Information Collection Request for the 2003 Drinking Water Infrastructure Needs Survey ( Supporting Statement for OMB Form 83 I)

September 2002 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 i Table of Contents A. 1 IDENTIFICATION OF THE INFORMATION COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . 1 A. 1. a Title of the Information Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 A. 1. b Short Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 A. 2 NEED FOR AND USE OF THE COLLECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 A. 2. a Authority and Need for the Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 A. 2. b Use and Users of the Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 A. 3 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA . . . . . 5 A. 3. a Nonduplication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 A. 3. b Public Notice Required Prior to ICR Submission to OMB . . . . . . . . . . . . . . . . . . . . . . . 6 A. 3. c Consultations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 A. 3. d Effects of less Frequent Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 A. 3. e General Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 A. 3. f Confidentiality and Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 A. 3. g Sensitive Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 A. 4 THE RESPONDENTS AND THE INFORMATION REQUESTED . . . . . . . . . . . . . . . . . . . . . 8 A. 4. a Respondents/ NAICS Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 A. 4. b Information Requested . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 A. 4. b. i Data Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 A. 4. b. ii Respondent Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 A. 5 INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 A. 5. a Agency and State Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 A. 5. b Collection Methodology and Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 A. 5. c Small Entity Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 A. 5. d Collection Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 A. 6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION . . . . . . . . . . . . . . . . . . 22 A. 6. a Respondent Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 A. 6. a. i Burden to Public Water Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 A. 6. a. ii Burden to Primacy Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 A. 6. b Respondent Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 A. 6. b. i Costs to Public Water Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 A. 6. b. ii Cost to Primacy Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 A. 6. c Agency Burden and Cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 A. 6. d Estimating Respondent Universe and Total Burden and Costs . . . . . . . . . . . . . . . . 39 A. 6. e Bottom Line Burden Hours and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 A. 6. f Reasons for Change in Burden . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 A. 6. g Burden Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 ii B. 1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES . . . . . . . . . . 45 B. 1. a Survey Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 B. 1. b Key Variables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 B. 1. c Statistical Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 B. 1. d Feasibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 B. 2 SURVEY DESIGN FOR MEDIUM AND LARGE CWSs . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 B. 2. a Target Population and Coverage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 B. 2. b Sample Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 B. 2. b. i Sampling Frame . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 B. 2. b. ii Sample Size . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 B. 2. b. iii Stratification Variables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 B. 2. b. iv Sampling Method . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 B. 2. b. v Multi Stage Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 B. 2. c Precision Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 B. 2. c. i Precision Targets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 B. 2. c. ii Nonsampling Error . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56 B. 2. d Data Collection Instrument Design . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 B. 3 PRETESTS AND PILOT TEST . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 B. 3. a Pretests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 B. 3. b Pilot Test . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 B. 4 COLLECTION METHODS AND FOLLOW UP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 B. 4. a Collection Method . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 B. 4. b Survey Response and Follow up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 B. 5 ANALYZING AND REPORTING SURVEY RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 B. 5. a Data Preparation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 B. 5. b Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 B. 5. c Reporting Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 1For the purposes of this ICR, American Indian and Alaska Native water systems are not included among the " large," " medium," and " small" systems, but are included in separate categories.

1 PART A OF THE SUPPORTING STATEMENT A. 1 IDENTIFICATION OF THE INFORMATION COLLECTION A. 1. a Title of the Information Collection The title of this ICR is Information Collection Request for the 2003 Drinking Water Infrastructure Needs Survey. The Office of Management and Budget control number for this ICR is 2040 new; EPA Form No. 2085.01.

A. 1. b Short Characterization The Environmental Protection Agency ( EPA) will conduct a survey to estimate the capital investment needs for drinking water systems. The nationwide survey 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 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, among the EPA Regions. The focus of the survey is collecting information on systems' needs and on the projected costs associated with those needs. All States have committed to help EPA administer this survey.

For the survey, EPA will conduct a census of all community water systems ( CWSs) serving populations greater than 40,000 and select a random sample of CWSs that serve populations of 3,301 to 40,000. The Agency will also conduct a census for all Alaska Native systems and all American Indian systems serving more than 3,300 people and conduct telephone interviews with a limited number of small American Indian systems. For the purposes of this ICR, large systems are systems that serve more than 50,000 people and medium systems serve populations of 3,301  50,000. Due to funding limitations, information will not be collected from State regulated small systems, which serve 3,300 and fewer people. 1 EPA will mail the data collection instrument to all large and selected medium systems, including medium American Indian systems. The data collection instrument consists of project tables in which the water systems list all their capital improvement projects through the year 2022. EPA will request ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 2See Exhibit A 6 8.

2 information from Region 10 for all Alaska Native Systems. Similarly, EPA will request information on the needs of non tribally owned water systems that serve predominantly American Indian systems from the appropriate Regions and Tribes.

The effort will involve 3,790 respondents, requiring 45,065 hours at a total cost to the respondents of $ 1,301,553. 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 3.97 hours. The average burden per response to complete the data collection instrument is 4.00 hours per response. 2 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 3 A. 2 NEED FOR AND USE OF THE COLLECTION A. 2. a Authority and Need for the Collection The Agency is conducting this Needs Survey 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 Safe Drinking Water Act Amendments of 1996 and every 4 years thereafter." Section 1452( i)( 4) requires that " 1 ½ percent of the amounts appropriated annually to carry out this section may be used by the Administrator to make grants to Indian Tribes and Alaskan Native Villages which are not otherwise eligible to receive either grants from the Administrator under this section or assistance from state revolving funds established under this section. Such grants may only be used for expenditures by such tribes and villages for public water system expenditures referred to in subsection ( a)( 2)."

A. 2. b Use and Users of the Information The results of the survey will be used as a basis for allocation of DWSRF funds among States and as one of the tools to allocate the drinking water DWSRF set aside for American Indian and Alaska Native water systems among EPA Regions. In addition, many water systems have now complied with SDWA regulations and have empirical data on the cost of compliance. A national survey will improve the Agency's ability to gauge the real cost of SDWA regulations.

We will collect two types of system specific information: ( 1) inventory and system characteristics; and ( 2) information on capital improvement projects. The specific uses of each data type vary. We will use inventory and system characteristics to characterize CWSs nationwide, and, in some cases, model individual systems' capital improvement projects. We 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. For projects designed to alleviate contamination problems, we will collect information on the proposed treatment to be installed or replacement of deteriorated infrastructure. We will use the information to assess cost reasonableness and verify our cost models.

If a system cannot document costs associated with specific project( s), we will request information on the project( s) to help us model those needs. The information we request will depend on the type of need. For example, we 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 many medium systems and some large systems. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 4 The data collected by this survey 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. The Indian Health Service ( IHS) may compare the results of the Needs Survey with its own projections. EPA will examine the differences between the needs of American Indian and Alaska Native water systems and similar, State systems, to respond to the Administration's concerns over environmental justice issues. Congress may use occurrence and cost information in considering new drinking water legislation. States have indicated to EPA that they plan to use the data collected to help identify projects that should be included on the State's DWSRF priority list and to implement capacity development strategies. The public may use information on costs associated with SDWA compliance. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 5 A. 3 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA The following sections verify that this information collection satisfies the Office of Management and Budget's ( OMB's) nonduplication and consultation guidelines, and does not duplicate another collection.

A. 3. a Nonduplication To the best of our knowledge, up to date State by State information on needs is not available from any other source. Some of the data collection efforts we considered include the following:

° Safe Drinking Water Information System. Some of the inventory data and information on system characteristics have been collected by States and Regions and entered into the Safe Drinking Water Information System ( SDWIS). For the statistical sample, we will preprint the SDWIS data on the survey form and ask the respondents to provide information only if SDWIS data are inaccurate or missing.

° Community Water System Survey. EPA recently completed a statistical survey that focuses on the operating and financial characteristics of CWSs. The survey is addressed in Information Collection Request for National Survey of the Financial and Operating Characteristics of Community Water Suppliers. The CWS Survey had a different objective than the Needs Survey. The CWS Survey was designed to characterize the technical and financial aspects of CWSs. In contrast, the Needs Survey will be used to develop national estimates of capital needs. In addition, the CWS Survey's targeted precision was on a national basis; the Needs Survey will provide State by State estimates.

° Economic Analyses ( EAs) for National Primary Drinking Water Regulations. The Agency has developed EAs ( formerly referred to Regulatory Impact Analyses) for its National Primary Drinking Water Regulations. These documents estimate the costs of complying with proposed regulations. EPA is utilizing the information in these EAs to develop its models for the Needs Survey, but the EAs do not provide an adequate substitute for the Needs Survey. This is because the EAs provide nationwide estimates. As discussed above, EPA is conducting the Needs Survey because it needs a State by State estimate so that an allocation formula can be developed 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. Finally, EAs deal solely with regulations and, therefore, cover only a portion of costs associated with providing safe drinking water.

° 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 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 6 the State surveys do not use a consistent methodology and they do not account for national variations in system characteristics.

