be broken into its labor component and materials component.  The labor
required to analyze each sample is estimated at 1 hour, based on the use
of the ICP-MS (200.8) method.  The average labor rate for 1 hour of
labor is estimated in the following table.

Size Category	Labor for 1 Hr

<= 100	$23.86

101 to 500	$25.70

501 to 3,300	$27.54

3.3K-10K	$28.20

10K-100K	$28.99

>100K	$34.79

Mean	$28.18

The materials cost associated with analyzing a compliance sample for
lead can then be estimated by subtracting the labor component of $28.18
from the total fee of $36.34 for an estimate of $8.16 materials cost per
sample.

Appendix F-2: Regulatory Change III.G System Tap Water Monitoring Costs
(4th Qtr 2006$)

# Systems Affected by Reg Change III.G [1]:	54

# Systems that re-exceed lead AL and continue LSL replacement [2]	1

Annual # LSL Samples per System [3]	1,431

Estimated # Samples in Sampling Pool [4]	21,465

Estimated # Samples that need to be Retested [5]	16,313

Total Labor Cost [6]	$1,507,994

Total O&M Cost [7]	$133,117

Annual Labor Cost [8]	$100,533

Annual O&M Cost [8]	$8,874

Total Annual Cost	$109,407

Notes:

1.  Systems that have been required to conduct a lead service line
replacement program may potentially be affected by Reg. Change III.G if
they discontinue the program, then later re-exceed the lead action
level. The number of systems was estimated based on survey responses
from the USEPA Survey of States Questions on State Implementation of
Lead and Copper Rule (July 2004).Six states indicated the specific
number of systems that have been required to initiate LSL replacement
programs (total of 28 systems).  Five other states indicated that they
had systems that were required to have LSL programs but did not indicate
the specific number of systems.  For these 5 States, it is assumed that
each State has 5 systems with LSL programs required by State, for a
total of 25 systems. One system is added for DCWASA. The total number of
systems affected by Reg. Change III.G is assumed to be 28+25+1= 54
systems.

2.  Assume 1.4% systems re-exceed lead action level and are required to
continue LSL replacement program (data source:   HYPERLINK
"http://www.epa.gov/safewater.lcrmr"  www.epa.gov/safewater.lcrmr )
Assumption is based on current exceedance rate for lead action level by
medium and large systems.

3.  If a system re-exceeds the lead action level, samples must be
collected from each lead service line previously deemed to be replaced
through testing. The number of LSLs per system that have previously been
replaced through testing is estimated based on a utility survey
completed by Black and Veatch in

July 2005.  Twenty-six utilities reported that 558,135 LSLs in 1992 or
21,467 LSLs per system. Assuming each utility conducts LSL replacements
at a rate of 7% per year or over 15 years, this equals 21,467 divided by
15 or 1,431 LSLs per system per year
(www.epa.gov/safewater/lcrmr/pdfs/summary_lcmr_review_lead_line_replacem
ent_workshop_10-26-04.pdf).

4.  Assume that a system conducts a LSL replacement program for 15 years
upon initial exceedance of the lead action level based on LCR
requirements. The number of samples in the sampling pool is equal to the
number of systems that re-exceed the lead AL, x (annual # samples per
system) x 15 years.

5.  Assume the utility replaces 24% of LSLs and tests-out the remaining
76% based on data from DCWASA (2003). The number of samples that needs
to be retested equals the number of samples in the sampling pool x 76%.

6.  Assume burden is 3 hours for sample collection and analysis as
described in Appendix F-1.  Use system labor rate of $30.81 per hour
(average of wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules" (2003) updated to 4th Qtr 2006.

7.  Use average O&M cost per sample $8.16as described in Appendix F-1.

8.  Assume the systems conduct retesting over a 15 year period (based on
LCR requirements for LSL replacement programs).

Appendix F-3: States with at least 1 system required to initiate lead
service line replacement

State	At Least One System Required to Do LSLR	Number of Systems (If
Specified)	Number of Systems Assumed

AK

	AL

	AR

	AS

	AZ	Yes

5

CA

	CO

	CT	Consent Decree

DC

	1

DE

	FL	Withdrawn

GA

	GU

	HI

	IA	Yes	1	1

ID

	IL	Yes

5

IN

	KS

	KY

	LA

	MA	Yes

5

MD

	ME

	MI	Yes	14	14

MN	Yes	2	2

MO

	MS

	MT	Yes

5

Navajo

	NC

	ND

	NE

	NH

	NJ

	NM

	Nmar

	NV

	NY	Yes	1	1

OH

	OK

	OR

	PA	Yes	9	9

PR

	RI

	SC

	SD

	TN

	TX

	UT	Yes	1	1

VA

	VI

	VT

	WA

	WI	Yes

5

WV

	WY

	Total	11	28	54

	* Requirement withdrawn before LSLR started due to not longer exceed AL

	Notes:

	(1) Average number of systems performing LSLR in States that specified:
28 systems in 6 States, average of 5 systems per State

(2) Assumed 5 systems for States that did not specify number (WI, MT,

MA, AZ, IL)

(3) Added DC WASA

Appendix G

Derivation of Direct Costs for Initial Rule Activities

Appendix G-1: System Rule Implementation Costs (4th Qtr 2006$)

System Classification	# Systems [1]	Burden Per System (Hrs.) [2]	Total
Burden (Hrs.)	Total Labor Cost [3]

CWS, 25-100	13,766	5	68,830	$1,642,284

CWS, 101-500	16,240	5	81,200	$2,086,840

CWS, 501-3,300 	14,212	5	71,060	$1,956,992

CWS, 3,300-10,000	4,707	8	37,656	$1,278,722

CWS, 10,001-100K	3,541	8	28,328	$979,866

CWS, >100K	372	40	14,880	$583,742

NTNCWSs, 25-100	9,548	5	47,740	$1,139,076

NTNCWSs, 101-500	6,997	5	34,985	$899,115

NTNCWSs, 501-3,300	2,720	5	13,600	$374,544

NTNCWSs, 3,300-10,000	96	8	768	$26,080

NTNCWSs, 10,001-100,000	14	8	112	$3,874

NTNCWSs, >100,000	0	40	0	$0

Total	72,213	 	399,159	$10,971,135

Notes:

1.  Number of systems per SDWIS/FED Data 2004.

2.  Burden estimate based on consensus agreement of expert panels on
11.21.05, adjusted to reflect comments received.

3.  Wage rates from SAIC contract study, "Labor Costs for National
Drinking Water Rules" (2003) updated to 4th Qtr 2006 dollars.

Appendix G-2: State/Primacy Agencies Rule Implementation Costs (4th Qtr
2006$)

# States/Primacy Agencies [1]	Burden Estimate per State (Hours) [2]
Total Burden (Hrs.)	Labor Rate ($/hr) [3]	Total Labor Cost

57	600	34,200	$43.52	$1,488,433

Notes:

1. The LCR Regulatory Changes apply to 50 states, 6 territories and 1
Indian Tribe, for a total of 57 entities.

2. Burden includes regulation adoption, program development and
miscellaneous training. (Approximately .3 FTE or 4 months of FTE)

3. Use state labor rate of $43.52/hour (Source: Information Collection
Request for Contaminant Occurrence Data in Support of EPA's Second  Six
Year Review of National Primary Drinking Water Regulations (August
2006)).

Appendix H

Derivation of Direct Costs for Regulatory Change III.F

Appendix H-1. Summary of Cost Estimates for New Public Education
Requirements for LCR Short Term Revisions (4th Qtr 2006$)

Activity	Table	Requirement	Affected Party	Annual Labor Cost	Annual
Material Cost	Total Cost

III.F(a) Changes to Mandatory Text

III.F(a)	Appendix H-2	Customer Notification	Systems that Exceed LAL
$91,400	$0	$91,400

III.F(b). Activities to Better Reach At-Risk Populations

III.F(b)(1)	Appendix H-3	Notify 3 Organizations	CWS that Exceed LAL
$21,900	$21,400	$43,300

III.F(b)(2) (i-viii)	Appendix H-6 	Additional Activities 	CWS that
Exceed LAL	$292,700	$0	$292,700

III.F(c) Communication Activities with Consumers throughout a Lead
Exceedance

III.F(c)(1)	Appendix H-21	Customer Bills	CWS that Exceed LAL	$47,400	$0
$47,400

III.F(c)(2)	Appendix H-22	Post on Website	Large CWS that Exceed LAL	$100
$0	$100

III.F(c)(3)	Appendix H-23	Press Releases	CWS that Exceed LAL	-$3,700
-$500	-$4,200

III.F(e) Change in Requirements for CCR Statements

III.F(e)	Appendix H-24	CCR Statement	CWS that Don’t Exceed LAL
$354,600	$0	$354,600

III.F(g) System Cost for Reporting and Consultation with State

III.F(g)	Appendix H-7	Consultation with State & Letter	CWS that Exceed
LAL	$33,500	$200	$33,700

III.F(f) Cost to State Primacy Agency

III.F(f)	Appendix H-25	Review	State Primacy Agency	$63,000	$0	$63,000

Total for All Affected Parties	$901,300	$21,200	$922,500

Subtotal Water Systems	$837,900	$21,200	$859,200

 Appendix H-2. III.F(a) Customer Notification - Additional Burden and
Costs for Systems that Exceed the Lead Action Level (4th Qtr 2006$)

System Size Category	# Systems that Exceed Lead AL [1,2]	Annual System
Burden (hrs) [3]	Annual System Labor Cost [4]	Annual System O&M Cost [5]
Total Annual System Costs

CWS

25-100	185	648	$15,449	$0	$15,449

101-500	155	543	$13,942	$0	$13,942

501-3,300	133	466	$12,820	$0	$12,820

3.3K-10K	54	189	$6,418	$0	$6,418

10K-50K	40	140	$4,843	$0	$4,843

50K-100K	7	25	$847	$0	$847

>100K	7	25	$961	$0	$961

 	 	 	 	 	$0

NTNCWS	 	 	 	 	$0

25-100	217	760	$18,122	$0	$18,122

101-500	143	501	$12,863	$0	$12,863

501-3,300	51	179	$4,916	$0	$4,916

3.3K-10K	1	4	$119	$0	$119

10K-50K	1	4	$121	$0	$121

50K-100K

>100K

Total	994	3,479	$91,421	$0	$91,421

Notes:

1.  Additional customer notification requirements affect only systems
that exceed the lead action level.  For systems serving <3,300 people,
the # systems is based on SDWIS/Fed data for the monitoring period
ending after January 2003.(Data source: USEPA Survey of States -
Questions on State Implementation of Lead and Copper Rule. July 2004).

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

3. Assume burden to prepare additional language for customer brochure is
3.5 hours for all systems based on Public Notification Rule. Tier 2
violation.

4.  Loaded wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules (2003) updated to 4th QTR 2006.

5.  Mailing and productions costs are covered in the existing
regulation.Appendix H-3. III.F(b)(1) Notify Organizations: Costs to
Deliver Brochures to Preschools, Licensed Daycares and OBGYNs for CWSs
that Exceed the Lead Action Level (4th Qtr 2006$)

System Size Category	# Systems that Exceed Lead AL [1,2]	Annual System
Burden for Contacting Organizations (hrs) [3]	Annual System Labor Cost
[4]	Annual System O&M Cost	Total Annual System Costs

CWS

25-100	185	185	$4,414	$85	$4,500

101-500	155	155	$3,984	$303	$4,287

501-3,300	133	133	$3,663	$754	$4,417

3.3K-10K	54	135	$4,585	$2,630	$7,215

10K-50K	40	100	$3,462	$7,317	$10,779

50K-100K	7	18	$614	$3,981	$4,595

100-500K	4	11	$420	$6,367	$6,787

500K-1M	1	5	$201	$5,887	$6,088

>1 M	2	15	$569	$33,732	$34,301

Total	581	756	$21,911	$21,436	$43,347

Notes

1.  Additional requirements affect only systems that exceed the lead
action level.  For systems serving <3,300 people, the # systems is based
on SDWIS/Fed data for the monitoring period ending after January
2003.(Data source: USEPA Survey of States - Questions on State
Implementation of Lead and Copper Rule. July 2004).

