SEQ CHAPTER \h \r 1

Information Collection Request for the 2007 Drinking Water Infrastructure Needs Survey and Assessment (DWINSA)

(Supporting Statement for ROCIS)

August 2006

Prepared by:

The Cadmus Group, Inc.

57 Water Street

Watertown, MA 02472

Prepared for:

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water

Drinking Water Protection Division

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Table of Contents

  TOC \o "2-2" \t "Heading 1,1,Heading 3,3"  PART A OF THE SUPPORTING STATEMENT	  PAGEREF _Toc142817564 \h  5

A.1	IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc142817565 \h  5

A.1.a	Title of the Information Collection Request	  PAGEREF _Toc142817566 \h  5

A.1.b	Short Characterization	  PAGEREF _Toc142817567 \h  5

A.2	NEED FOR AND USE OF THE COLLECTION	  PAGEREF _Toc142817568 \h  7

A.2.a	Authority and Need for the Collection	  PAGEREF _Toc142817569 \h  7

A.2.b	Use and Users of the Information	  PAGEREF _Toc142817570 \h  7

A.3	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	  PAGEREF _Toc142817571 \h  9

A.3.a	Nonduplication	  PAGEREF _Toc142817572 \h  9

A.3.b	Public Notice Required Prior to ICR Submission to OMB	  PAGEREF _Toc142817573 \h  10

A.3.c	Consultations	  PAGEREF _Toc142817574 \h  10

A.3.d	Effects of Less Frequent Collection	  PAGEREF _Toc142817575 \h  11

A.3.e	General Guidelines	  PAGEREF _Toc142817576 \h  11

A.3.f	Confidentiality Questions	  PAGEREF _Toc142817577 \h  12

A.3.g	Sensitive Questions	  PAGEREF _Toc142817578 \h  12

A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED	  PAGEREF _Toc142817579 \h  13

A.4.a	Respondents/NAICS Codes	  PAGEREF _Toc142817580 \h  13

A.4.b	Information Requested	  PAGEREF _Toc142817581 \h  14

A.4.b.i 	Data Items	  PAGEREF _Toc142817582 \h  14

A.4.b.ii	Respondent Activities	  PAGEREF _Toc142817583 \h  16

A.5	INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF _Toc142817584 \h  19

A.5.a	Agency Activities	  PAGEREF _Toc142817585 \h  19

A.5.b	Collection Methodology and Management	  PAGEREF _Toc142817586 \h  20

A.5.c	Small Entity Flexibility	  PAGEREF _Toc142817587 \h  24

A.5.d	Collection Schedule	  PAGEREF _Toc142817588 \h  24

A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	  PAGEREF _Toc142817589 \h  25

A.6.a	Respondent Burden	  PAGEREF _Toc142817590 \h  25

A.6.a.i	Burden to Public Water Systems	  PAGEREF _Toc142817591 \h  25

A.6.a.ii	Burden to Primacy Agencies	  PAGEREF _Toc142817592 \h  29

A.6.b	Respondent Costs	  PAGEREF _Toc142817593 \h  33

A.6.b.i	Costs to Public Water Systems	  PAGEREF _Toc142817594 \h  33

A.6.b.ii	Cost to States	  PAGEREF _Toc142817595 \h  34

A.6.c	Agency Burden and Cost	  PAGEREF _Toc142817596 \h  35

A.6.d	Estimating Respondent Universe and Total Burden and Costs	  PAGEREF _Toc142817597 \h  38

A.6.e	Bottom Line Burden Hours and Costs	  PAGEREF _Toc142817598 \h  38

A.6.f	Reasons for Change in Burden	  PAGEREF _Toc142817599 \h  41

A.6.g	Burden Statement	  PAGEREF _Toc142817600 \h  41

PART B OF THE SUPPORTING STATEMENT (FOR STATISTICAL SURVEYS)	  PAGEREF _Toc142817601 \h  43

B.1	Survey Objectives, Key Variables and Other Preliminaries	  PAGEREF _Toc142817602 \h  45

B.1.a	Survey Objectives	  PAGEREF _Toc142817603 \h  45

B.1.b	Key Variables	  PAGEREF _Toc142817604 \h  45

B.1.c	Statistical Approach	  PAGEREF _Toc142817605 \h  46

B.1.d	Feasibility	  PAGEREF _Toc142817606 \h  47

B.2	Survey Design	  PAGEREF _Toc142817607 \h  49

B.2.a	Target Population and Coverage	  PAGEREF _Toc142817608 \h  49

B.2.b	Sample Design	  PAGEREF _Toc142817609 \h  50

B.2.b.i	Sampling Frame	  PAGEREF _Toc142817610 \h  50

B.2.b.ii	Sample Size	  PAGEREF _Toc142817611 \h  51

B.2.b.iii	 Stratification Variables	  PAGEREF _Toc142817612 \h  54

B.2.b.iv	Sampling Method	  PAGEREF _Toc142817613 \h  55

B.2.b.v	Multi-Stage Sampling	  PAGEREF _Toc142817614 \h  56

B.2.c	Precision Requirements	  PAGEREF _Toc142817615 \h  56

B.2.c.i	Precision Targets	  PAGEREF _Toc142817616 \h  56

B.2.c.ii	Nonsampling Error	  PAGEREF _Toc142817617 \h  57

B.2.d	Data Collection Instrument Design	  PAGEREF _Toc142817618 \h  59

B.3	PRE-TESTS AND PILOT TEST	  PAGEREF _Toc142817619 \h  61

B.3.a	Pre-tests	  PAGEREF _Toc142817620 \h  61

B.3.b	Pilot Test	  PAGEREF _Toc142817621 \h  61

B.4	COLLECTION METHODS AND FOLLOW-UP	  PAGEREF _Toc142817622 \h  63

B.4.a	Collection Method	  PAGEREF _Toc142817623 \h  63

B.4.b	Survey Response and Follow-up	  PAGEREF _Toc142817624 \h  63

B.5	ANALYZING AND REPORTING SURVEY RESULTS	  PAGEREF _Toc142817625 \h  65

B.5.a	Data Preparation	  PAGEREF _Toc142817626 \h  65

B.5.b	Analysis	  PAGEREF _Toc142817627 \h  65

B.5.c	Reporting Results	  PAGEREF _Toc142817628 \h  65

Appendix A Public Notice Required Prior to ICR Submission to OMB	  PAGEREF _Toc142817630 \h  67

Appendix B Data Collection Instrument and Lists of Codes	  PAGEREF _Toc142817632 \h  71

Appendix C Comments and Response to Comments Received on the 1st Federal Register Notice	  PAGEREF _Toc142817634 \h  91

LIST OF TABLES tc "LIST OF TABLES"

 TOC \f D

  TOC \h \z \t "Exhibit" \c    HYPERLINK \l "_Toc143678799"  Exhibit A-5-1 Collection Schedule	  PAGEREF _Toc143678799 \h  24

  HYPERLINK \l "_Toc143678800"  Exhibit A-6-1 Estimated Unit Burden for Systems Serving More Than 50,000 People	  PAGEREF _Toc143678800 \h  26

  HYPERLINK \l "_Toc143678801"  Exhibit A-6-2 Estimated Unit Burden for Systems Serving 3,301 – 50,000 People	  PAGEREF _Toc143678801 \h  28

  HYPERLINK \l "_Toc143678802"  Exhibit A-6-3 Estimated Unit Burden for Small CWSs	  PAGEREF _Toc143678802 \h  28

  HYPERLINK \l "_Toc143678803"  Exhibit A-6-4 Overall State Burden Summary	  PAGEREF _Toc143678803 \h  29

  HYPERLINK \l "_Toc143678804"  Exhibit A-6-5 State Unit Burden for Up-Front Activities	  PAGEREF _Toc143678804 \h  30

  HYPERLINK \l "_Toc143678805"  Exhibit A-6-6 State Unit Burden for Systems Serving More Than 50,000 People	  PAGEREF _Toc143678805 \h  31

  HYPERLINK \l "_Toc143678806"  Exhibit A-6-7 State Unit Burden for Systems Serving 3,301 – 50,000 People	  PAGEREF _Toc143678806 \h  33

  HYPERLINK \l "_Toc143678807"  Exhibit A-6-8 State Unit Burden for Small Systems	  PAGEREF _Toc143678807 \h  33

  HYPERLINK \l "_Toc143678808"  Exhibit A-6-9 Total Burden and Cost to Water Systems	  PAGEREF _Toc143678808 \h  34

  HYPERLINK \l "_Toc143678809"  Exhibit A-6-10 Total Burden and Cost to States	  PAGEREF _Toc143678809 \h  35

  HYPERLINK \l "_Toc143678810"  Exhibit A-6-11 Burden/Cost to EPA (Excluding Contractor Activities)	  PAGEREF _Toc143678810 \h  36

  HYPERLINK \l "_Toc143678811"  Exhibit A-6-12 Burden/Cost of Contractor Activities	  PAGEREF _Toc143678811 \h  37

  HYPERLINK \l "_Toc143678812"  Exhibit A-6-13 Bottom Line Respondent Burden	  PAGEREF _Toc143678812 \h  38

  HYPERLINK \l "_Toc143678813"  Exhibit A-6-14 Burden Hours and Costs for Respondents per Year	  PAGEREF _Toc143678813 \h  38

  HYPERLINK \l "_Toc143678814"  Exhibit A-6-15 Bottom Line Burden Hours and Costs for EPA (including its contractor)	  PAGEREF _Toc143678814 \h  39

  HYPERLINK \l "_Toc143678815"  Exhibit A-6-16 Disaggregated Burden by Affected Information Collection (IC) Entities	  PAGEREF _Toc143678815 \h  40

  HYPERLINK \l "_Toc143678816"  Exhibit B-2-1 State Sample Sizes	  PAGEREF _Toc143678816 \h  52

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PART A OF THE SUPPORTING STATEMENT

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

A.1.a	Title of the Information Collection Request tc "A.1.a	Title of the Information Collection " \l 2

The title of this information collection request (ICR) is Information Collection Request for the 2007 Drinking Water Infrastructure Needs Survey and Assessment (DWINSA). The Office of Management and Budget (OMB) control number for this ICR is 2040-new; EPA ICR No. 2234.01.

A.1.b	Short Characterization  tc "A.1.b	Short Characterization " \l 2

The Environmental Protection Agency (EPA) will conduct an assessment to estimate the capital investment needs for drinking water systems eligible to receive Drinking Water State Revolving Fund (DWSRF) monies. The nationwide assessment will be conducted by the Drinking Water Protection Division (DWPD) of EPA’s Office of Ground Water and Drinking Water (OGWDW). The data collection is authorized by Sections 1452(h) and 1452(i)(4) of the Safe Drinking Water Act (SDWA) and will be used to estimate the cost of providing safe drinking water to consumers over a 20-year period. The data from the report will also be used to allot DWSRF monies among states. The focus of the 2007 DWINSA is collecting information on systems’ needs and on the projected costs associated with those needs. All states have committed to help EPA administer the 2007 DWINSA with at least the minimum of activities. Thirteen states have chosen not to participate in the statistical portion of the survey (i.e., collecting data from systems serving 3,301 – 100,000 people). For the states that opt out of 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 people. All states with systems serving more than 100,000 people will participate in census portion of the survey.

For the 2007 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 conduct a site visit for 600 randomly selected CWSs serving 3,300 and fewer people and will estimate infrastructure needs for not-for-profit noncommunity water systems (NPNCWSs)  in the states and all Alaska Native and American Indian systems based on the 1999 DWINSA.

EPA will send the data collection instrument to all CWSs serving more than 100,000 people and a random sample of CWSs serving between 3,301 and 100,000 people (i.e., medium and large system sample). The data collection instrument consists of project tables in which the water systems list all their capital improvement projects through the year 2026. The same data collection instrument will be used for CWSs serving a population of 3,300 and fewer (i.e., small system sample); however, the data collection instrument will be completed by an EPA site visit contractor.

