Filter Adoption Survey
(EPA ICR No. 2615.02, OMB Control No. 2008-0003)
“Filter Adoption Survey (Renewal)” EPA ICR Number: 2615.02; OMB Control Number: 2008-0003
Under Section 1415(a)(3) of the Safe Drinking Water Act, on December 16, 2019, the U.S. EPA granted Denver Water, a public water system, a variance (2019 Variance) from the definition of “optimal corrosion control treatment” in 40 C.F.R. 141.2. On November 30, 2022, a new variance (2022 Variance) was issued in order to allow the variance conditions to be extended. Per the Variance, to determine the efficacy of the filter program, Denver Water will conduct the “Filter Adoption Survey” every other year to determine the consumer filter adoption rate and assess whether consumers are properly using and maintaining the filters. Only one survey will be conducted (in 2025) for this three-year renewal period.
The Safe Drinking Water Act (SDWA) Section 1415(a)(3) gives the EPA the authority to issue a variance from a treatment technique requirement upon showing that an alternative is “at least as efficient” in lowering the level of the contaminant with respect to which such requirement was prescribed [in this case, optimal corrosion control treatment, OCCT].” In the 2019 Variance, the survey was a key component in statistically evaluating the lead reduction program’s (LRP) equivalency. Under the new variance, the survey will be conducted every other year to reduce survey fatigue and compensate for a smaller participant pool (as a result of lead service lines being removed).
EPA will use the survey results that Denver Water distributes every other year (2025) to determine the consumer filter adoption rate and to confirm whether customers are using and maintaining the filters correctly.
The information to be obtained under this ICR has been collected in the first three years of the 2019 Variance (EPA ICR # 2615.01) but has not been collected by the EPA, any other federal agency, or Denver Water previously.
The EPA publicly noticed this ICR in the Federal Register which was published on February 17, 2023. No comments were received in response to this notice.
The EPA has been in continuous contact with Denver Water and other interested parties on the subject of the 2019 and 2022 variances and their associated surveys.
The Variance requires that Denver Water conduct the survey every other year beginning in 2023. Therefore, after the 2023 survey, Denver Water must conduct another survey in 2025. The survey conducted under the 2019 Variance showed consistent results after annual surveys for three years. So, to avoid survey fatigue, it was determined that the 2022 Variance would reduce the survey frequency to a biennial basis. The filter adoption survey is related to other components of the Variance such as lead service line removal and education, communication, and outreach efforts, among other components.
None of the collection activities described within this trigger or exceed the conditions cited at 5 CFR 1320.5(d)(2) as requiring special justification.
EPA will receive summarized information from the surveys in Denver Water’s 2025 annual report. Denver Water will submit the report to the EPA through encrypted emails that will be opened only on a secured network. EPA will store the report on restricted drives.
The survey results may contain sensitive information in the form of customer IDs that are used to identify specific households. These are included to assist Denver Water should it need to provide specific communications, outreach, or educational information to specific households based upon their filter adoption survey results. Additionally, the survey includes optional sensitive questions related to race, gender, age, education, income, and primary languages spoken in the household. This information will inform Denver Water, CDPHE, and the EPA of the filter adoption rate by neighborhood or demographic group so Denver Water’s health equity and environmental justice principles set forth in their variance request can be evaluated. Denver Water will utilize this information to help inform future decisions pertaining to lead service line removal schedules and to improve its communication, education, and outreach efforts aimed at vulnerable populations at greatest risk from lead exposure. For example, as Denver Water’s variance submittal notes, if certain geographic areas or demographic groups are not responding to the survey, then Denver Water would carry out additional communication, outreach, and education activities to understand the issue and improve survey responses. This information will also help ensure Denver Water’s follow-up efforts are linguistically and culturally appropriate for the communities targeted.
Eligible respondents for the survey are individuals 18 years of age or older who are customers of the water system that Denver Water owns and operates (as well as integrated systems as referenced in the Variance). Respondents will be those homeowners confirmed to be inrolled in the filter program and have a LSL, are likely to have a LSL, or have galvanized lines requiring replacement. No businesses are targeted for this survey so Standard Industrial Classification (SIC) codes are not required. For each survey year an estimated 20,000 of these customers will be randomly selected to receive the survey from Denver Water. This number was set to ensure the minimum number of surveys (as defined in the Variance) is met assuming a 10% response rate. It is expected that those who have not received a survey in past or current rounds of the survey will be targeted in future rounds.