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

3. All CWSs that exceed the lead action level need to send a brochure
with a cover letter to daycare centers and preschools, obstetrician and
gynecologists, and one public health agency.  Table 4.a summarizes new
notifications requirements by system size.  For systems serving <3,300,
the only new burden is 1 hour per system to develop a cover letter and
assumes that systems will use a template provided by USEPA.  For systems
serving 3,300 to 100,000 people, assume new annual burden requirements
of 1 hours per system to update list of organizations; 1 hour per system
to develop a cover letter; 0.25 hour per 100 additional brochures for
production; and 0.5 hours per system to contact   the public health
agency. For systems serving >100,000 people, assume an annual burden of
2 hours per system to update list of organizations;1 hour per system to
develop a cover letter; 1 hour per 20 additional brochures for
production; and 0.5 hours per system to contact the public health
agency.

4.  Loaded wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules (2003) updated to 4th Qtr 2006.

5.  For systems serving <3,300 people, new O&M burden is equal to the
material cost for a cover letter for each current notification per
system ($0.01  per notification). For systems serving >3,300 people, new
O&M burden equals $0.44 per brochure ($0.39 postage, $0.02 for 2 sheets
paper and $0.03  envelope) multiplied by the number of additional
notifications (Table 4.a) multiplied by the number of systems that
exceed the lead action level, plus  $0.01 for a cover letter for each
current notification per system.

Appendix H-4. Detail on Notifying Organizations

System Size Category	Average Population Served per System1	Additional
Notifications Per System2	Current # of Notifications Per System

<100	46	0	5

101-500	196	0	5

501-1K	567	1	5

1k-3.3K	1,465	3	5

3.3K-10K	4,474	9	5

10K-50K	16,840	33	46

50K-100K	52,423	101	90

100-500K	146,713	283	239

500K-1M	542,647	1,047	872

>1 M	1,554,621	3,000	2535

Notes

1. Data source: USEPA, Community Water System Survey 2000, EPA
815-R-02-005b, December 2002, Table 40. See Appendix H-5 for details.

2. Assume total of 193 new organizations per 100,000 population
including 178 licensed day care facilities/preschools per 100,000
population (per National Child Care Association); and 15 ob/gyns per
100,000 population (per 2006 Statistical Abstract).

Appendix H-5. Average Population Served per System Size

System Size	Number of CWSs	Total Population in System Size	Average
Population Per System1

<100	13,766	827,126	46

101-500	16,240	4,130,005	196

501-1K	5,914	4,354,314	567

1k-3.3K	8,298	15,783,290	1,465

3.3K-10K	4,707	27,346,264	4,474

10K-50K	3,057	66,857,216	16,840

50K-100K	484	32,951,452	52,423

100-500K	322	61,352,680	146,713

500K-1M	32	22,551,546	542,647

>1 M	18	36,341,784	1,554,621

Total	52,788	213,602,347	4,046

Notes:

Data source: USEPA, Community Water System Survey 2000, EPA
815-R-02-005b, December 2002, Table 40.

1. Average population per system is equal to the total population in the
specified system size class divided by the number of CWSs in the
specified size class. The average population per system was reduced by
23% to account for multiple family housing that was formerly included in
the population data per consensus of EPA phone meeting 3.2.06.

Appendix H-6. III.F(b)(2)(i-viii) Additional Activities for CWSs that
Exceed the Lead Action Level  (4th Qtr 2006$)

System Size Category	# Systems that Exceed Lead AL [1,2]	Average Annual
Costs Per System for All Activities [3]	Number of Activities [4]	Total
Annual System Cost

CWS

25-100	185	$44	1	$8,142

101-500	155	$49	1	$7,541

501-3,300	133	$89	1	$11,772

3.3K-10K	54	$289	3	$46,886

10K-50K	40	$928	3	$111,380

50K-100K	7	$1,865	3	$39,162

>100K	7	$3,231	3	$67,856

Total	581	 	 	$292,739

Notes

1.  These additional requirements affect only CWSs that exceed the lead
action level.  For systems serving <3,300 people, the # systems is based
on SDWIS/Fed data for the monitoring period ending after January
2003.(Data source: USEPA Survey of States - Questions on State
Implementation of Lead and Copper Rule. July 2004).

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

3.  See detail on separate worksheet entitled "Add'l. Activities",
Column L rows 8-14

4. For new regulatory provision 7A-H, systems serving <3,300 people must
complete 1 activity while systems serving >3,300 people must complete 3
activities each year. Appendix H-7. III.F(g) Consultation with State
and Self-Certification Letter for CWSs that Exceed the Lead Action Level
 (4th Qtr 2006$)

System Size Category	# Systems that Exceed Lead AL [1,2]	Annual System
Burden for Consultation with State [3]	Annual System Labor Cost for
Consultation with State	Annual System Burden for Preparing
Self-Certification Letter [4]	Annual System Labor Cost for
Self-Certification Letter	Annual O&M for Self Certification Letter	Total
Annual System Costs

CWS

25-100	185	370	$8,828	22.2	$530	$80	$9,437

101-500	155	310	$7,967	18.6	$478	$67	$8,512

501-3,300	133	266	$7,326	15.96	$440	$57	$7,822

3.3K-10K	54	108	$3,667	6.48	$220	$23	$3,911

10K-50K	40	80	$2,767	4.8	$166	$17	$2,950

50K-100K	7	14	$484	0.84	$29	$3	$516

>100K	7	14	$549	0.84	$33	$3	$585

Total	581	1162	$31,589	69.72	$1,895	$250	$33,734

Notes:

1.  These additional requirements affect only CWSs that exceed the lead
action level.  For systems serving <3,300 people, the # systems is based
on SDWIS/Fed data for the monitoring period ending after January
2003.(Data source: USEPA Survey of States - Questions on State
Implementation of Lead and Copper Rule. July 2004).

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

3. Systems activities include consultation with state on additional
activities, content of cover, discussion of alternative mechanisms, and
discussion of extending deadlines at a burden of 2 hours per system.

4.  Systems will also prepare a letter self-certifying that PE
activities have taken place and that materials have been distributed, at
a burden of .12 per letter per year, with $0.43 O&M costs ($0.39
postage, $0.01 paper, $0.03 for envelope).Appendix H-8. Cost of Each
Additional Activity for F(b)(2)(i-viii) (4th Qtr 2006$)

System Size Category	A. Public Service Announcements	B. Paid
Advertisements	C. Display in Public Areas	D. Internet Notification	E.
Public Meetings	F. Delivery to Every Household	G. Targeted Contact	H.
Materials Directly to Multi-Family & Ints	Average Annual Cost Per System
for All Activities

CWS

25-100	$98	$105	$24 	$24 	$48 	$7 	$34	$12	$44

101-500	$101	$105	$26 	$26 	$51 	$30 	$35	$15	$49

501-3,300	$105	$180	$111 	$28 	$55 	$166 	$37	$27	$89

3.3K-10K	$118	$180	$137 	$420 	$900 	$435 	$44	$81	$289

10K-50K	$1,400	$850	$696 	$596 	$2,400 	$1,114 	$66	$303	$928

50K-100K	$1,400	$5,000	$1,392 	$596 	$3,000 	$2,448 	$138	$945	$1,865

>100K	$1,400	$5,000	$3,943 	$1,035 	$5,000 	$3,874 	$563	$5,035	$3,231

Notes

A. See Appendix H-9 for details.

B. See Appendix H-10 for details.

C. See Appendix H-11 for details.

D. See Appendix H-12 for details.

E. See Appendix H-13 for details.

F. See Appendix H-18 for details.

G. See Appendix H-19 for details.

H. See Appendix H-20 for details.

Appendix H-9. Cost for Activity F(b)(2)(i) Public Service Announcements
(4th Qtr 2006$)

System Size Category	Price Per PSA Radio1	Price Per PSA TV2	Total PSA
Radio	Total PSA TV	Total Cost Per System

CWS

25-100	$98	$840	1	0	$98

101-500	$101	$840	1	0	$101

501-3,300	$105	$840	1	0	$105

3.3K-10K	$118	$840	1	0	$118

10K-50K	$560	$840	1	1	$1,400

50K-100K	$560	$840	1	1	$1,400

>100K	$560	$840	1	1	$1,400

Notes:

1. For systems serving <10,000 people, assume they use free-lance talent
for voice-over of an announcement developed by the system.  Assume 2
hours of system labor to write the announcement, $50 to produce spot
using freelance voice talent.

For systems serving >10,000 people, assume $560 for production of a
radio PSA including $280 to produce the audio using union talent, $80
for 1 hour of studio time, and $200 for developing the script.

2.  Assume $840 for production of a TV PSA including $560 to produce the
audio using union talent, $80 for 1 hour of studio time, and $200 for
developing the script.Appendix H-10. Cost for Activity F(b)(2)(ii) Paid
Advertisements (4th Qtr 2006$)

System Size Category	Cost Per 10 Inch Newspaper Advertisement [1]	Number
of Times Published	Total Per System

CWS

	25-100	$105	1	$105

101-500	$105	1	$105

501-3,300	$180	1	$180

3.3K-10K	$180	1	$180

10K-50K	$850	1	$850

50K-100K	$5,000	1	$5,000

>100K	$5,000	1	$5,000

Notes

1.  Assume 10 column inches (1/8 page) per advertisement.  Rates range
from $105 per 10 column inch for local weekly newspapers to $5,000 for
the Washington Post based on a random search of six newspapers.

Appendix H-11. Cost for Activity F(b)(2)(iii) Display in Public Area
(4th Qtr 2006$)

System Size Category	Number of Posting [1]	Hours to Post [2]	Materials
Cost [3]	Total Cost Per System

CWS

25-100	5	1	$0.20 	$24

101-500	5	1	$0.20 	$26

501-3,300	20	4	$0.80 	$111

3.3K-10K	20	4	$0.80 	$137

10K-50K	100	20	$4.00 	$696

50K-100K	200	40	$8.00 	$1,392

>100K	500	100	$20.00 	$3,943

Notes:

1.  It is assumed that small and medium systems may post a notice at the
local grocery store, Laundromat or similar establishment.  Assume that
systems serving <500 people would need 5 such postings, and systems
serving between 501 and 10,000 people may need 20 postings.  It is
assumed that the posting is free but each system spends 1 to 2 hours in
travel time.

2.  Burden hours based on estimated travel time between postings.

3.  Assume material cost equals $0.04 per posting.

4.  Loaded wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules (2003) updated to 4th QTR 2006.

Appendix H-12. Cost for Activity F(b)(2)(iv) Internet Notification
(4th Qtr 2006$)

System Size Category	Hours to Compose Email & Check Email List	Materials
Cost	Total Cost Per System

CWS

25-100	1	$0.00 	$24

101-500	1	$0.00 	$26

501-3,300	1	$0.00 	$28

3.3K-10K	5	$250.00 	$420

10K-50K	10	$250.00 	$596

50K-100K	10	$250.00 	$596

>100K	20	$250.00 	$1,035

Notes

1. It is assumed that small systems may prefer to notify customers via
e-mail, and would have a pre-existing list of customer e-mail addresses.

