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  1. Home
  2. Water Quality Standards: Regulations and Resources

Individual Lagoon Tool for Supporting Ammonia WQS Variances

The Individual Lagoon Tool (ILT) is a screening-level economic analysis tool to help determine whether a water quality standards (WQS) variance for ammonia based on “substantial and widespread economic and social impacts” (i.e., 40 CFR 131.10(g)(6) or “Factor 6”) may be appropriate. This tool is specific to lagoon wastewater treatment systems with design flow between 0.01 and 2 million gallons per day (MGD).

The tool combines a preliminary analysis of the engineering costs for installing lagoon replacements or modifications that could provide adequate treatment to allow the lagoon wastewater treatment system to meet the applicable ammonia criterion along with the socioeconomic analyses described in the following:

  • 1995 Interim Economic Guidance for Water Quality Standards: Workbook (pdf) (2.29 MB, March 1995, EPA-823-B-95-002)
  • Clean Water Act Financial Capability Assessment Guidance (2024 Revision) (pdf) (1.19 MB)  ("FCA Guidance")

Socioeconomic analyses recommended in the guidance documents above inform whether a community will likely incur substantial economic and social impacts. These analyses include the Municipal Preliminary Screener (MPS), the Secondary Test, the Lowest Quintile Poverty Indicator (LQPI) Score, and a Financial Alternatives Analysis (FAA).

This tool is applicable to lagoon wastewater treatment systems within the 50 U.S. states, District of Columbia, and Puerto Rico, including Tribal lands within those locations. Communities on Tribal lands should work with their EPA Regional Contact to potentially identify economic data that may better characterize the community than data available in the Individual Lagoon Tool. Additionally, communities in the U.S. Virgin Islands, Northern Mariana Islands, Guam, and American Samoa should work with their EPA Regional Contact to develop an appropriate analysis, rather than use this tool, because U.S. Census data and engineering cost data are not available for those territories.

On this page:

  1. How to Use This Tool
  2. Use This Tool
  3. Location
  4. Existing Pollution Control
  5. Proposed Pollution Control
  6. Municipal Preliminary Screener
  7. Secondary Test
  8. Lowest Quintile Poverty Indicators
  9. Summary of Tool Outputs
  10. Next Steps

How to Use This Tool

  1. Select the state where the community is located and then select the Type of Jurisdiction (i.e., county, city/town, or zip code) and the corresponding location that best represents the lagoon's service area. Demographic and economic data for that location will then be automatically retrieved from the US Census American Community Survey (the Census).
  2. Review the retrieved Census data. If you have more accurate data, click the check box labeled alternate value for the relevant field and enter the more accurate data. Please include the data's source in the accompanying explanation field.
  3. Enter data into the Existing Pollution Control, Proposed Pollution Control, and Secondary Test sections. Fields with default values are marked with the letter “d”. If you have more appropriate data for your community, please overwrite any default value.
    1. Required data with no defaults include an estimate of existing pollution control costs (e.g., average monthly sewer bill) and the design flow of the lagoon.
    2. Required data with defaults available include the type of lagoon system, influent temperatures, estimated loan duration and interest rate to finance the proposed pollution control project, grant funding, and the percentage of pollution control costs borne by households. Use community-specific data when available to increase the accuracy and utility of the analysis.
    3. Highly encouraged, optional data include community economic data such as debt and property tax information. Use these data to increase the accuracy and utility of the analysis.
  4. In the Results section, indicate whether a Financial Alternatives Analysis was performed.
  5. In the Data and Information Download section, you can copy and paste a summary report into your document.

Your web browser will automatically save the data you enter even if you close the browser. When you return to the tool using the same browser and computer, it will prompt you to either restore the previous data or clear it. (Note: Data stored by the tool reside only on your local computer and are not transmitted to EPA or anywhere else. All data are lost when cleared within your browser).

