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Information Collection Request
Title: Consumer Confidence Reports Rule Revisions and Compliance Monitoring Data Reporting
OMB Control Number: 2040-NEW
EPA ICR Number: 2764.02
Abstract:
The Office of Ground Water and Drinking Water (OGWDW) in the Office of Water at the United States
Environmental Protection Agency (EPA) is responsible for managing the Public Water System
Supervision (PWSS) Program, a national program mandated by the Safe Drinking Water Act (SDWA).
Section 1414 of the SDWA requires each community water system to mail, or provide by electronic
means, to each customer of the system at least once annually a report on the level of contaminants in
the drinking water purveyed by that system, known as the “consumer confidence report.” SDWA
requires the EPA to monitor and enforce National Primary Drinking Water Regulations (NPDWRs) to
ensure that the nation’s drinking water reliably complies with the maximum contaminant levels (MCLs),
maximum residual disinfectant limits (MRDLs), treatment techniques (TT) and other requirements
stipulated in the Code of Federal Regulations (CFR), 40 CFR Part 141, Subpart B.
Section 1445 of the SDWA states that public water systems (PWS) shall conduct monitoring, maintain
records, and provide information as needed for the EPA to implement its monitoring and enforcement
responsibilities with respect to the Act. Primacy agencies, the EPA and state governments that have
assumed primary enforcement responsibility under SDWA section 1413, ensure that PWSs are
complying with these regulatory requirements.
As part of the PWSS Program, OGWDW uses the Safe Drinking Water Information System (SDWIS) as the
database of record for compliance with NPDWR requirements. SDWIS is a database management system
that assists the EPA in tracking and interpreting violations data and other program-related data.
This ICR provides burden and cost estimates for the final revised Consumer Confidence Report (CCR)
rule, including compliance monitoring data (CMD) reporting by primacy agencies. The EPA is finalizing
the revised CCR rule to require CWSs serving 10,000 or more people that have violations to include a sixmonth update with their annual report. All other CWSs (without violations) serving 10,000 or more
people will be required to reissue their annual report by December 31st. To implement its compliance
oversight and enforcement responsibilities under the SDWA, the EPA is finalizing a provision as part of
the rulemaking that will require primacy agencies to submit their CMD annually. The ICR estimates costs
for future rule implementation.
The total annual respondent burden associated with this ICR is estimated to be approximately 0.12
million hours per year. The total annual respondent cost associated with this ICR is estimated to be
approximately $4.4 million. The distribution of annual burden between PWSs and primacy agencies is
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approximately 0.09 million hours and 0.02 million hours, respectively. The distribution of annual costs
between PWSs and primacy agencies is approximately $3.1 million and $1.3 million, respectively.
There are no anticipated operation and maintenance (O&M) costs for respondents during the period
covered by the ICR. This represents the “cost burden” as reported in the OMB inventory. These costs are
for O&M only. There are no capital costs associated with the activities covered by this ICR.
The EPA burden for the final revised CCR rule and CMD are captured under the existing PWSS ICR (OMB
Control No: 2040-0090, EPA ICR No: 0270.48) and are not expected to change as a result of this rule.
The total number of respondents for this ICR is 49,490; 66 of these respondents are primacy agencies
and the balance, 49,424, are PWSs. The total annual number of responses for these respondents is
49,424 for PWSs, and 66 for primacy agencies).
1. NEED AND AUTHORITY FOR THE COLLECTION
Explain the circumstances that make the collection of information necessary. Identify any legal or
administrative requirements that necessitate the collection.
Section 2008 of the America’s Water Infrastructure Act of 2018 (AWIA) amended SDWA Section
1414(c)(4) on Consumer Confidence Reports by adding a new paragraph 1414(c)(4)(F). This new
paragraph requires the EPA to revise the 1998 CCR regulations to increase the readability, clarity, and
understandability of the information presented in the CCRs; increase the accuracy of information
presented and risk communication in the CCRs; mandate report delivery at least biannually by systems
serving 10,000 or more; and allow electronic delivery consistent with methods described in the
memorandum Safe Drinking Water Act-Consumer Confidence Report Rule Delivery Options issued by the
EPA on January 3, 2013. The AWIA amendments also require CCRs to include information on corrosion
control efforts and when corrective action to reduce lead levels throughout the system is required
following a lead action level exceedance. As with the original CCR Rule, the AWIA amendments direct
that the revised regulations must be developed in consultation with PWSs, environmental groups, public
interest groups, risk communication experts, the states, and other interested parties. The EPA will use
information collected under this rule to ensure and track compliance.