Assume that it would take systems 1 hour to compose and send out the
e-mail.

2.  Large systems would purchase email list and verify it.

Appendix H-13. Cost for Activity F(b)(2)(v) Public Meetings (4th Qtr
2006$)

System Size Category	Total Cost Per System

CWS

25-100	$48

101-500	$51

501-3,300	$55

3.3K-10K	$900

10K-50K	$2,400

50K-100K	$3,000

>100K	$5,000

Notes

1.  For systems serving <3,300 people, assume that system
representatives would bring up the issue for discussion at an existing
town meeting.  Assume 2 hours for preparation and meeting time.

2.  See detailed cost estimates on separate worksheet for systems
serving >3,300 people based on cost of USEPA public stakeholder meetings
not including cost of meeting space.

Appendix H-14. Cost for Activity F(b)(2)(v) Public Meetings for Systems
Serving 3,301-10,000 People (4th Qtr 2006$)

	Management	Technical	Total

	Rate:	$ 56.99	Rate:	$ 28.20

	Activity	Hours	Cost	Hours	Cost	$

	Pre-meeting logistical arrangements1	0	$ 0	6	 $     169.20 	 $
169.20

Preparation of presentation/talking points2	2	 $   113.98 	12	 $
338.40 	 $       452.38

Attend meeting3	3	 $   170.97 	3	 $       84.60 	 $       255.57

Post meeting, including notes4	0	$ 0	0	 $            -   	 $
-

Total	5	 $   284.95 	21	 $     592.20 	 $       877.15

	Estimated Total 5	$ 900

Hours	26

Notes

1. Select date, research and select site, negotiate with site for use,
publicize meeting, set up room including electronics (microphones, sound
system, presentation).

2. Prepare 30 minute presentation including consultation with health
experts and technical personnel as necessary, 30-50 slides, feedback
from management, practice presentation

3. Based on WASA, 1.5 hour open house, one hour presentation/Q&A, 15
minutes before and after, for a total of three hours, one senior
management, one technical staff

4. Prepare and review meeting transcript or notes, follow up with
attendees as appropriate

5. The estimated cost, $877.15, is rounded to the nearest hundred,
$900.00.

Appendix H-15. Cost for Activity F(b)(2)(v) Public Meetings for Systems
Serving 10,001-50,000 People (4th Qtr 2006$)

	Management	Technical	Total

	Rate:	$56.99	Rate:	$ 28.99

	Activity	Hours	Cost	Hours	Cost	$

	Pre-meeting logistical arrangements1	0	$ 0	10	 $     289.90 	 $
289.90

Preparation of presentation/talking points2	8	 $   455.92 	30	 $
869.70 	 $    1,325.62

Attend meeting3	6	 $   341.94 	6	 $     173.94 	 $       515.88

Post meeting, including notes4	0	$ 0	8	 $     231.92 	 $       231.92

Total	14	 $   797.86 	54	 $  1,565.46 	 $    2,363.32

Estimated Total 5	$ 2,400

Hours	68

Notes

1. Select date, research and select site, negotiate with site for use,
publicize meeting, set up room including electronics (microphones, sound
system, presentation).

2. Prepare 30 minute presentation including consultation with health
experts and technical personnel as necessary, 30-50 slides, feedback
from management, practice presentation

3. Based on WASA, 1.5 hour open house, one hour presentation/Q&A, 15
minutes before and after, for a total of three hours, one senior
management, one technical staff

4. Prepare and review meeting transcript or notes, follow up with
attendees as appropriate

5. The estimated cost, $ 2,363,32 is rounded to the nearest hundred,
$2,400.

Appendix H-16. Cost for Activity F(b)(2)(v) Public Meetings for Systems
Serving 50,001-100,000 People (4th Qtr 2006$)

	Management	Technical	Total

	Rate:	$56.99	Rate:	$ 28.99

	Activity	Hours	Cost	Hours	Cost	$

	Pre-meeting logistical arrangements1	0	$ 0	20	 $     579.80 	 $
579.80

Preparation of presentation/talking points2	10	 $   569.90 	40	 $
1,159.60 	 $    1,729.50

Attend meeting3	6	 $   341.94 	6	 $     173.94 	 $       515.88

Post meeting, including notes4	0	$ 0	6	 $     173.94 	 $       173.94

Total	16	 $   911.84 	72	 $  2,087.28 	 $    2,999.12

Estimated Total 5	$ 3,000

Hours	88

Notes

1. Select date, research and select site, negotiate with site for use,
publicize meeting, set up room including electronics (microphones, sound
system, presentation).

2. Prepare 30 minute presentation including consultation with health
experts and technical personnel as necessary, 30-50 slides, feedback
from management, practice presentation

3. Based on WASA, 1.5 hour open house, one hour presentation/Q&A, 15
minutes before and after, for a total of three hours, one senior
management, one technical staff

4. Prepare and review meeting transcript or notes, follow up with
attendees as appropriate

5. The estimated cost, $ 2,999.12, is rounded to the nearest hundred,
$3,000.

Appendix H-17. Cost for Activity F(b)(2)(v) Public Meetings for Systems
Serving >100,000 People (4th Qtr 2006$)

	Management	Technical	Total

	Rate:	$56.99	Rate:	$ 34.79

	Activity	Hours	Cost	Hours	Cost	$

	Pre-meeting logistical arrangements1	0	$ 0	20	 $     695.80 	 $
695.80

Preparation of presentation/talking points2	10	 $   569.90 	40	 $
1,391.60 	 $    1,961.50

Attend meeting3	12	 $   683.88 	18	 $     626.22 	 $    1,310.10

Post meeting, including notes4	0

28	 $     974.12 	 $       974.12

Total	22	 $ 1,253.78 	106	 $  3,687.74 	 $    4,941.52

Estimated Total 5	$ 5,000

Hours	128

Notes

1. Select date, research and select site, negotiate with site for use,
publicize meeting, set up room including electronics (microphones, sound
system, and presentation).

2. Prepare 30 minute presentation including consultation with health
experts and technical personnel as necessary, 30-50 slides, feedback
from management, practice presentation

3. Based on WASA, 1.5 hour open house, one hour presentation/Q&A, 15
minutes before and after, for a total of three hours, one senior
management, one technical staff

4. Prepare and review meeting transcript or notes, follow up with
attendees as appropriate

5. The estimated cost, $ 4,941.52, is rounded to the nearest thousand,
$5,000.00.

Appendix H-18. Cost for Activity F(b)(2)(vi) Delivery to Every
Household (4th Qtr 2006$)

System Size Category	Average Population Per System1	Persons Per
Household2	Delivery Cost Per Household3	Total Per System

CWS

25-100	46	2.57	$0.39 	$7

101-500	196	2.57	$0.39 	$30

501-3,300	1,091	2.57	$0.39 	$166

3.3K-10K	4,474	2.57	$0.25 	$435

10K-50K	16,840	2.57	$0.17 	$1,114

50K-100K	52,423	2.57	$0.12 	$2,448

>100K	248,896	2.57	$0.04 	$3,874

Notes

1. Data source: USEPA, Community Water System Survey 2000, EPA
815-R-02-005b, December 2002, Table 40. See Appendix H-5 for details.

2. Data source: US Census, Current Population Reports, America’s
Families and Living Arrangements: 2003, Table 1.

3. Assume delivery to every postal address either through mail or
distribution of flyers. Mailing costs would be $0.39 each. Assume
systems serving <3,300 people send notice through mail ($0.39 each).
Assume systems serving >3,300 people distribute flyers at a cost of
$0.25 per piece for systems serving 3,301 to 10,000 people; $0.17 per
piece for systems serving 10K to 50K; a $0.12 per piece for systems
serving 50K to 100K, and $0.04 for >100K (materials cost only, assumes
inclusion with existing mailing).

Appendix H-19. Cost for Activity F(b)(2)(vii) Targeted Contact  (4th
Qtr 2006$)

System Size Category	Average Population Per System 1	Upfront Cost For
List2	Pro-rated Upfront Cost	Number of Targeted Contacts3	Labor for
Production	Labor Costs for Production	Material Cost4	Total Cost

CWS

25-100	46	$250	$28	1	0.25	$6 	$0.44 	$34.18

101-500	196	$250	$28	1	0.25	$6 	$0.44 	$34.64

501-3,300	1,091	$250	$28	4	0.25	$7 	$1.92 	$36.58

3.3K-10K	4,474	$250	$28	18	0.25	$8 	$7.87 	$44.14

10K-50K	16,840	$250	$28	67	0.25	$9 	$29.64 	$66.06

50K-100K	52,423	$250	$28	210	0.52	$18 	$92.26 	$138.18

>100K	248,896	$250	$28	996	2.49	$98 	$438.06 	$563.48

Notes

1. Data source: USEPA, Community Water System Survey 2000, EPA
815-R-02-005b, December 2002, Table 40. See Appendix H-5 for details.

2. Assume $250 for purchase of targeted list.

3. Assume 1 targeted communication for every 250 population served
(based on Portland, OR targeted contact experience of approximately 2000
homes for a population served of 482,500).

4. Use $0.44 for unit materials and printing cost for letter, envelope
and postage.

Appendix H-20. Cost for Activity F(b)(2)(viii) Provide Materials
Directly to Multi-Family Homes and Institutions (4th Qtr 2006$)

System Size Category	Average Population Per System1	Multi-Family Per
100,0002	Number of Multi-Family Per System	Time to Identify Multi-Family
(Hrs)3	Upfront Labor Cost4	Pro-rated Upfront Labor Cost	Labor Burden for
Production	Labor Cost for Production	Material Cost5	Total Cost

CWS

25-100	46	4,035	2	0.17 	$4 	$0.44 	0.5	$12 	$0.08	$12

101-500	196	4,035	8	0.67 	$17 	$1.90 	0.5	$13 	$0.32	$15

501-3,300	1,091	4,035	44	3.67 	$101 	$11.22 	0.5	$14 	$1.76	$27

3.3K-10K	4,474	4,035	181	15.08 	$512 	$56.91 	0.5	$17 	$7.24	$81

10K-50K	16,840	4,035	679	56.58 	$1,957 	$217.47 	1.6975	$59 	$27.16	$303

50K-100K	52,423	4,035	2115	176.25 	$6,096 	$677.39 	5.2875	$183 	$84.60
$945

>100K	248,896	4,035	10043	836.92 	$32,832 	$3,648.03 	25.1075	$985
$401.72	$5,035

Notes:

1. Data source: USEPA, Community Water System Survey 2000, EPA
815-R-02-005b, December 2002, Table 40. See Appendix H-5 for details.

2. Data source: U.S. Census Housing Survey for buildings with more than
10 units each.

3. Assume five minutes per establishment to identify multi-family homes
and institutions.

4. Loaded wage rates from SAIC contract study, "Labor Costs for National
Drinking Water Rules (2003) updated to 4th Qtr 2006. Annual labor cost
equals hourly labor rate multiplied by annual burden.

5.  Assume a materials cost of $0.04 per notice.

Appendix H-21. III.F(c)(1) Customer Bills: Cost to Add Note to Customer
Bills for CWSs that Exceed the Lead Action Level (4th Qtr 2006$)

System Size Category	# Systems that Exceed Lead AL [1,2]	Annual System
Burden for Adding Notes to Customer Bills(hrs) [3]	Annual System Labor
Cost [4]	Annual System O&M Cost	Total Annual System Cost

CWS

25-100	185	555	$13,242	$0	$13,242

101-500	155	465	$11,951	$0	$11,951

501-3,300	133	399	$10,988	$0	$10,988

3.3K-10K	54	162	$5,501	$0	$5,501

10K-50K	40	120	$4,151	$0	$4,151

50K-100K	7	21	$726	$0	$726

>100K	7	21	$824	$0	$824

Total	581	1,743	$47,383	$0	$47,383

Notes:

1.  Additional customer notification requirements affect only CWSs that
exceed the lead action level.  For systems serving <3,300 people, the #
systems is based on SDWIS/Fed data for the monitoring period ending
after January 2003.(Data source: USEPA Survey of States - Questions on
State Implementation of Lead and Copper Rule. July 2004).

