[Federal Register Volume 85, Number 209 (Wednesday, October 28, 2020)]
[Proposed Rules]
[Pages 68255-68257]
[FR Doc No: 2020-23779]

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Proposed Rules
                                                Federal Register
________________________________________________________________________

This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.

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Federal Register / Vol. 85, No. 209 / Wednesday, October 28, 2020 /
Proposed Rules

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DEPARTMENT OF TRANSPORTATION

Federal Aviation Administration

14 CFR Part 39

[Docket No. FAA-2020-0830; Project Identifier 2020-CE-002-AD]
RIN 2120-AA64

Airworthiness Directives; Piper Aircraft, Inc., Airplanes

AGENCY: Federal Aviation Administration (FAA), DOT.

ACTION: Notice of proposed rulemaking (NPRM).

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SUMMARY: The FAA proposes to adopt a new airworthiness directive (AD)
for all Piper Aircraft, Inc., (Piper) Models PA-46-350P (Malibu
Mirage), PA-46R-350T (Malibu Matrix), and PA-46-500TP (Malibu Meridian)
airplanes. This proposed AD was prompted by a finding of several
airplanes with wing assemblies that did not have the proper stall
warning heater modification design. Without the proper stall warning
heat control modification kit installed, during flights into icing
conditions with the landing gear down, ice can form on the stall vane,
which may result in failure of the stall warning system. This proposed
AD would require identifying and correcting nonconforming stall warning
heat control systems. The FAA is proposing this AD to address the
unsafe condition on these products.

DATES: The FAA must receive comments on this proposed AD by December
14, 2020.

ADDRESSES: You may send comments, using the procedures found in 14 CFR
11.43 and 11.45, by any of the following methods:
     Federal eRulemaking Portal: Go to https://www.regulations.gov. Follow the instructions for submitting comments.
     Fax:<PHONE_NUMBER>.
     Mail: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue SE, Washington, DC 20590.
     Hand Delivery: Deliver to Mail address above between 9
a.m. and 5 p.m., Monday through Friday, except Federal holidays.
     For service information identified in this NPRM, contact
Piper Aircraft Inc., 2926 Piper Drive, Vero Beach, FL 32960, telephone:
772-299-2686, email<EMAIL_ADDRESS>internet: https://www.piper.com/. You may view the service information at the FAA,
Airworthiness Products Section, Operational Safety Branch, 901 Locust,
Kansas City, MO 64106. For information on the availability of this
material at the FAA, call<PHONE_NUMBER>.

Examining the AD Docket

    You may examine the AD docket on the internet at https://www.regulations.gov by searching for and locating Docket No. FAA-2020-
0830; or in person at Docket Operations between 9 a.m. and 5 p.m.,
Monday through Friday, except Federal holidays. The AD docket contains
this NPRM, any comments received, and other information. The street
address for Docket Operations is listed above. Comments will be
available in the AD docket shortly after receipt.

FOR FURTHER INFORMATION CONTACT: John Lee, Aerospace Engineer, Atlanta
ACO Branch, FAA, AIR-7A3, 1701 Columbia Avenue, College Park, GA 30337;
telephone:<PHONE_NUMBER>; email<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

Comments Invited

    The FAA invites you to send any written relevant data, views, or
arguments about this proposed AD. Send your comments to an address
listed under the ADDRESSES section. Include ``Docket No. FAA-2020-0830;
Project Identifier 2020-CE-002-AD'' at the beginning of your comments.
The most helpful comments reference a specific portion of the proposal,
explain the reason for any recommended change, and include supporting
data. The FAA will consider all comments received by the closing date
and may amend this proposed AD because of those comments.
    Except for Confidential Business Information (CBI) as described in
the following paragraph, and other information as described in 14 CFR
11.35, the FAA will post all comments received, without change, to
https://www.regulations.gov, including any personal information you
provide. The agency will also post a report summarizing each
substantive verbal contact received about this proposal.

Confidential Business Information

    CBI is commercial or financial information that is both customarily
and actually treated as private by its owner. Under the Freedom of
Information Act (FOIA) (5 U.S.C. 552), CBI is exempt from public
disclosure. If your comments responsive to this NPRM contain commercial
or financial information that is customarily treated as private, that
you actually treat as private, and that is relevant or responsive to
this NPRM, it is important that you clearly designate the submitted
comments as CBI. Please mark each page of your submission containing
CBI as ``PROPIN.'' The FAA will treat such marked submissions as
confidential under the FOIA, and they will not be placed in the public
docket of this NPRM. Submissions containing CBI should be sent to John
Lee, Aerospace Engineer, Atlanta ACO Branch, FAA, AIR-7A3, 1701
Columbia Avenue, College Park, GA 30337. Any commentary that the FAA
receives which is not specifically designated as CBI will be placed in
the public docket for this rulemaking.

Discussion

    The FAA issued AD 2008-26-11, Amendment 39-15777 (73 FR 78934,
December 24, 2008) (``AD 2008-26-11'') for certain serial-numbered
Piper Model PA-46-350P, PA-46R-350T, and PA-46-500TP airplanes. AD
2008-26-11 requires installing stall warning heat control modification
kit part number 88452-002. For those serial-numbered airplanes to which
AD 2008-26-11 does not apply, Piper incorporated the modification kit
in production.
    Since the FAA issued AD 2008-26-11, Piper found 11 airplanes (9
domestic) with the left wing replaced with a wing assembly from salvage
that did not have the proper stall warning heater modification design
change. Without the proper stall warning heat control modification kit
during flights into icing conditions with the landing gear down, ice
can form on the stall vane, which may result in failure of the stall
warning system.
    This condition, if not addressed, could result in the pilot being
unaware

of an approaching stall situation and being unable to react correctly.

Related Service Information Under 1 CFR part 51

    The FAA reviewed Piper Service Letter No. 1261, dated July 19,
2019. The service information contains procedures to identify and
correct nonconforming stall warning heat control systems. The intent of
these service letters is to ensure that wiring for the stall warning
heat control system meets current type design. This service information
is reasonably available because the interested parties have access to
it through their normal course of business or by the means identified
in the ADDRESSES section.

Other Related Service Information

    Piper also issued Mandatory Service Bulletin No. 1192, dated
September 15, 2008, which is incorporated by reference in AD 2008-26-
11.

FAA's Determination

    The FAA is proposing this AD because it evaluated all the relevant
information and determined the unsafe condition described previously is
likely to exist or develop in other products of these same type
designs.

Proposed AD Requirements

    This proposed AD would require accomplishing some of the actions
specified in the service information described previously.

Differences Between Proposed AD and Service Information

    This proposed AD would not require the first step, which is
identified as a ``required for compliance'' (RC) step, of Piper Service
Letter No. 1261, dated July 19, 2019. The first step specifies
reviewing the aircraft records to determine whether the inspection of
the stall warning heat control configuration must be done. This
proposed AD would not require a records review. Instead, all airplanes
identified in the applicability of the proposed AD would have to
inspect the stall warning heat control configuration.

Costs of Compliance

    The FAA estimates that this proposed AD would affect 1,261
airplanes of U.S. registry.
    The FAA estimates the following costs to comply with this proposed
AD:

                                                 Estimated Costs
----------------------------------------------------------------------------------------------------------------
                                                                                Cost per       Cost on U.S.
               Action                        Labor cost           Parts cost        product         operators
----------------------------------------------------------------------------------------------------------------
Inspect stall warning heat control    1 work-hour x $85 per                $0              $85         $107,185
 system.                               hour = $85.
----------------------------------------------------------------------------------------------------------------

    The FAA estimates the following costs to do any necessary repairs
that would be required based on the results of the proposed inspection.
The FAA has no way of determining the number of airplanes that might
need these repairs:

                                               On-Condition Costs
----------------------------------------------------------------------------------------------------------------
                                                                                Cost per
                    Action                                Labor cost               Parts cost        product
----------------------------------------------------------------------------------------------------------------
Install modification kit.....................  1.5 work-hours x $85 per hour =         $230.00          $357.50
                                                $127.50.
----------------------------------------------------------------------------------------------------------------

    According to the manufacturer, some of the costs of this proposed
AD may be covered under warranty, thereby reducing the cost impact on
affected individuals. The FAA does not control warranty coverage for
affected individuals. As a result, all costs are included in the cost
estimate.

Authority for This Rulemaking

    Title 49 of the United States Code specifies the FAA's authority to
issue rules on aviation safety. Subtitle I, section 106, describes the
authority of the FAA Administrator. Subtitle VII: Aviation Programs,
describes in more detail the scope of the Agency's authority.
    The FAA is issuing this rulemaking under the authority described in
Subtitle VII, Part A, Subpart III, Section 44701: General requirements.
Under that section, Congress charges the FAA with promoting safe flight
of civil aircraft in air commerce by prescribing regulations for
practices, methods, and procedures the Administrator finds necessary
for safety in air commerce. This regulation is within the scope of that
authority because it addresses an unsafe condition that is likely to
exist or develop on products identified in this rulemaking action.

Regulatory Findings

    The FAA determined that this proposed AD would not have federalism
implications under Executive Order 13132. This proposed AD would not
have a substantial direct effect on the States, on the relationship
between the national government and the States, or on the distribution
of power and responsibilities among the various levels of government.
    For the reasons discussed above, I certify this proposed
regulation:
    (1) Is not a ``significant regulatory action'' under Executive
Order 12866,
    (2) Will not affect intrastate aviation in Alaska, and
    (3) Will not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.