Section 1445(a) of the SDWA authorizes the EPA to require any person (including water systems and
States) subject to SDWA to make such reports as the EPA may reasonably require by regulation to assist
the agency in determining whether such person has acted or is acting in compliance with SDWA. Under
Section 1413(a)(1)-(3) of SDWA, states with primary enforcement authority are required to adopt
drinking water regulations no less stringent than NPDWRs, adopt and implement adequate procedures
for the enforcement of those regulations, and keep records and make reports with respect to those
activities as the EPA may reasonably require by regulation. The annual reporting of CMD as required by
the final rule will strengthen the agency’s ability to conduct oversight of PWS compliance with NPDWRs
and primacy States’ implementation of the PWS program. Evaluating PWS compliance with the NPDWRs
is based on the review and evaluation of sample results and operational data collected by PWSs and
submitted to primacy states. Currently the EPA only receives state data on water system violations,
water system inventory, and other information, such as enforcement actions, which does not allow the
EPA to fully assess trends in water system compliance with sample collection and other actions required
under the NPDWRs. As a result, the EPA is requiring annual reporting of CMD to assist the agency in
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federal oversight of primacy agency and PWS compliance with SDWA requirements as part of the final
rulemaking.
2. PRACTICAL UTILITY/USERS OF THE DATA
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection,
indicate the actual use the agency has made of the information received from the current collection.
The information collected by EPA is available to the public, via EPA’s website
(https://www.epa.gov/ground-water-and-drinkingwater/safe-drinking-water-information-system-sdwisfederal-reporting) or by requesting the data under the Freedom of Information Act (FOIA; 40 CFR,
Chapter 1, Part 2). In some cases, the SDWA requires that the information be provided to the public or
the primacy agency. Primary users of the data collected under this ICR are the EPA, water systems and
their customers, and primacy agencies, which include state regulators, Indian Tribes, and, in some
instances, the EPA Regional Administrators. Other users include:
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Laboratory personnel
Staff from other EPA programs (such as Superfund, the Resource Conservation and Recovery
Act, and the Office of Enforcement and Compliance Assurance (OECA))
Federal Emergency Management Administration
Centers for Disease Control and Prevention (CDC)
Military bases
Farmers Home Administration
Department of Interior
Department of Housing and Urban Development
U.S. Army Corps of Engineers
White House Task Forces
American Water Works Association (AWWA)
Association of Metropolitan Water Agencies (AMWA)
National Rural Water Association (NRWA)
National Association of Water Companies (NAWC)
Association of State Drinking Water Administrators (ASDWA)
Natural Resources Defense Council
Consumers Federation of America
News organizations
Native American Water Association (NAWA)
Association of American Indian Affairs
Inter-tribal Environmental Council
National Tribal Environmental Council (NTEC)
Airlines 4 America (A4A)
Other intertribal groups
3. USE OF TECHNOLOGY
Describe whether, and to what extent, the collection of information involves the use of automated,
electronic, mechanical, or other technological collection techniques or other forms of information
technology, e.g., permitting electronic submission of responses, and the basis for the decision for
adopting this means of collection. Also describe any consideration of using information technology to
reduce burden.
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The EPA currently requires primacy agencies to submit quarterly and annual reports, and in a format
prescribed to the Administrator (§ 142.15(a)). These existing reports are limited in scope because they
focus only on system inventory, violations, and other information, such as enforcement actions. This
information is maintained in SDWIS 1. Primacy agencies primarily transmit SDWIS data to the EPA
electronically. In the District of Columbia, Wyoming, and Indian Country (except for the Navajo Nation,
which has primacy), results of system samples are sent directly to the EPA Region. These data assist the
EPA in fulfilling its SDWA obligations. On a quarterly basis, the EPA uses the Enforcement Targeting Tool
(ETT) to generate a list of PWSs considered priority systems. The ETT assists the EPA and the primacy
agencies in prioritizing and directing enforcement response to PWSs with the most systemic
noncompliance by considering all violations incurred by a PWS in a comprehensive way.
