Information Collection Request for the 2015 Drinking Water Infrastructure Needs Survey and Assessment (DWINSA)
(Supporting Statement for ICRAS and ROCIS)

Final Draft October 23, 2014

Prepared by:

The Cadmus Group, Inc.
100 5[th] Avenue, Suite 100
Waltham, MA 02451

Prepared for:

U.S. Environmental Protection Agency
Office of Ground Water and Drinking Water
Drinking Water Protection Division

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Table of Contents

PART A OF THE SUPPORTING STATEMENT	1
A.1	IDENTIFICATION OF THE INFORMATION COLLECTION	1
A.1.a	Title of the Information Collection Request	1
A.1.b	Short Characterization	1
A.2	NEED FOR AND USE OF THE COLLECTION	2
A.2.a	Authority and Need for the Collection	2
A.2.b	Use and Users of the Information	2
A.3	NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA	3
A.3.a	Nonduplication	3
A.3.b	Public Notice Required Prior to ICR Submission to OMB	4
A.3.c	Consultations	4
A.3.d	Effects of Less Frequent Collection	5
A.3.e	General Guidelines	5
A.3.f	Confidentiality Questions	5
A.3.g	Sensitive Questions	6
A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED	8
A.4.a	Respondents/NAICS Codes	8
A.4.b	Information Requested	9
A.5	INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY AND INFORMATION MANAGEMENT	14
A.5.a	Agency Activities	14
A.5.b	Collection Methodology and Management	15
A.5.c	Small Entity Flexibility	19
A.5.d	Collection Schedule	19
A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	20
A.6.a	Respondent Burden	20
A.6.b	Respondent Costs	32
A.6.c	Agency Burden and Cost	33
A.6.d	Estimating Respondent Universe and Total Burden and Costs	36
A.6.e	Bottom Line Burden Hours and Costs	36
A.6.f	Reasons for Change in Burden	40
A.6.g	Burden Statement	40
PART B OF THE SUPPORTING STATEMENT (FOR STATISTICAL SURVEYS)	41
B.1	SURVEY OBJECTIVES, KEY VARIABLES AND OTHER PRELIMINARIES	43
B.1.a	Survey Objectives	43
B.1.b	Key Variables	43
B.1.c	Statistical Approach	44
B.1.d	Feasibility	45
B.2	SURVEY DESIGN	46
B.2.a	Target Population and Coverage	46
B.2.b	Sample Design	47
B.2.c	Precision Requirements	53
B.2.d	Data Collection Instrument Design	55
B.3	PRE-TESTS AND PILOT TEST	55
B.3.a	Pre-tests	55
B.3.b	Pilot Test	56
B.4	COLLECTION METHODS AND FOLLOW-UP	56
B.4.a	Collection Method	56
B.4.b	Survey Response and Follow-up	56
B.5	ANALYZING AND REPORTING SURVEY RESULTS	57
B.5.a	Data Preparation	57
B.5.b	Analysis	57
B.5.c	Reporting Results	57

List of Appendices

Appendix A  -  Public Notice Required Prior to ICR Submission to OMB
Appendix B  -  Data Collection Instrument and Lists of Codes
Appendix C  -  Comments and Response to Comments Received on the 2015 DWINSA Peer Review
Appendix D  -  Comments and Response to Comments Received on the First Federal Register Notice

List of Tables

Exhibit A-5-1 Collection Schedule	19
Exhibit A-6-1 Estimated Average Unit Burden for Systems Serving More Than 50,000 Persons	23
Exhibit A-6-2 Estimated Average Unit Burden for Systems Serving 3,301 to 50,000 Persons	26
Exhibit A-6-3 State Unit Burden for Up-Front Activities	27
Exhibit A-6-4 State Unit Burden for Systems Serving More Than 50,000 Persons	29
Exhibit A-6-5 Estimated State Average Unit Burden for Systems Serving 3,301 to 50,000 Persons	31
Exhibit A-6-6 Total Burden and Cost to Water Systems	32
Exhibit A-6-7 Total Burden and Cost to States	33
Exhibit A-6-8 Burden/Cost to EPA (Excluding Contractor Activities)	34
Exhibit A-6-9 Burden/Cost of Contractor Activities	35
Exhibit A-6-10 Bottom Line Respondent Burden	36
Exhibit A-6-11 Burden Hours and Costs for Respondents per Year	36
Exhibit A-6-12 Bottom Line Burden Hours and Costs for EPA (including EPA's contractor)	37
Exhibit A-6-13 Disaggregated Burden by Affected Information Collection (IC) Entities	38
Exhibit B-2-1 State Sample Sizes	49

PART A OF THE SUPPORTING STATEMENT
A.1	IDENTIFICATION OF THE INFORMATION COLLECTION
A.1.a	Title of the Information Collection Request
The title of this information collection request (ICR) is Information Collection Request for the 2015 Drinking Water Infrastructure Needs Survey and Assessment (DWINSA). The Office of Management and Budget (OMB) control number for this ICR is 2234.04; EPA ICR No. 2014-0274.
A.1.b	Short Characterization
The Environmental Protection Agency (EPA) will conduct an assessment to estimate the capital investment needs of drinking water systems eligible to receive Drinking Water State Revolving Fund (DWSRF) monies. The nationwide assessment will be conducted by the Drinking Water Protection Division (DWPD) of EPA's Office of Ground Water and Drinking Water (OGWDW). The data collection is authorized by Sections 1452(h) and 1452(i)(4) of the Safe Drinking Water Act (SDWA) and will be used to estimate the capital investment cost of providing safe drinking water to consumers over a 20-year period. The data from the report will also be used to allot DWSRF monies among states.
In determining an appropriate survey approach, EPA strives to achieve an acceptable level of statistical precision and avoid measurement errors while minimizing the burden placed on the states, water systems and the Agency in conducting the survey effort.  The two sources of potential inaccuracy in the survey results are "measurement error," which arises when determining the need for each individual infrastructure investment, and "sampling error," which occurs when estimating the needs of all water systems from a representative sample of those systems. EPA strives to reduce measurement error by relying on information from and judgment of those individuals most familiar with and directly responsible for the infrastructure, the owners and operators of water systems, and by assuring that their estimates of investment needs are within the context of the industry's best engineering practices. EPA addresses the sampling error by identifying and specifying statistical precision targets for the survey and determining the necessary sample and sub-sample sizes to achieve those targets
The 2015 DWINSA will focus on data collection from water systems overseen by state drinking water programs, referred to in previous DWINSA ICRs and reports to Congress as a "state survey." All states have committed to help EPA administer the 2015 DWINSA with at least a minimum set of activities. For this document, the term "states" refers to all 50 states, the U.S. territories (Guam, U.S. Virgin Islands, Northern Mariana Islands and American Samoa), Puerto Rico and the District of Columbia.
EPA will conduct a census of all community water systems (CWSs) serving populations more than 100,000. For CWSs serving populations of 3,301 to 100,000, EPA proposes to use a modified panel approach that will reassess the needs of most of the water systems that participated in the 2011 DWINSA. The modified panel approach will involve dropping a random selection of 25 percent of the systems serving 3,301 to 100,000 people that participated in the 2011 DWINSA and then drawing a random sample to replace those systems in the survey for the 2015 DWINSA. The approach will be implemented by state and stratum.
Fifteen states are expected not to participate in the statistical portion of the survey (i.e., collecting data from systems serving 3,301 to 100,000 persons). The needs of the participating states will be used to estimate the needs for systems serving 3,301 to 100,000 persons for the states that are not included in the statistical portion of the survey. All states with systems serving more than 100,000 persons will participate in the census portion of the survey.
For the 2015 DWINSA, EPA will not collect data from small CWSs in states (those serving 3,300 and fewer people), not-for-profit noncommunity water systems (NPNCWSs)  or American Indian or Alaska Native Village water systems. EPA will estimate the infrastructure needs for CWSs serving 3,300 and fewer persons based on the average system need calculated in the 2007 DWINSA, adjusted for inflation. Similarly, the infrastructure needs for NPNCWSs will be based on the 1999 DWINSA results, adjusted for inflation. The 2011 DWINSA included a survey of American Indian and Alaska Native Village water systems; those results will be adjusted for inflation for the 2015 DWINSA.
The data collection instrument to be used consists of project tables in which the water systems list all their capital improvement projects for the survey period of January 1, 2015, to December 31, 2034. The data collection instrument used will be in a Microsoft Excel format, with no significant changes in content or questions from the previous three DWINSAs.
The effort for the 2015 DWINSA will involve 2,915 respondents (2,859 water systems and 56 states), requiring 37,194 hours at a total cost to the respondents of $1,734,004. 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 5.53 hours and the average burden for a state response is 381.64 hours.
A.2	NEED FOR AND USE OF THE COLLECTION
A.2.a	Authority and Need for the Collection
EPA (the Agency) is conducting this DWINSA pursuant to its authority under Sections 1452(h) and 1452(i)(4) of the SDWA. Section 1452(h) requires that "the Administrator shall conduct an assessment of water system capital improvement needs of all eligible public water systems in the United States and submit a report to the Congress containing the results of such assessment within 180 days after the date of the enactment of the SDWA Amendments of 1996 and every 4 years thereafter." Section 1452(i)(4) requires that "the Administrator, in consultation with the Director of the Indian Health Service and Indian Tribes, shall, in accordance with a schedule that is consistent with the needs surveys conducted pursuant to subsection (h), prepare surveys and assess the needs of drinking water treatment facilities to serve Indian Tribes, including an evaluation of the public water systems that pose the most significant threats to public health."
A.2.b	Use and Users of the Information
The results of the DWINSA will be used as a basis for allocation of DWSRF funds among states and contributes to the allocation of DWSRF funds to EPA Regions and Tribes with primacy enforcement authority for American Indian and Alaska Native Village water systems. In addition, many water systems have empirical data on the cost of compliance with SDWA regulations. A national assessment improves the Agency's ability to gauge long-term capital costs of SDWA regulations.
EPA will collect two types of system-specific information:
   1. System inventory and characteristics data (i.e., name and address of the system, contact person, population served, total design capacity, number of connections, primary source, whether the water system is privately or publicly owned and whether the water system purchases/sells water from/to another water system).
   2. Information on capital improvement projects.
The specific uses of each data type vary. EPA will use system inventory and characteristics data to characterize CWSs nationwide and, in some cases, to model costs for individual water systems' capital improvement projects. EPA will use all data collected to estimate state and national needs.
Respondents will identify capital improvement needs on a project-by-project basis and identify the reason for the project on the data collection instrument. EPA will collect information on the proposed infrastructure to be installed, replaced, rehabilitated, upgraded or expanded. EPA will use the information to assess project allowability, which is determined by DWSRF funding allowability and DWINSA policies.
Respondents will also identify either a documented cost estimate for the project or will provide adequate information so that EPA can model the cost of the project. The information needed to model the cost will depend on the type of need. For example, EPA may collect information on the size and number of meters or the diameter and length of transmission or distribution lines. For the 2011 DWINSA, approximately 15 percent of the projects reported had documented costs; the costs for the remaining 85 percent of projects were modeled.