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

3. All CWS that exceed the lead action level need to include a note on
customer bills.  Assume all systems use quarterly billing. Current
requirements call for adding a note to one bill each year, so new burden
is adding a note to 3 bills each year per system.   Assume 1 hour per
billing period per system per year, which equals 3 hours per system per
year. No additional O&M costs.

4.  Loaded wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules (2003) updated to 4th Qtr 2006. Appendix
H-22. III.F(c)(2) Post on Website: Cost for Posting Notice on Website
for CWSs that Exceed the Lead Action Level and Serve >100,000 People
(4th Qtr 2006$)

System Size Category	# Systems that Exceed Lead AL [1,2]	Annual System
Burden for Posting on Website (hrs) [3]	Annual System Labor Cost [4]
Annual System O&M Cost	Total Annual System Costs

CWS

25-100	185	0	$0	$0	$0

101-500	155	0	$0	$0	$0

501-3,300	133	0	$0	$0	$0

3.3K-10K	54	0	$0	$0	$0

10K-50K	40	0	$0	$0	$0

50K-100K	7	0	$0	$0	$0

>100K	7	3.5	$137	$0	$137

Total	581	3.5	$137	$0	$137

Notes:

1.  Additional requirements affect only systems that exceed the lead
action level.  For systems serving <3,300 people, the # systems is based
on SDWIS/Fed data for the monitoring period ending after January 2003.
(Data source: USEPA Survey of States - Questions on State Implementation
of Lead and Copper Rule. July 2004).

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

3. CWSs that serve more than 100,000 people that exceed the lead action
level must post a notice on their website.  Assume burden of 0.5 hours
per system (source: ICR (PWSS ICR, 2040-0090, page B-6). No O&M costs.

4.  Loaded wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules (2003) updated to 4th Qtr 2006. Appendix
H-23. III.F(c)(3) Press Releases: Cost for Press Releases for CWSs that
Exceed the Lead Action Level (4th Qtr 2006$)

System Size Category	# Systems that Exceed Lead AL [1,2]	Annual System
Burden for Press Release (hrs) [3]	Annual System Labor Cost [4]	Annual
System O&M Cost [5]	Total Annual System Costs

CWS

25-100	185	0	$0	$0	$0

101-500	155	0	$0	$0	$0

501-3,300	133	0	$0	$0	$0

3.3K-10K	54	-54	-$1,834	-$232	-$2,066

10K-50K	40	-40	-$1,384	-$172	-$1,556

50K-100K	7	-7	-$242	-$30	-$272

>100K	7	-7	-$275	-$30	-$305

Total	581	-108	-$3,734	-$464	-$4,198

Notes

1.  Additional requirements affect only CWSs that exceed the lead action
level.  For systems serving <3,300 people, the # systems is based on
SDWIS/Fed data for the monitoring period ending after January 2003.(Data
source: USEPA Survey of States - Questions on State Implementation of
Lead and Copper Rule. July 2004).

2.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

3.  Systems serving more than 3,300 people that have exceeded the lead
action level have a reduced burden as compared to current requirements.
Current requirements are 2 public service announcements (PSAs) and 1
press release (PR) to 8 entities. New requirements are 2 PRs to 8
entities. Assume 1 hour of burden per system for each PSA or PR per 2004
ICR. Therefore, the burden for new requirements equals one less hour per
system as compared to current requirements.

4.  Loaded wage rates from SAIC contract study, "Labor Costs for
National Drinking Water Rules (2003) updated to 4th Qtr 2006.

5.  The reduced burden for annual system O&M cost equals the materials
and postage for 10 PSAs (5 to TV and 5 to radio stations) at $0.43 each
($0.39 postage, $0.01 paper and $0.03 envelope) for a total savings of
$4.30 per system.

Appendix H-24. III.F(e) CCR Statement: Cost to Add Statement to
Consumer Confidence Report for CWSs that Don’t Exceed the Lead Action
Level  (4th Qtr 2006$)

System Size Category	Total Number of CWSs [1]	# Systems that Exceed Lead
AL [2,3]	Additional Systems Affected by New Requirement [4]	Annual
System Burden to Add Statement to CCR (hrs) [5]	Annual System Labor Cost
Annual System O&M Cost	Total Annual System Costs

<100	13,766	185	13,581	3,395	$81,011	$0	$81,011

101-500	16,240	155	16,085	4,021	$103,346	$0	$103,346

501-3.3K	14,212	133	14,079	3,520	$96,934	$0	$96,934

3.3K-10K	4,707	54	4,653	1,163	$39,502	$0	$39,502

10K-50K	3,057	40	3,017	754	$26,090	$0	$26,090

50K-100K	484	7	477	119	$4,125	$0	$4,125

100K-500K	322	7	315	79	$3,089	$0	$3,089

500K-1M	32	 	32	8	$314	$0	$314

>1 M	18	 	18	5	$177	$0	$177

Total	52,838	581	52,257	13,064	$354,586	$0	$354,586

Notes:

1.  Number of CWS systems per SDWIS/FED Data 2004.

2.  For systems serving <3,300 people, the # systems is based on
SDWIS/Fed data for the monitoring period ending after January 2003.(Data
source: USEPA Survey of States - Questions on State Implementation of
Lead and Copper Rule. July 2004).

3.  For systems serving >3,300 people, the # systems is based on systems
that have exceeded the lead action level since 2003. data source:
www.epa.gov/safewater/lcrmr/lead-data.html, 8/30/05.

4. Under the new requirement, all systems will have to include an
informational statement in their CCR.

Currently, all systems whose 95th percentile sample is above the lead
action level include an informational statement in their CCR. The
estimated number of systems affected by this requirement are the total
number of systems affected by the LCR less the systems that exceed the
lead action level. These estimates are conservative because we are
including some systems that are already required to provide this
information in their CCR (systems whose 95 percentile sample exceeds the
lead action level).

5. Assume burden hours to add statement to Consumer Confidence Report
regarding lead issues will be 15 minutes per system, for all system
sizes.

Appendix H-25. Changes to State Burden for Review and Consultation
Activities (4th Qtr 2006$)

	Number of Affected States1	Net Change in State Burden (Hours)2,3,4,6
Labor Rate ($/hr)5	Total Labor Cost

Customer Notification Review	57	236	$43.52	$10,272

Review and Filing of Self-Certification Letter	57	58	$43.52	$2,529

Consultation on Activities	57	1,162	$43.52	$50,572

Total

1,456	 	$63,372

Notes:

1.  The LCR Regulatory Changes apply to 50 states, 6 territories and 1
Indian Tribe, for a total of 57 entities.

2.  States no longer have to approve changes for systems serving between
501 and 3,300 people.  Assume 0.5 hours savings for each of the 184
systems in this size category (Refer to Table 1 above). The total
reduction in burden equals 92 hours (184 * 0.5 hours).

3. For customer notification, States need to review additional language
for 994 systems that are estimated to exceed the LAL at an estimated 20
minutes per system. The total new burden to States equals 328 hours (994
systems * 0.33 hours).The net new burden to States equals 328 hours
minus 92 hours equals 236 hours.

4.  State labor rate of $43.52/hour (Source: Information Collection
Request for Contaminant Occurrence Data in Support of EPA's Second Six
Year Review of National Primary Drinking Water Regulations (2006)).

5. For consultation on activities, review of cover content, discussion
of alternative mechanisms, and discussion of extending deadlines, States
need to review activities with CWSs that exceed the LAL once per year at
2 hours per year.

6. For review and filing of letter from CWSs that exceed the LAL
self-certifying that additional PE activities have taken place, States
will require .10 hours per system per year, based on similar activity
for the CCR.

Appendix I

Uncertainty Analysis for III.F(b)(2) Activities

Uncertainty Analysis for Choosing Activities III.F(b)(2)(i)-(viii)

Due to the uncertainty in predicting the selection of activities (i)
through (viii) by systems to comply with Regulatory Change III.F(b)(2),
three alternative selection scenarios have been developed to illustrate
the potential range of costs.  The three scenarios represent predicted
activity selection based on different considerations:

Cost as the sole consideration

Cost as a primary consideration, with other factors as a secondary
considerations

Other factors as a primary consideration.

Cost as the sole consideration

	To simulate a situation in which cost minimization is the sole criteria
for choosing activities, this analysis assumes that systems will choose
the three least costly activities.  The average cost per system is
calculated as the average of the three least costly activities.  The
selection of activities and resulting average costs are presented in
Table I-1.

Table I-1: Activity Selection and Resulting Average Cost Per System:

Cost as Sole Consideration (4th Qtr 2006$)

System Size

Category	(i) Public Service Announcements	(ii) Paid Advertisements	(iii)
Display in Public Areas	(iv) Internet Notification	(v) Public Meetings
(vi) Delivery to Every Household	(vii) Targeted Contact	(viii) Materials
Directly

to Multi-Family & Institutions	Weighted Average Cost Per System

25-100	0%	0%	33%	0%	0%	33%	0%	33%	$14

101-500	0%	0%	33%	33%	0%	0%	0%	33%	$22

501-3,300	0%	0%	0%	33%	0%	0%	33%	33%	$30

3.3K-10K	0%	0%	0%	33%	0%	0%	33%	33%	$182

10K-50K	0%	0%	33%	0%	0%	0%	33%	33%	$355

50K-100K	0%	0%	0%	33%	0%	0%	33%	33%	$560

>100K	33%	0%	0%	33%	0%	0%	33%	0%	$999

	Although cost is an important consideration, it is not usually the sole
consideration.  Systems may choose more costly activities to reach a
broader range of audiences in a more effective manner.  To simulate a
situation in which cost is a primary , but not the sole, factor for
choosing activities, this analysis assumes that less costly activities
are more likely to be chosen and the more costly activities will be
chosen, but at a lower rate.  For each system size category, the
activities are characterized as “more likely”, “likely”, and
“unlikely” to be chosen based on the cost per system.  The two
lowest cost activities are classified as “more likely”, the two
highest cost activities are classified as “unlikely” and the middle
four activities are classified as “likely”.  To calculate a weighted
average cost per system given the activity choices, more likely
activities are assigned a probability of 25 percent (i.e., the activity
is chosen 25 percent of the time), likely activities are assigned a
probability of 10 percent, and the unlikely activities are assigned a
value of 5 percent.  The resulting selection of activities and weighted
average cost per system are presented in Table I-2.