List of Subjects in 14 CFR Part 39

    Air transportation, Aircraft, Aviation safety, Incorporation by
reference, Safety.

The Proposed Amendment

    Accordingly, under the authority delegated to me by the
Administrator, the FAA proposes to amend 14 CFR part 39 as follows:

PART 39--AIRWORTHINESS DIRECTIVES

0
1. The authority citation for part 39 continues to read as follows:

    Authority: 49 U.S.C. 106(g), 40113, 44701.

Sec.  39.13  [Amended]

0
2. The FAA amends Sec.  39.13 by adding the following new airworthiness
directive (AD):
    Piper Aircraft, Inc.: Docket No. FAA-2020-0830; Project
Identifier 2020-CE-002-AD

(a) Comments Due Date

    The FAA must receive comments by December 14, 2020.

(b) Affected ADs

    None.

(c) Applicability

    (c) This AD applies to the following Piper Aircraft, Inc.,
airplanes, certificated in any category:
    (1) Model PA-46-350P (Malibu Mirage) serial numbers (S/Ns)
4622041, 4636041, 4636142, 4636143, 4636313, 4636341, and 4636379;
    (2) Model PA-46-500TP (Malibu Meridian) S/Ns 4697141, 4697161,
4697086, and 4697020; and
    (3) Models PA-46-350P (Malibu Mirage), PA-46R-350T (Malibu
Matrix), and PA-46-500TP (Malibu Meridian), all serial numbers, if
the left wing has been replaced with a serviceable (more than zero
hours time-in-service) wing.

(d) Subject

    Joint Aircraft System Component (JASC)/Air Transport Association
(ATA) of America Code 3700, VACUUM SYSTEM.

(e) Unsafe Condition

    This AD was prompted by nonconforming stall warning heat control
systems, utilizing a left wing assembly without the proper stall
warning modification design. Without the proper stall warning heat
control modification kit during flights into icing conditions with
the landing gear down, ice can form on the stall vane, which may
result in failure of the stall warning system. The FAA is issuing
this AD to identify and correct nonconforming stall warning heat
control systems. The unsafe condition, if not addressed, could
result in the pilot being unaware of an approaching stall situation.

(f) Compliance

    Comply with this AD within the compliance times specified,
unless already done.

(g) Actions

    (1) Within 100 hours time-in-service (TIS) after the effective
date of this AD or within 12 months after the effective date of this
AD, whichever occurs first, inspect the configuration of stall
warning heat control system and, if required, install stall warning
heat control modification kit part number (P/N) 8452-002 before
further flight in accordance with steps 2 and 3 of the Instructions
in Piper Aircraft, Inc., Service Letter No. 1261, dated July 19,
2019.
    (2) As of the effective date of this AD, do not install a wing
on any Model PA-46-350P (Malibu Mirage), PA-46R-350T (Malibu
Matrix), or PA-46-500TP (Malibu Meridian) airplane unless you have
determined that the wing has the correct stall warning heat control
system as required by paragraph (g)(1) of this AD.

(h) Special Flight Permit

    A special flight permit may be issued to operate the airplane to
a location where the requirements of this AD can be accomplished
provided flight into known icing conditions is prohibited.

(i) Alternative Methods of Compliance (AMOCs)

    (1) The Manager, Atlanta ACO Branch, FAA, has the authority to
approve AMOCs for this AD, if requested using the procedures found
in 14 CFR 39.19. In accordance with 14 CFR 39.19, send your request
to your principal inspector or local Flight Standards District
Office, as appropriate. If sending information directly to the
manager of the certification office, send it to the attention of the
person identified in paragraph (j)(1) of this AD.
    (2) Before using any approved AMOC, notify your appropriate
principal inspector, or lacking a principal inspector, the manager
of the local flight standards district office/certificate holding
district office.
    (3) For service information that contains steps that are labeled
as Required for Compliance (RC), the provisions of paragraph
(i)(3)(i) and (ii) of this AD apply.
    (i) The steps labeled as RC, including substeps under an RC step
and any figures identified in an RC step, must be done to comply
with the AD. An AMOC is required for any deviations to RC steps,
including substeps and identified figures.
    (ii) Steps not labeled as RC may be deviated from using accepted
methods in accordance with the operator's maintenance or inspection
program without obtaining approval of an AMOC, provided the RC
steps, including substeps and identified figures, can still be done
as specified, and the airplane can be put back in an airworthy
condition.

(j) Related Information

    (1) For more information about this AD, contact John Lee,
Aerospace Engineer, Atlanta ACO Branch, FAA, AIR-7A3, 1701 Columbia
Avenue, College Park, GA 30337; telephone:<PHONE_NUMBER>; email:
<EMAIL_ADDRESS>    (2) For service information identified in this AD, contact Piper
Aircraft Inc., 2926 Piper Drive, Vero Beach, FL 32960, telephone:
772-299-2686, email<EMAIL_ADDRESS>internet: https://www.piper.com/. You may view the service information at the FAA,
Airworthiness Products Section, Operational Safety Branch, 901
Locust, Kansas City, MO 64106. For information on the availability
of this material at the FAA, call<PHONE_NUMBER>.

    Issued on October 22, 2020.
Lance T. Gant,
Director, Compliance & Airworthiness Division, Aircraft Certification
Service.
[FR Doc. 2020-23779 Filed 10-27-20; 8:45 am]
BILLING CODE 4910-13-P


safe drinking water under emergency circumstances including earthquakes,
floods, hurricanes, and other natural disasters, as appropriate; and

(6) has adopted authority for administrative penalties (unless the
constitution of the State prohibits the adoption of the authority) in a
maximum amount -

(A) in the case of a system serving a population of more than 10,000,
that is not less than $1,000 per day per violation; and

(B) in the case of any other system, that is adequate to ensure
compliance (as determined by the State); except that a State may
establish a maximum limitation on the total amount of administrative
penalties that may be imposed on a public water system per violation.

(b) Regulations

(1) The Administrator shall, by regulation (proposed within 180 days of
December 16, 1974), prescribe the manner in which a State may apply to
the Administrator for a determination that the requirements of
paragraphs (1), (2), (3), and (4) of subsection (a) of this section are
satisfied with respect to the State, the manner in which the
determination is made, the period for which the determination will be
effective, and the manner in which the Administrator may determine that
such requirements are no longer met. Such regulations shall require that
before a determination of the Administrator that such requirements are
met or are no longer met with respect to a State may become effective,
the Administrator shall notify such State of the determination and the
reasons therefore and shall provide an opportunity for public hearing on
the determination. Such regulations shall be promulgated (with such
modifications as the Administrator deems appropriate) within 90 days of
the publication of the proposed regulations in the Federal Register. The
Administrator shall promptly notify in writing the chief executive
officer of each State of the promulgation of regulations under this
paragraph. Such notice shall contain a copy of the regulations and shall
specify a State's authority under this subchapter when it is determined
to have primary enforcement responsibility for public water systems.

(2) When an application is submitted in accordance with the
Administrator's regulations under paragraph (1), the Administrator shall
within 90 days of the date on which such application is submitted (A)
make the determination applied for, or (B) deny the application and
notify the applicant in writing of the reasons for his denial.

(c) Interim primary enforcement authority A State that has primary
enforcement authority under this section with respect to each existing
national primary drinking water regulation shall be considered to have
primary enforcement authority with respect to each new or revised
national primary drinking water regulation during the period beginning
on the effective date of a regulation adopted and submitted by the State
with respect to the new or revised national primary drinking water
regulation in accordance with subsection (b)(1) of this section and
ending at such time as the Administrator makes a determination under
subsection (b)(2)(B) of this section with respect to the regulation.

Sec. 300g-4(e)(7)

(7) Regulations and guidance

(A) In general Not later than 2 years after August 6, 1996, and in
consultation with the States, the Administrator shall promulgate
regulations for variances to be granted under this subsection. The
regulations shall, at a minimum, specify -

(i) procedures to be used by the Administrator or a State to grant or
deny variances, including requirements for notifying the Administrator
and consumers of the public water system that a variance is proposed to
be granted (including information regarding the contaminant and
variance) and requirements for a public hearing on the variance before
the variance is granted;

(ii) requirements for the installation and proper operation of variance
technology that is identified (pursuant to section 300g-1(b)(15) of this
title) for small systems and the financial and technical capability to
operate the treatment system, including operator training and
certification;

(iii) eligibility criteria for a variance for each national primary
drinking water regulation, including requirements for the quality of the
source water (pursuant to section 300g-1(b)(15)(A) of this title); and

(iv) information requirements for variance applications.

(B) Affordability criteria Not later than 18 months after August 6,
1996, the Administrator, in consultation with the States and the Rural
Utilities Service of the Department of Agriculture, shall publish
information to assist the States in developing affordability criteria.
The affordability criteria shall be reviewed by the States not less
often than every 5 years to determine if changes are needed to the
criteria.

Sec. 300g-5 (a)(1)

(a) Requisite findings A State which has primary enforcement
responsibility may exempt any public water system within the State's
jurisdiction from any requirement respecting a maximum contaminant level
or any treatment technique requirement, or from both, of an applicable
national primary drinking water regulation upon a finding that -

(1) due to compelling factors (which may include economic factors,
including qualification of the public water system as a system serving a
disadvantaged community pursuant to section 300j-12(d) of this title),
the public water system is unable to comply with such contaminant level
or treatment technique requirement, or to implement measures to develop
an alternative source of water supply,

(2) the public water system was in operation on the effective date of
such contaminant level or treatment technique requirement, or, for a
system that was not in operation by that date, only if no reasonable
alternative source of drinking water is available to such new system,

(3) the granting of the exemption will not result in an unreasonable
risk to health; and reasonably be made that will result in compliance
with this subchapter or, if compliance cannot be achieved, improve the
quality of the drinking water.