A.3	NONDUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA
The following sections verify that this information collection satisfies the OMB's non-duplication and consultation guidelines and does not duplicate another collection.
A.3.a	Non-duplication
To the best of EPA's knowledge, up-to-date state-by-state information on water systems' capital needs is not available from any other source. Some of the data collection efforts EPA considered include the following:
 Safe Drinking Water Information System (SDWIS). Inventory data and information on system characteristics have been collected by states and EPA Regions and entered into the SDWIS. For systems in the statistical sample, EPA will pre-populate the SDWIS system characteristics data (i.e., name and address of the system, contact person, address, population served, total design capacity, number of connections, primary source, whether the system is privately or publicly owned and whether the system purchases/sells water from/to another water system) on the 2015 DWINSA form and ask the respondents to provide information only if the SDWIS data are inaccurate or missing. SDWIS does not contain information on water systems' capital needs.
 Community Water System Survey (CWSS). EPA completed a statistical survey in 2006 that focused on the operating and financial characteristics of CWSs. The CWSS is addressed in the ICR for the National Survey of the Financial and Operating Characteristics of Community Water Suppliers. The CWSS had a different objective than the DWINSA. The CWSS was designed to characterize technical and financial aspects of CWSs. In contrast, the DWINSA will be used to develop national estimates of capital needs. In addition, the CWSS's targeted precision was on a national basis, whereas the DWINSA will provide state-by-state estimates.
 Economic Analyses (EAs) for National Primary Drinking Water Regulations. The Agency has developed EAs for its National Primary Drinking Water Regulations. These documents estimate the costs of complying with proposed and final regulations. EAs do not typically include an estimate for capital projects needed to maintain compliance with existing regulations. Therefore, the EAs are not an adequate substitute for the DWINSA. In addition, the EAs provide nationwide estimates. As discussed above, EPA is conducting the DWINSA because the Agency needs a state-by-state estimate to develop the allocation formula for the DWSRF. Also, EAs may not, depending on when they were developed, reflect currently available contaminant occurrence data or current or emerging treatment technology costs.
 State Needs Surveys. Several states have conducted needs surveys of their own drinking water systems. The state results cannot be extrapolated to the nation as a whole because the state surveys do not use consistent methodologies and do not account for national variations in system characteristics and needs.

 1995, 1999, 2003, 2007 and 2011 DWINSAs. Under the SDWA, EPA must conduct the DWINSA every four years. The approach for the 2015 DWINSA will incorporate some data collected during the previous assessments updated to reflect 2015 construction costs and shifts in the number and characteristics of the Nation's water utilities.   The approach for the 2015 DWINSA also includes substantial new data from the field to ensure up-to-date information on changes in the relative level of infrastructure needs at the state level as well as change in the total national need.
A.3.b	Public Notice Required Prior to ICR Submission to OMB
To comply with the 1995 Amendments to the Paperwork Reduction Act (PRA), EPA is soliciting public comment on this ICR for a 60-day period before it is 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 (2234.04). This notice is included in Appendix A. Before submission to OMB, EPA will consider any comments received and determine 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 will be included in Appendix D. An additional Federal Register notice will be published when this ICR is submitted to OMB. The public comment period for this additional notice will be 30 days.
A.3.c	Consultations
In May 2014, EPA assembled a workgroup that consisted of EPA Headquarters, EPA Regions and state representatives to discuss the approach for the 2015 DWINSA. The purposes of the workgroup were to gather information on state and/or regional concerns, to discuss lessons learned during the 2011 DWINSA and to discuss new policies for the 2015 DWINSA. The information gathered by the workgroup contributed to the development of the methodology for the 2015 DWINSA.
For the 2007 DWINSA, the data collection instrument and some policies were modified substantially. Consequently, in 2007, EPA conducted a pre-test of the data collection instrument (see B.3 for more information on the pre-test) and a formal peer review of the 2007 DWINSA statistical methodology and policies. Based on comments received from the peer review and the pre-test, EPA made modifications to the data collection instrument, statistical procedures and survey polices.
The data collection instrument was further modified for the 2011 DWINSA by the addition of optional questions to gather information on "green" and climate readiness infrastructure projects. Consequently, EPA conducted a limited peer review focused on these new questions. The peer review included experts familiar with the operations of drinking water systems and "green" and climate readiness issues. Based on comments received from the peer review, EPA developed an addendum to the 2011 survey instructions that provided additional explanation about why EPA was interested in collecting information on "green" and climate readiness infrastructure projects as well as providing examples of what might constitute "green" and climate readiness. Based on the limited number of states that submitted projects with "green" or climate readiness attributes indicated, EPA concluded these attributes were likely underreported in 2011. For the 2015 DWINSA, the "green" and climate readiness questions will be removed from the data collection instrument. Instead, EPA will explore streamlined approaches that might enable the Agency, during the Survey review process, to identify and flag projects that are likely to have "green," climate readiness or climate resilience attributes.
The other significant modification for the 2015 data collection methodology will be the use of a modified panel approach. This approach uses a longitudinal study method for the survey with a 25 percent refresh of the sample (by state and by strata) of systems serving 3,301 to 100,000 population (this approach is described in more detail in Section B.2). EPA conducted a peer review of the applicability of this modified panel approach and the details of the approach. EPA considered comments from the peer review and made changes to the approach as necessary as described in Appendix C.
A.3.d	Effects of Less Frequent Collection
The 2015 DWINSA is a single collection and does not involve periodic reporting or recordkeeping.
A.3.e	General Guidelines
The 2015 DWINSA does not violate any guidelines for information collection activities specified by OMB. Specifically, the 2015 DWINSA respondents are not required to:
 Report information to EPA more often than quarterly.
 Retain records for more than three years.
 Complete the data collection instrument in fewer than 30 days.
 Maintain or provide information in a format other than that in which it is customarily maintained.
 Submit proprietary, trade secret or other confidential information.
 Submit more than one original and two copies of any document.
The information collection:
 Is a statistical assessment designed to produce data that can be generalized to the universe of the study (see Section B.2).
 Does not provide remuneration to participants.
 Will transcribe information collected into an automated format.
 Is designed with small entities particularly in mind (see Part A.5.c).
 Does not concern grants or grantees.
 Is voluntary.

A.3.f	Confidentiality Questions
This information collection does not require the respondent to disclose any confidential information. Respondents are not obliged to respond to this strictly voluntary information collection. Further, respondents could eliminate any confidential business information from their reply.
A.3.g	Sensitive Questions
The 2015 DWINSA does not ask sensitive questions.

