Clean Watersheds Needs Survey (CWNS) 2012 CWNS Eligibility, SRF Eligibility & SRF Audit

1. Clean Watersheds Needs Survey (CWNS) 2012CWNS Eligibility, SRF Eligibility & SRF Audit Presenter: Karen Fligger, EPA HQ

2. Session Overview • Introduction to CWNS • Needs Definitions and Categories • Needs Elgibility • SRF Eligibility and Audit

3. 1.) Introduction to CWNS

4. What is the CWNS? • Assessment of capital needs to meet the Clean Water Act’s (CWA) water quality goals • Joint effort by EPA, States, & Local organizations • Every 4 years as required by CWA Sec 516 (started in 1972) • Data is submitted via the CWNS Data Entry Portal (DEP) • Results in Report to Congress and on publicly available data on the Internet

5. Clean Water Act (CWA) Authority • CWA Sec. 516 excerpt The EPA Administrator, in cooperation with the States, …shall make (a) a detailed estimate of the cost of carrying out the provisions of this Act”; (b) a detailed estimate…of the cost of construction of all needed publicly owned treatment works in all of the States… • CWA Sec. 205(a) excerpt Allotments…shall be made only in accordance with a revised cost estimate made and submitted to Congress in accordance with Sec. 516 of this Act and only after such revised cost estimate shall have been approved by law specifically enacted hereafter.

6. Data is entered at facility/project level • Treatment plant • Collection system (combined & separate) • Stormwater management project • Combined sewer overflow (CSO) control project • Recycled water distribution facility • Decentralized wastewater treatment project • Non-point source pollution control project • Pump Station

7. Information collected includes: • Estimated needs (costs) • Documentation outlining needs & costs • Location and contact information • Permit information • Treatment plant population served, flow, effluent, and discharge information • Decentralized and collection system population served • Unit Process and Best Management Practices

8. Additional Background • EPA’s CWNS website: epa.gov/cwns • Under 2012 Planning, links to the CWNS 101 webinar, presentation, and FAQ

9. 2) Needs Definitions & Categories

10. Needs Definitions • Needs: The unfunded capital costs -- as of January 1, 2012 -- of a project that addresses an existing or projected (within next 20 years) water quality or public health problem • “Documented” Needs: Meet CWNS documentation criteria and fall within CWNS Categories • “Official” Needs: The subset of documented needs that are publicly owned treatment works as noted in Clean Water Act Section 516(B)(1)(b) • “Unofficial” Cost Estimates: Costs that are not included in EPA’s needs, because they do not meet CWNS documentation criteria. Such estimated are entered and used for State’s purposes only.

11. Official NeedsCWNS 2012 Wastewater Categories I: Secondary wastewater treatment II: Advanced wastewater treatment III-A: Infiltration/inflow correction III-B: Sewer replacement/rehabilitation IV-A: New collector sewers appurtenances IV-B: New interceptor sewers and appurtenances V-A: Combined sewer overflow correction -- Traditional Infrastructure V-B: Combined sewer overflow correction -- Green Infrastructure X: Recycled water distribution

12. Official Needs CWNS 2012 Stormwater Categories VI: Stormwater Management programs* VI-A: Stormwater Conveyance Infrastructure VI-B: Stormwater Treatment Systems VI-C: Green Infrastructure VI-D: General Stormwater Management * Pre-2008 needs only.

13. Documented NeedsCWNS 2012 Nonpoint Source and Decentralized Wastewater Treatment Categories VII-A: Nonpoint Source (NPS) Control Agriculture (cropland) VII-B: NPS Agriculture (animals) VII-C: NPS Silviculture VII-E: NPS Ground Water Protection VII-F: NPS Marinas VII-G: NPS Resource Extraction VII-H: NPS Brownfields VII-I: NPS Storage Tanks VII-J: NPS Sanitary Landfills VII-K: NPS Hydromodification VII-M: NPS Other Estuary Management Activities XII: Decentralized wastewater treatment systems

14. CWNS Needs Category Changes • Combine Sewer Overflow Correction now has two sub-categories • These categories include needs and costs to prevent or control the periodic discharges of mixed stormwater and untreated wastewater (combined sewer overflows) that occur when the capacity of a sewer system is exceeded during a wet weather event. • V-A:Traditional infrastructure (pipes, storage, etc.) • All current CSO needs will be considered this category • V-B: Green infrastructure (rain gardens, swales, etc.)