Table I-2: Activity Selection and Resulting Average Cost Per System:

Cost as the Primary (but not sole) Consideration (4th Qtr 2006$)

System Size

Category	(i) Public Service Announcements	(ii) Paid Advertisements	(iii)
Display in Public Areas	(iv) Internet Notification	(v) Public Meetings
(vi) Delivery to Every Household	(vii) Targeted Contact	(viii) Materials
Directly

to Multi-Family & Institutions	Weighted Average Cost Per System

25-100	5%	5%	10%	10%	10%	25%	10%	25%	$28

101-500	5%	5%	10%	25%	10%	10%	10%	25%	$35

501-3,300	10%	5%	10%	25%	10%	5%	10%	25%	$62

3.3K-10K	10%	10%	10%	10%	5%	5%	25%	25%	$184

10K-50K	5%	10%	10%	10%	5%	10%	25%	25%	$608

50K-100K	10%	5%	10%	25%	5%	10%	25%	10%	$1,202

>100K	10%	5%	10%	25%	5%	10%	25%	10%	$2,325

	The third scenario reflects a best guess estimate of activity choices
if cost were not a factor.  The members of the NDWAC working group were
asked to rank the activities on a scale of 1-8, with 1 representing
activities most likely to be chosen and 8 for activities least likely to
be chosen within each system size category.  The NDWAC working group
members were not provided information on the cost per system, so their
responses reflect considerations other than cost.  Due to time
constraints, only a limited number of responses were received.  The
rankings were averaged across the responses, so that each activity had
an average ranking.  The activities with the two lowest average ranking
were characterized as most likely and assigned a probability of 25
percent.  The activities with the two highest average ranking were
considered unlikely and assigned a probability of 5 percent.  All other
activities were considered likely and assigned a probability of 10
percent.  The resulting activity choices and weighted average cost per
system are displayed in Table I-3.

Table I-3: Activity Selection and Resulting Average Cost Per System:

Other Factors as the Primary Consideration (4th Qtr 2006$)

System Size

Category	(i) Public Service Announcements	(ii) Paid Advertisements	(iii)
Display in Public Areas	(iv) Internet Notification	(v) Public Meetings
(vi) Delivery to Every Household	(vii) Targeted Contact	(viii) Materials
Directly

to Multi-Family & Institutions	Weighted Average Cost Per System

25-100	10%	5%	25%	5%	10%	25%	10%	10%	$33

101-500	10%	5%	25%	10%	10%	25%	5%	10%	$40

501-3,300	10%	5%	25%	10%	10%	25%	5%	10%	$101

3.3K-10K	10%	10%	25%	25%	5%	10%	5%	10%	$268

10K-50K	10%	25%	10%	25%	5%	10%	10%	5%	$824

50K-100K	10%	25%	10%	25%	5%	10%	10%	5%	$2,134

>100K	25%	25%	10%	10%	5%	10%	10%	5%	$3,043

	Table I-4 summarizes the weighted average cost per system for each
system size and for each of the three scenarios.  Across all system
sizes, the weighted average cost per system is lowest for the scenario
in which activities are chosen with cost as the only consideration and
highest when other factors are the primary consideration. Table I-4 also
displays the total costs for III.F(b)(2) for each scenario.  It should
be noted that the total cost under the highest of the three scenarios,
the other factors as the primary consideration scenario at $276,952 is
lower than the cost of III.F(b)(2) reported in the main section of the
Economic Analysis ($292,700) based on an un-weighted average of all
activities.  Thus, the costs reported in the Economic Analysis may
overstate actual costs that will be experienced.

Table I-4:  Summary of Average Cost Per System and Resulting Total Costs
(4th Qtr 2006$)

System Size	Weighted Average Cost Per System

	Cost as Sole Consideration	Cost as Primary Consideration	Other Factors
Primary Consideration

25-100	 $                14 	 $               28 	 $                33

101-500	 $                22 	 $               35 	 $                40

501-3,300	 $                30 	 $               62 	 $              101

3.3K-10K	 $               182 	 $              184 	 $              268

10K-50K	 $               355 	 $              608 	 $              824

50K-100K	 $               560 	 $           1,202 	 $           2,134

>100K	 $               999 	 $           2,325 	 $           3,043

Total Costs	 $        114,997 	 $       195,532 	 $        276,952

Appendix J

Derivation of Direct Costs for Regulatory Change III.A

Appendix J-1: Regulatory Change III.A One-Time System Reporting Cost
(4th Qtr 2006$)

11 States that Favor 1 Sample & Alaska	# NTNCWS By State [1]	% of
NTNCWS With <5 taps [2]	# NTNCWS With <5 taps	CWS Serving <100 By State
[1]	% of CWS<100 With <5 taps [6]	# of CWS <100 With <5 taps	Total
Systems with <5 Taps	One-Time System Burden for Verification Letters [3]
One Time System Labor Cost for Verification Letters [4]	One-Time System
O&M Costs for Verification Letters [5]	Total System One-Time Cost for
Verification Letters [5]

AK	N/A	N/A	N/A	341	5%	17	17	17	$472	$7	$479

IN	686	53%	364	317	5%	16	380	380	$10,551	$163	$10,714

MI	1631	53%	864	744	5%	37	901	901	$25,016	$387	$25,403

WI	907	53%	481	592	5%	30	511	511	$14,188	$220	$14,407

IL	405	53%	215	670	5%	34	249	249	$6,913	$107	$7,020

TX	785	53%	416	2105	5%	105	521	521	$14,465	$224	$14,689

VT	234	53%	124	319	5%	16	140	140	$3,887	$60	$3,947

UT	63	53%	33	241	5%	12	45	45	$1,249	$19	$1,269

WA	315	53%	167	1748	5%	87	254	254	$7,052	$109	$7,161

MD	573	53%	304	327	5%	16	320	320	$8,885	$138	$9,022

MN	563	53%	298	484	5%	24	322	322	$8,940	$138	$9,079

TN	46	53%	24	151	5%	8	32	32	$888	$14	$902

Total	6208	 	3290	8039	 	402	3692	3692	$102,507	$1,588	$104,094

Notes:

(1) Number of NTNCWSs and CWSs <100 in States derived from "SDWISFED
GPRA, summ inv, compl trends, FY96-04 FINAL" at
http://www.epa.gov/safewater/data/pivottables.html

(2) Percent of small systems with <5 taps from data supplied by MI in
comments to the draft LCRSTR.

(3) Assumes 1 hour per system to verify number of taps, prepare letter,
and submit to State

(4) Assumes average labor cost per hour for small systems of $27.76

(5) Assumes O&M cost equals $0.43 per letter ($0.39 postage, $0.01 paper
and $0.03 envelope).

(6) Assumes relatively rare occurrence of CWSs with fewer than 5 taps:
5% Appendix J-2: Regulatory Change III.A One-Time State Review Cost
(4th Qtr 2006$)

Number of Letters for State Review	One-Time Burden for State Review of
Verification Letters [1]	State Labor Cost to Review and Document Number
of Taps [2]	State O&M Costs to Mail Approval Letter	Total One-Time State
Costs

3692	3692	$160,681	$1,588	$162,269

Notes:

(1) Assumes 1 hour of State labor required to review and track letters
from NTNCWSs with <5 taps

(2) Assumes State labor costs of $43.52per hour.

Appendix K

Derivation of Revenue Estimates for Small Systems

Revenue Estimates of Community Water Systems Serving

10,000 or Fewer People

Contract No.  68-C-02-069

Work Assignment No.  4-09

Prepared for:

Mr. Brian Rourke, Work Assignment Manager

U.S. Environmental Protection Agency

Office of Ground Water and Drinking Water

1201 Constitution Ave, NW, EPA East

Washington, DC 20460-0003

Prepared by:

The Cadmus Group, Inc.

57 Water Street

Watertown, MA 02472

March 29, 2007

This document provides an estimate of community water system (CWS)
revenue for systems serving 10,000 or fewer people.  The estimates are
based on two sources of information:  EPA’s 2000 CWS Survey and the
2002 Census of Governments fielded by the Census Bureau.  CWS revenue
and municipal government revenue for publicly owned CWSs are combined to
provide an estimate of the total resources available to CWSs in the
10,000 or fewer population size category.

CWS revenue comes from three sources:

Water sales.  This revenue is generated by the sale of water to
customers and is usually based on a rate charged per unit of water sold.

Water-related revenue.  This revenue consists of transfers from
municipal government general funds, fees, penalties, or other charges
related to the provision of water, but not tied directly to the sale of
water.  Note:  Water sales and water-related revenue together are
referred to as “water revenue.”

Non-water revenue.  Systems also may have non-water revenue.  For
example, combined drinking water and wastewater systems may have revenue
from sewerage charges. These sources of revenue are excluded from this
analysis, with two important exceptions.  Ancillary systems – small
privately owned systems (generally, serving populations of 3,300 or
fewer people) that provide water as an essential part of another
business – will have revenue from their primary business and often do
not report any water revenue at all. Municipal governments may rely on
general revenue in addition to or in lieu of water revenue to finance
their systems.  In many cases, these sources of revenue are available to
systems to support their operations; therefore, they must be included to
fully account for the resources available to water systems.

Exhibit 1 reports revenue of systems by the source of revenue.  The
estimates are based on data from the 2000 Community Water System Survey
(CWSS) and the 2002 Census of Governments.  For each source, it reports
the average revenue for systems with that source of revenue in the first
column of numbers; in other words, it excludes systems with zero revenue
from that source.  The second column reports the number of systems in
the nation with that source of revenue.  The final column of numbers
reports the number of observations in the sample on which the estimates
are based.  (Because the exhibit excludes systems that report zero
revenue from each source, the revenue figures from each source cannot be
summed to reach the total.  See below for a more detailed explanation)

Exhibit 1:  Average Revenue of Community Water Systems Serving 10,000 or
fewer People by Source (Dollars are in 2006 Dollars)

Revenue Source	Average

Revenue	Number of

Systems	Obser-vations

Water Revenue	Water Sales Revenue	191,252	35,540	556

	Water-Related Revenue

	General Fund Transfers	61,519	1,401	27

		Other Water-Related Revenue	35,894	21,947	401

Total1	218,702	35,060	552

Non-water

Revenue

		Private Systems (Revenue of the Primary Business of Ancillary Systems)
5,843,880	6,951	58

		Public Systems (Municipal Government Revenue, Excluding Transfers from
the General Fund to the Water System)	2,068,030

Total Revenue1  	2,166,712

1.	While each row is based on the most accurate information available,
columns do not sum.  See the Basis of Estimate below for additional
information about this table.

Source:  EPA’s 2000 Community Water System Survey, questions 26 and
27.

US Census Bureau's 2002 Census of Governments (Volume 4, Number 4),
Table 13.

Many systems do not have each source of revenue.  Exhibit 2 reports the
percentage of systems that reported positive revenue from each revenue
source.  According to the CWSS, approximately 82 percent of systems
reported revenue from water sales.  Less than 3 percent reported
transfers from the general fund (the percentage is higher for publicly
owned systems), and 51 percent reported other water-related revenue.
Overall, 80 percent of systems reported revenue from water sales or
water related revenue.

Judging from the percentage of systems reporting, it would appear that
fewer systems reported positive water revenue than reported positive
water sales.  This apparent contradiction is due to different response
rates to the various revenue questions in the survey.  Some systems
reported water sales, but could not provide their water-related revenue.
 Total water revenue for these systems therefore was not available and
these systems are excluded from the estimate of the percentage of
systems reporting positive total water revenue.  Other systems reported
their total water revenue, but could not distinguish between water sales
and other water revenue.  They are included in the estimate of the
percentage of systems that reported positive water revenue but are not
included in any of the components.  If we limit the analysis to systems
that provided data on all revenue components, approximately 81 percent
of systems reported positive water revenue.  Less than 1 percent of
these systems reported zero water sales revenue.  (In other words, they
relied solely on water-related revenue.)

Exhibit 2: Percentage of Systems Reporting Positive Revenue, by Revenue
Source

Revenue Source	Percentage

of Systems

Water Revenue	Water Sales Revenue	81.8%

	Water Related Revenue

	General Fund Transfers	2.9%

		Other Water Related Revenue	51.0%

	Total	80.3%

Non-water Revenue

	Private Systems (Primary Business Revenue of Ancillary Systems)	15.9%

	Public Systems (Municipal Government Revenue, Excluding Transfers from
the General Fund to the Water System)	49.2%

1.	While each row is based on the most accurate information available,
columns do not sum.  See the Basis of Estimate below for additional
information about this table.