The effort will involve 3,193 respondents (3,137 CWSs and 56 states), requiring 46,030 hours at a total cost to the respondents of $1,541,361. Section A.6, Estimating the Burden and Cost of the Collection, provides a detailed description of the unit burden and costs for this collection. The average water system burden per response is 7.25 hours. The average burden per response to complete the data collection instrument is 8.20 hours per response. (This burden is higher because the small systems do not complete the data collection instrument.)

A.2	NEED FOR AND USE OF THE COLLECTION tc "A.2	NEED FOR AND USE OF THE COLLECTION"

A.2.a	Authority and Need for the Collection  tc "A.2.a	Authority and Need for the Collection " \l 2

EPA (the Agency) is conducting this DWINSA pursuant to its authority under Sections 1452(h) and 1452(i)(4) of the SDWA. Section 1452(h) requires that “the Administrator shall conduct an assessment of water system capital improvements needs of all eligible public water systems in the United States and submit a report to the Congress containing the results of such assessment within 180 days after the date of the enactment of the SDWA Amendments of 1996 and every 4 years thereafter.”

A.2.b	Use and Users of the Information  tc "A.2.b	Use and Users of the Information " \l 2

The results of the 2007 DWINSA will be used as a basis for allocation of DWSRF funds among states. In addition, many water systems have empirical data on the cost of compliance with SDWA regulations. A national assessment will improve the Agency’s ability to gauge the real capital cost of SDWA regulations.

EPA will collect two types of system-specific information: (1) system inventory and characteristics data (i.e., name and address of the system, contact person, population served, total design capacity, number of connections, primary source, whether the system is privately or publicly owned, and whether the system purchases/sells water from/to another public water system (PWS)); and (2) information on capital improvement projects. The specific uses of each data type vary. EPA will use system inventory and characteristics data to characterize CWSs nationwide, and, in some cases, to model individual systems’ capital improvement projects. EPA will use all data collected to estimate state and national needs.

On the data collection instrument, the respondent will identify needs on a project-by-project basis and list the “type(s) of need” that the project will meet. EPA will collect information on the proposed infrastructure to be installed, replaced, rehabilitated, upgraded, or expanded. EPA will use the information to assess project reasonableness and develop the cost models.

The respondent will also identify either a documented cost estimate for the project or will provide adequate information so that EPA can model the cost of the project. The information needed to model the cost will depend on the type of need. For example, EPA may collect information on the type and number of valves or the diameter and length of transmission or distribution lines. EPA expects that modeling will be required to project the capital needs for small systems, many medium systems, and some large systems. For the 2003 DWINSA, approximately 18 percent of the projects reported had documented costs. The costs for the remaining 82 percent of projects were modeled.

The data collected by the 2007 DWINSA will likely have several secondary uses, both inside and outside of EPA. For example, EPA will use the information to support various program activities, such as the development of general enforcement strategies and new regulations. Congress may use occurrence and cost information in considering new drinking water legislation. States have indicated to EPA that they plan to use the data collected to help identify projects that should be included on the state’s DWSRF priority list and to implement capacity development strategies. The public may use information on costs associated with SDWA compliance.

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A.3	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA tc "A.3	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA"

The following sections verify that this information collection satisfies the OMB’s nonduplication and consultation guidelines, and does not duplicate another collection.

A.3.a	Nonduplication  tc "A.3.a	Nonduplication " \l 2

To the best of EPA’s knowledge, up-to-date state-by-state information on water system’s capital needs is not available from any other source. Some of the data collection efforts EPA considered include the following:

Safe Drinking Water Information System (SDWIS). Inventory data and information on system characteristics have been collected by states and regions and entered into the SDWIS. For the statistical sample, EPA will pre-print the SDWIS system characteristics data (i.e., name and address of the system, contact person, address, population served, total design capacity, number of connections, primary source, whether the system is privately or publicly owned, and whether the system purchases/sells water from/to another PWS) on the 2007 DWINSA form and ask the respondents to provide information only if the SDWIS data are inaccurate or missing. SDWIS does not contain information on water systems’ capital needs.

Community Water System Survey (CWSS). EPA completed a statistical survey in 2000 that focused on the operating and financial characteristics of CWSs. The CWSS is addressed in the ICR for National Survey of the Financial and Operating Characteristics of Community Water Suppliers. The CWSS had a different objective than the DWINSA. The CWSS was designed to characterize the technical and financial aspects of CWSs. In contrast, the DWINSA will be used to develop national estimates of capital needs. In addition, the CWSS’s targeted precision was on a national basis; whereas the DWINSA will provide state-by-state estimates. It is anticipated that EPA will conduct a new CWSS in 2007. Where possible, EPA will combine any efforts for the CWSS and DWINSA, such as the small system site visits. Even though the data collected are different, the burden may be reduced if only one site visit is conducted at a system to collect data for both the CWSS and DWINSA.

Economic Analyses (EAs) for National Primary Drinking Water Regulations. The Agency has developed EAs (formerly referred to as Regulatory Impact Analyses) for its National Primary Drinking Water Regulations. These documents estimate the costs of complying with proposed regulations. The scope of the EAs is limited to the cost associated with the implementation of a given proposed regulation. EAs do not include an estimate for on-going capital projects to maintain compliance with existing regulations. Therefore, the EAs are not an adequate substitute for the DWINSA. In addition, the EAs provide nationwide estimates. As discussed above, EPA is conducting the DWINSA because the Agency needs a state-by-state estimate to develop the allocation formula for the DWSRF. Also, many EAs are several years out of date. They do not consider currently available contaminant occurrence data, or current or emerging treatment technology costs.

State Needs Surveys. Several states have conducted needs surveys of their own drinking water systems. The state results cannot be extrapolated to the nation as a whole because the state surveys do not use consistent methodologies and do not account for national variations in system characteristics and needs.

American Water Works Association (AWWA) Water Industry Data Base: Utility Profiles. Like the CWSS, this AWWA survey and associated database focuses on financial and operating characteristics of water systems. Moreover, the AWWA database is not statistically representative.

Drinking Water Treatment Screener and Detailed Questionnaire. EPA plans to conduct a survey of drinking water treatment plants as part of its effort to evaluate the need for national effluent guidelines regulations for the drinking water treatment point source category. This survey will request information on drinking water treatment plants operating during the 2005 calendar year. This survey will be conducted under the authority of Section 308 of the Clean Water Act (Federal Water Pollution Control Act, 33 U.S.C. Section 1318). This survey will only collect data from systems serving more than 10,000 people and information specific to drinking water treatment residuals. As discussed above, EPA is conducting the DWINSA because it requires a state-by-state estimate to develop the allocation formula for the DWSRF. The data in this survey will not support that effort.

1995, 1999, and 2003 DWINSAs. Under the SDWA, EPA must conduct the DWINSA every 4 years. The approach for the 2007 DWINSA will incorporate some data collected during the previous assessments, as well as “lessons learned” from the earlier assessments. In addition, the approach for the 2007 DWINSA ensures that up-to-date data on infrastructure needs are collected for all CWSs. Small, medium, and large CWSs regulated by the states reported approximately 94 percent of the national need for the 2003 DWINSA. The remaining 6 percent were for needs associated with American Indian and Alaska Native water systems, NPNCWSs, and recently promulgated regulations (including the new Arsenic Rule).

A.3.b	Public Notice Required Prior to ICR Submission to OMB  tc "A.3.b Public Notice Required Prior to ICR Submission to OMB " \l 2

To comply with the 1995 Amendments to the Paperwork Reduction Act (PRA), EPA solicited public comment on this ICR for a 60-day period before it was submitted to OMB. Specifically, EPA published a notice in the Federal Register (FR) requesting comment on the estimated respondent burden and other aspects of this ICR (71FR32344). This notice is included in Appendix A. Before submission to OMB, EPA considered any comments received and determined if any adjustments were needed to the burden and cost calculations or to the supporting statement for this ICR. Comments received and EPA’s responses are included in Appendix C. An additional Federal Register notice will be published when this ICR is submitted to OMB. The public comment period for this additional notice is 30 days.

A.3.c	Consultations  tc "A.3.c	Consultations " \l 2

For the 2007 DWINSA, EPA assembled a workgroup that consisted of EPA headquarter, EPA regional, and state representatives. In October 2005 and April 2006, EPA held meetings with workgroup members. The purpose of the meetings was to gather information on state and/or regional concerns, to discuss lessons learned during the 2003 DWINSA, and to discuss new policies for the 2007 DWINSA. The information gathered during the meetings was used to develop the methodology for the 2007 DWINSA. EPA also convened an informal peer input group to involve stakeholders such as trade associations. In addition, 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 input group, the peer review, and the pre-test, EPA made modifications to the data collection instrument, statistical procedures, and survey polices.

Specific changes EPA will make to the statistical methodology based on the results of the peer review include:

The survey methodology required that at least one system be selected from each stratum that contains at least one system. Based on the suggestions of reviewers the sampling plan will be adjusted to also ensure that at least two systems are selected from each stratum that contains more than one system to allow for variance calculations by strata and maintain the precision of the estimates.

Upon completion of the data collection, EPA will consider recommendations for alternative approaches to determining the system weights.

EPA will also make changes to the survey policies based on the results of the peer review. Two of the changes that EPA will make are:

EPA will clarify and provide more guidance to state reviewers on what type of documentation will be acceptable for the different types of water system projects.

In the survey instructions, EPA will add the definition of “need” as defined for the 2007 DWINSA.

A.3.d	Effects of Less Frequent Collection  tc "A.3.d	Effects of less Frequent Collection " \l 2

The 2007 DWINSA is a single collection and does not involve periodic reporting or recordkeeping.

A.3.e	General Guidelines  tc "A.3.e	General Guidelines " \l 2

The 2007 DWINSA does not violate any guidelines for information collection activities specified by OMB. Specifically, the 2007 DWINSA respondents are not required to:

Report information to EPA more often than quarterly.

Retain records for more than 3 years.

Complete the data collection instrument in fewer than 30 days.

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

Submit proprietary, trade secret, or other confidential information.

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

The information collection:

Is a statistical assessment designed to produce data that can be generalized to the universe of the study (see Section B.2).

Does not provide remuneration to participants.

Will transcribe information collected into an automated format.

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

Does not concern grants or grantees.

Is voluntary.

A.3.f	Confidentiality Questions  tc "A.3.f	Confidentiality and Sensitive Questions " \l 2

This information collection does not require the respondent to disclose any confidential information. Respondents are not obliged to respond to this strictly voluntary information collection. Further, respondents could eliminate any confidential business information from their reply.

A.3.g	Sensitive Questions  tc "A.3.g	Sensitive Questions " \l 2

The 2007 DWINSA does not ask sensitive questions, such as those pertaining to sexual attitudes or behavior or religious beliefs.

A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED tc "A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED"

A.4.a	Respondents/NAICS Codes  tc "A.4.a	Respondents/NAICS Codes " \l 2

NAICS Codes

The respondents for the 2007 DWINSA are CWSs and states. 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 serve at least 25 year-round residents.” The North American Industry Classification System (NAICS) code for PWSs is 221310. State agencies that include drinking water programs are classified as NAICS code 924110 (Administration of Air and Water Resources and Solid Waste Management Programs) or 926130 (Regulation and Administration of Communications, Electric, Gas, and Other Utilities). Ancillary systems (i.e., those that supplement the function of other establishments like factories, power plants, mobile home parks, etc.) cannot be categorized in a single NAICS code. For ancillary systems, the NAICS code is that of the primary establishment or industry.

Respondents

EPA will gather information from large and medium CWSs, as well as a limited number of small water systems. Because of their variability and significant contribution to the overall drinking water capital investment need, EPA will survey 999 systems that serve more than 50,000 people. Systems serving more than 100,000 will be sampled with certainty (589 systems). EPA will select a statistically representative sample of systems serving 50,001 – 100,000 (410 systems).

