## Information Collection Request for the 2011 Drinking Water
Infrastructure Needs Survey and Assessment (DWINSA) (Supporting Statement for ICRAS and ROCIS )

Decem ber 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 DivisionThis page intentionally left blank.ICR for 2011 DWINSA i December 8 , 20 10 

## 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 Re spondent 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 Statis tical Approach

................................ ................................ ................................ ....... 48

B.1.d Feasibility

................................ ................................ ................................ ....................... 49

B.2 SURVEY DESIGN

................................ ................................ ................................ ........................ 49

B.2.a Target P opulation and Coverage

................................ ................................ .................... 50

B.2.b Sample Design

................................ ................................ ................................ ............... 50ICR for 2011 DWINSA ii December 8 , 20 10 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 M ETHODS 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

................................ ................................ ................................ ............. 6 1

B.5.b Analysis

................................ ................................ ................................ .......................... 61

B.5.c Reporting Results

................................ ................................ ................................ ........... 61

2011 NAT IVE AMERICAN DWINSA

................................ ................................ ................................ ..... 63

Introduction

................................ ................................ ................................ ................................ ................. 63

B.1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES

...................... 63

B.1.c Statistical Approach

................................ ................................ ................................ ....... 63

B.2 S URVEY 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

................................ ................................ ................................ .......... 65ICR for 2011 DWINSA iii December 8 , 20 10 

## 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 NoticeICR for 2011 DWINSA iv December 8 , 20 10 

## 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

- F ront 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 Cos t 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

................................ ................................ ................................ ............... 54ICR for 2011 DWINSA 1 December 8 , 20 10 

## 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 nu mber 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 sys tems 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 aut horized 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 amo ng states.

While t he 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 o f “ g reen ”

i nfrastructure p rojects

, and consideration s 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 ar e within the context of the industry’s best engineering practices. EPA addresses the “ sampling

error ” by identifying and specifying statistical precision targets for the s urvey and determining the necessary sample and sub

- sample sizes to achieve those targ ets. It is important to note that while greater statistical precision can be achieved by increasing the size of the sample to be survey ed , the additional burden that a larger sample size creates for collecting data and assuring its quality can result in

su bstantially 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 meas urement errors as well as to minimize the burden placed

on the s tates

, water systems , and t he 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 , 20 10 All states and the Navajo Nation have committed to help EPA administer the 2011 DWINSA with at least

the minimum of act ivities. 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

, the re 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 ” refer s 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 Alaska n Native Village water

systems (e.g., 2011 Native American DW INSA) . 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 w ill 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 Nativ e 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 system s 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 add itional 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 states 3 , 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 sy stem 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 , 20 10 

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

A.2.a Authority and Need for the Collection

EPA (t he 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, sha ll, 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 Region s (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 r eal 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

con nections, 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 climat e 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 u se all data collected to estimate state and nationa l needs

. Th is will be the first time EPA will collect information for “green” and climate readiness infrastructure projects.

R espondent s 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 allow ability.

R espondent s 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 exam ple, 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 person s , many of the systems that serve 3,301

– 10 0 ,000 persons , and almost all of the systems serving 3,300 and fewer (for the 2011 Native American DWINSA only) . For the 200 7 DWINSA, approximately 1 9 percent of the projects reported had documented costs ; t he co sts for the remaining 8 1 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 theICR for 2011 DWINSA 4 December 8 , 20 10 development of general enforcement strategies and new regulations. Congress may us e 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 cap acity development strategies. The public may use information on costs associated with SDWA compliance.ICR for 2011 DWINSA 5 December 8 , 20 10 

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

The following se ctions 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 stat e

- 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). I nventory data and information on syste m 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 i f 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 200 6 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 a spects 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

. T herefore

, the EAs are not an adequate substitute for the DWINSA. In addition, the EAs p rovide 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 a vailable 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 t he 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 , 20 10 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 Alaska n 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 t his ICR ( 75FR55324 ). This notice is included in Appendix A. Before submission to OMB,

EPA consider ed any comments received and determine d if any adjustments were needed to the burden and cost calculations or to the supporting statement for this ICR. Commen ts received and EPA ’ s

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

ICR i s 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 H eadquarter s , EPA R egional, 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 purpose s of the meetings w ere to gather information on state , Native American, and/or regional concerns ; to discuss lessons learned during

the 200 7 DWINSA ; and to discuss new policies for the 2011 DWINSA. The 2011 Native Am erican 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, i n 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 conduct ed a limited peer review of these new questions. The peer rev iew include d experts familia r 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 inf ormation 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 , 20 10 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.

**•** Comple te 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 a nd 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 informati on 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 i nformation 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 , 20 10 This page intentionally left blank.ICR for 2011 DWINSA 9 December 8 , 20 10 

## 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, t ribal 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 leas t 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”
( n on transient n on c ommunity 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” ( t ransient

n oncommunity water system). The North American Industry Classification System (NAICS) code for a public water system is 22131 0. For g overnment establishments providing public administration of

American Indian and Alaska n 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 oth er 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 g ather 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. S urveying all of these systems would impose a large burden on respondents, EPA, and states

. Therefore, EPA will select a statistica lly 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

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

American Indian and Alaska n 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 Marian a 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 , 20 10 A.4.b Information Requested

As previously discussed, EPA will collect th ree 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 DWINSA s , 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 on

site engineering reviews.

A.4.b.i Data Items

2011 State DWINSA

– Systems serving more than 3,300 person s

The da ta 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 sy stem 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 cor rect the information provided.

In addition, t he respondent is asked to provide information on tables associated with specific types of projects:

**•** Source.

**•** Treatment.

**•** Finished or Treated Water Stor age, Pumping

, and Other.

**•** Tra nsmission and Distribution.

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

Meters , and O ther

.

For each project, the respondent is asked to:

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

“ fil tration plant upgrade, ” “ high service pump replacement, ” “ c orrosion control treatment,” orICR for 2011 DWINSA 11 December 8 , 20 10 “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 1 5

– Develop separate cost estimates for source water treatment, transmission, storage, distribution, and other needs. (EPA will disaggregate the costs when p rojects 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 informati on 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 inf rastructure ( 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 deter mine 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

reg arding 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 m odels 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 numbe r 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 , 20 10 because they will allow EPA to account for differences in the value of money over differ ent 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., pl anning 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 replace ment or rehabilitat ion 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 collecti on 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. Th is 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 do cuments.

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 corr ecting 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 200 7 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 E PA 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 sys tems. 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 Alaska n Native Village Water Systems

To minimize the burden on American Indian a nd Alaska n 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 system s 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 , 20 10 The data coll ection 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 anti cipated 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 document ation. 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 a mount 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 Alaska n Native Village Water Systems

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

American Indian and Alaska n 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 describe s the purpose of the DWINSA.

**•** Answer basic questions posed by the EPA Regional Offic e 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 theICR for 2011 DWINSA 14 December 8 , 20 10 participating states will be used to determine an average need per strata . This will be applied to the inventory of systems i n 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 additi on, 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

r eviewed. Such data include s 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

syst em 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 DWIN SA 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 DWINS A:

– 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 th e
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 , 20 10 – Call systems that do not re turn 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 instrument s 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 system s 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 p repare
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 d ata 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 activit y , 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 , 20 10 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 DWIN S A to ensure participation and to schedule time to discuss the systems 20

- year need and review the complete d 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 DWIN S A

data collection instrument.

– Disc uss 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 c onfiguration, 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 syst em 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 ch eck 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 , 20 10 

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

MA NAGEMENT

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 p urposes 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 contra ctor ’ 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 DWINSA s 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 Na vajo

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 DWIN S A respo ndents. 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 200 7 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 system s that are selected to participate in the 2011 State DWI NSA, 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 Navaj o Nation.ICR for 2011 DWINSA 18 December 8 , 20 10 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 system s (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 all owable

.

**•** 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 DWIN S

A

EPA Regional Offices will help EPA Headquart ers 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

p articipating 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 co nnections, 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 activitie s. 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 , 20 10 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 DWIN S A 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 DWIN S A

data collectio n instrument.

