Clean Watersheds Needs Survey (CWNS) 2012: Documenting Small Community Needs

1. Clean Watersheds Needs Survey (CWNS) 2012:Documenting Small Community Needs Presenter: Karen Fligger, EPA

2. What is a Small Community? • Total Present Resident Population fewer than 10,000 persons present resident population receiving collection and centralized treatment present resident population serviced by onsite wastewater treatment systems present resident population not receiving wastewater treatment Total Resident Population = + +

3. Issues Facing Small Communities • Many unsewered areas and areas with decentralized wastewater treatment • Existing infrastructure old, not maintained • High per capita, per household costs for wastewater treatment • Residents often have low or fixed incomes • High administrative cost to operate systems • Needs are under-reported, don’t get attention

4. CWNS 2008 Small Community Data • $22.7 billion (8% of total needs) • Seven states (PA, NY, IA, UT, IL, WV & OH) reported ~50% of the small community needs. • Small community facilities are a large majority of the total number of publicly owned facilities in each State. • More than 90% of facilities in three States (IA, KS, NE) serve small communities. • 80-90% of facilities in nine additional States serve small communities • Only 32.3% of small communities have documented needs compared to 61.1% of non-small communities

5. Small Community Data Collection

6. Facility/ project types • Rules and documentation requirements for small communities apply to these facility types: • Publicly owned wastewater facilities • Combined sewer overflow (CSO) control • Decentralized wastewater treatment systems

7. What data is collected for small communities? • Information collected includes: • Estimated needs (cost and technical information) – and DOCUMENTS • Location and contact information • Permit information and discharge data • Solution to the project/ best management practices (BMPs) • WWT facility population served, flow, effluent, and unit process data

8. Documentation Methods • Standard Documentation • Simplified Methodology • Information from an Assistance Provider (72) • CUPSS (Check Up Program for Small Systems) Wastewater Asset Management Plan (73) • EPA-approved Small Community Survey (71) • State Form (12)

9. Standard Needs and Costs Documentation • States should use standard documentation if available • May use any of the 2012 Pre-approved Document Types or approved Innovative Methods • Common documents include: • Signed health department statement • Application for funding • Capital Improvement Plan • Engineering studies or Plans of Study • General Plan or Facilities Plan

10. Simplified Methodology for Small Communities • Water quality or water quality related public health needs are documented by: • Written explanation of need • Certified by the SIGNATURE of a local official representing the community. • A local official can be an elected official (e.g., mayor) or other qualified official (e.g., public works manager).

11. Simplified Methodology for Small Communities • Costs are documented by written explanation of costs • Costs are certified by one of the following: • The SIGNATURE of a local professional engineer (PE) in the cost certification or • The SIGNATURE of a local government official in the cost certification AND a the SIGNATURE the State Professional Engineer (PE) to certify that the cost is reasonable after reviewing the estimate. • If no cost certification signature is provided, cost curves generate estimated costs (if possible).

12. Special Circumstances for Very Small Communities • For communities with populations of 3,500 or less and under extraordinary circumstances: • A state registered engineer or circuit rider may sign the cost or need justification with pre-approval from EPA. • States should send written statements to EPA HQ with the each community’s details and why local signatures are not available. • States should wait until EPA HQ approves the request before entering needs or cost information into the database.

13. Information from an Assistance Provider (72) • To document need only • A statement from a technical assistance provider • E.g. state training center, health department, RCAP (Rural Community Assistance Partnership) • Requires signatures from a local official and the service provider

14. CUPSS Wastewater Asset Management Plan(73) • Asset management tool for small wastewater utilities available free from EPA • http://water.epa.gov/infrastructure/drinkingwater/pws/cupss/ • This document can only be used for communities already using CUPSS to manage their assets • Information must be entered by local community and the “Asset Management Plan” must be complete • May be supplemented by other documents if necessary • A CWNS specific cover sheet will require a local government official SIGNATURE to certify that: • The needs and costs are accurate • The community is using CUPSS to manage their assets

15. Small Community Needs Form (71) • Not Cover Pages for other documents Small Community Needs Form January 31, 2012 Town: Needsville Needs: SSOs Cost: $1,000,000 (See Attachments) Signatures: XXXXXX Needsville Capital Improvement Plan March 1, 2005 Project 1: Correct SSOs Problems. Estimated Cost: $1,000,000 Project 2: Rebuild High School. Estimated Cost: $9,000,000

16. Small Community Needs Form (71) • There are two versions: • Blank form • Will be available when CWNS 2012 ICR is approved • Very few changes from CWNS 2008 • Customized form, pre-populated with data in DEP • Available for all existing CWNS wastewater facilities with populations <10,000 persons • Will be available when CWNS DEP re-opens in April • Multi-print function will be implemented in April • Completed forms are submitted by fax, digitized, and uploaded to the facility’s “Needs by Document”

17. Customized Form available in DEP for each facility with Population < 10,000

18. Fax Cover Sheet (.pdf)

19. Customized Form pre-populates data currently entered in system

20. Alejandro Escobar A representative of the community corrects the form .25 .25

21. Local Official’s signature confirms the data is accurate

22. A representative of the community can add needs and costs not captured in the pre-populated form

23. Estimating Sewer Replacement/Rehabilitation Costs

24. A local official’s signature confirms the needs are accurate and a engineer’s signature confirms the accuracy of the costs

25. New multi-print function in DEP • Advanced search can be used to limit the Facility List to only Small Communities

26. Select some or all of the facilities with a Small Community Form Choose between Opening a file browser or Saving a .zip file

27. Open individual Small Community Forms or select all for printing

28. State Forms (12) • Must be pre-approved by EPA HQ prior to use • States should not begin data entry until the survey is approved • Surrveys approved in 2008 must be re-submitted for approval in 2012

29. State Forms Requirements • State forms are acceptable for documenting need if they contain certain minimum elements, such as: • Description of Needs & Project Benefits • Time Horizon of Needs • Contact Information • Population Estimates • A local government official's signature certifies that the community has the water quality needs described in the form.

30. State Forms Requirements • Cost Justification - Population <10,000: • Costs by engineer or engineer circuit rider. • Other acceptable documentation types not available. • State project staff signature.

31. Cover Letter for Surveys • A good cover letter is key for improving response rate to surveys • Added by state coordinators • Include contact information for state coordinator, state deadline for submitting needs, and reasons that your state’s communities should respond

32. Examples Cover Letters • “The results of this data will be sent to U.S. EPA where your response can help return your tax dollars to the State of Ohio! Demonstrating your wastewater infrastructure, storm water and nonpoint source pollution abatement needs will help determine the level of funds made available to communities in Ohio through programs such as the Water Pollution Control Loan Fund, and help keep that program’s interest rates low.” • “ Even if you no longer have need for water quality improvements locally, your response is vital to ensuring that all communities are represented in the overall needs of Ohio’s communities.” • “This information will help New Jersey to secure federal grants to fund the needs of New Jersey communities. Please try to fill out this survey form as completely as possible and return it to New Jersey State DEP.”

33. Questions