4(b)(i) Data items, including recordkeeping requirements
The recordkeeping requirements that Denver Water must comply with under the Variance, including those related to the filter adoption survey, are consistent with recordkeeping requirements under the existing Lead and Copper Rule. Denver Water is required to submit a summary of the information collected from the survey, including the filter adoption rate and information about filter use and maintenance in the 2025 annual report to the EPA and CDPHE.
To assemble this information collection, Denver Water composed the filter adoption survey. Denver Water will submit the survey analysis results to the EPA and CDPHE electronically. Denver Water will store the information on its own information platforms as described in Part B of the supporting statement. The respondents to the survey will experience only minimal burden associated with assembling and reporting their information. It is not expected they will retain or store their responses.
5(a) Agency Activities
EPA will review the summary of results that Denver Water will submit in their 2025 annual report. The EPA will store the annual report in a restricted drive.
Information about the survey, its processing, and the database that Denver Water will use is detailed in Part B. The survey information will be obtained online, through mail, and in-person.
Denver Water anticipates sending as many as 20,000 surveys in multiple waves (in English and Spanish) primarily through direct mail. Those receiving the survey via direct mail, will have the option to return their results on the prepaid mailer/form or online. Direct mail pieces will have a unique code used to track the location of returned surveys. The same questions used in the mailed and electronic surveys will be used during the 50 in-person interviews that Denver Water is required to conduct every six months. These 300+ in-person customer surveys are figured in to the 20,000 distributed, and 2,000 returned, response counts noted above. The burden for those respondents contacted for an in-person survey should be the same or less than respondents who are responding to the survey by mail or electronically because Denver Water will simultaneously conduct the in-person survey during its visit with the customer to collect compliance tap samples and customers will be able to either directly hand the survey responses back to the Denver Water staff person (rather than having to mail it in) or submit their surveys electronically. The estimated burden for customer respondents, including those responding in-person, is further described in Section 6(e)(i), Table 1, below.
This survey will be administered to individuals, not businesses. Thus, no small entities will be affected by this information collection.
The surveys are scheduled to be sent to respondents in the estimated timeframe of August 31 through September 4, 2025. Denver Water will have until the end of the calendar year to analyze and report the data to the EPA.
The EPA and Denver Water estimate that on average it will take each respondent about 15 minutes to review the introductory materials, complete the survey, and mail or submit the survey.
Denver Water is expected to spend roughly 468 hours (or 159 on average annually) working to prepare and distrubte the survey, record and analyze responses, and include results in the Annual Report.
Estimated respondent costs were based on the Bureau of Labor Statistic’s mean hourly wage for all occupations in the Denver metro area ( $32.09). This wage rate was then multiplied by the standard overhead factor of 1.6, resulting in a loaded hourly wage rate of $51.34.
The EPA expects Denver Water to send up to 20,000 surveys in 2025 and receive approximately 2,000 responses in return. Denver Water is also considered a single respondent. The total annual burden and cost for survey respondents and Denver Water is approximately 322.66 hours and $22,111.33 for the 2025 survey. Burden and costs associated with the 2025 survey have been divided by three (the approval period for an ICR) to produce average annual figures. See section 6(e) for details.
6(e) Bottom Line Burden Hours and Costs Tables
Please see 6(e)(i) through 6(e)(iii).
Respondent Category |
Burden Hours per year |
Total Cost per year |
Denver Water customers |
166.67 * |
$8,556.83 ** |
Denver Water |
156*** |
$ 13,554.66 |
Total cost per year for respondents |
322.67 hours |
*2,000 surveys will take each respondent .25 hours or 500 hours in 2025 or 166.67 hours per year..
** 166.83 hours per year multiplied by Denver area wage multiplied by the standard overhead of 1.6 or $51.34 per hour.
***Estimates from Denver Water.
6(e)(i) Respondent Tally
Estimated time and burden for the customer respondents is
Table 1 Total Estimated Burden and Cost for Customers to Complete the Survey |
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Number of respondents over a three year period |
Hours per respondent |
Hourly rate per respondent |
Cost Per Year |
Total Cost over three Years |
2,000 surveys* |
.25 hours |
$51.34 per hour** |
$8,556.67 |
$25,670 |
*Denver Water’s response rate since 2013 for an end-user survey yields a response rate between 9% and 13%. EPA has decided to use and expected response rate of 10% for this survey and its ICR. Approximately 15% of these surveys will constitute the in-person surveys. |
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**This estimate is from Bureau of Labor (below) and is the mean average of all occupations in the Denver area as of January 2023 and includes the standard overhead factor of 1.6 https://www.bls.gov/oes/current/oes_19740.htm#00-0000 ***2,000 surveys will take each respondent .25 hours or 500 hours in 2025 or 166.67 hours per year. 166.67 hours per year multiplied by the mean Denver area wage ($34.52) multiplied by the standard overhead of 1.6 for a loaded average wage of $51.34 per hour.