– Discuss 20

- year need. EPA Regional Offices will contact the water system s and discuss projects that have been identified, ask basic questions about the physical design of the plant, system configuration, and capital needs, and request additi onal 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 as surance / 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

conduct ing 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 20 11 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 H eadquarter s , EPA R egional , tribal , and state representatives. The 2011 DWINSA approach and many of the r efinements to the data collection instrument were based on experience in conducting the 1995, 1999, 2003, and 2007 DWINSAs. In addition, EPA conduct ed a
limited peer review of the 2011 DWINSA data collection instrument. In developing the 2011 DWINSA,

EPA w ill 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 need s to meet the 2011 DWINSA objectives.ICR for 2011 DWINSA 20 December 8 , 20 10 Methodology for 2011 State DWINSA

– CWSs serving more than 3,300 persons

Most systems serving more than 10 0,000 persons have CIPs or similar documents that summarize their

needs. Therefore, t hese systems are g enerally 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 indicate s that systems serving 3,301

– 10 0,000 persons can reliably complete a data
collection instrument, if techni cal 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 2 011 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. S tates will provide technical support to the systems participati ng 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. T he state will then forward the data collection instrument and supporting

documentation to EPA for review and data entry. EPA will perform a second quality ass urance / 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 veri fy 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 Alaska n 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 Alaska n Native Village water system s . To ensure that all appropriate systems are addressed, EPA Regional Offices and the Navajo Nation will r eview 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 c ollection 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 a ssurance / 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 . IfICR for 2011 DWINSA 21 December 8 , 20 10 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 c osts for American Indian projects will be assigned using the models developed for the overall 201 1 State DWINSA. The costs f or Alaska n Native Village projects will

be modeled using the cost model s 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 poss ible 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

R egions, EPA H eadquarters, 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 eac h 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 R egional , and Navajo Nation staff invo lved in the 2011 DWINSA. The r egional 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, tran smission, 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 r egional 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 i nformation to the EPA Region s , 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 staf f will refer questions that raise a policy or technical

issue to EPA staff.ICR for 2011 DWINSA 22 December 8 , 20 10 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 ade quate 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 project s
without a cost estimate will be modeled by EPA

.

**•** Provide an estimate of the tota l 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 docu mented (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 receip t 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 wil l 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, a ll 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

acco mpanying 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 wi ll 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 o ut 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 , 20 10 **•** Data systems. EPA updated a W eb

- based data system for th e 200 7 DWINSA that will be used

for the 2011 DWINSA. The W eb

- 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 reasonablene ss 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 unjustifi able 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. Ho wever, 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 res ources 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 D WINSA adjusted to 2011

d ollars

. F or 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 m ore than 10,000 persons) and will select a random sample of

American Indian and Alaska n 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 , 20 10 A.5.d Collection Schedule

The current schedule assume d EPA would receive OMB approval for data collection by December
1, 20 10

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

instruments to drink ing water systems as soon as possibl e after OMB approval . All systems participating

in the 2011 DWINSA will be asked to complete and return the data collection instruments to the ir state within 1 month of receipt.

To facilitate efficient data entry at EPA H eadquarters, EPA will ask the state s 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 20 10

States Submit to EPA Contact Information to be Included on Return

FedEx Labels By December 20 10

Training Sessions for States, EPA Regions , and the Navajo Nation October 20 10

Mail Out of Data Collection Instruments to Selected Systems or to EPA Regions a nd 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 20 12

All Information in the Data System Finalized February 2012

Report to Congress Due February 2, 2013ICR for 2011 DWINSA 25 December 8 , 20 10 

## 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 bas i s
for t he burden estimates are detailed below

.

2011 State DWINSA

– CWSs Serving More Than 5 0,000 Persons

The respondent burden for the systems serving more than 5 0,000 persons consists of systems ’ burden for completing the data collection instrument. EPA estimate s 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 hour s ). EPA a nticipates 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 s for technical staff.

**•** Read cover letter/data col lection 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 estimate s that it will take 1.5 hour s 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 , 20 10 – About 50 percent of the questions will be “ straight forward ” 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).

T hus, 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 pro vide 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 staf f. Thus,

the tota l unit burden is approximately 4.3 3 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 3.0 3 1.00 4.3 3

TOTAL 0.9 25 6. 49 5 3.00 10. 42

2011 State DWINSA

– CWSs Serving 3,30 1

– 50,000 Persons

Exhibit A

- 6

- 2 shows the unit burden for 1,936 systems serving 3,30 1

– 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 cov er 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 , 20 10 – Technical staff will read the cover letter and data collec tion 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, s ystems serving 3,30 1

– 50,000 persons typically have less documentation than larger CWSs. Therefore, EPA estimate s that it will take 1.0 hour at 50 percent of the systems, 2.0 hour at 25 percen t 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 hr s /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 es timate 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 ho urs) 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 , 20 10 Exhibit A

- 6

- 2 Estimated Unit Burden for Systems Serving 3,30 1

– 50,000 Persons

Activity Estimated Bu rden (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 2.0 3 2. 50

TOTAL 1. 095 4. 7 15 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 Alaska n Native Village Water Systems

To minimize the burden on American Indian and Alaska n 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 t he 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

Alaska n 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 an swer 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

rema ining 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 anticipa ted that these systems will have little onsite documentation and that the EPA Regional or Navajo Nation personnel will develop the

documentation ; t herefore

, the burden to the system is relatively small. EPA estimate s that 25ICR for 2011 DWINSA 29 December 8 , 20 10 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 Alaska n 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 i s not discussed in this section; however, they have the same role as the Navajo Nation. EPA Regional Offices’ burd en 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. Stat es 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 w ater 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 lea st at this

level. The unit burden estimates are consistent with what was found to be true in the 200 7 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 num ber 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 t he activity categories.ICR for 2011 DWINSA 30 December 8 , 20 10 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 3,30 1

– 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 b urden 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 sampl e will require approximately 12 minutes (0.2 hour s ) 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

- Fr ont Activities

Activity Estimated Burden

Participate in training and other pre

- mailou t 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 sy stems will be able to answer the questions on the data collection instrument, states will provide them with clarifyingICR for 2011 DWINSA 31 December 8 , 20 10 information as necessary. The state burden for activities associated with the systems serving more than
50,000 persons is summarized in E xhibit A

- 6

- 6, which follows the activity descriptions.

**•** Telephone systems to ensure participation. EPA estimate s that this preliminary phone call will take about 15 minutes (0.25 hours) per system.

**•** Provide technical assistance. In developing a burden estima te for this analysis, EPA ma d e 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 c all at all .)

– Of those that do require technical assistance, about 50 percent of their questions will be

“ straight forward, ” requiring only 15 minutes (0.25 hours) to answer.

– About 25 percent of their questions will entail limited research and follow

- up, req uiring 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 technica l 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 sy stems 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 quit e 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 hour s 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 collect ion instruments , EPA made the following assumptions:ICR for 2011 DWINSA 32 December 8 , 20 10 – 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 3,30 1

– 50,000 Persons

This section estimates the state burden for helping EPA conduct the 2011 State DWINSA for systems serving 3,30 1

– 50,000 persons by telephoning systems to ensure participation, calling back systems that

did not return the d ata 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 3,30 1

– 50,000 persons is summari zed in Exhibit A

- 6

- 7, which follows the activity descriptions.

**•** Telephone systems to ensure participation. EPA estimate s 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 mad e 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 reques ts more than once.)

– Of those that do require technical assistance, about 50 percent of their questions will be

“ straight forward

, ” 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 , 20 10 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

in strument will be returned directly to the state for review. For states, this is the most burdensome part of the 2011 DWINSA and the b urden 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 sy stem.

**•** Discuss results with EPA. To estimate the state burden f or resolving questions on completed

data collection instruments , EPA made the foll owing 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 3,30 1

– 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 6.25ICR for 2011 DWINSA 34 December 8 , 20 10 State Burden for CWSs S erving 3,300 and F ewer P ersons

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 d iscussing 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 select ed sys tems 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 burd en 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 min utes (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

t he documentation of need for the system. EPA estimate s 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 assumptio ns:

– 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 , 20 10 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 cost s 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 $2 6.05 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 200 9 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

Cost Manage ment Technical Clerical

Systems Serving

More Than
50,000 Persons 0.9 25 6. 495 3.00 916 9,544 $37.56 $ 358,473

Systems Serving
3,30 1

– 50,000

Persons 1. 095 4.7 15 1.00 1,936 13,184 $31.30 $ 412,659

American Indian

and Alaska n
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 , 20 10 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

. T he 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 participa te 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

infl ated to year 200 9 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

S tates/ Systems Unit Burden Total

Burden (hours) Hourly

Rate Total Cost

Up

- front 5 7 7 110

hours/state & Navajo Nation 6,270 $41.36 $ 259,327

2,892 8 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 4 0 7.42 hours/system 297 $41.36 $ 1 2
, 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 Am erican 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 th e Navajo Nation primacy agency.ICR for 2011 DWINSA 37 December 8 , 20 10 A.6.c Agency Burden and Cost

The Agency burden and cost reflects the burden and cost directly incurred by EPA H eadquarters

, EPA Region s , 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 e xhibits distribute burden/costs among Fiscal Years 2010

, 2011

, 2012 , and 2013 , reflecting that Agency and contractor act ivities will vary substantially over the 4

- year period.

EPA made the following assumptions in developing its estimate of Agency and contractor burden and

cost 9

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 . Assum ing 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. 3 8 FTE per year) providing support to the 2011 Native American DWINSA. Assuming 2,080 hours per year, this equates to 3,127 h ours.

**•** 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 3 6

, 510 hours of direct labor.