° American Water Works Association Water Industry Data Base: Utility Profiles. Like the CWS Survey, this AWWA survey and associated data base focus on financial and operating characteristics of water systems. Moreover, the AWWA database is not statistically representative.

° 1995 and 1999 Drinking Water Infrastructure Needs Surveys. Under the SDWA, EPA must conduct the Drinking Water Infrastructure Needs Survey every 4 years. The approach for the 2003 survey will incorporate a portion of the data collected during the previous surveys, as well as " lessons learned" from the earlier surveys. In addition, the approach for the 2003 survey ensures that up to date data on infrastructure needs are collected from large and medium water systems, which together account for approximately 74 percent of the national need. Among other needs, these data will reflect needs associated with recently promulgated drinking water regulations.

A. 3. b Public Notice Required Prior to ICR Submission to OMB To comply with the 1995 Amendments to the 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 ( 67 FR 46664). This notice is included in Appendix A. Before submission to OMB, EPA considers the comments received and determines if any adjustments are 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 was published when this ICR was submitted to OMB. The public comment period for this additional notice was 30 days.

A. 3. c Consultations For this survey, EPA has developed a workgroup that consists of EPA Headquarter, EPA Regional, State, American Indian, and Alaska Native representatives. EPA will also hold periodic stakeholder meetings to involve interested parties, such as trade associations. In April 2002, EPA held a 3 day meeting with workgroup members. The purpose of the meeting was to gather information on State and/ or Regional concerns and to hear about lessons learned in needs surveys conducted by the States and during the 1999 Drinking Water Infrastructure Needs Survey. The information gathered during the meeting was used to develop the survey methodology for the 2003 Needs Survey.

A. 3. d Effects of less Frequent Collection The survey is a single collection and does not involve periodic reporting or recordkeeping. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 7 A. 3. e General Guidelines The survey does not violate any guidelines for information collection activities specified by the Office of Management and Budget. Specifically, the survey 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 less 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 survey 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 and Sensitive Questions This information collection does not require the respondent to disclose any confidential information. Respondents are not obliged to respond to this strictly voluntary information collection. Further, respondents could eliminate any confidential business information from their reply. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 8 A. 3. g Sensitive Questions The survey 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 A. 4. a Respondents/ NAICS Codes NAICS & SIC Codes The respondents for the survey are CWSs. According to 40 CFR Part 141, 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 Public Water Systems ( PWSs) is 22131. State agencies that include drinking water programs are classified as NAICS code 92411 ( Administration of Air and Water Resources and Solid Waste Management Programs) or 923312 ( Administration of Public Health Programs). 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 We will gather information from large and medium CWSs, as well as a limited number of small American Indian water systems. Because of their variability and significant contribution to the overall drinking water capital investment need, large systems   those that serve more than 50,000 people   will be sampled with certainty. There are 886 large systems.

There are 7,949 medium systems. At this time, surveying all of these systems would impose a large burden on respondents, EPA, and States. Therefore, EPA will conduct a census of all systems serving 40,001  50,000 and will select a statistically representative sample of systems serving 3,301  40,000. This will result in 2,781 medium systems receiving the mailed data collection instrument. Part B of the supporting statement describes the sampling methodology.

EPA will collect needs data from all Alaska Native water systems and all medium American Indian. Small American Indian system needs will be based on the 1999 results. These results will be confirmed through a number of phone interviews ( 48 calls are assumed). Alaska Native system needs will be collected from Region 10 and assigned to one of four regions in the State, so there are no CWS respondents for Alaska Native systems. Section A. 4. b describes our methodology, which uses the results of the 1999 survey as a basis for estimating the needs of these systems. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 9 A. 4. b Information Requested As discussed above, we will collect two types of information from systems: ( 1) inventory and system 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 1995 and 1999 Drinking Water Infrastructure Needs Survey, 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 Medium and Large CWSs The data collection instrument asks respondents to verify or correct inventory 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 correct information in the space provided. States will verify this information in advance of the survey. Based on previous surveys, we anticipate 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 Projects; ° Transmission and Distribution; and ° 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 project ( e. g., " routine distribution system replacement," " filtration plant upgrade," " high service pump replacement," " corrosion control treatment," or " storage tank rehabilitation"). Information is being collected on a projectby 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. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 10 ° 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. We will use this information to:

  Develop separate cost estimates for source water treatment, transmission, storage, distribution, and other needs. ( We will work with the State to disaggregate the costs when projects meet multiple needs, but we expect this to occur only rarely.)

  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 or replace old infrastructure or rehabilitate or upgrade 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. We 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 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.

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

° Indicate the type of documentation, from List 4 of the Lists of Codes, that explains why the project is needed. 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 will not expect systems to develop cost estimates for the purposes of this survey.

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. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 11 The respondent is asked to attach documentation for all needs and costs reported in the survey.

The data collection instrument is attached as Appendix B.

American Indian and Alaska Native Water Systems EPA will determine the needs of medium American Indian water systems by conducting a census of all systems. EPA will base the needs for small American Indian water systems on the 1999 Needs Survey results. These results will be confirmed through 48 phone interviews with a random selection of systems for which EPA conducted site visits in 1999. Contractor personnel will complete the phone interviews. EPA anticipates that most system operators will make themselves available to answer questions about the water system. Region 10 will identify and document the needs of small Alaska Native water systems. Tribes and EPA Regions will have the opportunity to identify projects associated with non tribally owned water systems that serve predominantly American Indian communities.

A. 4. b. ii Respondent Activities Large CWSs To complete the instrument, large CWSs will:

° Participate in an informational telephone call from the State. Respondents will receive a call from the State describing the purpose of the Needs Survey, the information that will be requested, and the timetable for completing and returning the survey instrument.

° Read the cover letter and survey instructions. Respondents will review the cover letter and instructions accompanying the survey instrument.

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

° Complete the data collection instrument. Respondents will fill out the survey instrument and attach supporting documentation.

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

Medium CWSs To complete the data collection instrument, medium CWSs will: ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 12 ° Participate in an informational telephone call from the State. Respondents will receive a call from the State describing the purpose of the Needs Survey, the information that will be requested, and the timetable for completing and returning the survey instrument.

° Read cover letter and survey instructions. Respondents will review the cover letter and instructions accompanying the survey instrument.

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

° Complete the data collection instrument. Respondents will fill out the survey instrument and attach supporting documentation.

Some systems may contact the EPA helpline or States to obtain assistance completing the data collection instrument.

American Indian and Alaska Native Water Systems The survey methodology has been designed to minimize the burden on American Indian and Alaska Native water systems. Medium systems will be asked to participate in the same processes outlined above. Only a handful of small American Indian systems will be asked to answer basic questions during a phone call. Needs for small Alaska Native and non tribally owned systems serving predominantly American Indian communities will be identified by the Regions.

Some small American Indian water systems will:

° Participate in telephone call from EPA. Respondents will receive a call from EPA to review their 1999 Needs Survey and revise or add new projects. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 3In States that do not participate in the survey, EPA will also perform the activities identified in this ICR as " State Activities." This should have no net impact on burden.

13 A. 5 INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT A. 5. a Agency and State Activities EPA and Contractor Activities3 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 collection methodology, and collection and analysis of survey data. For purposes of describing Agency activities related to this survey, 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. EPA Regional staff will provide assistance in implementing the methodology developed for the American Indian and Alaska Native survey.

Up Front Activities The following pre survey activities will be conducted:

° Revise the data collection instruments protocol. EPA is revising the data collection instrument based on lessons learned during the 1999 Drinking Water Infrastructure Needs Survey. This task will include developing cover letters and other materials for State use.

° Train survey participants. To ensure that participating State, Regional, American Indian, and Alaska Native officials understand every aspect of the survey, we will conduct Regional training sessions. The training will help ensure consistent responses across the country, high response rates, and efficient use of State and EPA Regional staff.

° Select survey respondents. The Agency will draw samples for the survey.

° Develop data system. EPA will develop a data system to store and analyze data. The system will produce the necessary statistical reports for EPA, Congress, and States. The system will also allow States and EPA Regional offices access to the data.

° Mail data collection instruments. Data collection instruments will be mailed to the selected systems. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 14 Data Collection Activities EPA will conduct the following activities during the data collection phase of the survey:

° Provide technical assistance. The Agency will maintain a helpline primarily to provide technical assistance to large and medium systems ( unless the State wishes to do so), and to American Indian and Alaska Native water systems. The helpline will help ensure consistent responses across the country.

° Review survey instrument. We will review the completed collection instruments to ensure that all data are documented and reasonable.

° Maintain the data. We will enter survey data into the data system and perform quality control/ quality assurance checks of data entry.

State Activities All States have committed to support EPA on the Needs Survey. 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 ( Commonwealth of the Northern Mariana Islands, American Samoa, and Guam).

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. Also, States will have the option of increasing the sample size we develop, provided that we draw the sample to ensure the integrity of the survey. Because these activities are optional and not essential to ensure national consistency, this ICR does not address the associated burden.