There are 8,109 systems that serve populations of 3,301 – 50,000. Surveying all of these systems would impose a large burden on respondents, EPA, and states. Therefore, EPA will select a statistically representative sample of systems serving 3,301 – 50,000. This will result in 1,538 systems receiving the mailed data collection instrument. Part B of the supporting statement describes the sampling methodology.

There are 41,398 small systems. Surveying all of these systems would impose a large burden on respondents, EPA, and states. Therefore, EPA will select a statistically representative sample of 600 systems serving 3,300 and fewer people. The 2007 DWINSAs will be completed by EPA site visitors. Part B of the supporting statement describes the sampling methodology.

EPA will not collect new needs data from NPNCWSs, Alaska Native water systems, or American Indian water systems.

In addition, 56 states (50 states plus the District of Columbia, Puerto Rico, Northern Mariana Islands, American Samoa, Guam, and the U.S. Virgin Islands) will provide support and information for the 2007 DWINSA.

A.4.b	Information Requested  tc "A.4.b	Information Requested " \l 2

As previously discussed, EPA will collect two types of information from systems: (1) system inventory and characteristics; and (2) information on capital improvement projects. EPA anticipates that respondents will provide varying levels of information by system size category. Based on experience from the previous three DWINSA, EPA expects larger systems 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 large systems will be capable of providing accurate information on cost. Most medium systems 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.

A.4.b.i 	Data Items  tc "A.4.b.i 	Data Items " \l 3

Medium and Large CWSs (Systems serving more than 3,300 people)

The data collection instrument asks respondents to verify or correct system characteristic information (i.e., name and address of the system, contact person, address, population served, total design capacity, number of connections, primary source, whether the system is privately or publicly owned, and whether the system purchases/sells water from/to another PWS). It is Customary Business Practice (CBP) for the system to maintain this information. The respondent will either indicate that the information is correct as printed or enter the correct information in the space provided. States will verify this information in advance of the data collection instrument being sent to the systems. Based on previous assessments, EPA anticipates that very few systems will need to correct the information provided.

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

Source.

Treatment.

Finished or Treated Water Storage, Pumping, and Other.

Transmission and Distribution.

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

For each of these projects, the respondent is asked to:

Briefly describe the needed capital projects (e.g., “routine distribution system replacement,” “filtration plant upgrade,” “high service pump replacement,” “corrosion control treatment,” or “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 of the Lists of Codes and that best describes the reason for the need from List 2. EPA will use this information to:

Develop separate cost estimates for source water treatment, transmission, storage, distribution, and other needs. (EPA will disaggregate the costs when projects meet multiple needs, if necessary.)

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

Help determine if the project is an allowable need.

Help gauge cost-reasonableness.

Indicate if the project is to install new infrastructure to meet current population demands, replace old infrastructure, expand or upgrade existing infrastructure (such as treatment plants to meet current population demands, or rehabilitate existing infrastructure).

Indicate if the project is needed now to protect public health or not needed now, but will be necessary to continue providing safe drinking water over the next 20 years.

Indicate if the project is associated with a regulation, the codes for which are listed on List 3 in the Lists of Codes. EPA will use this information to determine which needs are required because of an SDWA regulation or state requirement.

Provide design capacity when applicable—millions of gallons per day (MGD) for treatment and pumping; or millions of gallons (MG) for storage; the diameter and number of feet of distribution or transmission lines that will be replaced or added; or the size and number of backflow prevention devices/assemblies, flushing hydrants, service lines, valves, and water meters. EPA will use these parameters to model project costs.

If available, provide the capital cost estimate and year and month (if known) of the estimate. EPA will use this information to identify the cost of the project. The year and month are important because they will allow EPA to account for differences in the value of money over different years and to convert all costs to a common year.

Provide inventory data on the total length of pipe in the water system. This information will only be required for water systems that submit pipe projects, but do not have independent documentation (i.e., planning document, sanitary survey, or leak and break records). It is expected that not all systems will need to provide this inventory information. This information is necessary to allow EPA to determine that the need reported is what is reasonably expected to be replaced or rehabilitated 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 2007 DWINSA.

The respondent is also asked to provide his or her name, title, address, phone number, and e-mail address. This information is requested in case EPA or the state must contact the respondent for clarification or explanation of any response.

The respondent is asked to attach documentation for all needs and costs reported in the 2007 DWINSA. Systems are encouraged to provide inventory data on their systems. Only where noted above will the inventory data be required.

The data collection instrument is attached as Appendix B.

Small CWSs (Systems serving 3,300 and fewer people)

As discussed above, EPA will collect data from small systems through site visits. EPA will use the large and medium system data collection instrument for the site visits. Contractor personnel will complete the instrument during the site visit. EPA anticipates that most system operators will make themselves available to accompany contractor personnel. The operators may be asked very basic questions about the physical design of the plant and configuration of their system.

American Indian and Alaska Native Water Systems and NPNCWSs

EPA will base the needs of Alaska Native and American Indian water systems and NPNCWSs on the 1999 DWINSA results. EPA conducted site visits in 1999 to estimate the needs of these systems and EPA will update these estimates for the 2007 DWINSA.

A.4.b.ii	Respondent Activities  tc "A.4.b.ii	Respondent Activities " \l 3

Medium and Large CWSs (Systems serving more than 3,300 people)

To complete the data collection instrument, the following activities are anticipated for medium and large CWSs:

Participate in an informational telephone call from the state. Respondents will receive a call from the state describing the purpose of the DWINSA, the information that will be requested, and the timetable for completing and returning the data collection instrument.

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

Collect and copy supporting documentation. Respondents will locate the necessary supporting documentation in system files and copy it.

Complete the data collection instrument and inventory data. Respondents will fill out the data collection instrument and attach supporting documentation. Inventory data must be filled out for any pipe project that is submitted without independent documentation of need (e.g., a planning document).

In addition, some systems may contact states (or an EPA-established helpline) to obtain clarifying information on the data collection instrument.

Small CWSs (Systems serving 3,300 and fewer people)

The 2007 DWINSA methodology has been designed to minimize the burden on small CWSs. These systems’ role will be limited to answering basic questions during a phone call and accompanying the 2007 DWINSA team during the site visit. They will:

Participate in an informational/scheduling telephone call from EPA. Respondents will receive a call from EPA to describe the purpose of the DWINSA and to schedule the site visit.

Answer simple questions posed by the 2007 DWINSA team. Respondents will be expected to answer very basic questions about the physical design of the plant, system configuration, and capital needs.

State Activities

All states have committed to help EPA administer the 2007 DWINSA with at least the minimum of activities. Region 3 (Philadelphia) will act as the state for the District of Columbia. Region 8 (Denver) will act as the state for Wyoming. Region 9 (San Francisco) will perform state activities for the three Pacific Islands (Northern Mariana Islands, American Samoa, and Guam). However, 13 states have chosen not to participate in the statistical portion of the survey (i.e., collecting data from systems serving 3,301 – 100,000 people). For non-participating states, the needs of the participating states will be used to determine an average need per strata. This will be applied to the inventory of systems in non-participating states to estimate the needs for systems serving 3,301 – 100,000 people. All states that have systems serving more than 100,000 people 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 2007 DWINSA.

Participate in training and other pre-mailout efforts. This activity includes participating in training sessions offered to the states 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 by states. Such data include PWS identification number (PWSID), system name, address, telephone numbers (if any), primary source, population served, number of service connections, whether the facility is publicly or privately owned, and whether the system is a consecutive system. In addition, states will need to review address information to ensure the street address for each system selected in the sample is accurate. To help states 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 2007 DWINSA (e.g., establishing system files). In addition, state management will explain the 2007 DWINSA to staff and allocate resources.

State Data Collection Activities for Medium and Large CWSs (Systems serving more than 3,300 people)

States will conduct the following activities for medium and large CWSs during the data collection phase of the 2007 DWINSA:

Telephone systems to ensure participation. To improve response rates, states that participate in the 2007 DWINSA will telephone the medium and large systems early in the process to ensure that they have received the survey package and understand how to complete the data collection instrument.

Provide technical assistance. Participating states will provide technical assistance to systems by answering their questions about the data collection instrument and how needs should be represented.

Call systems that do not return the data collection instrument by a certain date. To improve response rates, participating states will telephone systems that have not returned their assessment by a specific date to encourage participation.

Review completed data collection instruments and documentation. The data collection instrument will be returned directly to the state. State personnel will have the opportunity to review the information on the data collection instrument, as well as any accompanying documentation.

Discuss results with EPA. After the state reviews the submission and documentation, the state forwards the data to EPA for review and data entry. EPA performs a second quality control/quality assurance check to ensure all data are documented and reasonable. Any differences of opinion regarding the documentation of the data will be resolved by EPA and the state.

State Data Collection Activities for Small CWSs (Systems serving 3,300 and fewer people)

States will conduct the following activities for small CWSs during the data collection phase of the 2007 DWINSA:

Brief contractor conducting site visits. Participating states will brief site teams on water systems that they will visit. Some states may choose to attend the site visit with the contractor.

A.5	INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT tc "A.5	INFORMATION COLLECTED\:  AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT"

A.5.a	Agency Activities  tc "A.5.a	Agency and State Activities " \l 2

A.5.a.i	EPA and Contractor Activities

Many of the EPA activities described here will be conducted by contractors with EPA oversight/technical direction. For example, EPA will oversee contractor development of the data collection methodology, and collection and analysis of assessment data. For purposes of describing Agency activities related to the 2007 DWINSA, contractor effort is not distinguished from EPA effort. Separate estimates for contractor burden and cost will be provided in Section A.6.c. In addition, Section B.1.c describes the contractor’s role.

Up-Front Activities

The following pre-assessment activities will be conducted:

Revise the data collection instrument/site visit protocol. EPA is revising data collection instrument for the large and medium system surveys, and a site visit protocol for the small CWSs, based on lessons learned during the 1999 and 2003 DWINSAs. This task will include developing cover letters and as well as other materials for state use.

Train state participants. To ensure that participating state officials understand every aspect of the 2007 DWINSA, EPA will conduct regional training sessions. The training will help ensure consistent responses across the country, high response rates, and efficient use of state staff.

Select 2007 DWISNA respondents. The Agency will draw samples for the 2007 DWINSA.

Develop data system. EPA will update the data system, developed for the 2003 DWINSA, to store and analyze data. The system will produce the necessary statistical reports for EPA, Congress, and states. The system will also allow state offices access to the data.

Send data collection instruments. Data collection instruments will be sent via FedEx to the selected systems.

Develop an electronic data collection instrument. The Agency will develop an electronic reporting form that systems serving more than 100,000 people can use to report their systems’ projects. It is anticipated that this form will reduce the burden for systems completing the form, states reviewing the form, and the Agency performing data entry.

Data Collection Activities

EPA will conduct the following activities during the data collection phase of the 2007 DWINSA:

Provide technical assistance. The Agency will maintain a helpline primarily to provide technical assistance to large and medium systems (unless the state prefers to do so). The helpline will help ensure consistent responses across the country.

Perform site visits. To ensure consistency, the site visits to small CWSs will be conducted by an EPA contractor (accompanied by state or regional personnel, if they wish to participate). As indicated above, site visit teams will complete the large and medium system survey instrument during the site visits.

Review returned data collection instruments. EPA will review the completed data collection instruments to ensure that all data are documented and reasonable.

Maintain the data. EPA will enter DWINSA data into the data system and perform quality control/quality assurance checks of data entry.

A.5.b	Collection Methodology and Management  tc "A.5.b	Collection Methodology and Management " \l 2

This section discusses the steps that EPA has taken to ensure that the information being collected will be accurate, reliable, and retrievable. This methodology was developed using experience gained in conducting the previous DWINSAs. EPA has incorporated into this methodology comments and advice from EPA staff involved with those assessments.