This final rule revises § 142.15(b) to require all states with primacy to report the data necessary for
determining compliance with NPDWRs, including MCLs, MRDLs, and TTs. The data necessary for
determining compliance include sample results required under each NPDWR, and the related
monitoring data to ensure that the correct number of samples were taken at the right time, in the
correct locations, and were analyzed using an approved analytical method.
The EPA will develop the SDWIS State CMD Extraction Tool to facilitate state reporting. The EPA is
currently in the process of developing the Drinking Water State-Federal-Tribal Information Exchange
System (DW-SFTIES) as the long-term replacement for SDWIS State, the EPA plans to develop an
automated data extraction feature into DW-SFTIES. States that choose to adopt DW-SFTIES for state
data management purposes will be able to use this planned functionality to meet the annual CMD
reporting requirement. Prior to adoption of DW-SFTIES, EPA will facilitate state reporting to minimize
reporting burden. A primacy agency could submit CMD using one of two formats:
1) As a data extract using the EPA’s SDWIS State Data Extraction Tool or,
2) As an extracted copy of its database, and database documentation.
The EPA currently provides a SDWIS Data Extraction Tool to 42 primacy agencies that use SDWIS State,
which supports sharing of CMD with the EPA for the Six-Year Review of Drinking Water Standards. The
Data Extraction Tool extracts CMD from a SDWIS State database and packages it in a file that can easily
be submitted to the EPA. Prior to the implementation date for annual CMD reporting requirement and
based on planned EPA-state workgroup input and testing, the EPA will enhance the Data Extraction Tool
to enable these primacy agencies to automatically extract and annually submit the required CMD to the
EPA.
For the second format mentioned, primacy agencies could submit to the EPA a database extract and
share data documentation that describes the data structure and data element definitions. The EPA will
work with the eight states, five territories, and one tribe with PWSS program primacy that do not
currently use SDWIS State to submit a database extract to meet the annual CMD reporting requirement.
4. EFFORTS TO IDENTIFY DUPLICATION
The public can access the violation data in SDWIS online at
http://water.epa.gov/scitech/datait/databases/drink/sdwisfed/howtoaccessdata.cfm.
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Describe efforts to identify duplication. Show specifically why any similar information already available
cannot be used or modified for use for the purposes described in Item 2 above.
The EPA has made an effort to ensure that the data collection efforts associated with this ICR are not
duplicative. The EPA has consulted with state environmental programs, other federal agencies and
regulated entities, such as PWSs and their representative trade associations. To the best of the EPA’s
knowledge, data currently required by the SDWA, and its implementing regulations codified at 40 CFR
Parts 141 and 142, are not available from any other source.
5. MINIMIZING BURDEN ON SMALL BUSINESSES AND SMALL ENTITIES
If the collection of information impacts small businesses or other small entities, describe any methods
used to minimize burden.
In developing this ICR, the EPA considered the requirement of the Small Business Regulatory
Enforcement Fairness Act (SBREFA) to minimize the burden of information collections on small entities.
Small entities include “small businesses,” “small organizations” and “small government jurisdictions.”
These terms are defined below.
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A small business is any business that is independently owned and operated and not
dominant in its field as defined by the Small Business Administration regulations under
section 3 of the Small Business Act.
A small organization is any non-profit enterprise that is independently owned and operated
and not dominant in its field.
A small governmental jurisdiction is the government of a city, county, town, township,
village, school district, or special district that has a population of fewer than 50,000. This
definition may also include Indian Tribes.
The major requirement under SBREFA is a regulatory flexibility analysis of all new rules that have a
“significant economic impact on a substantial number of small entities.” This ICR is associated with new
rules. Therefore, this ICR is subject to the SBREFA.
The EPA has made significant efforts to minimize the burden for all respondents, particularly for small
entities as detailed below.