Up Front Activities This first activity category includes the States' " fixed burden" for helping EPA prepare for the survey.

° Participate in training and other pre survey efforts. This activity includes participating in training sessions offered to the States and becoming familiar with the project design. 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 once the sample has been chosen. 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. To help ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 15 States and Regions with this verification activity, we will provide the information that must be reviewed in either printout or electronic form.

° Perform miscellaneous administrative activities. States will perform various administrative duties prior to the survey ( e. g., establishing system files). In addition, State management will explain the survey to staff and allocate resources.

Data Collection Activities States will conduct the following activities during the data collection phase of the survey:

° Provide technical assistance. Participating States will provide technical assistance to these systems by answering their questions about the survey instrument and how needs should be represented.

° Telephone systems to ensure participation. To improve response rates, States that participate in the survey will telephone the medium and large systems early in the process to ensure that they have received the data collection instruments and that they understand how to complete them.

° Call back 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 survey by a specific date.

° 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 survey 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.

A. 5. b Collection Methodology and Management This section discusses the steps that EPA has taken in order to ensure that the information being collected will be accurate, reliable, and retrievable. This methodology was developed using experience gained in conducting the previous drinking water and clean water needs surveys. We have incorporated into this methodology comments and advice from EPA staff involved with those surveys. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 16 Development of Data Collection Instrument Appendix B contains the data collection instrument. EPA has developed the survey approach and the survey instrument with the assistance of a workgroup. As is explained in Section A. 3. c, the committee includes States, EPA Headquarters, EPA Regions, and American Indian and Alaska Native representatives. The survey approach and survey instrument were refined through testing with water systems and consultations with outside groups. Our basic approach and many of the refinements to it were based on experience in conducting the 1995 and 1999 Drinking Water Infrastructure Needs Surveys. In developing the survey, we selected a set of appropriate survey objectives for which we framed questions that are easily answerable by knowledgeable respondents. Our pretest of the instrument is described in Section B. 3. a. Section B. 2. c. ii describes the steps taken to ensure that the instrument would be an effective tool for retrieving the information we need to meet our survey objectives.

Methodology for Large and Medium CWSs Almost all large systems have Capital Improvement Plans ( CIPs) or similar documents that summarize their needs. These systems, therefore, are generally able to provide accurate information on their needs, and for most needs, accurate estimates on the associated cost. A data collection instrument will be sent to each of these systems. Clarifying information for completing the instrument will be available from the State or EPA.

The experience of States that participated in the previous Drinking Water Infrastructure Needs Surveys indicated that " medium CWSs" could 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 State will provide technical support to these systems by answering their questions. Training will also be provided to the States that may want to collect the needs for systems through site visits. We will offer a helpline for Regional, State, and system personnel.

EPA will mail the data collection instrument to the systems. Respondents will send the completed data collection instruments to the State. The State reviews all data and provides a quality control/ quality assurance function. Next, the State forwards data to EPA for review and data entry. EPA performs a second quality control/ quality assurance check to see that all data are documented and reasonable. We will enter the data. 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 survey.

Methodology for Small Systems Due to funding limitations, data will not be collected from small systems. Needs will be based on data collected during the 1999 Needs Survey. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 17 Methodology for American Indian and Alaska Native Water Systems The approach developed to estimate the American Indian and Alaska Native water system projects will use EPA and Tribal resources to establish a system by system estimate of need for all American Indian and Alaska Native water systems. The approach for compiling infrastructure needs for these systems is outlined below.

To ensure that all appropriate systems are addressed, EPA Regional Offices will review the inventory data in SDWIS and provide any updates or changes to EPA Headquarters. Costs for medium American Indian systems will be assigned using the model developed for the overall Needs Survey. Phone interviews to a handful of small American Indian systems will be conducted to confirm the 1999 Needs Survey results.

For Alaska Native systems, separate cost models will be used to reflect unique construction challenges in arctic areas. Project specific cost estimates that were developed for the 1999 survey will be refined, if necessary, by Region 10 for each of the four regions for Alaska Native systems ( unless documented costs are available).

Data Quality 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 in order 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. We will make it very clear to respondents that they are not expected to develop cost estimates ( such as a Capital Improvement Plan) for the purposes of this survey.

° Training. Among the most important steps in quality assurance is training. We will provide training sessions for State and Regional officials involved in the Needs Survey. We will also establish a helpline to answer questions. 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.

It is crucial that the results of the Needs Survey be as uniform as possible across the country. Toward this end, we will take the following steps. We will establish a uniform set of assumptions or criteria for State, Regional, Headquarters, and contractor staff to evaluate data submitted by systems. We will provide training to all those involved in the Needs Survey to ensure that the assumptions and procedures are clear and understood. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 18 The Regional training will be designed to enable State and Regional staff to review completed survey 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 survey.

We will develop materials for distribution to State personnel who are unable to attend Regional training sessions.

In addition to the training seminars, we will provide support for a helpline for State, Regional, and water system personnel to address questions that arise after the training sessions. Helpline staff will refer questions that raise a policy or technical issue to EPA staff.

° 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 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 our method for improving the response rate. States that receive data collection instruments from respondents will be trained in receipt control.

° Data review by States. As discussed above under " Data Flow," we will rely on the States to help ensure data quality. To date, all States have committed to support EPA in this effort. EPA will also 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 State participation is essential in ensuring nationally consistent results because the States have more frequent communications with the system and possess a better understanding of the 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, we have improved States' ability to submit modifications through the Web site. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 4Nonprofit NCWSs are also eligible for DWSRF funding.

19 ° Data entry. Prior to entry into the Needs Survey database, the EPA contractor will screen the completed survey instruments for legibility, completeness, and internal consistency. Reviewers will also code the open ended questions in preparation for entry into the database. Data from the survey 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.

° Data systems. EPA is developing a web based database system with a data entry interface allowing the Agency and its contractors to input data and allowing States to access, download, verify, and suggest modifications to their data ( www. 2003needs. com). EPA will use the 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 and Regions for review and verification of their data.   Predefined summary and statistical reports.

EPA will design and build the system data structures to be as compatible with the replacement for the existing SDWIS data structure as possible.

° Cost reasonableness ranges. EPA will develop " cost reasonableness ranges" to help verify the accuracy of the data.

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 survey data in accordance with EPA's policies and procedures for Freedom of Information Act ( FOIA) requests. We will develop standard report formats for providing data to the public.

A. 5. c Small Entity Flexibility In designing the survey methodology, EPA has taken small systems' relatively limited technical capabilities and financial resources into account. Because of budget constraints, small CWSs and nonprofit noncommunity water systems ( NCWSs) 4 regulated by the States will not be included in the 2003 survey. The 2003 survey will use the 1999 results as the primary basis for its estimates. However, most of ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 20 the American Indian and Alaska Native systems in the survey are small systems. Our experience with the previous Drinking Water Infrastructure Needs Surveys has shown that small systems lack the resources and technical ability to complete the data collection instruments. Instead of mailing a data collection instrument to American Indian systems, we will collect data from Regions and Tribes, through phone interviews. The data collected during the phone interview will be used to confirm the data collected from small American Indian systems in the 1999 Drinking Water Infrastructure Needs Survey. Thus, the 1999 results will serve as the primary basis for the 2003 estimates of small system needs.

EPA anticipates that many 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 The current schedule assumes we will receive OMB approval for the collection by October 27, 2002. We will mail data collection instruments to drinking water systems on November 18, 2002. All systems participating in the survey will be asked to complete and return the data collection instruments within one month of receipt.

To facilitate efficient data entry at EPA Headquarters, we will ask the States to submit data for one third of the systems within 4 months after data collection begins, or by March 18, 2003. Data for twothirds of the systems will be due within 7 months ( by June 18, 2003), and all data will be due on October 18, 2003. The schedule for American Indian and Alaska Native systems will be similar. Exhibit A 5 1 summarizes the major collection milestones. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 21 Exhibit A 5 1 Collection Schedule Task Date Information Collection Request Submitted to OMB July 2002 States Review Inventory Data mid June  mid July 2002 States Submit to EPA Contact Information to be Included on Return FedEx Labels August 2002 EPA Selects Systems to be Included in State Samples August 2002 Training Sessions for States and Regions September  November 2002 Mailout of Data Collection Instruments to Selected Systems November 18, 2002 Deadline Given to Systems to Return the Data collection instrument to States December 18, 2002 1/ 3 of Sent Data Collection Instruments Returned by States to EPA March 18, 2003 2/ 3 of Sent Data Collection Instruments Returned by States to EPA June 18, 2003 All Sent Data Collection Instruments Returned by States to EPA October 18, 2003 No New Data Collection Instrument Submission will be Accepted by EPA November 18, 2003 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 22 A. 6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION A. 6. a Respondent Burden A. 6. a. i Burden to Public Water Systems The annual CWS burden for the 2003 Needs Survey is estimated to be approximately 14,809 hours. Exhibit A 6 8 ( at the end of Section A. 6. b) shows the breakdown of the annual burden hours for large systems, medium systems, and American Indian systems. The bases for the burden estimates are detailed below.