Development of Data Collection Instrument

Appendix B contains the data collection instrument. EPA has developed the 2007 DWINSA approach and the data collection instrument with the assistance of a workgroup. As is explained in Section A.3.c, the committee includes EPA headquarter, EPA regional, and state representatives. The 2007 DWINSA approach and data collection instrument will be refined through testing with water systems and consultations with outside groups. EPA’s basic approach and many of the refinements to it were based on experience in conducting the 1995, 1999, and 2003 DWINSAs. In addition, EPA conducted a peer review of the 2007 DWINSA policies and statistical approach. In developing the 2007 DWINSA, EPA will select a set of appropriate assessment objectives that are easily answerable by knowledgeable respondents. EPA’s pre-test of the data collection instrument is described in Section B.3.a. Section B.2.c.ii describes the steps taken to ensure that the data collection instrument will be an effective tool for retrieving the information EPA needs to meet the 2007 DWINSA objectives.

Methodology for Large and Medium CWSs (Systems serving more than 3,300 people)

Most systems serving more than 50,000 people have CIPs or similar documents that summarize their needs. These systems, therefore, are generally able to provide accurate information on their needs, and for some needs, accurate estimates on the associated cost. A data collection instrument will be sent to each of these systems. Clarifying information for completing the data collection instrument will be available from the state or EPA. Also, systems that participated in the 2003 DWINSA will be able to obtain a copy of their 2003 DWINSA data from the state and upload that data to the electronic form. After uploading the data, the system can update the projects (i.e., change parameters, delete projects that have been started, and add new projects identified since 2003).

The experience of states that participated in the previous DWINSAs indicates that systems serving 3,301 – 50,000 people can reliably complete a data collection instrument, if technical support is available. Most of these systems could provide reliable data on the needs, and a large portion could provide cost estimates for meeting those needs. The states will provide technical support to these systems by answering their questions. EPA will provide classroom training to states that may want to collect the needs for systems through site visits. EPA will also offer a helpline for EPA regional, state, and system personnel.

EPA will send the data collection instrument to the systems. Respondents will send the completed data collection instruments to the state. The state will review all data and provide a quality control/quality assurance function. Next, the state will forward data to EPA for review and data entry. EPA performs a second quality control/quality assurance check to ensure that all data are documented and reasonable. EPA will enter the data (for systems that did not use the electronic reporting form). If the state 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 or state does not provide documentation, the project or cost estimate will be deleted from the 2007 DWINSA.

Methodology for Small CWSs (Systems serving 3,300 and fewer people)

Based on state experience with past needs surveys, the 1995 and 1999 DWINSA, and other experience in dealing with small CWSs, EPA know it is unlikely that small CWSs can reliably complete the data collection instrument. Therefore, EPA will collect data from these systems through site visits. To ensure consistency, the site visits will be conducted by an EPA contractor accompanied by state or EPA regional personnel, if they wish to participate. To help reduce costs, systems will be clustered together by county or clusters of counties. Unlike previous DWINSAs, the statistical pull for small systems will not require that all states have at least one cluster of small systems. In addition, at least 25 percent of the sample selected will be in counties with high levels of arsenic to ensure the collection of information regarding small system needs related to compliance with the new Arsenic Standard.

Methodology for American Indian and Alaska Native Water Systems and NPNCWSs

Estimates for the American Indian and Alaska Native water systems and NPNCWSs will be based on needs reported in the 1999 DWINSA and updated to 2007 dollars.

Data Quality

It is crucial that the results of the DWINSA be as uniform as possible across the country. Toward this end, EPA will take the following steps:

EPA will establish a uniform set of assumptions or criteria for state, EPA regions, EPA headquarters, and contractor staff to evaluate data submitted by systems.

EPA will provide training to all those involved in the DWINSA to ensure that the assumptions and procedures are clear and understood.

EPA will provide quality assurance reviews of each data collection instrument submitted to ensure compliance with DWINSA polices and accuracy of data.

Among the most important steps in quality assurance is training. EPA will provide training sessions for state and EPA regional officials involved in the DWINSA. The regional training sessions will be designed to enable state 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, transmission, storage, treatment, and distribution.

Estimating and reviewing construction cost estimates.

Completing the 2007 DWINSA data collection instrument.

EPA will develop materials for distribution to state personnel who are unable to attend regional training sessions.

In addition to the training sessions, EPA will provide support for a helpline for state and water system personnel. It is anticipated that the helpline will be used primarily to provide information to the EPA regions and states and that the states will provide technical support to the systems. However, the helpline will be available to systems in states that have chosen not to provide their own technical assistance. Helpline staff will refer questions that raise a policy or technical issue to EPA staff.

Data quality will be assured by implementing the following mechanisms throughout the gathering and processing phases of the information collection:

Adequate documentation. EPA has requested documentation of needs and costs, when available, to ensure the accuracy and reliability of the data. Acceptable forms of documentation of needs and costs are listed on List 4 of the Lists of Codes. EPA will not accept needs or costs without adequate documentation. EPA will make it very clear to respondents that they are not expected to develop cost estimates for the purposes of the 2007 DWINSA. The costs of projects without a cost estimate will be modeled.

Provide inventory data on the total length of pipe in the water system. This information will only be required for water systems that submit projects for rehabilitation or replacement of pipe that are not independently documented (i.e., planning document, sanitary survey, or leak and break records). It is expected that not all systems will need to provide this information. This information is necessary to allow EPA to determine that the need reported is reasonable for a 20-year timeframe.

Receipt control. The primary objective of the receipt control system will be to ensure that completed forms submitted by respondents (or forwarded by states) are logged in promptly and given proper chain of custody. A second objective is to provide states with the data needed to monitor cumulative receipts by date to identify potential problems with the response rate. Such response rate problems could necessitate action. See Section B.2.c.ii for EPA’s method for improving the response rate. States that receive data collection instruments from respondents will be trained in receipt control.

Data review by states. EPA will rely on the states to help ensure data quality. States that receive 1-percent of the DWSRF allocation formula were given the option to “opt-out” of participating in certain aspects of the DWISNA. Thirteen states have chosen not to participate in the statistical portion of the survey (i.e., collecting data from systems serving 3,301 – 100,000 people). However, all states that have systems serving more than 100,000 people will participate in the census portion of the survey. It is anticipated that the majority of states will support EPA in this effort. EPA will ask the Association of State Drinking Water Administrators (ASDWA) to communicate with the state drinking water administrators to encourage their participation. Staff from Region 9 will perform the state activities for systems in the three Pacific Islands, staff from EPA Region 3 will act as the state for the District of Columbia, and staff from EPA Region 8 will act as the state for Wyoming.

EPA believes that state participation is essential in ensuring nationally consistent results because the states have more frequent communications with systems and possess a better understanding of each particular system’s needs. Therefore, state personnel will have the opportunity to review the information on the form, as well as any accompanying documentation. When necessary, the states will contact the system to ask for clarifying information. In addition, EPA has improved states’ ability to submit modifications through the Web site.

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 database. Reviewers will also assign comment codes to projects to describe any changes made to the data collection instruments. Data from the data collection instruments will be keyed into the database only after they have passed the initial screening. As data are keyed, an automatic data entry program will provide reasonable bounds checking and data verification. The program will signal the data entry operator, if an entry is out of the allowable range or is an invalid entry. For data collection instruments submitted electronically, the EPA contractor will follow the same review procedures as those submitted in hard copy.

Data systems. EPA developed a web-based database system for the 2003 DWINSA that will be used for the 2007 DWINSA. The web-based system includes a data entry interface that allows the Agency and its contractors to input data and allows states 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 for review and verification of their data.

Predefined summary and statistical reports.

Cost reasonableness ranges. EPA will develop “cost reasonableness ranges” to help verify the accuracy of the data and identify projects for further review.

Public Access to Data

The Agency’s policy is to make the fullest possible disclosure of information without unjustifiable expense or unnecessary delay to the requester. Once the final Report to Congress has been submitted, the public will be given access to assessment data in accordance with EPA’s policies and procedures for Freedom of Information Act (FOIA) requests. However, as a matter of policy, EPA will neither disclose the identity of any respondent to this questionnaire, nor the identity of any participating water system. EPA will develop standard report formats for providing data to the public.

 tc " " \l 2

A.5.c	Small Entity Flexibility  tc "A.5.c	Small Entity Flexibility " \l 2

In designing the 2007 DWINSA methodology, EPA has taken small systems’ relatively limited technical capabilities and financial resources into account. EPA’s experience with the previous DWINSAs has shown that small systems lack the resources and technical ability to complete the data collection instruments. Small CWSs regulated by the states will be included in the 2007 DWINSA and assessed by site visitors. EPA will use the 1999 DWINSA results as the primary basis for the 2007 DWINSA estimates for NPNCWSs, and Alaska Native and American Indian water systems.

	EPA anticipates that many small and medium systems will not be able to provide information on all needs and capital costs. For projects without a documented cost, EPA will model a cost.

A.5.d	Collection Schedule  tc "A.5.d	Collection Schedule " \l 2

	The current schedule assumes EPA will receive OMB approval for data collection by November 1, 2006. EPA will send data collection instruments to drinking water systems on January 18, 2007. All systems participating in the 2007 DWINSA will be asked to complete and return the data collection instruments within 1 month of receipt.

	To facilitate efficient data entry at EPA headquarters, EPA will ask the states to submit data for one-third of the systems within 3 months after data collection begins, or by April 18, 2007. Data for two-thirds of the systems will be due within 6 months (by July 18, 2007), and all data will be due on October 18, 2007. Exhibit A-5-1 summarizes the major collection milestones.

Exhibit A-5-1 Collection Schedule

Task	Date

Information Collection Request Submitted to OMB	August 2006

EPA Selects Systems to be Included in State Samples	August 2006

States Submit to EPA Contact Information to be Included on Return FedEx Labels 	September 2006

Training Sessions for States and Regions	September - November 2006

Mail Out of Data Collection Instruments to Selected Systems	January 18, 2007

Deadline Given to Systems to Return the Data Collection Instrument to States	February 18, 2007

1/3 of Sent Data Collection Instruments Returned by States to EPA	April 18, 2007

2/3 of Sent Data Collection Instruments Returned by States to EPA	July 18, 2007

All Sent Data Collection Instruments Returned by States to EPA	October 18, 2007

No New Projects Will Be Accepted by EPA 	October 18, 2007

No New Information on Submitted Projects Will Be Accepted by EPA December 18, 2007

All Information in the Data System Finalized	February 18, 2008

Report to Congress Due	February 2, 2009

A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION tc "A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION"

A.6.a	Respondent Burden  tc "A.6.a	Respondent Burden " \l 2

A.6.a.i	Burden to Public Water Systems  tc "A.6.a.i	Burden to Public Water Systems " \l 3

The annual CWS burden for the 2007 DWINSA is estimated to be approximately 5,689 hours (approximately a total of 22,757 hours). Exhibit A-6-14 shows the breakdown of the annual burden hours for large, medium, and small CWSs. The bases for the burden estimates are detailed below.

Systems Serving More Than 50,000 People

The respondent burden for the systems serving more than 50,000 people consists of systems’ burden for completing the data collection instrument. EPA estimates that the total unit burden is 10.39 hours per system. Exhibit A-6-1 summarizes the unit burden, broken down by activity and labor category.

Participate in informational phone call. Each informational call should last about 15 minutes (0.25 hours). EPA anticipates that management staff will take the call at half of the systems and technical staff will take the call at the other half. Thus, the unit burdens are 0.125 hours for management staff and 0.125 hours for technical staff.

Read cover letter/data collection instructions. EPA made the following assumptions in estimating the burden for reviewing the cover letter and data collection instructions:

A manager will receive the 2007 DWINSA and read the cover letter. The estimated time for managers to review the cover letter is 30 minutes (0.50 hours).

Technical staff will read the cover letter and data collection instructions. EPA estimates that the burden for this activity is 1 hour per system.