Source:  EPA’s 2000 Community Water System Survey, questions 26 and
27.

Approximately 20 percent of small systems do not charge directly for
water, either through water sales or water-related charges.  Among some
subclasses of systems, the percentage of systems that do not charge for
water is substantially higher.  For example, according to the CWSS, 92
percent of ancillary systems reported zero water revenue.  Systems
without water revenue may rely – directly or otherwise – on other
sources of revenue.

Sources of Data

The 2000 CWSS collects data on all three sources of revenue.  It asks
each system for water sales and water-related revenue.  The survey also
asks ancillary systems to report non-water related revenue because many
of these systems do not charge directly for water.  (The survey does not
ask for non-water revenue of other systems.)  Because so many ancillary
systems do not charge for water, estimates of the resources available to
these systems include survey data from their main source of revenue.

The 2000 CWSS collected data from 104 ancillary systems.  The response
rate on the question about non-water revenue was relatively low;
approximately 50 percent of these systems provided data on their
non-water revenue.  It is not clear whether this non-response introduces
bias into the estimate of non-water revenue of ancillary systems.  The
revenue reported also varies greatly.

While some of the ancillary systems are small water systems, often
mobile home parks, they also may be relatively large companies and their
water revenue may be a very small part of their total revenue.  Other
ancillary systems may have very limited revenue from their other
sources.  Mobile home parks, for example, may fund all their expenses
– water-related and other wise – from pad fees that may be quite
modest.  The estimates of non-water revenue of ancillary systems are
therefore not precise.

Approximately 6 percent of publicly owned systems serving 10,000 or
fewer people report zero water revenue in the survey; nearly half of
publicly owned systems serving 100 or fewer people report zero water
revenue.  For these systems to operate, they must have other sources of
revenue that are not included in the survey.  Even systems run as public
enterprise funds may have access to funds from the general fund of their
municipality.  Therefore, estimates of water revenue do not fully
describe the financial resources available to these systems.  To account
for this potential resource of publicly owned systems, therefore, data
from the US Census Bureau’s 2002 Census of Governments were used to
estimate total municipal revenue of cities and towns that provide water
to 10,000 or fewer people.  Non-water revenue of municipalities is the
difference between the total revenue of the municipality and the revenue
generated by its water system.  Many municipalities transfer money from
their general funds to their water systems.  To avoid double counting
these transfers, they are excluded from the estimate of municipal
non-water revenue and included as part of water revenue.

Basis of the Estimates

The 2000 CWSS sample is used to calculate the average water system
revenue estimates.  The estimates are weighted by the inverse of the
sampling probabilities, corrected for overall non-response.  Four
systems were dropped from the analysis because they were outliers
(resorts or other special cases).  If they had been included, the
revenue estimates would have been higher.

Not every system reported revenue from each source in the CWSS.  For
example, of the 610 systems that reported revenue from any source, 54
did not report positive water sales revenue.  These systems are excluded
from the calculation of average water sales revenue.  Therefore, total
revenue is not equal to the sum of revenue from each source.  Before we
can sum the components, we must account for systems that did not report
revenue from an individual revenue source.

Exhibit 3 summarizes how water revenues are calculated based on the
average revenue reported for each source and the percentage of systems
with each source of revenue.  (Details may not sum to the total due to
rounding.) The calculation can be divided into two parts.  The first
part is shown in lines A through I.  We sum the sources of revenue,
adjusting for systems that reported zero revenue from each source.  For
example, the average water sales revenue of systems with water sales is
$191,252 (line A).  Approximately 82 percent of systems reported
positive water sales (line B).  The average water sales revenue of all
systems, including those reporting zero water sales revenue, is
$156,538, or line A multiplied by line B.  This calculation is repeated
for general fund transfers (lines D through F) and other water-related
revenue (lines (G through I).  The sum of these products is $176,658,
and is shown in line J (i.e., the sum of lines C, F, and I).

The second part of the calculation is shown in lines J through N in
Exhibit 3.  We make three adjustments to the sum shown in line J.
First, many systems reported their water sales revenue but not the other
components of their water revenue; therefore, their total revenue is
unknown.  The water sales revenue of these systems ($1,363, on line K)
must be removed from the total in line J.  Second, some systems reported
total water revenue, but could not divide their revenue by source.  The
average revenue not associated with an individual source is $222 (line
L).  This must be added to the total on line J.  Finally, the
approximately 20 percent of systems that did not report water revenue
(or line M) must be removed to estimate the average water revenue of
systems with positive water revenue.  Line N reports the adjusted total
water revenue of systems with water revenue.

As we cannot distinguish between systems that did not respond to a
revenue question and systems who, in fact, have zero revenue to report,
we may be over-estimating the percentage of systems with no revenue for
any given revenue category.  Thus, in calculating the average revenue
for all small systems, we may be underestimating revenue by assuming
that a non-response equals a zero.

The non-water revenue of publicly owned systems is based on the Bureau
of the Census estimate of total revenue of municipalities with fewer
than 10,000 people.  Exhibit 4 shows how we estimate the non-water
system revenue of municipalities, net of transfers to water systems.

Exhibit 3:  Calculation of Average Water Revenue for Systems Serving
25-10,000 People

A	Average Water Sales Revenue of Systems Reporting Positive Water Sales
Revenue:	191,252

B	Percentage of Systems Reporting Positive Water Sales Revenue	81.8%

C	Average Water Sales Revenue (A*B)	156,538

D	Average Transfers from the General Fund of Systems Reporting Positive
General Fund Transfers:	61,519

E	Percentage of Systems Reporting Positive Water-Related Revenue that
Reported General Fund Transfers	2.9%

F	Average General Fund Revenue (D*E)	1,796

G	Average Other Water-Related Revenue of Systems Reporting Positive
Other Water-Related Revenue:	35,894

H	Percentage of Systems Reporting Positive Water-Related Revenue that
Reported Other Water-Related Revenue	51.0%

I	Average Other Water-Related Revenue (G*H)	18,323

J	Sum of Average Water Sales, General Fund Transfers, and Other
Water-Related Revenue (C+F+I)	176,658

K	Subtract Water Sales Revenue of Systems not Reporting Total System
Revenue	1,363

L	Add Reported Total Water Revenue not Associated with Any Source of
Revenue	222

M	Percentage of Systems not Reporting Positive Water Revenue	19.7%

N	Average System Revenue of Systems Reporting Positive Water Revenue
(J-K+L)/(1-M)	218,702

According to the 2002 Census of Governments, there were 16,745
municipalities (line P) with populations under 10,000 in 2002.  The
total revenue of these municipalities was $34,944,647,000 in 2002 (line
O).  Average revenue per municipality is line O divided by line P, or
$2,086,871 (line Q).  Based on the US Bureau of Labor Statistics,
Consumer Price Index, the cumulative change in consumer prices between
2002 and 2006 was 13.8 percent (line R). The inflation-adjusted estimate
is $2,375,157, shown in line S.  According to the CWSS, water-system
revenue of publicly owned systems was $307,127 (line T).  Municipal
non-water-system revenue is line S minus line T, or $2,068,030 (line U).

Total revenue is a weighted average of system revenue and non-system
revenue.  The calculation is shown in Exhibit 5.  We assume that
privately owned systems that provide water as an essential part of
another business have non-water revenue.  According to the CWSS, average
non-water revenue for systems that report it is $5,843,880 (Line X).
The CWSS reports that 16.3 percent of systems have this non-water
revenue (line Y).  Average non-water system revenue, including systems
with no revenue from this source, is the product of line W and X, or
$953,489 (line Z).

Exhibit 4:  Calculation of Non-water System General Fund Revenue

of Publicly Owned Systems

O	Total General Revenue for Municipalities with fewer than 10,000 people
34,944,647,000

P	Number of Municipalities	16,745

Q	Average Revenue per Municipality (O/P)	2,086,871

R	Change in Consumer Price Index, 2002-2006	13.8%

S	Inflation-Adjusted Revenue per Municipality [Q*(1+R)]	2,375,157

T	Water System Revenue of Publicly Owned Systems	307,127

U	Municipal Revenue, Excluding Water System Revenue and Transfers to the
Water System (S-T)	2,068,030

While publicly owned systems do not have this source of revenue, they do
have access to general fund revenue of their municipalities.
Non-water-related revenue of municipalities is $2,068,030 (line AA).
According to the CWSS, 49.2 percent of systems serving 10,000 or fewer
people are publicly owned (line AB).  Average municipal revenue,
including systems with no revenue from this source, is $1,017,332 (line
AC).  Total revenue is the sum of water revenue (line W) and the two
sources of non-water revenue (lines Z and AC), or $2,166,712.

Conclusions

The average revenue available to small systems serving 10,000 or fewer
people is $2,166,712.  This estimate includes revenue from all sources.
This estimate includes non-water business and government revenue that
will be used for purposes other than financing the operations of the
water system.  But it provides the best estimate of the financial
situation of these water systems.

Exhibit 5:  Calculation of Total Revenue

W	Water Revenue  (line N from Exhibit 3)	218,702

X	Average Non-water Revenue of Private Systems Reporting Positive
Non-Water Revenue	5,843,880

Y	Percentage of Systems Reporting Positive Non-water Revenue	15.9%

Z	Average Non-water Revenue (W*Y)	930,679

AA	Municipal Revenue, Excluding Water System Revenue and Transfers to
the Water System (Line U from Exhibit 4)	2,068,030

AB	Percentage of Systems that are Publicly Owned	49.2%

AC	Average Municipal Revenue (AA*AB)	1,017,332

AD	Total Revenue (W+Z+AC)	2,166,712

Efforts to estimate the resources available to small water systems are
complicated by several factors.  First, there are few sources of data on
small systems.  The CWSS is one of the only surveys to systematically
collect data on small system finance.  Its focus is system operations
and finance, so it does not collect information about non-water system
finance that would inform this analysis.  The Census of Government data
fill some of the gaps and help portray a complete picture of small
system finance.

Second, small systems are a relatively diverse group that finances its
operations many different ways.  Some charge directly for water, but
many do not.  For example, a homeowners’ association may provide water
as one of its services, but it may not charge its members a separate
water fee; rather, it pays its water-related expenses out of general
fees its charges its members.  A small town may pay for water services
out of general fund revenue and not charge its residents for water.  The
water revenue, as we define it, is in fact zero in both cases.  But both
the homeowners’ association and the small town have resources to pay
for repairs and improvements to their water system.  Other demands are
placed on these resources, so further analysis is required to determine
whether those resources are sufficient to meet the needs of the water
system.

Finally, the data that are available on small system finances are often
incomplete.  This is due, in part, to the relative complexity of small
system finance.  Systems may not respond to financial questions because
it is difficult to distinguish water- from non-water-revenue.  As shown
in Exhibit 2, some systems provided data on some sources of revenue but
not others.  To produce the best estimates, we use all the data
available for each question rather than limiting the analysis to only
those systems that answered all the questions.  These estimates provide
the best estimates available of the resources available to small
systems.

References

US Bureau of Labor Statistics, Consumer Price Index, series CUUR0000SA0,
accessed at   HYPERLINK "http://data.bls.gov/cgi-bin/surveymost on
3/15/07"  http://data.bls.gov/cgi-bin/surveymost on 3/15/07 .

US Census Bureau, 2002 Census of Governments (Volume 4, Number 4), Table
13, accessed at   HYPERLINK "http://www.census.gov/govs/www/cog2002.html
on 7/16/06"  http://www.census.gov/govs/www/cog2002.html on 7/16/06 .