Consumer Confidence Report Rule Revision
If permitted by primacy their respective primacy agencies, the EPA’s regulations allow, systems serving
fewer than 10,000 people to advertise in the news media in lieu of sending reports to customers. Under
40 CFR 141.155(g)(2), CWSs serving 500 or fewer people may forego the notice-publishing requirement,
provided they give notice at least annually to their customers by mail, door-to-door delivery, or posting
in an appropriate location that the CCR is available upon request. These flexibilities are unchanged in the
final revised CCR rule.
Compliance Monitoring Data Reporting
There are no PWS burden associated with CMD reporting as this falls under the purview of state primacy
agency activities.
6. CONSEQUENCES OF LESS FREQUENT COLLECTION
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Describe the consequence to Federal program or policy activities if the collection is not conducted or is
conducted less frequently, as well as any technical or legal obstacles to reducing burden.
The EPA has considered a wide range of alternatives for frequency of data collection. The final revised
CCR rule requires at least annual reporting. For systems serving 10,000 or more people, SDWA requires
them to send reports biannually, or twice per year. Distributing CCRs less frequently is not allowed
under the SDWA. Annual reporting of compliance monitoring data is essential to enable the EPA to
determine if compliance monitoring determinations were made correctly.
For other information collection activities, the EPA has chosen to require the least frequent collection
that remains consistent with overall public health preservation objectives. If data are collected less
frequently, the primacy agencies may not identify, in a timely fashion, violations that might threaten
public health and the safety of drinking water consumers.
7. GENERAL GUIDELINES
Explain any special circumstances that require the collection to be conducted in a manner inconsistent
with OMB guidelines.
There are no special circumstances. The collection of information is conducted in a manner consistent
with the guidelines in 5 CFR 1320.6.
8. PUBLIC COMMENT AND CONSULTATIONS
8a. Public Comment
If applicable, provide a copy and identify the date and page number of publication in the Federal Register
of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection
prior to submission to OMB. Summarize public comments received in response to that notice and
describe actions taken by the Agency in response to these comments. Specifically address comments
received on cost and hour burden.
To comply with the 1995 Amendments to the Paperwork Reduction Act, Agencies developing rulerelated ICRs must solicit public comments for a 60-day period prior to submitting the request to OMB.
EPA notified the public regarding the preparation of this ICR in the Federal Register preamble for the
proposed revisions of the CCR rule (88 FR 20092, April 5, 2023).
No comments were received specifically on the ICR; however, based on public comment received on the
proposed rule, modifications were made to the rule and underlying analyses prior to promulgation of
the final rule. Where appropriate, these modifications are also reflected in this ICR. The most significant
change for purposes of the ICR was a change in compliance date. After consideration of public
comments, the EPA revised the compliance date to 2027 (from 2025 in the proposed rule), which shifts
the anticipated activities states and CWSs will perform during the first three years following
promulgation. For a full discussion of public comments on the proposed revisions of the CCR rule, as
well as EPA’s responses, see the Public Comment and Response Document included in the docket (EPAHQ-OW-2022-0260).
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of
data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting
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format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with
representatives of those from whom information is to be obtained or those who must compile records
should occur at least once every 3 years - even if the collection of information activity is the same as in
prior periods. There may be circumstances that may preclude consultation in a specific situation. These
circumstances should be explained.
Section 1414(c)(4)(F)(i) of the SDWA requires the agency to consult with “public water systems,
environmental groups, public interest groups, risk communication experts, and the States, and other
interested parties” in developing revisions to the Consumer Confidence Report Rule. In addition to
seeking and considering public comment on the proposed rule, the EPA consulted with various
stakeholders to solicit input on the rulemaking prior to publication of the proposal. The EPA sought
recommendations from the National Drinking Water Advisory Council. In addition, the EPA sought input
from tribal governments as part of tribal consultation, along with members of state, local government,
and utility associations as part of a Federalism consultation. As part of the final revised CCR rule, the EPA
consulted with representatives of CWSs and states regarding the accuracy of the EPA’s burden
estimates.