Symbols

  • d - Data entries for these input fields have default values that may be used if information specific to the community cannot be located. Use community-specific data when available to increase the accuracy and utility of the analysis.
  • i - Click for additional information and instructions regarding the data that should be entered for the field.

Financial Alternatives Analysis

The FCA Guidance recommends performing a Financial Alternatives Analysis (FAA). As noted in the FCA Guidance, an FAA, especially when performed at the beginning of an economic impact analysis for WQS decisions, may help provide the community with a clearer understanding of all costs associated with the implementation of Clean Water Act controls, such as reduced costs associated with low-interest loans, increased revenue from utility fees, or the costs associated with programs that assist low-income households. The ILT inputs that may change based on the results of an FAA include existing pollution control costs, proposed pollution control costs, and secondary test indicators. Including the economic effects of viable financial alternatives will strengthen the demonstration of substantial and widespread economic and social impacts.

The ILT may not capture the economic impacts of some financial alternatives such as those from variable rate structures or customer assistance programs. In that case, you should consider the results of the ILT and the FAA together to evaluate whether economic and social impacts are substantial, as recommended in the FCA Guidance.

Other Important Information

Use of this tool and resulting outputs does not guarantee EPA approval of a WQS variance. This tool does not impose legally binding requirements on the United States Environmental Protection Agency, states, territories, authorized Tribes, or the regulated community, nor does it confer legal rights or impose legal obligations upon any member of the public. The Clean Water Act provisions and EPA regulations implemented by this tool contain legally binding requirements. This tool does not constitute a regulation, nor does it change or substitute for any Clean Water Act provision or EPA regulation. This tool may be revised periodically without public notice. The adoption of a WQS variance is at the discretion of the state, territory, or authorized Tribe. The EPA encourages early and frequent coordination between a state, territory, or authorized tribe and the EPA Region before adopting a WQS variance to provide the best chance that it meets the requirements of the Clean Water Act and its implementing regulations.

Tool Update Year: Cost estimates for proposed pollution control projects and Census economic data are for yr dollars except for Census data associated with zip-code locations. Data associated with Census zip-code locations are for yr because the Census Bureau does not yet provide these data for years after yr.

For any questions on this tool, please contact EPA Office of Water, Office of Science and Technology, Standards and Health Protection Division at (202) 566-1018.


Location Data



Community Data from the US Census Bureau ( )
Population  

Number of Households  

Median Household Income (MHI)  

Upper Limit of Lowest Quintile Household Income  

Percentage of Unemployed Population 16 and Over in Civilian Labor Force  

Percentage of Population with Income Below 200% of Federal Poverty Level  

Percentage of Households Receiving Food Stamps/SNAP Benefits  

Percentage of Vacant Housing Units  

Trend in Household Growth  

Existing Pollution Control

Type and Flow Rate
Type of Lagoon System (Assume facultative if unknown.)
Cost Data
Approach for Estimating the Existing Treatment System's Annual Costs to Households
Annual cost of existing pollution controls:    

Proposed Pollution Control

Treatment Options
Full Replacement of Existing System
Modification of Existing System (Cover is available only if aerated lagoon system)
Key Design Parameters
Financing
No Proposed Options Selected
Annual Cost of Proposed Pollution Control
Treatment Options Annual Cost of Proposed Pollution Control Project to Households Annual Cost of Proposed Pollution Control Project per Household
Sequencing Batch Reactors    
Oxidation Ditch    
Covers (Floating Covers)    

Municipal Preliminary Screener

The Municipal Preliminary Screener (MPS) assesses the impact of the cost to households of the pollution control technology needed to meet water quality-based requirements. The MPS is the cost as a percentage of the median household income (i.e., the ratio of the total per-household costs and the median household income) as follows:

  • Below 1%: little economic impact
  • Between 1% and 2% (inclusively): midrange economic impact
  • Above 2%: large economic impact
 