US Environment Protection Agency, 2000 Community Water System Survey,
questions 26 and 27, estimated using sample data.

Appendix L

Summary of Differences Between the Proposed and Final Rule

Appendix L-1: Summary of Differences Between the Proposed and Final
Rule

(Differences Are Highlighted)

Provision	July 2006 Proposed Revisions	Final Rule Revisions

A. Minimum # of Samples Required	Clarifies the minimum number of samples
requirement (five).	Clarifies the minimum number of samples requirement
(five).  Allows State discretion to allow PWS to sample 100 percent of
taps if there are fewer than five taps that can be used for human
consumption in the system.

B. Definitions for Compliance and Monitoring Periods	Clarifies that
“compliance period” is a 3-year calendar year period as defined in
141.2.

“Monitoring period” is specific period in which a water system must
provide required monitoring (e.g., June – September).

Also will define more precisely when the “start date” for compliance
calendar and actions occur.

Systems on triennial monitoring must monitor once every 3 calendar
years.	Clarifies that “compliance period” is a 3-year calendar year
period as defined in 141.2.

“Monitoring period” is specific period in which a water system must
provide required monitoring (e.g., June – September).

Also will define more precisely when the “start date” for compliance
calendar and actions occur.  States have discretion to extend deadlines
for completing public education activities.

Systems on triennial monitoring must monitor once every 3 calendar
years.

C. Reduced Monitoring Criteria	Systems that meet water quality
parameters must also meet the Lead Action Level, but not necessarily the
Copper Action Level to go to reduced monitoring.

Copper will be dealt with during next set of revisions.	Systems that
meet water quality parameters must also meet the Lead Action Level, but
not necessarily the Copper Action Level to go to reduced monitoring.

Copper will be dealt with during next set of revisions.

D. Advanced Notification and Approval for Treatment Changes	Systems must
provide notice of change or source addition in advance and the State
must approve the change.	Systems must provide notice of long-term change
or source addition in advance and the State must approve the change.

E. Consumer Notice of Lead Tap Results	Systems must notify consumers who
occupy homes or buildings tested with results.	Systems must notify
consumers who occupy homes or buildings tested with results.

Provision	July 2006 Proposed Revisions	Final Rule Revisions

F. Public Education Requirements	Content – shortened introductory
statement and flexibility on body of statement, changed health effects
language.

Delivery – Add licensed child care centers, preschools, Ob-Gyns, and
midwives to list of organizations.  Include a cover letter

-Systems directly contact local health agencies by phone or in person

- Additional activities: >3,300 pick 3, <3,300 pick 1: public service
announcements, paid ads, information displays in public areas, using
internet or email, public mtgs, delivery to every household, individual
contact with customers, materials to multi-family homes and
institutions, other methods approved by State

-Systems exceeding Lead Action Level must: include information on water
bill as long as they have the exceedance; must post public education
material on website if they serve >100,000; issue 2 press releases per
year.  No public service announcements required

Timeframe – systems must deliver most public education materials
within 60 days after end of monitoring period in which exceedance
occurred.  Flexibility for State to allow longer for completion of water
bill delivery and selected additional activities

CCR – all CWS that detect lead must include informational statement.
NDWAC recommended changes to statement language.	Content – shortened
introductory statement and flexibility on body of statement, changed
health effects language.

Delivery – Add licensed child care centers, preschools, Ob-Gyns, and
midwives to list of organizations.  Include an informational notice

-Systems directly contact local health agencies by phone or in person

- Additional activities: >3,300 pick 3, <3,300 pick 1: public service
announcements, paid ads, information displays in public areas, using
internet or email, public mtgs, delivery to every household, individual
contact with customers, materials to multi-family homes and
institutions, other methods approved by State

-Systems exceeding Lead Action Level must: include information on water
bill as long as they have the exceedance; must post public education
material on website if they serve >100,000; issue 2 press releases per
year.  No public service announcements required

Timeframe – systems must deliver most public education materials
within 60 days after end of monitoring period in which exceedance
occurred.  Flexibility for State to allow longer for completion of all
activities

CCR – all CWS must include informational statement.  NDWAC recommended
changes to statement language.

G. Reevaluation of Lead Service Lines Deemed Replaced Through Testing
Applies to a system that (1) exceeds the action level, (2) tests out one
or more service lines, (3) brings lead levels below the action level for
two consecutive 6-month monitoring periods and discontinues replacing
lead service lines, and (4) later exceeds the action level again. That
system would have to reinitiate lead service line replacement
considering all lead service lines including those that had previously
tested out of the replacement program.	Applies to a system that (1)
exceeds the action level, (2) tests out one or more service lines, (3)
brings lead levels below the action level for two consecutive 6-month
monitoring periods and discontinues replacing lead service lines, and
(4) later exceeds the action level again. That system would have to
reinitiate lead service line replacement considering all lead service
lines including those that had previously tested out of the replacement
program.  Provision added for State discretion when systems have already
completed a 15-year replacement program.

H. Other Issues Related to LCR

Plumbing Component Replacement	Specifically define plumbing component
replacement as corrosion control treatment when 100% of plumbing
fittings and fixtures are directly controlled by the system.	No
revisions made.  Current rule provides flexibility for systems to
implement.

POU and POE Treatment	Specifically define POU/POE as corrosion control
treatment when 100% of taps are directly controlled by the system.	No
revisions made. Current rule provides flexibility for systems to
implement.

Site Selection in Areas with Water Softeners and POU	Allow lead and
copper tap samples at taps with POU/POE under certain conditions	No
revisions made. Monitoring issues will be dealt with during next set of
revisions.

Water Quality Parameter Monitoring	Synchronize water quality parameter
sampling with lead and copper sampling.	No revisions made. Monitoring
issues will be dealt with during next set of revisions.

 http://www.dcwasa.com/about/gen_overview.cfm

 ADMINISTRATIVE ORDER FOR COMPLIANCE ON CONSENT Docket No.
SDWA-03-2004-0259DS

 ADMINISTRATIVE ORDER FOR COMPLIANCE ON CONSENT Docket No.
SDWA-03-2004-0259DS

 DC WASA, 2004 DRINKING WATER QUALITY REPORT

 Forensic Analysis of Elevated Lead Levels in District of Columbia Water
and Sewer Authority Drinking Water: Task 5 Data Summary (Draft),
Prepared by HDR/EES, June 1, 2005

 Based on system inventory from 2nd Quarter 2005 SDWIS data pull.

	   HYPERLINK http://www.epa.gov/safewater/lcrmr/lead_data.html
http://www.epa.gov/safewater/lcrmr/lead_data.html  and Summary Lead
Action Level exceedances for medium (3,300-50,000) and large (>50,000)
public water systems (Updated as of June 1, 2004)

	 http://www.epa.gov/safewater/lcrmr/reductionplan_comparison.html

 Source: USEPA, State Responses to EPA Survey on State Implementation,
November 2005.

 Source: Drinking Water Lead Reduction Plan, EPA 810-F-05-001, March
2005, http://www.epa.gov/safewater/lcrmr/reductionplan_fs.html.

 70 FR 54375, US EPA, 2005.

 Lead and Copper Rule State File Review: National Report, EPA, March
2006

 Summary from Public Education Workshop, US EPA, 2004.

 http://www.epa.gov/safewater/data/pdfs/data_factoids_2004.pdf

 System inventory data from the 4th Quarter SDWIS/FED data pull is used
throughout the analysis to maintain consistency with data on the number
of systems exceeding the Lead Action Level collected during that time
period.

 System inventory data from the 4th Quarter SDWIS/FED data pull is used
throughout the analysis to maintain consistency with data on the number
of systems exceeding the Lead Action Level collected during that time
period.

 Updated data on the number of systems that have exceeded the Lead AL
are not available for use in the EA supporting the Final Rule.  Thus we
assume that this data reflects the current annual number of systems
exceeding the Lead AL and use 4th quarter 2004 SDWIS inventory data to
maintain consistency.

  USEPA Survey of States - Questions on State Implementation of Lead and
Copper Rule. July 2004.

 USEPA Survey of States - Questions on State Implementation of Lead and
Copper Rule. July 2004.

 Source: Information Collection Request: Disinfectants/Disinfection
Byproducts, Chemical, and Radionuclides Rules, USEPA, Office of Water,
September 2004, page H-27.

 Source: Information Collection Request: Disinfectants/Disinfection
Byproducts, Chemical, and Radionuclides Rules, USEPA, Office of Water,
September 2004, page H-12.

 USEPA Survey of States - Questions on State Implementation of Lead and
Copper Rule. July 2004.

  USEPA Survey of States - Questions on State Implementation of Lead and
Copper Rule. July 2004.

  EPA, Public Water System Supervision Information Collection Request,
July 2004, Exhibit E.16, page E-15.

 M. Cubed for the National Child Care Association, The National Economic
Impacts of the Child Care Sector, Fall 2002, page 4.

 U.S. Census Bureau, U.S. Summary: 2000 (Census 2000 Profile), July
2002, http://www.census.gov/prod/2002pubs/c2kprof00-us.pdf.

 U.S. Census Bureau, Statistical Abstract of the United States: 2006,
Table 152, page 113.
http://www.census.gov/prod/2005pubs/06statab/health.pdf

 USEPA, Public Water System Supervision Information Collection Request,
July 2004, page B-6.

 USEPA Survey of States - Questions on State Implementation of Lead and
Copper Rule. July 2004.

 Source: Notes from the EPA Lead Service Line Replacement Workshop,
December 10, 2004,
http://www.epa.gov/safewater/lcrmr/pdfs/summary_lcmr_review_lead_line_re
placement_workshop_10-26-04.pdf

 Source: Lead Service Line Replacement Program Annual Report for 2003,
District of Columbia Water and Sewer Authority, September 2003.

  Source: Information Collection Request: National Primary Drinking
Water Regulations For Lead and Copper, USEPA, Office of Water, June
1999, page A-B-1.

 Source: Economic Analysis for the Filter Backwash Recycling Rule,
USEPA, Office of Water, EPA 816-R-01-20, July 2001, Appendix E-4.

  Source: Final Regulatory Impact Analysis of National Primary Drinking
Water Regulations for Lead and Copper, USEPA, Office of Drinking Water,
April 1991, page 1-4.

  The Bureau of Labor Statistics has discontinued calculating the
Employment Cost Index by SIC code classifications (electric, gas and
sanitary services).  The comparable NAICS classification is for
utilities.  Also, BLS changed the base year for calculating the index
(Dec 2005 = 1.00).  The change in series classification and index year
does not result in an appreciable difference in the updating.  For
example, the update factor from 2001 to 2003 used in the exhibit is 1.07
either using SIC or NAICS for the time period.

 Source: Lead and Copper Monitoring and Reporting Guidance for Public
Water Systems, USEPA, Office of Water, EPA-816-R-02-009, February 2002.

  Source: Final Regulatory Impact Analysis of National Primary Drinking
Water Regulations for Lead and Copper, USEPA, Office of Drinking Water,
April 1991, page 4-9.

  Source: Information Collection Request: National Primary Drinking
Water Regulations For Lead and Copper, USEPA, Office of Water, June
1999, page A-3.

  Source: Information Collection Request: Disinfectants/Disinfection
Byproducts, Chemical, and Radionuclides Rules, USEPA, Office of Water,
September 2004, page H-43.

 Updated using the CPI for 1999 to Dec 2006 (201.8/166.6=1.211)

  Source: Labor Costs for National Drinking Water Rules, SAIC, October
24, 2003, updated.