Large Systems The respondent burden for the large systems consists of systems' burden for completing the data collection instrument. EPA estimates that the total unit burden is 5.39 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 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/ survey instructions. EPA made the following assumptions in estimating the burden for reviewing the cover letter and survey instructions:

  At 50 percent of the systems, a manager will receive the survey, read the cover letter, and delegate the task of completing the survey to technical staff. At the other 50 percent of the systems, the survey will be received by the technical staff. The estimated time for managers to review the cover letter is 12 minutes ( 0.20 hours). Given that this activity occurs at 50 percent of the systems, the unit burden is 6 minutes ( 0.10 hours) per system.

  Regardless of whether or not a manager receives the survey instrument initially, technical staff will read the cover letter and survey instructions. We estimate that the burden for this activity is 15 minutes ( 0.25 hours) per system.

Thus, the total unit burden is 21 minutes ( 0.35 hours) per system [ 0.50( 0.20)+( 0.25)].

° Collect and copy supporting documentation. Time required to review system files, and collect and copy supporting documentation will vary greatly. We estimate that it will take 1 hour at 30 percent of the systems, 2 hours at 30 percent of the systems, 3 hours at 30 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 5As noted in Section A. 4, the data collection instrument for the 2003 survey requests slightly more information than the previous data collection instruments. However, the States believe that the format of the new data collection instrument will be easier to follow, resulting in no overall increase in per system burden.

23 ( 1 x 0.30)

( 2 x 0.30)

( 3 x 0.30)

( 16 x 0.10)  3.4 hrs/ system percent of the systems, and 16 hours at 10 percent of the systems. Thus, the average time per system is as follows:

° Call for technical assistance. Many systems will call States for technical assistance. In developing the burden estimate for this activity, we 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 " easy" 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, we estimate 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 45 minutes ( 0.75 hours) to complete the data collection instrument. This estimate is consistent with EPA experience with the previous Needs Surveys. 5 Management is expected to take 18 minutes ( 0.30 hours) to review the completed survey instrument for accuracy. Thus, the total unit burden is approximately 1 hour per system. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 24 Exhibit A 6 1 Estimated Unit Burden for Large CWSs Activity Estimated Burden ( hours)

Management Technical Clerical Total Participate in informational phone call 0.125 0.125 0.25 Read cover letter/ survey instructions 0.10 0.25 0.35 Collect and copy supporting documentation 1.70 1.70 3.40 Call for technical assistance 0.34 0.34 Complete data collection instrument 0.30 0.75 1.05 TOTAL 0.53 3.17 1.70 5.39 Medium Systems Exhibit A 6 2 shows the unit burden for 2,781 medium CWSs. EPA estimates that each of these systems will take a total of 3.56 hours to respond to the survey.

° 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/ survey instructions. EPA used the following assumptions to estimate the burden for reviewing the cover letter and survey instructions:

  At 50 percent of the systems, a manager will receive the survey, read the cover letter, and delegate the task of completing the survey to technical staff. At the other 50 percent of the systems, the survey will be received by the technical staff. The estimated time for managers to review the cover letter is 12 minutes ( 0.20 hours). Given that this activity occurs at 50 percent of the systems, the unit burden is 6 minutes ( 0.10 hours) per system.

  Regardless of whether a manager receives the survey instrument initially, technical staff will read the cover letter and survey instructions. We estimate that the burden for this activity is 15 minutes ( 0.25 hours) per system.

Thus, the total unit burden is 21 minutes ( 0.35 hours) per system [ 0.50( 0.20)+( 0.25)]. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 25 ( 0.5 x 0.5)

( 1 x 0.25)

( 2 x 0.25)  1 hr/ system ° Collect and copy supporting documentation. Medium CWSs typically have less documentation than large CWSs. However, the time required to review system files, and collect and copy supporting documentation will vary greatly. We estimate that it will take 30 minutes at 50 percent of the systems, 1 hour at 25 percent of the systems, and 2 hours at 25 percent of the systems. Thus, the average time per system is as follows:

° Call for technical assistance. Many systems will call EPA or the contractor for technical assistance. In developing the burden estimate for this activity, we make 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 " easy" 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, we estimate 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. The burden for completing the data collection instrument is greater for medium CWSs than for large systems because medium CWSs are expected to be less familiar with their capital needs and costs. They are also less likely to have documentation for their costs, and would therefore supply more information. Medium systems should take about 1.40 hours to complete the data collection instrument. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 6Additional analysis is necessary to determine the exact number of American Indian and Alaska Native respondents. At this time, EPA believes that 19 medium systems will receive questions, and 25 50 will receive phone calls ( the ICR assumes 48).

26 Exhibit A 6 2 Estimated Unit Burden for Medium CWSs Activity Estimated Burden ( hours)

Management Technical Clerical Total Participate in informational phone call 0.125 0.125 0.25 Read cover letter/ survey instructions 0.10 0.25 0.35 Collect supporting documentation 0.50 0.50 1.00 Call for technical assistance 0.56 0.56 Complete data collection instrument 0.47 0.93 1.40 TOTAL 0.70 2.37 0.50 3.56 American Indian and Alaska Native System Survey Exhibit A 6 3 shows the unit burden for approximately 67 American Indian and Alaska Native water systems. 6 The burden for these systems depends on whether they receive mailed data collection instruments, or phone calls.

Systems completing data collection instruments. EPA estimates that the approximately 19 medium systems will take a total of 1.94 hours to respond to the mailed data collection instrument. Activities include the following:

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

  At 25 percent of the systems, a manager will receive the survey, read the cover letter, and delegate the task of completing the survey to technical staff. At the other 75 percent of the systems, the survey will be received by the technical staff. The estimated time for managers to review the cover letter is 12 minutes ( 0.20 hours). Given that this activity occurs at 25 percent of the systems, the unit burden is 3 minutes ( 0.05 hours) per system. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 27 (( 0.5 x 0.2)

( 1 x 0.60)

( 2 x 0.20)) x 0.3  20 min/ system   Regardless of whether a manager receives the survey instrument initially, technical staff will read the cover letter and survey instructions. We estimate that the burden for this activity is 15 minutes ( 0.25 hours) per system.

Thus, the total unit burden is 18 minutes ( 0.30 hours) per system [ 0.25( 0.20)+( 0.25)].

° Collect and copy supporting documentation. All the American Indian water system data collection instruments will have been completed based on last survey's responses. Therefore, only systems adding projects will be required to collect documentation. We estimate that 30 percent of the system will add projects to the instrument. We also estimate that it will take 30 minutes at 20 percent of the systems, 1 hour at 60 percent of the systems, and 2 hours at 20 percent of the systems. Thus, the average time per system is as follows:

° Participate in technical assistance phone call. EPA or contractor staff will contact medium American Indian systems to provide technical assistance. In developing the burden estimate for this activity, we make 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 involve technical staff.

  About 50 percent of the discussions will cover " easy" issues and require a single phone call averaging 15 minutes ( 0.25 hours) in duration.

  About 50 percent of the questions will require the contractor to perform research and call the system back. In this case, we estimate 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))]

° Review data collection instrument. Since the data collection instrument will have already been completed using data from the previous survey, water systems will review what was provided and add, modify, or delete projects. American Indian systems should take about 45 minutes to review and modify the data collection instrument ( 0.20 hours of management time and 0.55 hours of technical time). ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 28 Exhibit A 6 3a Estimated Unit Burden for American Indian and Alaska Native Systems Receiving Mailed Data collection instruments Activity Estimated Burden ( hours)

Management Technical Clerical Total Read cover letter/ survey instructions 0.05 0.25 0.30 Collect supporting documentation 0.23 0.10 0.33 Receive technical assistance 0.56 0.56 Complete data collection instrument 0.20 0.55 0.75 TOTAL 0.25 1.59 0.10 1.94 Systems receiving phone interviews. In order to confirm the 1999 Needs Survey results for small American Indian systems, a subset of small American Indian systems will receive phone calls in which EPA or its contractor will seek updated information on projects reported on the 1999 Needs Survey data collection instruments. EPA will conduct phone interview with 25 50 such systems. This ICR assumes that 48 will be interviewed. Because the Agency is conducting phone interviews, the burden imposed on the systems is small. We estimate that the unit burden to these systems averages 1.25 hours per system. Exhibit A 6 3b summarizes the burden for each activity.

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

° Participate in interview. The phone interview will be supplementing data completed on the last survey's responses. We estimate that the burden to answer questioning regarding new needs is 1 hour per system. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 29 Exhibit A 6 3b Estimated Unit Burden for American Indian Systems Receiving Phone Interviews Activity Estimated Burden ( hours)

Management Technical Clerical Total Participate in informational/ scheduling telephone call 0.25 0.25 Participate in interview 1.00 1.00 TOTAL 1.25 1.25 A. 6. a. ii Burden to Primacy Agencies Participating States will play an important role in conducting the Drinking Water Infrastructure Needs Survey   they will help EPA ensure that the survey 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 medium and large systems before the survey and by making reminder calls to large and medium CWSs that have not returned their data collection instruments by a specified date. States will help ensure data quality by answering large 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 survey 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 1999 Drinking Water Infrastructure Needs Survey.