No Options Selected

Secondary Test

The Secondary Test indicates the community's ability to obtain financing and describes the socioeconomic health of the community. To calculate a score, the test uses up to six indicators that describe the community's pre-compliance debt, socioeconomic, and financial management conditions. The indicators used for the Secondary Score calculation depend, in part, on whether the community is within a state that has statutory limits on property tax collections and/or rates and whether data on the full market value of taxable property are available. Each indicator is scored as weak (1 point), midrange (2 points), or strong (3 points). The Secondary Score, which is an average indicator score, is evaluated as follows:

  • Weak Economy: below 1.5
  • Midrange Economy: between 1.5 and 2.5 inclusively
  • Strong Economy: above 2.5

EPA recognizes that data for all indicators may not be available, especially for some small communities. The tool will still calculate the Secondary Score if some of the indicator fields are left blank. However, EPA encourages users to seek data on as many of the Secondary Test indicators as possible in order to derive a robust Secondary Score.

Enter data for the financial management and existing debt indicators below. Data for the socioeconomic indicators - specifically the community's MHI and unemployment rate - are automatically downloaded from the US Census Bureau as shown in Community Data from the US Census Bureau. The ILT will instead use any data overwritten by the user there.

Financial Management Indicators
Does your state set statutory limits on property tax collections and/or rates?
Are data available on the full market value of taxable property in the community?
Existing Debt Indicators
Secondary Test - Summary
Indicator Score Value
Bond Rating    
Overall Net Debt as % of Full Market Value of Taxable Property    
Unemployment    
MHI    
Overall Net Debt per Capita    
Property Tax Revenues as Percent of Full Market Value of Taxable Property    
Property Tax Collection Rate    
Secondary Score:   

Lowest Quintile Poverty Indicators

The Lowest Quintile Poverty Indicators (LQPIs) is a suite of six indicators for assessing the severity and prevalence of poverty in a community. Per the FCA Guidance, these indicators were selected because they are:

  • readily available from publicly available data sources;
  • clearly defined and understood;
  • simple, direct, and consistent;
  • valid and reliable measures, according to conventional research standards; and
  • applicable for comparative analyses among permittees.

Data for calculating the LQPIs and score are automatically pulled from the US Census Bureau. If you have more accurate data, you can enter it above under Community Data from the US Census Bureau.

The LQPI Score is a weighted average of each LQPI. LQPI #1 (Upper Limit of Lowest Quintile Income) is weighted as 5 while the others are weighted as 1. The LQPI Score is evaluated as follows:

  • High-Impact: below 1.5
  • Medium-Impact: between 1.5 and 2.5 inclusively
  • Low-Impact: above 2.5
Indicator Community Value National Value Community Value Relative to National Value Indicator Score
LQPI #1 Upper Limit of Lowest Quintile Household Income        
LQPI #2 Percentage of Population with Income Below 200% of Federal Poverty Level        
LQPI #3 Percentage of Households Receiving Food Stamps/SNAP Benefits        
LQPI #4 Percentage of Vacant Housing Units        
LQPI #5 Trend in Household Growth        
LQPI #6 Percentage of Unemployed Population 16 and Over in Civilian Labor Force        
Lowest Quintile Poverty Indicator Score :   

Summary of Tool Outputs: Economic Impact

This table combines the Municipal Preliminary Screener and the Secondary Score as recommended in EPA’s 1995 Economic Guidance for Water Quality Standards to determine the Initial Economic Impact, which can be substantial, unclear, or not substantial. This Initial Economic Impact is then combined with the results of the LQPI Score to generate the Expanded Economic Impact result below. This table also reports the estimated ammonia concentrations in winter and summer (i.e., performance) for each pollutant control technology. The estimated total annual cost to the community includes existing pollution control costs combined with each pollutant control technology's estimated cost.

No Options Selected
Did you perform a Financial Alternatives Analysis?
 

As noted in the introductory text, the FCA Guidance recommends that users combine the Expanded Economic Impact result (based on Individual Lagoon Tool inputs that reflect a Financial Alternatives Analysis, as appropriate) with the complete results of a Financial Alternatives Analysis to support a demonstration of substantial economic impacts that would justify a WQS variance. See Exhibit 13 of the FCA Guidance for more information.