Sec. 300g-9

(a) State authority for new systems

A State shall receive only 80 percent of the allotment that the State is
otherwise entitled to receive under section 300j-12 of this title
(relating to State loan funds) unless the State has obtained the legal
authority or other means to ensure that all new community water systems
and new nontransient, noncommunity water systems commencing operation
after October 1, 1999, demonstrate technical, managerial, and financial
capacity with respect to each national primary drinking water regulation
in effect, or likely to be in effect, on the date of commencement of
operations.

(b) Systems in significant noncompliance

(1) List Beginning not later than 1 year after August 6, 1996, each
State shall prepare, periodically update, and submit to the
Administrator a list of community water systems and nontransient,
noncommunity water systems that have a history of significant
noncompliance with this subchapter (as defined in guidelines issued
prior to August 6, 1996, or any revisions of the guidelines that have
been made in consultation with the States) and, to the extent
practicable, the reasons for noncompliance.

(2) Report Not later than 5 years after August 6, 1996, and as part of
the capacity development strategy of the State, each State shall report
to the Administrator on the success of enforcement mechanisms and
initial capacity development efforts in assisting the public water
systems listed under paragraph (1) to improve technical, managerial, and
financial capacity.

(3) Withholding The list and report under this subsection shall be
considered part of the capacity development strategy of the State
required under subsection (c) of this section for purposes of the
withholding requirements of section 300j-12(a)(1)(G)(i) of this title
(relating to State loan funds).

(c) Capacity development strategy

(1) In general Beginning 4 years after August 6, 1996, a State shall
receive only -

(A) 90 percent in fiscal year 2001;

(B) 85 percent in fiscal year 2002; and

(C) 80 percent in each subsequent fiscal year, of the allotment that the
State is otherwise entitled to receive under section 300j-12 of this
title (relating to State loan funds), unless the State is developing and
implementing a strategy to assist public water systems in acquiring and
maintaining technical, managerial, and financial capacity.

(2) Content In preparing the capacity development strategy, the State
shall consider, solicit public comment on, and include as appropriate -

(A) the methods or criteria that the State will use to identify and
prioritize the public water systems most in need of improving technical,
managerial, and financial capacity;

(B) a description of the institutional, regulatory, financial, tax, or
legal factors at the Federal, State, or local level that encourage or
impair capacity development;

(C) a description of how the State will use the authorities and
resources of this subchapter or other means to -

(i) assist public water systems in complying with national primary
drinking water regulations;

(ii) encourage the development of partnerships between public water
systems to enhance the technical, managerial, and financial capacity of
the systems; and

(iii) assist public water systems in the training and certification of
operators;

(D) a description of how the State will establish a baseline and measure
improvements in capacity with respect to national primary drinking water
regulations and State drinking water law; and

(E) an identification of the persons that have an interest in and are
involved in the development and implementation of the capacity
development strategy (including all appropriate agencies of Federal,
State, and local governments, private and nonprofit public water
systems, and public water system customers).

(3) Report Not later than 2 years after the date on which a State first
adopts a capacity development strategy under this subsection, and every
3 years thereafter, the head of the State agency that has primary
responsibility to carry out this subchapter in the State shall submit to
the Governor a report that shall also be available to the public on the
efficacy of the strategy and progress made toward improving the
technical, managerial, and financial capacity of public water systems in
the State.

(4) Review The decisions of the State under this section regarding any
particular public water system are not subject to review by the
Administrator and may not serve as the basis for withholding funds under
section 300j-12 of this title.

(d) Federal assistance

(1) In general The Administrator shall support the States in developing
capacity development strategies.

(2) Informational assistance

(A) In general Not later than 180 days after August 6, 1996, the
Administrator shall -

(i) conduct a review of State capacity development efforts in existence
on August 6, 1996, and publish information to assist States and public
water systems in capacity development efforts; and

(ii) initiate a partnership with States, public water systems, and the
public to develop information for States on recommended operator
certification requirements.

 (B) Publication of information The Administrator shall publish the
information developed through the partnership under subparagraph (A)(ii)
not later than 18 months after August 6, 1996.

(3) Promulgation of drinking water regulations In promulgating a
national primary drinking water regulation, the Administrator shall
include an analysis of the likely effect of compliance with the
regulation on the technical, financial, and managerial capacity of
public water systems.

(4) Guidance for new systems Not later than 2 years after August 6,
1996, the Administrator shall publish guidance developed in consultation
with the States describing legal authorities and other means to ensure
that all new community water systems and new nontransient, noncommunity
water systems demonstrate technical, managerial, and financial capacity
with respect to national primary drinking water regulations.

(e) Variances and exemptions Based on information obtained under
subsection (c)(3) of this section, the Administrator shall, as
appropriate, modify regulations concerning variances and exemptions for
small public water systems to ensure flexibility in the use of the
variances and exemptions. Nothing in this subsection shall be
interpreted, construed, or applied to affect or alter the requirements
of section 300g-4 or 300g-5 of this title.

(f) Small public water systems technology assistance centers

(1) Grant program The Administrator is authorized to make grants to
institutions of higher learning to establish and operate small public
water system technology assistance centers in the United States.

(2) Responsibilities of the centers The responsibilities of the small
public water system technology assistance centers established under this
subsection shall include the conduct of training and technical
assistance relating to the information, performance, and technical needs
of small public water systems or public water systems that serve Indian
Tribes.

(3) Applications Any institution of higher learning interested in
receiving a grant under this subsection shall submit to the
Administrator an application in such form and containing such
information as the Administrator may require by regulation.

(4) Selection criteria The Administrator shall select recipients of
grants under this subsection on the basis of the following criteria:

(A) The small public water system technology assistance center shall be
located in a State that is representative of the needs of the region in
which the State is located for addressing the drinking water needs of
small and rural communities or Indian Tribes.

(B) The grant recipient shall be located in a region that has
experienced problems, or may reasonably be foreseen to experience
problems, with small and rural public water systems.

(C) The grant recipient shall have access to expertise in small public
water system technology management.

(D) The grant recipient shall have the capability to disseminate the
results of small public water system technology and training programs.

(E) The projects that the grant recipient proposes to carry out under
the grant are necessary and appropriate.

(F) The grant recipient has regional support beyond the host
institution.

(5) Consortia of States At least 2 of the grants under this subsection
shall be made to consortia of States with low population densities.

(6) Authorization of appropriations There are authorized to be
appropriated to make grants under this subsection $2,000,000 for each of
the fiscal years 1997 through 1999, and $5,000,000 for each of the
fiscal years 2000 through 2003.

(g) Environmental finance centers

(1) In general The Administrator shall provide initial funding for one
or more university-based environmental finance centers for activities
that provide technical assistance to State and local officials in
developing the capacity of public water systems. Any such funds shall be
used only for activities that are directly related to this subchapter.

(2) National capacity development clearinghouse The Administrator shall
establish a national public water system capacity development
clearinghouse to receive and disseminate information with respect to
developing, improving, and maintaining financial and managerial capacity
at public water systems. The Administrator shall ensure that the
clearinghouse does not duplicate other federally supported clearinghouse
activities.

(3) Capacity development techniques The Administrator may request an
environmental finance center funded under paragraph (1) to develop and
test managerial, financial, and institutional techniques for capacity
development. The techniques may include capacity assessment
methodologies, manual and computer based public water system rate models
and capital planning models, public water system consolidation
procedures, and regionalization models.

(4) Authorization of appropriations There are authorized to be
appropriated to carry out this subsection $1,500,000 for each of the
fiscal years 1997 through 2003.

(5) Limitation No portion of any funds made available under this
subsection may be used for lobbying expenses.

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Appendix B

Comments and Response to Comments

 tc "Appendix C

2000 Community Water Systems Questionnaires"

This page intentionally left blank.

Part 1:  General Comments and Responses

Comment:

The survey instrument provided for review is not the Community Water
System Survey as the CWSS is a survey specifically designed to provide
cost and categorical data to serve as a general resource for EPA’s
SDWA program.

Response:

The survey instrument provided is the data collection instrument for
Community Water System Survey (CWSS). In addition to gathering
information within the same two broad financial and operating categories
as has been done for over 20 years, 16 of the 28 questions asked in this
questionnaire are either identical to or slight variations of questions
asked in the 2000 CWSS. While the survey has always gathered information
on distribution systems, water storage and residuals management
practices, the Agency’s responsibility to safeguard public health and
evolving program needs require new information in this area from time to
time. This survey instrument will not only serve as a resource for
financial and operating data but will also provide valuable information
on other areas of interest to the Agency, such as water system security.

Comment:

The instrument provided for comment reflects a number of information
collection efforts particular to specific proposed rulemakings,
including the Distribution System Rule and Effluent Guidelines for Water
Treatment Plants. The agency is doing a disservice to these rulemakings
if it conducts an inadequate information collection through the proposed
CWSS survey rather than a robust research and data collection effort for
each rulemaking.

Response:

Like other data collect by the CWSS, the data on distribution systems
and storage are designed to provide general information on current
practices and conditions in the water sector.  While the information to
be collected may inform assessments of risk, it is not the Agency’s
intent to use them to form the basis for formal risk analyses.