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A.4	THE RESPONDENTS AND THE INFORMATION REQUESTED
A.4.a	Respondents/NAICS Codes
NAICS Codes
The respondents for the 2015 DWINSA are CWSs in states and state agencies that include drinking water programs. CWSs are considered public water systems. According to 40 CFR Part 141.2, a CWS is a "public water system which serves at least 15 service connections used by year-round residents or regularly serves at least 25 year-round residents." The North American Industry Classification System (NAICS) code for a public water system is 221310. State agencies that include drinking water programs are classified as NAICS code 924110 (Administration of Air and Water Resources and Solid Waste Management Programs) or 926130 (Regulation and Administration of Communications, Electric, Gas and Other Utilities). Ancillary systems (i.e., those that supplement the function of other establishments like factories, power plants, mobile home parks, etc.) cannot be categorized in a single NAICS code. For ancillary systems, the NAICS code is that of the primary establishment or industry.
Respondents
EPA will gather information from CWSs serving more than 3,300 persons. For the purposes of this document, EPA will use inventory and sample numbers from the 2011 DWINSA to approximate sample sizes for 2015.
Because of their variability and significant contribution to the overall drinking water capital investment need, water systems serving more than 100,000 persons will be sampled with certainty. The burden estimates assume that EPA will survey approximately 612 water systems that serve more than 100,000 persons.
There are 8,927 water systems that serve populations of 3,301 to 100,000. Surveying all of these water systems would impose a large burden on respondents, EPA and states. Therefore, EPA will select a statistically representative sample of water systems serving populations of 3,301 to 100,000. As described in Section B.2., a modified panel approach will be used to select water systems to be sampled. This approach will result in a re-sampling of 75 percent or more of the water systems that were sampled in 2011. Based on the sampling conducted in 2011, the burden estimates assume that EPA will survey approximately 2,247 water systems that serve 3,301 to 100,000 persons.
EPA will not collect new needs data from NPNCWSs, small CWSs in states, Alaska Native Village water systems or American Indian water systems. EPA will instead extrapolate the findings for these systems from previous Needs Surveys to 2015 dollars taking into account changes in the number of these systems in current operation.
For purposes of this burden statement, EPA is assuming that fifty-six states (50 states plus the District of Columbia, Puerto Rico, Northern Mariana Islands, American Samoa, Guam and the U.S. Virgin Islands) will be called upon to provide support and information for the approximately 2,859 systems for the 2015 DWINSA.
A.4.b	Information Requested
As previously discussed, EPA will collect two types of information from systems:
   1. System inventory and characteristics.
   2. Information on capital improvement projects.
EPA anticipates that respondents will provide varying levels of information by system size category. Based on experience from the previous five DWINSAs, EPA generally expects larger systems (e.g., those systems serving more than 50,000 persons) to have a well-developed understanding of their capital needs and the costs for meeting them. Almost all of these systems will have detailed Capital Improvement Plans (CIPs). Most of these systems will be capable of providing accurate information on cost. Most medium-sized systems (e.g., those systems serving 3,301 to 50,000 persons) can provide reliable data on their needs and some can provide cost estimates for meeting their needs. The information that respondents will be asked to provide is generally maintained and reported as a function of the management and operation of the water system.
A.4.b.i 	Data Items
2015 DWINSA  -  Systems Serving More Than 3,300 Persons
The data collection instrument asks respondents to verify or correct system characteristic information (i.e., name and address of the system, contact person, address, population served, total design capacity, number of connections, primary source, whether the water system is privately or publicly owned and whether the water system purchases/sells water from/to another water system). It is customary business practice for the water system to maintain this information. The respondent will either indicate that the information is correct as provided or enter the correct information in the space provided. States verify this information in advance of the data collection instrument being sent to the water systems. Based on previous assessments, EPA anticipates that very few water systems will need to correct the information provided.
In addition, the respondent is asked to provide information associated with specific types of projects:
   * source;
   * treatment;
   * finished or treated water storage and pumping;
   * transmission and distribution; and
 backflow prevention devices/assemblies, service lines, valves, water meters and other (projects not associated with one of the specified project types).
For each project, 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," "storage tank rehabilitation"). Information is collected on a project-by-project basis because it is most commonly available to respondents in that form and because documentation, when available, is usually developed on a project-by-project basis.
   * Provide the codes that best describe the project's type of need and reason (see Appendix B for "Lists of Codes").
   * Indicate if the project is to install new infrastructure to meet current population demands, replace old infrastructure, expand or upgrade existing infrastructure (such as treatment plants to meet current population demands) or rehabilitate existing infrastructure.
 Indicate if the project is needed now to protect public health or is not needed now but will be necessary to continue providing safe drinking water within the next 20 years.
 Provide design capacity when applicable  -- i.e., millions of gallons per day (MGD) for treatment and pumping; millions of gallons (MG) for storage; the diameter and number of feet of distribution or transmission lines; and the size and number of backflow prevention devices/assemblies, lead service lines, valves and water meters. EPA will use these parameters to model project costs.
 If available, provide the capital cost estimate and year and month (if known) of the estimate. EPA will use this information to assign the cost of the project. The year and month are important because they will allow EPA to account for differences in the value of money over different years and to convert all costs to a common year.
   * Provide an estimate of the total length of pipe in the water system. This information will only be required for water systems that submit pipe projects but do not have independent documentation of need for these projects (i.e., planning document, sanitary survey or leak and break records). It is expected that not all systems will need to provide this inventory information due to submitting pipe projects supported by independent documentation.
   * Indicate the type of documentation using EPA's "Lists of Codes" that explains why the project is needed and, if an existing cost estimate (developed for other purposes independent of the DWINSA) is available, indicate the documentation that explains the breakdown of the cost. This will verify the cost for the project. NOTE: EPA discourages systems or states from developing new cost estimates solely for the purposes of the 2015 DWINSA.  For needs identified without independent cost estimates, the Agency instead will rely on extrapolations from cost models that are based on extensive independently-documented cost estimates.
   * Help verify that adequate documentation of the need has been submitted.
   * Help determine if the project is an allowable need.
   * Help gauge cost-reasonableness.
The data collection instrument contains optional worksheets where respondents can record information about the water system's existing infrastructure, such as information on storage tanks, pumps and pipe material as well as the age and condition of the infrastructure. This information will not be entered into the DWINSA data system.  The worksheets are only provided as a helpful tool for a respondent to inventory all of a water system's assets and assess any infrastructure needs that are not yet part of the system's formal planning documents.
For respondents to the 2015 DWINSA that did not participate in the 2011 DWINSA, the states will provide a data collection instrument with the water system characteristics information. The respondent will be asked to populate this document with a list of all the system's planned capital improvement projects for the survey period of January 1, 2015 to December 31, 2034. The system must provide documentation and ensure that all projects meet policy requirements established for the 2015 DWINSA.
For respondents to the 2015 DWINSA that reported projects in the 2011 DWINSA, states will provide them with a list of all the projects that were submitted in response to the 2011 DWINSA. EPA will provide the 2011 project list to each state for each water system selected for both surveys. The respondent will be asked to update the list by correcting any old information (e.g., cost estimate) and deleting projects that are completed or no longer needed. The respondent will also add any new projects that were not included in the 2011 DWINSA. All projects must meet documentation and policy requirements established for the 2015 DWINSA.
The respondent's representative is also asked to provide his or her name, title, address, phone number and e-mail address. This information is requested in case EPA or the state must contact the respondent for clarification or explanation of any response.
The respondent is asked to attach documentation for all needs and costs reported in the 2015 DWINSA or to refer to applicable documentation previously submitted to EPA for the 2011 DWINSA. Systems are encouraged to provide inventory data on their systems. Only where noted above will the inventory data be required.
The data collection instrument and Lists of Codes are attached as Appendix B.
A.4.b.ii	Respondent Activities
2015 DWINSA  -  Systems Serving More Than 3,300 Persons
To complete the data collection instrument, the following activities are anticipated for CWSs serving more than 3,300 persons:
 Participate in an informational telephone call. Respondents will receive a call from the state describing the purpose of the DWINSA, the information that will be requested and the timetable for completing and returning the data collection instrument.
 Read the cover letter. Respondents will review the cover letter and instructions accompanying the data collection instrument.
 Collect and copy supporting documentation. Respondents will locate the necessary supporting documentation in system files and copy it.
 Call for technical assistance. Respondents will call their state contacts for technical assistance, if necessary.
 Complete the data collection instrument. Respondents will discuss current needs with the state and complete the data collection instrument. An estimate of total amount of pipe in the system must be provided if any pipe project is submitted without independent documentation of need (e.g., a planning document).
 Respond to call back from the state about the status of 2015 DWINSA. Respondents who do not provide information to the states in a timely manner will be contacted by the state to provide a brief report on the status of the 2015 DWINSA response.
2015 DWINSA  -  State Activities
For this burden estimate, EPA assumes all states will participate in certain "up-front activities" where the measure of  the activity burden is on an "hours per state" basis  and the combined burden on all states is calculated by multiplying by the 56 participating states.
The burden of additional state activities is measured on an "hours per system" basis and the combined burden on all states is calculated by multiplying the number of systems being sampled in the survey.  The hours per system burden differs between systems serving 50,000 or more people and systems serving less than 50,000 persons.  The combined additional burden on all states from surveying the larger systems is calculated by multiplying the hours per system burden of these systems by 612  -  the total number of the larger systems being sampled in the survey.   The combined additional burden on all states from surveying the smaller systems (serving 3,300 to 49,999 people) is calculated by multiplying the hours per system burden of these systems by 2,247 - the total number of these smaller systems being sampled in the survey.
The total burden on all states is calculated by adding the combined burden based on "hours per state" with the combined burden based on hours per system for all systems to be surveyed.
      State Up-Front Activities
      This first activity category includes the states' "fixed burden" for helping EPA prepare for the 2015 DWINSA.
         oo Participate in training and other pre-survey efforts. This activity includes participating in training sessions offered by EPA and becoming familiar with the survey design and policies. In addition, it includes activities such as reviewing the draft data collection instrument.
         oo Help EPA verify SDWIS data. There are several important variables for which SDWIS data must be verified. Critical inventory data for the water systems being surveyed will need to be reviewed. Such data include the public water system identification number (PWSID), system name, address, telephone numbers (if any), primary source, population served, number of service connections, whether the water system is publicly or privately owned and whether the water system purchases/sells water from/to another water system. To help with this verification activity, EPA will provide the information that must be reviewed in electronic form.
         oo Perform miscellaneous administrative activities. States will perform various administrative duties prior to the 2015 DWINSA (e.g., establishing system files). In addition, state management will explain the 2015 DWINSA to staff and allocate resources.
      State Data Collection Activities for Systems Serving more than 3,300 Persons
      States will conduct the following activities for CWSs serving more than 3,300 persons during the data collection phase of the 2015 DWINSA:
         oo E-mail survey package to water systems. States will provide each system in the 2015 DWINSA with a survey package, which will be delivered via e-mail.
         oo Telephone systems to ensure participation and provide instructions. To improve response rates, states will telephone the water systems early in the process to ensure that they have received the survey package and understand how to complete the data collection instrument.
         oo Provide technical assistance. States will provide technical assistance to systems by answering their questions about the data collection instrument and how needs should be represented.
         oo Call systems that do not return the data collection instrument by a certain date. To improve response rates, states will telephone systems that have not returned their assessment by a specific date to encourage participation.
         oo Review completed data collection instruments and documentation. The data collection instrument will be returned directly to the state. State personnel will have the opportunity to review the information on the data collection instrument, as well as any accompanying documentation. The state's review will provide the first quality assurance/quality control check.
         oo Discuss results with EPA. After the state reviews the submission and documentation, the state forwards the data to EPA for review and data entry. EPA performs a second quality assurance/quality control check to ensure all data are documented and allowable. Any issues regarding the project descriptions or adequacy of the documentation of the data will be resolved by EPA and the state. States are provided access to the data system and are able to verify that the data have been entered into the data system.
Small CWSs (systems serving 3,300 and fewer people)
As discussed above, EPA will not collect data from small systems. The needs of these systems will be based on the results of the 2007 Assessment. EPA will adjust these estimates to 2015 dollars for the 2015 DWINSA.
NPNCWSs
EPA will base the needs of NPNCWSs on the 1999 DWINSA results. EPA will adjust these estimates to 2015 dollars for the 2015 DWINSA.
American Indian and Alaska Native Village Water Systems
EPA will base the needs of Alaska Native Village and American Indian water systems on the results of the 2011 Native American DWINSA. EPA will adjust these estimates to 2015 dollars for the 2015 DWINSA.