9. PAYMENTS OR GIFTS TO RESPONDENTS
Explain any decisions to provide payments or gifts to respondents, other than remuneration of
contractors or grantees.
No payments or gifts were or will be provided to CWSs and states.
10. ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in
statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or
privacy impact assessment (PIA), those should be cited and described here.
No confidential information will be collected as a result of this ICR.
11. JUSTIFICATION FOR SENSITIVE QUESTIONS
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and
attitudes, religious beliefs, and other matters that are commonly considered private. This justification
should include the reasons why the Agency considers the questions necessary, the specific uses to be
made of the information, the explanation to be given to persons from whom the information is
requested, and any steps to be taken to obtain their consent.
No information of a sensitive nature will be collected as a result of this ICR.
12. RESPONDENT BURDEN HOURS & LABOR COSTS
Provide estimates of the hour burden of the collection of information. The statement should:
• Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. Generally, estimates should not include burden
hours for customary and usual business practices.
• If this request for approval covers more than one form, provide separate hour burden estimates for
each form and the aggregate the hour burdens.
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Provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories. The cost of contracting out or
paying outside parties for information collection activities should not be included here. Instead, this
cost should be included as O&M costs under non-labor costs covered under question 13.
12a. Respondents/NAICS Codes
Data associated with this ICR are collected and maintained at the PWS, state, and federal levels.
Respondents include:
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Owners/operators of PWSs, who must report to the primacy agency.
State/Primacy agencies, and the EPA Regions that act as primacy agencies in Indian country.
The North American Industry Classification System (NAICS) code for PWSs is 22131. The NAICS code for
state agencies that include drinking water programs is 92411 (Administration of Air and Water
Resources and Solid Waste Management Programs) or 923312 (Administration of Public Health
Programs). Ancillary systems (i.e., those that supplement the function of other establishments like
factories, power plants, mobile home parks, etc.) cannot be categorized in a single NAICS code. For
ancillary systems, the NAICS code is that of the primary establishment or industry.
12b. Information Requested
The data items requested under this ICR differ across the three years covered by this ICR. As indicated in
the final rule preamble, systems and states must comply with the new requirements beginning in 2027.
In the first two years following promulgation, public water systems and primacy agencies will still be
engaged in the regulatory startup/implementation activities, see response to 12c.
In year three covered by this ICR, CWSs and states will engage in ongoing implementation of the revised
CCR rule requirements. CWSs will begin implementing additional activities according to the final rule
requirements, and states will begin reporting CMD to the EPA and providing technical assistance and
oversight of the revised CCR rule. Respondent information collection requirements covered by the CCR
Rule and CMD reporting ICR are summarized in Exhibit 1 and Exhibit 2 below.
Requirement
Exhibit 1: PWS Recordkeeping and Reporting Requirements
Regulatory Citation
Reporting Frequency/Record
Retention Period
CCRs
Mail or electronically deliver
copies of CCR to customers.
40 CFR 141.155(a)
Good faith delivery of CCR to
non-bill paying consumers.
40 CFR 141.155(b)
Submit copy of CCR to primacy
agency.
40 CFR 141.155(c)
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Annually, unless required to
provide biannually for systems
serving 10,000 or more persons,
or unless waived per 40 CFR
141.155(g)
Annually, unless required to
provide biannually for systems
serving 10,000 or more persons
Annually, unless required to
provide a 6-month update with
the report
Requirement
Regulatory Citation
Submit copy of CCR to agencies
or clearing houses identified by
the primacy agency.
Make current year’s CCR
available to public.
Post current year’s CCR on the
Internet (for systems serving
≥50,000 people).
Publish CCR in local newspaper
or online news media, if the
mailing requirement has been
waived.
Retain copy of CCR.
Submit a plan to provide access
to limited English proficiency
consumer to the primacy
agency (for systems serving
≥100,000 people)
40 CFR 141.155(d)
Requirement
40 CFR 141.155(e)
40 CFR 141.155(f)
40 CFR 141.155(g)(1)
40 CFR 141.155(h)
40 CFR 141.155(i)
Reporting Frequency/Record
Retention Period
Annually, as required, unless
required to provide a 6-month
update with the report
As requested
Annually, unless required to
provide a 6-month update with
the report
Annually, except that systems
serving ≤500 can forego per 40
CFR 141.155(g)(2)
For at least 3 years
Initial plans due in 2027, and
updated as needed
Exhibit 2: Primacy Agency Recordkeeping and Reporting Requirements
Regulatory Citation
Reporting Frequency/Record
Retention Period
CCRs
Make CCRs available to public.