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 survey, and other factors. Exhibit A 6 4 summarizes the burden estimates for each of the activity categories. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 30 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 Large CWS Survey 6.50 hours per system State Burden for Medium CWS Survey 6.33 hours per system Up Front Burden This activity category includes the State " fixed burden" for helping EPA prepare for the survey. The total burden for these activities is 110 hours per State, plus 0.2 hour per system surveyed. Exhibit A 6 5 summarizes this burden.

° Participate in training and other pre survey 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 hour) 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 survey 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 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 31 State Burden for Large System Survey This section estimates the State burden for helping EPA conduct the large system survey by providing technical assistance where needed, calling systems that do not return the data collection instrument on time, reviewing the completed surveys 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 participating in the large system survey will provide them with clarifying information as necessary. The State burden for activities associated with the large system survey is summarized in Exhibit A 6 6, which follows the activity descriptions.

° Telephone systems to ensure participation. We estimate that this preliminary phone call will take about 10 minutes ( 0.17 hours) per system.

° Provide technical assistance. In developing a burden estimate for this analysis, we make 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 " easy," 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 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 survey. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 32 ° 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 large system survey. The time required for this review is difficult to estimate. Based on discussions with the States concerning their level of effort in previous surveys, EPA estimates that, on average, States will take 5 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 surveys, we made the following assumptions:

  We will have questions on 50 percent of the completed surveys. 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 Large System Survey Activity Estimated Burden ( hours per system)

Call to ensure participation 0.17 Provide Technical Assistance 0.50 Call back systems that do not return the data collection instrument by a certain date 0.33 Review completed survey forms and documentation 5.00 Discuss results with EPA 0.50 TOTAL 6.50 State Burden for Medium CWSs This section estimates the State burden for helping EPA conduct these medium CWS surveys by telephoning systems to ensure participation, calling back systems that did not return the data collection instrument on time, reviewing the completed surveys and the accompanying documentation, and discussing the results with EPA. The State burden for activities associated with the medium system survey is ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 33 summarized in Exhibit A 6 7, which follows the activity descriptions.

° Telephone systems to ensure participation. We estimate that this preliminary phone call will take about 20 minutes ( 0.33 hours) per system.

° Provide technical assistance. In developing a burden estimate for this analysis, we make the following assumptions:

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

  Of those that do require technical assistance, about 50 percent of their questions will be " easy," 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 survey.

° 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 medium system survey, and the burden for this review is difficult to estimate. For this ICR, EPA assumes that this activity takes States an average of 4.25 hours per system. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 34 ° Discuss results with EPA. To estimate the State burden for resolving questions on completed surveys, we made the following assumptions:

  We will have questions on 50 percent of the completed surveys. Some of these questions will actually apply to all systems.

  Each question will take the State one 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 Medium Systems Activity Estimated Burden ( hours per system)

Telephone systems to ensure participation 0.33 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 6.33 A. 6. b Respondent Costs A. 6. b. i Costs to Public Water Systems Exhibit A 6 8 summarizes the burden and costs to large, medium, and American Indian and Alaska Native water systems. Total costs are estimated at $ 389,032, 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 the average hourly wage rate, including overhead. The average hourly wage rate is the rate quoted by the Bureau of Labor Statistics for SIC Code 51 8031, " Local Government   Water and Liquid Waste Treatment Plant and System Operators." The quoted rate was $ 14.69 in 1999 dollars ( see http:// stats. bls. gov). For consistency with ICRs recently developed by DWPD, this rate has been inflated to 2002 dollars using the Employment Cost Index. The inflated rate is $ 16.42. In addition, 60 percent overhead was assumed, bringing the loaded rate to $ 26.27 in 2002 dollars. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 7 Region 9 will perform State functions for the three Pacific Islands, Region 3 will perform these functions for the District of Columbia, and Region 8 will perform these functions for Wyoming. For simplicity, however, we are including the burden for these States in this ICR.

8 According to the ICR Handbook, an employee works an average of 2,080 hours in one year.

9 The State Workload Model is a spreadsheet model used by States/ Primacy Agencies to estimate resource needs for implementation of the SDWA.

35 Exhibit A 6 8 Total Burden and Cost to Water Systems*

Respondent Unit Burden ( hours)

Total Responses Total Hours Hourly Rate Total Cost Management Technical Clerical Large CWSs 0.53 3.17 1.70 886 4,784 $ 26.27 $ 125,676 Medium CWSs 0.70 2.37 0.50 2,781 9,928 $ 26.27 $ 260,809 American Indian and Alaska Native Water Systems Medium Systems 0.25 1.59 0.10 19 37 $ 26.27 $ 972 Small Systems ( American Indian only) 1.25 48 60 $ 26.27 $ 1,576 TOTAL 3,734 14,809 $ 389,032 * The average burden per response is 3.97 hours ( 14,809/ 3,734). The average burden for those systems completing a data collection instrument   all except the small American Indian systems   is 4.00 hours [( 4,784+ 9,928+ 37)/( 886+ 2,781+ 19)].

A. 6. b. ii Cost to Primacy Agencies Exhibit A 6 9 shows the annual costs to primacy agencies. As discussed above, all States have committed to support EPA on this survey. 7 Based on our projection that all States will participate in the Needs Survey, the cost to States is $ 912,521. We will survey a total of 3,667 systems in the States. The labor costs are based on an average full time equivalent ( FTE) cost of $ 62,735 including overhead, which equates to approximately $ 30.16 per hour. 8 This rate, which has been inflated to year 2002 dollars, is based on the rate ($ 55,000) suggested by the workgroup that developed the State Workload Model in 19979 and is consistent with the rates used in ICRs recently developed by DWPD. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 10Hourly rates are from U. S. Office of Personnel Management, 2002 General Schedule ( Gs) Locality Pay Tables and overhead rates are from Information Collection Request for Public Water Supply Program, December 20, 1993.

36 There are no O& M or capital costs for primacy agencies under this ICR.

Exhibit A 6 9 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 $ 30.16 $ 185,786 3,667 0.20 hours/ system 733 $ 30.16 $ 22,107 State burden for large system survey 886 6.50 hours/ system 5,759 $ 30.16 $ 173,691 State burden for medium CWS survey 2,781 6.33 hours/ system 17,604 $ 30.16 $ 530,937 TOTAL 30,256 $ 912,521 A. 6. c Agency Burden and Cost The Agency burden and cost reflects the burden and cost directly incurred by EPA Headquarters, EPA Regions and IHS, summarized in Exhibit A 6 10. EPA will also bear the cost of contractor activities. Exhibit A 6 10 details the burden/ cost of contractor activities. Both Exhibits distribute burden/ costs among Fiscal Years 2002, 2003, 2004, and 2005, reflecting that Agency and contractor activities will vary substantially over the four year survey period. These estimates provide for all burden and costs that the Federal Government will assume in the place of States that do not participate in the Needs Survey.

EPA made the following assumptions in developing its estimate of Agency and contractor burden and cost10:

EPA Headquarters ° Over the four year survey period, EPA Headquarters will expend a total of 2.8 FTEs ( e. g., an average of 0.7 FTEs per year over the four years). Assuming 2,080 hours per year, this equates to 5,824 hours. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 37 ° 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 $ 120,093. Assuming 2,080 hours per year, this equates to $ 57.74 per hour.

EPA Regional Offices ° Over the survey period, EPA Regions will expend an 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 4 FTEs is at the GS 11, Step 5 level of $ 85,377. Assuming 2,080 hours per year, this equates to $ 41.05 per hour.

Indian Health Service ° Over the four year survey period, IHS Headquarters will expend a total of 0.1 FTE. Assuming 2,080 hours per year, this equates to 208 hours.

° The average salary and benefits ( i. e., PC& B) of the FTEs is at the GS 13, Step 5 level of $ 120,093. Assuming 2,080 hours per year, this equates to $ 57.74 per hour.

EPA Contractor( s)

° Over four years, the EPA contractor( s) will expend a total of 37,500 hours of direct labor.

° The EPA contractor( s) will provide this professional labor at a total hourly rate, including all applicable indirect costs, of $ 64.00.

Based on these assumptions, EPA estimates that the total burden/ cost to EPA and IHS of the Needs Survey over the four year period is 46,444 hours and $ 2,867,825. Exhibits A 6 10 and A 6 11 follow, providing greater detail.

