWS is a 

“public water system which serves at least 15 service connections used by year-round residents or 

regularly serves at least 25 year-round residents” and a NCWS is a “public water system that is not a 

community water system and that regularly serves at least 25 of the same persons over 6 months per year”

(nontransient noncommunity water system) or is a public water system that is not a community water 

system and “does not regularly serve at least 25 of the same persons over six months per year” (transient 

noncommunity water system). The North American Industry Classification System (NAICS) code for a 

public water system is 221310. For government establishments providing public administration of 

American Indian and Alaskan Native Village affairs, the NAICS code is 921190 (Other General 

Government Support). State agencies that include drinking water programs are classified as NAICS code 

924110 (Administration of Air and Water Resources and Solid Waste Management Programs) or 926130 

(Regulation and Administration of Communications, Electric, Gas, and Other Utilities). Ancillary systems 

(i.e., those that supplement the function of other establishments like factories, power plants, mobile home 

parks, etc.) cannot be categorized in a single NAICS code. For ancillary systems, the NAICS code is that 

of the primary establishment or industry.

Respondents

For the 2011 State DWINSA, EPA will gather information from CWSs serving more than 3,300 persons. 

Because of their variability and significant contribution to the overall drinking water capital investment 

need, systems serving more than 100,000 persons will be sampled with certainty. EPA will survey 611

systems that serve more than 100,000 persons. There are 8,919 systems that serve populations of 3,301 –

100,000. Surveying all of these systems would impose a large burden on respondents, EPA, and states.

Therefore, EPA will select a statistically representative sample of systems serving 3,301 – 100,000. This 

will result in 2,241 systems receiving the mailed data collection instrument. Part B of the supporting 

statement describes the sampling methodology.

For the 2011 Native American DWINSA, EPA will collect information from all American Indian and 

Alaskan Native Village water systems serving more than 10,000 and will select a random sample of 

American Indian and Alaskan Native Village water systems serving 10,000 and fewer persons. This will 

result in 306 water systems being selected as part of the 2011 Native American DWINSA. Part B of the 

supporting statement describes the sampling methodology.

Fifty-six states (50 states plus the District of Columbia, Puerto Rico, Northern Mariana Islands, American 

Samoa, Guam, and the U.S. Virgin Islands) and the Navajo Nation will provide support and information 

for the 2011 DWINSA. 
ICR for 2011 DWINSA 10 December 8, 2010

A.4.b Information Requested 

As previously discussed, EPA will collect three types of information from systems: (1) system inventory 

and characteristics; (2) information on capital improvement projects; and (3) information on “green” and 

climate readiness infrastructure projects. EPA anticipates that respondents will provide varying levels of 

information by system size category. Based on experience from the previous four DWINSAs, EPA 

expects larger systems (e.g., those systems serving more than 50,000 persons) to have a good 

understanding of their capital needs and the costs for meeting them. Almost all of these systems will have 

detailed Capital Improvement Plans (CIPs). Most of these systems will be capable of providing accurate 

information on cost. Most medium-sized systems (e.g., those systems serving 3,301 to 50,000 persons)

can provide reliable data on their needs and some can provide cost estimates for meeting their needs. The 

information that respondents will be asked to provide is generally maintained and reported as a function 

of the management and operation of the water system. American Indian and Alaskan Native Village water 

systems that serve populations of 3,300 or fewer are unlikely to be able to provide much information on 

needs or costs. EPA will use data provided by the IHS from their Sanitation Deficiency System (SDS) to 

identify potential needs and EPA Regions will collect additional information through phone calls or onsite engineering reviews.

A.4.b.i Data Items 

2011 State DWINSA – Systems serving more than 3,300 persons

The data collection instrument asks respondents to verify or correct system characteristic information 

(i.e., name and address of the system, contact person, address, population served, total design capacity, 

number of connections, primary source, whether the system is privately or publicly owned, and whether 

the system purchases/sells water from/to another PWS). It is Customary Business Practice (CBP) for the 

system to maintain this information. The respondent will either indicate that the information is correct as 

printed or enter the correct information in the space provided. States verify this information in advance of 

the data collection instrument being sent to the systems. Based on previous assessments, EPA anticipates 

that very few systems will need to correct the information provided.

In addition, the respondent is asked to provide information on tables associated with specific types of 

projects:

• Source.

• Treatment.

• Finished or Treated Water Storage, Pumping, and Other.

• Transmission and Distribution.

• Backflow Prevention Devices/Assemblies, Flushing Hydrants, Service Lines, Valves, and Water 

Meters, and Other.

For each project, the respondent is asked to:

• Briefly describe the needed capital projects (e.g., “routine distribution system replacement,”

“filtration plant upgrade,” “high service pump replacement,” “corrosion control treatment,” or 
ICR for 2011 DWINSA 11 December 8, 2010

“storage tank rehabilitation”). Information is collected on a project-by-project basis because it is 

most commonly available to respondents in that form, and because documentation, when 

available, is usually developed on a project-by-project basis.

• Provide the code that best describes the project from List 15

– Develop separate cost estimates for source water treatment, transmission, storage, 

distribution, and other needs. (EPA will disaggregate the costs when projects meet 

multiple needs, if necessary.) 

of the Lists of Codes and that best 

describes the reason for the need from List 2. EPA will use this information to:

– Help verify that adequate documentation of the need has been submitted.

– Help determine if the project is an allowable need.

– Help gauge cost-reasonableness.

• Indicate if the project is to install new infrastructure to meet current population demands, replace 

old infrastructure, expand or upgrade existing infrastructure (such as treatment plants to meet 

current population demands), or rehabilitate existing infrastructure. 

• Indicate if the project is needed now to protect public health or not needed now, but will be 

necessary to continue providing safe drinking water over the next 20 years.

• Indicate if the project is associated with a regulation requirement or if the infrastructure is for a 

“green” or climate readiness need using the codes from List 3 in the Lists of Codes. EPA will use 

this information to determine which needs are required or necessary because of SDWA 

regulation, state requirement, or green or climate readiness need. If a system indicates they have 

projects pertaining to climate readiness, they will be asked to provide additional information 

regarding those projects on the data collection instrument. They will be asked if the project is for 

source quality degradation issues, source quantity degradation issues, or infrastructure 

vulnerability. They will also be asked if data was obtained through models or by other means.

• Provide design capacity when applicable—millions of gallons per day (MGD) for treatment and 

pumping; millions of gallons (MG) for storage; the diameter and number of feet of distribution or 

transmission lines; or the size and number of backflow prevention devices/assemblies, flushing 

hydrants, service lines, valves, and water meters. EPA will use these parameters to model project 

costs.

• If available, provide the capital cost estimate and year and month (if known) of the estimate. EPA 

will use this information to assign the cost of the project. The year and month are important 

 

5 List 1 of the List of Codes are the same for the 2011 State DWINSA and the 2011 Native American DWINSA, 

except the 2011 Native American DWINSA will have 5 extra Type of Need codes. This is consistent with the codes 

used for systems serving 3,300 and fewer persons in the 2007 DWINSA. Both List of Codes are included in 

Appendix B. 
ICR for 2011 DWINSA 12 December 8, 2010

because they will allow EPA to account for differences in the value of money over different years 

and to convert all costs to a common year.

• Provide an estimate of the total length of pipe in the water system. This information will only be 

required for water systems that submit pipe projects but do not have independent documentation 

(i.e., planning document, sanitary survey, or leak and break records). It is expected that not all 

systems will need to provide this inventory information. This information is necessary to allow 

EPA to determine that the need reported is reasonable for replacement or rehabilitation in a 20-

year timeframe. 

• Indicate the type of documentation from List 4 of the Lists of Codes that explains why the project 

is needed and, if a cost estimate is available, indicate the documentation that explains the 

breakdown of the cost. This will verify the cost for the project. NOTE: EPA does not expect 

systems to develop cost estimates for the purposes of the 2011 DWINSA.

The data collection instrument contains optional worksheets where respondents can record information 

about the water system’s existing infrastructure including information on storage tanks, pumps, and pipe 

material as well as the age and condition of the infrastructure. This information will not be entered into 

the DWINSA data system, but is only provided as a helpful tool for a respondent to inventory all of a 

water system’s assets and assess any infrastructure needs that are not yet part of the system’s formal 

planning documents.

For respondents of the 2011 State DWINSA that reported projects in the 2007 State DWINSA, EPA will 

provide them a list of all the projects that were submitted in response to the 2007 DWINSA. The 

respondent will be asked to update the list, by correcting any old information (e.g., cost estimate), 

deleting projects that are completed or no longer needed, and providing appropriate documentation that 

support the project. These respondents will also add any new projects that were not included in the 2007 

State DWINSA. All projects must meet documentation and policy requirements established for the 2011 

DWINSA.

The respondent is also asked to provide his or her name, title, address, phone number, and e-mail address. 

This information is requested in case EPA or the state must contact the respondent for clarification or 

explanation of any response.

The respondent is asked to attach documentation for all needs and costs reported in the 2011 DWINSA. 

Systems are encouraged to provide inventory data on their systems. Only where noted above will the 

inventory data be required. 

The data collection instrument is attached as Appendix B.

2011 Native American DWINSA – American Indian and Alaskan Native Village Water Systems 

To minimize the burden on American Indian and Alaskan Native Village water systems, EPA Regional 

Offices and the Navajo Nation will use available information from the IHS SDS. EPA Regional and 

Navajo Nation personnel will complete the data collection instrument for the water systems using the 

information from the IHS SDS and any additional information collected from the respondent. 

Respondents will be expected to answer very basic questions about the physical design of the plant, 

system configuration, and capital needs.
ICR for 2011 DWINSA 13 December 8, 2010

The data collection instrument is attached as Appendix B.

A.4.b.ii Respondent Activities 

2011 State DWINSA –Systems serving more than 3,300 persons

To complete the data collection instrument, the following activities are anticipated for CWSs serving 

more than 3,300 persons:

• Participate in an informational telephone call from the state. Respondents will receive a call 

from the state describing the purpose of the DWINSA, the information that will be requested, and 

the timetable for completing and returning the data collection instrument.

• Read the cover letter and data collection instructions. Respondents will review the cover letter 

and instructions accompanying the data collection instrument.

• Collect and copy supporting documentation. Respondents will locate the necessary supporting 

documentation in system files and copy it.

• Complete the data collection instrument. Respondents will fill out the data collection 

instrument and attach supporting documentation. An estimate of total amount of pipe in the 

system must be provided if any pipe project is submitted without independent documentation of 

need (e.g., a planning document). 

In addition, some respondents may contact states (or an EPA-established helpline) to obtain clarifying 

information on the data collection instrument.

2011 Native American DWINSA – American Indian and Alaskan Native Village Water Systems 

The 2011 Native American DWINSA methodology has been designed to minimize the burden on 

American Indian and Alaskan Native Village water systems. Their role will be limited to answering basic 

questions during a phone call and providing any available documentation to the Regional Offices or the 

Navajo Nation. They will:

• Participate in an informational telephone call from the EPA Regional Office or Navajo 

Nation. Respondents will receive a call that describes the purpose of the DWINSA.

• Answer basic questions posed by the EPA Regional Office or the Navajo Nation. 

Respondents will be expected to answer very basic questions about the physical design of the 

plant, system configuration, and capital needs.

• Collect and copy supporting documentation. Respondents will locate the necessary supporting

documentation in system files and copy it.

2011 State DWINSA – State Activities

All states have committed to help EPA administer the 2011 State DWINSA with at least the minimum of 

activities. Fifteen states will not participate in the statistical portion of the survey (i.e., collecting data 

from systems serving 3,301 – 100,000 persons). For non-participating states, the needs of the 
ICR for 2011 DWINSA 14 December 8, 2010

participating states will be used to determine an average need per strata. This will be applied to the 

inventory of systems in non-participating states to estimate the needs for systems serving 3,301 – 100,000 

persons. All states that have systems serving more than 100,000 persons will participate in the census 

portion of the survey.

The activities described in this section represent a level of participation that will ensure nationally 

consistent results. Some states will participate at a higher level. 

State Up-Front Activities

This first activity category includes the states’ “fixed burden” for helping EPA prepare for the 

2011 State DWINSA. 

– Participate in training and other pre-mailout efforts. This activity includes 

participating in training sessions offered by EPA and becoming familiar with the survey 

design and policies. In addition, it includes activities such as reviewing the draft data 

collection instrument.

– Help EPA verify SDWIS data. There are several important variables for which SDWIS 

data must be verified. Critical inventory data for the statistical sample will need to be 

reviewed. Such data includes the PWS identification number (PWSID), system name, 

address, telephone numbers (if any), primary source, population served, number of 

service connections, whether the facility is publicly or privately owned, and whether the 

system is a consecutive system. In addition, states will need to review address 

information to ensure the street address for each system selected in the sample is 

accurate. To help with this verification activity, EPA will provide the information that 

must be reviewed in electronic form.

– Perform miscellaneous administrative activities. States will perform various 

administrative duties prior to the 2011 State DWINSA (e.g., establishing system files). In 

addition, state management will explain the 2011 State DWINSA to staff and allocate 

resources. 

State Data Collection Activities for Systems serving more than 3,300 persons

States will conduct the following activities for CWSs serving more than 3,300 persons during the 

data collection phase of the 2011 State DWINSA:

– Telephone systems to ensure participation. To improve response rates, states that 

participate in the 2011 DWINSA will telephone the water systems early in the process to 

ensure that they have received the survey package and understand how to complete the 

data collection instrument.

– Provide technical assistance. Participating states will provide technical assistance to 

systems by answering their questions about the data collection instrument and how needs 

should be represented.
ICR for 2011 DWINSA 15 December 8, 2010

– Call systems that do not return the data collection instrument by a certain date. To 

improve response rates, participating states will telephone systems that have not returned 

their assessment by a specific date to encourage participation.

– Review completed data collection instruments and documentation. The data 

collection instrument will be returned directly to the state. State personnel will have the 

opportunity to review the information on the data collection instrument, as well as any 

accompanying documentation. 

– Discuss results with EPA. After the state reviews the submission and documentation, the 

state forwards the data to EPA for review and data entry. EPA performs a second quality 

assurance/quality control check to ensure all data are documented and allowable. Any 

differences of opinion regarding the documentation of the data will be resolved by EPA 

and the state. 

2011 Native American DWINSA – Navajo Nation Activities

The Navajo Nation has primary enforcement for water systems within its tribal organization. The Navajo 

Nation has committed to help EPA administer the 2011 Native American DWINSA with at least the 

minimum of activities for its water systems that are selected in the 2011 Native American DWINSA. EPA 

Regional Offices will provide support for all other American Indian and Alaskan Native Village water 

systems. Their activities are discussed in A.5. 

Navajo Nation Up-Front Activities

This first activity category includes the Navajo Nation “fixed burden” for helping EPA prepare 

for the 2011 Native American DWINSA. 

– Participate in training and other pre-mailout efforts. This activity includes 

participating in training sessions offered by EPA and becoming familiar with the survey 

design and policies. In addition, it includes activities such as reviewing the draft data 

collection instrument.

– Help EPA verify SDWIS data. There are several important variables for which SDWIS 

data must be verified. Critical inventory data for the statistical sample will need to be 

reviewed. Such data include PWSID, system name, address, telephone numbers (if any), 

primary source, population served, number of service connections, whether the facility is 

a NPNCWSs, and whether the system is a consecutive system. To help with this 

verification activity, EPA will provide the information that must be reviewed in 

electronic form.

– Perform miscellaneous administrative activities. The Navajo Nation will perform 

various administrative duties prior to the 2011 Native American DWINSA (e.g., 

establishing system files). In addition, Navajo Nation management will explain the 2011 

Native American DWINSA to staff and allocate resources.
ICR for 2011 DWINSA 16 December 8, 2010

Navajo Nation Data Collection Activities 

The Navajo Nation will conduct the following activities for their water systems during the data 

collection phase:

– Telephone systems to ensure participation. The Navajo Nation will contact the water 

system operators of systems selected in the 2011 Native American DWINSA to ensure 

participation and to schedule time to discuss the systems 20-year need and review the 

completed data collection instrument.

– Review the IHS SDS projects. The Navajo Nation will review the list of projects 

extracted from the IHS SDS and incorporate appropriate projects onto the 2011 DWINSA 

data collection instrument. 

– Discuss 20-year need. The Navajo Nation will contact the water system and discuss 

projects that have been identified, ask basic questions about the physical design of the 

plant, system configuration, and capital needs, and request additional documentation 

from the water system. 

– Complete the data collection instrument. Based on all the data collected from IHS and 

the water system, the Navajo Nation will complete the data collection instrument and 

submit it to EPA. An estimate of total amount of pipe in the system must be provided if

any pipe project is submitted without independent documentation of need (e.g., a 

planning document).

– Discuss results with EPA. After the data collection instrument is submitted, EPA will 

perform a quality assurance/quality control check to ensure all data are documented and 

allowable. Any differences of opinion regarding the documentation of the data will be 

resolved by EPA and the Navajo Nation. 
ICR for 2011 DWINSA 17 December 8, 2010

A.5 INFORMATION COLLECTED: AGENCY ACTIVITIES, 

COLLECTION METHODOLOGY, AND INFORMATION 

MANAGEMENT

A.5.a Agency Activities 

A.5.a.i EPA and Contractor Activities

Many of the EPA activities described here will be conducted by contractors with EPA oversight/technical 

direction. For example, EPA will oversee contractor development of the data collection methodology and 

collection and analysis of assessment data. For purposes of describing Agency activities related to the 

2011 DWINSA, contractor effort is not distinguished from EPA effort. Separate estimates for contractor 

burden and cost will be provided in Section A.6.c. In addition, Section B.1.c describes the contractor’s 

role. 

Up-Front Activities

The following pre-assessment activities will be conducted:

• Revise the data collection instrument. EPA is revising the data collection instrument based on 

lessons learned during the previous DWINSAs and to incorporate questions on “green” and 

climate readiness infrastructure projects. This task will include developing cover letters and other 

materials for state use.

• Train state and Navajo Nation participants. To ensure that participating state and Navajo 

Nation officials understand every aspect of the 2011 DWINSA, EPA will conduct regional 

training sessions. The training will help ensure consistent responses across the country, high 

response rates, and efficient use of staff. 

• Select 2011 DWINSA respondents. The Agency will draw state samples for the 2011 State 

DWINSA, a national sample for the American Indian portion of the 2011 Native American 

DWINSA, and a sample of Alaskan Native Village water systems. 

• Update data system. EPA will update the data system used for the 2007 DWINSA to store and 

analyze data. The system will produce the necessary statistical reports for EPA, Congress, states, 

and the Navajo Nation. The system will also allow EPA, state, and Navajo Nation offices access 

to the data.

• Send data collection instruments. This will include preprinting information on the front and last 

page of the data collection instrument, printing a list of projects reported in the 2007 DWINSA 

for systems that are selected to participate in the 2011 State DWINSA, and sending the data 

collection instrument and additional material via FedEx directly to the selected systems for the 

2011 State DWINSA. For the 2011 Native American DWINSA, data collection instruments will 

be sent to the EPA Regional Offices or Navajo Nation. 
ICR for 2011 DWINSA 18 December 8, 2010

Data Collection Activities

EPA will conduct the following activities during the data collection phase of the 2011 DWINSA:

• Provide technical assistance. The Agency will maintain a helpline primarily to provide technical 

assistance to water systems (unless the state prefers to do so). The helpline will promote

consistent responses across the country.

• Review completed data collection instruments. EPA will review the completed data collection 

instruments to ensure that all data are documented and allowable.

• Maintain the data. EPA will enter DWINSA data into the data system and perform quality 

assurance/quality control checks of data entry.

A.5.a.ii EPA Regional Activities for the 2011 Native American DWINSA

EPA Regional Offices will help EPA Headquarters administer the 2011 Native American DWINSA with 

at least the minimum of activities. Support will be provided for all American Indian (except for those 

water systems under the primacy of the Navajo Nation) and Alaskan Native Village water systems. 

EPA Regional Offices Up-Front Activities

This first activity category includes the EPA Regional Offices “fixed burden” for helping EPA 

prepare for the 2011 Native American DWINSA. 

– Participate in training and other pre-mailout efforts. This activity includes 

participating in training sessions offered by EPA and becoming familiar with the survey 

design and policies. In addition, it includes activities such as reviewing the draft data 

collection instrument.

– Help EPA verify SDWIS data. There are several important variables for which SDWIS 

data must be verified. Critical inventory data for the statistical sample will need to be 

reviewed. Such data include PWSID, system name, address, telephone numbers (if any), 

primary source, population served, number of service connections, whether the facility is 

a NPNCWSs, and whether the system is a consecutive system, To help with this 

verification activity, EPA will provide the information that must be reviewed in 

electronic form.

– Perform miscellaneous administrative activities. EPA Regional Offices will perform 

various administrative duties prior to the 2011 Native American DWINSA (e.g., 

establishing system files). In addition, EPA Regional management will explain the 2011 

Native American DWINSA to staff and allocate resources.
ICR for 2011 DWINSA 19 December 8, 2010

EPA Regional Offices Data Collection Activities 

EPA Regional Offices will conduct the following activities for the American Indian water 

systems (except those water systems under the primacy of the Navajo Nation) and Alaskan Native 

Village water systems during the data collection phase:

– Telephone systems to ensure participation. EPA Regional Offices will contact the 

water system operators of systems selected in the 2011 Native American DWINSA to 

ensure participation and to schedule time to discuss the systems 20-year need and review 

the completed data collection instrument.

– Review the IHS SDS projects. EPA Regional Offices will review the list of projects 

extracted from the IHS SDS and incorporate appropriate projects onto the 2011 DWINSA 

data collection instrument. 

– Discuss 20-year need. EPA Regional Offices will contact the water systems and discuss 

projects that have been identified, ask basic questions about the physical design of the 

plant, system configuration, and capital needs, and request additional documentation 

from the water system. 

– Complete the data collection instrument. Based on all the data collected from IHS and 

the water system, EPA Regional Offices will complete the data collection instrument and 

submit it to EPA. An estimate of total amount of pipe in the system must be provided if

any pipe project is submitted without independent documentation of need (e.g., a 

planning document).

– Discuss results with EPA. After the data collection instrument is submitted, EPA will 

perform a quality assurance/quality control check to ensure all data are documented and 

allowable. Any differences of opinion regarding the documentation of the data will be 

resolved by EPA and EPA Regional Offices. 

A.5.b Collection Methodology and Management 

This section discusses the steps that EPA has taken to ensure that the information being collected will be 

accurate, reliable, and retrievable. This methodology was developed using experience gained in 

conducting the previous DWINSAs. EPA has incorporated into this methodology comments and advice 

from EPA staff involved with those assessments. 