40 CFR 142.16(f)(2)
Retain copies of CCRs and
40 CFR 142.14(h)(1)
certifications that CCRs were
distributed.
Report violations of CCR
40 CFR 142.16(f)(4)
provisions.
Retain copies of the translation 40 CFR 142.14(h)(2)
access plan
Compliance Monitoring Data Reporting
Report compliance monitoring
40 CFR 142.15(b)(3)
data to SDWIS.
As requested
CCRs: 5 years
Certifications: 1 year
Quarterly
5 years
Annually beginning in 2027
12c. Respondent Activities
PWSs and primacy agencies must complete the activities described in the sections below.
Public Water Systems
Consumer Confidence Report Rule Revisions
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For CCRs, CWSs will conduct the following start up activities:
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Review training materials from primacy agencies
Train staff
Conduct background research to determine applicability of access plan requirements
(for CWSs serving 100,000 or more people only)
Develop plan to facilitate translation access (for CWSs serving 100,000 or more people
only)
Develop templates for brief report summary
For CCRs, CWSs must conduct the following ongoing activities:
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CWSs serving 10,000 or more people will be required to provide two reports per year.
The EPA will require that all reports include a report summary.
Large systems serving 100,000 or more persons will be required to identify plans for
providing access to the reports for consumers with limited English proficiency.
All CWSs will be required to provide include language explaining their corrosion control
procedures.
Compliance Monitoring Data Rule
There are no PWS activities associated with the compliance monitoring data rule.
Primacy Agencies
Consumer Confidence Reports Rule Revisions
For the revised CCR rule, primacy agencies will conduct the following start up activities:
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Read and understand rule
Regulation adoption, update of state program/primacy package
Updating reporting system
Preliminary data analysis
CWS outreach, support and education
Staff training
Set up reporting system to extract and submit CMD
As part of the revised CCR rule, primacy agencies must conduct the ongoing activities:
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Review and retain reports and certifications from CWSs.
Review and retain copies of the plan to provide access to limited English proficiency
consumers for systems serving 100,000 or more people.
Assist in preparation of reports, as needed.
Provide technical assistance for translation support, as needed.
Report compliance to the EPA.
Compliance Monitoring Data Reporting
Primacy agencies will be required to annually report CMD to the EPA.
12d. Respondent Burden Hours and Labor Costs
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Burden and labor hours and costs are summarized for the final revised CCR rule and CMD reporting
below. Labor costs are based on the number of burden hours times the average hourly wage rate,
including overhead. Labor rates in 2022 dollars are used and are loaded with a 60 percent overhead
factor. A loaded labor rate of $56.18 per hour in 2022 dollars was used for state labor.
Burden to Public Water Systems
The annual PWS burden for final revised CCR rule and CMD reporting, is estimated to be approximately
93,193 hours. Exhibit 3 shows the breakdown of the annual burden hours The bases for the burden
estimates are detailed below.
The EPA relied on several sources of data to estimate the potential cost of the final rule, including
information from interviews and from published sources. The EPA supplemented these data with several
assumptions about how the rule would be implemented.
Consumer Confidence Reports Rule Revisions
The final CCR rule require, at a minimum, that each CWS mail or electronically deliver to each of its
customers an annual report on the level of contaminants in the drinking water purveyed by that system.
For systems serving 10,000 or more persons, they will need to provide CCRs biannually. If a system
serving 10,000 or more persons has a violation between January 1st and June 30th of the current year,
they will be required to provide a 6-month update with the second report. For systems serving 100,000
or more people, they will be required to provide a plan to their primacy agencies describing their
approach for providing language access to limited English proficient consumers. The EPA estimates that
final revised CCR rule requirements will affect approximately 49,424 CWSs during the course of this ICR
period. Activities associated with the preparation and delivery of CCRs account for 93,193 burden hours
per year, which includes burden for understanding the rule, CCR development and distribution for PWSs.