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

Collect and copy supporting documentation. Time required to review system files, and collect and copy supporting documentation will vary greatly. EPA estimates that it will take 1.5 hours at 30 percent of the systems, 2.5 hours at 30 percent of the systems, 4 hours at 30 percent of the systems, and 16 hours at 10 percent of the systems. Thus, the average time per system is as follows:

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

Call for technical assistance. Many systems will call states for technical assistance. In developing the burden estimate for this activity, EPA made the following assumptions:

The number of requests for assistance will equal 100 percent of the number of systems. (This estimate accounts for the fact that some systems will call more than once, while some will not call at all.)

Each call will be placed by technical staff.

About 50 percent of the questions will be “straightforward” and require a single phone call averaging 15 minutes (0.25 hours).

About 50 percent of the questions will require the state to perform research and call the system back. In this case, EPA estimates that the total burden for the two calls is 26 minutes (0.43 hours).

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

Complete data collection instrument. EPA estimates that technical staff will take 3 hours to complete the data collection instrument. This estimate is consistent with EPA’s experience with the previous DWINSAs. Management is expected to take 18 minutes (0.30 hours) to review the completed data collection instrument for accuracy. Clerical staff is anticipated to take 1 hour to provide support to the technical and managerial staff. Thus, the total unit burden is approximately 4.30 hours per system.

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

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	3.00	1.00	4.30

TOTAL	0.93	6.47	3.00	10.39

Systems Serving 3,301 – 50,000 People

Exhibit A-6-2 shows the unit burden for 1,538 systems serving 3,301 – 50,000 people. EPA estimates that each of these systems will take a total of 6.78 hours to respond to the 2007 DWINSA.

Participate in informational phone call. Each informational call should last about 15 minutes (0.25 hour). EPA anticipates that management staff will take the call at half of the systems and technical staff will take the call at the other half. Thus, the unit burdens are 0.125 hours for management staff and 0.125 hour for technical staff.

Read cover letter/data collection instructions. EPA used the following assumptions to estimate the burden for reviewing the cover letter and data collection instructions:

A manager will receive the 2007 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. Systems serving 3,301 – 50,000 people typically have less documentation than larger CWSs. However, the time required to review system files, and collect and copy supporting documentation will vary greatly. EPA estimate that it will take 1.0 hour at 50 percent of the systems, 2.0 hour at 25 percent of the systems, and 4.0 hours at 25 percent of the systems. Thus, the average time per system is as follows:

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

Call for technical assistance. Many systems will call EPA or the contractor for technical assistance. In developing the burden estimate for this activity, EPA made the following assumptions:

The number of requests for assistance will equal 150 percent of the number of systems. (This estimate accounts for the fact that some systems will call more than once.)

Each call will be placed by technical staff.

About 50 percent of the questions will be “straightforward” and require a single phone call averaging 15 minutes (0.25 hours) in duration.

About 50 percent of the questions will require the state to perform research and call the system back. In this case, EPA estimates that the total burden for the two calls will be 30 minutes (0.50 hours).

Thus, the total unit burden is 34 minutes (0.56 hours) per system [1.5(.50(0.25) +. 50(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. 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 2.47 hours per system.

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

Activity	Estimated Burden (hours)

	Management	Technical	Clerical	Total

Participate in informational phone call	0.125	0.125

0.25

Read cover letter/data collection instructions	0.50	1.00

1.50

Collect supporting documentation

1.00	1.00	2.00

Call for technical assistance

0.56

0.56

Complete data collection instrument	0.47	2.00

2.47

TOTAL	1.10	4.69	1.00	6.78

Small Systems (Systems serving 3,300 and fewer people)

EPA will conduct site visits at 600 small CWSs. Because EPA is conducting site visits to these CWSs, the burden imposed on the systems is small. EPA estimates that the unit burden to small CWSs averages 3.25 hours per system. Exhibit A-6-3 summarizes the burden for each activity.

Participate in informational/scheduling telephone call. The telephone call to discuss and schedule the site visit should take approximately 15 minutes (0.25 hours). Most small CWSs are staffed by one technical person; therefore, the entire burden falls with the technical labor category.

Accompany survey team/answer questions. EPA does not expect that small CWS personnel will accompany the survey team for the entire site visit; however, EPA anticipates that system staff will make themselves available to answer very basic questions about the system configuration. EPA estimates that the burden to assist the survey team is 2 hours for half of the small CWSs selected and 4 hours for the remaining 300 systems. Thus, the average burden per system is as follows:

[(2 x 0.5) + (4 x 0.5)] = 3.0 hrs /system

Exhibit A-6-3 Estimated Unit Burden for Small CWSs

Activity	Estimated Burden (hours)

	Management	Technical	Clerical	Total

Participate in informational phone call

0.25

0.25

Accompany data collection team/answer questions

3.00

3.00

TOTAL	0	3.25	0	3.25

A.6.a.ii	Burden to Primacy Agencies  tc "A.6.a.ii  Burden to Primacy Agencies " \l 3

Participating states will play an important role in conducting the DWINSA—they will help EPA ensure that the 2007 DWINSA is administered consistently nationwide. Most state activities will either involve using and reviewing data directly or facilitating EPA’s use and review of data. For example, states will review SDWIS inventory information for the statistical sample and verify that it is correct. They will help ensure a high response rate by telephoning systems serving more than 3,300 people before the 2007 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.

Given varying time and resource constraints, some states will wish to participate in the 2007 DWINSA more fully than others. The burden and cost estimates presented below represent a level of participation that EPA believes will ensure nationally consistent results. EPA encourages all states to participate at least at this level. The unit burden estimates are consistent with what was found to be true in the 2003 DWINSA.

The reader should note that the burden will vary widely by state, even for the same set of activities. A state’s actual burden depends on the number of drinking water systems in the state, the size and sophistication of those systems, the extent to which the state goes beyond the minimum requirements for the 2007 DWINSA, and other factors. Exhibit A-6-4 summarizes the burden estimates for each of the activity categories.

Exhibit A-6-4 Overall State Burden Summary

Activity Category	Estimated Burden

Up-Front Activities	110 hours, plus 0.2 hours/system

State Burden for Systems Serving More Than 50,000 People Assessment	6.58 hours per system

State Burden for Systems Serving 3,301 – 50,000 People Assessment	6.25 hours per system

State Burden for Small CWS Assessment	0.5 hours per system

Up-Front Burden

This activity category includes the state “fixed burden” for helping EPA prepare for the 2007 DWINSA. The total burden for these activities is 110 hours per state, plus 0.2 hour per system assessed. Exhibit A-6-5 summarizes this burden.

Participate in training and other pre-mailout efforts. The burden for this activity is estimated at 80 hours per state and is not expected to depend on the number of systems in the state.

Help EPA verify SDWIS data. Based on state experience EPA estimates that verifying SDWIS data for systems in the sample will require approximately 12 minutes (0.2 hours) per system.

Perform miscellaneous administrative activities. The burden for these activities should be 30 hours per state.

Exhibit A-6-5 State Unit Burden for Up-Front Activities

Activity	Estimated Burden

Participate in training and other pre-mailout activities	80 hours/state

Help EPA verify SDWIS data	0.2 hours/system

Perform miscellaneous administrative activities	30 hours/state

TOTAL	110 hours/state, plus 0.2 hours/system

State Burden for Systems Serving More Than 50,000 People

This section estimates the state burden for helping EPA conduct the 2007 DWINSA in systems serving more than 50,000 people assessment by providing technical assistance where needed, calling systems that do not return the data collection instrument on time, reviewing the completed data collection instrument and documentation, and discussing the results with EPA. Although most of these systems will be able to answer the questions on the data collection instrument, states will provide them with clarifying information as necessary. The state burden for activities associated with the systems serving more than 50,000 people is summarized in Exhibit A-6-6, which follows the activity descriptions.

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

Provide technical assistance. In developing a burden estimate for this analysis, EPA made the following assumptions:

The number of requests for technical assistance will equal 100 percent of the number of systems. (This estimate accounts for the fact that some systems make such requests more than once.)

Of those that do require technical assistance, about 50 percent of their questions will be “straightforward,” requiring only 15 minutes (0.25 hours) to answer.

About 25 percent of their questions will entail limited research and follow-up, requiring 30 minutes (0.50 hours) to answer, including time to call EPA with questions.

About 25 percent of their questions will require the state to perform some research, and will require 1.0 hours to answer.

Therefore, the state burden for providing technical assistance is estimated at about 30 minutes (0.50 hours) per request [0.5(0.25) + 0.25(0.50) + 0.25(1.0)]. This is an average. Some states may choose to provide a much higher or lower level of technical assistance than anticipated by EPA.

Call back systems that do not return the data collection instrument by a certain date. EPA assumes that the number of these “reminder” calls will equal 100 percent of the systems. This assumes that most (but not all) will need at least one reminder call and some 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 2007 DWINSA response.

Review completed data collection instruments and documentation. The data collection instrument will be returned directly to the state for review. For some systems, this documentation is expected to be quite voluminous, and reviewing it will be the most burdensome part of the 2007 DWINSA. The time required for this review is difficult to estimate. States that generate their own documentation for the 2007 DWINSA or add projects for distribution or transmission projects are required to ensure that the total pipe inventory section on the 2007 DWINSA is completed. Based on discussions with the states concerning their level of effort in previous assessments, EPA estimates that, on average, states will take 5.0 hours to review each submission. This estimate includes the time required to make follow-up phone calls and gather additional information as necessary.

Discuss results with EPA. To estimate the state burden for resolving questions on completed data collection instruments, EPA made the following assumptions:

EPA will have questions on 50 percent of the completed data collection instruments. Some of these questions will actually apply to all systems.

Each question will take the state 1 hour to resolve.

Therefore, the burden per system is 0.5 times 1 hour, or 0.5 hours per system [0.50(1.0)].

Exhibit A-6-6 State Unit Burden for Systems Serving More Than 50,000 People

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 Systems Serving 3,301 – 50,000 People

This section estimates the state burden for helping EPA conduct the systems serving 3,301 – 50,000 people for the 2007 DWINSA by telephoning systems to ensure participation, calling back systems that did not return the data collection instrument on time, reviewing the completed data collection instrument and the accompanying documentation, and discussing the results with EPA. The state burden for activities associated with the systems serving 3,301 – 50,000 people is summarized in Exhibit A-6-7, which follows the activity descriptions.

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

Provide technical assistance. In developing a burden estimate for this analysis, EPA made the following assumptions:

The number of requests for technical assistance will equal 150 percent of the number of systems. (This estimate accounts for the fact that some systems make such requests more than once while some will not call at all.)

Of those that do require technical assistance, about 50 percent of their questions will be “straightforward,” requiring only 15 minutes (0.25 hours) to answer.

About 25 percent of their questions will entail limited research and follow-up, requiring 30 minutes (0.50 hours) to answer, including time to call EPA with questions.

About 25 percent of their questions will require the state to perform some research, and will require 1.0 hours to answer.

Therefore, the state burden is estimated at about 45 minutes (0.75 hours) per request [1.5(0.5(0.25) + 0.25(0.50) + 0.25(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 2007 DWINSA response.

Review completed data collection instruments and documentation. The data collection instrument will be returned directly to the state for review. For states, this is the most burdensome part of the 2007 DWINSA, and the burden for this review is difficult to estimate. States that generate their own documentation for the 2007 DWINSA or add projects for distribution or transmission projects are required to ensure that the total pipe inventory section on the 2007 DWINSA is completed. For this ICR, EPA assumes that this activity takes states an average of 4.25 hours per system.

Discuss results with EPA. To estimate the state burden for resolving questions on completed data collection instruments, EPA made the following assumptions:

EPA will have questions on 50 percent of the completed data collection instruments. Some of these questions will actually apply to all systems.

Each question will take the state 1 hour to resolve.

Therefore, the burden per system is 0.5 times 1 hour, or 0.50 hours per system.