15. CWNS Needs Category Changes • Energy Efficiency -- The capital costs to implement energy efficiency measures at a facility. • Indicate the % of needs for Energy Efficiency within allowable 2012 categories • e.g. 10% of Category I costs are for energy efficiency • Not required to link to water quality or public health benefit • Valid facility types: treatment plants, pump stations, stormwater types, collection systems • New Change Type: Improve energy efficiency • Documentation of energy and other operational efficiencies (reduced need for chemical or O&M costs) will be sufficient to document need for projects in CWNS 2012.

16. CWNS Needs Category Changes • Climate Change – The capital costs to mitigate the impacts (e.g. floods, hurricanes) of climate change at a facility • Indicate the % of needs for Climate change within allowable 2012 categories • Need to link to water quality or public benefit not required, but the link to climate change must be explicit in documentation. Assumptions about the impacts of climate change will not be accepted. • Valid facility types: treatment plant, collection systems, pump stations, stormwater management types, nonpoint source types • New Change Type: Climate Change Adaptation • If this is selected, supporting documents must be submitted for review (non-footnotable)

17. 3) Needs Eligibility

18. “Official Needs” Eligibility Criteria • Description of the water quality or public health problem • Location of the problem • Solution to the problem • Cost of the solution • Basis for the cost • Total cost • Current Documentation Needs Costs

19. 1. Description of the water quality or public health problem • Water quality impairment or potential source of impairment. • Specific pollutant source information. • General statements about water quality impairment do not meet this criterion. • Examples: permit violations, more stringent permit requirements, discharge to impaired waters.

20. 2. Location of the problem 1Address is not required for the following wastewater Facility Types: Collection: Combined Sewers, Collection: Separate Sewers, Collection: Interceptor Sewers, Collection: Pump Stations, and Recycled Water Distribution. 2 Indicate one, several, or all cities, towns and/or unincorporated areas in a county. 3 OWTS can occur in all or a portion of towns and/or areas selected.

21. Location of the problem • For all types facilities/ projects: • Primary County • Primary Watershed • Primary Congressional District

22. 3. Solution to the problems • Specific pollution control measures or BMPs to address the problem. • If applicable, the number of units needed to address the problem must be clearly documented.

23. 4. Cost of the solution • The capital cost to implement each pollution control measure or BMP. • General estimates for the problem area are not permitted; only site-specific data information is acceptable to generate the costs. • Costs entered in CWNS Data Entry Portal must be adjusted downward from document costs to reflect known funding since the document date.

24. 5. Basis for the cost • The source of the costs for each solution. • Examples: engineer’s estimate, facility plan, cost of comparable practices, estimates from equipment suppliers, cost curves • Detailed information on documentation sources will be provided in the Documentation Rules Web Seminar • 11/22/10 @ 2:00 pm ET • 12/1/10 @ 1:00 pm ET

25. 6. Total Cost • The total capital costs for all pollution control measures and BMPs documented for a facility • All costs will be automatically converted from documented costs to January 1, 2012 dollars using the cost base date entered into the CWNS Data Entry Portal

26. 7. Current Documentation • When the total needs for the facility/project: • >$30 Million: January 1, 2006, or more current • <$30 Million: January1, 2002, or more current

27. 4) SRF Eligibility and Audits

28. SRF Eligibility • No changes from 2008 • During CWNS data entry, states identify the percentage of each need that is CWSRF eligible according to National CWSRF eligibility rules

29. Example • Facility Plan for a Category II Advanced Treatment process estimates $10 million in total costs. • $1 million of the cost is associated with land not integral to the treatment process and is therefore not CWSRF eligible. • State would identify 90% of this need as CWSRF eligible

30. SRF Eligibility: Audit Process • Contractor verifies CWSRF eligibility status designations by reviewing a sample of the documents. • CWSRF Panel reviews contractor’s report and makes final eligibility decisions. States have opportunity to respond. • Panel is composed of 3 CWSRF staff (HQ & regions) • Preparation of an Audit Report. • After all decisions and appeals are finalized • Shows percents that States correctly identified as CWSRF eligible for each category • Included as an Appendix of the Report to Congress

31. Common Issues • For land purchases, the land must be integral to the treatment process to be SRF eligible • Laterals are not SRF eligible unless they are publicly owned • Salaries are not SRF elgible

32. Resources • Consult with State CWSRF personnel • Consult with National CWSRF policy memos, questions and answers, and factsheets • Linked from CWNS 2012 Planning web page (http://water.epa.gov/scitech/datait/databases/cwns/plan.cfm) • Consult with the CWSRF Regional Coordinator who may consult with the Headquarters CWSRF Branch.

33. Questions?