Overview
Title
Agency Information Collection Activities; Proposed Information Collection Request; Comment Request; The 8th Drinking Water Infrastructure Needs Survey and Assessment
Agencies
ELI5 AI
The Environmental Protection Agency (EPA) is asking people to share their thoughts about a plan to check how much money is needed to fix and keep the drinking water systems across the country safe and clean. They want to make sure everyone can have good, clean water to drink, and they’re inviting answers to some questions to help decide how to share money for these water improvements.
Summary AI
The Environmental Protection Agency (EPA) is planning to submit an information collection request focused on assessing the capital improvement needs for drinking water systems. This is part of the 8th Drinking Water Infrastructure Needs Survey and Assessment, and the EPA is seeking public comments before moving forward. The survey will collect data to estimate the needs for maintaining and updating water systems across the U.S., with a focus on large and medium community water systems. The information collected will help determine the distribution of funds from the Drinking Water State Revolving Fund to ensure safe drinking water, and respondents are encouraged to participate voluntarily.
Abstract
The U.S. Environmental Protection Agency (EPA) is planning to submit an information collection request (ICR), the 8th Drinking Water Infrastructure Needs Survey and Assessment (EPA ICR Number 7798.01, OMB Control Number 2024-0561) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. Before doing so, the EPA is soliciting public comments on specific aspects of the proposed information collection as described below. This is a request for approval of a new collection. This notice allows for 60 days for public comments.
Keywords AI
Sources
AnalysisAI
Summary of the Document
The Environmental Protection Agency (EPA) intends to gather information to assess the capital needs of drinking water systems in the United States through the 8th Drinking Water Infrastructure Needs Survey and Assessment. This survey is designed to collect data from large and medium-sized community water systems. The ultimate goal is to inform the distribution of funds from the Drinking Water State Revolving Fund, ensuring the public has access to safe drinking water. The EPA is currently soliciting public comments on this initiative, allowing a period of 60 days for feedback.
Significant Issues and Concerns
One area of concern is the ambiguity surrounding which Tribal systems will be chosen for additional questions about operation and maintenance needs. The document does not specify the criteria for selection, which could lead to feelings of unfairness or inconsistency.
Additionally, the document reports a significant reduction in the respondent burden due to a decreased sample size. However, it fails to explain why this sample size has been reduced, which could raise doubts about whether the data collected will be sufficiently representative.
There is also mention of using the Lead and Copper Rule Revisions (LCRR) service line inventory as an alternative method for collecting lead service line data. Details about how this will work in practice, including how it will be evaluated and implemented, are not provided.
The document's technical language, especially in sections discussing survey justifications and methodologies, may be challenging for laypersons to comprehend. This complexity might hinder public understanding and reduce effective engagement with the consultation process.
Impact on the Public and Stakeholders
Broadly speaking, the document outlines an initiative aimed at ensuring long-term access to safe drinking water. This is a goal likely to be widely supported by the public. The survey results could lead to better-targeted funding and improvements in water infrastructure, benefiting communities across the nation.
However, the impact on specific stakeholders varies. Large and medium-sized community water systems will face the survey's demands, though their participation is voluntary. Tribal systems may experience additional pressures if selected for supplemental questioning. On the brighter side, these stakeholders could benefit from potential funding improvements based on the survey's findings.
For state agencies and the community water systems chosen to participate, the estimated cost and time burden may be significant. While the document provides a cost estimate, it does not clarify how these expenses directly translate into benefits for respondents, leading to some apprehension about the practical outcomes of their cooperation.
Overall, while the EPA's intentions are clear and potentially beneficial, the approach and communication outlined in the document could be improved in clarity and transparency to foster broader public participation and understanding.
Financial Assessment
The Federal Register notice regarding the 8th Drinking Water Infrastructure Needs Survey and Assessment (DWINSA) conducted by the Environmental Protection Agency (EPA) outlines the financial implications and requirements associated with this initiative. The notice highlights significant financial references which provide insights into both the costs incurred by respondents and the overall cost of conducting the survey.
Financial Overview
The financial aspect of the survey is captured in two primary figures. Firstly, the effort involved in conducting the 8th DWINSA is expected to engage 2,164 respondents, which includes 2,108 water systems and 56 states. The total estimated time commitment is 30,087 hours, translating to an overall cost to respondents of $1,875,387. This figure encompasses the labor costs necessary to respond to the survey.
Additionally, the document outlines the total estimated annual cost, which amounts to $937,694 per year. This figure surprisingly includes $0 annualized capital or operation & maintenance costs, thereby indicating that the costs are almost entirely related to labor and administrative tasks rather than equipment or ongoing operational expenses.
Relation to Identified Issues
The financial definition of respondent burden is crucial when considering the identified issues in the document. For example, the notice mentions a significant decrease of 13,444 hours in total estimated respondent burden from previous iterations. This reduction is attributed to a decreased sample size, but the document lacks an explanation for this decrease. Without a clear rationale, stakeholders might question whether the data collected will adequately represent the needs of the national community water systems.
Moreover, while the notice details the financial expectations from respondents, it does not thoroughly explain how these costs might translate into tangible benefits or improvements for these respondents. There is a mention of potential supplemental questions specific to Tribal systems, yet the financial and methodological vagueness surrounding this aspect could lead to uncertainties about the justification and fairness of resource allocation.
Additionally, the notice's consideration of using Lead and Copper Rule Revisions (LCRR) service line inventory information as an alternative method for collecting data appears to present an opportunity for cost-saving. However, without detailed evaluation criteria or implementation plans, the financial implications of shifting to this alternative data collection method remain speculative.
Conclusion
In summary, while the EPA's notice regarding the 8th DWINSA provides explicit financial details related to the survey's implementation and respondent participation, it also raises questions about the sufficiency and efficiency of the funding allocations. Stakeholders might benefit from further clarity on how these financial efforts will effectively enhance data quality and ultimately support the funding and improvement of drinking water infrastructure across various jurisdictions.
Issues
• The document does not specify the criteria for selecting which Tribal systems will be sampled for supplemental questions. This could lead to ambiguity or perceived unfairness.
• The estimated decrease of 13,444 hours in respondent burden due to a decreased sample size is mentioned, but without explaining why the sample size decreased, this could raise questions regarding the adequacy of the data collection.
• The EPA's consideration of using LCRR service line inventory information as an alternative for collecting lead service line data is mentioned, but lacks detail about how this alternative will be evaluated or implemented.
• The document's language, particularly in sections outlining the justification and methodology for the survey, becomes quite technical, which might be difficult for laypersons to understand without additional context or simplification.
• There is no clear explanation of how the potential questions for Tribal systems regarding operation and maintenance needs will be developed, which creates uncertainty about how these questions will address the specific needs and circumstances of Tribal systems.
• The notice discusses extensive data collection and costs but doesn't provide a clear breakdown of how these costs will benefit the respondents or improve outcomes.