9 Hourly rates are from U. S. Office of Personnel Management, 20 10 General Schedule (GS) Locality Pay Tables ( http://opm.gov/flsa/oca/10tables/indexGS.asp ) and overhead rates are from Information Collection Request for

Publi c Water Supply Program , December 20, 1993.ICR for 2011 DWINSA 38 December 8 , 20 10 **•** The EPA contractor(s) will provide this professional labor at a total hourly rate, including all applicable indirect costs, of $ 7 8 .0 6

.

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 an nual 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, 59 9 $86, 506 60 $4,547 2, 5 51 $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 $ 2 39,292

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 $ 783,817ICR for 2011 DWINSA 39 December 8 , 20 10 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

, 7 29 $ 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 1 7
, 918 $1, 398
, 679 8,642 $ 674,595 3,210 $ 250,573 36,510 $ 2,849,971ICR for 2011 DWINSA 40 December 8 , 20 10 A.6.d Estimating Respondent Universe and Total Burden and Costs

Respon dents 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 5 6 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

- 1 4

.

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 th at 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 $ 8 8 $ 4 87 0 $0ICR for 2011 DWINSA 41 December 8 , 20 10 Exhibit A

- 6

- 15 summarizes the bottom line burden hours and costs for EPA for this collection. The total

burden for EPA (including EPA Region al 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, t ribal owned CWSs and NPNCW S s, state government agencies and tribal authorities (the Navajo Nation)

.ICR for 2011 DWINSA 42 December 8 , 20 10 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 77 3

10.42 8, 0 54

$37.56 $ 302,508

$391 Private/Investor Owned CWSs 105 1, 094 $ 41
, 091

State Owned CWSs 38 396 $ 1 4
, 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

$213 Private/Investor Owned CWSs 173 1,178 $ 36,871

State Owned CWSs 27 184 $ 5,759

Tribal Owned CWSs & NPNCWSs 75 3.25 2 44 $ 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 2 31 751 $ 23,506

Subtotal 2 31 751 $ 23,506

Total Water System Respondents

Publicly Owned CWSs 2, 509 7.9 2 19
, 876 $ 672,537 $ 2 68

Private/Investor Owned CWSs 278 8. 17 2, 272 $ 7 7
, 962 $ 2 80

State Owned CWSs 65 8

. 92 580 $ 2 0
, 633 $ 3 17

Tribal Owned CWSs & NPNCWSs 306 3.25 995 $ 31,144 $ 102

Subtotal 3,158 7.51 23,723 $ 802,275 $ 25 4ICR for 2011 DWINSA 43 December 8 , 20 10 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, 3 59

Total Tribal Authority Respondents 1 4 15 .00 415 $ 17
, 164 $ 1 7

, 164

Total Respondents 3,215 15.24 48,995 $ 1,847,525 $ 57 5
Note: Numbers may not total due to rounding.ICR for 2011 DWINSA 44 December 8 , 20 10 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 require s 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 readine ss” 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 Navaj o 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 de veloping 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 resourc es 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 requi rements, 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 nee d 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, Atten tion: 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 , 20 10 

## 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 tha n 3,300 persons as was used in the 200 7 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 , 20 10 This page intentionally left blank.ICR for 2011 DWINSA 47 December 8 , 20 10 

## 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 Natio n, 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 participatin g 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 prop oses to collect information on the cost of systems’ infrastructure needs

. I f 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 id entify 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

als o 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 stat es and as part of an

allotment formula for the DWSRF TSA P rogram.

EPA is proposing the same methodology as used in previous DWINSA s

. No significant changes were

made for the 2011 State DWINSA from the approach used in 200 7 . 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 capacit y, 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 , 20 10 Information on capital needs will be collected from responde nts 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,

rehab ilitate 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 c urrent 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 L ists of C odes. 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 s electing a code from

List 3 in the List s of Codes. In addition, the data collection instrument include s additional questions for systems that include climate readiness projects i n 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 20 11

– 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 T SA 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 part icularly 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 th e 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 us ed 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 pre cision.

The 2011 State DWINSA design divides CWSs serving populations of more than 3,300 into two groups:

CWSs serving populations of more than 10 0,000 , and systems serving populations of 3,30 1

– 10 0,000. 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 se rving 3,30 1

– 100,000 persons . This methodology can reduce burden and still achieve the DWINSA data quality objectives. To meet the state

- level precisionICR for 2011 DWINSA 49 December 8 , 20 10 targets, EPA will first determine the total sample size for each state to meet the target level of pre cision. 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

.

- Oversig ht 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 pr ojects. In those cases, the 2011 DWINSA data collection instrument requests other readily

available 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 th e 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 technolog y.

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

- tes t

, collection methods, and follow

- up procedures.ICR for 2011 DWINSA 50 December 8 , 20 10 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

a n 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 sy stems. 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 : 3,30 1

– 10,000; 10,00 1

– 25,000 ; 25,00 1

– 50,000 ; 50,00 1

– 100,000 ; and populations of more than 100,000), and primary source s 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
3,30 1

– 100,000 is set to meet the 2011 DWINSA ’ s data quality objectiv es.

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 wi ll 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 p opulation 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 d esigned to produce estimates of the capital need of systems serving more than 3,300 persons for each participating state. In non

participating states, EPA will be able to provide state specific results for systems serving 100,000 or more

persons

. EPA will include a n 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 d esigned 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 des ign 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 , 20 10 B.2.b.i Sampling Frame

The sampling frame is developed from SDWIS. SDWIS is a centra lized 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 nu mber ( 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 th e 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, sho w 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 fram e, 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, t hey often have in

- house data systems with very accurate data. Even if these data areICR for 2011 DWINSA 52 December 8 , 20 10 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 p ersons . 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 re quirements. The sample size is given by:

g H

h gh gh

g 

## V s N

n 2

1

0 

##  ** **  ** **  ****

**=** 

# ∑

**=**

Where: n 0g = the sample size (prior to the finite population correction)

N gh = the total number of systems in the h th stratum in the g th state (taken from SDWIS)

s gh = the standard deviation of the variable of interest for the h th stratum in the g th state (estimated using data from the 200 7 DWINSA)

H = the number of strata defined in the sample design for the g th state

V g = the desired sampling variance for the tota l 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, V g = (d/Z

α * g 

### Y ˆ ) 2

.

g 

### Y ˆ is an estimate of the total capital needs for a given state. g 

### Y ˆ is computed for each state by calculating the mean total capital needs for stratum h (from the 200 7 DWINSA) and mult iplying by the actual number of systems in each stratum for that state (N gh ). Summing across strata provides an estimate of g 

### Y ˆ

. d is the half

- width of the desired confidence interval (0.10 for the Assessment). Z

α is the value of a

standard normal distribution for a confidence level of 1

- α, (1.96 for the Asses sment).ICR for 2011 DWINSA 53 December 8 , 20 10 Because the number of water systems is known and finite, the following population correction is applied:



# ∑

**=** 

### + **=** H

h gh gh

g g

g



### s N 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 e ach of these strata. The Neyman allocation formula is used for the allocation: 12



###  ** **  ****

** ** 

** **  ** ** 

** ** 

**=** 

# ∑

**=** H

h gh gh

gh gh

g gh



### s N s N

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 V g , N gh , s gh , and mean total capital needs by stratum. Information on mean total capital needs by stratum and

s gh were estimated using data from the 200 7 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, Samplin g Techniques (New York: John Wiley & Sons), 1977.ICR for 2011 DWINSA 54 December 8 , 20 10 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 1ICR for 2011 DWINSA 55 December 8 , 20 10 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 3 5 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 )

. H owever , those states that have systems that serve more than 100,0 0 0 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 state s, t he number in

the “ Estimated Sample Size for Systems Serving More Than 3,300 Persons ” represent s the total number of systems in the state
that serve more than 100 ,000 persons

.ICR for 2011 DWINSA 56 December 8 , 20 10 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 precisio n) 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 samp ling, 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 estim ate 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 e stimate 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 sourc e (ground water and surface water). 13

Size of Population Served Using total capital need information

obtained from the 200 7 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 2011 State DWINSA ’ s overall precis ion is not reduced. The proposed strata for systems serving more than 3,300 persons are as follows:

Source Sample Methodologies

3,30 1

– 10,000 Ground Random sample.

3,30 1

– 10,000 Surface

10,00 1

– 25,000 Ground Random sample. In some states the number of strata will be reduced based on analysis of optimal stratum boundaries

. Specifically, i n some states systems serving between 10,001 and 50,000 will be in one group rather than two. 10,00 1

– 25,000 Surface

25,00 1

– 50,000 Ground

25,00 1

– 50,000 Surface

50,00 1

– 100,000 Ground Random s ample

50,00 1

– 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 3,30 1

– 100,000 persons, all CWSs will be allocated to eight strata, based on population served and primary source. The sample size f or 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 , 20 10 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 3,30 1

– 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 billio n 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 rate s . 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 i nstead 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 partic ipated 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 believe s that the average water system respondent can complete the data collecti on instrument in approximately 7.51 hours.

