Clean Watersheds Needs Survey (CWNS) 2012 Documentation Rules

1. Clean Watersheds Needs Survey (CWNS) 2012Documentation Rules Presenter: Karen Fligger, EPA HQ

2. Session Overview • CWNS 2012 Documentation Criteria Recap • Pre-Approved Document Types • Innovative Needs and Costs Documentation • Requirements for Submitting Documents

3. 1) CWNS 2012 Documentation Criteria Recap

4. “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

5. Footnotable Definition • A document is footnotable if a facility’s total needs are less than $30 million (2012 dollars) and is pre-approved as footnotable • Footnotable documents: • Must be retained in state’s files rather than being sent to EPA • Are audited; the portion to be audited will be requested at end of data entry

6. Needs, Costs or Both • Documents may be used to justify just needs, just costs, or both needs and costs • If a document has been pre-approved to only justify needs, the DEP will restrict entering costs for the document

7. 2) Pre-Approved Document Types

8. Document Types • The documents are grouped into the following five sections: • Documents with no specific emphasis • Wastewater treatment • Non-point source (NPS) • Stormwater • Small communities

9. Guidelines for all Documents • Recommended Alternatives: • If one alternative is recommended in the documented, the recommended alternative’s costs must be used. • If there is not a recommended alternative, the average cost across all alternatives must be used. • All documented costs must be adjusted to reflect known funding that occurred between the document date and 1/1/2012.

10. Most Commonly Used Documents for CWNS 2008 (as % of need) • Capital Improvement Plan (CIP) (20)- 36.1% • Facility Plan (21)- 14.3% • CSO Long Term Control Plan (32)- 6.7% • Intended Use Plan (IUP) (01) – 6.4% • Preliminary Engineer’s Estimate – 4.8%

11. Documents with no specific emphasis on the type of need

12. Intended Use Plan / Project Priority List (1) • Need: Yes • Costs: Yes • Footnotable: Yes • To use an IUP or PPL to document needs and costs, states must include documentation which identifies projects the state intended to fund in the year related to the IUP.

13. State and Federal Loan and Grant Applications (2) • Need: Yes • Costs: Yes • Footnotable: Yes • All supporting documentation to the grant application must be submitted • Need: Signatures, description of problem/solution. • Cost: cost estimate from engineer.

14. CWSRF Loan Applications (3) • Need: Yes • Costs: Yes • Footnotable: Yes

15. ARRA Loan Applications (93) NEW! • Need: Yes • Costs: Yes • Footnotable: Yes • These documents are similar to CWSRF Loan Applications

16. GPR Business Cases (94) NEW! • Need: Yes • Costs: Yes • Footnotable: Yes • CWSRF Green Project Reserve (GPR) Business Cases that have been approved by EPA Regions or by States can be used to document needs and costs.

17. Cost of Previous Comparable Construction (5) • Need: No • Costs: Yes • Footnotable: No • The approach used to create each document must be pre-approved by EPA headquarters before entering the information into the system.

18. Cost of Previous Comparable Construction (5) • Cost must be based on at least 3 bid or completed projects that are: • Recent: within the last two years. • Similar in size, scope, and geographic area. • Size: plus or minus 25 percent. • Generally in the same county or watershed. • Certain specific rules apply to some Categories of cost.

19. Impaired Waters or TMDL Listing (11) • Need: Yes • Costs: No • Footnotable: N/A • States will directly link the facilities to the database of impaired waters based on the discharge location. • There will be no need to submit documentation.

20. State Needs Surveys & Other State Forms (12) • Need: Yes • Costs: No (except for small communities) • Footnotable: Yes • Must be pre-approved by EPA headquarters prior to use.

21. State Needs Surveys & Other State Forms (12)

22. State Needs Surveys & Other State Forms (12) • Cost Justification - Population <10,000: • Costs by engineer or engineer circuit rider. • Other acceptable documentation types not available. • State project staff signature. • Cost Justification - Population <3,500: • State registered engineer or circuit rider sign the cost. • Requires EPA HQ pre-approval, done on a community by community basis.

23. Excel Spreadsheet Annotations (96) NEW! • Need: N/A • Costs: N/A • Footnotable: No • Alternative to inserting all the annotations within a document

24. EPA-headquarters Approved (99) •  Used for unique documents that meet all criteria but are not listed as a Pre-Approved Document • States must send at least two examples to EPA headquarters for approval prior to data entry. • Document type 99 will not be available to select in DEP until approved by EPA

25. Documents with Emphasis on Wastewater Facility Needs

26. Capital Improvement Plan (CIP) (20) • Need: Yes • Costs: Yes • Footnotable: Yes • Inclusion in a CIP is not by itself a justification for need. It must contain a satisfactory description of an existing problem or additional documentation should be provided.

27. Facility Plan (21) • Need: Yes • Costs: Yes • Footnotable: Yes • Use recommended alternative only.

28. Preliminary Engineer's Estimate (22) • Need: Yes • Costs: Yes • Footnotable: No • Preliminary Engineering Reports (PER) completed for USDA Rural Utility Service loan/grant applications are included in this category if they are not attached to the application.