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Table 2 Total Estimated Burden and Cost for respondent Denver Water per year * |
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Description |
Hours |
Hourly Rate |
Cost |
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Revise and approve survey for 2025 per year |
Staff: 3.33 Management: 0.66 |
Staff: $110 ** Management: $220*** |
$366.3 $145.2 |
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Identify participants andconduct in-person surveys for (includestravel time to these customer premises). |
Staff: 98 |
Staff: $50 |
$4,900 |
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Database development |
Database Development: Staff: 2.33 Database Development Staff: 2.33 Database Development Management: 1 |
Database Development: Staff: $110 Database Development Staff: $150***** Database Development Management: $220 |
$256.3 $349.5 $220 |
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Mail surveys and cost of the mailings |
Assume 20,000 surveys sent Staff: 1 |
Staff: $50
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$50 Cost to print $133.33 Cost to mail $1,111 |
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Process survey responses and any associated additional costs |
Assume 2,000 surveys returned (10% + in-person) Process Surveys Staff: 18 Process Surveys Management: 2.6 |
Process Surveys Staff: $110 Process Surveys Management: $220 |
$1,980 $572 |
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Collect and input data into a data base, time to organize and sort and analyze the data and time to develop a report per the LRPP, time for other activities (staff, management, administrative) |
Assume 2,000 surveys returned (10% + in-person) Input Survey Data Staff: 18 Report Preparation Staff: 4.6 Process Surveys Management: 2.66 |
Input Survey Data Staff: $110 Report Preparation Staff: $110 Process Surveys Management: $220 |
$1,980 $506 $585.2 |
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Gift cards (O&M) |
Report Preparation Staff: 4 |
Report Preparation Staff: $50 |
$ 200 $333.33 gift cards Total 1,200 |
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Total (hours and cost) Budget |
158.5 |
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$13,554.66 |
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Total Budget per year |
$ 13,554.66 |
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Total Budget (three years) 468 (hours) |
$40,663.98 |
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*The wage rates are the average wage rates for employees that Denver Water pays for salaries as of 2023.
**Consultant staff admin support rate.
***Consultant staff program manager rate.
****Denver Water Administrative Assistant Mid-Range.
*****Consultant staff database lead rate
6(e)(ii) The Agency Tally
Estimated time and burden for EPA Region 8 to approve the Survey
Table 3 Total Estimated Burden and Cost Summary for EPA |
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Technical staff |
3 hours |
GS 13 step 10 67.60 per hour |
$202.8 |
Attorney |
2 hours |
GS 14 Step 10 79.89 per hour |
$159.78 |
Management |
2 hours |
GS 14 Step 10 79.89 per hour |
$159.78 |
Annual Cost |
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$522.36 |
Estimated time and burden for EPA Region 8 to review the data related to the survey per the annual report
Table 4 Total Estimated Burden and Cost Summary for EPA |
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Technical staff |
1 hours |
GS 13 step 10 67.60 per hour |
$67.60 |
Attorney |
1 hours |
GS 14 Step 10 78.89 per hour |
$78.89 |
Management |
1 hours |
GS 14 Step 5 78.89 per hour |
$78.89 |
Annual Cost |
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$227.38 |
Note: The burden for EPA is less when compared to the surveys required under the 2019 Variance because only one survey will be conducted during this ICR renewal period, in 2025 (rather than every year).
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6(e)(iii) Variations in the Annual Bottom Line
We do not anticipate significant variation (>25%) in the respondent reporting/recordkeeping burden.
6(f) Reasons for Change in Burden
No changes in burden.
For the Filter Adoption Survey, the public reporting burden is estimated to average 0.25 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.
To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number R08-OW-2019-0404], which is available for online viewing at www.regulations.gov, or in person viewing at the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ or R08-OW-2019-0404 and OMB Control Number 2008-NEW in any correspondence.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | lwells |
| File Modified | 0000-00-00 |
| File Created | 2023-09-30 |