A.5	INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY AND INFORMATION MANAGEMENT
A.5.a	Agency Activities
A.5.a.i	EPA and Contractor Activities
Many of the EPA activities described here will be conducted by contractors with EPA oversight/technical direction. For example, EPA will oversee contractor acceptance of survey submissions and subsequent data analysis. For purposes of describing Agency activities related to the 2015 DWINSA, contractor effort is not distinguished from EPA effort. Separate estimates for contractor burden and cost will be provided in Section A.6.c. In addition, Section B.1.c describes the contractor's role.
Up-Front Activities
The following pre-assessment activities will be conducted:
 Revise the data collection instrument. EPA is revising the data collection instrument based on lessons learned during the previous DWINSAs and state input from a May 2014 Workgroup meeting. This task will include developing materials for water system use and for state use in supporting water systems.
 Train state participants. To ensure that state staff understand every aspect of the 2015 DWINSA, EPA will conduct five training sessions at locations across the country. The training will help ensure consistent responses across the country, high response rates and efficient use of staff.
 Select 2015 DWINSA respondents. The Agency will drop a random selection of 25 percent of the systems serving 3,301 to 100,000 people that participated in the 2011 DWINSA. The Agency will draw a random sample to replace those systems in the survey for the 2015 DWINSA. The Agency will also update inventory numbers for water systems serving more than 3,300 people. Section B.2.c. describes the precision targets in more detail.
 Update data system. EPA will update the data system used for the 2011 DWINSA to store and analyze data. The data system will produce the necessary statistical reports for EPA, Congress and states. The data system will also allow EPA and state offices to have access to the data.
 Send data collection instruments. This will include prepopulating an electronic data collection instrument with water system inventory information and a list of projects reported in the 2011 DWINSA (for systems that participated in the 2011 DWINSA) and sending the survey packages via e-mail to the states. Survey packages will include the prepopulated data collection instrument for each water system selected in the 2015 DWINSA, Lists of Codes for the survey, instructions and a cover letter from EPA.
Data Collection Activities
EPA will conduct the following activities during the data collection phase of the 2015 DWINSA:
 Provide technical assistance. The Agency will provide technical assistance to water systems and states to promote consistent responses across the country.
 Review completed data collection instruments. EPA will review the completed data collection instruments to ensure that all data are documented and allowable.
 Maintain the data. EPA will enter DWINSA data into the data system and perform quality assurance/quality control checks of data entry.
 Communicate results of review to the state. EPA will communicate the results of each survey submittal review to the states via a website that shows the updated project table and comment codes indicating the changes made. EPA Regional staff will also be able to view the data for states in their respective Regions.
A.5.b	Collection Methodology and Management
This section discusses the steps that EPA has taken to ensure that the information being collected will be accurate, reliable and retrievable. This methodology was developed using experience gained in conducting the previous DWINSAs. EPA has incorporated into this methodology comments and advice from EPA staff involved with those assessments.
Development of Data Collection Instrument
Appendix B contains the data collection instrument. EPA has developed the 2015 DWINSA approach and the data collection instrument with the assistance of a workgroup. As is explained in Section A.3.c, the workgroup includes EPA Headquarters, EPA Regions and state representatives. The 2015 DWINSA approach and many of the refinements to the data collection instrument were based on experience in conducting the 1995, 1999, 2003, 2007 and 2011 DWINSAs.  One change to the data collection instrument for the 2015 DWINSA is that it will only be administered electronically, whereas in the past respondents had the option of receiving printed or electronic data collection instruments. Another change, which can be found in EPA's Lists of Codes, is the deletion of certain types of needs from the list that water systems use in filling out the survey instrument (see Appendix B).  These types of needs are being removed from the 2015 DWINSA pursuant to discussions with states in which they were identified as having very little relative impact on survey results.  Note that these needs are stricken out on the list rather than simply dropped; this was done to help facilitate the re-review in the 2015 DWINSA of submissions from systems' surveys in 2011 when these codes were still being used.
EPA is also modifying the approach for collecting information on "green" and climate readiness attributes of infrastructure projects for the 2015 DWINSA. EPA will not include questions about these projects in the data collection instrument.   Instead, EPA will explore streamlined approaches that might enable the Agency, during the Survey review process, to identify and flag projects that are likely to have "green," climate readiness or climate resilience attributes.
The format and content of the data collection instrument will otherwise remain largely unchanged from the 2011 DWINSA. Section B.2.c.ii describes the steps taken to ensure that the data collection instrument will be an effective tool for retrieving the information EPA needs to meet the 2015 DWINSA objectives.
Methodology for 2015 DWINSA  -  CWSs Serving More Than 3,300 Persons
Most systems serving more than 100,000 persons have CIPs or similar documents that summarize their projects. Therefore, these systems are generally able to provide accurate information on their needs and, for some projects, accurate estimates on the associated cost. A data collection instrument will be sent to states for every CWS that serves more than 100,000 persons. Clarifying information for completing the data collection instrument will be available from EPA.
The experience of states that participated in the previous DWINSAs indicates that most systems serving 3,301 to 100,000 persons could provide reliable data on their needs and a large portion of these systems could provide at least some cost estimates for meeting those needs.
Also, water systems that participated in the 2011 DWINSA and are selected to participate in the 2015 DWINSA will receive a copy of their project submissions from the 2011 DWINSA. These water systems will be able to update the information on the list and add new projects to the data collection instrument. States will provide technical support to the water systems participating in the 2015 DWINSA.  EPA will also offer technical support to state and water system personnel.
EPA will send the data collection instrument to the states to forward on to the water systems. Water systems will return the completed data collection instruments to the state. The state will then forward the data collection instrument and supporting documentation to EPA for review and data entry. EPA will perform a second quality assurance/quality control check to ensure that all infrastructure projects are documented and allowable. EPA will enter the data 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 2015 DWINSA. EPA will offer technical support to state personnel to assist with the completion of each of these steps.
For projects that do not have cost estimates, EPA will model the costs.
Methodology for 2015 DWINSA  -  CWSs Serving 3,300 and Fewer Persons
Data will not be collected in the 2015 DWINSA from CWSs serving 3,300 and fewer persons. Their needs will be based on data collected during the 2007 DWINSA and updated to 2015 dollars.
Methodology for 2015 DWINSA  -  NPNCWSs
Data will not be collected in the 2015 DWINSA from NPNCWSs. Their needs will be based on data collected during the 1999 DWINSA and updated to 2015 dollars.
Methodology for American Indian and Alaska Native Village Water Systems
EPA conducted a survey of American Indian and Alaska Native Village water systems in the 2011 DWINSA. EPA will not collect data in the 2015 DWINSA from American Indian and Alaska Native Village water systems. Their needs will be based on data collected during the 2011 Native American DWINSA and updated to 2015 dollars.
Data Quality
It is important that the results of the DWINSA be as uniform as possible across the country. Toward this end, EPA will take the following steps:
 EPA will establish a uniform set of assumptions or criteria for state, EPA Regions, EPA Headquarters and contractor staff to evaluate data provided by systems.
 EPA will provide training to all those involved in the DWINSA to ensure that the assumptions and procedures are clear and understood.
 EPA will provide quality control reviews of each data collection instrument submitted to ensure compliance with DWINSA policies and accuracy of data.
Among the most important steps in quality assurance is training. EPA will provide training sessions for state and EPA Regions involved in the 2015 DWINSA. The training sessions will be designed to enable state and EPA Regions to review completed data collection instruments and respond to questions from systems on the projects to be included in the survey response and related project documentation. The training will emphasize the following elements:
 Identifying the capital improvements associated with source, treatment, transmission, distribution and storage.
 Discussing policies and documentation requirements.
 Completing the 2015 DWINSA data collection instrument.
EPA will develop materials for distribution to state and EPA Region personnel who are unable to attend training sessions.
In addition to the training sessions, EPA will provide technical support to state, EPA Region and water system personnel. It is anticipated that this support will primarily consist of providing information to the EPA Regions and states, which will then provide technical support to the systems. However, technical support will be available to systems in states that have chosen not to provide their own technical assistance.
Data quality will be assured by implementing the following mechanisms throughout the gathering and processing phases of the information collection:
 Adequate documentation. EPA has requested documentation of needs and costs, when cost documentation is available, to ensure the accuracy and reliability of the data. Acceptable forms of documentation of needs and costs are included on List 4 of the Lists of Codes. EPA will not accept needs or costs without adequate documentation. EPA will emphasize to respondents that they are not expected to develop cost estimates for the purposes of the 2015 DWINSA. The costs of projects without a cost estimate will be modeled by EPA.
 Provide an estimate of the total length of pipe in the water system. This information will only be required for water systems that submit projects for rehabilitation or replacement of pipe that are not independently documented (e.g., planning document or sanitary survey). It is expected that not all systems will need to provide this information.
 Receipt control. The primary objective of the receipt control system will be to ensure that completed forms submitted by respondents (or forwarded by states) are logged in promptly and given proper chain of custody. A second objective is to provide states with the data needed to monitor cumulative receipts by date to identify potential problems with the response rate. Such response rate problems could necessitate action. See Section B.2.c.ii for EPA's method for improving the response rate. States that receive data collection instruments from respondents will be trained in receipt control.
 Data review by states and EPA Regions. EPA will rely on the states and EPA Regions to help ensure data quality. Fifteen states are expected to opt out of participating in the statistical portion of the 2015 DWINSA (i.e., collecting data from systems serving 3,301 to 100,000 persons). However, all states that have systems serving more than 100,000 persons are expected to participate in the census portion of the survey. EPA will ask the Association of State Drinking Water Administrators (ASDWA) to communicate with the state drinking water program administrators to encourage their participation. EPA believes that state review is important in ensuring nationally consistent results because the states have more frequent communications with systems and possess a better understanding of each particular system's needs. Therefore, state personnel will have the opportunity to review the information on the form, as well as any accompanying documentation. When necessary, the states will contact the water system to ask for clarifying information.
   * Survey review and data entry. EPA will screen the submitted electronic data collection instruments for completeness and review projects to ensure that they are allowable and adequately documented based on survey policies. To reduce the review time for water systems that participated in the 2011 DWINSA, EPA will compare the responses of the 2015 DWINSA with those of the 2011 DWINSA and conduct a thorough review of the projects flagged as requiring a complete review. Projects that are needed in each 20-year survey period and that remain unchanged from the 2011 survey will not require a complete review unless that project is impacted by another project that is added or changed. Reviewers will also assign comment codes to projects to describe any changes made to the data. Data from the data collection instruments will be entered into the database only after they have passed the initial screening. As data are entered, an automatic data entry program will provide reasonable bounds checking and data verification. The program will signal if an entry is out of the allowable range or is an invalid entry for that data field. All such signals will be investigated and resolved.
   * Data systems. EPA updated a Web-based data system for the 2007 and 2011 DWINSAs that will be used for the 2015 DWINSA. The Web-based system includes a data entry interface that allows the Agency and its contractor to input data and allows states and EPA Regions to access, download, verify and suggest modifications to their data (www.DWNeeds.com). EPA will use a commercial "off the shelf" program, Microsoft Access, to manage the information. The data system will provide the following functions:
         oo Data entry through the user interface or batch upload.
         oo Data verification through bounds checking.
         oo A password-protected data modification interface.
         oo Data access for states and EPA Regions for review and verification of their data.
         oo Predefined summary and statistical reports.
 Cost reasonableness ranges. EPA will develop "cost reasonableness ranges" to help verify the accuracy of the data and identify projects for further review.
Public Access to Data
The Agency's policy is to make the fullest possible disclosure of information without unjustifiable expense or unnecessary delay to the requester. Once the final Report to Congress has been submitted, the public will be given access to assessment data in accordance with EPA's policies and procedures for Freedom of Information Act (FOIA) requests. However, as a matter of policy, EPA will not disclose the identity of any respondent to the 2015 DWINSA. EPA will develop standard report formats for providing data to the public.
 A.5.c	Small Entity Flexibility
In designing the 2015 DWINSA methodology, EPA has taken small systems' relatively limited technical capabilities and financial resources into account. EPA's experience with the previous DWINSAs has shown that some small systems lack the resources and technical ability to complete the data collection instruments. Small CWSs (those serving 3,300 and fewer persons) will not be included in the surveying for the 2015 DWINSA.  EPA will use the results from the 2007 DWINSA adjusted to 2015 dollars. For NPNCWSs, EPA will use the 1999 DWINSA results, adjusted to 2015 dollars, as the basis for the 2015 DWINSA estimates.
For the 2011 DWINSA, EPA conducted a census of all American Indian water systems that served  more than 10,000 persons (there were no Alaska Native Village water systems that serve more than 10,000 persons) and selected a random sample of American Indian and Alaska Native Village systems serving 10,000 and fewer persons. To reduce the burden on these systems and EPA, the Agency will use the results from the 2011 DWINSA as the basis for the 2015 DWINSA estimates for these water systems.
A.5.d	Collection Schedule
The current schedule assumes EPA would receive OMB approval for data collection by January 2015. The schedule will be adjusted based on the final approval date. EPA will send data collection instruments to states as soon as possible after OMB approval. All systems participating in the 2015 DWINSA will be asked to complete and return the data collection instruments to their state within 1 month of receipt.
To facilitate efficient data entry by EPA, the Agency will ask the states to submit data for one-third of the systems within three months after data collection begins. Data for two-thirds of the systems will be due within six months and all data will be due within nine months. Exhibit A-5-1 summarizes the major collection milestones.
Exhibit A-5-1 Collection Schedule
                                     Task
                                     Date
EPA Tentatively Selects Systems to be Included in State Samples
                                September 2014
Training Sessions for States and EPA Regions
                           September - October 2014
Information Collection Request Submitted to OMB
                                 December 2014
Electronic Delivery of Data Collection Instruments to States
                                 February 2015
 Date by which Systems Are to Return the Data Collection Instrument to States
                                  March 2015
1/3 of Sent Data Collection Instruments Returned by States to EPA
                                   May 2015
2/3 of Sent Data Collection Instruments Returned by States to EPA
                                  August 2015
All Sent Data Collection Instruments Returned by States to EPA
                                 November 2015
No New Projects Will Be Accepted by EPA
                                 December 2015
No New Information on Submitted Projects Will Be Accepted by EPA
                                 February 2016
All Information in the Data System Finalized
                                  August 2016
Report to Congress Due
                               February 2, 2017