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

Activity	Estimated Burden

(hours per system)

Telephone systems to ensure participation	0.25

Provide Technical Assistance	0.75

Call back systems that do not return the data collection instrument by a certain date	0.50

Review completed data collection instruments and documentation	4.25

Discuss results with EPA	0.50

TOTAL	6.25

State Burden for Small CWSs (Systems serving 3,300 and fewer people)

This section estimates state burden for briefing the EPA contractor on systems that will be visited. The state burden for small CWSs is summarized in Exhibit A-6-8, which follows the activity descriptions.

Brief contractor conducting site visits. States should take about 30 minutes (0.50 hours) per system to brief the contractor on individual systems. States may choose to accompany the site visitor on the site visit, but it is not required.

Exhibit A-6-8 State Unit Burden for Small Systems

Activity	Estimated Burden

(hours per system)

Brief contractor conducting site visits	0.50

TOTAL	0.50

A.6.b	Respondent Costs  tc "A.6.b	Respondent Costs " \l 2

A.6.b.i	Costs to Public Water Systems  tc "A.6.b.i  Costs to Public Water Systems " \l 3

Exhibit A-6-9 summarizes the burden and costs to water systems. Total costs are estimated at $701,206, which consists solely of labor costs. There are no operation and maintenance (O&M) costs or capital costs associated with the collection.

PWS labor costs are based on the number of burden hours times an average hourly wage rate, including overhead. The average hourly wage rate is the rate taken from a 2003 EPA document entitled Labor Costs for National Drinking Water Rules. The quoted rate was $26.05 in 2003 dollars for small systems and systems serving 3,301 – 50,000 people and $31.26 in 2003 dollars for systems serving more than 50,000 people. This rate has been inflated to 2005 dollars using the Employment Cost Index. The inflated rate is $28.24 for small systems and systems serving 3,301 – 50,000 people and $33.88 for systems serving more than 50,000 people.

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

Respondent	Unit Burden (hours)

Total

Responses

Total Hours

Hourly Rate	Total Cost

	Management	Technical	Clerical

Systems Serving More Than 50,000 People	0.93	6.47	3.00	999	10,380	$33.88 $351,661

Systems Serving 3,301 – 50,000 People 	1.10	4.69	1.00	1,538	10,428 $28.24	$294,477

Small CWSs	0.00	3.25	0.00	600	1,950	$28.24	$55,068

TOTAL	2.02	14.40	4.00	3,137	22,757

$701,206

Note:	The average burden per response is 7.25 hours (22,757/3,137). The average burden for those systems 	completing a data collection instrument is 8.20 hours [(10,380+10,428)/(999+1,538)].

	Numbers may not add due to rounding.

A.6.b.ii	Cost to States  tc "	A.6.b.ii	Cost to Primacy Agencies " \l 3

Exhibit A-6-10 shows the annual costs to states. As discussed above, all states have committed to help EPA administer the 2007 DWINSA with at least the minimum of activities. Based on EPA’s projection that all states will participate in the DWINSA, the cost to states is $840,155. EPA will assess a total of 3,137 systems in the states. The labor costs are based on an average full time equivalent (FTE) cost of $75,088 including overhead, which equates to approximately $36.10 per hour. This rate, which has been inflated to year 2005 dollars, is based on the rate ($65,255) suggested by the workgroup that developed the State Workload Model in 2001 and is consistent with the rates used in ICRs recently developed by DWPD.

There are no O&M or capital costs for states under this ICR.

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

Activity	Number of states/

Systems*

Unit Burden	Total

Burden	Hourly Rate	Total Cost

Up-front	56	110 hours/state	6,160	$36.10	$222,376

	3,137	0.20 hours/system	627	$36.10	$22,635

State burden for systems serving more than 50,000 people assessment	999 6.58 hours/system	6,573	$36.10	$237,285

State burden for systems serving 3,301 – 50,000 people assessment 1,538	6.25 hours/system	9,613	$36.10	$347,029

State burden for small CWS assessment	600	0.50

hours/system	300	$36.10	$10,830

TOTAL	23,273

$840,155

A.6.c	Agency Burden and Cost  tc "A.6.c	Agency Burden and Cost " \l 2

The Agency burden and cost reflects the burden and cost directly incurred by EPA headquarters and EPA regions, summarized in Exhibit A-6-11. EPA will also bear the cost of contractor activities. Exhibit A-6-11 details the burden/cost of contractor activities. Both exhibits distribute burden/costs among Fiscal Years 2006, 2007, 2008, and 2009, reflecting that Agency and contractor activities will vary substantially over the 4-year period.

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

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 $140,262. Assuming 2,080 hours per year, this equates to $67.43 per hour.

  SEQ CHAPTER \h \r 1 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). Assuming 2,080 hours per year, this equates to 2,912 hours.

The average salary and benefits (i.e., PC&B) of the 1.4 FTEs is at the GS 11, Step 5 level of $99,862. Assuming 2,080 hours per year, this equates to $48.01 per hour.

EPA Contractor(s)

Over the 4-year period, the EPA contractor(s) will expend a total of 49,780 hours of direct labor.

The EPA contractor(s) will provide this professional labor at a total hourly rate, including all applicable indirect costs, of $68.00.

Based on these assumptions, EPA estimates that the total burden/cost to EPA of the DWINSA over the 4-year period is 58,516 hours and $3,917,558. Exhibits A-6-11 and A-6-12 follow, providing greater detail.

Exhibit A-6-11 Burden/Cost to EPA (Excluding Contractor Activities)

Fiscal Year	EPA Headquarters	EPA Regions	Total

	Hours	Cost	Hours	Cost	Total Hours	Total Cost

FY 2006	892	$60,148	446	$21,412	1,338	$81,560

FY 2007	2,020	$136,209	1,010	$48,490	3,030	$184,699

FY 2008	2,020	$136,209	1,010	$48,490	3,030	$184,699

FY 2009	892	$60,148	446	$21,412	1,338	$81,560

TOTAL	5,824	$392,714	2,912	$139,804	8,736	$532,518

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

Activities	FY 06	FY 07	FY 08	FY 09	Total

	Hours	Cost	Hours	Cost	Hours	Cost	Hours	Cost	Hours	Cost

Planning	2,000	$136,000	5,159	$350,812	3,200	$217,600	300	$20,400	  =SUM(B3,D3,F3,H3) \# "#,##0"  10,659 	  =SUM(C3,E3,G3,I3) \# "$#,##0;($#,##0)"  $724,812

Assessment Design	200	$13,600	0	$0	0	$0	0	$0	  =SUM(B4,D4,F4,H4) \# "#,##0"   200 	  =SUM(C4,E4,G4,I4) \# "$#,##0;($#,##0)"  $13,600

Peer Review	280	$19,040	0	$0	0	$0	0	$0	  =SUM(B5,D5,F5,H5) \# "#,##0"   280 	  =SUM(C5,E5,G5,I5) \# "$#,##0;($#,##0)"  $19,040

Modeling	334	$22,712	982	$66,776	960	$65,280	960	$65,280	  =SUM(B6,D6,F6,H6) \# "#,##0"  3,236 	  =SUM(C6,E6,G6,I6) \# "$#,##0;($#,##0)"  $220,048

Data Base Development	862	$58,616	1,000	$68,000	1,000	$68,000	1,000 $68,000	  =SUM(B7,D7,F7,H7) \# "#,##0"  3,862 	  =SUM(C7,E7,G7,I7) \# "$#,##0;($#,##0)"  $262,616

Assessment Production	0	$0	945	$64,260	0	$0	0	$0	  =SUM(B8,D8,F8,H8) \# "#,##0"   945 	  =SUM(C8,E8,G8,I8) \# "$#,##0;($#,##0)"  $64,260

Site Visits	0	$0	12,000	$816,000	0	$0	0	$0	  =SUM(B9,D9,F9,H9) \# "#,##0"  12,000 	  =SUM(C9,E9,G9,I9) \# "$#,##0;($#,##0)"  $816,000

Data Analysis	0	$0	9,629	$654,772	2,533	$172,244	0	$0	  =SUM(B10,D10,F10,H10) \# "#,##0"  12,162 	  =SUM(C10,E10,G10,I10) \# "$#,##0;($#,##0)"  $827,016

Report Writing	0	$0	208	$14,144	1,459	$99,212	700	$47,600	  =SUM(B11,D11,F11,H11) \# "#,##0"  2,367 	  =SUM(C11,E11,G11,I11) \# "$#,##0;($#,##0)"  $160,956

Statistical Analysis	0	$0	94	$6,392	656	$44,608	750	$51,000	  =SUM(B12,D12,F12,H12) \# "#,##0"  1,500 	  =SUM(C12,E12,G12,I12) \# "$#,##0;($#,##0)"  $102,000

Tech Assistance	0	$0	960	$65,280	200	$13,600	200	$13,600	  =SUM(B13,D13,F13,H13) \# "#,##0"  1,360 	  =SUM(C13,E13,G13,I13) \# "$#,##0;($#,##0)"  $92,480

Training	389	$26,452	820	$55,760	0	$0	0	$0	  =SUM(B14,D14,F14,H14) \# "#,##0"  1,209 	  =SUM(C14,E14,G14,I14) \# "$#,##0;($#,##0)"  $82,212

TOTAL	  =SUM(ABOVE)  4,065 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $276,420 	  =SUM(ABOVE)  31,797 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $2,162,196 	  =SUM(ABOVE)  10,008 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $680,544 	  =SUM(ABOVE)  3,910 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $265,880 	  =SUM(ABOVE)  49,780 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $3,385,040

A.6.d	Estimating Respondent Universe and Total Burden and Costs	  tc "A.6.d	Estimating Respondent Universe and Total Burden and Costs	 " \l 2

Respondents for this ICR include CWSs and states. This ICR estimates that the number of CWS respondents is 3,137. In addition to the CWS respondents, this ICR assumes 56 states (50 states plus the District of Columbia and U.S. Territories). Therefore, the total number of respondents is 3,193. The total costs and burden for these respondents are detailed in Exhibits A-6-9 and A-6-10.

A.6.e	Bottom Line Burden Hours and Costs  tc "A.6.e	Bottom Line Burden Hours and Costs " \l 2

Exhibit A-6-13 summarizes the bottom line burden hours and costs for CWSs and states for this collection. The total burden for CWSs and states is 46,030 hours at a cost of $1,541,361.

Exhibit A-6-13 Bottom Line Respondent Burden

Respondent Type	Burden Hours	Total Cost

Community Water Systems	22,757	$701,206

States	23,273	$840,155

TOTAL	  =SUM(ABOVE) \# "#,##0"  46,030 	  =SUM(ABOVE) \# "$#,##0;($#,##0)"  $1,541,361

Exhibit A-6-14 summarizes the burden hours and costs for CWSs and states per year. It is estimated that the CWSs will complete the data collection instrument in 2007. It is estimated that states will incur half of the burden associated with the 2007 DWINSA in 2007. The remaining half is assumed to be incurred evenly in 2006 and 2008.

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

Respondent

Type	Total Hour Burden (per year)	Total Cost (per year)

	2006	2007	2008	2009	2006	2007	2008	2009

CWSs	0	22,757	0	0	$0	$701,206	$0	$0

States	5,818	11,637	5,818	0	$210,039	$420,077	$210,039	$0

TOTAL	  =B3+b4 \# "#,##0"  5,818 	  =c3+c4  34,394 	  =d3+d4  5,818 	  =e3+e4  0 	  =f3+f4 \# "$#,##0"  $210,039 	  =g3+g4 \# "$#,##0"  $1,121,283 	  =h3+h4 \# "$#,##0;($#,##0)"  $210,039 	  =i3+i4 \# "$#,##0;($#,##0)"  $0

Average per Respondent	1.82	10.77	1.82

$66	$351	$66

Exhibit A-6-15 summarizes the bottom line burden hours and costs for EPA for this collection. The total burden for EPA (including its contractor) is 58,516 hours at a cost of $3,917,558.