**•** Toll

- free phone numbers will be provi ded 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 , 20 10 **•** Pre

- paid return envelopes will be provided to respondents to make returning the data collectio n
instrument convenient.

Standard methods to reduce other sources of non

- sampling error also will be used :

**•** EPA expects complete coverage of the target population usi ng SDWIS, supplemented by state

agency /Navajo Nation/EPA Regional Office review of all syst ems.

**•** 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 elimina te 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 organizat ions 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 rate s and low item non

- response. P ersonnel

who work with water systems every day are in a strong position to encour age 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 w ill 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 fo r the 2011 DWINSA can be helpful in many ways to minimize non

- sampling errors. For example,

– In past DWINSAs, national water associations sent letter s to each system in their membership, stressing the importance of surveying d rinking water infrastructure ne eds.

Th ese letter s , 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

— provide d support through its national organization. To improve the response rate, the AWWA enlisted the support of its stateICR for 2011 DWINSA 59 December 8 , 20 10 affiliates (called “ Sections ” ) to conduct telephone follow

- up calls to encourage resp onse. 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

wil l 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 th e 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 a ccurate 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, an d 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 a mbiguous 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

- TEST S AND PILOT TEST

B.3.a Pre

- test s

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

- participati ng 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 inICR for 2011 DWINSA 60 December 8 , 20 10 these states they were able to reduce costs. The names of t he 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

co llecting 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 L ists of C odes 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 realize s that this is an ambitious tar get, 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 200 7 surveys, respectively. In the first four surveys, EPA

conducte d 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, a ll national organizations will be contacted by EPA to seek their

endorse ment 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 endor se participation in the

DWINSA ; for the 2011 Surve y, 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

p rocedures includ ing the us e 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 , 20 10 

### B.5 ANALYZING AND REP ORTING 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 th e 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 Sta te 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. Exa mples 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 erro rs 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 thr ough EPA’s Safe Drinking Water w ebsite

.

**•** Desktop computer a ccess to state /Nav ajo Nation data on the DWINSA Web site without modeled project costs (each state /Navajo Nation can access only its own data).

**•** Desktop computer a ccess 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 , 20 10 This page intentionally left blank.ICR for 2011 DWINSA 63 December 8 , 20 10 

## 2011 NATIVE AMERICAN DWINSA

Introduction

In the following paragraphs, we present information on the survey of Ameri can 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 India n 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

. E xperience with mail surveys for these systems suggests that total non

- response and item non

- response would be very high. Also, EPA believe s 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 201 1 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 t wo 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 (p opulations of: 25

– 500; 501

– 1,000; 1,001

– 3,300; 3,301

– 10,000; and populations of more than 10,000), and primary source s 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

con nections used by year

- round residents or regularly serves a t 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” ( n on transie nt 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” ( t ransient noncommunity water system). (40 CFR 141.2)ICR for 2011 DWINSA 64 December 8 , 20 10 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 sam ple

size will be selected instead of s tate

- by

- s tate 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 wat er 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

outlin ed 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 rat e 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 , 20 10 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 o f 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 record s

. 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 c onducting the survey in this manner for American Indian and Alaskan Native

V illage water systems

, the information collection burden on the se water system respondents will be

minimized

.ICR for 2011 DWINSA 66 December 8 , 20 10 This page intentionally left blank.ICR for 2011 DWINSA December 8 , 20 10 

## Appendix A Public Notice Required Prior to ICR Submission to OMBICR for 2011 DWINSA December 8 , 20 10 This page intentionally left blank.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


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 communitywater 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