Exhibit A 6 10 Burden/ Cost to EPA ( Excluding Contractor Activities)

Fiscal Year EPA Headquarters EPA Regions IHS Total Hours Cost Hours Cost Hours Cost Total Hours Total Cost FY 2002 892 $ 51,504 446 $ 18,308 60 $ 3,464 1,398 $ 73,277 FY 2003 2,020 $ 116,635 1,010 $ 41,461 64 $ 3,695 3,094 $ 161,791 FY 2004 2,020 $ 116,635 1,010 $ 41,461 64 $ 3,695 3,094 $ 161,791 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 38 FY 2005 892 $ 51,504 446 $ 18,308 20 $ 1,155 1,358 $ 70,967 TOTAL 5,824 $ 336,278 2,912 $ 119,538 208 $ 12,010 8,944 $ 467,825 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 39 Exhibit A 6 11 Burden/ Cost of Contractor Activities Activities FY 02 FY 03 FY 04 FY 05 Total Hours Cost Hours Cost Hours Cost Hours Cost Hours Cost Planning 2,000 $ 128,000 5,159 $ 330,176 3,200 $ 204,800 300 $ 19,200 10,659 $ 682,176 Survey Design 200 $ 12,800 0 $ 0 0 $ 0 0 $ 0 200 $ 12,800 Modeling 334 $ 21,376 982 $ 62,848 960 $ 61,440 960 $ 61,440 3,236 $ 207,104 Data Base Development 862 $ 55,168 1,000 $ 64,000 1,000 $ 64,000 1,000 $ 64,000 3,862 $ 247,168 Survey Production 0 $ 0 945 $ 60,480 0 $ 0 0 $ 0 945 $ 60,480 Data Analysis 0 $ 0 9,629 $ 616,256 2,533 $ 162,112 0 $ 0 12,162 $ 778,368 Report Writing 0 $ 0 208 $ 13,312 1,459 $ 93,376 700 $ 44,800 2,367 $ 151,488 Statistical Analysis 0 $ 0 94 $ 6,016 656 $ 41,984 750 $ 48,000 1,500 $ 96,000 Tech Assistance 0 $ 0 960 $ 61,440 200 $ 12,800 200 $ 12,800 1,360 $ 87,040 Training 389 $ 24,896 820 $ 52,480 0 $ 0 0 $ 0 1,209 $ 77,376 Total 3,785 $ 242,240 19,797 $ 1,267,008 10,008 $ 640,512 3,910 $ 250,240 37,500 $ 2,400,000 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 11 For several of these entities, primacy activities are actually implemented by EPA Regional offices. However, as a simplifying assumption, they are included with the States for respondent calculations under this ICR.

40 A. 6. d Estimating Respondent Universe and Total Burden and Costs Respondents for this ICR include CWSs and primacy agencies. This ICR estimates that the number of CWS respondents is 3,734 CWSs, including 3,667 CWSs in the States and 67 American Indian systems. In addition to the CWS respondents, this ICR assumes 56 primacy agencies ( 50 States plus the District of Columbia and U. S. Territories). 11 Therefore, the total number of respondents is 3,790. The total costs and burden for these respondents are summarized in Exhibits A 6 8 and A 6 9.

A. 6. e Bottom Line Burden Hours and Costs Exhibit A 6 12 summarizes the bottom line burden hours and costs for CWSs and States for this collection. The total burden for CWSs and States is 45,065 hours at a cost of $ 1,301,553.

Exhibit A 6 12 Bottom Line Respondent Burden Respondent Type Burden Hours Total Cost Community Water Systems 14,809 $ 389,032 States 30,256 $ 912,521 TOTAL 45,065 $ 1,301,553 Exhibit A 6 13 summarizes the burden hours and costs for CWSs and States per year. It is estimated that the water systems will complete the data collection instrument in 2003. It is estimated that States will incur half of the burden associated with the survey in 2003. The remaining half is assumed to be incurred evenly in 2002 and 2004. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 41 Exhibit A 6 13 Burden Hours and Costs for Respondents per Year Respondent Type Total Hour Burden ( per year) Total Cost ( per year)

2002 2003 2004 2005 2002 2003 2004 2005 CWSs 0 14,809 0 0 $ 0 $ 389,032 $ 0 $ 0 States 7,564 15,128 7,564 0 $ 228,130 $ 456,260 $ 228,130 $ 0 Total 7,564 29,937 7,564 0 $ 228,130 $ 845,293 $ 228,130 $ 0 Average 2.0 7.9 2.0 $ 60 $ 223 $ 60 Exhibit A 6 14 summarizes the bottom line burden hours and costs for EPA and IHS for this collection. The total burden for EPA ( including its contractor) and IHS is 46,444 hours at a cost of $ 2,867,825.

Exhibit A 6 14 Bottom Line Burden Hours and Costs for EPA and IHS Respondent Type Burden Hours Total Cost EPA 46,236 $ 2,855,816 IHS 208 $ 12,010 TOTAL 46,444 $ 2,867,826 A. 6. f Reasons for Change in Burden This ICR does not modify an existing ICR.

A. 6. g Burden Statement The public reporting burden for collections included in this ICR is detailed above. The total burden over the four year length of the survey to be 45,065 hours, of which 14,809 hours are attributable to CWSs and 30,256 hours to primacy agencies. These estimates include time for gathering information as well as developing and maintaining records. Public reporting burden for this collection of information is ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 12For this ICR, the number of responses is calculated at 3,790 ( 886 large systems; 2,781 medium systems, 67 American Indian systems, and 56 States and U. S. Territories). The burden per response is calculated as the total respondent burden ( 45,065) divided by the number of responses ( 3,790). Note that CWSs' burden is ranges between 1.25 and 5.39 hours per response.

13See Exhibit A 6 8.

42 estimated to average 12 hours per response. 12 Respondent burden for completing the data collection instrument is 4.00 hours. 13 Burden means the total time, effort, or financial resources expended by people to generate, maintain, retain, disclose, or provide information to or for a Federal agency. This includes the time needed to review instructions, adjust the existing ways to comply with any previously applicable instructions and requirements, train personnel to respond to the information collection request, search data sources, complete and review the collection of information, and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a request for information collection unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

Please send comments on the Agency's need for this information, accuracy of the burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques to Director, Office of Environmental Information, Collection Strategies Division, U. S. Environmental Protection Agency ( 2822T), Ariel Rios Building, 1200 Pennsylvania Ave., N. W., Washington, D. C. 20460; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA ICR number and OMB control number in any correspondence. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 43 This page intentionally left blank. 44 PART B OF THE SUPPORTING STATEMENT ( FOR STATISTICAL SURVEYS)

INTRODUCTION TO PART B EPA proposes to conduct the following type of statistical survey for the 2003 Drinking Water Infrastructure Survey. EPA proposes a mail survey of community water systems serving populations of more than 3,300. We will present a complete Part B of the Supporting Statement for the survey of community water systems serving populations of more than 3,300. EPA is proposing the same methodology for collecting data for systems serving more than 3,300 as was used in the 1999 Drinking Water Infrastructure Needs Survey. No revision to that methodology has taken place. Due to budgetary constraints, EPA is not currently proposing to collect additional data from systems serving 3,300 and fewer. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 45 This page intentionally left blank. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 46 SURVEY OF COMMUNITY WATER SYSTEMS SERVING MORE THAN 3,300 PERSONS B. 1 SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES B. 1. a Survey Objectives The primary objective of the 2003 Drinking Water Infrastructure Needs Survey is to collect information from CWSs on their infrastructure needs associated with providing safe drinking water to consumers. ( If information on costs is not available from systems, EPA proposes to collect information that will enable the Agency to model costs.) In the data collection instrument, the respondent will identify needs on a project by project basis and list the " type( s) of need" that the project will meet. The " types of need" include raw water source, transmission, source water treatment, storage, distribution, pumping stations, and other needs.

EPA will use the information from the Needs Survey to project capital investment requirements of drinking water systems. The information will be used to allot DWSRF monies among States and as part of an allotment formula for the American Indian and Alaska Native DWSRF set aside program.

EPA is proposing the same methodology for collecting data for systems serving more than 3,300 as was used in the 1999 Drinking Water Infrastructure Needs Survey. No revision to that methodology has taken place. Due to budgetary constraints, EPA is not currently proposing to collect additional data from systems serving 3,300 and fewer.

B. 1. b Key Variables Several key variables are available from SDWIS. To ensure accuracy, the survey will verify these data by asking respondents to confirm existing information ( pre printed on the survey 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.

The principal variable of interest is total projected capital need for each CWS in the survey for the period 2003  2022. Total capital needs for all systems in each State ( to be derived from the statistical sample of systems) is the key variable that decision makers at EPA need for allocation of funds to States based on need. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 47 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, if the project is to meet a current regulation or state requirement what regulation or 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 the Lists of Codes.

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 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 create cost models to impute costs. Each of these variables will be described in greater detail later in this document.

B. 1. c Statistical Approach This survey is being designed to achieve a desired level of precision for state level estimates of total capital needs for medium and large CWSs. EPA proposes to use a statistical survey approach 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.