Development of Data Collection Instrument

Appendix B contains the data collection instrument. EPA has developed the 2011 DWINSA approach and 

the data collection instrument with the assistance of a workgroup. As is explained in Section A.3.c, the 

workgroup includes EPA Headquarters, EPA Regional, tribal, and state representatives. The 2011 

DWINSA approach and many of the refinements to the data collection instrument were based on 

experience in conducting the 1995, 1999, 2003, and 2007 DWINSAs. In addition, EPA conducted a 

limited peer review of the 2011 DWINSA data collection instrument. In developing the 2011 DWINSA, 

EPA will select a set of appropriate assessment objectives that are easily answerable by knowledgeable 

respondents. Section B.2.c.ii describes the steps taken to ensure that the data collection instrument will be 

an effective tool for retrieving the information EPA needs to meet the 2011 DWINSA objectives.
ICR for 2011 DWINSA 20 December 8, 2010

Methodology for 2011 State DWINSA – CWSs serving more than 3,300 persons

Most systems serving more than 100,000 persons have CIPs or similar documents that summarize their 

needs. Therefore, these systems are generally able to provide accurate information on their needs and, for 

some needs, accurate estimates on the associated cost. A data collection instrument will be sent to every 

CWS that serves more than 100,000 persons. Clarifying information for completing the data collection 

instrument will be available from the state or EPA. The experience of states that participated in the 

previous DWINSAs indicates that systems serving 3,301 – 100,000 persons can reliably complete a data 

collection instrument, if technical support is available. Most of these systems could provide reliable data 

on the needs, and a large portion could provide cost estimates for meeting those needs. 

Also, systems that participated in the 2007 DWINSA and are selected to participate in the 2011 DWINSA 

will receive a copy of their projects from the 2007 DWINSA. These systems will be able to update the 

information on the list and add new projects to the data collection instrument. States will provide 

technical support to the systems participating in the 2011 DWINSA by answering their questions. EPA 

will also offer a helpline for state and system personnel.

EPA will send the data collection instrument directly to the systems. Respondents will send the completed 

data collection instruments to the state. The state will review all data and provide a quality assurance 

/quality control function. The state will then forward the data collection instrument and supporting 

documentation to EPA for review and data entry. EPA will perform a second quality assurance/quality 

control check to ensure that all data are documented and allowable. EPA will enter the data (for systems 

that did not use the electronic reporting form) into the data system. States are provided access to the data 

system and are able to verify that the data have been entered into the data system. Projects or cost 

estimates that are not documented will be identified in the data system as lacking documentation. If the 

system or state does not provide documentation, the project or cost estimate will be deleted from the 2011

State DWINSA. 

For projects that do not have cost estimates, EPA will model the costs.

Methodology for 2011 State DWINSA – CWSs serving 3,300 and fewer persons

Due to funding limitations, data will not be collected in the 2011 State DWINSA from CWSs serving 

3,300 and fewer persons. Their needs will be based on data collected during the 2007 DWINSA and 

updated to 2011 dollars.

Methodology for American Indian and Alaskan Native Village Water Systems 

EPA Regional Offices and the Navajo Nation will use EPA, IHS, and tribal resources to establish an 

estimate of need for the American Indian and Alaskan Native Village water systems. To ensure that all 

appropriate systems are addressed, EPA Regional Offices and the Navajo Nation will review the 

inventory data in SDWIS and provide any updates or changes to EPA Headquarters. The EPA Regional 

Offices and the Navajo Nation will collect information on the projects needed by the selected systems 

over the 20-year period and complete the data collection instrument. The information will be collected on

the same data collection instrument as will be used for the 2011 State DWINSA. 

The data collection instruments will then be forwarded to EPA for review and data entry. EPA will 

perform a quality assurance/quality control check to ensure that all data are documented and allowable. 

EPA will enter the data (for systems that did not use the electronic reporting form) into the data system. If 
ICR for 2011 DWINSA 21 December 8, 2010

the EPA Regional Office or the Navajo Nation chooses, it may verify that the data have been entered into 

the data system. Projects or cost estimates that are not documented will be identified in the data system as 

lacking documentation. If the system, EPA Regional Office, or Navajo Nation does not provide 

documentation, the project or cost estimate will be deleted from the 2011 Native American DWINSA. 

For projects that do not have a cost, the costs for American Indian projects will be assigned using the 

models developed for the overall 2011 State DWINSA. The costs for Alaskan Native Village projects will 

be modeled using the cost models with adjustments to reflect unique construction challenges in arctic 

areas.

Data Quality

It is crucial that the results of the DWINSA be as uniform as possible across the country. Toward this end, 

EPA will take the following steps:

• EPA will establish a uniform set of assumptions or criteria for state, the Navajo Nation, EPA 

Regions, EPA Headquarters, and contractor staff to evaluate data submitted by systems. 

• EPA will provide training to all those involved in the DWINSA to ensure that the assumptions 

and procedures are clear and understood. 

• EPA will provide quality control reviews of each data collection instrument submitted to ensure 

compliance with DWINSA polices and accuracy of data. 

Among the most important steps in quality assurance is training. EPA will provide training sessions for 

state, EPA Regional, and Navajo Nation staff involved in the 2011 DWINSA. The regional training 

sessions will be designed to enable state, EPA Regional, and Navajo Nation staff to review completed 

data collection instruments and respond to questions from systems on the data collection instrument. The 

training will emphasize the following elements:

• Identifying the capital improvements associated with source, treatment, transmission, distribution, 

and storage.

• Discussing policies and documentation requirements.

• Completing the 2011 DWINSA data collection instrument. 

EPA will develop materials for distribution to state, EPA Regional, and Navajo Nation personnel who are 

unable to attend regional training sessions. 

In addition to the training sessions, EPA will provide support for a helpline for state, EPA Regional, 

Navajo Nation, and water system personnel. It is anticipated that the helpline will be used primarily to 

provide information to the EPA Regions, Navajo Nation, and states and that they will provide technical 

support to the systems. However, the helpline will be available to systems in states that have chosen not 

to provide their own technical assistance. Helpline staff will refer questions that raise a policy or technical 

issue to EPA staff. 
ICR for 2011 DWINSA 22 December 8, 2010

Data quality will be assured by implementing the following mechanisms throughout the gathering and 

processing phases of the information collection:

• Adequate documentation. EPA has requested documentation of needs and costs, when 

available, to ensure the accuracy and reliability of the data. Acceptable forms of documentation of 

needs and costs are listed on List 4 of the Lists of Codes. EPA will not accept needs or costs 

without adequate documentation. EPA will make it very clear to respondents that they are not 

expected to develop cost estimates for the purposes of the 2011 DWINSA. The costs of projects

without a cost estimate will be modeled by EPA. 

• Provide an estimate of the total length of pipe in the water system. This information will only 

be required for water systems that submit projects for rehabilitation or replacement of pipe that 

are not independently documented (i.e., planning document, sanitary survey, or leak and break

records). It is expected that not all systems will need to provide this information. This information 

is necessary to allow EPA to determine that the need reported is reasonable for a 20-year 

timeframe.

• Receipt control. The primary objective of the receipt control system will be to ensure that 

completed forms submitted by respondents (or forwarded by states) are logged in promptly and 

given proper chain of custody. A second objective is to provide states with the data needed to 

monitor cumulative receipts by date to identify potential problems with the response rate. Such 

response rate problems could necessitate action. See Section B.2.c.ii for EPA’s method for 

improving the response rate. States that receive data collection instruments from respondents will 

be trained in receipt control.

• Data review by states, EPA Regional Offices, and Navajo Nation. EPA will rely on the states, 

EPA Regional, Offices, and the Navajo Nation to help ensure data quality. Fifteen states will not 

participate in the statistical portion of the 2011 State DWINSA (i.e., collecting data from systems 

serving 3,301 – 100,000 persons). However, all states that have systems serving more than 

100,000 persons will participate in the census portion of the survey. EPA will ask the Association 

of State Drinking Water Administrators (ASDWA) to communicate with the state drinking water 

administrators to encourage their participation. EPA believes that state review is essential in 

ensuring nationally consistent results because the states have more frequent communications with 

systems and possess a better understanding of each particular system’s needs. Therefore, state 

personnel will have the opportunity to review the information on the form, as well as any 

accompanying documentation. When necessary, the states will contact the system to ask for 

clarifying information. 

• Data entry. For data collection instruments submitted in hard copy form, the EPA contractor will 

screen the completed data collection instruments for legibility, completeness, and internal 

consistency, prior to entry into the DWINSA data. Reviewers will also assign comment codes to 

projects to describe any changes made to the data collection instruments. Data from the data 

collection instruments will be keyed into the data only after they have passed the initial screening. 

As data are keyed, an automatic data entry program will provide reasonable bounds checking and 

data verification. The program will signal the data entry operator, if an entry is out of the 

allowable range or is an invalid entry. For data collection instruments submitted electronically, 

the EPA contractor will follow the same review procedures as those submitted in hard copy. 
ICR for 2011 DWINSA 23 December 8, 2010

• Data systems. EPA updated a Web-based data system for the 2007 DWINSA that will be used 

for the 2011 DWINSA. The Web-based system includes a data entry interface that allows the 

Agency and its contractor to input data and allows states, EPA Regions, and the Navajo Nation to 

access, download, verify, and suggest modifications to their data (www.DWNeeds.com). EPA 

will use a commercial “off the shelf” program, Microsoft Access, to manage the information. The 

data system will provide the following functions:

– Data entry through the user interface or batch upload.

– Data verification through bounds checking.

– A password-protected data modification interface.

– Data access for states, EPA Regions, and the Navajo Nation for review and verification 

of their data.

– Predefined summary and statistical reports.

• Cost reasonableness ranges. EPA will develop “cost reasonableness ranges” to help verify the 

accuracy of the data and identify projects for further review.

Public Access to Data

The Agency’s policy is to make the fullest possible disclosure of information without unjustifiable 

expense or unnecessary delay to the requester. Once the final Report to Congress has been submitted, the 

public will be given access to assessment data in accordance with EPA’s policies and procedures for 

Freedom of Information Act (FOIA) requests. However, as a matter of policy, EPA will not disclose the 

identity of any respondent to the 2011 DWINSA. EPA will develop standard report formats for providing 

data to the public. 

A.5.c Small Entity Flexibility 

In designing the 2007 DWINSA methodology, EPA has taken small systems’ relatively limited technical 

capabilities and financial resources into account. EPA’s experience with the previous DWINSAs has 

shown that small systems lack the resources and technical ability to complete the data collection 

instruments. Small CWSs (those serving 3,300 and fewer persons) under state primacy will not be 

included in the 2011 State DWINSA. EPA will use the results from the 2007 DWINSA adjusted to 2011 

dollars. For NPNCWSs, EPA will use the 1999 DWINSA results as the primary basis for the 2011 State 

DWINSA estimates. 

EPA will conduct a census of all American Indian systems serving more than 10,000 (there are no 

Alaskan Native Village systems that serve more than 10,000 persons) and will select a random sample of 

American Indian and Alaskan Native Village systems serving 10,000 and fewer persons. Past experiences 

with the DWINSA has shown that many of these systems cannot complete the data collection instrument. 

Instead of mailing a data collection instrument to the water systems, EPA Regions and the Navajo Nation 

will collect data and complete the data collection instrument for the water systems.

EPA anticipates that almost all of the systems serving 3,300 and fewer (for the 2011 Native American 

DWINSA only) will not be able to provide information on all needs and capital costs. For projects 

without a documented cost, EPA will model a cost. 
ICR for 2011 DWINSA 24 December 8, 2010

A.5.d Collection Schedule 

The current schedule assumed EPA would receive OMB approval for data collection by December

1, 2010. The schedule will be adjusted based on the final approval date. EPA will send data collection 

instruments to drinking water systems as soon as possible after OMB approval. All systems participating 

in the 2011 DWINSA will be asked to complete and return the data collection instruments to their state 

within 1 month of receipt.

To facilitate efficient data entry at EPA Headquarters, EPA will ask the states to submit data for one-third 

of the systems within 3 months after data collection begins. Data for two-thirds of the systems will be due 

within 6 months , and all data will be due on November 2011. Exhibit A-5-1 summarizes the major 

collection milestones.

Exhibit A-5-1 Collection Schedule

Task Date

Information Collection Request Submitted to OMB November 2010

EPA Selects Systems to be Included in State Samples By September 2010

States Submit to EPA Contact Information to be Included on Return 

FedEx Labels 

By December 2010

Training Sessions for States, EPA Regions, and the Navajo Nation October 2010

Mail Out of Data Collection Instruments to Selected Systems or to 

EPA Regions and the Navajo Nation

January 2011

Deadline Given to Systems to Return the Data Collection Instrument to 

States

February 2011

1/3 of Sent Data Collection Instruments Returned by States, EPA 

Regions, and the Navajo Nation to EPA

July 2011

2/3 of Sent Data Collection Instruments Returned by States, EPA 

Regions, and the Navajo Nation to EPA

September 2011

All Sent Data Collection Instruments Returned by States, EPA 

Regions, and the Navajo Nation to EPA

November 2011

No New Projects Will Be Accepted by EPA November 2011

No New Information on Submitted Projects Will Be Accepted by EPA January 2012

All Information in the Data System Finalized February 2012

Report to Congress Due February 2, 2013
ICR for 2011 DWINSA 25 December 8, 2010

A.6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

A.6.a Respondent Burden 

A.6.a.i Burden to Public Water Systems 

The annual water system burden for the 2011 DWINSA is estimated to be approximately 5,931 hours 

(approximately a total of 23,723 hours over the full 4-year project effort). Exhibit A-6-9 shows the 

breakdown of the annual burden hours for CWSs by system size in the 2011 State DWINSA. The basis 

for the burden estimates are detailed below.

2011 State DWINSA – CWSs Serving More Than 50,000 Persons

The respondent burden for the systems serving more than 50,000 persons consists of systems’ burden for 

completing the data collection instrument. EPA estimates that the total unit burden is 10.42 hours per 

system. Exhibit A-6-1 summarizes the unit burden, broken down by activity and labor category. 

• Participate in informational phone call. Each informational call should last about 15 minutes 

(0.25 hours). EPA anticipates that management staff will take the call at half of the systems and 

technical staff will take the call at the other half. Thus, the unit burdens are 0.125 hours for 

management staff and 0.125 hours for technical staff.

• Read cover letter/data collection instructions. EPA made the following assumptions in 

estimating the burden for reviewing the cover letter and data collection instructions: 

– A manager will receive the 2011 DWINSA and read the cover letter. The estimated time 

for managers to review the cover letter is 30 minutes (0.50 hours). 

– Technical staff will read the cover letter and data collection instructions. EPA estimates 

that the burden for this activity is 1 hour per system.

Thus, the total unit burden is 1.5 hours per system [0.50 + 1.0].

• Collect and copy supporting documentation. Time required to review system files, and collect 

and copy supporting documentation will vary greatly. EPA estimates that it will take 1.5 hours at 

30 percent of the systems, 2.5 hours at 30 percent of the systems, 4 hours at 30 percent of the 

systems, and 16 hours at 10 percent of the systems. Thus, the average time per system is as 

follows:

(1.5 x 0.30) + (2.5 x 0.30) + (4 x 0.30) + (16 x 0.10) = 4.0 hrs/system

• Call for technical assistance. Many systems will call states for technical assistance. In 

developing the burden estimate for this activity, EPA made the following assumptions:

– The number of requests for assistance will equal 100 percent of the number of systems. 

(This estimate accounts for the fact that some systems will call more than once, while 

some will not call at all.)

– Each call will be placed by technical staff.
ICR for 2011 DWINSA 26 December 8, 2010

– About 50 percent of the questions will be “straightforward” and require a single phone 

call averaging 15 minutes (0.25 hours).

– About 50 percent of the questions will require the state to perform research and call the 

system back. In this case, EPA estimates that the total burden for the two calls is 26 

minutes (0.43 hours).

Thus, the total unit burden is 20.5 minutes (0.34 hours) per system [(0.50 x 0.25) + (0.50 x 0.43)].

• Complete data collection instrument. EPA estimates that technical staff will take 3 hours to 

complete the project table of the data collection instrument. This estimate is consistent with 

EPA’s experience with the previous DWINSAs. In addition, EPA estimates that 10 percent of the 

systems will have “green” or climate readiness infrastructure projects and will take an additional 

20 minutes (0.33 hours) to provide information on these projects. Management is expected to take 

18 minutes (0.30 hours) to review the completed data collection instrument for accuracy. Clerical 

staff is anticipated to take 1 hour to provide support to the technical and managerial staff. Thus, 

the total unit burden is approximately 4.33 hours per system. 

Exhibit A-6-1 Estimated Unit Burden for Systems Serving More Than 50,000 Persons

Activity

Estimated Burden (hours)

Management Technical Clerical Total

Participate in informational phone call 0.125 0.125 0.25

Read cover letter/data collection 

instructions 0.50 1.00 1.50

Collect and copy supporting documentation 2.00 2.00 4.00

Call for technical assistance 0.34 0.34

Complete data collection instrument 0.30 3.03 1.00 4.33

TOTAL 0.925 6.495 3.00 10.42

2011 State DWINSA – CWSs Serving 3,301 – 50,000 Persons

Exhibit A-6-2 shows the unit burden for 1,936 systems serving 3,301 – 50,000 persons. EPA estimates 

that each of these systems will take a total of 6.81 hours to respond to the 2011 State DWINSA.

• Participate in informational phone call. Each informational call should last about 15 minutes 

(0.25 hour). EPA anticipates that management staff will take the call at half of the systems and 

technical staff will take the call at the other half. Thus, the unit burdens are 0.125 hours for 

management staff and 0.125 hour for technical staff.

• Read cover letter/data collection instructions. EPA used the following assumptions to estimate 

the burden for reviewing the cover letter and data collection instructions:

– A manager will receive the 2011 DWINSA and read the cover letter. The estimated time 

for managers to review the cover letter is 30 minutes (0.50 hours). 
ICR for 2011 DWINSA 27 December 8, 2010

– Technical staff will read the cover letter and data collection instructions. EPA estimates 

that the burden for this activity is 1 hour per system.

Thus, the total unit burden is 1.5 hours per system [(0.50) + (1.0)].

• Collect and copy supporting documentation. The time required to review system files, and 

collect and copy supporting documentation will vary greatly. However, systems serving 3,301 –

50,000 persons typically have less documentation than larger CWSs. Therefore, EPA estimates

that it will take 1.0 hour at 50 percent of the systems, 2.0 hour at 25 percent of the systems, and 

4.0 hours at 25 percent of the systems. Thus, the average time per system is as follows:

(1.0 x 0.5) + (2.0 x 0.25) + (4.0 x 0.25) = 2.0 hrs/system

• Call for technical assistance. Many systems will call EPA or the contractor for technical 

assistance. In developing the burden estimate for this activity, EPA made the following 

assumptions:

– The number of requests for assistance will equal 150 percent of the number of systems. 

(This estimate accounts for the fact that some systems will call more than once.)

– Each call will be placed by technical staff.

– About 50 percent of the questions will be “straightforward” and require a single phone 

call averaging 15 minutes (0.25 hours) in duration.

– About 50 percent of the questions will require the state to perform research and call the 

system back. In this case, EPA estimates that the total burden for the two calls will be 30 

minutes (0.50 hours).

Thus, the total unit burden is 34 minutes (0.56 hours) per system [1.5 x ((0.50 x 0.25) + (0.50 x 

0.50))].

• Complete data collection instrument. EPA estimates that technical staff will take 2 hours to 

complete the data collection instrument. This estimate is consistent with EPA experience with the 

previous DWINSAs. In addition, EPA estimates that 10 percent of the systems will have “green” 

or climate readiness infrastructure projects and will take an additional 20 minutes (0.33 hours) to 

provide information on these projects. Management is expected to take 28 minutes (0.47 hours) to 

review the completed data collection instrument for accuracy. Thus, the total unit burden is 

approximately 2.5 hours per system.
ICR for 2011 DWINSA 28 December 8, 2010

Exhibit A-6-2 Estimated Unit Burden for Systems Serving 3,301 – 50,000 Persons

Activity

Estimated Burden (hours)

Management Technical Clerical Total

Participate in informational phone call 0.125 0.125 0.25

Read cover letter/data collection 

instructions 0.50 1.00 1.50

Collect supporting documentation 1.00 1.00 2.00

Call for technical assistance 0.56 0.56

Complete data collection instrument 0.47 2.03 2.50

TOTAL 1.095 4.715 1.00 6.81

2011 State DWINSA – CWSs serving 3,300 and fewer persons

EPA will adjust the 2007 DWINSA the need for CWSs serving 3,300 and fewer persons to 2011 dollars 

for the 2011 State DWINSA. There will be no burden for these systems. 

2011 Native American DWINSA – American Indian and Alaskan Native Village Water Systems 

To minimize the burden on American Indian and Alaskan Native Village water systems, EPA Regional 

and Navajo Nation personnel will complete the data collection instrument for the water system using the 

information from the IHS SDS and any additional information collected from the respondent. Because the 

EPA Region and the Navajo Nation are collecting the information and completing the data collection 

instrument, the burden imposed on the systems is small. EPA estimates that the unit burden to these 

systems averages 3.25 hours per system. Exhibit A-6-3 summarizes the burden for each activity.

• Participate in an informational telephone call from the EPA Regional Office or the Navajo 

Nation. Respondents will receive a call that describes the purpose of the DWINSA. The 

telephone call should take approximately 15 minutes (0.25 hours). Most American Indian and 

Alaskan Native Village water systems are staffed by one technical person; therefore, the entire 

burden falls with the technical labor category.

• Answer basic questions posed by the EPA Regional Office or the Navajo Nation.

Respondents will be expected to answer very basic questions about the physical design of the 

plant, system configuration, and capital needs. EPA estimates that the burden to assist the EPA 

Regional Office or Navajo Nation is 2 hours for half of the systems selected and 3 hours for the 

remaining systems. Thus, the average burden per system is as follows:

[(2 x 0.5) + (3 x 0.5)] = 2.5 hrs/system

• Collect and copy supporting documentation. Respondents will locate the necessary supporting 

documentation in system files and copy it. It is anticipated that these systems will have little 

onsite documentation and that the EPA Regional or Navajo Nation personnel will develop the 

documentation; therefore, the burden to the system is relatively small. EPA estimates that 25 
ICR for 2011 DWINSA 29 December 8, 2010

percent of the systems will not have any documentation, 50 percent will need 30 minutes (0.50 

hours), and 25 percent will need 1.0 hour. Thus, the average time per system is as follows:

[(0.0 x 0.25) + (0.5 x 0.50) + (1.0 x 0.25)] = 0.5 hrs/system

Exhibit A-6-3 Estimated Unit Burden for American Indian and Alaskan Native Village 

Water Systems

Activity Estimated Burden (hours)

Management Technical Clerical Total

Participate in informational phone call 0.25 0.25

Answer questions posed by EPA Regional 

or Navajo Nation personnel 2.5 2.5

Collect and copy supporting 

documentation 0.5 0.5

TOTAL 0 3.25 0 3.25

A.6.a.ii Burden to Primacy Agencies 

Participating states and the Navajo Nation will play an important role in conducting the DWINSA—they 

will help EPA ensure that the 2011 DWINSA is completed and administered consistently nationwide. 