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


## Appendix B
Data Collection Instrument and Lists of CodesICR for 2011 DWINSA December 8 , 20 10 This page intentionally left blank.EPA Form 6100-01109/20/20102011 Drinking Water InfrastructureNeeds Survey and AssessmentU.S. Environmental Protection AgencyWashington, DC 20460Please verify or correct the following information:Check if Correctas PrintedCorrected Information(Fill in only if preprinted information is missing or incorrect)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 systemssold to):Number of Connections (not including those in consecutive systems):Total System Design Capacity: ____________ MGDSource Water Type (Ground,Surface/GWUDI, etc.):Check All That Apply:GroundSurface/GWUDIPurchased GroundPurchased Surface/GWUDIOwnership Type:Check All That Apply:PublicFederal GovernmentNative AmericanInvestor-Owned or PrivateNon-ProfitPublic reporting burden for this collection of information is estimated to average 7.51 hours per response. This estimate includes time for reviewing the instructions,searching existing data sources, gatheringand maintaining the data needed,and completing and reviewing the information collected. Burden means the total time, effort, or financial resources expended by person(s)to generate, maintain, retain, ordisclose 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; adjust the existing ways tocomply with any previously applicable instructions; search data sources; complete and review the collection of information; and transmit orotherwise disclose the information. An agency may not conduct orsponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. TheOMB 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 burden, including through the use ofautomated collection techniques to the Director, OPPI, Regulatory Information Division,U.S. Environmental Protection Agency (1804A), Ariel Rios Building, 1200 Pennsylvania Ave., NW, Washington, DC20460; and Office of Information and Regulatory Affairs, Officeof Management and Budget, 725 17th Street, N.W., Washington, DC20503.State Use OnlyState Reviewer: ___________________________________________________________________________________Telephone Number: __________________________Information provided for this survey can be requested by the public. It is our experience that survey information is rarely requested.OMB No.:Approval Expires:Federal PWSID No.: ____________EPA Form 6100-01209/20/2010Source, Treatment, Storage, and Pumping InventoryTo ensure all potential source, treatment, storage, and pumping projects are considered, it may be helpful to complete some orall of this inventory table. However,completion of this table is not required.Source WaterInventoryNeeding ReplacementNeeding RehabilitationNew Infrastructure NeedsTotal Number and Capacity of ExistingWells or Springs:Wells (pumps included) or Springs:Wells (pumps included) or Springs:Does your system have additional source watercapacity needs to meet the needs of currentusers? (check one)Yes ___No ___ ______Total Number and Capacity of ExistingSurface Water Sources:Existing Surface Water Intakes (excludingpumps):Existing Surface Water Intakes (excludingpumps):If yes, how many additional sources arenecessary? And what are the design capacities?Total Number and Capacity of ExistingPumps (excluding booster pumpstations):Existing Groundwater Pumps (if wells notlisted):Existing Groundwater Pumps (if wells notlisted):Existing Raw Surface Water Pumps:Existing Raw Surface Water Pumps:TreatmentInventoryNeeding ReplacementNeeding Expansion/Upgrading orRehabilitationNew Infrastructure NeedsFor the sources identified above, enterthe number of locations where the following treatment is applied:Disinfection (including boosterdisinfection):Disinfection:Disinfection:Does your system have additional treatmentneeds for provision of additional public healthprotection or for aesthetic concerns? (check one)Yes ___ No ___If yes, what additional treatment is necessary?Filtration:Filtration:Filtration:Chemical removal or addition:Chemical treatment:Chemical treatment:Storage and Pump StationsInventoryNeeding ReplacementNeeding RehabilitationNew Infrastructure NeedsTotal Number and Capacity of ExistingStorage Tanks:Number of Existing Storage Tanks:Number of Existing Elevated or Ground-LevelStorage Tanks:Does your system have additional storagecapacity and/or booster pumping needs to meetthe needs of current users? (check one)YesNo _If yes, how much additional finished waterstorage or booster pumping capacity isnecessary?Total Number and Capacity of ExistingBooster Pump Stations:Number of Existing Booster Pump Stations:Number of Existing Booster Pump Stations:Source Projectsare all projects related to collecting and pumping raw water.This includes wells, surface water intakes, springs, off-streamraw water storage, pumps, and wellhouses.Treatment Projectsare all projects related to disinfection, filtration, or othertreatment processes for ground or surface water sources, or fortreatment applied in the distributionsystem.Storage and Pumping Projectsare related to finished or treated water storage, and booster pump stations.EPA Form 6100-01309/20/2010Source, Treatment, Storage, and Pumping ProjectsProjectNumberProject NameType ofNeed(List 1)Reasonfor Need(List 2)New,Replace,ReHab,Expand/upgradeCurrentorFutureReg orSecondaryPurpose(List 3)DesignCapacity(MG,MGD,kW)NumberNeeded(ifapplicable)CostEstimate(if available)Date ofCostEstimate(Month/Year)Documentation(List 4)Ex. 1Replace Wells 3 and 8at 0.5 MGD eachR1 A1 R C 4A 0.5 2 - - 6, 10Ex. 2Rehab Treatment Plant andBooster StationT10, P2 A1,A6 H F 1A 5.0 1 $6,027,000 12/2009 410001001100210031004100510061007If 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 (included i n t his package ordownloadable at www.DWNeeds.com). Project numbers for these types of projects are 1000-1999, and should be numbered in sequence.EPA requires documentation of all projects provided. Applicable types of documentation are presented in List 4 of the Lists ofCodes.Use only existing documentation of cost. Wedo not expect you to develop new cost estimates.EPA Form 6100-01409/20/2010Transmission and Distribution InventoryOn the table below, please provide an estimate of the total feetor miles of pipe in your system, if possible. Completion of this table is not required, but it may behelpful 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 aresubmitted based solely on survey-generated documentation (documentation codes 10 or 11).______________Total feet or miles ofpipe in system(Circle orunderline feet or miles)Total Pipe in System(Circle or underline feet or miles)<=6 inch8-12 inch15-42 inch> =48 inchPlastic________Feet or miles Amount of PVC by pipe size ________feet ormiles________feet ormiles________feet ormiles________feet or miles________% of total pipe% of this category/size pipe currentlyin poor condition or beyond usefullife________% ________% ________% ________%DuctileIron________Feet or miles Amount of ductile iron by pipe size ________feet ormiles________feet ormiles________feet ormiles________feet or miles________% of total pipe% of this category/size pipe currentlyin poor condition or beyond usefullife________% ________% ________% ________%Cast Iron________Feet or miles Amount of cast iron by pipe size ________feet ormiles________feet ormiles________feet ormiles________feet or miles________% of total pipe% of this category/size pipe currentlyin poor condition or beyond usefullife________% ________% ________% ________%AsbestosCement________Feet or milesAmount of asbestos cement by pipesize________feet ormiles________feet ormiles________feet ormiles________feet or miles________% of total pipe% of this category/size pipe currentlyin poor condition or beyond usefullife________% ________% ________% ________%Other________Feet or miles Amount of other by pipe size ________feet ormiles________feet ormiles________feet ormiles________feet or miles________% of total pipe% of other currently in poorcondition or beyond useful life________% ________% ________% ________%Transmission and distribution projectsare the piping needs of a water system.Projects for valves,backflow prevention devices and assemblies,hydrants, and metersthat are not part of a transmission or distribution project listed in this table should be recorded in the table on page 6.EPA Form 6100-01509/20/2010Transmission and Distribution ProjectsProjectNumberProject NameType ofNeed(List 1)Reasonfor Need(List 2)New,Replace,orReHabCurrentorFutureReg orSecondaryPurpose(List 3)Diameterof Pipe(Inches)Length ofPipe(Feet)CostEstimate(if available)Date of CostEstimate(Month/Year)Documentation(List 4)Ex. 1Cleaning and Lining Old CastIron Mains M1 A1 H C 4A 12 18,000 - - 11Ex 2Replace DeterioratedTransmission Main X2 A1 R C 4A 24 20,000 $4,200,000 06/2008 120002001200220032004200520062007If a project is coded 2G for “climate readiness” fromList 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 packa ge or d ownloadable atwww.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 List 4 of the Lists ofCodes.Use only existing documentation of cost. We do not expect you to develop new cost estimates.EPA Form 6100-01609/20/2010Meters, Service Lines, Backflow Prevention Devices/Assemblies, Hydrants, Valves, etcInventoryNeeding ReplacementNew Infrastructure NeedsTotal Number of Existing Water Meters:Number of Water Meters:Number of Water Meters:Total Number of Existing BackflowPrevention Devices/Assemblies:Number of Backflow PreventionDevices/Assemblies:Number of Backflow PreventionDevices/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:ProjectNumberProject NameType ofNeed(List 1)Reasonfor Need(List 2)New,Replace,orReHabCurrentorFutureReg orSecondaryPurpose(List 3)Size(Diameterin Inches)NumberNeededCostEstimate(if available)Date of CostEstimate(Month/Year)Documentation(List 4)Ex.1 Replace Lead Service Lines M2 A6 R C 1D- 100 $100,000 05/2010 9, 1130003001300230033004Projects for meters, service lines, backflow prevention devices and assemblies, valves, hydrants and other miscellaneous projects are recorded in thissection to accommodate entries of multiple identical items on one line in the project table.Record only projects that are not a part of another project(e.g., water main replacement projects will alreadyinclude valves, hydrants, and other appurtenances).EPA requires documentation of all projectsprovided. Applicable types of documentation are presented in List4 of the Lists of Codes. Use only existing documentation ofcost. We do not expect you todevelop new cost estimates.EPA Form 6100-01709/20/2010ProjectNumberProject NameType ofNeed(List 1)Reasonfor Need(List 2)New,Replace,orReHabCurrentorFutureReg orSecondaryPurpose(List 3)Size(Diameterin Inches)NumberNeededCostEstimate(if available)Date of CostEstimate(Month/Year)Documentation(List 4)3005300630063008If a project is coded 2G for “climate readiness” fromList 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 (included in this packa ge or download able atwww.DWNeeds.com). Project numbers for these types of projects are 3000-3999, and should be numbered in sequence.Climate ReadinessSupplemental QuestionsIf you used code 2G from List 3, in the “Regulation or Secondary Purpose” column of the survey, indicating that you have one ormoreprojects that are related to climate readiness, please answer the following questions. Only one response is requested; do not provide aresponse 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 readiness projects?(check all that apply)oSource water quality (e.g., water quality degradation affecting treatment processes, alternate sources, etc.)oSource water quantity (e.g., availability affected by snowmelt or weather patterns, or hydraulic patterns)oInfrastructure Vulnerability (e.g., facility locations affected by sea level rise, increased precipitation intensity)oOther (please explain)_______________________Please describe the data you are relying on to determine climate change consequences and implications.oModel developed from state-specific data.oModel developed from region-specific data.oOther (please describe)_______________________EPA Form 6100-01809/20/2010Respondent InformationPlease provide the following information in case we need to contact you for clarification or additional explanation of any of yourresponses.