The survey 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 to 50,000). For large CWSs, EPA proposes to conduct a mail survey and sample with certainty all systems in that category. These systems have the largest capital needs, and they have the staff to respond efficiently to the survey. For a minimal burden, we can sample with certainty in the domain that has the greatest impact on total State needs. For medium sized systems ( 3,301 to 50,000), EPA proposes to conduct a mail survey and sample with certainty systems serving between 40,001 and 50,000 and conduct a statistical sample of systems serving between 3,301 and 40,000. By using this methodology, we can reduce burden and still achieve our precision targets. Since State level precision is important for EPA decision makers, we have selected a two step approach to sampling. First, we will determine the total sample size per State ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 48 to meet the target level of precision. Second, we will allocate the sample to strata in order to maximize the efficiency of our design.

EPA is designing and conducting the survey with the assistance of several contractors, as listed below:

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.

Abt Associates Inc. 55 Wheeler Street Cambridge, MA 02138 ° Statistical sample design.

B. 1. d Feasibility The survey 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 around the country 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 survey instrument is currently being pre tested, as described in Section B. 3. a, below.

The Agency recognizes that some medium sized systems ( and a few large CWSs) may not have cost data or documentation of costs for some projects. In those cases, the survey 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 this survey. In addition, EPA ( or States) will provide large and medium CWSs with a helpline to assist them in completing the data collection instrument.

Sufficient contract funds have been identified to complete the survey. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 49 The time frame for the survey is acceptable to the users of data within the Office of Ground Water and Drinking Water and sufficient to complete a report to Congress by its anticipated due date of early 2005. The schedule also is acceptable to other users of the data including: the Indian Health Service of the U. S. Department of Health and Human Services, State drinking water administrators, and American Indian and Alaska Native representatives. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 50 B. 2 SURVEY DESIGN FOR MEDIUM AND LARGE CWSs 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, pretest, collection methods, and follow up procedures.

The sample design for the Needs Survey is based on the concept of stratified random sampling within each State. Stratification increases the precision of estimates compared with a simple random sample of a target population. 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 more than 50,000, populations of 40,001 to 50,000, 25,001 to 40,000, 10,001 to 25,000, and 3,301 to 10,000), and primary source of supply ( surface and ground).

There are two steps in the stratification process. The first step is to compute a total sample size for the target populations ( i. e., systems serving populations of more than 3,300 in each state) that will provide a pre specified level of precision. For example, in this survey, our 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 a total sample size has been determined for the entire population of CWSs serving populations of more than 3,300 in a State, the number of samples to be taken in each of the within State strata will be computed ( or allocated). Samples will be allocated in a manner that minimizes the variance of the variable of interest ( total capital costs) being estimated for the population in each state. For the allocation of samples in systems serving populations of more than 3,300, we employ an allocation method referred to as Neyman allocation. The Neyman allocation is described in detail in Section B. 2. b. ii.

B. 2. a Target Population and Coverage The target population is CWSs serving populations greater than 3,300. A CWS is a public water system that serves at least 15 service connections used by year round residents or regularly serves at least 25 year round residents ( 40 CFR 141.2).

B. 2. b Sample Design This section describes the sample design. It includes a description of the sampling frame, target sample size, stratification variables, and sampling method. The sampling design employed is a stratified random sample of CWSs. The strata employed in the design are discussed in Section B. 2. b. iii. Neyman allocation is used to efficiently allocate the sample of water systems among the strata. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 51 B. 2. b. i Sampling Frame The sampling frame is developed from SDWIS. SDWIS is a centralized database for information on public water systems, including their compliance with monitoring requirements, maximum contaminant levels ( MCLs), and other requirements of the SDWA Amendments of 1996. The following information will be extracted from SDWIS for the statistical survey and verified by participating States:

° Name of system ° Address of system ° Population served ° Total design capacity ° Number of connections ° Primary source ( surface water or ground water) ° PWSID ° Ownership type ° Consecutive system ( i. e., does system purchase or sell water)

From these data, we will develop a list frame from which we 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 from which take part in the survey.

Justification for the Use of SDWIS Criteria often used in assessing a proposed sampling frame are:

° 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 public water systems ( PWSs). SDWIS is the ideal choice for a sample frame because of its inclusive coverage of all units of observation for this survey. 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 the following:

° Errors in classification of systems by strata proposed for this survey are rare. Audits show that systems are misclassified by population or source in fewer than one percent of all cases. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 52 Aspects of the proposed sample design that mitigate any potential problems with the sample frame include the following:

° The survey design anticipates substantial State involvement in the survey process. Participating States, for example, will be checking the sample frame of systems that will be used to determine the final sample. In our 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 Exhibit B 2 1 at the end of this subsection shows the preliminary sample sizes for the survey. 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. b. iii.

The task of designing a sample size requires two steps. The first is selecting a sample size for each State that achieves the precision targets for that state. The second is allocating the sample across the relevant strata in the population. As stated in the introduction to this section, we have ten possible strata within each State, based on five population categories and two categories for source of supply.

These strata are:

Size of Population Served Source Sample Methodologies More than 50,000 Ground Sampled with certainty More than 50,000 Surface 40,001 to 50,000 Ground 40,001 to 50,000 Surface 25,001 to 40,000 Ground Random sample. In some States the number of strata will be reduced based on analysis of optimal stratum boundaries. Specifically, in some States one grouping for systems serving between 10,001 to 40,000, will be used ( versus two groupings for populations of 10,001 to 25,000 and 25,000 to 40,000), provided the survey's precision is not affected. 25,001 to 40,000 Surface 10,001 to 25,000 Ground 10,001 to 25,000 Surface 3,301 to 10,000 Ground Random sample. 3,301 to 10,000 Surface The first step in selecting sample size is calculating the total number of samples required at the State level to meet the precision requirements. This estimate is calculated from: ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 14J. Neyman, " On the Two Different Aspects of the Representative Method: The Method of Stratified Sampling and the Method of Purposive Selection," Journal of the Royal Statistical Society, Vol. 97 ( 1934), pp. 558 606; as cited in William G. Cochran, Sampling Techniques ( New York: John Wiley & Sons), 1977.

53 n 0g

H h

1 N gh s gh 2 V g ( 4)

n g

n 0g 1  1 V g

H h

1 N gh s 2 gh ( 5) 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 ( taken from existing 1999 Drinking Water Infrastructure Needs Survey data)

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.

The desired error in the sample estimate can be expressed as a relative error or an absolute error. From a relative error perspective, one often specifies the desired coefficient of variation ( cv) rather than the desired variance of the sample estimate. In Equation 1 above, Vg = ( cv *

g) 2.

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

g is computed for each State by calculating the mean total capital needs for stratum h ( from the 1999 Needs Survey) and multiplying by the actual number of systems in each stratum for that State ( Ngh). Summing across strata provides an estimate of

g.

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

The second step involves allocating the total number of samples to each of the six strata ( i. e., we will randomly draw this number of samples from each of these strata). The Neyman allocation formula is used for the allocation: 14 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 54 n gh

n g N gh S gh

H h

1 N gh s gh ( 6)

Note: Since large systems ( those serving populations more than 50,000) 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, we needed estimates for Vg, Ngh, sgh, and mean total capital needs by stratum. Information on mean total capital needs by stratum and sgh were available from the 1999 Needs Survey.

We set the precision level for the estimate of capital need for all large and medium systems in each State to be 95 percent confident that the true need is within 10 percent of the estimated need. This implies a cv of 5.1 percent ( i. e., ten percent divided by 1.96). ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 55 Exhibit B 2 1 State Sample Sizes State Total Number of Medium and Large Systems Estimated Sample Size for Medium and Large Systems Alabama 242 105 Alaska 15 13 American Samoa 1 1 Arizona 85 60 Arkansas 159 112 California 620 253 Colorado 96 67 Connecticut 58 40 Delaware 11 10 District of Columbia 1 1 Florida 370 121 Georgia 183 91 Guam 3 3 Hawaii 28 21 Idaho 38 25 Illinois 434 114 Indiana 180 103 Iowa 113 93 Kansas 84 39 Kentucky 219 111 Louisiana 197 81 Maine 32 15 Maryland 49 35 Massachusetts 238 75 Michigan 261 81 Minnesota 142 74 Mississippi 156 99 Missouri 162 54 Montana 28 26 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 State Total Number of Medium and Large Systems Estimated Sample Size for Medium and Large Systems 56 Nebraska 42 20 Nevada 25 20 New Hampshire 34 26 New Jersey 228 67 New Mexico 51 52 New York 305 305 North Carolina 225 93 North Dakota 23 19 Northern Mariana Islands 1 4 Ohio 304 94 Oklahoma 137 69 Oregon 95 51 Pennsylvania 314 115 Puerto Rico 113 63 Rhode Island 26 25 South Carolina 141 80 South Dakota 29 20 Tennessee 231 108 Texas 742 181 Utah 88 41 Vermont 30 25 Virgin Islands 3 3 Virginia 122 85 Washington 181 60 West Virginia 74 36 Wisconsin 156 57 Wyoming 24 25 Total 7,949 3,667 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 15For the purposes of this survey, purchased surface water systems are included with ground water systems. This design yields lower within stratum variance.