29. Final Engineer's Estimate (23) • Need: Yes • Costs: Yes • Footnotable: Yes • Lowest responsive, responsible bids are equivalent to Final Engineer's Estimates.

30. New Municipal, State, or Federal Regulation (28) • Need: Yes • Costs: No • Footnotable: No • Indication of affected facilities is needed.

31. Administrative Orders, Court Orders, or Consent Decrees (30) • Need: Yes • Costs: No • Footnotable: No

32. NPDES or State Permit Requirement (with Schedule) (31) • Need: Yes • Costs: No • Footnotable: Yes

33. CSO Long Term Control Plans (LTCP) CSO LTCP (32) Approved CSO LTCP (33) • Need: Yes • Costs: Yes • Footnotable: No • Annual CSO Reports for facilities without approved LTCPs are considered this document type. • Need: Yes • Costs: Yes • Footnotable: Yes • Annual CSO Reports for facilities with approved LTCPs are considered this document type.

34. CSO LTCP- EZ Template NEW! • Template is a planning tools for small communities (as defined by the CSO program as population 75,000 or less) who must develop LTCPs to address CSOs • Template available at www.epa.gov/npdes/cso • Can only be used when a standard LTCP is not available

35. CSO LTCP- EZ Template NEW! Signed Draft (34) Approved (35) • Need: Yes • Costs: Yes • Footnotable: No • Must be accompanied by signed cover sheet to be provided by EPA • Need: Yes • Costs: Yes • Footnotable: Yes • Must be accompanied by documentation of state or EPA approval

36. Documents with Emphasis on Nonpoint Source (NPS) Needs

37. Needs for Small Communities • Communities with populations of fewer than 10,000 persons. • Use only if other acceptable documentation types are not available.

38. Small Community Needs Form (71) • Need: Yes • Costs: Yes • Footnotable: Yes • Local signatures are required. • Special signature requirements for communities <3,500

39. Information from an Assistance Provider (72) • Need: Yes • Costs: No • Footnotable: No • Local official and provider signatures must be included.

40. CUPSS (Check Up Program for Small Systems) Wastewater Asset Management Plan (73) NEW! • Need: Yes • Costs: Yes • Footnotable: No • This document can only be used if the local community is using CUPSS • CUPSS is a free, easy-to-use, asset management tool for small drinking water and wastewater utilities. • http://water.epa.gov/infrastructure/drinkingwater/pws/cupss/index.cfm • A cover sheet with signatures from local official to indicate the accuracy of the information and that the community is using CUPSS for asset management will be required

41. 3) Innovative Needs and Costs Documentation

42. Innovative Needs & Costs Documentation • Innovative methods can be used to document needs and costs with pre-approval from EPA headquarters. • Approved innovative approaches will be documented and shared with other States. • Will be posted at CWNS  >  Library  >  2012 Innovative Methods 

43. Innovative Needs & Costs Documentation Schedule • Written proposals can be submitted from November 1, 2010 through March 30, 2012. • EPA will provide the State CWNS coordinator initial feedback within three weeks. • Written proposals to use another State’s innovative method must be submitted by April 30, 2012. • Final evaluation of all Innovative Methods will occur by June 30, 2012.

44. Innovative Needs & Costs Documentation • State CWNS coordinators should provide their 1-2 page proposed methodology to EPA (cwns@epa.gov). • Proposal should include: • Category of need • Whether the proposed methodology will be used for documenting needs and/or costs • Attach sample surveys, spreadsheets, documentation, etc. when appropriate. Describe any external data sets that you plan to use (e.g., land cover).

45. Summary of Approved CWNS 2008 Proposals • Decentralized (7) • ME, FL, MO, NY, OH, NJ, CT • Nonpoint Source (4) • TX, MI, MN, IA • Stormwater (3) • OH, MN, NJ • Small Communities (4) • NY, AR, MA, NC • Wastewater (6) • MO, NY, PA, MS, MA, NJ • Materials from these are available in CWNS Portal Library at: My Workspaces  >  CWNS  >  Library  >  ZZZ - Archives, CWNS 2008  >  Needs Documentation Support  >   Innovative Methods Application

46. 4) Requirements for Submitting Documents

47. Document Submittal • Two options: • Documents can be submitted either electronically via the DEP (preferred method) • Hard copy via mail or courier • Both electronic and hard copy documents must be annotated

48. Annotating Documents Submitted Electronically • If the first page does not clearly identify the document title, date, and author, these items must be annotated. • Indicate the sections(i.e., annotate the paragraphs) that contain the information describing: • The water quality or public health problem(i.e., needs justification) • The recommended alternative (if more than one is presented) • Associated costs and category(ies) of costs. Costs should be labeled with the same cost category(ies) entered into the DEP. • Base date for the costs

49. Annotating Documents Submitted Electronically (cont.) • If the document is only used for one facility the comment must only include the type of information presented (e.g., need justification, recommended alternative, cost category). • If the document is used for multiple facilities the comments must include the facility/project’s CWNS number in addition to the type of information presented. • User’s initials are not required for CWNS 2012.

50. Example • Document title, date, and author are clear • No annotations needed