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 atwww.dwneeds.com) or call the U.S. EPAtoll-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 return this questionnaire andthe documentation to the address below? (See the pink enclosure for further return instructions.)Jane Q. OfficialDivision of WaterOne Capital StreetCapital, XX 99999Use these instructions and lists of codes when y ou fill out theNeeds Survey and Assessment questionnaire. In yourdocumentation please be sure to include project descriptions. Alsoinclude copies of the breakdown of cost estimates, if available.LIST 4 - DOCUMENTATIONCodeIndependent Documentation of Need and/or Cost1Capital Improvement Plan or Master Plan: The plan must addresswhy the project is needed and/or provide a cost.2Facilities Plan or Preliminary Engineering Report: Excerptsjustifying need and/or cost from the plan or report are acceptable ifproject-specific.3Grant or Loan Application Form: An application form is acceptable ifit specifically describes a problem requiring capital expenditures.4Engineer's Estimate or Bid Tabulation: These must be projectspecific and independently generated. They must also be accompaniedby an explanation of why the project is needed.CodeIndependent Documentation of Need Only5Intended Use Plan/State Priority List: The excerpts must include adescription of why the project is needed. Costs from IUPs will not beused - modeling parameters or other cost documentation must beprovided.6Comprehensive Performance Evaluation (CPE) or Sanitary SurveyResults: The results or recommendations may be used to justify needif the state concurs.7Monitoring Results: Monitoring results indicating an MCL exceedanceor a trending towards an exceedance can demonstrate a need for aproject if accompanied by a written statement explaining how the resultsdemonstrate the need.8Other Independent Document: Use this code if documentation isindependent but none of the codes listed above apply. Examplesinclude: state enforcement order/notice of violation, engineering studies,watermain break report, repair reports, and distribution system studies.CodeIndependent Documentation of Cost Only9Cost of Previous Comparable Construction: This may be used tojustify costs if the costs are project-specific. It must includedocumentation of how the costs were derived.CodeSurvey-generated Documentation of Need Only10Written by State:Brief description and statement of need written bystate.11Written by System:Brief description and statement of need written bysystem.Lists of Codes79-20-10Instructions for Each Column on the 2011 Drinking WaterInfrastructure Needs Survey and Assessment QuestionnaireThe following instructions apply to columns on all tables in the questionnaire.Column TitleInstructionsProject NumberNumber the projects in each category in sequence, using the rangeof numbers specified for each category of need.Project NameProvide a name that briefly describes and identifies the project.Type of NeedRefer to List 1 in the Lists ofCodes and enter the code(s) that bestidentifies the project. More than onecode may apply to a project if acost is provided. Use only one code if no cost is available.Reason for NeedRefer to List 2 in the Lists ofCodes and enter the code(s) that bestjustifies the project. More than onecode may apply to a project if acost is provided. Use only one code if no cost is available.New,Replace,Expand/Upgrade,orReHabilitateIdentify whether the project is for:-Newinfrastructure installation where none exists, enter ‘N’Resulting infrastructure is entirely new.-Replacementof existing infrastructure, enter ‘R’Existing infrastructure is replaced with new infrastructure.-Expansion or Upgradeof a complete treatment plant, enter ‘E’Major improvements to an existing complete plant. May addor change unit processes. May result in an increase incapacity. Use for complete treatment plants only.-Rehabilitationof existing infrastructure, enter ‘H’Restore existing infrastructure to near new condition.Current orFutureIdentify whether the project is:- Needed now, enterC=(even if you cannot start construction now)- Not needed now, enterF=(but will be necessary before 12/31/2030Regulation orSecondaryPurposeIf the project is needed to maintain or obtain compliance with aregulation, secondary MCL, or if one or more of the secondarypurpose codes (green or climate readiness) apply, refer to List 3 inthe Lists of Codes andenter the appropriate code. Enter ‘4A’ if nocode applies.Cost EstimateIf available, enter the documented cost estimate for this project.Use only existing cost estimates.If no cost estimate is provided andmodeling parameters are recorded, EPA will use models toestimate the cost.Date of CostEstimateEnter the month and year (MM/YYYY)of the cost estimate. EPA willadjust cost estimates to current-year dollars.DocumentationRefer to List 4 in the Lists ofCodes and enter the code(s) thatapplies to the type of documentationprovided that explains why theproject is needed. If a cost estimateis provided, also enter the codethat applies to the type of costdocumentation. More than one codemay apply to a project if a cost isprovided. Use only one code if nocost is available.Please enclose the appropriate pages of needand cost documentation, identified by project number.LIST 3REGULATION OR SECONDARY PURPOSECodeRegulation or Secondary PurposeEXISTING SDWA REGULATIONS1A Surface Water Treatment Regulations(Surface Water Treatment Rule, InterimEnhanced Surface Water Treatment Rule,Filter Backwash Recycling Rule, LongTerm 1 Enhanced Surface Water Treatment Rule, or Long Term 2 EnhancedSurface Water Treatment Rule)1B Total Coliform Rule (published June 1989)1C Nitrate or Nitrite Standard1D Lead and Copper Rule1E Arsenic Rule (10 μg/L Arsenic Standard)1F Stage 1 Disinfectants/Disinfection Byproducts Rule (for compliance with the 80μg/L for TTHMs and 60 μg/L for HAA5s as a runningannual average)1G Other Regulated VOCs, SOCs, IOCs,or Radionuclides (excludes Radon)1H Ground Water RuleOTHER REQUIREMENTS OR SECONDARY PURPOSES2A Secondary Contaminants (e.g., iron, taste and odor, and color)2B State Requirements2C Green – Green Infrastructure (e.g., porous pavement, green roofs, etc.)2D Green – Water Efficiency (e.g., meters, pressure reducing valves, etc.)2E Green – Energy Efficiency (e.g., pump rehab, VFDs, SCADA, etc.)2F Green – Environmentally Innovative (e.g., LEED buildings, etc.)2G Climate Readiness (e.g., source qualitydegradation, source quantity availability,or infrastructure vulnerability)PROPOSED AND RECENTLY PROMULGATED SDWA REGULATIONSNeeds associatedsolelywith the following proposedor recently promulgatedregulations are not allowable and shouldnot be included. The costs for theseneeds, estimated for each rule’s Economic Analysis, will be added to the totalnational need. These regulations include:****Stage 2 Disinfectants/Disinfection Byproducts Rule(for compliance with the 80 μg/L for TTHMs and 60 μg/L for HAA5s as alocationalrunning annual average)****Proposed Revisions to the 1989 Total Coliform Rule****Proposed Radon RuleIf None of the Above Codes Applies4A Use this code if noneof the codes above apply16LIST 2REASON FOR NEEDCodeReason the Project is NeededA1 Project is for existing infrastructure that is or will be old ordeteriorated by 12/31/2030.A2 Project is to correct a deficiency in source water quantity caused bycurrent user demand.A3 Project is to correct a deficiency in storage capacity caused bycurrent user demand.A4 Project is to correct existing pressure problems (not related to fireflow).A5 Project needed as a result of, but not in preparation for, a naturaldisaster.A6Project is to obtain or maintain compliance with anexistingregulation(enter the regulation code from List 3 in the Lists of Codesin the regulation column of the questionnaire).A7Project is to obtain or maintain compliance with asecondarystandard(e.g., iron, taste and odor, and color) (enter regulation code2A in the regulation column of the questionnaire).A8 Project is for consolidation with and/or connection to an existingpublic water system.A9 Project is for extending service to existing homes without adequatewater 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, communicationsequipment, analytical equipment)A11 Use this code if codes A1-A10 do not apply.The following instructions apply to columns on specific tables in the questionnaire.Column TitleInstructionsDesignCapacityOn theSource,Treatment,Storage, and Pumpingproject table enterthe design capacity when applicablemillion gallons per day (MGD) forsource, treatment, and pumping; million gallons (MG) for storage; andkilowatts (kW) for emergency power. For this survey, “design capacity”is the total volume or the flow that can be produced when allcomponents of the project are operating.Diameter ofPipeOn theTransmission and Distributionproject table enter the diameterof pipe (in inches) that must be rehabilitated, replaced,or installed asnew. Use a separate project number andline for different sizes of pipe.Length of PipeOn theTransmission and Distributionproject table enter the length ofpipe (in feet) that mustbe upgraded, replaced, or installed as new foreach diameter identified inthe previous column.SizeOn theBackflow Prevention Devices/Assemblies, Hydrants, ServiceLines, Valves, Water Meter, and Otherproject table enter the diameter(in inches) for infrastructure that must be upgraded, replaced, orinstalled as new. Use a separate project number and line for differentdiameters of the same type of need.Diameter is not needed for serviceline projects.NumberNeededOn theSource,Treatment,Storage, and Pumpingproject table indicatethe total number of components if youhave multiple identical projectsat the same capacity (e.g., rehabilitate 10 wells each with a 0.5 MGDcapacity).On theBackflow Prevention Devices/Assemblies, Hydrants, ServiceLines, Valves, Water Meterand Otherproject table indicate the totalnumber of components. For example, a future project to install four 8”diameter valves would include the size (diameter in inches) of thevalves and the number “4” would be entered as the number needed.If you use this column and provide a project cost, the cost shouldreflect the entire project (i.e.,all10 wells orall400 meters,notthe costof an individual well or meter).Important Notes:A description of each project or a copy of the documentation mustalso be clearly identified by project number and submitted with thecompleted questionnaire.Projectsprimarilyfor meeting expected future population growth orfor fire flow are unallowable.oWhat is a “need?”– Installation or rehabilitation of capital infrastructureneeded over the next 20 years.oWhat is “independent documentation?”– Documents generated through aprocess independent of the survey (e.g., CIP, master plan, sanitary surveyreport, etc.).oWhat is “survey-generated documentation?”– Documents generatedspecifically for the survey written by the system or the state.52LIST 1TYPE OF NEED (cont.)CodeType of NeedT35 Chemical FeedT36 Chemical Storage TankT37 Fluoride AdditionT38 Presedimentation BasinT39 Sedimentation/FlocculationT40 Granular Activated CarbonT41 Membrane Filtration (not complete plant)T42 Media FiltersT43 Waste Handling/Treatment: Mechanical (not included in another project)T44 Waste Handling/Treatment: Nonmechanical or Connection to a Sanitary Sewer(not included in another project)T45 Type of Treatment UnknownT46Other (Please include an explanation)1TRANSMISSION:(Any mains that transport raw water tothe treatment plant, or treated waterfrom the plant to the distribution system grid)X1 Raw Water TransmissionX2 Finished Water TransmissionDISTRIBUTIONM1 Distribution Mains (Any mains that transportwater through a piping grid serving customers -see "transmission" above)M2 Lead (Pb) Service Line ReplacementM3 Service Lines (otherthan lead service lines)M4 Hydrants Used for Flushing (notincluded in another pipe project)M5 Valves (gate, butterfly, etc.) (not included in another pipe project)M6 Control Valves (PRVs, altitude, etc.)M7 Backflow Prevention Devices/AssembliesM8 Water MetersFINISHED/TREATED WATER STORAGES1 Elevated Finished/Treated Water StorageS2 Ground-level Finished/Treated Water StorageS3 Hy dropneumatic StorageS5 Cover for Existing Finished/Treated Water StoragePUMP STATION AND FINISHED WATER PUMPP1 Finished Water PumpP2 Pump Station (booster or raw water pumpstation-may include clearwell, pumps, housing)OTHER INFRASTRUCTURE NEEDSW1Laboratory Capital Costs for Labs Owned by the System1W2 Computer and Automation Costs (SCADA)W3 Pump Controls/TelemetryW4 Emergency Power (enter design capacity as kilowatts)W5 Security: FencingW6Security: Other Physical (lights, wall, manhole locks, other locks)1W7Security: Electronic/Cyber (computer firewall, closed circuit TV)1W8Security: Monitoring Tools (used to identify anomalies in process streams or finished water)1W9Security: Other Security (describe in documentation)1W10Other (Please include an explanation)1LIST 1TYPE OF NEEDCodeType of NeedRAW/UNTREATED WATER SOURCER1 Well (including pump and appurtenances, not including a well house)R2 Well PumpR3 Well House (may include a chemical feed room)R4 Eliminate Well PitR5 Abandon WellR6 Aquifer Storage and Recovery WellR7 Surface Water IntakeR8 Raw Water PumpR9Off-Stream Raw Water Storage1R10 Spring CollectorR11De-stratification1TREATMENT:DisinfectionT1 ChlorinationT2 ChloraminationT3 Chlorine DioxideT4 OzonationT5 Mixed Oxidant Type EquipmentT6 Ultraviolet DisinfectionT7 Contact Basin for CTT8 Dechlorination of Treated WaterT9 Chlorine Gas ScrubberTREATMENT:Complete Plants (N/R/E require independent documentation)T10 Conventional Filter Plant(includes CAC technologies)T11 Direct or In-line Filter PlantT12 Slow Sand Filter PlantT13 Diatomaceous Earth Filter PlantT14 Membrane Technology for Particulate RemovalT15 Cartridge or Bag Filtration PlantT16 Lime SofteningT17 Reverse OsmosisT18 Electrodialy sisT19 Activated AluminaT20 Manganese Green Sand (or other oxidation/filtration technology)T21 Ion ExchangeT22 Groundw ater Chemical-feedT23 Iron AdsorptionT24 Aeration (complete plant)TREATMENT:Other Components / Equipment / ProcessesT30 Zebra Mussel ControlT31 Corrosion Control (chemical addition)T32 Powdered Activated CarbonT33 Aeration (component)T34 Sequestering for Iron and/or Manganese41Cost must be provided. Infrastructure cannot be modeled.3Use these instructions and lists of codes when y ou fill out theNeeds Survey and Assessment questionnaire. In yourdocumentation please be sure to include project descriptions. Alsoinclude copies of the breakdown of cost estimates, if available.For American Indian and Alaskan Native Village Water SystemsLIST 4 - DOCUMENTATIONCodeIndependent Documentation of Need and/or Cost1Capital Improvement Plan or Master Plan:The plan must address whythe project is needed and/or provide a cost.2Facilities Plan or Preliminary Engineering Report:Excerpts justifyingneed and/or cost from the plan or reportare acceptable ifproject-specific.3Grant or Loan Application Form:An application form