The compliance with the revised requirements of the final rule begins in 2027, therefore, activities
covered by this ICR include two years of upfront costs, and one year of ongoing costs (see section 12c).
Administration
The upfront administrative costs for CWSs include reviewing training materials received from primacy
agencies and training staff to develop CCRs in compliance with the rule revisions. Systems serving
100,000 or more people will have ongoing administrative casts because they will periodically research,
adjust, and update their translation access plan to account for changing demographics, as well as revise
their plan to address feedback from the primacy agency.
Report Development
Preparation of a CCR includes assembling data, writing the report, ensuring that the notice meets
regulatory requirements, and printing the document or notice. Burden estimates range from 1 hours for
CWSs serving 10,000 or fewer people to 4 hours for CWSs serving 100,000 people or more. After
completion of CCR preparation activities, all CWSs, regardless of size, are assumed to have the same
burden (0.5 hours) for submitting to the state a copy of the CCR distributed to customers. Certification
that the reports were distributed is also required along with the report. All CWSs, regardless of size, are
assumed to have the same burden (0.25 hours) for maintaining a copy of the CCR and making it publicly
available, if requested.
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Report Delivery
The burden estimate for CCR delivery includes the following activities and assumptions: This ICR
assumes a burden 3 hours per system to deliver CCRs for CWS serving 10,000-50,000 people, 5 hours
per system to deliver CCRs for CWS serving 50,000-100,000 people, and 9 hours per system to deliver
CCRs for CWS serving more than 100,000 people.
Compliance Monitoring Data Reporting
There is no PWS burden associated with CMD reporting as this falls under the purview of state primacy
agency activities.
Burden to Primacy Agencies
The annual burden for state primacy agencies for final revised CCR rule and CMD reporting, is estimated
to be approximately 22,701 hours. Exhibit 4 shows the annual burden on an activity-specific basis. The
following briefly describes the bases for the burden estimates:
Consumer Confidence Reports Rule Revisions
Primacy agencies are expected to incur burden for information collection activities associated with
preparation assistance, review, and filing of CCRs. The total annual state burden is estimated at 21,232
hours.
Compliance Monitoring Data Rule
As illustrated in Exhibit 4, hours of burden are for providing the EPA with information regarding all CMD
that is necessary to determine compliance with the drinking water requirements. The total annual state
burden is estimated at 1,469 hours.
Exhibit 3: Annual PWS Burden and Cost
Annual Burden Annual Labor
Total Annual
Activity
Hours
Cost ($K)
Labor Cost ($K)
Consumer Confidence Reports
93,193
$3,082
$3,082
Rule Revisions
0
$0
$0
CMD
93,193
$3,082
$3,082
TOTAL
Exhibit 4: Annual State Burden and Cost
Annual Burden
Annual Labor Total Annual
Activity
Hours
Cost ($K)
Cost ($K)
Consumer Confidence Reports
21,232
$1,193
$1,193
Rule Revisions
1,469
$83
$83
CMD
22,701
$1,275
$1,275
TOTAL
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Estimating Respondent Universe and Total Burden and Costs
Respondents for this ICR include PWSs and states or other primacy agencies. This ICR estimates the
number of CWS respondents at 49,424.
In addition to the PWS respondents, this ICR assumes 66 primacy agencies (50 states plus the District of
Columbia, U.S. territories, the EPA Regions conducting direct implementation of tribal primacy, and the
Navajo Nation). 2 Therefore, the total number of respondents is 49,490.
The total costs and burden for these respondents are summarized in. Agency costs and burden are
detailed in section 14.
Total Burden Hours and Costs
The bottom line burden hours and costs are presented in Exhibit 5. The total annual respondent burden
associated with this ICR is estimated to be 115,895 burden hours. There is no the EPA burden or cost
associated with this ICR.