A.6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION
A.6.a	Respondent Burden
Modifications to the implementation of the 2015 DWINSA will change how burden is distributed among the systems and states from past DWINSAs. For the 2015 DWINSA, the majority of the respondents will be updating their submittal from 2011. It is anticipated this will reduce the burden for both entities. In addition, all responses will be submitted in electronic format, which will reduce the burden associated with EPA or states distributing the survey packages to systems.
       EPA estimates that there will be Respondents by Water System Size
   * Systems serving more than 50,000 persons = 920 systems.
         o   612 serving more than 100,000 and participated in the 2011 DWINSA.
         o   231 serving 50,001-100,000 and participated in the 2011 DWINSA.
         o   77 serving 50,001-100,000 and did not participate in the 2011 DWINSA.
   * Systems serving 3,301-50,000 persons = 1,939 systems.
         o   1,454 serving 3,301-50,000 and participated in 2011 DWINSA.
         o   485 serving 3,301-50,000 and did not participate in 2011 DWINSA.
                       Respondents by Water System Size
   * Systems serving more than 50,000 persons = 920 systems.
         o   612 serving more than 100,000 and participated in the 2011 DWINSA.
         o   231 serving 50,001-100,000 and participated in the 2011 DWINSA.
         o   77 serving 50,001-100,000 and did not participate in the 2011 DWINSA.
   * Systems serving 3,301-50,000 persons = 1,939 systems.
         o   1,454 serving 3,301-50,000 and participated in 2011 DWINSA.
         o   485 serving 3,301-50,000 and did not participate in 2011 DWINSA.
612 systems serving more than 100,000 people and 308 systems serving 50,001 to 100,000 people (231 of which participated in the 2011 DWINSAs and 77 of which did not). EPA estimates that 1,939 systems serving 3,001 to 50,000 people will participate in the 2015 DWINSA and approximately 75 percent of these systems (1,454) also participated in the 2011 DWINSA. This breakdown is used to calculate the average burden per system in the sections that follow.A.6.a.i	Burden to Community Water Systems
The annual water system burden for the 2015 DWINSA is estimated to be 3,956 hours (a total of 15,822 hours over the full four-year project effort). Exhibit A-6-6 shows the breakdown of the total burden hours for CWSs by system size in the 2015 DWINSA. The basis for the burden estimates are detailed below.
2015 DWINSA  -  CWSs Serving More Than 50,000 Persons
The respondent burden for the systems serving more than 50,000 persons consists of systems' burden for completing the data collection instrument. EPA estimates that the total unit burden is 6.48 hours per system. Exhibit A-6-1 shows the unit burden for 920 systems serving more than 50,000 persons.
 Participate in informational phone call. All systems will participate in an informational phone call with the state. For systems that participated in the 2011 DWINSA, each informational call should last about 15 minutes (0.25 hours).
      EPA anticipates that systems that did not participate in the 2011 DWINSA will require more time on the phone call to understand the process. Each informational call should last about 20 minutes (0.33 hours).
      Consequently, the average burden per system is as follows:
      [0.25 x (612 + (0.75 x 308))/(612 + 308)] + [0.33 x (0.25 x 308)/(612 + 308)] = 0.26 hrs/system
      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.
 Read cover letter. EPA anticipates that systems that participated in the 2011 DWINSA will require less time to read the cover letter and data collection instructions because they will already be familiar with the process and will only need to become familiar with aspects of the survey that have changed. EPA estimates that the burden for each of these systems is 45 minutes (0.75 hours) and breaks down as follows:
 A manager will receive the 2015 DWINSA, read the cover letter and review the instructions and other materials. The estimated time for managers to perform these activities is 15 minutes (0.25 hours).
 Technical staff will read the cover letter and data collection instructions in detail. EPA estimates that the burden for this activity is 30 minutes (0.5) hours per system.
      EPA estimates that systems that did not participate in the 2011 DWINSA will require 1.5 hours to read these materials. This estimate breaks down as follows:
         oo A manager will receive the 2015 DWINSA, read the cover letter and review the instructions and other materials. The estimated time for managers to perform this role is 30 minutes (0.50 hours).
         oo Technical staff will read the cover letter and data collection instructions in detail. EPA estimates that the burden for this activity is 1.0 hour per system.
	Thus, the total unit burden is:
[0.75 x (612 + (0.75 x 308))/(612 + 308)] + [1.5 x (0.25 x 308)/(612 + 308)] = 0.81 hrs/system
   * Collect and copy supporting documentation. The time required to review system files and to collect and copy supporting documentation will vary greatly. EPA anticipates that systems that participated in the 2011 DWINSA will use much of the same documentation that was collected and submitted for the previous DWINSA with limited modifications or updates. Therefore, EPA estimates that the time for these systems to collect and copy supporting documentation will be reduced from previous years. EPA estimates that it will take 1.0 hour at 50 percent of the systems, 2.0 hours at 25 percent of the systems and 4.0 hours at 25 percent of the systems. Thus, the average time per system is as follows:
      (1.0 x 0.5) + (2.0 x 0.25) + (4.0 x 0.25) = 2.0 hrs/system
      For systems that did not participate in the 2011 DWINSA, EPA estimates that it will take 1.5 hours at 30 percent of the systems, 2.5 hours at 30 percent of the systems, four hours at 30 percent of the systems and 16 hours at 10 percent of the systems. Thus, the average time per system is as follows:
      (1.5 x 0.30) + (2.5 x 0.30) + (4 x 0.30) + (16 x 0.10) = 4 hrs/system
      The total average time per system is:
      [2.0 x (612 + (0.75 x 308))/(612 + 308)] + [4 x (0.25 x 308)/(612 + 308)] = 2.16 hrs/system
      Half of this time will be spent by technical staff and half will be spent by clerical staff.
 Call for technical assistance. Many systems will call states for technical assistance. In developing the burden estimate for this activity, EPA assumes that the number of requests for assistance will equal 100 percent of the number of systems. (This estimate considers the likelihood that some systems will call more than once, while some will not call at all.) EPA also assumes that each call will be placed by technical staff.
      EPA anticipates that systems that participated in the 2011 DWINSA will require less technical assistance than those that did not participate in the 2011 DWINSA. Therefore, EPA estimates that all questions from systems that participated in the 2011 DWINSA will be readily answerable and the state will not need to conduct any additional research and will be able to answer the question during the initial call. That initial call is estimated to average 15 minutes (0.25 hours).
EPA estimates that the burden for systems that did not participate in the 2011 DWINSA is 20 minutes (0.33 hours) and break down as follows:
         oo About 50 percent of the questions will be readily answerable" and the state will not need to conduct any additional research and will be able to answer the question during the initial call that will average 15 minutes (0.25 hours).
         oo About 50 percent of the questions will require the state to perform research and call the system back. In this case, EPA estimates that the total burden for the two calls is 25 minutes (0.42 hours).
            [(0.25 x 0.50) + (0.42 x 0.50)] = 0.34 hrs/system
      The total average burden per system is:
      [0.25 x (612 + (0.75 x 308))/(612 + 308)] + [0.34 x (0.25 x 308)/(612 + 308)] = 0.26 hrs/system
 Complete data collection instrument. The burden to systems to complete the data collection instrument will vary depending on whether the system participated in the 2011 DWINSA. The 2011 DWINSA participants will have a relatively low burden because EPA expects that a large portion of the information in the 2011 survey will carry over to the 2015 DWINSA. Thus, 2011 DWINSA participants will only update their needs and documentation rather than identify their needs anew.
      EPA estimates that technical staff at systems that participated in the 2011 DWINSA will require two hours to update the 2011 survey and complete the project table of the data collection instrument. Management is expected to take 18 minutes (0.30 hours) to review the completed data collection instrument for accuracy. Clerical staff is anticipated to take 18 minutes (0.30 hours) to provide support to the technical staff. Thus, the total unit burden to systems that participated in the 2011 DWINSA is approximately 2.6 hours per system.
      EPA estimates that technical staff at systems that did not participate in the 2011 DWINSA will take three hours to complete the project table of the data collection instrument. This estimate is consistent with EPA's experience with the previous DWINSAs. Management is expected to take 18 minutes (0.30 hours) to review the completed data collection instrument for accuracy. Clerical staff is anticipated to take one hour to provide support to the technical and managerial staff. Thus, the total unit burden to systems that did not participate in the 2011 DWINSA is approximately 4.3 hours per system.
      The total average burden per system is as follows:
      [2.6 x (612 + (0.75 x 308))/(612 + 308)] + [4.3 x (0.25 x 308)/(612 + 308)] = 2.74 hrs/system
   * Respond to call back from state about status of 2015 DWINSA.  For this burden estimate, EPA assumes each system will spend time responding to the state call(s) to request a status update on completing the survey's questionnaire.  EPA assumes that the average total time spent by each system on responding to the state call(s) is 15 minutes (0.25 hours) per system.  This does not include discussing technical questions, which is accounted for above. Rather, it includes time required for the system to provide the state with a brief report on the status of the 2015 DWINSA response.
Exhibit A-6-1 Estimated Average Unit Burden for Systems Serving More Than 50,000 Persons
                                   Activity
                           Estimated Burden (hours)