  SEQ CHAPTER \h \r 1 Exhibit A-6-15 Bottom Line Burden Hours and Costs for EPA (including its contractor)

Respondent Type	Burden Hours	Total Costs

EPA	8,736	$532,518

Contractor	49,780	$3,385,040

TOTAL	  =SUM(ABOVE) \# "#,##0"  58,516 	  =SUM(ABOVE) \# "$#,##0"  $3,917,558

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, and state government agencies.

  SEQ CHAPTER \h \r 1 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 People	Publicly Owned CWSs	837	10.39	9,008 	$     33.88 	$305,195 	$ 352

	Private/Investor Owned CWSs	123

1,278

$43,298

State Owned CWSs	9

94

$3,168

Subtotal	999

10,380

$351,661

	Serving 3,301 to 50,000 People	Publicly Owned CWSs	1,368 	6.78	9,275 	$     28.24 	$261,927 	$191

	Private/Investor Owned CWSs	145

983

$27,763

State Owned CWSs	25

170

$4,787

Subtotal	1,538

10,428

$294,477

	Serving 3,300 and Fewer People	Publicly Owned CWSs	285 	3.25	926 	$     28.24 	$26,157 	$92

	Private/Investor Owned CWSs	305

991

$27,993

State Owned CWSs	10

33

$918

Subtotal	600

1,950

$55,068

State Government Respondents 	56 	415.59	23,273	$     36.10 	$840,155 $15,003

Total Water System Respondents

	Publicly Owned CWSs	2,520 	7.62	19,209

$593,280 	$235

	Private/Investor Owned CWSs	573 	5.68	3,252

$99,053 	$173

	State Owned CWSs	44 	6.72	296

$8,873 	$202

	Total CWSs Subtotal	3,137 	7.25	22,757

$701,206 	$224

Total Respondents	3,193 	14.42	46,030

$1,541,361 	$483

A.6.f	Reasons for Change in Burden  tc "A.6.f	Reasons for Change in Burden " \l 2

This ICR does not modify an existing ICR.

A.6.g	Burden Statement  tc "A.6.g	Burden Statement " \l 2

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 2007 DWINSA is estimated to be 46,030 hours, of which 22,757 hours are attributable to CWSs and 23,273 hours to states. These estimates include time for gathering information as well as developing and maintaining records. Public reporting burden for this collection of information is estimated to average 14.42 hours per response. Respondent burden for completing the data collection instrument is 8.20 hours.

Burden means the total time, effort, or financial resources expended by people to generate, maintain, retain, disclose, or provide information to or for a Federal agency. This includes the time needed to review instructions, adjust the existing ways to comply with any previously applicable instructions and requirements, train personnel to respond to the information collection request, search data sources, complete and review the collection of information, and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a request for information collection unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OW-2006-0486 which is available for online viewing at www.regulations.gov, or in person at the public viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426.  An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA.  Please include the EPA Docket ID No. EPA-HQ-OW-2006-0486 in any correspondence.

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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 2007 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 will send site visitors to collect data from CWSs serving 3,300 or fewer people. EPA is proposing the same methodology for collecting data for CWSs serving more than 3,300 people, as was used in the 2003 DWINSA. EPA is also proposing the same approach used in 1999 to collect data from CWSs serving 3,300 or fewer people.

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B.1	SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES tc "B.1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES"

B.1.a	Survey Objectives  tc "B.1.a	Survey Objectives " \l 2

The primary objective of the 2007 DWINSA is to collect information from CWSs 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-specific estimates of water systems’ 20-year need.  EPA has established policies to ensure that the overarching goals of the survey are met. These polices are provided to the states and help EPA:

Estimate the total national 20-year need.

Estimate the total 20-year need for each participating state.

Provide complete and accurate data to Congress.

Provide a tool to fairly distribute DWSRF capitalization funds to states.

Maintain the credibility of the DWINSA findings.

EPA proposes to collect information on the cost of systems’ infrastructure needs; if cost data are not available from systems, EPA proposes to collect information that will enable the Agency to model costs. In the data collection instrument, the respondent will identify needs on a project-by-project basis and list the “type(s) of need” that the project will meet. The “types of need” includes raw water source, transmission, source water treatment, storage, distribution, pumping stations, and other needs.

EPA will use the information from the DWINSA to project capital investment requirements of drinking water systems. The information will be used to allot Drinking Water State Revolving Fund (DWSRF) monies among states and as part of an allotment formula for the American Indian and Alaska Native DWSRF set-aside program.

EPA is proposing the same methodology as used in previous DWINSAs. Two changes were made for the 2007 DWINSA from the approach used in 2003. Data will be collected from systems serving 3,300 or fewer people. Data was not collected from these systems in the 2003 DWINSA. Data will be collected from a random sample of systems serving 50,001 – 100,000 people. These systems were selected with certainty in 2003. The sampling design will be discussed in detail below.

B.1.b	Key Variables  tc "B.1.b	Key Variables " \l 2

Several key variables are available from the Safe Drinking Water Information System (SDWIS). To ensure accuracy, the 2007 DWINSA will verify these data by asking respondents to confirm existing information (pre-printed on the data collection instrument), or correct it. These variables include population served, total design capacity, number of service connections, primary source of supply, ownership type (private or public), and whether the system purchases water from, or sells water to, another public water system (PWS).

Information on capital needs will be collected from respondents on a project-by-project basis. For each project, respondents will be asked to provide the following types of information: type of need; documentation of need and cost (if necessary); if the project is a new project or rehabilitation of 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 or state requirement; design capacity of source, storage, and treatment projects; cost of the project; and date of the cost estimate. For most of these variables, respondents will choose the appropriate “documentation,” “type,” or “regulation or requirement” from a lists of codes.

The principal variable of interest is total projected capital needed for each CWS in the 2007 DWINSA for the time period 2007 – 2026. The total capital need for all systems in each state (to be derived from the statistical sample of systems) is the key variable that decision-makers at EPA use to allocate funds to states based on need.

The method of data collection has been designed to minimize burden on respondents while ensuring that information is collected in a consistent manner. Collecting information on a project-by-project basis, for example, will be particularly helpful in reducing burden since most respondents develop Capital Improvement Plans (CIPs) in this manner.

Information on type of need will be used to disaggregate total capital needs for EPA’s Report to Congress. Information on documentation of need will be used to verify the public health benefit of the need. Information on the date of the cost estimate will be used to provide a consistent basis for cost estimates across systems. Information on a regulation or requirement will be used to determine the reported project costs related to Federal regulations or state requirements.

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  tc "B.1.c	Statistical Approach " \l 2

The 2007 DWINSA is being designed to achieve a desired level of precision for state-level estimates of total capital needs for medium and large CWSs. It also is being designed to estimate the total capital needs of small systems for the nation as a whole. EPA proposes a survey of a statistical sample to estimate total capital needs for CWSs serving populations of more than 3,300. This statistical approach minimizes burden while achieving the desired level of precision.

Medium and Large CWSs

The 2007 DWINSA design divides CWSs serving populations of more than 3,300 into two groups: large CWSs (serving populations of more than 50,000), and medium-sized systems (serving populations of 3,301 – 50,000). EPA proposes to sample with certainty systems serving more than 100,000 people. These systems have the largest capital needs, and they have the staff to respond efficiently to the 2007 DWINSA. EPA proposes to draw a random sample of medium systems (serving 3,301 – 100,000 people). This methodology can reduce burden and still achieve the DWINSA data quality objectives. To meet the state-level precision targets, EPA will first determine the total sample size for each state to meet the target level of precision. EPA will then allocate the sample to strata in order to maximize the efficiency of their design.

Small CWSs

The objective of the 2007 DWINSA is to develop state-level estimates of total capital needs for CWSs. For large and medium systems, as explained above, this objective is achieved by selecting samples that are allocated across various strata in the population to achieve an overall precision level for each state. Several barriers prevent us from developing state-level estimates for systems serving populations 3,300 and fewer:

First, a mail survey is not an effective approach to collection of data from these small CWSs. State experience with mail surveys for small CWSs suggests that total non-response and item non-response would be very high with a mail survey. Also, states believe that the absence of knowledgeable respondents at small CWSs limits the general reliability of the responses. Therefore, the 2007 DWINSA workgroup recommended, and EPA agrees, that the best way to gather information from small CWSs is through site visits made by EPA contractors. This will minimize total non-response, eliminate item non-response, and significantly improve the reliability of data collected.

Second, if EPA assumes that all data collected from small CWSs will require site visits, then the number of such visits is constrained by the budget allocated for the 2007 DWINSA. EPA’s current budget provides for approximately 600 site visits. Including small CWSs in the state-level design proposed for the medium and large systems, however, would require approximately 22,000 site visits. Thus, the statistical design for medium and large systems cannot be applied to small CWSs.

Given this dilemma, the EPA workgroup committee recommended that EPA adopt a different approach for small CWSs, one that focused on national-level estimates. The direct sample estimates of total capital needs at the national level will be used to infer the total capital needs for small CWSs in each state. The workgroup preferred this approach.

EPA is designing and conducting the 2007 DWINSA with the assistance of a contractor:

Contractor

The Cadmus Group, Inc.

57 Water Street

Watertown, MA 02472

(617) 673-7000

	Contractor Roles

Technical oversight for all contractor activities

Oversight of data collection instrument design and testing.

Oversight of statistical sample design

Training

Mailings; logistics

Technical support for respondents and states

Model development

Data processing

Statistical sample design

B.1.d	Feasibility  tc "B.1.d	Feasibility " \l 2

The 2007 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. First, EPA convened a workgroup (see Section A.5.b) to comment on the proposed data collection and its feasibility. Second, 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 data collection instrument was pre-tested, as described in Section B.3.a.

The Agency recognizes that some medium CWSs (and a few large CWSs) may not have cost data or documentation of costs for some projects. In those cases, the 2007 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 2007 DWINSA. In addition, EPA (or states) will provide large and medium CWSs with a helpline to assist them complete the data collection instrument.

Unlike the medium and large systems, the DWINSA will not be self-administered by small CWSs; rather, EPA contractors, accompanied by state personnel if state personnel participate in this portion of the 2007 DWINSA, will visit the small CWSs. Prior to the visit, the contractors will have access to all state records on the system (e.g., the results of recent sanitary surveys and inspections). The contractors will spend approximately 3 hours with the system owner or operator, requesting information that will be helpful in estimating system infrastructure needs. The contractor will then conduct a physical inspection of the system to confirm information provided by the owner or operator.

The EPA contractor will focus attention on the capital needs associated with treatment of source water, transmission, storage, and distribution. Capital needs associated with treatment will be modeled using methods similar to those currently used by EPA in the development of economic analyses. (In these analyses, data on occurrence of contaminants and cost estimates for treatment of source water to remove contaminants yield the cost of compliance with regulations that require the removal of contaminants from finished water.)

Reliance on site visits to small CWSs was strongly recommended by the EPA workgroup to avoid problems that have faced every state survey of small CWS infrastructure needs:

Total non-response. Since many systems have not clearly identified responsible parties, and since responsible parties often are unwilling to respond to data collection instruments, it is difficult to use a mail survey to obtain the necessary information. Working with participating state regulatory agencies and representatives of small CWSs should minimize non-response problems.

Item non-response. System owners and operators often are not knowledgeable about the capital needs of their systems. Unlike larger systems, who may maintain CIPs, small CWSs lack information to answer questions. Since EPA contractor engineers will conduct site visits to gather data, item non-response should be eliminated.

Reliability. State drinking water regulators are suspicious of information provided directly from owners or operators of small CWSs. Unlike larger systems, small CWSs usually do not have professional, certified operators. Instead, one is likely to meet mobile home park owners, volunteers from homeowners associations, and others who are not water supply professionals. State drinking water administrators clearly prefer the judgments of EPA contractor engineers, accompanied by their own staff, for reliable information on capital needs.