The usefulness of the distribution system questions is not limited to
supporting potential, new regulatory actions, but can also be used to
assess current risk factors and practices that might suggest new rule
making is unnecessary. Any proposed future regulation will be based on
the best information available and will not be limited to data collected
from the CWSS. For example, the effluent guidelines Screener Survey,
soon to be conducted by the Office of Science and Technology, is another
independent source of information in this area.  The usefulness of the
effluent disposal practices information will be discussed in the
response to detailed comments section.

Comment:

Commenter supports the CWSS in as far as it can be used to help the
Agency understand cost impacts in its regulatory impact analyses.
Commenter also supports the Agency’s intent to use the survey to
“help the Agency better conduct its outreach efforts to assist the
regulated community[.]”

Response:

A number of questions have been added to the questionnaire this time
specifically in order to assess the best ways to reach out to water
system managers and operators.

Comment:

Commenter believes the CWSS is being used to discover opportunities for
future rulemakings.  Several of the questions in the survey appear to be
efforts to cast an overly wide net in order to explore regulatory
possibilities that are outside the scope of this effort.  This does not
fit the survey’s purpose. Instead, EPA should collect the data it
needs for future rulemakings in the context of developing risk
assessments and via Information Collection Rules for specific
rulemakings, as is being done for the Effluent Guidelines for Drinking
Water Treatment Residuals Rulemaking.

Response:

As the Agency is charged with regulating drinking water contaminants, it
is only reasonable to assess risks of contamination and operating
practices which might pose a risk to public health.  Questions of this
nature are intended as much to determine that regulatory measures are
unnecessary as they are to support any that might be needed.  The
questions are purely exploratory and responses will be augmented by
additional information in the future as needed.

Comment:

The commenter believes EPA should avoid survey questions that could be
answered instead by leveraging other data sources or collection
activities that may be available or underway in the Office of Water.
AMWA encourages EPA to coordinate its many survey and information
collection efforts occurring to better leverage the information
gathered.  For example, the Office of Science and Technology is planning
a survey of utilities to gather information about treatment and disposal
of treatment residuals, which may overlap with question 18.

Response:

EPA is in complete agreement.  As far as the Agency is aware, this
survey is the only way of collecting a nationally representative sample
of the financial and operating characteristics of water systems of all
sizes that will support our rule making and programmatic needs.  The
survey to be conducted by the Office of Science and Technology (OST)
requires substantially different treatment and residuals disposal
information than is required by the CWSS.  This derives from the two
different purposes of each office. However, the Office of Ground Water
and Drinking Water (OGWDW) is in the process of coordinating our
financial questions with those being asked by OST so that systems
responding to OST’s financial questions would not have to respond to
those in the CWSS, thus reducing the burden on systems that are jointly
sampled by both surveys.   Also, for the first time this year, EPA is
combining the small system data collection efforts of the CWSS and the
Drinking Water Needs Survey to minimize burden and reduce costs.

Comment:

Infrastructure cost information is being collected by the infrastructure
needs survey as well as the CWSS.  Although the information sought is
slightly different between the efforts, EPA should provide thorough
explanations and context for each question to the best of its ability.
This will not only help utilities better understand the question but
also help ensure responses are adequate for the Agency’s purposes.

Response:

The purpose of the Drinking Water Infrastructure Needs Survey and
Assessment (DWINSA) is to estimate future capital needs.  The purpose of
the CWSS is to provide a recent history of financial and operating
conditions. Thus, even though both contain questions related to a
system’s infrastructure, each approaches the subject with a very
different orientation. EPA intends to add additional explanations as to
the purposes of its questions.

Comment:

Commenter believes the burden estimate is too low and anticipates that
large utilities (serving >100,000 persons) will require between 40 and
60 hours to respond to the survey.  With regard to small systems, the
low-end estimate of 30 minutes is too low.  The proposed survey has 28
questions, and several have more than one part.  Commenter estimates it
would take an experienced employee at least 15 minutes just to read and
understand the survey before trying to respond to the questions.
Commenter also suggests EPA develop an estimate for more than the two
widely disparate categories used in the survey.  It is highly unlikely
that a system serving fewer than 10,000 persons, for example, would
require the same amount of time that a utility serving greater than
100,000 persons would require.

EPA estimates that a public water system (PWS) will complete a 21-page
survey in less than 5 hours. In most systems, completing this survey
will require coordination among multiple individuals.  Even small
systems with limited on-site expertise will likely need to consult with
their consulting engineering firms to answer some of the questions, .
The current estimate of burden grossly underestimates the amount of time
and effort PWSs of any size and configuration will have to undertake to
complete the survey accurately with information of any reasonable level
of quality.  Given EPA’s own experience conducting surveys at
very-small PWSs, it should be clear to the agency that this burden
estimate is inadequate to reflect a good faith effort to garner the
information requested.

Response:

The estimated burden is based on past experience with the survey and the
results of a pre-test of the current questionnaire.  The estimate
recognizes differences in potential burden among systems by providing a
range.  EPA recognizes that some questions may take some systems
considerable time to answer completely and encourages systems to provide
estimates when possible.  The estimate for small systems reflects the
amount of time the system will need to spend with the site visitor; past
experience has shown that the site visitors can collect most of the data
without immediate involvement of the system. The 2006 CWSS has 28
questions on 21 pages and an estimated burden of from 1 to 5 hours, with
an average of 3.58 hours.  By comparison, the 2000 CWSS had 32 questions
on 22 pages and a burden estimate of 1 – 4 hours, with an average of
2.24 hours.

Comment:

Commenter encourages EPA to allow utilities to respond to the survey
using a web-based survey instrument.  EPA should also allow for the
survey to be partially completed and saved online during the completion
process.  This feature is common business practice.  Employing it will
facilitate utilities’ response efforts and thus reduce completion
time.

Response:

EPA is in complete agreement and plans to offer the respondents the
option of completing the questionnaire in stages as time allows.

 Comment:

The CWSS is specifically designed to support the development of national
regulations, particularly the cost implications of national rules.
Typically, this means estimating the national average impact.  Though
estimates for individual size categories and percentiles other than the
50th percentile will be generated in most rulemakings, the quality of
those estimates is typically much lower than that of the aggregate
central tendency estimates.  Understanding this fundamental inadequacy
in the agency’s current analyses should lead the agency to revise its
objectives for the CWSS.  It is clear from the questions posed and the
scope of the survey effort (e.g., 1,700 of 50,000 CWSs) that the survey
is inadequate to make a meaningful contribute to either of the latter
goals identified by the agency in its description of the CWSS’s
objectives:

1. “measure the impact of drinking water regulations,” or

2. “measure the effectiveness of [state] programs already in
existence”

Response:

As stated above, the sampling design meets the data quality objectives
of the survey.  The sampling rate in itself is not an indicator of the
quality of the data.  The sample size, nearly 500 systems larger than
the previous CWSS, was determined using standard statistical techniques
and it is adequate to meet the objectives of the survey. Because the
survey is designed to be accurate at the national level, rather than the
state level, it would not be possible to measure the effectiveness of
any particular state’s program.  Nor is it the purpose of this survey
to do so.  Commenter was in error in inserting “[state]” into the
quotation.

Comment:

Only one question bears on discerning the impact of drinking water
regulations retrospectively on PWSs and none of the questions bear on
the effectiveness of state programs.

Response:

The primary purpose of the CWSS is to provide a baseline of information
on the financial and operating characteristics of  water systems on
which potential future rules might impact. While it is not designed to
measure individual rule impacts retrospectively, it can show how
revenues and expenditures have increased in order to cover a wide
variety of purposes. Also, by collecting information in question 27 B,
EPA can gather data on the proportion of total capital expenditures have
been devoted to regulatory-related expenses. EPA is conducting a
separate collection effort which will look retrospectively at rule
impacts. Being designed to provide information that is representative on
a national rather than state level, the CWSS is not intended to collect,
nor has it ever collected, information that bears on the effectiveness
of state programs.  It does, however, seek to assess progress in
implementing certain drinking water programs nationwide.

Comment:

The CWSS does not provide any protection of sensitive information from
Freedom of Information (FOIA) requests, yet the CWSS requests this
information without warning PWSs of this lack of security.

Response:

The CWSS has always protected the anonymity of respondents, although
details of this had not yet been added to the early version of the
questionnaire available for commenters’ reviews.  We do not publish
any document that reveals either the name of the respondent of the water
system. Because of this, the voluntary nature of the survey and the fact
that we provide systems with an opportunity to claim confidential
business information (CBI) if EPA receives a FOIA request, we do not
provide respondents an opportunity to claim CBI in the questionnaire.
However, we have provided and will provide the following information on
the inside front cover of the questionnaire:

Participation in the survey is voluntary. However, as a matter of
policy, EPA will not disclose the identity of any respondent to this
questionnaire, nor the identity of any participating water system. While
no respondent has ever claimed that the information asked for in this
survey contains confidential business information (CBI), EPA will offer
the opportunity of claiming CBI to a representative of your water system
in the event that we receive a Freedom of Information Act request for
any data that would identity you or your system. It should be noted,
however, that EPA has never received a Freedom of Information Act
request for such information.

 Comment:

Review of how EPA has employed the data from previous CWSS’s suggests
that there is little if any value for PWSs to submit additional
schematics of treatment, diagrams of distribution systems or other
facilities, or indeed more detailed financial responses than are
required by the survey itself.  The data is unlikely to be used
constructively and there is the added potential for it to be found and
misused through FOIA or other means.