Note the burden incurred by the EPA Regional Offices for supporting the 2011 Native American 

DWINSA is not discussed in this section; however, they have the same role as the Navajo Nation. EPA 

Regional Offices’ burden is discussed in section A.6.c. Most state/Navajo Nation activities will either 

involve using and reviewing data directly or facilitating EPA’s use and review of data. For example, 

states and the Navajo Nation will review SDWIS inventory information for the statistical sample and 

verify that it is correct. States will help ensure a high response rate by telephoning systems serving more 

than 3,300 persons before the 2011 DWINSA mailout and by making reminder calls to the systems that 

have not returned their data collection instruments by a specified date. States will help ensure data quality 

by answering systems’ questions on the data collection instrument and by reviewing completed data 

collection instruments and accompanying documentation for completeness and accuracy. To minimize the 

burden on American Indian water systems, Navajo Nation personnel will complete the data collection 

instrument for the water system using the information from the IHS SDS and any additional information 

collected from the respondent. 

Given varying time and resource constraints, some states will participate in the 2011 DWINSA more fully 

than others. The burden and cost estimates presented below represent a level of participation that EPA 

believes will ensure nationally consistent results. EPA encourages all states to participate at least at this 

level. The unit burden estimates are consistent with what was found to be true in the 2007 DWINSA. 

The reader should note that the burden will vary widely by state, even for the same set of activities. A 

state’s actual burden depends on the number of drinking water systems in the state, the size and 

sophistication of those systems, the extent to which the state goes beyond the minimum requirements for 

the 2011 DWINSA, and other factors. Exhibit A-6-4 summarizes the burden estimates for each of the 

activity categories.
ICR for 2011 DWINSA 30 December 8, 2010

Exhibit A-6-4 Overall State/Navajo Nation Burden Summary

Activity Category Estimated Burden

Up-Front Activities (States & Navajo Nation) 110 hours, plus 0.2 hours/system

State Burden for Systems Serving More Than 

50,000 Persons

6.58 hours per system

State Burden for Systems Serving 3,301 –

50,000 Persons

6.25 hours per system

Navajo Nation Burden for Systems 7.42 hours per system

Up-Front Burden

This activity category includes the state “fixed burden” for helping EPA prepare for the 2011 DWINSA. 

The total burden for these activities is 110 hours per state/Navajo Nation, plus 0.2 hour per system 

assessed. Exhibit A-6-5 summarizes this burden. 

• Participate in training and other pre-mailout efforts. The burden for this activity is estimated 

at 80 hours per state and the Navajo Nation and is not expected to depend on the number of 

systems.

• Help EPA verify SDWIS data. Based on past experience, EPA estimates that verifying SDWIS 

data for systems in the sample will require approximately 12 minutes (0.2 hours) per system.

• Perform miscellaneous administrative activities. The burden for these activities should be 30 

hours per state and the Navajo Nation.

Exhibit A-6-5 State and Navajo Nation Unit Burden for Up-Front Activities

Activity Estimated Burden

Participate in training and other pre-mailout activities 80 hours/state & Navajo Nation

Help EPA verify SDWIS data 0.2 hours/system

Perform miscellaneous administrative activities 30 hours/state & Navajo Nation

TOTAL 110 hours/state & Navajo Nation, 

plus 0.2 hours/system

State Burden for CWSs Serving More Than 50,000 Persons

This section estimates the state burden for helping EPA conduct the 2011 State DWINSA for systems 

serving more than 50,000 persons by providing technical assistance where needed, calling systems that do 

not return the data collection instrument on time, reviewing the completed data collection instrument and 

documentation, and discussing the results with EPA. Although most of these systems will be able to 

answer the questions on the data collection instrument, states will provide them with clarifying 
ICR for 2011 DWINSA 31 December 8, 2010

information as necessary. The state burden for activities associated with the systems serving more than 

50,000 persons is summarized in Exhibit A-6-6, which follows the activity descriptions.

• Telephone systems to ensure participation. EPA estimates that this preliminary phone call will 

take about 15 minutes (0.25 hours) per system.

• Provide technical assistance. In developing a burden estimate for this analysis, EPA made the 

following assumptions:

– The number of requests for technical assistance will equal 100 percent of the number of 

systems. (This estimate accounts for the fact that some systems will call more than once

while some will not call at all.)

– Of those that do require technical assistance, about 50 percent of their questions will be 

“straightforward,” requiring only 15 minutes (0.25 hours) to answer.

– About 25 percent of their questions will entail limited research and follow-up, requiring 

30 minutes (0.50 hours) to answer, including time to call EPA with questions.

– About 25 percent of their questions will require the state to perform some research and 

will require 1.0 hour to answer.

Therefore, the state burden for providing technical assistance is estimated at about 30 minutes 

(0.50 hours) per request [0.5 x 0.25 + 0.25 x 0.50 + 0.25 x 1.0]. This is an average. Some states 

may choose to provide a much higher or lower level of technical assistance than anticipated by 

EPA.

• Call back systems that do not return the data collection instrument by a certain date. EPA 

assumes that the number of these “reminder” calls will equal 100 percent of the systems. This 

assumes that most (but not all) will need at least one reminder call and a few will need two or 

three. The average time for these calls is 20 minutes (0.33 hours) per system. This does not 

include answering technical questions, which is accounted for above. Rather, it includes locating 

the correct contact person and obtaining a brief report on the status of the 2011 DWINSA

response.

• Review completed data collection instruments and documentation. The data collection 

instrument will be returned directly to the state for review. For some systems, this documentation 

is expected to be quite voluminous and reviewing it will be the most burdensome part of the 2011

DWINSA. The time required for this review is difficult to estimate. States that generate their own 

documentation for the 2011 DWINSA or add projects for distribution or transmission projects are 

required to ensure that the total pipe inventory section on the 2011 DWINSA is completed. Based 

on discussions with the states concerning their level of effort in previous assessments, EPA 

estimates that, on average, states will take 5.0 hours to review each submission. This estimate 

includes the time required to make follow-up phone calls and gather additional information as 

necessary.

• Discuss results with EPA. To estimate the state burden for resolving questions on the completed 

data collection instruments, EPA made the following assumptions:
ICR for 2011 DWINSA 32 December 8, 2010

– EPA will have questions on 50 percent of the completed data collection instruments. 

Some of these questions will actually apply to all systems. 

– Each question will take the state 1 hour to resolve.

Therefore, the burden per system is 0.5 times 1 hour, or 0.5 hours per system [0.50 x 1.0].

Exhibit A-6-6 State Unit Burden for Systems Serving More Than 50,000 Persons

Activity Estimated Burden

(hours per system)

Call to ensure participation 0.25

Provide Technical Assistance 0.50

Call back systems that do not return the data collection instrument by 

a certain date 0.33

Review completed assessment forms and documentation 5.00

Discuss results with EPA 0.50

TOTAL 6.58

State Burden for CWSs Serving 3,301 – 50,000 Persons

This section estimates the state burden for helping EPA conduct the 2011 State DWINSA for systems 

serving 3,301 – 50,000 persons by telephoning systems to ensure participation, calling back systems that 

did not return the data collection instrument on time, reviewing the completed data collection instrument 

and the accompanying documentation, and discussing the results with EPA. The state burden for activities 

associated with systems serving 3,301 – 50,000 persons is summarized in Exhibit A-6-7, which follows 

the activity descriptions.

• Telephone systems to ensure participation. EPA estimates that this preliminary phone call will 

take about 15 minutes (0.25 hours) per system.

• Provide technical assistance. In developing a burden estimate for this analysis, EPA made the 

following assumptions:

– The number of requests for technical assistance will equal 150 percent of the number of 

systems. (This estimate accounts for the fact that some systems make such requests more 

than once.)

– Of those that do require technical assistance, about 50 percent of their questions will be 

“straightforward,” requiring only 15 minutes (0.25 hours) to answer.

– About 25 percent of their questions will entail limited research and follow-up, requiring 

30 minutes (0.50 hours) to answer, including time to call EPA with questions.

– About 25 percent of their questions will require the state to perform some research, and 

will require 1.0 hour to answer.
ICR for 2011 DWINSA 33 December 8, 2010

Therefore, the state burden is estimated at about 45 minutes (0.75 hours) per request.

[1.5 x ((0.5 x 0.25) + (0.25 x 0.50) + (0.25 x 1.0))]

This is an average. Some states may choose to provide a much higher or lower level of technical 

assistance than anticipated by EPA.

• Call back systems that do not return the data collection instrument by a certain date. It is 

assumed that the number of these “reminder” calls will equal 100 percent of the systems. This 

assumes that most (but not all) will need at least one reminder call and some will need two or 

three. The average time for these calls is 30 minutes (0.50 hours) per system. This does not 

include answering technical questions, which is accounted for above. Rather, it includes locating 

the correct contact person and obtaining a brief report on the status of the 2011 DWINSA

response.

• Review completed data collection instruments and documentation. The data collection 

instrument will be returned directly to the state for review. For states, this is the most burdensome 

part of the 2011 DWINSA and the burden for this review is difficult to estimate. States that 

generate their own documentation for the 2011 DWINSA or add projects for distribution or 

transmission projects are required to ensure that the total pipe inventory section on the 2011

DWINSA is completed. For this ICR, EPA assumes that this activity takes states an average of 

4.25 hours per system. 

• Discuss results with EPA. To estimate the state burden for resolving questions on completed 

data collection instruments, EPA made the following assumptions:

– EPA will have questions on 50 percent of the completed data collection instruments. 

Some of these questions will actually apply to all systems.

– Each question will take the state 1 hour to resolve.

Therefore, the burden per system is 0.5 times 1 hour, or 0.50 hours per system. 

Exhibit A-6-7 State Unit Burden for Systems Serving 3,301 – 50,000 Persons

Activity Estimated Burden

(hours per system)

Telephone systems to ensure participation 0.25

Provide Technical Assistance 0.75

Call back systems that do not return the data collection instrument by 

a certain date 0.50

Review completed data collection instruments and documentation 4.25

Discuss results with EPA 0.50

TOTAL 6.25
ICR for 2011 DWINSA 34 December 8, 2010

State Burden for CWSs Serving 3,300 and Fewer Persons

The 2011 State DWINSA will use the 2007 DWINSA need for CWSs serving 3,300 and fewer persons 

adjusted to 2011 dollars. There will be no state burden for these CWSs.

Navajo Nation Burden 

This section estimates the burden for the Navajo Nation to conduct the 2011 Native American DWINSA 

for systems under their primacy. Activities include telephoning systems to ensure participation, gathering 

information about the systems’ 20-year need, completing the data collection instrument for the system, 

and discussing the results with EPA. The Navajo Nation’s burden for activities associated with the water 

systems is summarized in Exhibit A-6-7, which follows the activity descriptions.

• Contact selected water systems. The Navajo Nation will contact selected systems to explain the 

2011 DWINSA and to schedule a time for a longer discussion about the water systems’ 20-year 

need. The telephone call should take approximately 15 minutes (0.25 hours). 

• Gather Information from IHS and water systems. To minimize the burden on American 

Indian water systems, Navajo Nation personnel will complete the data collection instrument for 

selected water systems under their primacy. EPA estimates that the Navajo Nation will use 

information from the IHS SDS, any information they have on file regarding infrastructure 

improvements, and additional information they collect from the water system. EPA estimates that 

the burden to obtain information for half of the systems selected is 2 hours and 10 minutes (0.17 

hours) and 3 hours and 10 minutes (0.17 hours) for the remaining systems. Thus, the average 

burden per system is as follows:

[(2.17 x 0.5) + (3.17 x 0.5)] = 2.67 hrs/system

• Complete the data collection. The Navajo Nation will complete the data collection instrument 

based on the information they collected from IHS and the water system. It is anticipated that these 

systems will have little onsite documentation and that the Navajo Nation personnel will develop 

the documentation of need for the system. EPA estimates the average time per system is 4 hours.

• Discuss results with EPA. To estimate the Navajo Nation burden for resolving questions on 

completed data collection instruments, EPA made the following assumptions:

– EPA will have questions on 50 percent of the completed data collection instruments. 

Some of these questions will actually apply to all systems. 

– Each question will take Navajo Nation 1 hour to resolve.

Therefore, the burden per system is 0.5 times 1 hour, or 0.5 hours per system [0.50 x 1.0].
ICR for 2011 DWINSA 35 December 8, 2010

Exhibit A-6-8 Navajo Nation Unit Burden for Systems

Activity Estimated Burden 

(hours per system)

Participate in informational phone call 0.25

Gather information on projects from IHS 

and water system

2.67

Complete data collection instrument 4

Discuss results with EPA 0.5

TOTAL 7.42

A.6.b Respondent Costs 

A.6.b.i Costs to Public Water Systems 

Exhibit A-6-9 summarizes the burden and costs to water systems. Total costs are estimated at $802,275, 

which consists solely of labor costs. There are no operation and maintenance (O&M) costs or capital costs 

associated with the collection. 

PWS labor costs are based on the number of burden hours multiplied by the average hourly wage rate, 

including overhead. The average hourly wage rate is the rate taken from a 2003 EPA document entitled 

Labor Costs for National Drinking Water Rules. The quoted rate was $26.05 in 2003 dollars for systems 

serving 50,000 and fewer persons and $31.26 in 2003 dollars for systems serving more than 50,000 

persons. This rate has been inflated to 2009 dollars using the Employment Cost Index. The inflated rate is 

$31.30 for systems serving 50,000 and fewer persons and $37.56 for systems serving more than 50,000 

persons. 

Exhibit A-6-9 Total Burden and Cost to Water Systems

Respondent

Unit Burden (hours) Total

Responses

Total 

Hours

Hourly 

Rate

Total 

Management Technical Clerical Cost

Systems Serving 

More Than 

50,000 Persons

0.925 6.495 3.00 916 9,544 $37.56 $358,473

Systems Serving 

3,301 – 50,000 

Persons

1.095 4.715 1.00 1,936 13,184 $31.30 $412,659

American Indian 

and Alaskan

Native Village

Water Systems 

0 3.25 0 306 995 $31.30 $31,144

TOTAL 2.02 14.46 4.00 3,158 23,723 $802,275

Note: The average burden per response is 7.51 hours (23,723/3,158). 

Numbers may not add due to rounding.
ICR for 2011 DWINSA 36 December 8, 2010

A.6.b.ii Cost to States and the Navajo Nation

Exhibit A-6-10 shows the annual costs to states and the Navajo Nation. The cost burden for EPA 

Regional Offices is discussed in section A.6.c. As previously discussed, all states and the Navajo Nation 

have committed to help EPA administer the 2011 DWINSA with at least the minimum of activities; 

specifically, the states and Navajo Nation will assist in surveying 2,892 systems. Based on EPA’s 

projection that all states and the Navajo Nation will participate in the DWINSA, the cost to states and the 

Navajo Nation is $1,045,250. The labor costs are based on an average full time equivalent (FTE) cost of 

$86,029 including overhead, which equates to approximately $41.36 per hour.6

There are no O&M or capital costs for states or the Navajo Nation under this ICR.

This rate, which has been 

inflated to year 2009 dollars, is based on the rate used in the 2007 DWINSA and is consistent with the 

rates used in ICRs recently developed by the Agency.

Exhibit A-6-10 Total Burden and Cost to States

Activity

Number of 

States/

Systems

Unit Burden

Total

Burden

(hours)

Hourly 

Rate Total Cost

Up-front

577

110 

hours/state & 

Navajo Nation

6,270 $41.36 $259,327

2,8928 0.20 

hours/system 578 $41.36 $23,906

State burden for systems serving 

more than 50,000 persons

assessment

916 6.58 

hours/system 6,027 $41.36 $249,277

State burden for systems serving 

3,301 – 50,000 persons assessment 1,936 6.25 hours/system 12,100 $41.36 $500,456

Navajo Nation burden for systems 40 7.42 

hours/system 297 $41.36 $12,284

TOTAL 25,272 $1,045,250

 

6 According to the ICR Handbook, an employee is paid an average of 2,080 hours in 1 year.

7 Fifty-seven includes the 50 states plus the District of Columbia, Puerto Rico, Northern Mariana Islands, American 

Samoa, Guam, the U.S. Virgin Islands, and the Navajo Nation. 

8 The total number of systems in the 2011 DWINSA is 3,158 systems. The number of systems shown is the number 

of total systems selected for the 2011 DWINSA minus the American Indian and Alaskan Native Village systems 

supported by the EPA Regional offices; the burden for these systems is addressed in the Agency burden section in 

A.6.c. The number, however, includes the 40 American Indian water systems to be surveyed by the Navajo Nation 

primacy agency.
ICR for 2011 DWINSA 37 December 8, 2010

A.6.c Agency Burden and Cost 

The Agency burden and cost reflects the burden and cost directly incurred by EPA Headquarters, EPA 

Regions, and IHS, and is summarized in Exhibit A-6-11. EPA will also bear the cost of contractor 

activities as detailed in Exhibit A-6-11. Both exhibits distribute burden/costs among Fiscal Years 2010, 

2011, 2012, and 2013, reflecting that Agency and contractor activities will vary substantially over the 4-

year period.

EPA made the following assumptions in developing its estimate of Agency and contractor burden and 

cost9

EPA Headquarters

:

• Over the 4-year period, EPA Headquarters will expend a total of 2.8 FTEs (e.g., an average of 0.7 

FTEs per year over the 4 years). Assuming 2,080 hours per year, this equates to 5,824 hours.

• The average salary and benefits (i.e., personnel compensation and benefits [PC&B]) of the FTEs 

is at the GS 13, Step 5 level of $157,629. Assuming 2,080 hours per year, this equates to $75.78

per hour.

EPA Regional Offices

• Over the 4-year period, EPA Regions will expend a total of 1.4 FTEs (i.e., an average of 0.35 

FTE per year) providing support to the 2011 State DWINSA. Assuming 2,080 hours per year, this 

equates to 2,912 hours.

• Over the 4-year period, EPA Regions will expend a total of 1.5 FTEs (i.e., an average of 0.38

FTE per year) providing support to the 2011 Native American DWINSA. Assuming 2,080 hours 

per year, this equates to 3,127 hours.

• The average salary and benefits (i.e., PC&B) of the 2.8 FTEs is at the GS 11, Step 5 level of 

$112,524. Assuming 2,080 hours per year, this equates to $54.10 per hour.

Indian Health Service

• Over the 4-year period, IHS Headquarters will expend a total of 0.1 FTEs (e.g., an average of 

0.03 FTEs per year over the 4 years). Assuming 2,080 hours per year, this equates to 208 hours.

• The average salary and benefits (i.e., PC&B) of the FTEs is at the GS 13, Step 5 level of 

$157,629. Assuming 2,080 hours per year, this equates to $75.78 per hour.

EPA Contractor(s)

• Over the 4-year period, the EPA contractor(s) will expend a total of 36,510 hours of direct labor.

 

9 Hourly rates are from U. S. Office of Personnel Management, 2010 General Schedule (GS) Locality Pay Tables

(http://opm.gov/flsa/oca/10tables/indexGS.asp) and overhead rates are from Information Collection Request for 

Public Water Supply Program, December 20, 1993.
ICR for 2011 DWINSA 38 December 8, 2010

• The EPA contractor(s) will provide this professional labor at a total hourly rate, including all 

applicable indirect costs, of $78.06.

Based on these assumptions, EPA estimates that the total burden/cost to EPA and IHS for the DWINSA 

over the 4-year period is 48,581 hours and $3,633,788. Over the 3-year ICR, the average annual hours 

would be 16,194 hours per year and $1,211,263 per year. Exhibits A-6-11 and A-6-12, however, provide 

greater detail on the estimated yearly expenditures for the actual 4-year effort

Exhibit A-6-11 Burden/Cost to EPA (Excluding Contractor Activities) and IHS

Fiscal 

Year

EPA Headquarters EPA Regions IHS Total

Hours Cost Hours Cost Hours Cost Total 

Hours

Total 

Cost

FY 2010 892 $67,596 1,599 $86,506 60 $4,547 2,551 $158,649

FY 2011 2,020 $153,076 2,490 $134,709 64 $4,850 4,574 $292,635

FY 2012 2,020 $153,076 1,504 $81,366 64 $4,850 3,588 $239,292

FY 2013 892 $67,596 446 $24,129 20 $1,516 1,358 $93,241

TOTAL 5,824 $441,344 6,039 $326,710 208 $15,763 12,071 $783,817
ICR for 2011 DWINSA 39 December 8, 2010

Exhibit A-6-12 Burden/Cost of Contractor Activities

Activities

FY 10 FY 11 FY 12 FY 13 Total

Hours Cost Hours Cost Hours Cost Hours Cost Hours Cost

Planning 5,100 $398,106 2,000 $156,120 1,500 $117,090 300 $23,418 8,900 $694,734

Survey Design 200 $15,612 0 $0 0 $0 0 $0 200 $15,612

Peer Review 140 $10,928 0 $0 0 $0 0 $0 140 $10,928

Modeling 0 $0 282 $22,013 1,994 $155,652 960 $74,938 3,236 $252,602

Data Development 300 $23,418 800 $62,448 300 $23,418 300 $23,418 1,700 $132,702

Survey Production 500 $39,030 945 $73,767 0 $0 0 $0 1,445 $112,797

Data Analysis 0 $0 11,729 $915,566 2,533 $197,726 0 $0 14,262 $1,113,292

Report Writing 0 $0 208 $16,236 1,459 $113,890 700 $54,642 2,367 $184,768

Statistical Analysis 0 $0 94 $7,338 656 $51,207 750 $58,545 1,500 $117,090

Tech Assistance 0 $0 960 $74,938 200 $15,612 200 $15,612 1,360 $106,162

Training 500 $39,030 900 $70,254 0 $0 0 $0 1,400 $109,284

Total 6,740 $526,124 17,918 $1,398,679 8,642 $674,595 3,210 $250,573 36,510 $2,849,971
ICR for 2011 DWINSA 40 December 8, 2010

A.6.d Estimating Respondent Universe and Total Burden and Costs

Respondents for this ICR include CWSs, NPNCWSs (in the 2011 Native American DWINSA), states, 

and the Navajo Nation. This ICR estimates that the number of CWS and NPNCWSs respondents is 3,158. 

In addition to the CWS and NPNCWSs respondents, this ICR assumes 56 states (50 states plus the 

District of Columbia and the U.S. Territories) and the Navajo Nation. Therefore, the total number of 

respondents is 3,215. The total costs and burden for these respondents are detailed in Exhibits A-6-13 and 

A-6-14.

A.6.e Bottom Line Burden Hours and Costs 

Exhibit A-6-13 summarizes the bottom line burden hours and costs for CWSs, NPNCWSs, states, and the 

Navajo Nation for this collection. The total burden is 48,995 hours at a cost of $1,847,525.

Exhibit A-6-13 Bottom Line Respondent Burden 

Respondent Type Burden Hours Total Cost

Water Systems 23,723 $802,275

States and Navajo Nation 25,272 $1,045,250

TOTAL 48,995 $1,847,525

Over the 3-year ICR, the average annual burden would be 16,332 hours and the average annual cost 

would be $615,842 per year. However, Exhibit A-6-14 summarizes more specifically the estimated 

burden hours and costs for CWSs, NPNCWSs, states, and the Navajo Nation for each year of the 4-year 

survey. It is estimated that the CWSs and NPNCWSs will complete the data collection instrument in 

2011. It is estimated that states and the Navajo Nation will conduct the Up-Front Activities in 2010 and 

the Data Collection Activities in 2011. 

