Presenter: Karen Fligger, EPA HQ 1

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

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“ Official Needs” Eligibility Criteria 1. Description of the water quality or public health problem 2. Location of the problem 3. Solution to the problem 4. Cost of the solution 5. Basis for the cost 6. Total cost 7. Current Documentation 4 Needs Costs

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 5

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 6

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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 8

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/

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% 10

Documents with no specific emphasis on the type of need DocumentDoc Type Intended Use Plan / Project Priority List1 State and Federal Loan and Grant Applications2 CWSRF Loan Applications3 ARRA Loan Applications 93 GPR Business Cases 94 Non-governmental Grant Applications4 Cost of Previous Comparable Construction5 State-Approved Area-wide or Regional Basin Plan6 State-Approved Local Comprehensive Water and Sewer Plan7 Total Maximum Daily Load (TMDL)8 National Estuary Program Comprehensive Conservation and Management Plan 9 Nutrient Criteria Studies10 Impaired Waters or TMDL Listing11 State Needs Surveys & other State forms12 Excel Spreadsheet Annotations96 EPA-HQ Approved99 11

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. 12

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. 13

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

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

GPR Business Cases (94) 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. 16 NEW!

Non-governmental Grant Applications (4) Need: Yes Costs: Yes Footnotable: No Need: Signatures, description of problem/solution. Cost: cost estimate from engineer. 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) Need: N/A Costs: N/A Footnotable: No Alternative to inserting all the annotations within a document 24 NEW!

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 Document Doc Type Capital Improvement Plan (CIP)20 Facility Plan21 Preliminary Engineer's Estimate22 Final Engineer's Estimate23 Sewer System Evaluation Documents24 Diagnostic Evaluation25 Sanitary Survey26 State-Approved Municipal Wasteload Allocation Plan27 New State or Federal Regulation28 Future or Proposed Municipal, State, or Federal Regulation29 Administrative Orders, Court Orders, or Consent Decrees30 NPDES or State Permit Requirement (with Schedule)31 CSO Long-Term Control Plan (LTCP)32 Approved CSO Long-Term Control Plan (LTCP)33 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

Future or Proposed Municipal, State, or Federal Regulation (29) Need: “unofficial cost estimates” only Costs: No Footnotable: No Indication of affected facilities is needed. 32

Administrative Orders, Court Orders, or Consent Decrees (30) Need: Yes Costs: No Footnotable: No 33

NPDES or State Permit Requirement (with Schedule) (31) Need: Yes Costs: No Footnotable: Yes 34

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. 35

CSO LTCP- EZ Template 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 Can only be used when a standard LTCP is not available 36 NEW!

CSO LTCP- EZ Template 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 37 NEW!

Documents with Emphasis on Nonpoint Source (NPS) Needs Document Doc Type Watershed-Based Plans40 Section 319 Funded or EPA Reviewed Watershed-Based Plans41 Approved State Annual 319 Workplans42 Approved State 319 Project Implementation Plans43 NPS Management Program/Assessment Report44 NPS Management Program/Ground Water Protection Strategy Report45 NPS Management Program/Wellhead Protection Program and Plan46 NPS Management Program/Delegated Underground Injection Control Program Plan 47 Source Water Assessment/Source Water Protection Plans48 NRCS Conservation Plans and Farm Plans49 Electronic Field Office Technical Guide (eFOTOG)50 State/Federal Agricultural Cost-Share Program Cost Tables51 Professional Appraisals52 38

Watershed-Based Plans (40) Need: Yes Costs: Yes Footnotable: No 39

Section 319 Funded or EPA Reviewed Watershed-Based Plans (41) Need: Yes Costs: Yes Footnotable: Yes 40

Source Water Assessment/Source Water Protection Plans (48) Need: Yes Cost: No Footnotable: No Use the system or town specific assessment, not the statewide summary. 41

NRCS Conservation Plans and Farm Plans (49) Need: Yes Cost: No* Footnotable: No Areas needing treatment may not be water quality related. 42

Electronic Field Office Technical Guide (eFOTOG) (50) Need: No* Cost: Yes Footnotable: No Areas needing treatment may not be water quality related. 43

State/Federal Agricultural Cost- Share Program Cost Tables (51) Need: No Cost: Yes Footnotable: No These unit costs can be used to estimate the total cost of a project. 44

Professional Appraisals (52) Need: No Cost: Yes Footnotable: No 45

Needs for Small Communities Communities with populations of fewer than 10,000 persons. Use only if other acceptable documentation types are not available. DocumentDoc Type Small Community Needs Form71 Information from an Assistance Provider72 CUPSS (Check Up Program for Small Systems) Wastewater Asset Management Plan 73 46

Small Community Needs Form (71) Need: Yes Costs: Yes Footnotable: Yes Local signatures are required. Special signature requirements for communities <3,500 47

Information from an Assistance Provider (72) Need: Yes Costs: No Footnotable: No Local official and provider signatures must be included. 48

CUPSS (Check Up Program for Small Systems) Wastewater Asset Management Plan (73) 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. dex.cfm dex.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 49 NEW!

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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 51

Innovative Needs & Costs Documentation Schedule Written proposals can be submitted from November 1, 2010 through March 30, 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, Final evaluation of all Innovative Methods will occur by June 30,

Innovative Needs & Costs Documentation State CWNS coordinators should provide their 1-2 page proposed methodology to EPA 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). 53

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 54

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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 56

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 57

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

Example Document title, date, and author are clear No annotations needed 59

Tag: Example 60 CWNS Number Category I and II costs 70% Category I: 14,871,765 30% Category II: 6,373,614 CWNS Number Need Justifcation CWNS Number , Base Date CWNS Number Category II costs Category II: 9,500,000

Documents Submitted in Hard Copy Label the document with the CWNS Number(s) Highlight the document title, date, and author. Highlight and flag the page or pages that contain the information substantiating: Water quality or public health problem Recommended alternative (if more than one is presented) Associated costs and category(ies) of costs. Base date for costs. All relevant section must be sent to EPA Documents that are not correctly annotated will not be reviewed. States will be informed of the situation but documents will not be returned 61

Summary Spreadsheet Alternative to inserting all annotations within a document The following fields are required in the spreadsheet: Document name Document type Facility/Project Name CWNS number Project ID number used in document (if applicable) Amount of needs by category Total needs (calculated by spreadsheet and left as formula) Page number(s) of needs justification (the justification must still be highlighted in the document) Page number(s) of cost information The above information should be listed in the order it appears in the document. Uploaded to the DEP as document type

Contacts and More Information Karen Fligger, US EPA or Includes list of state & regional coordinators News about CWNS 2012 Access to CWNS data and Reports to Congress 63