is acceptable if itspecifically describes a problem requiring capital expenditures.4Engineer's Estimate or Bid Tabulation:These must be project specificand independently generated. They must also be accompanied by anexplanation of why the project is needed.CodeIndependent Documentation of Need Only5Intended Use Plan/State Priority List:The excerpts must include adescription of why the project is needed.Costs from IUPs will not be used -modeling parameters or other costdocumentation must be provided.6Comprehensive Performance Evaluation (CPE) or Sanitary SurveyResults:The results or recommendations may be used to justify need if thestate concurs.7Monitoring Results:Monitoring results indicating an MCL exceedance or atrending towards an exceedance can demonstrate a need for a project ifaccompanied by a written statement explaining how the results demonstrate theneed.8Other Independent Document:Use this code if documentation isindependent but none of the codes listed above apply. Examples include: stateenforcement order/noticeof violation, engineering studies, watermain breakreport, repair reports, and distribution system studies.CodeIndependent Documentation of Cost Only9Cost of Previous Comparable Construction:This may be used to justifycosts if the costs are project-specific. It must include documentation of how thecosts were derived.CodeSurvey-generated Documentation of Need Only10Written by State:Brief description and statementof need written by state.11Written by System:Brief description and statement of need written bysystem.12Written by EPA Region/Navajo Nation:Brief description and statement ofneed written by EPA Region/Navajo Nation based on site visit or other datacollection means.Lists of Codes79-20-10Instructions for Each Column on the 2011 Drinking WaterInfrastructure Needs Survey and Assessment QuestionnaireThe following instructions apply to columns on all tables in the questionnaire.Column TitleInstructionsProject NumberNumber the projects in each category in sequence, using the rangeof numbers specified for each category of need.Project NameProvide a name that briefly describes and identifies the project.Type of NeedRefer to List 1 in the Lists ofCodes and enter the code(s) that bestidentifies the project. More than onecode may apply to a project if acost is provided. Use only one code if no cost is available.Reason for NeedRefer to List 2 in the Lists ofCodes and enter the code(s) that bestjustifies the project. More than onecode may apply to a project if acost is provided. Use only one code if no cost is available.New,Replace,Expand/Upgrade,orReHabilitateIdentify whether the project is for:-Newinfrastructure installation where none exists, enter ‘N’Resulting infrastructure is entirely new.-Replacementof existing infrastructure, enter ‘R’Existing infrastructure is replaced with new infrastructure.-Expansion or Upgradeof a complete treatment plant, enter ‘E’Major improvements to an existing complete plant. May addor change unit processes. May result in an increase incapacity. Use for complete treatment plants only.-Rehabilitationof existing infrastructure, enter ‘H’Restore existing infrastructure to near new condition.Current orFutureIdentify whether the project is:- Needed now, enterC=(even if you cannot start construction now)- Not needed now, enterF=(but will be necessary before 12/31/2030Regulation orSecondaryPurposeIf the project is needed to maintain or obtain compliance with aregulation, secondary MCL, or if one or more of the secondarypurpose codes (green or climate readiness) apply, refer to List 3 inthe Lists of Codes andenter the appropriate code. Enter ‘4A’ if nocode applies.Cost EstimateIf available, enter the documented cost estimate for this project.Use only existing cost estimates.If no cost estimate is provided andmodeling parameters are recorded, EPA will use models toestimate the cost.Date of CostEstimateEnter the month and year (MM/YYYY)of the cost estimate. EPA willadjust cost estimates to current-year dollars.DocumentationRefer to List 4 in the Lists ofCodes and enter the code(s) thatapplies to the type of documentationprovided that explains why theproject is needed. If a cost estimateis provided, also enter the codethat applies to the type of costdocumentation. More than one codemay apply to a project if a cost isprovided. Use only one code if nocost is available.Please enclose the appropriate pages of needand cost documentation, identified by project number.LIST 3REGULATION OR SECONDARY PURPOSECodeRegulation or Secondary PurposeEXISTING SDWA REGULATIONS1A Surface Water Treatment Regulations(Surface Water Treatment Rule, InterimEnhanced Surface Water Treatment Rule,Filter Backwash Recycling Rule, LongTerm 1 Enhanced Surface Water Treatment Rule, or Long Term 2 EnhancedSurface Water Treatment Rule)1B Total Coliform Rule (published June 1989)1C Nitrate or Nitrite Standard1D Lead and Copper Rule1E Arsenic Rule (10 μg/L Arsenic Standard)1F Stage 1 Disinfectants/Disinfection Byproducts Rule (for compliance with the 80μg/L for TTHMs and 60 μg/L for HAA5s as a runningannual average)1G Other Regulated VOCs, SOCs, IOCs,or Radionuclides (excludes Radon)1H Ground Water RuleOTHER REQUIREMENTS OR SECONDARY PURPOSES2A Secondary Contaminants (e.g., iron, taste and odor, and color)2B State Requirements2C Green – Green Infrastructure (e.g., porous pavement, green roofs, etc.)2D Green – Water Efficiency (e.g., meters, pressure reducing valves, etc.)2E Green – Energy Efficiency (e.g., pump rehab, VFDs, SCADA, etc.)2F Green – Environmentally Innovative (e.g., LEED buildings, etc.)2G Climate Readiness (e.g., source qualitydegradation, source quantity availability,or infrastructure vulnerability)PROPOSED AND RECENTLY PROMULGATED SDWA REGULATIONSNeeds associatedsolelywith the following proposedor recently promulgatedregulations are not allowable and shouldnot be included. The costs for theseneeds, estimated for each rule’s Economic Analysis, will be added to the totalnational need. These regulations include:****Stage 2 Disinfectants/Disinfection Byproducts Rule(for compliance with the 80 μg/L for TTHMs and 60 μg/L for HAA5s as alocationalrunning annual average)****Proposed Revisions to the 1989 Total Coliform Rule****Proposed Radon RuleIf None of the Above Codes Applies4A Use this code if noneof the codes above apply16LIST 2REASON FOR NEEDCodeReason the Project is NeededA1 Project is for existing infrastructure that is or will be old ordeteriorated by 12/31/2030.A2 Project is to correct a deficiency in source water quantity caused bycurrent user demand.A3 Project is to correct a deficiency in storage capacity caused bycurrent user demand.A4 Project is to correct existing pressure problems (not related to fireflow).A5 Project needed as a result of, but not in preparation for, a naturaldisaster.A6Project is to obtain or maintain compliance with anexistingregulation(enter the regulation code from List 3 in the Lists of Codesin the regulation column of the questionnaire).A7Project is to obtain or maintain compliance with asecondarystandard(e.g., iron, taste and odor, and color) (enter regulation code2A in the regulation column of the questionnaire).A8 Project is for consolidation with and/or connection to an existingpublic water system.A9 Project is for extending service to existing homes without adequatewater 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, communicationsequipment, analytical equipment)A11 Use this code if codes A1-A10 do not apply.The following instructions apply to columns on specific tables in the questionnaire.Column TitleInstructionsDesignCapacityOn theSource,Treatment,Storage, and Pumpingproject table enterthe design capacity when applicablemillion gallons per day (MGD) forsource, treatment, and pumping; million gallons (MG) for storage; andkilowatts (kW) for emergency power. For this survey, “design capacity”is the total volume or the flow that can be produced when allcomponents of the project are operating.Diameter ofPipeOn theTransmission and Distributionproject table enter the diameterof pipe (in inches) that must be rehabilitated, replaced,or installed asnew. Use a separate project number andline for different sizes of pipe.Length of PipeOn theTransmission and Distributionproject table enter the length ofpipe (in feet) that mustbe upgraded, replaced, or installed as new foreach diameter identified inthe previous column.SizeOn theBackflow Prevention Devices/Assemblies, Hydrants, ServiceLines, Valves, Water Meter, and Otherproject table enter the diameter(in inches) for infrastructure that must be upgraded, replaced, orinstalled as new. Use a separate project number and line for differentdiameters of the same type of need.Diameter is not needed for serviceline projects.NumberNeededOn theSource,Treatment,Storage, and Pumpingproject table indicatethe total number of components if youhave multiple identical projectsat the same capacity (e.g., rehabilitate 10 wells each with a 0.5 MGDcapacity).On theBackflow Prevention Devices/Assemblies, Hydrants, ServiceLines, Valves, Water Meterand Otherproject table indicate the totalnumber of components. For example, a future project to install four 8”diameter valves would include the size (diameter in inches) of thevalves and the number “4” would be entered as the number needed.If you use this column and provide a project cost, the cost shouldreflect the entire project (i.e.,all10 wells orall400 meters,notthe costof an individual well or meter).Important Notes:A description of each project or a copy of the documentation mustalso be clearly identified by project number and submitted with thecompleted questionnaire.Projectsprimarilyfor meeting expected future population growth orfor fire flow are unallowable.oWhat is a “need?”– Installation or rehabilitation of capital infrastructureneeded over the next 20 years.oWhat is “independent documentation?”– Documents generated through aprocess independent of the survey (e.g., CIP, master plan, sanitary surveyreport, etc.).oWhat is “survey-generated documentation?”– Documents generatedspecifically for the survey written by the system or the state.52LIST 1TYPE OF NEED (cont.)CodeType of NeedT38 Presedimentation BasinT39 Sedimentation/FlocculationT40 Granular Activated CarbonT41 Membrane Filtration (not complete plant)T42 Media FiltersT43 Waste Handling/Treatment: Mechanical (not included in another project)T44 Waste Handling/Treatment: Nonmechanical or Connection to a Sanitary Sewer(not included in another project)T45 Type of Treatment UnknownT46Other (Please include an explanation)1T50T51T52T53Streaming Current MonitorsParticle CountersTurbidity MetersChlorine Residual MonitorsTRANSMISSION:(Any mains that transport raw water tothe treatment plant, or treated waterfrom the plant to the distribution system grid)X1 Raw Water TransmissionX2 Finished Water TransmissionDISTRIBUTIONM1 Distribution Mains (Any mains that transportwater through a piping grid serving customers -see "transmission" above)M2 Lead (Pb) Service Line ReplacementM3 Service Lines (otherthan lead service lines)M4 Hydrants Used for Flushing (notincluded in another pipe project)M5 Valves (gate, butterfly, etc.) (not included in another pipe project)M6 Control Valves (PRVs, altitude, etc.)M7 Backflow Prevention Devices/AssembliesM8 Water MetersFINISHED/TREATED WATER STORAGES1 Elevated Finished/Treated Water StorageS2 Ground-level Finished/Treated Water StorageS3 Hy dropneumatic StorageS4 CisternsS5 Cover for Existing Finished/Treated Water StoragePUMP STATION AND FINISHED WATER PUMPP1 Finished Water PumpP2 Pump Station (booster or raw water pumpstation-may include clearwell, pumps, housing)OTHER INFRASTRUCTURE NEEDSW1Laboratory Capital Costs for Labs Owned by the System1W2 Computer and Automation Costs (SCADA)W3 Pump Controls/TelemetryW4 Emergency Power (enter design capacity as kilowatts)W5 Security: FencingW6Security: Other Physical (lights, wall, manhole locks, other locks)1W7Security: Electronic/Cyber (computer firewall, closed circuit TV)1W8Security: Monitoring Tools (used to identify anomalies in process streams or finished water)1W9Security: Other Security (describe in documentation)1W10Other (Please include an explanation)1LIST 1TYPE OF NEEDCodeType of NeedRAW/UNTREATED WATER SOURCER1 Well (including pump and appurtenances, not including a well house)R2 Well PumpR3 Well House (may include a chemical feed room)R4 Eliminate Well PitR5 Abandon WellR6 Aquifer Storage and Recovery WellR7 Surface Water IntakeR8 Raw Water PumpR9Off-Stream Raw Water Storage1R10 Spring CollectorR11De-stratification1TREATMENT:DisinfectionT1 ChlorinationT2 ChloraminationT3 Chlorine DioxideT4 OzonationT5 Mixed Oxidant Type EquipmentT6 Ultraviolet DisinfectionT7 Contact Basin for CTT8 Dechlorination of Treated WaterT9 Chlorine Gas ScrubberTREATMENT:Complete Plants (N/R/E require independent documentation)T10 Conventional Filter Plant(includes CAC technologies)T11 Direct or In-line Filter PlantT12 Slow Sand Filter PlantT13 Diatomaceous Earth Filter PlantT14 Membrane Technology for Particulate RemovalT15 Cartridge or Bag Filtration PlantT16 Lime SofteningT17 Reverse OsmosisT18 Electrodialy sisT19 Activated AluminaT20 Manganese Green Sand (or other oxidation/filtration technology)T21 Ion ExchangeT22 Groundw ater Chemical-feedT23 Iron AdsorptionT24 Aeration (complete plant)TREATMENT:Other Components / Equipment / ProcessesT30 Zebra Mussel ControlT31 Corrosion Control (chemical addition)T32 Powdered Activated CarbonT33 Aeration (component)T34 Sequestering for Iron and/or ManganeseT35 Chemical FeedT36 Chemical Storage TankT37 Fluoride Addition41Cost must be provided. Infrastructure cannot be modeled.3ICR for 2011 DWINSA December 8 , 20 10 