Exhibit A-6-14 Burden Hours and Costs for Respondents per Year

Respondent 

Type

Total Hour Burden (per year) Total Cost (per year)

2010 2011 2012 2013 2010 2011 2012 2013

Water 

systems

0 23,723 0 0 $0 $802,275 $0 $0 

States and the 

Navajo 

Nation

6,848 18,424 0 0 $283,233 $762,017 0 $0 

TOTAL 6,848 42,147 0 0 $283,233 $1,564,292 0 $0 

Average per 

Respondent

2.13 13.11 0 0 $88 $487 0 $0 
ICR for 2011 DWINSA 41 December 8, 2010

Exhibit A-6-15 summarizes the bottom line burden hours and costs for EPA for this collection. The total 

burden for EPA (including EPA Regional Offices), IHS, and EPA’s contractor is 48,581 hours at a cost of 

$3,633,788.

Exhibit A-6-15 Bottom Line Burden Hours and Costs for EPA (including EPA’s 

contractor) and IHS

Respondent Type Burden Hours Total Costs

EPA 11,863 $768,054

IHS 208 $15,763

Contractor 36,510 $2,849,971

TOTAL 48,581 $3,633,788

Exhibit A-6-16 shows the bottom line hour and dollar burden estimate by the Information Collection (IC) 

Entities. IC Entities covered by this ICR include publicly-owned CWSs, privately/investor owned CWSs, 

state owned CWSs, tribal owned CWSs and NPNCWSs, state government agencies and tribal authorities 

(the Navajo Nation). 
ICR for 2011 DWINSA 42 December 8, 2010

Exhibit A-6-16 Disaggregated Burden by Affected Information Collection (IC) Entities

Total Number Of 

IC Entities

Burden Per 

Response

Total Hour 

Burden

Hourly 

Rate Total Cost Cost Per Response

Water Systems Respondents 

Serving More 

than 50,000 

Persons

Publicly Owned CWSs 773

10.42

8,054

$37.56

$ 302,508

$391 

Private/Investor Owned CWSs 105 1,094 $ 41,091

State Owned CWSs 38 396 $ 14,874 

Tribal Owned CWSs & NPNCWSs - - $ -

Subtotal 916 9,544 $ 358,473

Serving 3,301 

to 50,000 

Persons

Publicly Owned CWSs 1,736

6.81

11,822

$31.30

$ 370,029

Private/Investor Owned CWSs 173 1,178 $ 36,871 $213

State Owned CWSs 27 184 $ 5,759 

Tribal Owned CWSs & NPNCWSs 75 3.25 244 $ 7,637 $102

Subtotal 2,011 Avg. 6.68 13,428 $ 420,296 Avg. $209

Serving 3,300 

and Fewer 

Persons

Publicly Owned CWSs -

3.25

-

$31.30

$ -

$102 

Private/Investor Owned CWSs - - $ -

State Owned CWSs - - $ -

Tribal Owned CWSs & NPNCWSs 231 751 $ 23,506

Subtotal 231 751 $ 23,506

Total Water System Respondents

Publicly Owned CWSs 2,509 7.92 19,876 $ 672,537 $ 268

Private/Investor Owned CWSs 278 8.17 2,272 $ 77,962 $ 280

State Owned CWSs 65 8.92 580 $ 20,633 $ 317

Tribal Owned CWSs & NPNCWSs 306 3.25 995 $ 31,144 $ 102 

Subtotal 3,158 7.51 23,723 $ 802,275 $ 254
ICR for 2011 DWINSA 43 December 8, 2010

Total Number Of 

IC Entities

Burden Per 

Response

Total Hour 

Burden

Hourly 

Rate Total Cost Cost Per Response

Total State Government Respondents 56 443.88 24,857

$ 41.36

$1,028,086 $ 18,359

Total Tribal Authority Respondents 1 415.00 415 $ 17,164 $ 17,164

Total Respondents 3,215 15.24 48,995 $ 1,847,525 $ 575

Note: Numbers may not total due to rounding. 
ICR for 2011 DWINSA 44 December 8, 2010

A.6.f Reasons for Change in Burden 

This ICR does not modify an existing ICR. However, it should be noted that an ICR was prepared for the 

previous survey effort done in 2007, which is outside of the 3-year window for modifying an existing ICR 

for a new effort and requires a comparison of burden of the proposed new effort to the estimates of the 

previous effort’s ICR.

The estimated total public reporting burden over the 4-year length of the 2007 DWINSA was 46,029 

hours with an estimated average of 14.42 hours per survey. These estimates are smaller than the estimates 

described below for the 2011 DWINSA. The increase in burden for the 2011 Survey are attributed to: 1) a 

very slight increase due to the “green” and “climate readiness” infrastructure project questions (on 

average estimated to be 2 minutes per survey respondent) new to the 2011 effort; EPA assuming a 100% 

response rate rather than the assumption of only 90% used in the 2007 Survey ICR; and 3) the addition of 

the Navajo Nation as a respondent with a burden equivalent to that of a state primacy agency.

A.6.g Burden Statement 

The public reporting burden for collections included in this ICR is detailed above. The total public 

reporting burden over the 4-year length of the 2011 DWINSA is estimated to be 48,995 hours, of which 

23,723 hours are attributable to water systems and 25,272 hours to states and the Navajo Nation. These 

estimates include time for gathering information as well as developing and maintaining records. Public 

reporting burden for this collection of information is estimated to average 15.24 hours per response.10

Respondent burden for the water system is 7.51 hours.11

Burden means the total time, effort, or financial resources expended by people to generate, maintain, 

retain, disclose, or provide information to or for a Federal agency. This includes the time needed to 

review instructions, adjust the existing ways to comply with any previously applicable instructions and 

requirements, train personnel to respond to the information collection request, 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 request for information 

collection 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.

Please send comments on the Agency’s need for this information, accuracy of the burden estimates, and 

any suggested methods for minimizing respondent burden, including the use of automated collection 

techniques to Director, Office of Environmental Information, Collection Strategies Division, U.S. 

Environmental Protection Agency (2822T), Ariel Rios Building, 1200 Pennsylvania Ave., N.W., 

Washington, D.C. 20460; and to the Office of Information and Regulatory Affairs, Office of Management 

and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please 

include the EPA ICR number and OMB control number in any correspondence.

 

10 For this ICR, the number of responses is calculated at 3,215 (916 systems serving more than 50,000 people, 2,011

systems serving 3,301 – 50,000 people, 231 serving 3,300 and fewer people, 1 tribal authority, and 56 states and 

U.S. Territories). The burden per response is calculated as the total respondent burden (48,995) divided by the 

number of responses (3,215).

11 See Exhibit A-6-9.
ICR for 2011 DWINSA 45 December 8, 2010

PART B OF THE SUPPORTING STATEMENT (FOR STATISTICAL 

SURVEYS)

INTRODUCTION TO PART B

The Environmental Protection Agency (EPA) proposes to conduct the following type of 

statistical survey for the 2011 State Drinking Water Infrastructure Needs Survey and 

Assessment (DWINSA). EPA proposes a mail assessment of community water systems 

(CWSs) serving populations of more than 3,300. EPA is proposing the same methodology for 

collecting data for CWSs serving more than 3,300 persons as was used in the 2007 DWINSA. 

No revision to that methodology has taken place. Due to budgetary constraints, EPA is not 

currently proposing to collect additional data from CWSs serving 3,300 and fewer. For the 

2011 Native American DWINSA, EPA proposes a national sample for American Indian 

systems and a separate sample for Alaskan Native Village water systems. EPA also proposes 

EPA Regions and the Navajo Nation collect the information for these systems. 
ICR for 2011 DWINSA 46 December 8, 2010

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ICR for 2011 DWINSA 47 December 8, 2010

2011 STATE DWINSA

B.1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES

B.1.a Survey Objectives 

The primary objective of the 2011 DWINSA is to collect information from water systems on the 

infrastructure they need to continue to provide safe drinking water to consumers. These data are used to 

produce a national estimate as well as state, Navajo Nation, or EPA Regional specific estimates of water 

systems’ 20-year need. EPA has established policies to ensure that the overarching goals of the survey are 

met:

• Estimate the total national 20-year need. 

• Estimate the total 20-year need for each participating state/Navajo Nation/EPA Region. 

• Provide complete and accurate data to Congress. 

• Provide a tool to fairly distribute DWSRF capitalization funds to states and the Tribal Set-Aside 

(TSA) Program. 

• Maintain the credibility of the DWINSA findings. 

EPA proposes to collect information on the cost of systems’ infrastructure needs. If cost data are not 

available from systems, EPA proposes to collect information that will enable the Agency to model costs. 

In the data collection instrument, the respondent will identify needs on a project-by-project basis and list 

the “type(s) of need” that the project will meet. The “types of need” include raw water source, 

transmission, source water treatment, storage, distribution, pumping stations, and other needs. EPA will 

also collect information on “green” and climate readiness infrastructure projects.

EPA will use the information from the DWINSA to project capital investment requirements of drinking 

water systems. The information will be used to allot DWSRF monies among states and as part of an 

allotment formula for the DWSRF TSA Program. 

EPA is proposing the same methodology as used in previous DWINSAs. No significant changes were 

made for the 2011 State DWINSA from the approach used in 2007. The sampling design will be 

discussed in detail below. The sampling design for the 2011 Native American DWINSA is discussed in a 

separate section below. 

B.1.b Key Variables 

Several key variables are available from the Safe Drinking Water Information System (SDWIS). To 

ensure accuracy, the 2011 DWINSA will verify these data by asking respondents to confirm existing 

information (pre-printed on the data collection instrument), or correct it. These variables include 

population served, total design capacity, number of service connections, primary source of supply, 

ownership type (private or public), and whether the system purchases water from, or sells water to, 

another public water system (PWS). 
ICR for 2011 DWINSA 48 December 8, 2010

Information on capital needs will be collected from respondents on a project-by-project basis. For each 

project, respondents will be asked to provide the following types of information: type of need; reason for 

need; documentation of need and cost (if necessary); if the project is a new project or to replace, 

rehabilitate or expand existing infrastructure; if the project is needed now to protect public health or if it is 

needed over the next 20 years to continue to provide safe drinking water; the federal regulation or state 

requirement if the project is to meet a current regulation, state requirement, or is for “green” or climate 

readiness; design capacity of source, storage, and treatment projects; length and diameter of pipe projects; 

diameter for projects such as water meters; cost of the project; and date of the cost estimate. For most of 

these variables, respondents will choose the appropriate “documentation,” “type of need,” “reason for 

need” or “regulation or requirement” from a Lists of Codes. EPA will also collect information on “green” 

and climate readiness infrastructure projects. For each project, the respondent will identify if it is 

considered a “green” project or if it is a climate readiness infrastructure project by selecting a code from 

List 3 in the Lists of Codes. In addition, the data collection instrument includes additional questions for 

systems that include climate readiness projects in their data collection instrument. 

The principal variable of interest is total projected capital needed for each water system in the 2011

DWINSA for the time period 2011 – 2030. The total capital need for all systems in each state/Navajo 

Nation/EPA Region (to be derived from the statistical sample of systems) is the key variable that 

decision-makers at EPA use to allocate funds to states and the TSA Program based on need.

The method of data collection has been designed to minimize burden on respondents while ensuring that 

information is collected in a consistent manner. Collecting information on a project-by-project basis, for 

example, will be particularly helpful in reducing burden since most respondents develop Capital 

Improvement Plans (CIPs) on a project-by-project basis. 

Information on type of need will be used to disaggregate total capital needs for EPA’s Report to 

Congress. Information on the reason for need will be used to verify the public health benefit of the need. 

Information on the date of the cost estimate will be used to provide a consistent basis for cost estimates 

across systems. Information on a regulation or requirement will be used to determine the reported project 

costs related to Federal regulations, state requirements, and/or identify if the project is “green” or for a 

climate readiness need. 

If a system cannot provide cost estimates, additional data are necessary so that the Agency can impute 

costs. Each of these variables will be described in greater detail later in this document.

B.1.c Statistical Approach 

The 2011 State DWINSA is being designed to achieve a desired level of precision for state-level 

estimates of total capital needs for systems serving more than 3,300 persons. EPA proposes a survey of a 

statistical sample to estimate total capital needs. This statistical approach minimizes burden while 

achieving the desired level of precision. 

The 2011 State DWINSA design divides CWSs serving populations of more than 3,300 into two groups: 

CWSs serving populations of more than 100,000, and systems serving populations of 3,301 – 100,000. 

EPA proposes to sample with certainty systems serving more than 100,000 persons. These systems have 

the largest capital needs and they have the staff to respond efficiently to the 2011 State DWINSA. EPA 

proposes to draw a random sample of systems serving 3,301 – 100,000 persons. This methodology can 

reduce burden and still achieve the DWINSA data quality objectives. To meet the state-level precision 
ICR for 2011 DWINSA 49 December 8, 2010

targets, EPA will first determine the total sample size for each state to meet the target level of precision. 

EPA will then allocate the sample to strata in order to maximize the efficiency of their design. 

EPA is designing and conducting the 2011 DWINSA with the assistance of a contractor:

Contractor

The Cadmus Group, Inc.

57 Water Street

Watertown, MA 02472

(617) 673-7000

Contractor Roles

- Technical oversight for all contractor activities

- Oversight of data collection instrument design 

and testing.

- Oversight of statistical sample design

- Training

- Mailings; logistics

- Technical support for respondents and states

- Model development

- Data processing

- Statistical sample design

B.1.d Feasibility 

The 2011 DWINSA data collection instrument has been designed with the capabilities of the typical 

respondent in mind. To fully assess feasibility, the Agency undertook the following steps. EPA convened 

a workgroup (see Section A.5.b) to comment on the proposed data collection and its feasibility. The data 

collection instrument to be used for the 2011 DWINSA is generally the same form as used for the past 

DWINSA. For those assessments, EPA met with individual CWS operators and discussed the proposed 

survey. System operators were asked to comment on all proposed data elements and the feasibility of 

collecting information by a mail survey. The Agency recognizes that most systems serving fewer than 

50,000 persons and some that serve 50,000 or more may not have cost data or documentation of costs for 

some projects. In those cases, the 2011 DWINSA data collection instrument requests other readilyavailable information that EPA can use to model costs. EPA will make it very clear to respondents that 

they are not expected to develop cost estimates for the purposes of the 2011 DWINSA. In addition, EPA 

(or states) will provide systems with a helpline to assist them in completing the data collection instrument.

EPA has developed cost models for most of the infrastructure needs included in the 2011 DWINSA based 

on the size and capacity of a project. These cost models were developed during the 2007 DWINSA and 

will be used again for the 2011 DWINSA. New cost models may be developed for weak cost models, 

influential cost models, and new technology.

The time frame for the 2011 DWINSA is acceptable to the users of data within the Office of Ground 

Water and Drinking Water (OGWDW) and sufficient to complete a report to Congress by its anticipated 

due date of early 2013. The schedule also is acceptable to other users of the data. 

B.2 SURVEY DESIGN

This section contains a detailed description of the statistical survey design including a description of the 

sampling frame, sample identification, precision requirements, data collection instrument, pre-test, 

collection methods, and follow-up procedures.
ICR for 2011 DWINSA 50 December 8, 2010

The sample design for the 2011 State DWINSA is stratified random sampling within each state. In cases 

where the state is not participating in the data collection for systems serving 3,301 – 100,000 persons,

EPA will only be able to provide state specific results for systems serving more than 100,000 persons and 

systems serving 3,300 and fewer persons (using the results from the 2007 DWINSA). EPA will include 

an overall national result for the systems serving 3,301 – 100,000 persons using the average need by strata 

of the systems in states that are participating in the full 2011 State DWINSA. 

Stratification increases the precision of estimates compared with a simple random sample of the target 

population of systems. In stratified samples, the target population is divided into non-overlapping groups, 

known as strata, from which separate samples are drawn. The goal of stratified sampling is to choose 

sample sizes within each stratum in a manner designed to obtain maximum precision in the overall 

estimate for the population. Stratification variables for this study include: population size (populations of:

3,301 – 10,000; 10,001 – 25,000; 25,001 – 50,000; 50,001 – 100,000; and populations of more than 

100,000), and primary sources of supply (surface and ground). Systems serving more than 100,000 

persons are selected with certainty. The size of each state’s sample of systems serving populations of 

3,301 – 100,000 is set to meet the 2011 DWINSA’s data quality objectives. 

EPA’s precision target for the 2011 State DWINSA is to be 95 percent confident that the true need lies 

within an interval, the upper and lower bounds of which do not exceed 10 percent of the sample mean (or 

estimated need). Once the total size of the sample of systems serving more than 3,300 persons has been 

determined for each state, the number of samples to be taken in each stratum within each state will be 

allocated in a manner that minimizes the variance of the estimated total capital costs. EPA will use a 

Neyman allocation to determine the number of systems to select from each stratum. The Neyman 

allocation is described in detail in Section B.2.b.ii.

B.2.a Target Population and Coverage 

The target population for the 2011 State DWINSA is the number of CWSs in the nation. A CWS is a 

PWS that serves at least 15 service connections used by year-round residents or regularly serves at least 

25 year-round residents (40 CFR 141.2). The 2011 State DWINSA is designed to produce estimates of 

the capital need of systems serving more than 3,300 persons for each participating state. In nonparticipating states, EPA will be able to provide state specific results for systems serving 100,000 or more 

persons. EPA will include an overall national result for the systems serving 3,301 – 100,000 persons

using the average need by strata of the systems in participating states and the total number of systems by 

strata in the non-participating state. The 2011 State DWINSA is designed to produce estimates of the 

capital need of systems serving 3,300 and fewer persons for the nation as a whole using the results of the 

2007 DWINSA. 

B.2.b Sample Design 

This section describes the sample design. It includes a description of the sampling frame, target sample 

size, stratification variables, and sampling method. The sampling design employed is a stratified random 

sample of CWSs. The strata employed in the design are discussed in Section B.2.b.iii. Neyman allocation 

is used to efficiently allocate the sample of water systems among the strata.
ICR for 2011 DWINSA 51 December 8, 2010

B.2.b.i Sampling Frame 

The sampling frame is developed from SDWIS. SDWIS is a centralized database for information on 

PWSs, including their compliance with monitoring requirements, maximum contaminant levels (MCLs), 

and other requirements of the Safe Drinking Water Act (SDWA) Amendments of 1996. The following 

information will be extracted from SDWIS for the statistical survey and verified by participating states:

• Name of system

• Contact person

• Address of system

• Population served

• Total design capacity

• Number of connections 

• Primary source (surface water or ground water)

• PWS identification number (PWSID)

• Ownership type 

• Consecutive system (i.e., does system purchase or sell water)

From these data, EPA will develop the frame from which EPA will (1) calculate summary statistics (e.g., 

number of systems per state in pre-defined strata) for use in calculating sample size, and (2) randomly 

choose systems within the design strata to take part in the 2011 DWINSA.

Justification for the Use of SDWIS

The following criteria are often used in assessing a proposed sampling frame:

• It fully covers the target population.

• It contains no duplication.

• It contains no foreign elements (i.e., elements that are not members of the population).

• It contains information for identifying and contacting the units selected in the sample.

• It contains other information that will improve the efficiency of the sample design.

The units of observation for this survey are CWSs, a subset of PWSs. SDWIS is the ideal choice for a 

sample frame because of its inclusive coverage of all units of observation for the 2011 DWINSA. In 

addition, SDWIS has two other advantages: it contains information that will facilitate contacting the 

respondents, and it contains other information that is useful in stratifying the sample, thereby improving 

the efficiency of the sample design.

In previous surveys where SDWIS was used as a sample frame, there have been criticisms of its utility. 

Since 1989, EPA has conducted audits of the quality of SDWIS data. As a result, EPA is aware of the 

problems with SDWIS. The audits, however, show that errors in classification of systems by strata 

proposed for the 2011 DWINSA are rare. The audits show that systems are misclassified by population or 

source in less than 1 percent of all cases. 

To mitigate any potential problems with the sample frame, the 2011 DWINSA design anticipates 

substantial state/Navajo Nation/EPA Region involvement in the 2011 DWINSA process. They, for 

example, will be checking the sample frame of systems that will be used to determine the final sample. In 

EPA’s experience, they often have in-house data systems with very accurate data. Even if these data are 
ICR for 2011 DWINSA 52 December 8, 2010

not transmitted to SDWIS, they are available and can be used by states/Navajo Nation/EPA Regions to 

check the sample frame. 

B.2.b.ii Sample Size 

Exhibit B-2-1 at the end of this subsection shows the preliminary sample sizes for the 2011 State 

DWINSA. As shown on this exhibit, the sampling design will be implemented to achieve state-level 

precision targets for CWSs serving more than 3,300 persons. Precision targets are discussed in Section 

B.2.c. 

The task of determining the sample size for each stratum requires two steps. The first step determines the 

sample size for each state that achieves the precision targets for that state. The second step allocates the 

sample across the relevant strata in the state. The strata are described in section B.2.b.iii. 

The first step in determining the sample size is calculating the total number of samples required at the 

state level to meet the precision requirements. The sample size is given by:

g

H

h

gh gh

g V

N s

n

2

1

0





 





=

∑=

Where: n0g = the sample size (prior to the finite population correction)

Ngh = the total number of systems in the hth stratum in the gth state (taken from SDWIS)

sgh = the standard deviation of the variable of interest for the hth stratum in the gth state

(estimated using data from the 2007 DWINSA) 

H = the number of strata defined in the sample design for the gth state 

Vg = the desired sampling variance for the total system (those serving more than 3,300 persons) 

capital needs estimate for state g.

The desired error in the sample is expressed as a relative error. In the above equation, Vg = (d/Zα * Yg

ˆ )

2

. 

Yg

ˆ is an estimate of the total capital needs for a given state. Yg

ˆ is computed for each state by calculating 

the mean total capital needs for stratum h (from the 2007 DWINSA) and multiplying by the actual 

number of systems in each stratum for that state (Ngh). Summing across strata provides an estimate of Yg

ˆ . 

d is the half-width of the desired confidence interval (0.10 for the Assessment). Zα is the value of a 

standard normal distribution for a confidence level of 1- α, (1.96 for the Assessment). 
ICR for 2011 DWINSA 53 December 8, 2010

Because the number of water systems is known and finite, the following population correction is applied:

∑=

+

= H

h

gh gh

g

g

g

N s

V

n

n

1

2

0

1 1

The second step allocates the total sample to each of the strata. EPA will randomly draw this number of 

samples from each of these strata. The Neyman allocation formula is used for the allocation:12

























=

∑=

H

h

gh gh

gh gh

gh g

N s

N s

n n

1

(Because systems serving populations more than 100,000 are to be sampled with certainty, H is reduced 

by the number of system serving more than 100,000 strata in the sample design.)

In order to implement these sample size and sample allocation equations, EPA needs estimates for Vg, 

Ngh, sgh, and mean total capital needs by stratum. Information on mean total capital needs by stratum and 

sgh were estimated using data from the 2007 DWINSA.

