According to Missouri Revised Statutes section 644.145, RSMo, the Missouri Department of Natural Resources must make a “finding of affordability” on the costs to be incurred and the impact of any rate changes on ratepayers when either of the following situations occur:

  • Issuing wastewater permits that include a new requirement for discharges from publicly owned combined or separate sanitary or storm sewer systems or publicly owned treatment works, or
  • Enforcing provisions of Chapter 644, RSMo or the federal Water Pollution Control Act, 33 U.S.C. 1251 et seq., pertaining to any portion of a publicly owned combined or separate sanitary or storm sewer system or [publicly owned] treatment works.

A "finding of affordability" is a statement as to whether an individual or a household receiving an income amount equal to or lower than the median household income for the applicant community would be required to make unreasonable sacrifices in the individual's or the household's essential lifestyle or spending patterns or undergo hardships in order to make the projected monthly payments for sewer services. Affordability findings are based on reasonably verifiable data and include an assessment of affordability with respect to persons or entities affected. Each year the department is required to produce and submit Finding of Affordability Annual Report about the findings of affordability completed in the previous calendar year. 

Prescriptive formulas and measures used in determining financial capability, affordability and thresholds for expenditure, such as median household income, are not the only indicator of a community's ability to implement control technology. The department uses several tools to make affordability findings, which are described below.

Affordability Prescreening Tool

The Affordability Prescreening Tool is a socioeconomic database, mainly designed to assist department staff in conducting affordability findings. The data is collected from the U.S. Census Bureau and U.S. Bureau of Labor Statistics and includes population, median household income, per capita income, median age, unemployment rate, poverty level, food stamps reception and consumer price indices. Data is provided for various administrative units including the United States, the State of Missouri, all 114 Missouri counties and all 1,039 Missouri communities for the years 1990, 2000, 2010 and annually beginning in 2011.


The Cost Analysis for Compliance (CAFCom) was developed by the department and estimates the potential cost for publicly-owned treatment works to comply with new requirements in a permit. The results of the CAFCom are used to determine an adequate compliance schedule for the permit that may mitigate the financial burden of new permit requirements. The department must consider eight criteria presented in section 644.145 RSMo, to evaluate the cost associated with new permit requirements.

  1. A community's financial capability and ability to raise or secure necessary funding.
  2. Affordability of pollution control options for the individuals or households at or below the median household income level of the community.
  3. An evaluation of the overall costs and environmental benefits of the control technologies.
  4. Inclusion of ongoing costs of operating and maintaining the existing wastewater collection and treatment system, including payments on outstanding debts for wastewater collection and treatment systems when calculating projected rates.
  5. An inclusion of ways to reduce economic impacts on distressed populations in the community, including but not limited to low- and fixed-income populations. This requirement includes but is not limited to:
    • Allowing adequate time in implementation schedules to mitigate potential adverse impacts on distressed populations resulting from the costs of the improvements and taking into consideration local community economic considerations and
    • Allowing for reasonable accommodations for regulated entities when inflexible standards and fines would impose a disproportionate financial hardship in light of the environmental benefits to be gained.
  6. An assessment of other community investments and operating costs relating to environmental improvements and public health protection.
  7. An assessment of factors set forth in the United States Environmental Protection Agency's guidance, including but not limited to the "Combined Sewer Overflow Guidance for Financial Capability Assessment and Schedule Development" that may ease the cost burdens of implementing wet weather control plans, including but not limited to small system considerations, the attainability of water quality standards, and the development of wet weather standards.
  8. An assessment of any other relevant local community economic condition.

For additional information about CAFComs, please contact the Water Protection Program's Operating Permits Section at 800-361-4827 or 573-751-6825.


The department uses CapdetWorks software to estimate the cost for reconstruction of a treatment plant. CapdetWorks is a preliminary design and costing software program developed by Hydromantis Environmental Software Solutions Inc. This program is for wastewater treatment plants that use national indices, such as the Marshall and Swift Index and Engineering News Records Cost Index, for pricing in developing capital, operating, maintenance, material and energy costs for each treatment technology.

The department uses CapdetWorks to estimate costs of upgrading to meet new permit requirements in CAFComs. The estimated costs are expected to be higher than actual costs since the program works from national indices and each community is unique in its budget commitments and treatment design. CapdetWorks provides a cost estimate based on national averages, not the site-specific conditions of a community. The design parameters are for larger facilities, with flows greater than most Missouri facilities are designed for. The department verifies cost estimates through tracking actual costs from submitted facility plans, engineering reports, bid documents and loan closures. This verification process allows the department to track costs to see if the assumptions from CapdetWorks are appropriate for Missouri.

For additional information about CapdetWorks, please contact the Water Protection Program's Engineering Section at 800-361-4827 or 573-751-6621.

Financial Questionnaire

Financial Questionnaire MO 780-2511 is a required attachment to the permit renewal application for publicly-owned treatment works. Along with the Community Supplemental Survey, it collects information on the sustainability and financial capability of the community. Examples of information requested are the “current monthly residential sewer rates” and “property tax collection rate in the municipality.”

For assistance in completing the Financial Questionnaire, please contact the Water Protection Program's Operating Permits Section at 800-361-4827 or 573-751-6825.


The State of Missouri contracted with Wichita State University to complete the Rural Missouri Sustainability Assessment Tool (MoSAT). This assessment tool uses statistical modeling analysis of factors associated with each rural Missouri community to predict rural Missouri community populations and future sustainability changes in each community. A stepwise regression model that was applied produced 19 individual sustainability factors with statistically significant coefficients.

  1. Change in the population group aged 18 to 29 years from 2000 to 2010
  2. Change in the population group aged 50 and over from 2000 to 2010
  3. Change in the number of persons employed in construction from 2000 to 2010
  4. Change in the number of public assistance income recipients from 2000 to 2010
  5. Change in the number of bachelor’s or higher degree recipients from 2000 to 2010
  6. Change in the number of persons employed in entertainment, recreation and food service from 2000 to 2010
  7. Change in the number of retirement income recipients from 2000 to 2010
  8. Change in the number of Social Security income recipients from 2000 to 2010
  9. Change in the number of persons employed in professional services, scientific and management from 2000 to 2010
  10. Change in the number of high school graduates from 2000 to 2010
  11. Change in the number of persons employed in manufacturing from 2000 to 2010
  12. Change in the number of persons employed in finance, insurance and real estate from 2000 to 2010
  13. Change in the number of persons employed in wholesale trade from 2000 to 2010
  14. Change in the number of persons employed in information technologies from 2000 to 2010
  15. Change in population density (per square mile) from 2000 to 2010
  16. Natural Amenity Scale Rank (1=Low, 7=High)
  17. Change in the number of rural immigrants from 2000 to 2010
  18. Change in the number of persons migrating into the town or village from 2006 to 2010
  19. Change in the number of persons employed in retail trade from 2000 to 2010

These sustainability factors are valid predictors of rural population change in Missouri and were incorporated into the assessment tool along with overall population changes from 2000 to 2010. The model establishes a hierarchy of the predictive factors, which allows it to place a weighted value on each factor. A total of 745 rural towns and villages in Missouri received a weighted value for each of the predicting factors. The weighted values for each rural community were then added together to determine an overall decision score, which was then divided into five categories. Each town was assigned to a different categorical group based on the overall decision score.

  • 1-2 - Likely to see sustainability challenges through time
  • 3 - Sustainable over time but a small change in the social or economic conditions could easily decrease or increase sustainability challenges
  • 4-5 - Shows progress and growth and is likely sustainable over time