Exhibit 5: Bottom Line Annual Burden and Cost
Total Number of Respondents
CWS
Primacy Agency
Total Annual Responses
CWS
Primacy Agency
Number of Responses per Respondent
Total respondents
Total responses
Total Respondent Hours
CWS
Primacy Agency
Hours Per Response
Annual Respondent Hours
Annual Responses
Total Annual Respondent Cost ($K)
CWS
Primacy Agency ($K)
Total Annual Hours (respondents and agency)
Total Annual Cost (respondents and agency)
49,490
49,424
66
49,490
49,424
66
1
49,490
49,490
115,895
93,193
22,701
2.3
115,895
49,490
$4,357
$3,082
$1,275
115,895
$4,357
13. RESPONDENT CAPITAL AND O&M COSTS
This is a simplifying assumption. Primacy activities for Wyoming and the District of Columbia are actually carried
out by the respective EPA Regional offices.
2
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Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the
collection of information. (Do not include the cost of any hour burden already reflected on the burden
worksheet).
The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life) and (b) a total operation and maintenance and
purchase of services component. The estimates should consider costs associated with generating,
maintaining, and disclosing or providing the information. Include descriptions of methods used to
estimate major cost factors including system and technology acquisition, expected useful life of capital
equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up
costs include, among other items, preparations for collecting information such as purchasing computers
and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain
the reasons for the variance. The cost of purchasing or contracting out information collections services
should be a part of this cost burden estimate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made:
(1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with
the information collection, (3) for reasons other than to provide information or keep records for the
government, or (4) as part of customary and usual business or private practices.
The EPA estimates there will be no O&M costs incurred during the period covered by the rule. Beginning
in 2027 when system will incur O&M costs as a result of the final revised CCR rule which would reflect
non-labor costs associated with printing, delivery, posting, and publishing CCRs. There are no capital
costs associated with this ICR. All costs incurred by primacy agencies are labor costs.
14. AGENCY COSTS
Provide estimates of annualized costs to the Federal government. Also, provide a description of the
method used to estimate cost, which should include quantification of hours, operational expenses (such
as equipment, overhead, printing, and support staff), and any other expense that would not have been
incurred without this collection of information.
14a. Agency Activities
The EPA is assumed not to have any new burden associated with final revised CCR rule or CMD reporting
that is not captured under the PWSS ICR.
14b. Agency Labor Cost
The EPA costs are captured under the PWSS ICR for this rule.
14c. Agency Non-Labor Costs
The EPA costs are captured under the PWSS ICR for this rule.
15) REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost
estimates.
AWIA amended SDWA section 1414 which required the EPA to revise the CCR rule, as previously
described. The annual reporting of CMD as required by this final rule will strengthen the agency’s ability
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to conduct oversight of PWS compliance with NPDWRs and primacy States’ implementation of the PWS
program.
16) PUBLICATION OF DATA
For collections of information whose results will be published, outline plans for tabulation and
publication. Address any complex analytical techniques that will be used. Provide the time schedule for
the entire project, including beginning and ending dates of the collection of information, completion of
report, publication dates, and other actions.
Currently the EPA only receives state data on water system violations, water system inventory, and
other information, such as enforcement actions. The information collected by EPA is available to the
public, via EPA’s website (https://www.epa.gov/ground-water-and-drinkingwater/safe-drinking-waterinformation-system-sdwis-federal-reporting). Following promulgation of the final rule, the EPA will
engage stakeholders to inform implementation, including incorporating CMD into the EPA’s publicly
available platforms. Because the first installment of the CMD will not be received by the EPA until the
compliance date in 2027 as identified in the Federal Register, the EPA does not anticipate publication of
data for the first three years following promulgation covered under this ICR.
17) DISPLAY OF EXPIRATION DATE
If seeking approval to not display the expiration date for OMB approval of the information collection,
explain the reasons that display would be inappropriate.
Not applicable.
18) CERTIFICATION STATEMENT
Explain each exception to the topics of the certification statement identified in “Certification for
Paperwork Reduction Act Submissions.”
Not applicable.
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File Type | application/pdf |
File Title | 18Q Supporting Statement Instructions_draft |
Author | McGrath, Daniel |
File Modified | 2024-05-13 |
File Created | 2024-05-13 |