 

12 J. Neyman, “On the Two Different Aspects of the Representative Method: The Method of Stratified Sampling and 

the Method of Purposive Selection,” Journal of the Royal Statistical Society, Vol. 97 (1934), pp. 558-606; as cited in 

William G. Cochran, Sampling Techniques (New York: John Wiley & Sons), 1977. 
ICR for 2011 DWINSA 54 December 8, 2010

Exhibit B-2-1 State Sample Sizes

State

Total Number Of Systems 

Serving More Than 3,300 

Persons 

Estimated Sample Size 

For Systems Serving 

More Than 3,300 Persons

Alaska * 19 1

Alabama 348 131

Arkansas 181 83

American Samoa 1 1

Arizona 130 39

California 688 169

Colorado 169 61

Connecticut 57 36

District of Columbia 1 1

Delaware * 30 3

Florida 387 128

Georgia 237 66

Guam 3 3

Hawaii * 30 2

Iowa 138 53

Idaho * 50 1

Illinois 460 98

Indiana 214 82

Kansas 117 65

Kentucky 259 141

Louisiana 231 65

Massachusetts 253 73

Maryland 59 26

Maine 35 25

Michigan 303 63

Minnesota 181 91

Missouri 216 121

Northern Mariana Islands 2 2

Mississippi 202 105

Montana * 35 1
ICR for 2011 DWINSA 55 December 8, 2010

State

Total Number Of Systems 

Serving More Than 3,300 

Persons 

Estimated Sample Size 

For Systems Serving 

More Than 3,300 Persons

North Carolina 274 80

North Dakota * 32 -

Nebraska * 43 2

New Hampshire * 39 1

New Jersey 242 61

New Mexico * 60 1

Nevada 35 15

New York 362 50

Ohio 320 90

Oklahoma 165 86

Oregon 116 54

Pennsylvania 349 83

Puerto Rico 118 58

Rhode Island * 28 3

South Carolina * 159 9

South Dakota * 45 2

Tennessee 288 158

Texas 986 138

Utah 109 50

Virginia 157 56

Virgin Islands 2 2

Vermont * 34 -

Washington 213 58

Wisconsin 181 58

West Virginia * 110 1

Wyoming * 27 -

Total 9,530 2,852

*Fifteen states will not participate in the statistical portion of the survey (i.e., collecting data from systems serving 3,301 –

100,000 persons). However, those states that have systems that serve more than 100,000 people will participate in the census 

portion of the survey (i.e., collecting date from systems serving more than 100,000 persons). For those 15 states, the number in 

the “Estimated Sample Size for Systems Serving More Than 3,300 Persons” represents the total number of systems in the state 

that serve more than 100,000 persons.
ICR for 2011 DWINSA 56 December 8, 2010

B.2.b.iii Stratification Variables 

The objective of stratification is to increase the efficiency of the sampling design (thereby reducing the 

number of samples required at any level of precision) by the creation of independent strata. Stratified 

sampling may produce a gain in precision in the estimates of the characteristics of the target population as 

compared to simple random sampling. In stratified sampling, the target population (i.e., CWSs) is divided 

into non-overlapping strata that are internally homogeneous, in that the measurements vary little from one 

unit to another (i.e., the within-strata variance is minimized). If the within-stratum variance is relatively 

small, then a precise estimate of the variable of interest can be obtained with a relatively small number of 

samples. Each of the strata estimates can be combined to obtain a precise estimate for the target 

population. If the strata are constructed correctly, the target population estimate can be achieved with 

greater precision and with fewer samples than the estimate obtained from simple random sampling.

EPA’s drinking water programs have historically evaluated CWSs based on (1) size (number of persons 

served), and (2) primary source (ground water and surface water).13

Size of Population Served

Using total capital need information 

obtained from the 2007 DWINSA, EPA evaluated several classification schemes. This analysis showed 

that the stratification scheme selected for the 2011 State DWINSA (10 strata based on size and source) 

was reasonable. Some states may have a different number of strata; this accommodated using their data as 

it is currently organized. Varying strata will be permitted only when the 2011State DWINSA’s overall 

precision is not reduced. The proposed strata for systems serving more than 3,300 persons are as follows: 

Source Sample Methodologies

3,301 – 10,000 Ground Random sample. 

3,301 – 10,000 Surface

10,001 – 25,000 Ground Random sample. In some states the number of strata will be 

reduced based on analysis of optimal stratum boundaries. 

Specifically, in some states systems serving between 10,001 

and 50,000 will be in one group rather than two. 

10,001 – 25,000 Surface

25,001 – 50,000 Ground

25,001 – 50,000 Surface

50,001 – 100,000 Ground Random sample

50,001 – 100,000 Surface

More than 100,000 Ground Sampled with certainty

More than 100,000 Surface

B.2.b.iv Sampling Method 

As indicated above, all CWSs serving populations of more than 100,000 will be sampled with certainty. 

For systems serving 3,301 – 100,000 persons, all CWSs will be allocated to eight strata, based on 

population served and primary source. The sample size for each stratum in each state will be determined 

 

13 For the purposes of the 2011 DWINSA, purchased surface water systems are included with ground water systems. 

This design yields lower within-stratum variance.
ICR for 2011 DWINSA 57 December 8, 2010

by the sampling strategy outlined above. The sampling method will be an equal probability random 

sample within each stratum. Anticipating a level of non-response, EPA will over-sample to achieve the 

desired number of completed data collection instruments. Since the expected response rate for systems 

serving 3,301 – 100,000 persons is 90 percent, EPA will draw a sample of 2,241.However, as discussed 

below, the DWINSA has consistently achieved a higher response rate than estimated. Therefore EPA has 

included the full sample size estimate in the burden estimate of this ICR.

B.2.c Precision Requirements 

B.2.c.i Precision Targets 

The sampling design for the 2011 State DWINSA will be implemented at the state level. EPA’s goal is to 

be 95 percent confident that the margin of error, when estimating the total capital needs facing these 

systems in each state, will be plus or minus 10 percent of the total need for these systems. For example, if 

the total need for these systems in a state is estimated to be $2 billion, EPA will be 95 percent confident 

that the actual total need is between $1.8 billion and $2.2 billion.

B.2.c.ii Nonsampling Error 

EPA has developed an assessment approach that will employ several quality assurance techniques to 

maximize response rates, response accuracy, and processing accuracy to minimize nonsampling error. 

Particular emphasis will be placed on maximizing response rates. Standard methods that have proved 

effective in other surveys of water systems will be used, including the following:

• States will review the sample of systems to receive the mail data collection instrument and will 

ensure that the best person to receive the data collection instrument is determined in advance.

• EPA and the states will coordinate in the production of a cover letter for the 2011 DWINSA. 

EPA’s opinion (shared by state drinking water administrators, trade associations, and PWSs) is 

that surveys on state letterhead will be better received than surveys on EPA letterhead. Therefore, 

states can use state-level cover letters signed by a senior state official instead of the EPA letter.

• The data collection instrument design, content, and format have been reviewed by organizations 

representing water systems. In addition, the data collection instrument design, content, and format 

were reviewed by states that participated in the 1995, 1999, and 2003, and 2007 DWINSAs. 

• Items being asked are those that owners or operators of systems should know. EPA does not ask 

for items that require monitoring, research, or calculations on the part of the respondent.

• The data collection instrument design is limited to 8 pages. By limiting the information requested, 

EPA believes that the average water system respondent can complete the data collection 

instrument in approximately 7.51 hours.

• Toll-free phone numbers will be provided to help respondents with questions or problems. In 

addition, respondents will be encouraged to call state personnel who will be trained to answer 

questions. 
ICR for 2011 DWINSA 58 December 8, 2010

• Pre-paid return envelopes will be provided to respondents to make returning the data collection 

instrument convenient.

Standard methods to reduce other sources of non-sampling error also will be used:

• EPA expects complete coverage of the target population using SDWIS, supplemented by state 

agency/Navajo Nation/EPA Regional Office review of all systems.

• Data will be 100 percent independently keyed and verified.

• The data collection instrument is pre-coded to improve accuracy by eliminating unnecessary 

processing steps. 

Supplementing these standard methods, EPA proposes several unique steps to eliminate non-sampling 

error, which have been developed in concert with organizations representing the states and water systems. 

These organizations believe that the 2011 DWINSA is important and that a high level of participation by 

all water systems is essential to its success. Because of the substantial commitment being made by states 

and water systems to the 2011 DWINSA, EPA believes that response rates will be higher than most 

surveys of similar respondents. To ensure success, states and organizations representing water systems are 

taking the following steps. 

• Participation of the states/Navajo Nation/EPA Regions. Because the DWINSA will be used to 

allocate DWSRF funds to states and TSA monies to the Navajo Nation and EPA Regions, each 

entity has a strong interest in achieving a high response rate. EPA believes that their participation 

will be a key factor in guaranteeing high response rates and low item non-response. Personnel 

who work with water systems every day are in a strong position to encourage systems to complete 

the 2011 DWINSA form. These states, the Navajo Nation, and EPA Regions have committed to 

assisting EPA in achieving a high response rate by participating in follow-up activities. The 

states, the Navajo Nation, and EPA Regions also will be available for technical assistance for any 

system that has questions about the 2011 DWINSA. 

• Participation of Organizations Representing Water Systems. EPA anticipates public support of 

organizations representing water systems. The prior assessments were supported by groups such 

as the American Water Works Association (AWWA), the National Association of Water 

Companies (NAWC), and the Association of Metropolitan Water Agencies (AMWA). 

This support by the organizations representing the respondents for the 2011 DWINSA can be 

helpful in many ways to minimize non-sampling errors. For example,

– In past DWINSAs, national water associations sent letters to each system in their 

membership, stressing the importance of surveying drinking water infrastructure needs. 

These letters, along with the letter from the states, helped convince water systems to 

respond. EPA will seek similar support from these associations for the 2011 Survey 

effort.

– In the past DWINSAs, the largest association representing water systems serving 

populations greater than 3,300—AWWA— provided support through its national 

organization. To improve the response rate, the AWWA enlisted the support of its state 
ICR for 2011 DWINSA 59 December 8, 2010

affiliates (called “Sections”) to conduct telephone follow-up calls to encourage response. 

AWWA assisted in past DWINSAs to help achieve the overall response rate of 94 

percent. EPA will seek similar support from AWWA in support of the 2011 DWINSA. 

• Communications Strategy. EPA has developed a comprehensive communications strategy that 

will inform likely respondents of the need for their participation. This strategy includes articles in 

magazines, newsletters, and bulletins of all major organizations that represent (or communicate 

with) water systems. This includes publications of all of the organizations mentioned above, plus 

the state and local affiliates of these organizations. The strategy is designed to develop 

widespread peer-group support for participation in the 2011 DWINSA.

B.2.d Data Collection Instrument Design 

Questions about system characteristics (name, population served, number of connections, and other 

customary business information) will be pre-printed on all data collection instruments. The respondent 

needs only to enter accurate information if any pre-printed information is not correct.

The 2011 DWINSA is based on matrices that request a list of capital projects that the system plans for the 

period 2011 through 2030. For each project listed, the system is asked to provide: type of need; reason for 

need; documentation of need and cost (if necessary); if the project is for new infrastructure or to replace, 

rehabilitate or expand existing infrastructure; if the project is needed now to protect public health or if it is 

needed over the next 20 years to continue to provide safe drinking water; the federal regulation or state 

requirement if the project is to meet a current regulation, state requirement, or is for “green” or climate 

readiness; design capacity of source, storage, and treatment projects; length and diameter of pipe projects; 

diameter for projects such as meters; cost of the project; and date of the cost estimate. EPA will also 

collect information on “green” and climate readiness infrastructure projects. For most of these variables, 

respondents will choose the appropriate “documentation,” “type of need,” “reason for need,” or 

“regulation or requirement,” from the Lists of Codes. All matrices have been designed to be concise, to 

avoid jargon, and to avoid ambiguous words or instructions. Terms and formats have been standardized to 

the extent possible. There is no intentional bias in the ordering of the items. 

B.3 PRE-TESTS AND PILOT TEST

B.3.a Pre-tests 

For the 2007 DWINSA the data collection instrument and some policies were modified substantially. 

Since the only significant modification to the 2011 data collection instrument was the addition of 

questions and codes to gather information on “green” and climate readiness infrastructure projects, EPA 

will conduct a limited peer review of these new questions, however, EPA will not conduct a pre-test of 

the 2011 DWINSA data collection instrument. 

EPA conducted two pre-tests of the data collection instrument for the 2007 DWINSA. The 2007 

DWINSA pre-tests were conducted by EPA’s contractor, The Cadmus Group, Inc. The pre-tests gathered 

feedback on the effectiveness of the data collection instrument, highlighted imprecise, ambiguous, or 

redundant questions, and indicated where further inquiry is needed. A pre-test was held in both Maine 

(four participants) and Montana (three participants). These states were chosen because they were both 

non-participating states and because most of their systems did not participate in the 2007 DWINSA. Also, 

the contractor conducting the pre-tests has offices in both these states and by conducting the pre-test in 
ICR for 2011 DWINSA 60 December 8, 2010

these states they were able to reduce costs. The names of the seven systems were provided to EPA by the 

2007 DWINSA state contacts. Based on the comments received, EPA made modifications to the data 

collection instrument. 

B.3.b Pilot Test 

To eliminate unnecessary burden on states and water systems, it has been decided that no pilot test for the 

2011 DWINSA will be conducted. A pilot test was conducted for the 1995 DWINSA and consisted of 60 

CWSs from New York and Texas. The procedures for mailing the data collection instruments and 

collecting the data are the same as those used for the 1995, 1999, 2003, and 2007 DWINSAs. EPA 

believes these procedures are well tested and have proven to be successful; therefore, it is not necessary to

repeat this testing step. 

B.4 COLLECTION METHODS AND FOLLOW-UP

B.4.a Collection Method 

The proposed collection method is a mail survey. The data collection instrument and Lists of Codes will 

be mailed to all systems in the sample. State drinking water agencies will begin follow-up if the mail data 

collection instrument has not been returned in 30 days. For a complete description of the follow-up 

procedures proposed to increase the response rate, see section B.2.c.ii.

B.4.b Survey Response and Follow-up 

The target response rate (defined as the ratio of responses to eligible respondents) for the 2011 DWINSA 

is 90 percent. EPA realizes that this is an ambitious target, but EPA believes that there are special 

circumstances that warrant such a target. Also, overall response rates of 94, 97, 96, and 93 percent were 

achieved in the 1995, 1999, 2003, and 2007 surveys, respectively. In the first four surveys, EPA 

conducted the following proposed activities to achieve that high response rate. 

• Seek Support from the Respondent Population. This is a national survey of infrastructure needs 

for drinking water systems. EPA will work to bring to the attention of water systems, as well as 

all national organizations representing these systems, the importance of the DWINSA results. As 

with the previous four surveys, all national organizations will be contacted by EPA to seek their 

endorsement of the DWINSA and to communicate to their members the importance of a high 

response rate to their members. As discussed in Section B.2.c, in past surveys, organizations have 

provided access to their newsletters and magazines to publicize and endorse participation in the 

DWINSA; for the 2011 Survey, EPA will seek similar efforts by these organizations.

• Follow-up by States and Respondent Peer Groups. Since a majority of participating states have 

indicated their willingness to participate in follow-up activities, EPA has requested that state 

personnel, most of whom are personally familiar with the respondents, conduct follow-up

procedures including the use of reminder letters and telephone calls. In states that elect not to 

participate in follow-up, the EPA contractor will conduct these activities. If the follow-up fails 

after three attempts (one reminder letter plus two telephone follow-up calls), EPA is planning to 

shift to a second approach of peer-group follow-up by members of a trade association, such as 

AWWA. 
ICR for 2011 DWINSA 61 December 8, 2010

B.5 ANALYZING AND REPORTING SURVEY RESULTS

B.5.a Data Preparation 

State personnel will check all cost data and documentation to ensure that it is consistent with state and 

national standards. States will then send the completed and reviewed data collection instruments to EPA 

for a second round of review by EPA contractor staff. 

Once data have been checked, the contractor will key and verify the data. Senior data entry staff will be 

used for the verification process to improve quality control. Editing will include automated logic and 

range checks and checks for missing data. Missing cost data will be modeled, using other information 

provided by the respondents on the data collection instrument. When modeling is insufficient, missing 

data will be imputed using the standard methods such as cell means and regression. The sample of water 

systems will be weighted so that stratum estimates can be summed to prepare state-level estimates for the 

2011 State DWINSA and national estimates for the 2011 Native American DWINSA.

B.5.b Analysis 

EPA will prepare a report that tabulates the results of the 2011 DWINSA and explains the precision of the 

estimates of total capital needs. Examples of statistics that will be produced include:

• Total capital needs by state/Navajo Nation/EPA Region and by types of need.

• Total capital needs by domains within the total population, e.g., systems serving populations 

greater than 100,000.

• Standard errors calculated for key statistics.

The analysis will be similar to that of previous DWINSAs.

B.5.c Reporting Results 

The 2011 DWINSA results will be made available to EPA and the public through:

• A printed report that is submitted to Congress on drinking water infrastructure needs. This report 

will be made available to all participants in the 2011 DWINSA and the public through EPA’s 

Safe Drinking Water website. 

• Desktop computer access to state/Navajo Nation data on the DWINSA Web site without modeled 

project costs (each state/Navajo Nation can access only its own data).

• Desktop computer access to the entire data system (EPA only).

A report providing the cost models used to develop costs for the 2011 DWINSA will be made available to 

EPA and the public through EPA’s Safe Drinking Water Web site.
ICR for 2011 DWINSA 62 December 8, 2010

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ICR for 2011 DWINSA 63 December 8, 2010

2011 NATIVE AMERICAN DWINSA

Introduction

In the following paragraphs, we present information on the survey of American Indian and Alaskan 

Native Village water systems. This discussion includes only those sections of Part B where the approach 

is different from the approach being used for the 2011 State DWINSA as previously discussed.

B.1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES

B.1.c Statistical Approach 

The 2011 Native American DWINSA is designed to estimate the total capital needs of American Indian 

systems for the nation as a whole and for Alaskan Native Village systems. EPA proposes a survey of a 

statistical sample to estimate total capital needs. This statistical approach minimizes burden while 

achieving the desired level of precision. 

However, a mail survey is not an effective approach to the collection of data from these water systems. 

Experience with mail surveys for these systems suggests that total non-response and item non-response 

would be very high. Also, EPA believes that the absence of knowledgeable respondents at these systems 

limits the general reliability of the responses. The best way to gather information from these systems is 

through direct contact by the EPA Regions or the Navajo Nation. 

B.2 SURVEY DESIGN 

The design for the 2011 Native American DWINSA, like that for the 2011 State DWINSA, is stratified 

random sampling. The stratification variables for these systems are the same as those for other systems: 

size of population served and primary source of supply. However, unlike the 2011 State DWINSA, the 

2011 Native American DWINSA will select two separate samples: 1) American Indian systems in the 

continental U.S., and 2) Alaskan Native Village systems. Stratification variables for both samples include 

population size (populations of: 25 – 500; 501 – 1,000; 1,001 – 3,300; 3,301 – 10,000; and populations of 

more than 10,000), and primary sources of supply (surface and ground). Systems serving more than 

10,000 persons are selected with certainty.

B.2.a Target Population and Coverage 

The target population is CWSs and not-for-profit noncommunity water systems (NPNCWSs) that have 

been designed as Native American. A CWS 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. A NCWSs 

is a “public water system that is not a community water system and that regularly serves at least 25 of the 

same persons over 6 months per year” (nontransient noncommunity water system) or is a public water 

system that is not a community water system and “does not regularly serve at least 25 of the same persons 

over six months per year” (transient noncommunity water system). (40 CFR 141.2)
ICR for 2011 DWINSA 64 December 8, 2010

B.2.b Sample Design

B.2.b.ii Sample Size

The procedures proposed for designing a sample size for the 2011 Native American DWINSA is the same 

as that proposed for 2011 State DWINSA. Equations 1, 2, and 3 still apply, except that a national sample 

size will be selected instead of state-by-state samples and data from the 1999 DWINSA will be used 

instead of data from the 2007 DWINSA for the standard deviation of the variable of interest.

B.2.b.iii Stratification Variables 

As with the design for the 2011 State DWINSA, the sample design for the 2011 Native American 

DWINSA is stratified on the basis of (1) size (number of persons served by the CWS or NPNCWS), and 

(2) primary source (ground water and surface water). 

The proposed strata are as follows:

Size of Population Served Source Sample Methodologies

25 – 1,000 Ground

Random sample. 

25 – 1,000 Surface

1,001 – 3,300 Ground

1,001 – 3,300 Surface

3,301 – 10,000 Ground

3,301 – 10,000 Surface

More than 10,000 Ground

Sampled with certainty More than 10,000 Surface

B.2.b.iv Sampling Method 

As indicated above, all systems serving populations of more than 10,000 will be sampled with certainty. 

For systems serving 25 – 10,000 persons, all systems will be allocated to six strata based on population 

served and primary source. The sample size for each stratum will be determined by the sampling strategy 

outlined above. The sampling method will be an equal probability random sample within each stratum. 

Anticipating a level of non-response, EPA will over-sample to achieve the desired number of completed 

data collection instruments. Since the expected response rate is 90 percent, EPA will draw a sample of 

206 American Indian water systems and 86 Alaskan Native Village water systems. However, the 

DWINSA has consistently achieved a higher response rate than estimated. Therefore EPA has included 

the full sample size estimate in the burden estimate of this ICR.
ICR for 2011 DWINSA 65 December 8, 2010

B.2.c Precision Requirements 

B.2.c.i Precision Targets

The sampling design for the 2011 Native American DWINSA will be implemented at the national level 

for American Indian water system and for the State of Alaska for Alaskan Native Village water systems. 

EPA’s goal is to be 95 percent confident that the margin of error, when estimating the total capital needs 

facing these systems nationally (for American Indian water systems) and at the state (for Alaskan Native 

Village water systems), will be plus or minus 10 percent of the total need for these systems. 

B.4 COLLECTION METHODS AND FOLLOW-UP 

B.4.a Collection Method 

The proposed collection method for the 2011 Native American DWINSA is for the EPA Region or the 

Navajo Nation to first preliminarily fill out the data collection instrument for each system in the sample 

based on information obtained from IHS and the water systems records. The Navajo Nation or EPA 

Region will then contact each system and interview the respondent to identify possible additional projects 

and to concur on the final set of identified infrastructure investment needs. By having the EPA Regions 

and the Navajo Nation conducting the survey in this manner for American Indian and Alaskan Native 

Village water systems, the information collection burden on these water system respondents will be 

minimized.
ICR for 2011 DWINSA 66 December 8, 2010

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ICR for 2011 DWINSA December 8, 2010

Appendix A 

Public Notice Required Prior to ICR Submission to OMB
ICR for 2011 DWINSA December 8, 2010

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55324 Federal Register / Vol. 75, No. 175 / Friday, September 10, 2010 / Notices 

comment date. On or before the 

comment date, it is not necessary to 

serve motions to intervene or protests 

on persons other than the Applicant. 

The Commission encourages 

electronic submission of protests and 

interventions in lieu of paper using the 

‘‘eFiling’’ link at http://www.ferc.gov. 

Persons unable to file electronically 

should submit an original and 14 copies 

of the protest or intervention to the 

Federal Energy Regulatory Commission, 

888 First Street, NE., Washington, DC 

20426. 

This filing is accessible on-line at 

http://www.ferc.gov, using the 

‘‘eLibrary’’ link and is available for 

review in the Commission’s Public 

Reference Room in Washington, DC. 