Response:

The CWSS requests this information to reduce the burden on systems.
Systems may provide a financial report in lieu of filling out the
questionnaire if the report contains the requested information.  The
supporting documentation also is useful for validating responses and
ensuring the responses to the questionnaire are internally consistent.
In most cases, the supporting documents requested are public
information.  If not, the system does not need to provide them.
Additional procedures to safeguard system-specific information from FOIA
requests are in place as noted above.  The diagrams are extremely useful
for the Agency.  The agency does not use the diagram to draw statistical
inferences to the nation as a whole.  Rather, it uses the diagram to
validate responses to the survey.  For example, it uses it to ensure it
can account for each water source in a system.

Part 2:  Detailed Comments and Responses

Comment:

 It is not clear how the survey can be compiled to accurately reflect
CWS conditions at a specific point in time if the survey results do not
consistently reflect the same time period.  The survey currently
requests that respondents provide information for the “most recent
12-month period for which data is available” and indicate what period
of time the response reflects.  Consequently, small system data
collected by EPA may reflect a substantially different period of time
than PWSs that respond using end-of-year financial statements, and
different yet again from PWSs that calculate answers from the latest 12
months of operation.  Given recent trends in energy and construction
price indices, the differentials in capital and operational costs could
be substantial even over short periods of time.  EPA should select a
specific calendar year.

Response:

While a valid concern, it is not uncommon that respondents to surveys
report results for different time periods.   In most cases, the data are
reported for similar period, so the impact is relatively small.  EPA
does not ask for the data for specific year for two reasons.  First, it
would prefer to have audited financial data.  These data may not be
available for the year requested, and the quality of the data that are
provided would likely be lower. Second, this request would significantly
increase the burden of the survey on respondents. In fact, pre-test
participants specifically suggested that the survey request data for the
latest year available rather than for a specific year. EPA has
successfully used this approach in the last two surveys.

 Comment:

 It is not clear how questions 4B and C regarding the details of PWS
computer equipment will assist the agency.  It is not clear what the
agency can infer from the data collected or that the data will have any
reasonable shelf life as computer equipment is typically obsolescent
within 3 years of purchase.  Is there national significance to the
number of PWSs with DVDs, high-speed modem access, and other new
computer equipment?

Response:

Understanding the technological resources available to a PWS will assist
primarily with  rule implementation. The Agency, states and technical
assistance providers develop a variety of products and tools to help
systems understand and comply with regulations.  Our goal is to ensure
that these materials are appropriate for the target audience.  Since the
last CWSS, we have learned anecdotally that many more small PWS are
using computers on a daily basis.  This exercise will validate this
information as well as refine our project planning for the future.  In
addition, information exchanges may occur more frequently and more
accurately through the use of the internet via email, webpage postings,
etc., thus keeping our stakeholders better informed and up-to-date on
new rules as well as the old.

Comment:

Constructing a relationship diagram like that in Figure 1 to answer
question 5 is not useful to the agency for at least two reasons.  First,
it is not useful because the agency cannot collect enough information to
make the relationships described informative when using other data
collected in the survey.  Second, the relationship diagrams for every
drinking water system is unique. Consequently, the agency will not be
able to draw any conclusions from the diagrams that it collects as the
sample size of 1,700 is too small to adequately capture even general
trends in such relationship diagrams.

Response:

The agency does not use the diagram to draw statistical inferences to
the nation as a whole.  Rather, it uses the diagram to validate
responses to the survey.  For example, it uses it to ensure it can
account for each water source in a system.  The sample size is adequate
for the purposes of the survey as noted above. A similar diagram was
provided by respondents to the 2000 CWSS.

Comment:

Question 6A will result in inconsistent and consequently unusable
observations.  To provide valid responses, the PWSs completing the
survey must have common definitions for the following:

1. What is the definition of a “seasonal” source?  For example, if a
utility cycles its entire well field are all of the sources
“seasonal”; if a source is used to meet peak demand but that peak
occurs both in the winter from main breaks and in the summer from
increased lawn watering, is it “seasonal”?

2. What is the definition of an “emergency” supply? Is every supply
that is used less than 30 days a year, supplies that are of low quality
and only used with there is no other choice, supplies that are
particularly robust and unlikely to be affected by natural disasters,
etc.?

3. What constitutes “treatment”?  Treatment could be maintaining a
residual disinfectant, operating a tray aerator, softening, conventional
treatment, or advanced treatment.  Where on this continuum is
“treatment” occurring for the purposes of this survey?

 In order to determine what definition is appropriate, the agency will
need to consider how the survey results will be used.  For example, if
“treatment” is tracked as application of any unit operation and the
agency used the subsequent data to track whether more ground water
systems “treated” ground water as a result of the Ground Water Rule,
it would underestimate the impact of the rule by generating a false
baseline of existing 4-log disinfection or equivalent treatment
practice.

Response:

A seasonal source is one used on for a portion of the year only.  For
example, a source used to account for seasonal fluctuations in demand.
Emergency sources are ones used on an emergency basis only.  There is no
limit on the number of days it can be used or the type of emergency.
These data are used to characterize the overall capacity of water
systems.

Treatment includes any process intended to improve or maintain water
quality. It includes disinfection.  Subsequent questions ask systems to
characterize the type of treatment.  A definition of treatment will be
added to the question.  The treatment question in question 6 is an
internal consistency check; it is to ensure that additional information
about the treatment process is provided for all water treated by the
system.  This information is intended to provide a general
characterization of the myriad types of treatment used in the water
industry; it will not be used to evaluate the effectiveness of a
particular rule or to estimate the level of disinfection achieved by
systems.

Comment:

Question 6A also includes the following sub-question, “Estimate the
maximum daily amount of water that can be drawn from this source that
supply each ground water entry point.”  This question does not allow
for the impact of the water quality limitations on withdrawals. The
subsequent footnote also provides for the possibility of unlimited
withdrawal. Without an appreciation of state and local water resource
plans, local economic development and growth projections, and numerous
other factors, this data element is of little to no value to the agency.

Response:

Collected routinely since 1995, these data are used to characterize the
capacity of systems, including the variability in system capacity.
Systems should account for water quality issues when providing estimates
of the quantities of water that can be withdrawn from a source.  They
also should take into account local water resource plans or other
factors that limit withdrawals.  Text will be added to the question to
ensure systems take these issues in to account when the estimate the
limitations on withdrawals.

Comment:

All of the points made above regarding question 6A are relevant to 6B
regarding surface water supplies and 6C regarding purchased water
connections.  Question 6B includes a category of surface supplies that
withdrawn but not treated by the PWS.  It is not relevant to the
agency’s needs to understand if a PWS withdraws water and provides
that water untreated to a non-drinking water customer.  There are PWSs
that are also bulk water providers and power producers – neither of
these business elements bear on the agency’s purview under the Safe
Drinking Water Act.  Another definitional problem emerges in Question 6B
and 6C – what is “typical” needs to be clearly stated.  For
example, in question 6B is this value intended to be the annual average,
annual mean, seasonal average, or some other statistic.  Is the value
intended to reflect the previous 12 months of record or some longer more
meaningful period of time that would reflect more than the most recent
weather pattern?  Question 6C complicates the use of typical further by
asking for the amount of water purchased on a “typical day” “on
average”; so not only is this value “typical” but it is typical of
the “average” day, where there is no context for what constitutes an
“average day.” In Question 6C, it is not clear how a PWS could
purchase water from a supplier and not know if it was finished drinking
water or not as suggested by one of the fifth sub-question.

Response:

These data are used to characterize the capacity of systems. This
characterization must account for non-drinking water use; otherwise, it
may overestimate the drinking water capacity of a system.  Wholesalers
(“bulk providers”) and combined water and power utilities are
subject to EPA regulations under SDWA.

The question asks for average withdrawals data requested are for the 12
month period reported in question 2 of the questionnaire.  While that 12
month period may be unusual, the CWSS is intended to provide a snapshot.
 The terms “average” and “mean” are synonymous and are generally
understood. Because means can be sensitive to extreme values, the
question asks for the average use on typical day. Systems will have some
discretion as to how they define typical.  Based on the experience of
past surveys, systems have little trouble interpreting these questions.
The option for providing a response of “Unknown” in Question 6.C is
simply to capture all possible, albeit unlikely, responses.

Comment:

Question 6C also asks if booster disinfection occurs – but does not
specify when booster disinfection might occur.  Should a PWS only
indicate that booster disinfection occurs if the whole volume of water
purchased from a given source receives additional disinfection?  How
should a PWS respond if water is purchased from the same supply from
multiple turnouts, only some of which require booster disinfection?
This same question applies equally to the question of treatment more
broadly in the following sub-question.

Response:

The question asks for information by connection.  If a system purchases
water from one source but has multiple connections or turnouts, it
should list each separately.  This point will be clarified in the
instructions.

Comment:

Question 7 is reminiscent of the Information Collection Rule.  Asking
each of 1,700 rather than just the 372 CWS serving more than 100,000
persons to identify all of their water treatment plants and associate
the sources and flows of those sources for each of its plants.  This
information was captured in the ICR and the agency found that even with
monthly water quality data and treatment characterization data, it was
very difficult to use this information constructively in the development
of rule provisions.  It is not clear that the agency will be able to use
this data productively for a much larger group of systems if collected
today.