16For purposes of burden calculation, we assume 100 percent response. New York State has indicated that it plans to increase its sample size by 187 systems in order to achieve a census of its systems. This will not affect the statistical precision of the estimate. However, for completeness, we are including these 187 systems in the burden estimate.

57 B. 2. b. iii Stratification Variables The objective of stratification is to increase the efficiency of the sampling design ( thereby reducing the number of samples required at any level of precision) by the creation of independent strata. Stratified sampling may produce a gain in precision in the estimates of the characteristics of the target population as compared to simple random sampling. In stratified sampling, the target population ( e. g., the State) 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 by the CWS), and ( 2) primary source ( ground water and surface water). 15 Using total capital need information obtained from the 1999 Drinking Water Infrastructure Needs Survey, we evaluated several classification schemes. This analysis showed that the stratification scheme selected for this survey ( ten 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 survey's overall precision is not affected.

B. 2. b. iv Sampling Method As indicated above, all CWSs serving populations of more than 40,000 will be sampled with certainty.

For systems serving 3,301 to 40,000 persons, all CWSs will be allocated to six strata, based on population served and primary source. The sample size for each stratum in each State will be determined by the sampling strategy outlined above. The sampling method will be an equal probability systematic sample within each stratum. Anticipating a level of non response, we will over sample to achieve the desired number of completed data collection instruments. Since the expected response rate for systems serving 3,301 to 40,000 persons is 90 percent, we will draw a sample of 2,588.16 ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 58 B. 2. b. v Multi Stage Sampling The design does not include multi stage sampling.

B. 2. c Precision Requirements B. 2. c. i Precision Targets The sampling design for large and medium systems will be implemented at the State level. Our goal is to be 95 percent confident that the margin of error, when estimating the total capital needs facing these systems in each State will be plus or minus 10 percent of the sample mean. For example, if the total need for these systems in a State is estimated to be $ 2 billion, we will be 95 percent confident that the actual total need is between $ 1.8 billion and $ 2.2 billion.

B. 2. c. ii Nonsampling Error EPA has developed a survey approach that will employ several quality assurance techniques to maximize response rates, response accuracy, and processing accuracy to minimize nonsampling error. A pretest will supplement the experience of EPA and its contractors ( The Cadmus Group, Inc.) in formulating a strategy to reduce non sampling error.

Particular emphasis will be placed on maximizing response rate. Standard methods that have proved effective in other surveys of CWSs will be used. These include:

° States will review the sample of systems to receive the mail survey instrument and will ensure that the best person to receive the data collection instrument is determined in advance.

° EPA and the States will coordinate in the production of a cover letter for the survey. EPA's opinion ( shared by State drinking water administrators, trade associations, and public water systems), is that surveys on State letterhead will be better received than letters on EPA letterhead. Therefore, States can use State level cover letters signed by a senior State official instead of the EPA letter.

° The data collection instrument design, content, and format have been reviewed by organizations representing CWSs. In addition, the data collection instrument design, content, and format were reviewed by States that participated in the 1995 and 1999 Drinking Water Infrastructure Needs Surveys.

° The data collection instrument design, content, and format will be pretested to ensure that all questions are properly stated and can be answered by all systems in the mail survey. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 59 ° Items being asked are those that owners or operators of systems serving populations greater than 3,300 should know. We do not ask for items that require monitoring, research, or calculations on the part of the respondent.

° The data collection instrument design is limited to 12 pages. By limiting the information requested, we believe that the average respondent can complete the instrument in approximately 4 hours.

° Toll free phone numbers will be provided to help respondents with questions or problems. In addition, respondents will be encouraged to call State personnel who will be trained to answer questions.

° Pre paid return envelopes will be provided to respondents to make returning the data collection instrument convenient.

Standard methods to reduce other sources of non sampling error also will be used.

° We expect complete coverage of the target population using SDWIS, supplemented by State agency review of all systems.

° Data will be 100 percent independently keyed and verified.

° The data collection instrument is precoded to improve accuracy by eliminating unnecessary processing steps.

Supplementing these standard methods, EPA proposes several unique steps to eliminate nonsampling error, which have been developed in concert with organizations representing the States and CWSs. These organizations believe that the survey is important and that a high level of participation by all CWSs is essential to its success. Because of the substantial commitment being made by States and CWSs to this survey, we believe that response rates will be higher than most surveys of similar respondents. To ensure success, States and organizations representing CWSs are taking the following steps.

° Participation of the States. Because the Needs Survey will be used to allocate DWSRF funds to States, each State has a strong interest in achieving a high response rate. EPA believes that State participation will be a key factor in guaranteeing high response rate and low item non response. State personnel who work with CWSs every day are in a strong position to encourage systems to complete the survey form. These States have committed to assisting EPA in achieving a high response rate by participating in follow up activities. The States also will be available for technical assistance for any system that has questions about the survey. All States have already agreed to participate in the survey.

° Participation of Organizations Representing CWSs. EPA anticipates public support of organizations representing CWSs. The prior surveys were supported by groups such as: ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 60 the American Water Works Association, the National Association of Water Companies, and the Association of Metropolitan Water Agencies.

This support by the organizations representing the respondents for this survey can be helpful in many ways to minimize non sampling errors. For example,

  These associations are likely to agree to prepare a letter for each system in their membership, stressing the importance of this survey of drinking water infrastructure needs. This letter, along with the letter from the States, should make systems more likely to respond.

  In the past Drinking Water Infrastructure Needs Surveys, the largest association representing CWSs serving populations greater than 3,300   the American Water Works Association ( AWWA)   agreed to put the support of its national organization behind the survey. To improve the response rate, the AWWA enlisted of the support of its State affiliates ( called " Sections") in telephone followup to encourage response. AWWA assisted in past Drinking Water Infrastructure Needs Survey to help achieve the overall response rate of 94 percent. EPA hopes to secure similar AWWA support for this survey.

° Communications Strategy. EPA has developed a comprehensive communications strategy that will inform likely respondents of the need for their participation. This strategy includes articles in magazines, newsletters, and bulletins of all major organizations that represent ( or communicate with) CWSs. This includes publications of all of the organizations mentioned above, plus the State and local affiliates of these organizations. The strategy is designed to develop widespread peer group support for participation in the survey.

B. 2. d Data Collection Instrument Design Questions about system characteristics ( name, population served, number of connections, and other customary business information) will be pre printed on all data collection instruments. The respondent needs only to enter accurate information if any pre printed information is not correct.

The survey is based on matrices that requests a list of capital projects that the system plans for the period 2003 through 2022. For each project listed, the system is asked to provide: 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; if the project is to meet a current regulation or state requirement then what regulation or 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 of need," or " regulation or requirement," from the Lists of Codes. All matrices ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 61 have been designed to be concise, to avoid jargon, and to avoid ambiguous words or instructions. Terms and formats have been standardized to the extent possible. There is no intentional bias in the ordering of the items. All design features will be tested in the pretest. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 62 B. 3 PRETESTS AND PILOT TEST B. 3. a Pretests EPA will conduct a pretest of the instrument in order to receive feedback on the effectiveness of the instrument, highlight imprecise, ambiguous, or redundant questions, and indicate where further inquiry is needed. The pretest will include nine randomly selected systems from Maryland. Both large and medium systems will be pretested.

The pretest will be conducted by EPA's contractor, The Cadmus Group, Inc., and a report should be completed by August 18, 2002. Results will be submitted to OMB as soon as it is complete.

B. 3. b Pilot Test EPA will not conduct a pilot test for the 2003 Drinking Water Infrastructure Needs Survey. A pilot test was conducted for the 1995 Needs Survey and consisted of 60 CWSs from New York and Texas. To eliminate unnecessary burden on States and CWSs, it has been decided that no pilot test for the 2003 Needs Survey will be conducted. The procedures for mailing the data collection instruments and collecting the data are the same as was used for the 1995 and 1999 Drinking Water Infrastructure Needs Surveys. EPA believes these procedures are well tested and have proven to be successful; therefore, it is not necessary repeat this testing step. ICR for the 2003 Drinking Water Infrastructure Needs Survey September 2002 63 B. 4 COLLECTION METHODS AND FOLLOW UP B. 4. a Collection Method The collection method proposed is a mail survey. The study data collection instrument and Lists of Codes will be mailed to all systems in the sample. State drinking water agencies will begin follow up if the mail data collection instrument has not been returned in 30 days. For a complete description of the followup procedures proposed to increase response rate, see the following paragraph.

B. 4. b Survey Response and Follow up The target response rate for the survey ( defined as the ratio of responses to eligible respondents) is 90 percent. We realize that this is an ambitious target, but we believe that there are special circumstances that warrant such a target and overall response rates of 94 percent and 97 percent were achieved in the 1995 and 1999 surveys, respectively. In the first two surveys, we conducted the following proposed activities to achieve that high response rate.