There is an ‘‘eSubscription’’ link on the 

Web site that enables subscribers to 

receive e-mail notification when a 

document is added to a subscribed 

docket(s). For assistance with any FERC 

Online service, please e-mail 

FERCOnlineSupport@ferc.gov, or call 

(866) 208–3676 (toll free). For TTY, call 

(202) 502–8659. 

Comment Date: 5 p.m. Eastern Time 

on September 30, 2010. 

Kimberly D. Bose, 

Secretary. 

[FR Doc. 2010–22511 Filed 9–9–10; 8:45 am] 

BILLING CODE 6717–01–P 

DEPARTMENT OF ENERGY 

Federal Energy Regulatory 

Commission 

[Docket No. CP10–489–000] 

Columbia Gas Transmission, LLC; 

Notice of Request Under Blanket 

Authorization 

September 2, 2010. 

Take notice that on August 23, 2010, 

Columbia Gas Transmission, LLC 

(Columbia), 5151 San Felipe, Suite 

2500, Houston, TX, 77056, filed an 

application pursuant to Section 7(b), 

Parts 157.205 and 157.216, of the 

Commission’s regulations under the 

Natural Gas Act (NGA) for authorization 

to abandon: (1) The Weaver Storage 

Well No. 9297 together with the 

associated well pipeline designated as 

Line SLW–9297 and appurtenances; and 

(2) the Lucas Storage Well No. 10572 

together with the associated well 

pipeline designated as Line SWL–10572 

and appurtenances, all as more fully set 

forth in the application, which is on file 

with the Commission and open to 

public inspection. The filing may also 

be viewed on the Web at http:// 

www.ferc.gov using the ‘‘eLibrary’’ link. 

Enter the docket number excluding the 

last three digits in the docket number 

field to access the document. For 

assistance, contact FERC at 

FERCOnlineSupport@ferc.gov or call 

toll-free, (866) 208–3676 or TTY, (202) 

502–8659. 

Any questions regarding the 

application should be directed to Fredic 

J. George, Senior Counsel, Columbia Gas 

Transmission, LLC, P.O. Box 1273, 

Charleston, West Virginia 25325–1273 

at (304) 357–2359, or by e-mail at 

fgeorge@nisource.com. 

Any person may, within 60 days after 

the issuance of the instant notice by the 

Commission, file pursuant to Rule 214 

of the Commission’s Procedural Rules 

(18 CFR 385.214) a motion to intervene 

or notice of intervention. Any person 

filing to intervene or the Commission’s 

staff may, pursuant to section 157.205 of 

the Commission’s regulations under the 

NGA (18 CFR 157.205) file a protest to 

the request. If no protest is filed within 

the time allowed therefore, the proposed 

activity shall be deemed to be 

authorized effective the day after the 

time allowed for protest. If a protest is 

filed and not withdrawn within 30 days 

after the time allowed for filing a 

protest, the instant request shall be 

treated as an application for 

authorization pursuant to section 7 of 

the NGA. 

The Commission strongly encourages 

electronic filings of comments, protests, 

and interventions via the internet in lieu 

of paper. See 18 CFR 385.2001(a)(1)(iii) 

and the instructions on the 

Commission’s Web site (http:// 

www.ferc.gov) under the ‘‘e-Filing’’ link. 

Kimberly D. Bose, 

Secretary. 

[FR Doc. 2010–22510 Filed 9–9–10; 8:45 am] 

BILLING CODE 6717–01–P 

ENVIRONMENTAL PROTECTION 

AGENCY 

[EPA–HQ–OW–2010–0689; FRL–9200–2] 

Agency Information Collection 

Activities: Proposed Collection; 

Comment Request; 2011 Drinking 

Water Infrastructure Needs Survey and 

Assessment (Reinstatement); EPA ICR 

No. 2234.03; OMB Control No. 2040– 

0274 

AGENCY: Environmental Protection 

Agency (EPA). 

ACTION: Notice. 

SUMMARY: In compliance with the 

Paperwork Reduction Act (PRA) (44 

U.S.C. 3501 et seq.), this document 

announces that the Environmental 

Protection Agency (EPA) is planning to 

submit a request for a new Information 

Collection Request (ICR) to the Office of 

Management and Budget (OMB). Before 

submitting the ICR to OMB for review 

and approval, EPA is soliciting 

comments on specific aspects of the 

proposed information collection as 

described below. 

DATES: Comments must be submitted on 

or before November 9, 2010. 

ADDRESSES: Submit your comments, 

identified by Docket ID No. EPA–HQ– 

OW–2010–0689, by one of the following 

methods: 

• http://www.regulations.gov: Follow 

the on-line instructions for submitting 

comments. 

• E-mail: barles.robert@epa.gov. 

• Fax: 202–564–3757. 

• Mail: Water Docket, EPA Docket 

Center (EPA/DC), Environmental 

Protection Agency, Mailcode: 28221T, 

1200 Pennsylvania Avenue, NW., 

Washington, DC 20460. 

• Hand Delivery: Water Docket, EPA 

Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., 

NW., Washington, DC. 

Instructions: Direct your comments to 

Docket ID No. EPA–HQ–OW–2010– 

0689. EPA’s policy is that all comments 

received will be included in the public 

docket without change and may be 

made available online at http:// 

www.regulations.gov, including any 

personal information provided, unless 

the comment includes information 

claimed to be Confidential Business 

Information (CBI) or other information 

of which disclosure is restricted by 

statute. Do not submit information that 

you consider to be CBI or otherwise 

protected through http:// 

www.regulations.gov or by e-mail. The 

http://www.regulations.gov Web site is 

an ‘‘anonymous access’’ system, which 

means EPA will not know your identity 

or contact information unless you 

provide it in the body of your comment. 

If you send an e-mail comment directly 

to EPA without going through http:// 

www.regulations.gov, your e-mail 

address will be automatically captured 

and included as part of the comment 

that is placed in the public docket and 

made available on the Internet. If you 

submit an electronic comment, EPA 

recommends that you include your 

name and other contact information in 

the body of your comment and with any 

disk or CD–ROM you submit. If EPA 

cannot read your comment due to 

technical difficulties and cannot contact 

you for clarification, EPA may not be 

able to consider your comment. 

Electronic files should avoid the use of 

special characters or any form of 


srobinson on DSKHWCL6B1PROD with NOTICES
Federal Register / Vol. 75, No. 175 / Friday, September 10, 2010 / Notices 55325 

encryption and be free of any defects or 

viruses. For additional information 

about EPA’s public docket visit the EPA 

Docket Center homepage at http:// 

www.epa.gov/dockets. 

FOR FURTHER INFORMATION CONTACT: 

Robert Barles, Drinking Water 

Protection Division (Mail Code 4606M), 

Office of Ground Water and Drinking 

Water, U.S. EPA, 1200 Pennsylvania 

Avenue, NW., Washington, DC 20460; 

telephone number: 202–564–3814; fax 

number: 202–564–3757; e-mail address: 

barles.robert@epa.gov. 

SUPPLEMENTARY INFORMATION: 

How can I access the docket and/or 

submit comments? 

EPA has established a public docket 

for this ICR under Docket ID No. EPA– 

HQ–OW–2010–0689 which is available 

for online viewing at http:// 

www.regulations.gov or in person 

viewing at the Water Docket in the EPA 

Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., 

NW., Washington, DC. The EPA/DC 

Public Reading Room is open from 8:30 

a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The 

telephone number for the Reading Room 

is 202–566–1744 and the telephone 

number for the Water Docket is 202– 

566–2426. 

Use http://www.regulations.gov to 

obtain a copy of the draft collection of 

information, submit or view public 

comments, access the index listing of 

the contents of the docket, and access 

those documents in the public docket 

that are available electronically. Once in 

the system, select ‘‘search,’’ then key in 

the docket ID number identified in this 

document. 

What information is EPA particularly 

interested in? 

Pursuant to section 3506(c)(2)(A) of 

the PRA, EPA specifically solicits 

comments and information to enable it 

to: 

(i) Evaluate whether the proposed 

collection of information is necessary 

for the proper performance of the 

functions of the Agency, including 

whether the information will have 

practical utility; 

(ii) Evaluate the accuracy of the 

Agency’s estimate of the burden of the 

proposed collection of information, 

including the validity of the 

methodology and assumptions used; 

(iii) Enhance the quality, utility, and 

clarity of the information to be 

collected; and 

(iv) Minimize the burden of the 

collection of information on those who 

are to respond, including through the 

use of appropriate automated electronic, 

mechanical, or other technological 

collection techniques or other forms of 

information technology, e.g., permitting 

electronic submission of responses. In 

particular, EPA is requesting comments 

from very small businesses (those that 

employ less than 25 people) on 

examples of specific additional efforts 

that EPA could make to reduce the 

paperwork burden for very small 

businesses affected by this collection. 

What should I consider when I prepare 

my comments for EPA? 

You may find the following 

suggestions helpful for preparing your 

comments: 

1. Explain your views as clearly as 

possible and provide specific examples. 

2. Describe any assumptions that you 

used. 

3. Provide copies of any technical 

information and/or data you used that 

support your views. 

4. If you estimate potential burden or 

costs, explain how you arrived at the 

estimate that you provide. 

5. Offer alternative ways to improve 

the collection activity. 

6. Make sure to submit your 

comments by the deadline identified 

under DATES. 

7. To ensure proper receipt by EPA, 

be sure to identify the docket ID number 

assigned to this action in the subject 

line on the first page of your response. 

You may also provide the name, date 

and Federal Register citation. 

What information collection activity or 

ICR does this apply to? 

Affected entities: Entities potentially 

affected by this action are those which 

own, operate or regulate community 

water systems including, but not limited 

to, owners/operators of community 

water systems, state environmental 

water quality agencies, and state 

departments of health. 

Title: 2011 Drinking Water 

Infrastructure Needs Survey and 

Assessment (DWINSA) (Reinstatement). 

ICR numbers: EPA ICR No. 2234.03, 

OMB Control No. 2040–0274. 

ICR status: This ICR seeks 

reinstatement of a previously approved 

information collection activity that was 

discontinued on December 31, 2009. 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 in title 40 of the CFR, 

after appearing in the Federal Register 

when approved, are listed in 40 CFR 

part 9, and are displayed either by 

publication in the Federal Register or 

by other appropriate means, such as on 

the related collection instrument or 

form, if applicable. The display of OMB 

control numbers in certain EPA 

regulations is consolidated in 40 CFR 

part 9. 

Abstract: The purpose of this 

information collection is to identify the 

infrastructure needs of public water 

systems for the 20-year period from 

January 2011 through December 2031. 

EPA’s Office of Ground Water and 

Drinking Water (OGWDW) will collect 

these data to comply with Sections 

1452(h) and 1452(i)(4) of the Safe 

Drinking Water Act (42 U.S.C. 300j–12). 

EPA will use a questionnaire to 

collect capital investment need 

information from community water 

systems serving more than 3,300 

persons and from American Indian and 

Alaskan Native Village community 

water systems and not-for-profit noncommunity water systems serving more 

than 25 persons. Participation in the 

survey is voluntary. The data from the 

questionnaires will provide EPA with a 

basis for estimating the nationwide 

infrastructure needs of public water 

systems. Also, as mandated by section 

1452(a)(1)(D)(ii) of the Safe Drinking 

Water Act, EPA uses the results of the 

latest survey to allocate the next fiscal 

year’s appropriation of the Drinking 

Water State Revolving Fund (DWSRF) 

monies to the States. Under the 

allotment formula, each state receives a 

grant of the annual DWSRF 

appropriation in proportion to its share 

of the total national need—with the 

proviso that each state receives at least 

one percent of the total funds available. 

Burden Statement: Over the entire 

survey effort, the annual public 

reporting and recordkeeping burden for 

this collection of information is 

estimated to average 7.55 hours per 

response for States and water system 

respondents combined. However, nearly 

all of the responses from water systems 

will occur in the single year of 2011. 

Burden means the total time, effort, or 

financial resources expended by persons 

to generate, maintain, retain, or disclose 

or provide information to or for a 

Federal agency. This includes the time 

needed to review instructions; develop, 

acquire, install and utilize technology 

and systems for the purposes of 

collecting, validating, and verifying 

information, processing and 

maintaining information, and disclosing 

and providing information; adjust the 

existing ways to comply with any 

previously applicable instructions and 

requirements which have subsequently 

changed; train personnel to be able to 

respond to a collection of information; 

search data sources; complete and 


srobinson on DSKHWCL6B1PROD with NOTICES
55326 Federal Register / Vol. 75, No. 175 / Friday, September 10, 2010 / Notices 

review the collection of information; 

and transmit or otherwise disclose the 

information. 

The ICR provides a detailed 

explanation of the Agency’s estimate, 

which is only briefly summarized here: 

• Estimated total number of potential 

respondents: 3,176. 

• Frequency of response: Once. 

• Estimated total average number of 

responses for each respondent: One per 

system. 

• Estimated total annual burden: 

16,250 hours. 

• Estimated total annual costs: 

$613,014. This includes an estimated 

burden cost of $613,014 and an 

estimated cost of $0.00 for capital 

investment or maintenance and 

operational costs. 

What is the next step in the process for 

this ICR? 

EPA will consider the comments 

received and amend the ICR as 

appropriate. The final ICR package will 

then be submitted to OMB for review 

and approval pursuant to 5 CFR 

1320.12. At that time, EPA will issue 

another Federal Register notice 

pursuant to 5 CFR 1320.5(a)(1)(iv) to 

announce the submission of the ICR to 

OMB and the opportunity to submit 

additional comments to OMB. If you 

have any questions about this ICR or the 

approval process, please contact the 

technical person listed under the FOR

FURTHER INFORMATION CONTACT section. 

Dated: September 3, 2010. 

Cynthia C. Dougherty, 

Director, Office of Ground Water and Drinking 

Water. 

[FR Doc. 2010–22642 Filed 9–9–10; 8:45 am] 

BILLING CODE 6560–50–P 

ENVIRONMENTAL PROTECTION 

AGENCY 

[ER–FRL–8992–6] 

Environmental Impacts Statements; 

Notice of Availability 

Responsible Agency: Office of Federal 

Activities, General Information (202) 

564–1399 or http://www.epa.gov/ 

compliance/nepa/. 

Weekly receipt of Environmental Impact 

Statements. 

Filed 08/30/2010 through 09/03/2010. 

Pursuant to 40 CFR 1506.9. 

Notice: 

In accordance with Section 309(a) of 

the Clean Air Act, EPA is required to 

make its comments on EISs issued by 

other Federal agencies public. 

Historically, EPA has met this mandate 

by publishing weekly notices of 

availability of EPA comments, which 

includes a brief summary of EPA’s 

comment letters, in the Federal 

Register. Since February 2008, EPA has 

been including its comment letters on 

EISs on its Web site at: http:// 

www.epa.gov/compliance/nepa/ 

eisdata.html. Including the entire EIS 

comment letters on the website satisfies 

the Section 309(a) requirement to make 

EPA’s comments on EISs available to 

the public. Accordingly, on March 31, 

2010, EPA discontinued the publication 

of the notice of availability of EPA 

comments in the Federal Register. 

EIS No. 20100360, Draft EIS, USFS, CA, 

Gemmill Thin Project, Updated 

Information on Four Alternatives, 

Chanchellula Late-Successional 

Reserve, Shasta-Trinity National 

Forest, Trinity County, CA, Comment 

Period Ends: 10/25/2010, Contact: 

Bobbie DiMonte Miller 530–226– 

2425. 

EIS No. 20100361, Revised Draft EIS, 

FHWA, CO, PROGRAMMATIC—I–70 

Mountain Corridor Tier 1 Project, 

from Glenwood Springs and C–470, 

Proposes to Increase Capacity, 

Improve Accessibility and Mobility, 

and Decrease Congestion, Colorado, 

Garfield, Eagle, Summit, Clear Creek, 

and Jefferson Counties, CO, Comment 

Period Ends: 11/08/2010, Contact: 

Monica Pavilik, P.E. 720–963–3012. 

EIS No. 20100362, Draft EIS, USFS, CA, 

Big Pony Project, Proposes to Reduce 

Fire Hazard to Permanent Research 

Plots and to Areas Within and 

Adjacent to Wildland Urban Interface 

near Tennant, Goosenest Ranger 

District, Klamath National Forest, 

Siskiyou County, CA, Comment 

Period Ends: 10/25/2010, Contact: 

Wendy Coats 530–841–4470. 

EIS No. 20100363, Draft EIS, NOAA, 

CA, Gray’s Reef National Marine 

Sanctuary (GRNMS) Research Areas 

Designation, Establish a Research 

Area, Implementation, GA, Comment 

Period Ends: 12/08/2010, Contact: 

George Sedberry 912–598–2345. 

EIS No. 20100364, Final EIS, USN, 00, 

Northwest Training Range Complex 

(NWTRC), Support and Conduct 

Current, Emerging, and Future 

Training, and Research Development, 

Test and Evaluation (RDT&E) 

Activities, WA, OR, and CA, Wait 

Period Ends: 10/11/2010, Contact: 

Kimberly Kler 360–396–0927. 

EIS No. 20100365, Final EIS, BLM, NV, 

Silver State Solar Energy Project, 

Construction and Operation of a 400- 

megawatt Photovoltaic Solar Plant 

and Associated Facilities on Public 

Lands, Application, Right-of-Way 

Grant, Primm and Clark Counties, NV, 

Wait Period Ends: 10/11/2010, 

Contact: Greg Helseth 702–515–5173. 

EIS No. 20100366, Final EIS, USFWS, 

MT, Montana Department of Natural 

Resources and Conservation Forested 

Trust Lands Habitat Conservation 

Plan, Issuance of Incidental Take 

Permit, Implementation, MT, Wait 

Period Ends: 10/11/2010, Contact: 

Kathleen Ports 406–542–4330. 

Amended Notices 

EIS No. 20100322, Draft EIS, USAF, 00, 

Powder River Training Complex 

Project, Proposal to Improve Airspace 

for Training, Primarily, B–1 Aircrews 

at Ellsworth AFB, South Dakota, and 

B–52 Aircrews at Minot AFB, North 

Dakota, Comment Period Ends: 11/15/ 

2010, Contact: Linda Devine 757– 

964–9434. 

Revision to FR Notice Published 08/ 

20/2010: Change to Contact Phone 

Number and Change Comment Period 

from 11/17/2010 to 11/15/2010. 

Dated: September 7, 2010. 

Cliff Rader, 

Environmental Protection Specialist, Office 

of Federal Activities. 

[FR Doc. 2010–22617 Filed 9–9–10; 8:45 am] 

BILLING CODE 6560–50–P 

ENVIRONMENTAL PROTECTION 

AGENCY 

[FRL–9199–9] 

Notice of Proposed Administrative 

Settlement Pursuant to the 

Comprehensive Environmental 

Response, Compensation, and Liability 

Act 

AGENCY: Environmental Protection 

Agency. 

ACTION: Notice; request for public 

comment. 

SUMMARY: In accordance with Section 

122(h) of the Comprehensive 

Environmental Response, 

Compensation, and Liability Act, as 

amended (‘‘CERCLA’’), 42 U.S.C. 9622(i), 

notice is hereby given of a proposed 

administrative settlement concerning 

the Malone Service Company Superfund 

Site, Texas City, Galveston County, 

Texas. 

The settlement requires the thirty-two 

(32) settling parties to pay a total of 

$1,015,013 payment of response costs to 

the Hazardous Substances Superfund. 

The settlement includes a covenant not 

to sue pursuant to Sections 106 or 107 

of CERCLA, 42, U.S.C. 9606 or 9607. 

For thirty (30) days following the date 

of publication of this notice, the Agency 

will receive written comments relating 


srobinson on DSKHWCL6B1PROD with NOTICES
ICR for 2011 DWINSA December 8, 2010

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ICR for 2011 DWINSA December 8, 2010

Appendix B

Data Collection Instrument and Lists of Codes
ICR for 2011 DWINSA December 8, 2010

This page intentionally left blank.
EPA Form 6100-01 1 

2011 Drinking Water Infrastructure 

Needs Survey and Assessment 

U.S. Environmental Protection Agency 

Washington, DC 20460 

Please verify or correct the following information: 

Check if Correct 

as Printed 

Corrected Info

(Fill in only if preprinted informa

Name of System (Community): Name of Contact for Water System: (Record name of person completing survey on page 8; may be same person) Street Address: City, State, and Zip: 



Population Served (if wholesale seller, include population of systems sold to): Number of Connections (not including those in consecutive systems): Total System Design Capacity: ____________ MGD Source Water Type (Ground, Surface/GWUDI, etc.): Check All That Apply:  Ground  

 Purchased Ground  

Ownership Type: 

Check All That Apply:  Public  

 Native American  

 

Public reporting burden for this collection of information is estimated to average 7.51 hours per response. This estimate includes time for reviewing the instructions, se

and maintaining the data needed, and completing and reviewing the information collected. Burden means the total time, effort, or financial resources expended by per

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 sy

validating, and verifying information; adjust the existing ways to comply with any previously applicable instructions; search data sources; complete and review the collotherwise 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 OMB control numbers for EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent buautomated collection techniques to the Director, OPPI, Regulatory Information Division, U.S. Environmental Protection Agency (1804A), Ariel Rios Building, 1200 Pen20460; and Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503.

State Use Only State Reviewer: ___________________________________________________________________________________ Telephone NumbeInformation provided for this survey can be requested by the public. It is our experience that survey information is rarely 

F
EPA Form 6100-01 2 

Source, Treatment, Storage, and Pumping Inventory

To ensure all potential source, treatment, storage, and pumping projects are considered, it may be helpful to complete some or all of t

completion of this table is not required. 

Source Water

Inventory Needing Replacement Needing Rehabilitation N

Total Number and Capacity of Existing Wells or Springs: 

Wells (pumps included) or Springs: Wells (pumps included) or Springs: Does your s

capacity neeusers? (cheYes ___ No 

Total Number and Capacity of Existing Surface Water Sources: 

Existing Surface Water Intakes (excluding pumps): 

Existing Surface Water Intakes (excluding pumps): 

If yes, how mnecessary? 

Total Number and Capacity of Existing Pumps (excluding booster pump stations): 

Existing Groundwater Pumps (if wells not listed): 

Existing Groundwater Pumps (if wells not listed): 

Existing Raw Surface Water Pumps: Existing Raw Surface Water Pumps: 

Treatment

Inventory Needing Replacement Needing Expansion/Upgrading or Rehabilitation N

For the sources identified above, enter the number of locations where the following treatment is applied: Disinfection (including booster disinfection): 

Disinfection: Disinfection: Does your s

needs for prprotection oYes ___ No If yes, what 

Filtration: Filtration: Filtration: Chemical removal or addition: Chemical treatment: Chemical treatment: 

Storage and Pump Stations

Inventory Needing Replacement Needing Rehabilitation N

Total Number and Capacity of Existing Storage Tanks: 

Number of Existing Storage Tanks: Number of Existing Elevated or Ground-Level 

Storage Tanks: 

Does your scapacity andthe needs oYes N

If yes, how mstorage or bnecessary? 

Total Number and Capacity of Existing Booster Pump Stations: 

Number of Existing Booster Pump Stations: Number of Existing Booster Pump Stations: 

 Source Projects are all projects related to collecting and pumping raw water. This includes wells, surface water intakes, springs, off-stream raw 

houses.