Response:

These data have been collected by past CWS Surveys and are used to
provide a general picture of the industry.  They are used to estimate
average daily production, treatment capacity ,and peak daily production
of systems.  They are not used to estimate water quality of systems.
Data from large systems would not help estimate the capacity of smaller
system; therefore, the data are collected from all systems in the
sample.

Comment:

The treatment and objective codes provided on page T1 / T2 will provide
some standardization to the PWS response to the following questions.
Corrections to the codes include:

1. Combine T3 and T4 (chloramine with free chlorine period and
chloramine with seasonal free chlorine use).

2. T7 is “Ultraviolet light” not “ultraviolet”.

3. Delete T8 (potassium permanganate) as potassium permanganate is not a
recognized disinfectant under the SWTR, IESWTR, LT1ESWTR, LT2ESWTR, or
proposed GWR.

4. Delete T15 (polymer addition) as polymers can be used during
coagulation and filtration and the current survey scheme does not
provide mechanism to distinguish.  Also, the survey does not
characterize coagulants generally (alum, ferric, etc.) so the use of
polymers seems to be an aberration in the survey scheme.

5. Delete T39 (clearwell) as the clearwell is either a component of
disinfection or storage. This question is about treatment so
disinfection is already covered.

6. Objective O6 (oxidation) is redundant with other objective codes that
are more descriptive.

7. Objectives that are missing include, DBP control, meet water
production demands with limited available water resources, meet customer
expectations, meet local water quality goals, and meet state-specific
regulations.

Response:

1. We agree to consolidate T3 and T4 into one treatment code.

2. The question distinguishes between the seasonal use of free chlorine
addition  and its temporary use to address nitrates or other issues on
an irregular basis.  EPA will consider rephrasing the terms to clarify
the difference.

3.  EPA agrees and will make this change.

4. Potassium permanganate is used as an oxidant; some systems may use it
for disinfection,  even though it is not an approved disinfectant.  EPA
will move it to the “Other” category.

5. Polymers are used by some system in addition to coagulants.  Past
surveys indicate they are added in a separate step from coagulants.
Polymer addition will be moved up in the list of processes so it follows
coagulant .

6. Clearwell follows filtration, and it must be included to allow
systems to completely characterize the treatment process.  It helps to
understand where and when systems add disinfectant.  EPA will consider
changing the step to “Clearwell and/or contact basin.”

7. Some processes may be used for either oxidation or disinfection.  For
example, a system may add chlorine prior to filtration for oxidation
purposes; it may add it again afterwards for disinfection.  The
oxidation objective allows systems to make this distinction.

8. DBP control will be added as an objective. Question 8 requests data
on treatment objectives in terms of the treatment practice’s impact on
water quality, not the overall objective of the system.  The other
objectives suggested are not relevant in this context.

Comment:

Responding to Question 8 (filling in the treatment and objective matrix
for each water treatment plant) imposes objectives on each unit
operation, when in fact, drinking water treatment is a series of
inter-related united operations.  For example, the IESWTR sets a filter
performance standard that reflects the performance of “conventional
treatment” – coagulation, flocculation, settling, and filtration all
have to occur successfully to meet the 0.3 NTU combined filter effluent
treatment technique.  The artificial boundaries imposed by this survey
design will result in difficult to interpret and spurious summaries of
treatment plant unit operation objectives.

Response:

EPA recognizes that treatment plants use integrated processes.  Several
steps may be required to meet a single objective.  In that case, systems
may repeat the objective on each step.  As some steps have multiple
objectives, systems also may record more than one objective for each
step of the treatment process.

Comment:

Any useful application of the results of Questions 10, 11, 18, and 19
must be premised on a logical linkage between the descriptions of the
treatment plant(s) from questions 7 an 8 and the data that is
subsequently collected.  This linkage does not exist in the current
survey design.  Adding this additional dimension to the survey design
would increase the level of effort required by PWSs to answer the
questions to the order of weeks rather than days of effort.

Response:

Question 10 is explicitly linked to question 8.  Question 11 is intended
to collect general information about storage and is not linked to the
treatment in place.  Question 18 collects data about the distribution
system; systems with multiple plants may not be able to link the
responses to individual treatment plants.  Question 19 is not related to
treatment, but is intended to provide a proxy measure of the service
area of the system as was done for the 1995 CWSS. The Agency is aware of
the potential shortfalls of using ZIP code data.  The data are used to
link the survey data with data from the US Census.  Alternative
approaches – like asking for service area maps – proved inadequate.

Comment:

Question 9 is inadequate to the task it appears to be attempting to
solve, that is, informing the development of CWA Effluent Guidelines for
drinking water treatment plants.  The survey question is not specific
with respect to what residual streams are of interest.  Indeed, it
provides a number of disposal options, any combination of which may be
applicable to a given plant for some fraction of its residual streams.
The question also asks “Can you discharge to a water-way?” without
providing any context (is this a question of if pipes are in place for
such a discharge, are there legal prohibitions, are there permit
restrictions, etc.).  AWWA submitted detailed comments on the draft
Water Treatment Plant questionnaire prepared by the CWA Effluent
Guidelines Team.  A review of those comments will illustrate the
complexity of ascertaining useful information about water treatment
plant residual management processes.  The proposed survey question will
not generate any information of value to the Effluent Guidelines effort
or SDWA efforts to understand residuals management.  AWWA has proposed a
detailed alternative survey strategy to EPA for capturing information
about residuals management that the agency should pursue rather than
developing questions that in the CWSS that do not provide data that can
be used to inform decision-making processes.

Response:

A separate survey conducted by the Office of Science and Technology, not
the CWSS, will collect  data to inform the development of CWA Effluent
Guidelines. Rather, the question provides data on alternative approaches
to residual management practices used by systems as was gathered by a
nearly identical question in the 2000 CWSS.  The data inform estimates
of the cost of treatment by providing information on residual management
practices associated with various treatment processes. Columns 8, 10 and
12 of this question will be re-worded for clarity such that “Can
you…?” will be replaced in all instances with: “Are you legally
able to…?”

Comment:

Question 10 cannot be answered by PWSs.  The purpose of the regulatory
process is to determine what must be removed to protect public health
and to what levels it must be reduced to achieve that goal.  The
chemical and physical processes at work in drinking water treatment
plant unit operations also affect the concentrations of constituents in
natural waters that are not regulated.  The extent to which this occurs
is a topic for focused research, not a survey query to PWSs.
Understanding removal does not occur through a random response from a
survey, it comes from focused experiments that evaluate the conditions
under which specific contaminants are removed by particular treatment
processes or combinations of processes.  The information collected by
this question would not have any utility to EPA because there is
insufficient information collected to understand any removal that is
observed.

Question 10 appears to be an effort to identify every unregulated
contaminant utilities are monitoring, regardless of EPA’s intent to
regulate those contaminants.  EPA also appears to be seeking
information on contaminants the utilities are removing, again regardless
of EPA’s regulatory plans.  Utilities may test for many unregulated
contaminants, but monitoring for unregulated contaminants is not uniform
across all systems.  Additionally, utilities do not necessarily have, as
the question assumes, information on every unregulated contaminant that
may be reduced or removed by treatment plant technology, given that
treatment may address contaminants not specifically identified by the
utility.

Instead, unregulated contaminant monitoring should be accomplished
through the third Unregulated Contaminant Monitoring Rule (UCMR) based
on the current Contaminant Candidate List (CCL).  EPA used this approach
in the 2000 CWSS, by asking for raw water and treated water
concentrations of specific unregulated contaminants on the CCL (e.g.,
MTBE) as well as contaminants that had been proposed (e.g. arsenic.)

In addition, EPA should continue to use the National Contaminant
Occurrence Database (NCOD) for analysis, rulemaking and rule evaluation.
 And the NCOD should be populated by data collected under the UCMR, in
STORET and from USGS surveys and research projects, and not the CWSS.

Response:

Question 10 collects data on raw and finished water concentrations of
unregulated contaminants for very large systems only.  39 of 89 systems
were, in fact, able to provide similar data in the 2000 CWSS.  That data
has proved useful in the past in confirming MTBE and Boron data from the
UCMR.  The question is not designed to estimate the effectiveness of
treatment processes for removing unregulated contaminants and the data
will not be used for that purpose.  Instead, the data would be useful
for several efforts which include (1) the development of the Contaminant
Candidate List (CCL) and the Unregulated Contaminant Monitoring
Regulation (UCMR), (2) the regulatory determinations for the CCL, and
(3) the review process for the Six Year Review.

In the case of CCL and UCMR, the surveillance of unregulated
contaminants is an important aspect of the Agency’s strategy to
identify potential candidates for CCL and UCMR.  If the data indicate
that some contaminants are occurring in many different systems and if
these contaminants have not yet been identified by either CCL or UCMR,
this information could provide “early warning” and help the Agency
identify contaminants that should be considered for future CCLs and/or
the UCMRs.

In the case of regulatory determinations for CCL, the Agency primarily
relies on drinking water occurrence data from UCMR to determine whether
a national primary drinking water regulation is needed for a particular
contaminant.  While the Agency gains valuable information from the UCMR
effort, its focus differs from that of Question 10 in one important way
- UCMR occurrence data are collected after treatment is applied, which
means that some raw water contaminants may be removed or greatly diluted
by the treatment process and thus go undetected, leaving a false
impression that the contaminant is absent in the source water.  In cases
where the UCMR finished water data indicate that a contaminant is not
occurring, this would lead the Agency to make a determination not to
regulate a particular contaminant.  If an unregulated contaminant listed
on CCL and monitored by UCMR is being removed because of current
treatment practices, this information is valuable since it demonstrates
that some additional health protection may be occurring and unaccounted
for since we do not have information on raw vs. finished water.  And
even though the Agency decides not to regulate a contaminant based on
the UCMR finished water data, it would be advantageous for the Agency to
point to cases or take credit for unregulated contaminants that are
being removed by current treatment practices.