Next Steps

Constructing a WQS Variance Using the ILT

Once your ILT analysis is complete, you can copy and paste a summary report for inclusion in the supporting documentation of a WQS variance package. In addition to determining whether the impact is “substantial” (as performed by the ILT), demonstrating the need for a WQS variance using Factor 6 requires a determination of whether the impact is “widespread.” “Widespread impacts” refer to how a substantial impact could affect the community or surrounding area. See the Applications Document for more information on "widespread impacts" and other aspects of preparing a WQS variance demonstration consistent with 40 CFR 131.14 based on the results of this ILT.

Data and Information Download

Click the button below to copy and paste a summary report into your document.


Individual Lagoon Tool for Water Quality Standards Variances - Summary Report

Location

State  
Type of Local Jurisdiction  
Location  

Community Data from the US Census Bureau ([census yr])*

Population  
Number of Households  
Median Household Income (MHI)  
Upper Limit of Lowest Quintile Household Income  
Percentage of Unemployed Population 16 and Over in Civilian Labor Force  
Percentage of Population with Income Below 200% of Federal Poverty Level  
Percentage of Households Receiving Food Stamps/SNAP Benefits  
Percentage of Vacant Housing Units  
Trend in Household Growth  

Existing Pollution Control

Type and Flow Rate

Type of Lagoon System  
Current Design Flow Capacity (MGD)  

Cost Data

Approach for Estimating the Existing Treatment System's Annual Costs to Households  
Year of Data Used for Estimating the Treatment System's Annual Costs  
Average monthly household sewer bill ($/month)  
Annualized capital cost ($/yr)  
Annual O&M cost ($/yr)  
Percentage of existing pollution control costs borne by households  
Annual cost of existing pollution controls:   

Proposed Pollution Control

Treatment Options Selected

Full Replacement of Existing System  
Modification of Existing System (Cover is available only if aerated lagoon system)  

Key Design Parameters

Winter influent temperature (°F)  
Summer influent temperature (°F)  

Financing

Interest rate for financing (%)  
Capital cost to be paid by grants  
Financing period (years)  
Percentage of proposed pollution reduction project costs borne by households  

Annual Cost of Proposed Pollution Control

Insert copy of optsTable

Municipal Preliminary Screener

Summary

Insert copy of optsTable2a

Secondary Test

Financial Management Indicators

Does your state set statutory limits on property tax collections and/or rates?  
Are data available on the full market value of taxable property in the community?  
Property tax revenues ($)  
Full market value of taxable property ($)  
Property tax collection rate (%)  

Existing Debt Indicators

Direct net debt  
Overlapping debt  
Bond rating  

Summary

Insert copy of indicatorsTable
 

Lowest Quintile Poverty Indicators

Insert copy of finCapAnalysisTbl
 

Summary of Tool Outputs: Economic Impact

Insert copy of optsTable4a
Did you perform a Financial Alternatives Analysis?  
 

Related Documentation & Resources

  • The following implementation document for the Small Lagoon Community Economic Streamlining (SLCES) Tool and ILT describes when each tool might be most useful and how to use the tools’ results to construct a WQS variance consistent with the EPA’s WQS regulation.
    • Applying the EPA’s Economic Analysis Tools to a WQS Variance for Ammonia for Small Lagoon Communities (pdf) (1.22 MB, August 2024, 820-B-24-005)
  • Review the EPA’s methodology for developing the cost estimation models and the sources for the performance estimates for the three pollutant control technologies used in the ILT and SLCES Tool.
    • Cost and Performance Estimation Approaches for the Individual Lagoon Tool and Small Lagoon Community Economic Streamlining Tool (pdf) (811.92 KB, March 2025, 820-B-24-003)
 
 
Contact Us to ask a question, provide feedback, or report a problem.
Last updated on April 22, 2025
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