 Treatment Projects are all projects related to disinfection, filtration, or other treatment processes for ground or surface water sources, or for trea

system.

 Storage and Pumping Projects are related to finished or treated water storage, and booster pump stations. 
EPA Form 6100-01 3 

Source, Treatment, Storage, and Pumping Projects

Project 

Number Project Name 

Type of 

Need 

(List 1) 

Reason 

for Need 

(List 2) 

New, 

Replace, 

ReHab, 

Expand/ 

upgrade 

Current

or 

Future 

Reg or 

Secondary 

Purpose 

(List 3) 

Design 

Capacity 

(MG, 

MGD, 

kW) 

Number 

Needed 

(if 

applicable)

Co

Estim

(if avai

Ex. 1 Replace Wells 3 and 8 at 0.5 MGD each R1 A1 R C 4A 0.5 2 - Ex. 2 Rehab Treatment Plant and Booster Station T10, P2 A1,A6 H F 1A 5.0 1 $6,02

1000 1001 1002 1003 1004 1005 1006 1007 

If a project is coded 2G for “climate readiness” from List 3, please refer to page 7 for supplemental questions. 

If you have more source, treatme nt, storage, or p umping projects ch eck this box  and continue o n a supplemental sheet 

downloadable at www.DWNeeds.com). Project numbers for these types of projects are 1000-1999, and should be numbered in seque

EPA requires documentation of all projects provided. Applicable types of documentation are presented in Li

Use only existing documentation of cost. We do not expect you to develop new cost estim
EPA Form 6100-01 4 

Transmission and Distribution Inventory

On the table below, please provide an estimate of the total feet or miles of pipe in your system, if possible. Completion of this table is nhelpful to ensure all potential transmission and distribution pipe projects are considered. 

Note: The total feet or miles of pipe in your system is required information if any pipe projects are 

submitted based solely on survey-generated documentation (documentation codes 10 or 11). ______________ 

Total Pipe in System

(Circle or underline feet or miles) <=6 inch 8-12 inch 15-42 inch > 

Plastic 

________ Feet or miles Amount of PVC by pipe size ________ feet or miles ________ feet or miles ________ feet or miles ________ % of total pipe 

% of this category/size pipe currently in poor condition or beyond useful life 

 ________ % ________ % ________ % 

Ductile Iron

________ Feet or miles Amount of ductile iron by pipe size ________ feet or miles ________ feet or miles ________ feet or miles ________ % of total pipe 

% of this category/size pipe currently in poor condition or beyond useful life 

 ________ % ________ % ________ % 

Cast Iron

________ Feet or miles Amount of cast iron by pipe size ________ feet or miles ________ feet or miles ________ feet or miles ________ % of total pipe 

% of this category/size pipe currently in poor condition or beyond useful life 

 ________ % ________ % ________ % 

Asbestos Cement

________

 Feet or miles Amount of asbestos cement by pipe size ________ feet or miles ________ feet or miles ________ feet or miles 

________ % of total pipe 

% of this category/size pipe currently in poor condition or beyond useful life 

 ________ % ________ % ________ % 

Other

________ Feet or miles Amount of other by pipe size ________ feet or miles ________ feet or miles ________ feet or miles ________ % of total pipe % of other currently in poor condition or beyond useful life ________ % ________ % ________ % 

Transmission and distribution projects are the piping needs of a water system. Projects for valves, backflow prevention devic

hydrants, and meters that are not part of a transmission or distribution project listed in this table should be recorded in the table on 
EPA Form 6100-01 5 

Transmission and Distribution Projects 

Project 

Number Project Name 

Type of 

Need 

(List 1) 

Reason 

for Need

(List 2) 

New, 

Replace, 

or 

ReHab 

Current 

or 

Future 

Reg or 

Secondary 

Purpose 

(List 3) 

Diameter 

of Pipe 

(Inches) 

Length of

Pipe 

(Feet) 

Cos

Estim

(if avail

Ex. 1 Cleaning and Lining Old Cast 

Iron Mains M1 A1 H C 4A 12 18,000 - 

Ex 2 Replace Deteriorated 

Transmission Main X2 A1 R C 4A 24 20,000 $4,200,

2000 2001 2002 2003 2004 2005 2006 2007 

If a project is coded 2G for “climate readiness” from List 3, please refer to page 7 for supplemental questions. 

If you have more transmi ssion or di stribution proje cts che ck this box  and continue on a sup plemental sheet (in cluded in thi s 

www.DWNeeds.com). Project numbers for transmission or distribution projects are 2000-2999, and should be numbered in sequence. 

EPA requires documentation of all projects provided. Applicable types of documentation are presented in Lis

Use only existing documentation of cost. We do not expect you to develop new cost estimate
EPA Form 6100-01 6 

Meters, Service Lines, Backflow Prevention Devices/Assemblies, Hydrant

Inventory Needing Replacement New Infra

Total Number of Existing Water Meters: Number of Water Meters: Number of Water Meters: Total Number of Existing Backflow Prevention Devices/Assemblies: 

Number of Backflow Prevention Devices/Assemblies: 

Number of Backflow PreveDevices/Assemblies: 

Total Number of Existing Valves: Number of Valves: Number of Valves: Total Number of Existing Hydrants: Number of Hydrants: Number of Hydrants: Total Number of Lead Service Lines: 

Project 

Number Project Name 

Type of 

Need 

(List 1) 

Reason 

for Need

(List 2) 

New, 

Replace, 

or 

ReHab 

Current 

or 

Future 

Reg or 

Secondary 

Purpose 

(List 3) 

Size 

(Diameter 

in Inches)

Number 

Needed 

Co

Estim

(if avai

Ex.1 Replace Lead Service Lines M2 A6 R C 1D - 100 $100

3000 3001 3002 3003 3004 

Projects for meters, service lines, backflow prevention devices and assemblies, valves, hydrants and other miscellaneous projects 

section to accommodate entries of multiple identical items on one line in the project table. Record only projects that are not a p(e.g., water main replacement projects will already include valves, hydrants, and other appurtenances). EPA requires do

provided. Applicable types of documentation are presented in List 4 of the Lists of Codes. Use only existing documentation of cosdevelop new cost estimates.
EPA Form 6100-01 7 

Project 

Number Project Name 

Type of 

Need 

(List 1) 

Reason 

for Need

(List 2) 

New, 

Replace, 

or 

ReHab 

Current 

or 

Future 

Reg or 

Secondary 

Purpose 

(List 3) 

Size 

(Diameter 

in Inches)

Number 

Needed 

Co

Estim

(if avai

3005 3006 3006 3008 

If a project is coded 2G for “climate readiness” from List 3, please refer to page 7 for supplemental questions. 

If you have more of th ese types of proje cts check thi s box  and con tinue on a sup plemental sheet (i ncluded in this p

www.DWNeeds.com). Project numbers for these types of projects are 3000-3999, and should be numbered in sequence. 

Climate Readiness

Supplemental Questions

If you used code 2G from List 3, in the “Regulation or Secondary Purpose” column of the survey, indicating that you have projects that are related to climate readiness, please answer the following questions. Only one response is requested; do response for each project.

Projects that included a climate ready component [Project #(s)]: ______________________________________________

Which of the following secondary consequences of climate change have contributed to your system’s need for climate rea

(check all that apply) 

o Source water quality (e.g., water quality degradation affecting treatment processes, alternate sources, etc.) o Source water quantity (e.g., availability affected by snowmelt or weather patterns, or hydraulic patterns) o Infrastructure Vulnerability (e.g., facility locations affected by sea level rise, increased precipitation intensityo Other (please explain)_______________________ 

Please describe the data you are relying on to determine climate change consequences and implications. 

o Model developed from state-specific data. o Model developed from region-specific data. o Other (please describe)_______________________ 
EPA Form 6100-01 8 

Respondent Information

Please provide the following information in case we need to contact you for clarification or additional explanatio

responses. 

Contact Person (Person who completed this questionnaire): 

Signature: 

Name (please print): Title: Mailing Address: (Street Address) 

Telephone Number: 

Fax Number: E-mail Address: Best Time to Reach You: 

If you have any questions, contact your state coordinator (contact information can be found at www.dwneeds

toll-free Needs Survey Helpline at X-XXX-XXX-XXXX.

CLOSING: Thank you for your help. Did you remember to: 

 Attach all additional project tables to the questionnaire?  Identify, by project number, available documentation for all needs and costs reported above?  Put the questionnaire and the documentation in the pre-paid, pre-addressed Federal Express Pak provided and 

the documentation to the address below? (See the pink enclosure for further return instructions.) 

Jane Q. Official 

Division of Water 

One Capital Street 

Capital, XX 99999 
Use these instructions and lists of co

Needs Survey and Assessment qudocumentation please be sure to includinclude copies of the breakdown of co

LIST 4 - DOCUMENTATION 

Code Independent Documentation of Need and/or Cost 1 Capital Improvement Plan or Master Plan: The plan must address 

why the project is needed and/or provide a cost. 

2 Facilities Plan or Preliminary Engineering Report: Excerpts 

justifying need and/or cost from the plan or report are acceptable if project-specific. 

3 Grant or Loan Application Form: An application form is acceptable if 

it specifically describes a problem requiring capital expenditures. 

4 Engineer's Estimate or Bid Tabulation: These must be project 

specific and independently generated. They must also be accompanied by an explanation of why the project is needed. 

Code Independent Documentation of Need Only 5 Intended Use Plan/State Priority List: The excerpts must include a 

description of why the project is needed. Costs from IUPs will not be used - modeling parameters or other cost documentation must be provided. 

6 Comprehensive Performance Evaluation (CPE) or Sanitary Survey 

Results: The results or recommendations may be used to justify need if the state concurs. 

7 Monitoring Results: Monitoring results indicating an MCL exceedance 

or a trending towards an exceedance can demonstrate a need for a project if accompanied by a written statement explaining how the results demonstrate the need. 

8 Other Independent Document: Use this code if documentation is 

independent but none of the codes listed above apply. Examples include: state enforcement order/notice of violation, engineering studies, watermain break report, repair reports, and distribution system studies. 

Code Independent Documentation of Cost Only 9 Cost of Previous Comparable Construction: This may be used to 

justify costs if the costs are project-specific. It must include documentation of how the costs were derived. 

Code Survey-generated Documentation of Need Only 10 Written by State: Brief description and statement of need written by 

state. 

11 Written by System: Brief description and statement of need written by 

system. 

Lists of C

7 
Instructions for Each Column on the 2011 Drinking Water 

Infrastructure Needs Survey and Assessment Questionnaire 

The following instructions apply to columns on all tables in the questionnaire. Column Title Instructions Project Number Number the projects in each category in sequence, using the range 

of numbers specified for each category of need. 

Project Name Provide a name that briefly describes and identifies the project. Type of Need Refer to List 1 in the Lists of Codes and enter the code(s) that best 

identifies the project. More than one code may apply to a project if a 

cost is provided. Use only one code if no cost is available. 

Reason for Need Refer to List 2 in the Lists of Codes and enter the code(s) that best 

justifies the project. More than one code may apply to a project if a cost is provided. Use only one code if no cost is available. 

New,

Replace, Expand/Upgrade, 

or ReHabilitate 

Identify whether the project is for:  -New infrastructure installation where none exists, enter ‘

N’ 

 Resulting infrastructure is entirely new. 

 -Replacement of existing infrastructure, enter ‘

R’ 

 Existing infrastructure is replaced with new infrastructure. 

 -Expansion or Upgrade of a complete treatment plant, enter ‘E’

 Major improvements to an existing complete plant. May add 

or change unit processes. May result in an increase in capacity. Use for complete treatment plants only. 

 -Rehabilitation of existing infrastructure, enter ‘

H’ 

 Restore existing infrastructure to near new condition. 

Current or 

Future 

Identify whether the project is: 

- Needed now, enter C= 

 (even if you cannot start construction now) 

- Not needed now, enter F= 

 (but will be necessary before 12/31/2030 

Regulation or Secondary Purpose 

If the project is needed to maintain or obtain compliance with a regulation, secondary MCL, or if one or more of the secondary purpose codes (green or climate readiness) apply, refer to List 3 in the Lists of Codes and enter the appropriate code. Enter ‘4A’ if no code applies. 

Cost Estimate If available, enter the documented cost estimate for this project. 

Use only existing cost estimates. If no cost estimate is provided and modeling parameters are recorded, EPA will use models to 

estimate the cost. 

Date of Cost Estimate 

Enter the month and year (MM/YYYY) of the cost estimate. EPA willadjust cost estimates to current-year dollars. 

Documentation Refer to List 4 in the Lists of Codes and enter the code(s) that 

applies to the type of documentation provided that explains why the 

project is needed. If a cost estimate is provided, also enter the code that applies to the type of cost documentation. More than one code 

may apply to a project if a cost is provided. Use only one code if no cost is available. Please enclose the appropriate pages of need and cost documentation, identified by project number.

LIST 3 

 REGULATION OR SEC

Code Regulation or Secondary Purpose EXISTING SDWA REGULATIONS

1A Surface Water Treatment Regulations (Sur

Enhanced Surface Water Treatment Rule, Term 1 Enhanced Surface Water TreatmenSurface Water Treatment Rule) 

1B Total Coliform Rule (published June 1989) 1C Nitrate or Nitrite Standard 1D Lead and Copper Rule 1E Arsenic Rule (10 μg/L Arsenic Standard) 1F Stage 1 Disinfectants/Disinfection Byprodu

μg/L for TTHMs and 60 μg/L for HAA5s as 

1G Other Regulated VOCs, SOCs, IOCs, or Ra1H Ground Water Rule OTHER REQUIREMENTS OR SECONDARY PUR

2A Secondary Contaminants (e.g., iron, taste a2B State Requirements 2C Green – Green Infrastructure (e.g., porous 2D Green – Water Efficiency (e.g., meters, pre2E Green – Energy Efficiency (e.g., pump reha2F Green – Environmentally Innovative (e.g., L2G Climate Readiness (e.g., source quality deg

or infrastructure vulnerability) 

PROPOSED AND RECENTLY PROMULGATED 

Needs associated solely with the following propos

regulations are not allowable and should not be incneeds, estimated for each rule’s Economic Analysnational need. These regulations include: 

 Stage 2 Disinfectants/Disinfection Byprod (for compliance with the 80 μg/L for TTHM locational running annual average)  Proposed Revisions to the 1989 Total Col Proposed Radon Rule 

If None of the Above Codes Applies

4A Use this code if none of the codes above a

1 

6 
LIST 2 

 REASON FOR NEED

Code Reason the Project is Needed A1 Project is for existing infrastructure that is or will be old or 

deteriorated by 12/31/2030. 

A2 Project is to correct a deficiency in source water quantity caused by 

current user demand. 

A3 Project is to correct a deficiency in storage capacity caused by 

current user demand. 

A4 Project is to correct existing pressure problems (not related to fire 

flow). 

A5 Project needed as a result of, but not in preparation for, a natural 

disaster. 

A6 Project is to obtain or maintain compliance with an existing 

regulation (enter the regulation code from List 3 in the Lists of Codes in the regulation column of the questionnaire). 

A7 Project is to obtain or maintain compliance with a secondary 

standard (e.g., iron, taste and odor, and color) (enter regulation code 2A in the regulation column of the questionnaire). 

A8 Project is for consolidation with and/or connection to an existing 

public water system. 

A9 Project is for extending service to existing homes without adequate 

water quantity or quality. 

A10 Project is to prevent, detect, or respond to a security event 

(e.g., fence, locks, protective structures, gates, on-line sensors, motion sensors, alarm systems, generators, communications equipment, analytical equipment) 

A11 Use this code if codes A1-A10 do not apply. 

The following instructions apply to columns o

Column Title Instructions Design Capacity

On the Source, Treatment, Sto

the design capacity when applicsource, treatment, and pumpingkilowatts (kW) for emergency pis the total volume or the flow thcomponents of the project are o

Diameter of Pipe

On the Transmission and Distriof pipe (in inches) that must be new. Use a separate project nu

Length of Pipe On the Transmission and Distri

pipe (in feet) that must be upgreach diameter identified in the 

Size On the Backflow Prevention De

Lines, Valves, Water Meter, an(in inches) for infrastructure thainstalled as new. Use a separatdiameters of the same type of n

line projects. 

Number Needed 

On the Source, Treatment, Sto

the total number of components at the same capacity (e.g., rehacapacity). On the Backflow Prevention DeLines, Valves, Water Meter and number of components. For exdiameter valves would include tvalves and the number “4” wouIf you use this column and provreflect the entire project (i.e., al

of an individual well or meter). 

Important Notes:A description of each project or a copy of the documentation must also be clearly identified by project number and submitted with the completed questionnaire. Projects primarily for meeting expected future population growth or for fire flow are unallowable. 

o What is a “need?” – Installation or reh

needed over the next 20 years. 

o What is “independent documentation

process independent of the survey (e.greport, etc.). 

o What is “survey-generated documen

specifically for the survey written by the 

5 2 
LIST 1 

 TYPE OF NE

Code Type of Need T35 Chemical Feed T36 Chemical Storage Tank T37 Fluoride Addition T38 Presedimentation Basin T39 Sedimentation/Flocculation T40 Granular Activated Carbon T41 Membrane Filtration (not complete plant) T42 Media Filters T43 Waste Handling/Treatment: Mechanical (not incluT44 Waste Handling/Treatment: Nonmechanical or Co

(not included in another project) 

T45 Type of Treatment Unknown T46 Other (Please include an explanation) 1

TRANSMISSION: (Any mains that transport raw water from the plant to the distribution system grid)X1 Raw Water Transmission X2 Finished Water Transmission DISTRIBUTION 

M1 Distribution Mains (Any mains that transport wate

see "transmission" above) 

M2 Lead (Pb) Service Line Replacement M3 Service Lines (other than lead service lines) M4 Hydrants Used for Flushing (not included in anoth

M5 Valves (gate, butterfly, etc.) (not included in anothM6 Control Valves (PRVs, altitude, etc.) M7 Backflow Prevention Devices/Assemblies M8 Water Meters FINISHED/TREATED WATER STORAGES1 Elevated Finished/Treated Water Storage S2 Ground-level Finished/Treated Water Storage S3 Hy dropneumatic Storage S5 Cover for Existing Finished/Treated Water StoragPUMP STATION AND FINISHED WATER PUMPP1 Finished Water Pump P2 Pump Station (booster or raw water pump stationOTHER INFRASTRUCTURE NEEDSW1 Laboratory Capital Costs for Labs Owned by the 

W2 Computer and Automation Costs (SCADA) W3 Pump Controls/Telemetry W4 Emergency Power (enter design capacity as kilowW5 Security: Fencing W6 Security: Other Physical (lights, wall, manhole loc

W7 Security: Electronic/Cyber (computer firewall, clos

W8 Security: Monitoring Tools (used to identify anom

W9 Security: Other Security (describe in documentati

W10 Other (Please include an explanation) 1

LIST 1 

 TYPE OF NEED

Code Type of Need RAW/UNTREATED WATER SOURCE R1 Well (including pump and appurtenances, not including a well house) R2 Well Pump R3 Well House (may include a chemical feed room) R4 Eliminate Well Pit R5 Abandon Well R6 Aquifer Storage and Recovery Well R7 Surface Water Intake R8 Raw Water Pump R9 Off-Stream Raw Water Storage1

R10 Spring Collector R11 De-stratification1

TREATMENT: Disinfection

T1 Chlorination T2 Chloramination T3 Chlorine Dioxide T4 Ozonation T5 Mixed Oxidant Type Equipment T6 Ultraviolet Disinfection T7 Contact Basin for CT T8 Dechlorination of Treated Water T9 Chlorine Gas Scrubber TREATMENT: Complete Plants (N/R/E require independent documentation)

T10 Conventional Filter Plant (includes CAC technologies) 

T11 Direct or In-line Filter Plant T12 Slow Sand Filter Plant T13 Diatomaceous Earth Filter Plant T14 Membrane Technology for Particulate Removal T15 Cartridge or Bag Filtration Plant T16 Lime Softening T17 Reverse Osmosis T18 Electrodialy sis T19 Activated Alumina T20 Manganese Green Sand (or other oxidation/filtration technology) T21 Ion Exchange T22 Groundw ater Chemical-feed T23 Iron Adsorption T24 Aeration (complete plant) TREATMENT: Other Components / Equipment / Processes T30 Zebra Mussel Control T31 Corrosion Control (chemical addition) 

T32 Powdered Activated Carbon T33 Aeration (component) T34 Sequestering for Iron and/or Manganese 

4 

1 Cost must be provided. Infrastructure cannot be modeled. 

3 
Use these instructions and lists of co

Needs Survey and Assessment qudocumentation please be sure to includinclude copies of the breakdown of co

For American Indian and Alaskan Na

LIST 4 - DOCUMENTATION 

Code Independent Documentation of Need and/or Cost 1 Capital Improvement Plan or Master Plan: The plan must address why 

the project is needed and/or provide a cost.

2 Facilities Plan or Preliminary Engineering Report: Excerpts justifying 

need and/or cost from the plan or report are acceptable if project-specific.

3 Grant or Loan Application Form: An application form is acceptable if it 

specifically describes a problem requiring capital expenditures.

4 Engineer's Estimate or Bid Tabulation: These must be project specific 

and independently generated. They must also be accompanied by an explanation of why the project is needed.

Code Independent Documentation of Need Only 5 Intended Use Plan/State Priority List: The excerpts must include a 

description of why the project is needed. Costs from IUPs will not be used - modeling parameters or other cost documentation must be provided.

6 Comprehensive Performance Evaluation (CPE) or Sanitary Survey 

Results: The results or recommendations may be used to justify need if the 

state concurs.

7 Monitoring Results: Monitoring results indicating an MCL exceedance or a 

trending towards an exceedance can demonstrate a need for a project if accompanied by a written statement explaining how the results demonstrate the need.

8 Other Independent Document: Use this code if documentation is 

independent but none of the codes listed above apply. Examples include: state 

enforcement order/notice of violation, engineering studies, watermain break report, repair reports, and distribution system studies.

Code Independent Documentation of Cost Only 9 Cost of Previous Comparable Construction: This may be used to justify 

costs if the costs are project-specific. It must include documentation of how the 

costs were derived.

Code Survey-generated Documentation of Need Only 10 Written by State: Brief description and statement of need written by state.11 Written by System: Brief description and statement of need written by 

system.

12 Written by EPA Region/Navajo Nation: Brief description and statement of 

need written by EPA Region/Navajo Nation based on site visit or other data collection means.

Lists of C

7 
Instructions for Each Column on the 2011 Drinking Water 

Infrastructure Needs Survey and Assessment Questionnaire 

The following instructions apply to columns on all tables in the questionnaire. Column Title Instructions Project Number Number the projects in each category in sequence, using the range 

of numbers specified for each category of need. 

Project Name Provide a name that briefly describes and identifies the project. Type of Need Refer to List 1 in the Lists of Codes and enter the code(s) that best 

identifies the project. More than one code may apply to a project if a 

cost is provided. Use only one code if no cost is available. 

Reason for Need Refer to List 2 in the Lists of Codes and enter the code(s) that best 

justifies the project. More than one code may apply to a project if a cost is provided. Use only one code if no cost is available. 