In the case of Six Year Review, if the data indicates that certain
unregulated contaminants are removed or their concentrations
significantly reduced by the use of treatment processes designed to
treat regulated contaminants, then the Six Year Review process may also
be able to take credit for the benefits of treating unregulated
contaminants.

Lastly, there is no sampling error (the random error referred to by the
comment), as the survey asks all very large systems for the data.  The
data will not be used to draw inferences to other systems.

Comment:

Question 11A asks for information on every water storage facility in a
drinking water utility.  It is not clear what the agency could possibly
do with this information.  What is the national significance of the
number of 200,000 gal tanks versus the number of 500,000 gal tanks?  Is
there a national need to know how many tanks are baffled? How many tanks
have separated inlets and outlets? The agency, once again, is collecting
information that is inadequate to answer any important policy questions.
 There are numerous PWSs with large numbers of tanks – completing this
portion of the survey would be an onerous task with little benefit for
the agency.  The agency also specifically asked “"What is the typical
detention time of the water in the vessel (in days)?".   How would this
be calculated – is the standard of care a calculation of the hydraulic
detention time based on plug flow, a modeled result compliant with Stage
2 DBPR IDSE requirements, or a best guess? The information collected
through this question will vary greatly across PWSs and the role of
particular tanks in the PWSs distribution system.  For example, how will
the agency separate out tanks that are used to move water long distances
through a distribution system or combined distribution from tanks that
are used to serve residential areas?  The former will have very short
hydraulic detention times while the later may or may not, but it is only
the later has the greater potential to directly affect water quality at
the customer’s home.  Question 11B asks “Do you use any of the
following practices to maintain water quality in storage vessels in your
system? (check all that apply)”.   Providing this information without
context is meaningless.  Are the options provided used? Yes.  The
information needed is in what situations, and to what effect.  Simply
capturing the frequency utilities respond that they use different
approaches does not make any linkage to water quality, to frequency of
use within a given utility, the tank settings where different approaches
are employed, etc.  With this much missing information, the agency
should reconsider the utility of this question.

Response: EPA proposes to revise the questions accordingly.

11A:  This question has been deleted.

11B:  The purpose of asking this question is simply to identify the
frequency of common practices, not to reach conclusions about water
quality.  We have added a second column of check boxes next to the first
where systems can react to the following question: “Check below if you
believe you have adequate information on how to use this strategy to
address water quality degradation in your storage facilities”

Comment:

Question 12 uses incorrect definitions for “transmission lines” and
“mains”.  Transmission mains are described as raw water or partially
treated water mains.  However, the term is frequently used in
distribution system parlance as large diameter pipe used to move water
from the plant to major storage facilities and major sources of water
demand.  If raw water piping is to be captured, then a separate table
should be added to the table.  Also, the table for answering the
question specifies all pipe information relates to “mains” (see left
axis) when the text above the table indicates that service lines are
relevant.  Service lines are not “mains” and should not be counted
as such.  Again, a separate category would be appropriate if the agency
has a need for information about service lines.  Since the agency’s
authority under SDWA stops at the customer’s property line, it is not
clear what value information on service lines has for the agency.

With respect two Question 12, it is curious that the period of
construction captured is 5 years when previous questions have not
specified more than a period of one year.  Consistency is needed within
the survey instrument to reduce inadvertent errors.  Also, this once
again raises the question of what is the pertinent timeframe for the
questions in this survey.  Infrastructure investments occur over
extended timeframes as do other factors that affect PWS decisions.

Response:

The 2000 survey asked for the length of pipe replaced during the last 5
years.  A 5 year planning period is appropriate so that outlier years
with significant additions or replacements are spread out over a period
of time to better reflect overall expansion and replacement trends and
ensures that significant expenditures are not overlooked. EPA has
simplified the question to reduce the number of pipe categories from 6
to 4.   Beyond that, EPA believes the following clarifications will
address the rest of the concerns:

.

A transmission line is defined as a pipeline that transports raw or
partially treated water to a water treatment plant or finished water to
a distribution grid.

A distribution main is defined as part of the pipeline network that
distributes water to the consumers.

Replaced pipe is pipe that has either been physically removed from the
ground or has been subject to major rehabilitation efforts.

New pipe installed is new service lines pipe for transmission lines or
distribution mains that do not replace existing pipe.

On diagram, “Distribution Mains System”

In table, “Existing (or Current) Length of Pipe”

Comment:

Questions 13 – 17 raise the question of whether this is the Community
Water System Survey or whether it is an Information Collection Rule for
the Distribution System Rule.  If this information collection is
intended to provide a sound backdrop for any cost-analysis of regulatory
or policy decisions made by EPA, then this question is going into an
area of detail that is not pertinent.  If the agency intends for this
information collection activity to support the TCR/DSR rulemaking
effort, then the questions asked are inadequate, lack context to provide
meaningful information, and could lead to misleading assumptions in
development of a rulemaking focused on PWS distribution systems.  With
respect to these questions, the agency does not”

1. Collect information to put booster disinfection use in context –
what percent of distribution system is downstream of booster
disinfection, is booster disinfection continuous, what other activities
are coordinated with booster disinfection (e.g., capital improvement
program for new transmission mains, tankage, etc.).

2. Identify what “minimum daily operating pressure” means.  (e.g.,
is this water pressure or a pressure related to booster chlorination, if
water pressure is this a value measured at the point of entry (pressure
entering the pressure zone, the pressure at a representative topographic
high point), if water pressure is it pressure at a particular time of
the year (during high demand, low demand, etc.) or averaged over 365
days, etc.

3. Areal extent of pressure drop below 20 psi (e.g., it is not
appropriate to equally weight the number of pressure losses affecting a
single building (e.g., service line break) with pressure losses
affecting the entire distribution system (e.g., simultaneous loss of
high service pumps and major distribution storage failure).

Again, the definitions used will limit the utility of the survey effort
on flushing.  The definitions of directional and random flushing are
inadequate.  Also, in asking if a utility “has every flushed” the
survey instrument fails to ascertain if any water quality challenges
were evident in the system.

Response:

Regarding item 1, above, EPA does not need this other information to
provide context because Although we have reduced the scope of some
questions to minimize the burden to utilities responding to the survey,
we do not believe we need the detail suggested by AWWA to achieve the
purpose for which we intend to use this data.

Regarding item 2, above, the question will be revised to read, “What
is the minimum operating pressure recorded during your peak demand month
across all pressure zones in your system?”

Regarding item 3, above, we are collecting this information because they
affect distribution system water quality and it is the Agency’s
responsibility to safeguard public health. Backflow events are
associated with pressure reductions, and booster disinfection mitigates
the risk associated with backflow. We need to determine the extent to
which management measures are already in place (e.g., use of pressure
zones, booster disinfection) in order to identify whether further
measures are necessary, and the potential utility cost of implementing
risk reduction strategies. The NAS has identified cross connections and
backflow as another high priority distribution system risk.  The recent
NAS report has specifically mentioned improvements in pressure
maintenance as being effective for preventing and controlling DS
contamination; consequently it is important to collect better data on
current practices to support regulatory and costing analyses.

As EPA has previously indicated, the purpose of the CWSS is to obtain
new data to support its development and evaluation of drinking water
regulations.  The Agency plans to use the data for regulatory, policy,
and implementation analyses.  The scope of these questions is indeed
pertinent for inclusion in the CWSS.  EPA has developed these questions
to balance the information needs of the Agency with the burden of
responding to the survey.

Collecting information to support cost-analysis and regulatory and
policy decisions is pertinent to the CWSS.  As stated in previous CWSS
reports, the purpose of the CWSS is to obtain new data to support its
development and evaluation of drinking water regulations.  The Agency
plans to use the data for regulatory, policy, implementation, and
compliance analyses.   The responses to these questions will provide
baseline data for risk evaluation, costing information, and for
development of guidance and training materials.

Regarding the comment that the survey instrument fails to ascertain if
any water quality challenges were evident in the system, EPA will
determine through engineering and scientific analysis how these
practices best contribute to water quality maintenance in the
distribution system. The flushing questions will inform us to what
extent practices are currently in use, identify need for guidance or
training, and estimate costs for improved or additional flushing
programs. Flushing has been selected as a high priority area for data
collection because it is one of the most common mitigation strategies.

Again, regarding the comment that the survey instrument fails to
ascertain if any water quality challenges were evident in the system,
EPA will determine through engineering and scientific analysis how these
practices best contribute to water quality maintenance in the
distribution system. EPA proposes to make the following revisions to
questions:

Revision to question 13a (Parts 4 a and b):

These parts have been eliminated.

Revision to question 16:

“Uni-) Directional  (Restricting water flow to one direction using
closed valves to maximize velocity, generally from source/plant to the
lowest elevation in the system)”

Random Conventional

Comment:

Question 18 asks PWSs to provide average residual values at the
point-of-entry to the distribution system and in the distribution
system.  Scott Summer’s work in the analysis of the ICR data during
the Stage 2 M/DBP FACA illustrated that this data is of little value in
understanding chlorine decay in the distribution system unless evaluated
on a system-by-system basis.  Collecting this information from 1,700
systems without information characterizing the distribution systems in
detail does not provide any information that can be used constructively.