                                  Management
                                   Technical
                                   Clerical
                                                                          Total
Participate in informational phone call
                                                                           0.13
                                                                           0.13

                                                                           0.26
Read cover letter/data collection instructions
                                                                           0.27
                                                                           0.54

                                                                           0.81
Collect supporting documentation

                                                                           1.08
                                                                           1.08
                                                                           2.16
Call for technical assistance

                                                                           0.26

                                                                           0.26
Complete data collection instrument
                                                                           0.30
                                                                           2.08
                                                                           0.36
                                                                           2.74
Respond to call back from state

                                                                           0.25

                                                                           0.25
TOTAL
                                                                           0.70
                                                                           4.34
                                                                           1.44
                                                                           6.48

2015 DWINSA  -  CWSs Serving 3,301  -  50,000 Persons
Exhibit A-6-2 shows the unit burden for 1,939 systems serving 3,301 to 50,000 persons. EPA estimates that each of these systems will take a total of 5.09 hours to respond to the 2011 DWINSA.
 Participate in informational phone call.  All systems will participate in an informational phone call with the state. For systems that participated in the 2011 DWINSA, each informational call should last about 15 minutes (0.25 hours).
      EPA anticipates that systems that did not participate in the 2011 DWINSA will require more time on the phone call to understand the process. Each informational call should last about 20 minutes (0.33 hours).
      Consequently, the average burden per system is as follows:
      [(0.25 x 0.75) + (0.33 x 0.25)] = 0.27 hrs/system
      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.
 Read cover letter. EPA anticipates that systems that participated in the 2011 DWINSA will require less time to read the cover letter and data collection instructions because they will already be familiar with the process and will only need to become familiar with aspects of the survey that have changed. EPA estimates that the burden for each of these systems is 45 minutes (0.75 hours) and breaks down as follows:
 A manager will receive the 2015 DWINSA, read the cover letter and review the instructions and other materials. The estimated time for managers to review these items is 15 minutes (0.25 hours).
 Technical staff will read the cover letter and data collection instructions in detail. EPA estimates that the burden for this activity is 30 minutes (0.50) hours per system.
      EPA estimates that systems that did not participate in the 2011 DWINSA will require 1.5 hours to read these materials. This estimate breaks down as follows:
         oo A manager will receive the 2015 DWINSA, read the cover letter and review the instructions and other materials. The estimated time for managers to review the cover letter is 30 minutes (0.50 hours).
         oo Technical staff will read the cover letter and data collection instructions in detail. EPA estimates that the burden for this activity is one hour per system.
	Thus, the total unit burden is:
[(0.75 x 0.75) + (1.5 x 0.25)] = 0.94 hrs/system
   * Collect and copy supporting documentation. The time required to review system files and to collect and copy supporting documentation will vary greatly.  For instance, systems serving 3,301 to 50,000 persons typically have less documentation than larger CWSs. Furthermore, EPA anticipates that systems that participated in the 2011 DWINSA will use much of the same documentation that was collected and prepared for the previous DWINSA with limited modifications or updates. Therefore, EPA estimates that the time for these systems to collect and copy supporting documentation will be reduced from previous years. EPA estimates that it will take approximately 45 minutes (0.75 hours) at 40 percent of these systems, 1.5 hours at 40 percent of these systems and three hours at 20 percent of these systems. Thus, the average time per system that participated in the 2011 DWINSA is as follows:
      [(0.75 x 0.40) + (1.5 x 0.40) + (3 x 0.20)] = 1.5 hrs/system
      For systems that did not participate in the 2011 DWINSA, EPA estimates that it will take one hour at 50 percent of the systems, two hours at 25 percent of the systems and four hours at 25 percent of the systems. Thus, the average time per system is as follows:
      [(1.0 x 0.5) + (2.0 x 0.25) + (4.0 x 0.25)] = 2.0 hrs/system
      The total average time per system is:
      [(1.5 x 0.75) + (2.0 x 0.25)] = 1.63 hrs/system
      Half of this time will be spent by technical staff and half will be spent by clerical staff.
 Call for technical assistance. Many systems will call states for technical assistance. In developing the burden estimate for this activity, EPA assumes that 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, while some will not call at all.) EPA also assumes that each call will be placed by technical staff.
      EPA anticipates that systems that participated in the 2011 DWINSA will require less technical assistance than those that did not participate in the 2011 DWINSA. Therefore, EPA estimates that all questions from systems that participated in the 2011 DWINSA will be readily answerable and the state will not need to conduct any additional research and will be able to answer the question during the initial call. That initial call is estimated to average 15 minutes (0.25 hours).
EPA estimates that the burden for systems that did not participate in the 2011 DWINSA is 20 minutes (0.34 hours) and breaks down as follows:
         oo About 50 percent of the questions will be readily answerable and the state will not need to conduct any additional research and will be able to answer the question during the initial call that will average 15 minutes (0.25 hours).
         oo About 50 percent of the questions will require the state to perform research and call the system back. In this case, EPA estimates that the total burden for the two calls is 25 minutes (0.42 hours).
      [(0.25 x 0.50) + (0.42 x 0.50)] = 0.34 hrs/system
	The total average burden per system is:
      1.50 x [(0.25 x 0.75) + (0.34 x 0.25)] = 0.41 hrs/system
 Complete data collection instrument. The burden to systems to complete the data collection instrument will vary depending on whether or not the system participated in the 2011 DWINSA. The 2011 DWINSA participants will have a relatively low burden because EPA expects that a large portion of the information in the 2011 survey will carry over to the 2015 DWINSA. Consequently, 2011 DWINSA participants will only update their needs and documentation rather than identify their needs anew.
      EPA estimates that technical staff at systems that participated in the 2011 DWINSA will require 1 hour to update the 2011 survey and complete the project table of the data collection instrument. Management is expected to take 18 minutes (0.30 hours) to review the completed data collection instrument for accuracy. Thus, the total unit burden to systems that participated in the 2011 DWINSA is approximately 1.3 hours per system.
      EPA estimates that technical staff at systems that did not participate in the 2011 DWINSA will take two hours to complete the data collection instrument. This estimate is consistent with EPA experience with the previous DWINSAs. Management is expected to take 28 minutes (0.47 hours) to review the completed data collection instrument for accuracy. Thus, the total unit burden to systems that did not participate in the 2011 DWINSA is approximately 2.47 hours per system.
      The total average burden per system is as follows:
      (1.3 x 0.75) + (2.47 x 0.25) = 1.59 hrs/system
   * Respond to call back from state about status of 2015 DWINSA. For this burden estimate, EPA assumes each system will spend time responding to the state call(s) to request a status update on completing the survey's questionnaire.  EPA assumes that the average total time spent by each system on responding to the state call(s) is 15 minutes (0.25 hours) per system.  This does not include discussing technical questions, which is accounted for above. Rather, it includes time required to provide the state with a brief report on the status of the 2015 DWINSA response.
Exhibit A-6-2 Estimated Average Unit Burden for Systems Serving 3,301 to 50,000 Persons
                                   Activity
                           Estimated Burden (hours)

                                  Management
                                   Technical
                                   Clerical
                                                                          Total
Participate in informational phone call
                                                                          0.135
                                                                          0.135

                                                                           0.27
Read cover letter/data collection instructions
                                                                           0.31
                                                                           0.63

                                                                           0.94
Collect supporting documentation

                                                                           0.81
                                                                           0.81
                                                                           1.63
Call for technical assistance

                                                                           0.41

                                                                           0.41
Complete data collection instrument
                                                                           0.34
                                                                           1.25

                                                                           1.59
Respond to call back from state

                                                                           0.25

                                                                           0.25
TOTAL
                                                                           0.79
                                                                           3.49
                                                                           0.81
                                                                           5.09
Note: 	Numbers may not add due to rounding.
2015 DWINSA  -  CWSs Serving 3,300 and Fewer Persons
EPA will adjust the 2007 DWINSA need for CWSs serving 3,300 and fewer persons to 2015 dollars for the 2015 DWINSA and to reflect the 2015 number and sizes of these systems. There will be no burden for these systems.
2015 DWINSA  -  NPNCWSs
EPA will adjust the 1999 DWINSA need for NPNCWSs to 2015 dollars for the 2015 DWINSA. There will be no burden for these systems.
2015 Native American DWINSA  -  American Indian and Alaska Native Village Water Systems
EPA will adjust the 2011 DWINSA need for American Indian and Alaska Native Village Water Systems to 2015 dollars for the 2015 DWINSA and to reflect the 2015 number and sized of these systems. There will be no burden for these systems.
A.6.a.ii	Burden to States
As previously discussed, all states have committed to help EPA administer the 2015 DWINSA with at least the minimum of activities. The majority of states expected to opt out of the statistical portion of the survey have systems serving more than 100,000 persons; therefore, they would participate in the data collection phase of the 2015 DWINSA.
Up-Front Burden
This activity category includes the "fixed burden" for states to help EPA prepare for the 2015 DWINSA. The total burden for these activities is 110 hours per state, plus 0.2 hour per system assessed. Exhibit A-6-3 summarizes this burden.
 Participate in training and other pre-survey efforts. The burden for this activity is estimated at 80 hours per state.
 Help EPA verify SDWIS data. Based on past experience, EPA estimates that verifying SDWIS data for systems in the sample will require approximately 12 minutes (0.2 hours) per system.
 Perform miscellaneous administrative activities. The burden for these activities should be 30 hours per state.
Exhibit A-6-3 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