Finally, employing site visits will substantially reduce the burden on small CWSs. Total burden on the systems, on average, will be about 1 hour. Instead of completing a data collection instrument, the system owner or operator can answer questions asked by the visiting engineer. The approach was discussed with knowledgeable state drinking water regulators, as well as representatives of small CWSs, and all parties agreed that it was the best approach to achieve the desired results of the 2007 DWINSA.

Sufficient contract funds have been identified to complete the 2007 DWINSA.

The time frame for the 2007 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 2009. The schedule also is acceptable to other users of the data.

B.2	SURVEY DESIGN

This section contains a detailed description of the statistical survey design including a description of the sampling frame, sample identification, precision requirements, data collection instrument, pre-test, collection methods, and follow-up procedures.

Medium and Large CWSs

The sample design for the DWINSA is stratified random sampling within each state. Stratification increases the precision of estimates compared with a simple random sample of the target population of systems. In stratified samples, the target population is divided into non-overlapping groups, known as strata, from which separate samples are drawn. The goal of stratified sampling is to choose sample sizes within each stratum in a manner designed to obtain maximum precision in the overall estimate for the population. Stratification variables for this study include: population size (populations of: 3,301 – 10,000; 10,001 – 25,000; 25,001 – 50,000; 50,001 – 100,000; and populations of more than 100,000), and primary source of supply (surface and ground). Systems serving more than 100,000 people are selected with certainty. The size of each state’s sample of systems serving populations of 3,301 – 100,000 is set to meet the DWINSA’s data quality objectives.

EPA’s precision target 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 people has been determined for each state, the number of samples to be taken in each stratum within each state will be allocated in a manner that minimizes the variance of the estimated total capital costs. EPA will use a Neyman allocation to determine the number of systems to select from each stratum. The Neyman allocation is described in detail in Section B.2.b.ii.

Small CWSs

The 2007 DWINSA design for small CWSs, like that for medium and large systems, is stratified random sampling. The stratification variables for small CWSs are the same as those for other systems: size of population served and primary source of supply.

Unlike the medium and large systems, the design for small CWSs is driven by a significant budgetary constraints: EPA cannot afford to complete more than approximately 600 site visits. EPA’s objective in sampling is to achieve the maximum level of precision on a national basis without exceeding that budgetary constraint. Precision targets will be discussed in Section B.2.c, below.

B.2.a	Target Population and Coverage  tc "B.2.a	Target Population and Coverage " \l 2

The target population is 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 DWINSA is being designed to produce estimates of the capital need of medium and large systems for each state. It is being designed to produce estimates of the capital need of small systems for the nation as a whole.

B.2.b	Sample Design  tc "B.2.b	Sample Design " \l 2

This section describes the sample design. It includes a description of the sampling frame, target sample size, stratification variables, and sampling method. The sampling design employed is a stratified random sample of CWSs. The strata employed in the design are discussed in Section B.2.b.iii. Neyman allocation is used to efficiently allocate the sample of water systems among the strata.

B.2.b.i	Sampling Frame  tc "B.2.b.i	Sampling Frame " \l 3

The sampling frame is developed from SDWIS. SDWIS is a centralized database for information on PWSs, including their compliance with monitoring requirements, maximum contaminant levels (MCLs), and other requirements of the Safe Drinking Water Act (SDWA) Amendments of 1996. The following information will be extracted from SDWIS for the statistical survey and verified by participating states:

Name of system

Contact person

Address of system

Population served

Total design capacity

Number of connections

Primary source (surface water or ground water)

PWS identification number (PWSID)

Ownership type

Consecutive system (i.e., does system purchase or sell water)

From these data, EPA will develop the frame from which EPA will (1) calculate summary statistics (e.g., number of systems per state in pre-defined strata) for use in calculating sample size, and (2) randomly choose systems within the design strata to take part in the 2007 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 medium and large system survey are CWSs, a subset of PWSs. SDWIS is the ideal choice for a sample frame because of its inclusive coverage of all units of observation for the 2007 DWINSA. In addition, SDWIS has two other advantages: it contains information that will facilitate contacting the respondents, and it contains other information that is useful in stratifying the sample, thereby improving the efficiency of the sample design.

In previous surveys where SDWIS was used as a sample frame, there have been criticisms of its utility. Since 1989, EPA has conducted audits of the quality of SDWIS data. As a result, EPA is aware of the problems with SDWIS. The audits, however, show that errors in classification of systems by strata proposed for the 2007 DWINSA are rare. The audits show that systems are misclassified by population or source in less than 1 percent of all cases.

To mitigate any potential problems with the sample frame, the 2007 DWINSA design anticipates substantial state involvement in the 2007 DWINSA process. Participating states, for example, will be checking the sample frame of systems that will be used to determine the final sample. In EPA’s experience, states often have in-house data systems with very accurate data, particularly on medium- and large-sized CWSs. Even if these data are not transmitted to SDWIS, they are available to states and can be used by states to check the sample frame.

B.2.b.ii	Sample Size  tc "B.2.b.ii	Sample Size " \l 3

Medium and Large CWSs

Exhibit B-2-1 at the end of this subsection shows the preliminary sample sizes for the 2007 DWINSA. As shown on this exhibit, the sampling design will be implemented to achieve state-level precision targets for medium and large CWSs. Precision targets are discussed in Section B.2.c.

The task of determining the sample size for each stratum requires two steps. The first step determines the sample size for each state that achieves the precision targets for that state. The second step allocates the sample across the relevant strata in the state. The strata are described in section B.2.b.iii.

The first step in determining the sample size is calculating the total number of samples required at the state level to meet the precision requirements. The sample size is given by:

Where:	n0g	=	the sample size (prior to the finite population correction)

	Ngh	=	the total number of systems in the hth stratum in the gth state (taken from SDWIS)

	sgh	=	the standard deviation of the variable of interest for the hth stratum in the gth state (estimated using data from the 2003 DWINSA)

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

	Vg	=	the desired sampling variance for the total medium and large system capital needs estimate for state g.

 . d is the half-width of the desired confidence interval (0.10 for the Assessment). Zα is the value of a standard normal distribution for a confidence level of 1- α, (1.96 for the Assessment).

Because the number of water systems is known and finite, the following population correction is applied:

The second step allocates the total sample to each of the strata EPA will randomly draw this number of samples from each of these strata. The Neyman allocation formula is used for the allocation:

(Because systems serving populations more than 100,000 are to be sampled with certainty, H is reduced by the number of large-system strata in the sample design for the large and medium systems.)

In order to implement these sample size and sample allocation equations, EPA needs estimates for Vg, Ngh, sgh, and mean total capital needs by stratum. Information on mean total capital needs by stratum and sgh were estimated using data from the 2003 DWINSA.

Exhibit B-2-1 State Sample Sizes

State	Total Number Of Medium And Large Systems	Estimated Sample Size For Medium And Large Systems

Alaska	                                           21 	                                           16

Alabama	                                         354 	                                         137

Arkansas	                                         174 	                                           82

American Samoa	                                             1 	                                             1

Arizona	                                         127 	                                           28

California	                                         676 	                                         194

Colorado	                                         159 	                                           39

Connecticut	                                           60 	                                           46

District of Columbia	                                             1 	                                             1

Delaware *	                                           26 	                                             3

Florida	                                         382 	                                         108

Georgia	                                         224 	                                           57

Guam	                                             3 	                                             3

Hawaii *	                                           30 	                                             2

Iowa	                                         135 	                                           40

Idaho *	                                           45 	                                             1

Illinois	                                         462 	                                           83

Indiana	                                         213 	                                         100

Kansas	                                         120 	                                           41

Kentucky	                                         266 	                                         102

Louisiana	                                         224 	                                           87

Massachusetts	                                         247 	                                           57

Maryland	                                           55 	                                           20

Maine *	                                           35 	                                             1

Michigan	                                         306 	                                           55

Minnesota	                                         160 	                                           56

Missouri	                                         207 	                                           82

Northern Mariana Islands	                                             2                                               2

Mississippi	                                         197 	                                         148

Montana *	                                           34 	                                             1

North Carolina	                                         272 	                                           47

North Dakota **	                                           31 	                                            -

Nebraska	                                           44 	                                           21

New Hampshire *	                                           37 	                                             2

New Jersey	                                         227 	                                           57

New Mexico *	                                           60 	                                             1

Nevada	                                           35 	                                           11

New York	                                         355 	                                           56

Ohio	                                         314 	                                           79

Oklahoma	                                         160 	                                           53

Oregon	                                         109 	                                           43

Pennsylvania	                                         341 	                                           75

Puerto Rico	                                         122 	                                           56

Rhode Island *	                                           28 	                                             2

South Carolina	                                         167 	                                           46

South Dakota *	                                           42 	                                             1

Tennessee	                                         282 	                                         114

Texas	                                         968 	                                         109

Utah *	                                         105 	                                             7

Virginia	                                         164 	                                           45

Virgin Islands	                                             3 	                                             3

Vermont	                                           34 	                                           12

Washington	                                         199 	                                           50

Wisconsin	                                         177 	                                           51

West Virginia *	                                         110 	                                             3

Wyoming **	                                           27 	                                            -

Total	                                       9,359 	                                       2,537

*Eleven states have chosen not to participate in the statistical portion of the survey (i.e., collecting data from systems serving 3,301 – 100,000 people). They will however participate in the census portion of the survey (i.e., collecting date from systems serving more than 100,000 people). The number in the “Estimated Sample Size for Medium and Large Systems” represents the total number of systems in the state that serve more than 100,000 people.

** Two states have chosen not to participate in the statistical portion of the survey (i.e., collecting data from systems serving 3,301 – 100,000 people). In addition, these states do not have any systems that serve more than 100,000 people.

Small CWSs

The total small system sample is set at 600 by available resources. EPA will allocate the sample among six strata to produce the most efficient estimate of small sample need, given this sample size. Section B.2.b.iii discusses the how the sample will be stratified. The sample for systems serving 3,300 or fewer people is allocated among source water and population-served strata using a Neyman allocation. Within each ground water stratum, the sample is divided proportionately between systems in states with and without a substantial occurrence of arsenic. This method was chosen because the data on the variance in system need by arsenic occurrence are not available.

B.2.b.iii	 Stratification Variables  tc "B.2.b.iii	Stratification Variables " \l 3

The objective of stratification is to increase the efficiency of the sampling design (thereby reducing the number of samples required at any level of precision) by the creation of independent strata. Stratified sampling may produce a gain in precision in the estimates of the characteristics of the target population as compared to simple random sampling. In stratified sampling, the target population (i.e., CWSs) is divided into non-overlapping strata that are internally homogeneous, in that the measurements vary little from one unit to another (i.e., the within strata variance is minimized). If the within-stratum variance is relatively small, then a precise estimate of the variable of interest can be obtained with a relatively small number of samples. Each of the strata estimates can be combined to obtain a precise estimate for the target population. If the strata are constructed correctly, the target population estimate can be achieved with greater precision and with fewer samples than the estimate obtained from simple random sampling.

EPA’s drinking water programs have historically evaluated CWSs based on (1) size (number of persons served), and (2) primary source (ground water and surface water). Using total capital need information obtained from the 2003 DWINSA, EPA evaluated several classification schemes. This analysis showed that the stratification scheme selected for the 2007 DWINSA medium and large system sample (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 2007 DWINSA’s overall precision is not reduced. The proposed strata for medium and large systems are as follows:

Size of Population Served	Source	Sample Methodologies

3,301 – 10,000	Ground	Random sample.

3,301 – 10,000	Surface

	10,001 – 25,000	Ground	Random sample. In some states the number of strata will be reduced based on analysis of optimal stratum boundaries. Specifically, in some states systems serving between 10,001 and 50,000 will be in one group rather than two.

10,001 – 25,000	Surface

	25,001 – 50,000	Ground

	25,001 – 50,000	Surface

	50,001 – 100,000	Ground	Random sample

50,001 – 100,000	Surface

	More than 100,000	Ground	Sampled with certainty

More than 100,000	Surface