New,

Replace, Expand/Upgrade, 

or ReHabilitate 

Identify whether the project is for:  -New infrastructure installation where none exists, enter ‘

N’ 

 Resulting infrastructure is entirely new. 

 -Replacement of existing infrastructure, enter ‘

R’ 

 Existing infrastructure is replaced with new infrastructure. 

 -Expansion or Upgrade of a complete treatment plant, enter ‘E’

 Major improvements to an existing complete plant. May add 

or change unit processes. May result in an increase in capacity. Use for complete treatment plants only. 

 -Rehabilitation of existing infrastructure, enter ‘

H’ 

 Restore existing infrastructure to near new condition. 

Current or 

Future 

Identify whether the project is: 

- Needed now, enter C= 

 (even if you cannot start construction now) 

- Not needed now, enter F= 

 (but will be necessary before 12/31/2030 

Regulation or Secondary Purpose 

If the project is needed to maintain or obtain compliance with a regulation, secondary MCL, or if one or more of the secondary purpose codes (green or climate readiness) apply, refer to List 3 in the Lists of Codes and enter the appropriate code. Enter ‘4A’ if no code applies. 

Cost Estimate If available, enter the documented cost estimate for this project. 

Use only existing cost estimates. If no cost estimate is provided and modeling parameters are recorded, EPA will use models to 

estimate the cost. 

Date of Cost Estimate 

Enter the month and year (MM/YYYY) of the cost estimate. EPA willadjust cost estimates to current-year dollars. 

Documentation Refer to List 4 in the Lists of Codes and enter the code(s) that 

applies to the type of documentation provided that explains why the 

project is needed. If a cost estimate is provided, also enter the code that applies to the type of cost documentation. More than one code 

may apply to a project if a cost is provided. Use only one code if no cost is available. Please enclose the appropriate pages of need and cost documentation, identified by project number.

LIST 3 

 REGULATION OR SEC

Code Regulation or Secondary Purpose EXISTING SDWA REGULATIONS

1A Surface Water Treatment Regulations (Sur

Enhanced Surface Water Treatment Rule, Term 1 Enhanced Surface Water TreatmenSurface Water Treatment Rule) 

1B Total Coliform Rule (published June 1989) 1C Nitrate or Nitrite Standard 1D Lead and Copper Rule 1E Arsenic Rule (10 μg/L Arsenic Standard) 1F Stage 1 Disinfectants/Disinfection Byprodu

μg/L for TTHMs and 60 μg/L for HAA5s as 

1G Other Regulated VOCs, SOCs, IOCs, or Ra1H Ground Water Rule OTHER REQUIREMENTS OR SECONDARY PUR

2A Secondary Contaminants (e.g., iron, taste a2B State Requirements 2C Green – Green Infrastructure (e.g., porous 2D Green – Water Efficiency (e.g., meters, pre2E Green – Energy Efficiency (e.g., pump reha2F Green – Environmentally Innovative (e.g., L2G Climate Readiness (e.g., source quality deg

or infrastructure vulnerability) 

PROPOSED AND RECENTLY PROMULGATED 

Needs associated solely with the following propos

regulations are not allowable and should not be incneeds, estimated for each rule’s Economic Analysnational need. These regulations include: 

 Stage 2 Disinfectants/Disinfection Byprod (for compliance with the 80 μg/L for TTHM locational running annual average)  Proposed Revisions to the 1989 Total Col Proposed Radon Rule 

If None of the Above Codes Applies

4A Use this code if none of the codes above a

1 6 
LIST 2 

 REASON FOR NEED

Code Reason the Project is Needed A1 Project is for existing infrastructure that is or will be old or 

deteriorated by 12/31/2030. 

A2 Project is to correct a deficiency in source water quantity caused by 

current user demand. 

A3 Project is to correct a deficiency in storage capacity caused by 

current user demand. 

A4 Project is to correct existing pressure problems (not related to fire 

flow). 

A5 Project needed as a result of, but not in preparation for, a natural 

disaster. 

A6 Project is to obtain or maintain compliance with an existing 

regulation (enter the regulation code from List 3 in the Lists of Codes in the regulation column of the questionnaire). 

A7 Project is to obtain or maintain compliance with a secondary 

standard (e.g., iron, taste and odor, and color) (enter regulation code 2A in the regulation column of the questionnaire). 

A8 Project is for consolidation with and/or connection to an existing 

public water system. 

A9 Project is for extending service to existing homes without adequate 

water quantity or quality. 

A10 Project is to prevent, detect, or respond to a security event 

(e.g., fence, locks, protective structures, gates, on-line sensors, motion sensors, alarm systems, generators, communications equipment, analytical equipment) 

A11 Use this code if codes A1-A10 do not apply. 

The following instructions apply to columns o

Column Title Instructions Design Capacity

On the Source, Treatment, Sto

the design capacity when applicsource, treatment, and pumpingkilowatts (kW) for emergency pis the total volume or the flow thcomponents of the project are o

Diameter of Pipe

On the Transmission and Distriof pipe (in inches) that must be new. Use a separate project nu

Length of Pipe On the Transmission and Distri

pipe (in feet) that must be upgreach diameter identified in the 

Size On the Backflow Prevention De

Lines, Valves, Water Meter, an(in inches) for infrastructure thainstalled as new. Use a separatdiameters of the same type of n

line projects. 

Number Needed 

On the Source, Treatment, Sto

the total number of components at the same capacity (e.g., rehacapacity). On the Backflow Prevention DeLines, Valves, Water Meter and number of components. For exdiameter valves would include tvalves and the number “4” wouIf you use this column and provreflect the entire project (i.e., al

of an individual well or meter). 

Important Notes:A description of each project or a copy of the documentation must also be clearly identified by project number and submitted with the completed questionnaire. Projects primarily for meeting expected future population growth or for fire flow are unallowable. 

o What is a “need?” – Installation or reh

needed over the next 20 years. 

o What is “independent documentation

process independent of the survey (e.greport, etc.). 

o What is “survey-generated documen

specifically for the survey written by the 

5 2 
LIST 1 

 TYPE OF NE

Code Type of Need T38 Presedimentation Basin T39 Sedimentation/Flocculation T40 Granular Activated Carbon T41 Membrane Filtration (not complete plant) T42 Media Filters T43 Waste Handling/Treatment: Mechanical (not incluT44 Waste Handling/Treatment: Nonmechanical or Co

(not included in another project) 

T45 Type of Treatment Unknown T46 Other (Please include an explanation) 1

T50 T51 T52 T53 

Streaming Current Monitors Particle Counters Turbidity Meters Chlorine Residual Monitors 

TRANSMISSION: (Any mains that transport raw water from the plant to the distribution system grid)X1 Raw Water Transmission X2 Finished Water Transmission DISTRIBUTION 

M1 Distribution Mains (Any mains that transport wate

see "transmission" above) 

M2 Lead (Pb) Service Line Replacement M3 Service Lines (other than lead service lines) M4 Hydrants Used for Flushing (not included in anoth

M5 Valves (gate, butterfly, etc.) (not included in anothM6 Control Valves (PRVs, altitude, etc.) M7 Backflow Prevention Devices/Assemblies M8 Water Meters FINISHED/TREATED WATER STORAGES1 Elevated Finished/Treated Water Storage S2 Ground-level Finished/Treated Water Storage S3 Hy dropneumatic Storage S4 Cisterns S5 Cover for Existing Finished/Treated Water StoragPUMP STATION AND FINISHED WATER PUMPP1 Finished Water Pump P2 Pump Station (booster or raw water pump stationOTHER INFRASTRUCTURE NEEDSW1 Laboratory Capital Costs for Labs Owned by the 

W2 Computer and Automation Costs (SCADA) W3 Pump Controls/Telemetry W4 Emergency Power (enter design capacity as kilowW5 Security: Fencing W6 Security: Other Physical (lights, wall, manhole loc

W7 Security: Electronic/Cyber (computer firewall, clos

W8 Security: Monitoring Tools (used to identify anom

W9 Security: Other Security (describe in documentati

W10 Other (Please include an explanation) 1

LIST 1 

 TYPE OF NEED

Code Type of Need RAW/UNTREATED WATER SOURCE R1 Well (including pump and appurtenances, not including a well house) R2 Well Pump R3 Well House (may include a chemical feed room) R4 Eliminate Well Pit R5 Abandon Well R6 Aquifer Storage and Recovery Well R7 Surface Water Intake R8 Raw Water Pump R9 Off-Stream Raw Water Storage1

R10 Spring Collector R11 De-stratification1

TREATMENT: Disinfection

T1 Chlorination T2 Chloramination T3 Chlorine Dioxide T4 Ozonation T5 Mixed Oxidant Type Equipment T6 Ultraviolet Disinfection T7 Contact Basin for CT T8 Dechlorination of Treated Water T9 Chlorine Gas Scrubber TREATMENT: Complete Plants (N/R/E require independent documentation)

T10 Conventional Filter Plant (includes CAC technologies) 

T11 Direct or In-line Filter Plant T12 Slow Sand Filter Plant T13 Diatomaceous Earth Filter Plant T14 Membrane Technology for Particulate Removal T15 Cartridge or Bag Filtration Plant T16 Lime Softening T17 Reverse Osmosis T18 Electrodialy sis T19 Activated Alumina T20 Manganese Green Sand (or other oxidation/filtration technology) T21 Ion Exchange T22 Groundw ater Chemical-feed T23 Iron Adsorption T24 Aeration (complete plant) TREATMENT: Other Components / Equipment / Processes T30 Zebra Mussel Control T31 Corrosion Control (chemical addition) 

T32 Powdered Activated Carbon T33 Aeration (component) T34 Sequestering for Iron and/or Manganese T35 Chemical Feed T36 Chemical Storage Tank T37 Fluoride Addition 

4

1 Cost must be provided. Infrastructure cannot be modeled. 

3
ICR for 2011 DWINSA December 8, 2010

Appendix C

Comments and Response to Comments Received on the First Federal Register 

Notice
ICR for 2011 DWINSA December 8, 2010

This page intentionally left blank.
November 9, 2010 

Water Docket 

U.S. Environmental Protection Agency 

EPA West, Room B102 

1301 Constitution Avenue, N.W. 

Washington, D.C. 24640 

RE: Agency Information Collection Activities: Proposed Collection; Comment 

Request; 2011 Drinking Water Infrastructure Needs Survey Agency 

Information Collection; EPA ICR No. 2234.03, OMB Control No. 2040-

0274 (Docket ID. No. EPA–HQ–OW–2010–0689) 

Dear Sir or Madam: 

The American Water Works Association (AWWA) appreciates the opportunity to 

submit these comments on the U.S. Environmental Protection Agency’s (EPA’s) 

notice on the Drinking Water Infrastructure Needs Survey 2011 Agency 

Information Collection (September 10, 2010, 75 Federal Register 55324). AWWA is 

an international, nonprofit, scientific and educational society dedicated to the 

improvement of water quality and supply. Founded in 1881, the association is the 

largest organization of water supply professionals in the world. Our more than 

55,000 members represent the full spectrum of the drinking water community: 

treatment plant operators and managers, environmental advocates, engineers, 

scientists, academicians, and others who hold a genuine interest in water supply 

and public health. Our membership includes more than 4,100 water systems that 

supply roughly 80 percent of the nation's drinking water. AWWA and its member 

utilities are dedicated to safe water, and are committed to assisting in the 

development of science-based regulations that provide meaningful risk reduction to 

protect public health. 

AWWA’s comments on the proposed survey are attached. AWWA appreciates and 

supports the collection of data when the effort is appropriately structured and the 

data collected can be used to support sound decisions. The Needs Survey is an 

important part of Safe Drinking Water Act implementation that should be 

Government Affairs Office 

1300 Eye Street NW 

Suite 701W 

Washington, DC 20005-3314 

T 202.628.8303 

F 202.628.2846 

Headquarters Office 

6666 W. Quincy Avenue 

Denver CO 80235 

T 303.794.7711 

F 303.347.0804 

The Authoritative Resource on Safe Water SM
Water Docket 

Docket Id. No. EPA–HQ–OW–2010–0689 

Page 2 

undertaken regularly and organized in a fashion that is both statistically sound and 

represents as small a response burden as possible on individual drinking water 

utilities. 

 

AWWA appreciates the agency’s consideration of our concerns and 

recommendations. If there are any questions, please direct them to me or Steve Via 

at (202) 326-6130. 

Best regards, 

Thomas W. Curtis 

Deputy Executive Director 

AWWA Government Affairs 

cc: Robert Barles, EPA/OW/OGWDW 

 Charles Job, EPA/OW/OGWDW 

 Cynthia Dougherty, EPA/OW/OGWDW 
 

COMMENTS ON 

DRAFT DRINKING WATER INFRASTRUCTURE NEEDS SURVEY 

AGENCY INFORMATION COLLECTION 

(September 10, 2010, 75 Federal Register 55324, Docket ID. No. EPA–HQ–OW–

2010–0689) 

AWWA Supports Needs Survey 

Support documentation for the Drinking Water Infrastructure Needs Survey and 

Assessment (Needs Survey) notes that AWWA has supported previous Needs 

Surveys by direct mail contact and through outreach by AWWA sections. AWWA 

provides this support because a robust and accurate Needs Survey is important. A 

current and accurate assessment of infrastructure needs facing drinking water 

systems will enable the agency to properly administer the drinking water revolving 

loan fund and implement the nation’s overall regulatory program for drinking 

water. AWWA will happily provide its support for this survey once it is clear that it 

is constructed in a manner that will provide a robust and accurate estimate of need 

in each State 

Setting Objectives for the Needs Survey 

AWWA agrees with the agency that the survey should identify needs captured by 

long-term water system planning rather than simply focusing on near-term capital 

investments. This longer-term view will by necessity introduce some inaccuracy 

into the survey response. 

AWWA recommends that the survey clearly state concise objectives and how those 

objectives will be met. There is a good example of such a statement on page 49 of 

the support document (Information Collection Request for the 2011 Drinking Water 

Infrastructure Needs Survey and Assessment (DWINSA) (Supporting Statement for 

ROCIS)). Page 49 states that: 

“...EPA’s precision target for the 2011 State DWINSA is to be 95 percent 

confident that the true need lies within an interval, the upper and lower 

bounds of which do not exceed 10 percent of the sample mean (or estimated 

need)..” 

This type of objective statement should be brought forth earlier in the 

document. 

AWWA recommends the agency report the goals for survey accuracy within 

individual system size categories. AWWA also encourages the agency to set 

stringent objectives for the accuracy of the survey results at the individual state 

level in designing the Needs Survey. 
Page 2 

Improvements to Survey Approach Over 2007 Survey 

The 2007 Needs Survey relied on an inappropriate analytical approach to estimate 

the impact of the Long-Term 2 Enhanced Surface Water Treatment Rule 

(LT2ESWTR). In 2007, EPA based the estimate of need associated with LT2ESWTR 

on the agency’s economic analysis for the rule. AWWA supports the current survey 

approach which is to use available utility documentation to understand the cost of 

implementing the LT2ESWTR. 

The proposed survey effort will also include an assessment of infrastructure needs 

on Native American lands. This population of systems has not been captured in the 

past two Needs Surveys. AWWA applauds the agency’s proposed effort to capture 

infrastructure needs on Native American lands. 

Transparency

The detailed survey contains questions that do not comport with the purpose of the 

survey. In AWWA’s judgment such questions (e.g., enumerating valve, meter, 

hydrant, service line, and backflow prevention device replacement programs) will 

consequently increase response burden without contributing to the survey 

objectives. Similarly, the distribution of pipe materials and the sizes and numbers 

of lead service lines are information that may be useful to the agency for the 

purpose of targeting research funding, developing guidance, and informing 

regulatory actions, but these data are not pertinent to the needs assessment. If 

EPA is going to collect this type of information the agency should clearly document 

why this information is needed and how such data will be used both in its 

justification of the survey and in the survey questionnaire. 

Supplemental questions regarding climate readiness also lack a clear relevance to 

the stated purpose of the Needs Survey and AWWA recommends their deletion. 

The site-specific nature of efforts to enhance system resiliency must consider a 

variety of site-specific challenges – the degree to which any particular action is 

clearly documented as being based on “climate readiness” will vary widely. Due to 

the site-specific nature of the questions and degree of uncertainty in available 

climate-ready planning tools, the data generated from these questions are unlikely 

to generate reliable data to inform public policy in a useful way. 

Burden 

The current estimate of 10.42 hours per system is inadequate to undertake the data 

collection reflected in the draft survey questionnaire. Compiling inventories of pipe, 

assigning individual projects to specific rule requirements and other activities will 

require a number of different individuals to be involved in assembling the 

information, providing oversight and quality control. These activities will require 

staff with relevant technical skills (e.g., accounting, engineering, water quality) and 

senior staff. Additional time will likely be needed for administrative staff to copy 

requested documents and prepare the transmission for EPA. According to the 
Page 3 

proposed survey, EPA expects PWS staff will spend on average roughly one half 

hour interacting with State staff (obtaining technical support). Based on the 

proposed questions, documentation requirements, and historical experience it is 

likely that a significant number of utilities will be contacted by States for 

clarification of responses. Consequently, the estimated number of hours required to 

conduct the survey will be considerably higher. Completing the survey and related 

research will require substantially more time and resources than is reflected in the 

current burden estimate. The burden estimate should be adjusted accordingly. 

Small Systems 

It is important that the 2011Needs Survey collect information about the 

needs of small systems. The cumulative costs of SDWA regulations and other 

pressures are overwhelming small systems. AWWA does not support the 

proposed approach of extrapolating large system costs to small systems. The 

agency approach does not capture the unique challenges of small systems or 

the degree to which new regulations impact small systems (e.g., Ground 

Water Rule, Arsenic Rule, etc.). Nor does this approach capture the interstate variability in the number of small systems per capita served. In 2007 

the Needs Survey included a survey of small systems. The methodology used 

in 2007, or a larger small system survey, would be more effective approaches 

than the proposed 2011 effort. 
1

EPA Response to Comments Received from AWWA Regarding the 2011 DWINSA

Below is a summary of the comments received from the American Water Works Association regarding

the Draft Information Collection Request for the 2011 DWINSA and EPA’s responses to each comment.

• AWWA suggested that the survey clearly state concise objectives and how those objectives will

be met.

o EPA’s primary goal is to achieve the most accurate survey possible.  The two sources of

potential inaccuracy in the survey result from “measurement error” in determining the

need for each individual infrastructure investment and “sampling error” in estimating

the needs of all water systems from a representative sub‐sample of those systems.   

EPA strives to reduce “measurement error” by relying on the information and judgment

of those individuals most familiar and directly responsible for the infrastructure, the

owners and operators of water systems, and assuring that their estimates of investment

needs are within the context of historic best engineering practices.   EPA addresses the

“sampling error” by identifying and specifying statistical precision targets for the Survey

and determining the necessary sample and sub‐sample sizes to achieve those targets,

including a census of systems with the largest need, and by selecting the sample

randomly.

It is important to note that while greater statistical precision can be achieved by

increasing the size of the sample to be survey, the additional burden that a larger

sample size creates for collecting data and assuring its quality can result in substantially

increasing measurement errors and reducing the overall accuracy of the survey.  EPA

strives to create a balance between achieving statistical precision and avoiding

measurement errors within the constraints of reasonable budget and manpower

available not only to the Agency but to the states’ and water systems’ personnel.

A statement to this effect has been placed in the ICR for clarification.

• AWWA recommended that the goals for survey accuracy within individual system size categories

be reported. AWWA recommended that stringent objectives for the accuracy of the survey

results at the individual state level be set.

o The statistical approach for the 2011 DWINSA stratifies by system size and state‐specific

samples will be drawn for the survey.  The precision target and statistical approach for

the survey are discussed in Section B.2 of the ICR.   
2

• AWWA was concerned that providing system inventory information would be too burdensome

for many of the surveyed water system operators.  

o It will be made further clear that in the final questionnaire that the inventory tables are

simply provided as a helpful tool for the optional use by each system to assess any asset

investment needs that are not yet part of their formal planning documents.

o In addition the ICR was updated to make it clearer that the inventory tables are

intended to be helpful worksheets for water systems’ optional use.  

• AWWA was concerned that the supplemental questions regarding climate readiness lacked a

clear relevance to the stated purpose of the Needs Survey.

o In addition to the primary goal of an accurate survey of investment needs to underpin

EPA’s allotment of the DWSRF to the states, the Agency also believes the Survey should

take the opportunity to identify and assess emerging trends and issues related to

infrastructure in the Nation’s water supply industry and report this to Congress.  While it

may be early in the industry’s understanding of the potential impacts of possible climate

change, EPA believes the significance of those impacts on the water infrastructure

needs warrants an early reading on the thinking within the industry.  

o The data collection instrument was updated to include an addendum to the instructions

on the green and climate readiness questions.  The ICR was updated to include this

information.  

• AWWA was concerned that the burden estimate was likely too low.  

o EPA has reviewed the assumptions made regarding burden and believes they are sound.

EPA’s estimates of burden are based on the experience of four previous DWINSAs and

the input of survey respondents and state coordinators during those efforts and after in

reviews to determine the strengths and weaknesses of those DWINSAs. The burden

estimate was revised substantially from the estimate from the last DWINSA primarily

taking into account greater efforts to ensure consistency across systems and states in

determining long‐term infrastructure rehabilitation and replacement needs.

o In addition, the 2011 DWINSA ICR estimates includes burden for all the systems in

selected for the survey. In past DWINSA ICRs the burden estimates were adjusted for

non‐response. However, the DWINSA has consistently achieved a higher response rate

than estimated. Therefore EPA has included the full sample size estimate in the burden

estimate of this ICR.
3

• AWWA was concerned that data was not being collected from small systems.  

o The proposed approach is similar to the approach taken for the 2003 DWINSA in which

the needs from the 1999 DWINSA small systems were used to determine the need by

states for the 2003 DWINSA. EPA will use the small system results of the 2007 DWINSA

to determine the small system needs for participating states. The full survey cannot be

fielded due to budgetary constraints and the EPA believes surveying the American

Indian and Alaskan Native Village water system is an important step.  They were last

surveyed in 1999.   
From: Dave Emme <demme@ndep.nv.gov> 

To: Robert Barles/DC/USEPA/US@EPA 

Date: 11/08/2010 01:31 PM 

Subject: Drinking Water Needs survey. 

Mr. Barles,

Nevada wishes to opt in to the 2011 DWINSA and is committed to

allocating the resources necessary to complete the survey.

David Emme, Chief

Bureau of Administrative Services

Nevada Division of Environmental Protection

901 S Stewart St, Suite 4001

Carson City, NV 89706

tel. 775.687.9307

fax.775.687.5856
EPA Response to Comments Received from Nevada Division of Environmental 

Protection Regarding the 2011 DWINSA

Below is a summary of the comment received from the Nevada Division of Environmental Protection 

regarding the Draft Information Collection Request for the 2011 DWINSA and EPA’s responses to each 

comment. Both the comment and response were originally submitted through email.

Nevada wishes to opt in to the 2011 DWINSA and is committed to allocating the resources 

necessary to complete the survey.

o Nevada will be included in the 2011 DWINSA, pending approval from OMB.