Presenter:Karen Fligger, EPA HQ

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Session Overview1) Introduction to CWNS2) Needs Definitions and Categories3) Needs Elgibility4) SRF Eligibility and Audit

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What is the CWNS?Assessment of capital needs to meet the Clean Water

Act’s (CWA) water quality goalsJoint effort by EPA, States, & Local organizationsEvery 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

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Clean Water Act (CWA) AuthorityCWA 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) excerptAllotments…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.

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Data is entered at facility/project levelTreatment plantCollection system (combined & separate)Stormwater management projectCombined sewer overflow (CSO) control projectRecycled water distribution facilityDecentralized wastewater treatment projectNon-point source pollution control projectPump Station

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Information collected includes:Estimated needs (costs) Documentation outlining needs & costsLocation and contact informationPermit informationTreatment plant population served, flow, effluent, and

discharge informationDecentralized and collection system population servedUnit Process and Best Management Practices

Additional BackgroundEPA’s CWNS website: epa.gov/cwns

Under 2012 Planning, links to the CWNS 101 webinar, presentation, and FAQ

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Needs DefinitionsNeeds: 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.

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I: Secondary wastewater treatmentII: Advanced wastewater treatmentIII-A: Infiltration/inflow correctionIII-B: Sewer replacement/rehabilitation IV-A: New collector sewers appurtenancesIV-B: New interceptor sewers and appurtenancesV-A: Combined sewer overflow correction

-- Traditional Infrastructure

V-B: Combined sewer overflow correction -- Green Infrastructure

X: Recycled water distribution

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VI: Stormwater Management programs*VI-A: Stormwater Conveyance InfrastructureVI-B: Stormwater Treatment SystemsVI-C: Green InfrastructureVI-D: General Stormwater Management

* Pre-2008 needs only.

Documented Needs

CWNS 2012 Nonpoint Source and Decentralized Wastewater Treatment Categories

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VII-A: Nonpoint Source (NPS) Control Agriculture (cropland)VII-B: NPS Agriculture (animals)VII-C: NPS SilvicultureVII-E: NPS Ground Water Protection VII-F: NPS MarinasVII-G: NPS Resource ExtractionVII-H: NPS BrownfieldsVII-I: NPS Storage TanksVII-J: NPS Sanitary LandfillsVII-K: NPS HydromodificationVII-M: NPS Other Estuary Management ActivitiesXII: Decentralized wastewater treatment systems

CWNS Needs Category ChangesCombine Sewer Overflow Correction now has two sub-

categoriesThese 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.)

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CWNS Needs Category ChangesEnergy 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 benefitValid facility types: treatment plants, pump stations, stormwater

types, collection systemsNew Change Type: Improve energy efficiencyDocumentation 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.

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CWNS Needs Category ChangesClimate Change – The capital costs to mitigate the impacts

(e.g. floods, hurricanes) of climate change at a facilityIndicate 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)

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“Official Needs” Eligibility Criteria1. Description of the water quality or

public health problem2. Location of the problem3. Solution to the problem4. Cost of the solution5. Basis for the cost6. Total cost7. Current Documentation

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Needs

Costs

1. Description of the water quality or public health problemWater 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.

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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.

Location of the problemFor all types facilities/ projects:

Primary CountyPrimary WatershedPrimary Congressional District

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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.

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4. Cost of the solutionThe 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.

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5. Basis for the costThe 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

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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

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7. Current Documentation When the total needs for the facility/project:

>$30 Million: January 1, 2006, or more current <$30 Million: January 1, 2002, or more current

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SRF EligibilityNo changes from 2008During CWNS data entry, states identify the percentage

of each need that is CWSRF eligible according to National CWSRF eligibility rules

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ExampleFacility 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

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SRF Eligibility: Audit ProcessContractor 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

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Common IssuesFor land purchases, the land must be integral to the

treatment process to be SRF eligibleLaterals are not SRF eligible unless they are publicly

ownedSalaries are not SRF elgible

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ResourcesConsult with State CWSRF personnelConsult with National CWSRF policy memos, questions

and answers, and factsheetsLinked 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.

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