## Appendix C Comments and Response to Comments Received on th e First Federal Register
NoticeICR for 2011 DWINSA December 8 , 20 10 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 Acti vities: Proposed Collection; Comment Request; 2011 Drinking Water Infras tructure Needs Survey Agency Information Collection; EPA IC R 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 profes sionals 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 incl udes 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 e ffort is appropriately structured and the data collected can be used to support so und 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 fash ion that is both statistically sound and represents as small a response burden as possible on individual drinking water
utilities.

AWWA appreciates the agency’s co nsideration 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 thro ugh outreach by AWWA sections. AWWA provides this support because a robust and accurate Needs Survey is important. A
current and accurate assessment of infr astructure needs facing drinking water systems will enable the agency to properly administer the drinking water revolving loan fund and implement the nation’s ov erall regulatory program for drinking water. AWWA will happily prov ide 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 su rvey should identify needs captured by long-term water system planning rather th an 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 Assessme nt (DWINSA) (Supporting Statement for ROCIS) ). Page 49 states that:

“...EPA’s precision target for the 2011 St ate 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 perce nt of the sample mean (or estimated need)..”

This type of objective statement shou ld be brought forth earlier in the
document.

AWWA recommends the agency report th e goals for survey accuracy within individual system size categories. A WWA also encourages the agency to set stringent objectives for the accuracy of th e 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 inapprop riate analytical approach to estimate the impact of the Long-Term 2 Enha nced Surface Water Treatment Rule (LT2ESWTR). In 2007, EPA based the estima te of need associated with LT2ESWTR on the agency’s economic analysis for th e 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 w ill also include an assessme nt 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 ques tions (e.g., enumerat ing valve, meter, hydrant, service line, and backflow preven tion 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 no t pertinent to the needs assessment. If EPA is going to collect this type of info rmation 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 re adiness 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 e nhance 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 ge nerated 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 syst em is inadequate to undertake the data collection reflected in the draft survey ques tionnaire. 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 acti vities 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 (obtai ning technical support). Based on the proposed questions, documentation requirements, and historical experience it is likely that a significant number of utilit ies 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 substant ially more time and resources than is reflected in the
current burden estimate. The burden esti mate 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 syst ems. AWWA does not support the proposed approach of extrapolating larg e system costs to small systems. The agency approach does not capture the unique challenges of small systems or the degree to which new regulations i mpact 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: D ave Emme < demme@ndep.nv.gov >

To: R obert 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 Respons e 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.