State Burden for CWSs Serving More Than 50,000 Persons
This section estimates the state burden for helping EPA conduct the 2015 DWINSA for systems serving more than 50,000 persons by providing technical assistance where needed, working with systems to identify their needs in 2015, calling systems that do not return the data collection instrument on time, reviewing the completed data collection instrument and documentation and discussing the results with EPA. Although most of these systems will be able to answer the questions on the data collection instrument, states will provide them with clarifying information as necessary. The state burden for activities associated with the systems serving more than 50,000 persons is summarized in Exhibit A-6-4, which follows the activity descriptions.
   * Telephone systems to ensure participation and provide instructions. EPA estimates that this preliminary phone call will take about 15 minutes (0.25 hours) per system that participated in the 2011 DWINSA and about 20 minutes (0.33 hours) per system that did not participate in the 2011 DWINSA. Thus, the average burden to states for each system is as follows:
[0.25 x (612 + (0.75 x 308))/(612 + 308)] + [0.33 x (0.25 x 308)/(612 + 308)] = 0.26 hrs/system
   * E-mail survey package to systems. Each state will send the survey packet (provided by EPA) to systems via e-mail. EPA estimates that states will spend a total of 30 minutes drafting text for two e-mails: one to systems that participated in the 2011 DWINSA and one to systems that did not participate in the 2011 DWINSA. This amounts to approximately 0.01 minutes (0.0002 hours) per system. EPA anticipates that states will spend approximately five minutes (0.08 hours) compiling each e-mail, including addressing the e-mail to the correct recipient and attaching the correct files. EPA also estimates that approximately 10 percent of these e-mails will be returned to the states and states will require an additional five minutes (0.08 hours) to locate the correct recipient and resend the e-mail. Thus, the average burden to states for each system is as follows:
      [0.0005 + 0.08 + (0.10 x 0.08)] = 0.09 hrs/system
   * Provide technical assistance. In developing a burden estimate for this analysis, EPA assumes that the number of requests for technical assistance will equal 100 percent of the number of systems. (This estimate considers that some systems will call more than once while some will not call at all.)
EPA anticipates that systems that participated in the 2011 DWINSA will require less technical assistance than those that did not participate in the 2011 DWINSA. Therefore, EPA estimates that all questions from these systems will be readily answerable, requiring only 15 minutes (0.25 hours) to answer.
EPA estimates that the burden to assist systems that did not participate in the 2011 DWINSA is 30 minutes (0.5 hours) and breaks down as follows:
         oo Of those that do require technical assistance, about 50 percent of their questions will be readily answerable, requiring only 15 minutes (0.25 hours) to answer.
         oo 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.
         oo About 25 percent of their questions will require the state to perform some research and will require one hour to answer.
      Therefore, the state burden for providing technical assistance is estimated as:
[0.25 x (612 + (0.75 x 308))/(612 + 308)] + [0.5 x (0.25 x 308)/(612 + 308)] = 0.27 hrs/system
   * Call back systems that do not provide information for the data collection instrument by a certain date. EPA assumes that the number of these "reminder" calls will equal 100 percent of the systems. This assumes that most (but not all) will need at least one reminder call and a few will need two or three. The average time for these calls is 20 minutes (0.33 hours) per system. This estimate includes the time to find the contact information and call the system as well as time to talk to the technical staff. 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 2015 DWINSA response.
   * Review completed data collection instruments and documentation. The data collection instrument will be returned directly to the state for review. For some systems, the documentation is expected to be quite voluminous and reviewing it will be the most burdensome part of the 2015 DWINSA. The time required for this review is difficult to estimate. States may generate their own documentation for the 2015 DWINSA and, if they add distribution or transmission projects, are required to ensure that the total pipe inventory section on the 2015 DWINSA is completed.
      For the 2015 DWINSA, the burden to states to review the data collection instrument for each system will vary depending on whether the system participated in the 2011 DWINSA. Based on discussions with the states concerning their level of effort in previous assessments, and based on the estimates for systems to complete the survey in previous assessments, EPA estimates that, on average, states will take 3.5 hours to review the submission for each system that participated in the 2011 DWINSA. This estimate reflects a lower burden than in the 2011 DWINSA because EPA expects the total time for states to review the data collection instrument for systems that participated in the 2011 DWINSA will be less than the time needed to review a newly developed data collection instrument. For the 2011 DWINSA it was assumed that all systems were preparing a new data collection instrument.
      For systems that did not participate in the 2011 DWINSA, EPA estimates that a total of five hours will be required for the state to review each data collection instrument.
      Thus, the average burden to states for each system is as follows:
      [3.5 x (612 + (0.75 x 308))/(612 + 308)] + [5 x (0.25 x 308)/(612 + 308)] = 3.63	hrs/system
   * Discuss results with EPA. To estimate the state burden for resolving questions on the completed data collection instruments, EPA made the following assumptions:
         oo EPA will have questions for the state on 50 percent of the completed data collection instruments. Some of these questions will actually apply to all systems.
         oo Each question will take the state one hour to resolve.
Thus, the average burden to states for each system is as follows:
[0.5 x 1] = 0.50 hrs/system
Exhibit A-6-4 State Unit Burden for Systems Serving More Than 50,000 Persons
                                   Activity
                      Estimated Burden (hours per system)
Call to ensure participation
                                                                           0.26
E-mail surveys to systems
                                                                           0.09
Provide Technical Assistance
                                                                           0.27
Call back systems that do not return the data collection instrument by a certain date
                                                                           0.33
Review completed assessment forms and documentation
                                                                           3.63
Discuss results with EPA
                                                                           0.50
TOTAL
                                                                           5.08

State Burden for CWSs Serving 3,301  -  50,000 Persons
This section estimates the state burden for helping EPA conduct the 2015 DWINSA for systems serving 3,301 to 50,000 persons by telephoning systems to ensure participation, calling back systems that did not return the data collection instrument on time, reviewing the completed data collection instrument and the accompanying documentation and discussing the results with EPA. The state burden for activities associated with systems serving 3,301 to 50,000 persons is summarized in Exhibit A-6-5, which follows the activity descriptions.
   * Telephone systems to ensure participation. EPA estimates that this preliminary phone call will take about 15 minutes (0.25 hours) per system that participated in the 2011 DWINSA and about 20 minutes (0.33 hours) per system that did not participate in the 2011 DWINSA. Thus, the average burden to states for each system is as follows:
[(0.25 x 0.75) + (0.33 x 0.25)] = 0.27 hrs/system
   * E-mail survey package to systems. Each state will send the survey packet (provided by EPA) to systems via e-mail. EPA estimates that states will spend a total of 30 minutes drafting text for two e-mails: one to systems that participated in the 2011 DWINSA and one to systems that did not participate in the 2011 DWINSA. This amounts to approximately 0.01 minutes (0.0002 hours) per system. EPA anticipates that states will spend approximately five minutes (0.08 hours) compiling each e-mail, including addressing the e-mail to the correct recipient and attaching the correct files. EPA also estimates that approximately 10 percent of these e-mails will be returned to the states and states will require an additional five minutes (0.08 hours) to locate the correct recipient and resend the e-mail. Thus, the average burden to states for each system is as follows:
      [0.0005 + 0.08 + (0.10 x 0.08)] = 0.09 hrs/system
   * Provide technical assistance. In developing a burden estimate for this analysis, EPA assumes that 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 will call more than once while some will not call at all.)
EPA anticipates that systems that participated in the 2011 DWINSA will require less technical assistance than those that did not participate in the 2011 DWINSA. Therefore, EPA estimates that all questions from these systems will be readily answerable, requiring only 15 minutes (0.25 hours) to answer.
EPA estimates that the burden to assist systems that did not participate in the 2011 DWINSA is 30 minutes (0.5 hours) and breaks down as follows:
         oo Of those that do require technical assistance, about 50 percent of their questions will be readily answerable, requiring only 15 minutes (0.25 hours) to answer.
         oo 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.
         oo About 25 percent of their questions will require the state to perform some research and will require one hour to answer.
      Therefore, the state burden for providing technical assistance is estimated as:
1.5 x [(0.25 x 0.75) + (0.5 x 0.25)] = 0.47 hrs/system
   * 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 150 percent of the systems. This assumes that most (but not all) will need at least one reminder call and some will need two or possibly 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 2015 DWINSA response.
      [1.5 x 0.33] = 0.50 hrs/system
   * Review completed data collection instruments and documentation. The data collection instrument will be returned directly to the state for review. For some systems, the documentation is expected to be quite voluminous and reviewing it will be the most burdensome part of the 2015 DWINSA. The time required for this review is difficult to estimate. States may generate their own documentation for the 2015 DWINSA and, if they add distribution or transmission projects, are required to ensure that the total pipe inventory section on the 2015 DWINSA is completed.
      For the 2015 DWINSA, the burden to states to review the data collection instrument for each system will vary depending on whether or not the system participated in the 2011 DWINSA. Based on discussions with the states concerning their level of effort in previous assessments, and based on the estimates for systems to complete the survey in previous assessments, EPA estimates that, on average, states will take three hours to review the submission for each system that participated in the 2011 DWINSA. This estimate reflects a lower burden to the state than in the 2011 DWINSA because EPA expects the total time for states to review the data collection instrument for systems that participated in the 2011 DWINSA will be less than the time needed to review a newly developed data collection instrument. For the 2011 DWINSA, it was assumed that all systems were preparing a new data collection instrument.
      For systems that did not participate in the 2011 DWINSA, EPA estimates that a total of 4.25 hours will be required for the state to review each data collection instrument.
      Thus, the average burden to states for each system is as follows:
      [(3 x 0.75) + (4.25 x 0.25)] = 3.31 hrs/system
   * Discuss results with EPA. To estimate the state burden for resolving questions on completed data collection instruments, EPA made the following assumptions:
         oo EPA will have questions for the state on 50 percent of the completed data collection instruments. Some of these questions will actually apply to all systems.
         oo Each question will take the state one hour to resolve.
      Thus, the average burden to states for each system is as follows:
      [0.5 x 1] = 0.50 hrs/system
Exhibit A-6-5 Estimated State Average Unit Burden for Systems Serving 3,301 to 50,000 Persons
                                   Activity
                      Estimated Burden (hours per system)
Telephone systems to ensure participation
                                                                           0.27
E-mail surveys to systems
                                                                           0.09
Provide technical assistance
                                                                           0.47
Call back systems that do not return the data collection instrument by a certain date
                                                                           0.50
Review completed data collection instruments and documentation
                                                                           3.31
Discuss results with EPA
                                                                           0.50
TOTAL
                                                                           5.14

State Burden for CWSs Serving 3,300 and Fewer Persons
The 2015 DWINSA will use the 2007 DWINSA need for CWSs serving 3,300 and fewer persons adjusted to 2015 dollars. There will be no state burden for these CWSs.
State Burden for NPNCWSs
The 2015 DWINSA will use the 1999 DWINSA need for NPNCWSs, adjusted to 2015 dollars. There will be no state burden for these CWSs.
A.6.b	Respondent Costs
A.6.b.i	Costs to Community Water Systems
Exhibit A-6-6 summarizes the burden and costs to water systems. Total costs are estimated at $603,853, which consists solely of labor costs. There are no operation and maintenance (O&M) costs or capital costs associated with the collection.
CWS labor costs are based on the number of burden hours multiplied by the average hourly wage rate, including overhead. The average hourly wage rate is the rate taken from a 2003 EPA document titled Labor Costs for National Drinking Water Rules. The quoted rate was $26.05 in 2003 dollars for systems serving 50,000 and fewer persons and $31.26 in 2003 dollars for systems serving more than 50,000 persons. This rate has been inflated to 2013 dollars using the Employment Cost Index. The inflated rate is $35.49 for systems serving 50,000 and fewer persons and $42.59 for systems serving more than 50,000 persons.
Exhibit A-6-6 Total Burden and Cost to Water Systems
                                  Respondent
                          Average Unit Burden (hours)
                                Total Responses
                                  Total Hours
                                  Hourly Rate
                                  Total Cost