  Source: Information Collection Request: National Primary Drinking
Water Regulations For Lead and Copper, USEPA, Office of Water, June
1999, page A-11.

  Source: Information Collection Request: Disinfectants/Disinfection
Byproducts, Chemical, and Radionuclides Rules, USEPA, Office of Water,
September 2004, page H-27.

 Source: Information Collection Request: National Primary Drinking Water
Regulations For Lead and Copper, USEPA, Office of Water, June 1999, page
A-11.

  Source: Information Collection Request: Disinfectants/Disinfection
Byproducts, Chemical, and Radionuclides Rules, USEPA, Office of Water,
September 2004, page H-27.

 An estimate of the number of systems that may change treatment due to
the Ground Water Rule is not publicly available with sufficient
certainty at this time.

 Rogers, Everett, Diffusion of Innovation, Free Press; 4th edition
(February 1, 1995).

  Source: Information Collection Request: National Primary Drinking
Water Regulations For Lead and Copper, USEPA, Office of Water, June
1999, page A-7.

  Source: Information Collection Request: Disinfectants/Disinfection
Byproducts, Chemical, and Radionuclides Rules, USEPA, Office of Water,
September 2004, page H-2.

 Updated using the CPI for 1999 to Dec 2006 (201.8/166.6=1.211)

  Source: Labor Costs for National Drinking Water Rules, SAIC, October
24, 2003, updated.

 Community water system means a public water system which serves at
least 15 service connections used by year round residents or regularly
serves at least 25 year-round residents.

DRAFT

March 28, 2007

DRAFT

March 30, 2007

Page   PAGE  88

Page   PAGE  71

Page   PAGE  78

Appendix A-

Appendix A-  PAGE  2

Appendix A-  PAGE  2

Appendix B-  PAGE  2

Appendix B-  PAGE  2

Appendix B-  PAGE  2

Appendix C-  PAGE  12

Appendix C-  PAGE  11

Appendix D-  PAGE  6

Appendix D-  PAGE  7

Appendix E-  PAGE  14

Appendix E-  PAGE  9

Page   PAGE  2

Appendix F-  PAGE  1

Appendix F-  PAGE  6

Appendix F-  PAGE  7

Appendix G-  PAGE  2

Appendix G-  PAGE  3

Page   PAGE  2

Appendix H-  PAGE  6

Appendix H-  PAGE  26

Appendix H-  PAGE  14

Appendix H-  PAGE  26

Appendix I-  PAGE  4

Appendix J-   PAGE  2

Appendix J-   PAGE  2

Appendix K-   PAGE  5

Appendix L-   PAGE  3


[Federal Register Volume 77, Number 50 (Wednesday, March 14, 2012)]
[Notices]
[Pages 15167-15169]
[FR Doc No: 2012-6183]

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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-66540; File No. SR-NASDAQ-2012-031]

Self-Regulatory Organizations; The NASDAQ Stock Market LLC;
Notice of Filing and Immediate Effectiveness of Proposed Rule Change
Relating to Supplemental Orders

March 8, 2012.
    Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that
on February 27, 2012, The NASDAQ Stock Market LLC (``NASDAQ'' or
``Exchange'') filed with the Securities and Exchange Commission
(``Commission'') the proposed rule change as described in Items I, II,
and III below, which Items have been prepared by the Exchange. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
---------------------------------------------------------------------------

    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------

I. Self-Regulatory Organization's Statement of the Terms of the
Substance of the Proposed Rule Change

    The Exchange proposes to introduce the ``Supplemental Order'' for
use on NASDAQ. The text of the proposed rule change is available on the
Exchange's Web site at http://nasdaq.cchwallstreet.com, at the
principal office of the Exchange, and at the Commission's Public
Reference Room.

II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change

    In its filing with the Commission, the Exchange included statements
concerning the purpose of and basis for the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. The Exchange has prepared summaries, set forth in
sections A, B, and C below, of the most significant aspects of such
statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change

1. Purpose
    NASDAQ proposes to introduce a new order type, to be known as the
``Supplemental Order,'' for use on NASDAQ. The order type and its
associated execution process are virtually identical to the ``Tracking
Order'' and ``Tracking Order Process'' that have long been in use at
NYSEArca.\3\ The purpose of the order is to offer institutional
investors and other traders that have longer trading horizons a means
to post stable trading interest executable at the national best bid or
best offer (``NBBO''). The Exchange believes that if the Supplemental
Order becomes widely used, market participants seeking to access
liquidity will more readily direct their orders to NASDAQ, because they
will have a heightened expectation of the availability of liquidity at
the NBBO.
---------------------------------------------------------------------------

    \3\ See NYSEArca Rules 7.31(f) and 7.37(c).
---------------------------------------------------------------------------

    Supplemental Orders are Non-Displayed limit orders that are
available for execution only between 9:30 a.m. and 4 p.m., and that are
not eligible for participation in the Nasdaq Opening Cross, the Nasdaq
Halt Cross, the Nasdaq Imbalance Cross, or the Nasdaq Closing Cross.
All Supplemental Orders must be entered with size of one or more normal
units of trading. Upon entry in the Nasdaq Market Center system, a
Supplemental Order will always post to the book and thereafter become
eligible for execution against incoming orders in accordance with the
Nasdaq Market Center's Supplemental Process.
    An incoming order that has been designated as eligible for routing
may interact with Supplemental Orders.\4\ Such an order will first be
matched against orders other than Supplemental Orders in accordance
with Rule 4757(a)(1)(A) through (C). If any of the order remains
unexecuted, it will enter the Supplemental Process before being routed
to other venues. In the process, the order will be matched against
Supplemental Order(s) in price/time priority. However, executions will
be permitted to occur only at the NBBO, and only if the size of the
incoming order is less than or equal to the aggregate size of
Supplemental Order interest available at the price of the order. A
Supplemental Order may not trade through a Protected Quotation, and
will not be permitted to execute if the NBBO is locked or crossed.
---------------------------------------------------------------------------

    \4\ Orders that are not designated for routing are not
executable against Supplemental Orders, because market participants
entering non-routable orders either expect to post liquidity on
NASDAQ, or seek to execute against the NASDAQ displayed quote, as
through an Immediate or Cancel order type. By contrast, the
Supplemental Order is designed to interact with market participants
that seek to access liquidity at the NBBO, and that employ routable
orders to access such liquidity at a range of trading venues.
---------------------------------------------------------------------------

    Supplemental Orders post to the book, rather than interacting with
resting orders before posting, because the market participant entering
a Supplemental Order is willing to cede execution priority in order to
provide liquidity to those orders that are eligible to enter into the
Supplement Order process (i.e., orders that seek to access liquidity at
the NBBO). NYSEArca Tracking Orders are similarly designed to post to
the book in all circumstances.
    If a Supplemental Order is not executed in full, the remaining
portion of the order shall continue to repost in the Supplemental
Process until the order is fully executed, the order is cancelled by
the member that entered the order, or the size of the order is reduced
to less than one normal unit of trading (in which case the remaining
order will be cancelled by the System). Supplemental Orders may be
entered at any time between 7 a.m. and 4 p.m., but are available for
potential execution only between 9:30 a.m. and 4 p.m. Any Supplemental
Orders still on the book after 4 p.m. will be cancelled.
    In addition to adding descriptions of the Supplemental Order and
its associated execution process to Rules 4751 and 4757, NASDAQ is also
proposing to make conforming changes to Rule 4755, and to correct
several minor typographical errors in Rule 4757.
2. Statutory Basis
    NASDAQ believes that the proposed rule change is consistent with
the provisions of Section 6 of the Act,\5\ in general, and with Section
6(b)(5) of the Act,\6\ in particular, in that the proposal is designed
to prevent fraudulent and manipulative acts and practices, to promote
just and equitable principles of trade, to foster cooperation and
coordination with persons engaged in regulating, clearing, settling,
processing information with respect to, and facilitating transactions
in securities, to remove impediments to and perfect the mechanism of a
free and open market and a national market system, and, in general, to
protect investors and the public interest. Specifically, NASDAQ
believes that the proposed rule change will promote the interests of
retail and institutional investors and other investors with longer term
trading horizons by (i) offering liquidity providers a means to use
NASDAQ to post larger limit orders that are only executable at the NBBO
and that do not disclose their trading interest to other market
participants in advance of execution, and (ii) offering market
participants seeking to access liquidity a greater expectation of
market depth at the NBBO than may currently be the case.
---------------------------------------------------------------------------

    \5\ 15 U.S.C. 78f.
    \6\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------

B. Self-Regulatory Organization's Statement on Burden on Competition

    NASDAQ does not believe that the proposed rule change will result
in any burden on competition that is not necessary or appropriate in
furtherance of the purposes of the Act, as amended. The proposed change
will allow NASDAQ to offer functionality that is similar to
functionality already offered by NYSEArca, and will therefore promote
competition between exchanges.

C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants or Others

    No written comments were either solicited or received.

III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action

    The proposed rule change is effective upon filing pursuant to
Section 19(b)(3)(A) of the Act \7\ and paragraph (f)(6) of Rule 19b-4
thereunder,\8\ in that the proposed rule change: (i) Does not
significantly affect the protection of investors or the public
interest; (ii) does not impose any significant burden on competition;
and (iii) does not become operative for 30 days after the date of the
filing, or such shorter time as the Commission may designate if
consistent with the protection of investors and the public interest;
provided the self-regulatory organization has given the Commission
written notice of its intent to file the proposed rule change, along
with a brief description and text of the proposed rule change, at least
five business days prior to the date of filing of the proposed rule
change, or such shorter time as designated by the Commission. NASDAQ
provided the Commission with such written notice on February 8, 2012.
NASDAQ proposes to implement the proposed rule change on a date that is
on, or shortly after, the 30th day following the date of the filing.

NASDAQ believes that the proposed rule change does not significantly
affect the protection of investors or the public interest, and does not
impose any significant burden on competition because (i) the proposal
seeks to enhance market quality by providing a means to encourage
market participants to offer greater liquidity at the NBBO, and (ii)
the proposal enhances NASDAQ's ability to compete with comparable
functionality that is already being offered by NYSEArca.
---------------------------------------------------------------------------

    \7\ 15 U.S.C. 78s(b)(3)(A).
    \8\ 17 CFR 240.19b-4(f)(6).
---------------------------------------------------------------------------

    At any time within 60 days of the filing of the proposed rule
change, the Commission summarily may temporarily suspend such rule
change if it appears to the Commission that such action is necessary or
appropriate in the public interest, for the protection of investors, or
otherwise in furtherance of the purposes of the Act. If the Commission
takes such action, the Commission shall institute proceedings to
determine whether the proposed rule should be approved or disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:

Electronic Comments

     Use the Commission's Internet comment form (http://www.sec.gov/rules/sro.shtml); or
     Send an email to<EMAIL_ADDRESS>Please include
File Number SR-NASDAQ-2012-031 on the subject line.

Paper Comments

     Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F Street NE.,
Washington, DC 20549-1090.

All submissions should refer to File Number SR-NASDAQ-2012-031. This
file number should be included on the subject line if email is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (http://www.sec.gov/rules/sro/shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official business days between the hours of 10
a.m. and 3 p.m. Copies of such filing also will be available for
inspection and copying at the principal office of the Exchange. All
comments received will be posted without change; the Commission does
not edit personal identifying information from submissions. You should
submit only information that you wish to make available publicly. All
submissions should refer to File No. SR-NASDAQ-2012-031 and should be
submitted on or before April 4, 2012.

    For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\9\
---------------------------------------------------------------------------

    \9\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-6183 Filed 3-13-12; 8:45 am]
BILLING CODE 8011-01-P