Response:

We have identified this as a high priority area because we are not aware
of any other means of access we have to this type of data. It is
necessary to collect new disinfectant residual data because ICR data
will be 10 years old and do not reflect the significant operational
changes that have been implemented in response to the Stage 1 and Stage
2 DBPRs, including reduced disinfectant demand due to greater precursor
removal and changes to residual disinfectant practices.  Utilities rely
on disinfectant residual to mitigate contamination events and control
biofilm and growth.  It is important for EPA to understand disinfectant
levels in the distribution system as systems are complying with the
current regulations to achieve an understanding of baseline risk and
determine whether changes to existing requirements are appropriate. EPA
intends to evaluate data received from this question on a
system-by-system basis and aggregate the results of the system-by-system
evaluation.

Comment:

Question 19 would link 5-digit ZIP codes to PWS service areas for small
to medium-sized PWSs.  The agency should seriously evaluate the utility
of such an approach.  There is seldom a one-to-one match between zip
codes and service areas.  Zip codes will frequently include many more
individuals than are served by a PWS so any extrapolation of the PWS to
zip codes will overstate utility service areas and underestimate per
capita costs.

Response:

The Agency is aware of the potential shortfalls of using ZIP code data.
The data are used to link the survey data with data from the US Census.
Alternative approaches – like asking for service area maps – proved
inadequate.  The data are not used to estimate per capita costs, so it
will not lead to an underestimate of per capita costs.

 Comment:

Question 20 is largely a solicitation of opinions.  It is not clear how
the opinions garnered would be actionable by the agency. The questions
in this section will require highly subjective answers and will vary
widely on local opinions, politics, and a utility’s engagement in the
water security arena locally and nationally. By contrast, most other
questions in the CWSS are based on specific data that can be collected.

Question 20 A.3.a. - Utilities will always be working to improve their
ability to prevent, detect, respond to and recover from a security
incident.  Therefore, utilities will always be needing and seeking more
information on these topics

Response:

The answers to question 20 will help EPA use official responses from
utilities on their security needs to make programmatic decisions, rather
than assuming those needs or justifying program expenses and priorities
because of hearsay. This is essentially what GAO does when they issue a
report with recommendations. GAO sends out a survey and gets responses.
Those responses are used to justify their recommendations for program
priorities and redirection. The same would be true for how EPA will use
these answers.

In addition, question 20 helps EPA gauge the exposure of its security
products in the water sector. If utilities have or have not taken our
training and/or heard of our programs, then that is helpful information
for EPA to know, because it tells us how effective or ineffective our
outreach/training has been.

Comment:

Questions 22 and 23 are regarding PWS rate structures and assistance to
disadvantaged households.  Like other pieces of information collected by
the proposed survey instrument, this is interesting information.  But,
to what end is EPA collecting this data?  EPA does not have a need for
this information within its mission, implementing the SDWA.

Response:

System finance is a critical component of EPA’s capacity development
program.  These data support EPA’s analysis of issues related to
full-cost pricing, affordability, and asset management.  Collected in
1995 and in 2000, the data also support EPA’s overall assessment of
the industry.

Comment:

Question 24 will provide the maximum number of residential connections.
This information has no value.  If the issue is the regulatory bin the
system falls in (e.g., greater or less than 10,000 population served) or
the changing demand on the system then the data needed is the change in
population served.  Secondly, while there are instances where the number
of “residential connections” will increase or decrease the more
common metric is the increase in water delivered to the greater number
of persons present in a given service area.

Response:

Other data are used to determine the size of the system for regulatory
purposes.  These data are used to further understand the impact of
seasonal populations on systems’ with substantial seasonal
fluctuations in population.  The number of connections is a proxy for
the potential fluctuation in the size of the population served.  EPA
will consider requesting data on changes in water deliveries rather than
connection; EPA suspects this information would be more difficult for
systems to provide than data on seasonal connections.

Comment:

Question 25 is not clear and should be better explained.  Specifically,
is EPA interested in the average number of hours employees work per week
(e.g., 40), or in the cumulative number of hours all operators, managers
and administrative staff work (e.g., 40 hours x total number of
operators.)  How should responses address part-time employees?

Response:

The question asks for the average number of hours per week system’s
employees work in the system, e.g. 40 hours per week.  Part-time
employees and employees should be included in the average.  Text will be
added to clarify what information is required.

Comment:

Question 26 asks for expenses over the last fiscal years and indicates
that this is the same period as identified in Question 2.  Question 2
asks for the PWS to “the most recent 12-month period for which data
are available”.  Financial data can be compiled for any preceding
12-month period after the receipt of the survey instrument.  This is
different from the preceding fiscal year, which will allow referencing a
standard fiscal report for some, though by no means all of the fiscal
data requested.

Response:

The agency will clarify the language for the question.  EPA wants
financial data for the latest 12 month period for which they are
available.  The requirement that systems compile financial data
specifically for the survey would impose a large burden on systems. This
question was also asked in the 2000 CWSS.

 Comment:

Question 26 A-D asks the respondent to enumerate expenses into a set of
categories.  Are these categories meant to be exclusive (should the
total sum to 100%) or does the agency realize that expenses for
purchased water will include capital and operational costs, that capital
costs will include security costs, etc.

Response:

The categories are intended to be mutually exclusive.  Expenses for
purchased water should include the cost of the water only, not the
capital required to bring it to the system.  EPA will clarify this issue
in the next draft of the questionnaire.

Comment:

Question 27.  Again the period for capital expenditures is described as
a 5-year period where the previous question 26 (expenses) was limited to
most recent fiscal year.  The survey continues to mix and match periods
over which data is aggregated.

Response:

Question 26 asks about regular, routine operating expenses.  Question 27
asks for capital expenses, which are not routine and thus may not have
been made during the last 12-month period.  While the system may not
have incurred capital expenses in the 12 months covered by question 26,
it may have had large investments the years immediately preceding.
Therefore, as has been done since 1995, the CWSS asks for capital
expenses for a longer period of time so as to gain a more realistic,
annualized estimate.

 Comment:

It is not possible to answer Question 27B as written “What percentage
of the total capital expenditures identified in part A were used for the
following ... “Compliance with regulations, excluding expenditures for
system expansion and replacement and repair of equipment.”  The costs
of regulations are embedded in every capital decision a drinking water
utility.  By answering this question by using one of the other
categories provided the respondent underestimates the impact of
regulations in its decisions; if the respondent allocates all costs to
this category then the estimate will misrepresent the impact of other
drivers.  Thirdly, even system expansions include cost elements that are
directly related to regulations (e.g., sizing of tanks, choice of pipe
material, selection of treatment processes, selection of water sources,
etc.).

Response:

The agency recognizes that capital expenses serve multiple purposes.
The survey asks systems to use their judgment and estimate the share
that goes towards each purpose. Such questions have been successfully
answered by respondents in two prior CWSSs, 1995 and 2000. While EPA
realizes that a variety of purposes underlie each expenditure, the
Agency believes that the system owners and operators are in a better
position to estimate such an allocation for their system than are those
not familiar with the system.

Comment:

Question 28A, like many questions in this survey, lacks a specific
purpose that is closely linked to the agency’s responsibilities under
SDWA.  Moreover, lacking a sound definition of “asset management
plan” the response will be meaningless.  Finally, the selection of a
20-year planning horizon may not be appropriate for systems that choose
to focus aggressively on a shorter-term planning horizon.

Response:

Over the last several years, along with EPA and many other drinking
water industry stakeholders, AWWA has undertaken considerable effort to
promote sound asset management. For example, from   HYPERLINK
"http://www.awwa.org/education/seminars/index.cfm?SemID=57_"
http://www.awwa.org/education/seminars/index.cfm?SemID=57  , “This new
AWWA Asset Management seminar will underscore the urgency of getting
started and enable you to launch the appropriate management strategies
to provide prudent stewardship of public utility assets.” However, we
too recognized that the message may not have reach ever owner and
operator, and where it has, we also recognize that a consensus on the
detailed specifications of what makes a sound asset management plan has
not yet been concluded.

At the same time, we do believe that the industry has progress enough in
the area that a general definition can be derived and we will insert one
into the instructions for the Survey.   We believe it is important to
gain some sense of the degree that systems are beginning to avoid the
fundamental folly of "aggressively focusing on a shorter-term planning
horizon" without the context of understanding their long-term asset
management needs.  Similarly, if the industry’s asset management needs
and direction are, as AWWA and many others have stated, true phenomena,
it would be folly for EPA regulatory efforts to proceed over the next
several years in ignorance of the trend.

Please note that the 20-year horizon has gained some foothold in the
assessment management field including its use in the Drinking Water
Infrastructure Needs Survey conducted every four years by EPA and in
EPA’s “Gap Analysis Report.”  It has also been used in similar
assessments and reports by the Water Infrastructure Network (WIN) as
well as by the Government Accounting Office.  We are open to suggestions
for alternative asset management timeframes but we would need some
rationale for not being consistent with these other efforts.

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

 This method is based on Folsom, R.E., F.J Potter., and S.R. Williams,
“Notes on a Composite Size Measure for Self-Weighting Samples in
Multiple Domains,” American Statistical Association 1987 Proceedings
of the Section on Survey Research Methods, August, 1987, pp. 792-796.

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