                                  Management
                                   Technical
                                   Clerical
                                  Subtotal

Systems Serving More Than 50,000 Persons
                                                                           0.70
                                                                           4.34
                                                                           1.44
                                                                           6.48
                                                                            920
                                                                          5,962
                                                                         $42.59
                                                                       $253,922
Systems Serving 3,301  -  50,000 Persons
                                                                           0.79
                                                                           3.49
                                                                           0.81
                                                                           5.09
                                                                          1,939
                                                                          9,860
                                                                         $35.49
                                                                       $349,931
TOTAL

                                                                          2,859
                                                                         15,822

                                                                       $603,853
Note:	The average burden per system response is 5.53 hours (15,822/2,859).
	Numbers may not add due to rounding.
A.6.b.ii	Cost to States
Exhibit A-6-7 shows the total burden and costs to states. The cost burden for EPA Regions is discussed in section A.6.c. Based on EPA's projection that all states will participate in the DWINSA, the cost to states is $1,130,151. The labor costs are based on an average full time equivalent (FTE) cost of $109,990 including overhead, which equates to approximately $52.88 per hour. This rate has been inflated to year 2013 dollars using the Employment Cost Index and is based on the rates provided by the Association of State Drinking Water Administrators' 2011 Survey of State Drinking Water Programs. This survey provides the most recent estimate of state salaries and FTEs, which were used in EPA's 2011 State Resource Needs Model.
There are no O&M or capital costs for states under this ICR.
Exhibit A-6-7 Total Burden and Cost to States
                                   Activity
                           Number of States/ Systems
                                  Unit Burden
                                 Total Burden
                                    (hours)
                                  Hourly Rate
                                  Total Cost
Up-front
                                                                             56
                                                               110 hours/state
                                                                          6,160
                                                                         $52.88
                                                                       $325,741

                                                                          2,859
                                                              0.20 hours/system
                                                                            572
                                                                         $52.88
                                                                        $30,247
State burden for systems serving more than 50,000 persons assessment
                                                                            920
                                                              5.08 hours/system
                                                                          4,674
                                                                         $52.88
                                                                       $247,161
State burden for systems serving 3,301  -  50,000 persons assessment
                                                                          1,939
                                                              5.14 hours/system
                                                                          9,966
                                                                         $52.88
                                                                       $527,002
TOTAL
                                                                         21,372

                                                                     $1,130,151

A.6.c	Agency Burden and Cost
The Agency burden and cost reflects the burden and cost directly incurred by EPA Headquarters and EPA Regions and is summarized in Exhibit A-6-8. EPA will also bear the cost of contractor activities as detailed in Exhibit A-6-8. Both exhibits distribute burden/costs among Fiscal Years 2014, 2015, 2016 and 2017, reflecting that Agency and contractor activities will vary substantially over the four-year period.
EPA made the following assumptions in developing its estimate of Agency and contractor burden and cost:
EPA Headquarters
   * Over the four-year 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.
   * 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 $163,062. Assuming 2,080 hours per year, this equates to $78.40 per hour.
EPA Regions
   * Over the four-year period, EPA Regions will expend a total of 1.4 FTEs (i.e., an average of 0.35 FTE per year) providing support to the 2015 DWINSA. Assuming 2,080 hours per year, this equates to 2,911 hours.
   * The average salary and benefits (i.e., PC&B) of the 1.4 FTEs is at the GS 11, Step 5 level of $113,651. Assuming 2,080 hours per year, this equates to $54.64 per hour.
EPA Contractor(s)
   * Over the four-year period, the EPA contractor(s) will expend a total of 27,685 hours of direct labor.
   * The EPA contractor(s) will provide this professional labor at a total hourly rate, including all applicable indirect costs, of $84.46.
Based on these assumptions, EPA estimates that the total burden/cost to EPA (excluding EPA's contractor) for the DWINSA over the four-year period is 8,735 hours and $615,658. Over the three-year ICR period, the average annual hours would be 2,912 hours per year and $205,219 per year. Exhibits A-6-8 and A-6-9, however, provide greater detail on the estimated yearly expenditures for the actual four-year effort.
Exhibit A-6-8 Burden/Cost to EPA (Excluding Contractor Activities)
                                  Fiscal Year
                               EPA Headquarters
                                  EPA Regions
                                     Total

                                     Hours
                                     Cost
                                     Hours
                                     Cost
                                  Total Hours
                                  Total Cost
FY 2014
                                                                            892
                                                                        $69,933
                                                                            446
                                                                        $24,369
                                                                          1,338
                                                                        $94,302
FY 2015
                                                                          2,020
                                                                       $158,368
                                                                          1,009
                                                                        $55,132
                                                                          3,029
                                                                       $213,500
FY 2016
                                                                          2,020
                                                                       $158,368
                                                                          1,010
                                                                        $55,186
                                                                          3,030
                                                                       $213,554
FY 2017
                                                                            892
                                                                        $69,933
                                                                            446
                                                                        $24,369
                                                                          1,338
                                                                        $94,302
TOTAL
                                                                          5,824
                                                                       $456,602
                                                                          2,911
                                                                       $159,056
                                                                          8,735
                                                                       $615,658

Exhibit A-6-9 Burden/Cost of Contractor Activities

                                  Activities
                                     FY 14
                                     FY 15
                                     FY 16
                                     FY 17
                                     Total

                                     Hours
                                     Cost
                                     Hours
                                     Cost
                                     Hours
                                     Cost
                                     Hours
                                     Cost
                                     Hours
                                     Cost
Planning
                                                                          5,100
                                                                       $430,746
                                                                          2,000
                                                                       $168,920
                                                                          1,500
                                                                       $126,690
                                                                            300
                                                                        $25,338
                                                                          8,900
                                                                       $751,694
Survey Design
                                                                            200
                                                                        $16,892
                                                                              0
                                                                             $0
                                                                              0
                                                                             $0
                                                                              0
                                                                             $0
                                                                            200
                                                                        $16,892
Peer Review
                                                                             40
                                                                         $3,378
                                                                              0
                                                                             $0
                                                                              0
                                                                             $0
                                                                              0
                                                                             $0
                                                                             40
                                                                         $3,378
Modeling
                                                                              0
                                                                             $0
                                                                            141
                                                                        $11,909
                                                                            997
                                                                        $84,207
                                                                            480
                                                                        $40,541
                                                                          1,618
                                                                       $136,656
Database Development
                                                                            300
                                                                        $25,338
                                                                            800
                                                                        $67,568
                                                                            300
                                                                        $25,338
                                                                            300
                                                                        $25,338
                                                                          1,700
                                                                       $143,582
Survey Production
                                                                            250
                                                                        $21,115
                                                                            473
                                                                        $39,950
                                                                              0
                                                                             $0
                                                                              0
                                                                             $0
                                                                            723
                                                                        $61,065
Data Analysis
                                                                              0
                                                                             $0
                                                                          7,037
                                                                       $594,345
                                                                          1,520
                                                                       $128,379
                                                                              0
                                                                             $0
                                                                          8,557
                                                                       $722,724
Report Writing
                                                                              0
                                                                             $0
                                                                            208
                                                                        $17,568
                                                                          1,459
                                                                       $123,227
                                                                            700
                                                                        $59,122
                                                                          2,367
                                                                       $199,917
Statistical Analysis
                                                                              0
                                                                             $0
                                                                             94
                                                                         $7,939
                                                                            656
                                                                        $55,406
                                                                            750
                                                                        $63,345
                                                                          1,500
                                                                       $126,690
Tech Assistance
                                                                              0
                                                                             $0
                                                                            480
                                                                        $40,541
                                                                            100
                                                                         $8,446
                                                                            100
                                                                         $8,446
                                                                            680
                                                                        $57,433
Training
                                                                            500
                                                                        $42,230
                                                                            900
                                                                        $76,014
                                                                              0
                                                                             $0
                                                                              0
                                                                             $0
                                                                          1,400
                                                                       $118,244
Total
                                                                          6,390
                                                                       $539,699
                                                                         12,133
                                                                     $1,024,753
                                                                          6,532
                                                                       $551,693
                                                                          2,630
                                                                       $222,130
                                                                         27,685
                                                                     $2,338,275

A.6.d	Estimating Respondent Universe and Total Burden and Costs
Respondents for this ICR include CWSs and states. This ICR estimates that the number of CWS respondents is 2,859. In addition to the CWS respondents, this ICR assumes 56 states (50 states plus the District of Columbia and the U.S. Territories). Therefore, the total number of respondents is 2,915. The total costs and burden for these respondents are detailed in Exhibits A-6-10 and A-6-11.
A.6.e	Bottom Line Burden Hours and Costs
Exhibit A-6-10 summarizes the bottom line burden hours and costs for CWSs and states for this collection. The total burden is 37,194 hours at a cost of $1,734,004.
Exhibit A-6-10 Bottom Line Respondent Burden
                                Respondent Type
                                 Burden Hours
                                  Total Cost
Water Systems
                                                                         15,822
                                                                       $603,853
States
                                                                         21,372
                                                                     $1,130,151
TOTAL
                                                                         37,194
                                                                     $1,734,004

Over the three-year ICR period, the average annual burden for all respondents (i.e., states and systems combined) would be 12,398 hours and the average annual cost would be $578,001 per year. Exhibit A-6-11 summarizes more specifically the estimated burden hours and costs for CWSs and states for each year of the four-year survey period. It is estimated that the states will conduct the up-front activities in 2014 and the data collection activities in 2015. It is estimated that the CWSs will provide information to the states for the completion of the data collection instrument in 2015.
Exhibit A-6-11 Burden Hours and Costs for Respondents per Year
                                Respondent Type
                         Total Hour Burden (per year)
                             Total Cost (per year)

                                     2014
                                     2015
                                     2016
                                     2017
                                     2014
                                     2015
                                     2016
                                     2017
Water systems
                                                                              0
                                                                         15,822
                                                                              0
                                                                              0
                                                                            $0
                                                                      $603,853
                                                                            $0
                                                                            $0
States
                                                                          6,732
                                                                         14,640
                                                                              0
                                                                              0
                                                                      $355,988
                                                                      $774,163
                                                                              0
                                                                            $0
TOTAL
                                                                          6,732
                                                                         30,462
                                                                              0
                                                                              0
                                                                      $355,988
                                                                    $1,378,016
                                                                              0
                                                                            $0
Average per Respondent
                                                                           2.31
                                                                          10.45
                                                                              0
                                                                              0
                                                                          $122
                                                                          $473
                                                                              0
                                                                            $0

Exhibit A-6-12 summarizes the bottom line burden hours and costs for EPA for this collection. The total burden for EPA, including EPA Regions and EPA's contractor is 36,420 hours at a cost of $2,953,933.