		

Renewal of an 

Information collection request

 for

Regulatory Pilot Projects

OMB Control No. 2010-0026

EPA ICR No. 1755.08

The United States Environmental Protection Agency

September 2007

Table of Contents

  TOC \o "1-2" \h \z \u    HYPERLINK \l "_Toc180381692"  1. 
Identification of the Information Collection	  PAGEREF _Toc180381692 \h 
3  

  HYPERLINK \l "_Toc180381693"  1(a) 	Title and Number of the
Information Collection	  PAGEREF _Toc180381693 \h  3  

  HYPERLINK \l "_Toc180381694"  1(b) 	Short Characterization	  PAGEREF
_Toc180381694 \h  3  

  HYPERLINK \l "_Toc180381695"  2. Need for and Use of the Collection	 
PAGEREF _Toc180381695 \h  4  

  HYPERLINK \l "_Toc180381696"  2(a)	Need/Authority for the Collection	 
PAGEREF _Toc180381696 \h  5  

  HYPERLINK \l "_Toc180381697"  2(b)	Practical Utility/Uses of the Data	
 PAGEREF _Toc180381697 \h  5  

  HYPERLINK \l "_Toc180381698"  3.  Nonduplication, Consultations, and
Other Collection Criteria	  PAGEREF _Toc180381698 \h  6  

  HYPERLINK \l "_Toc180381699"  3(a) 	Nonduplication	  PAGEREF
_Toc180381699 \h  6  

  HYPERLINK \l "_Toc180381700"  3(b)	Public Notice Required Prior to ICR
Submission to OMB	  PAGEREF _Toc180381700 \h  6  

  HYPERLINK \l "_Toc180381701"  3(c)	Consultations	  PAGEREF
_Toc180381701 \h  6  

  HYPERLINK \l "_Toc180381702"  3(d) 	General Guidelines	  PAGEREF
_Toc180381702 \h  6  

  HYPERLINK \l "_Toc180381703"  3(e)	Confidentiality	  PAGEREF
_Toc180381703 \h  6  

  HYPERLINK \l "_Toc180381704"  3(f) 	Sensitive Questions	  PAGEREF
_Toc180381704 \h  7  

  HYPERLINK \l "_Toc180381705"  4. The Respondents and the Information
Requested	  PAGEREF _Toc180381705 \h  7  

  HYPERLINK \l "_Toc180381706"  4(a)	Respondents/NAICS Codes	  PAGEREF
_Toc180381706 \h  7  

  HYPERLINK \l "_Toc180381707"  4(b)	Information Requested	  PAGEREF
_Toc180381707 \h  7  

  HYPERLINK \l "_Toc180381708"  5.  The Information Collected.  Agency
Activities, Collection Methodology, and Information Management.	 
PAGEREF _Toc180381708 \h  8  

  HYPERLINK \l "_Toc180381709"  5(a) 	Agency Activities	  PAGEREF
_Toc180381709 \h  8  

  HYPERLINK \l "_Toc180381710"  5(b)	Collection Methodology and
Information Management	  PAGEREF _Toc180381710 \h  8  

  HYPERLINK \l "_Toc180381711"  5(c)	Small Entity Flexibility.	  PAGEREF
_Toc180381711 \h  9  

  HYPERLINK \l "_Toc180381712"  5(d)	Collection Schedule.	  PAGEREF
_Toc180381712 \h  9  

  HYPERLINK \l "_Toc180381713"  6. Estimating the Burden and the Cost of
the Collection	  PAGEREF _Toc180381713 \h  9  

  HYPERLINK \l "_Toc180381714"  6(a) 	Estimating Respondent Burden and
Cost to State Agencies	  PAGEREF _Toc180381714 \h  9  

  HYPERLINK \l "_Toc180381715"  6(b) 	Estimating Respondent Burden  for
Participating Facilities (Private Entities)	  PAGEREF _Toc180381715 \h 
11  

  HYPERLINK \l "_Toc180381716"  6(c) 	Estimating Agency (EPA) Burden and
Cost	  PAGEREF _Toc180381716 \h  13  

  HYPERLINK \l "_Toc180381717"  6(d)	Estimating the Respondent Universe
and Total Burden and Costs	  PAGEREF _Toc180381717 \h  14  

  HYPERLINK \l "_Toc180381718"  6(e)	Reasons for Burden Hour Change	 
PAGEREF _Toc180381718 \h  15  

  HYPERLINK \l "_Toc180381719"  7. Burden Statement	  PAGEREF
_Toc180381719 \h  15  

 

1.  Identification of the Information Collection

1(a) 	Title and Number of the Information Collection

Title:  Regulatory Innovation Pilot Projects, ICR No. 1755.08, OMB
Control No. 2010-0026.

1(b) 	Short Characterization

This is a request for renewal of currently approved ICR No. 1755.07,
which authorizes the solicitation of proposals for innovative pilot
projects. A 60-day comment period for this ICR renewal in the Federal
Register concluded on August 14, 2007, during which no comments were
received. 

In 1995, the U.S. Environmental Protection Agency (EPA) began to solicit
innovative pilot projects in response to a challenge to transform the
environmental regulatory system to better meet the needs of a rapidly
changing society while maintaining the nation’s commitment to protect
human health and safeguard the natural environment. Since then, through
a number of mechanisms including: site-specific agreements with project
sponsors at the facility or community level; broader agreements under
the Joint EPA – State Agreement to Pursue Regulatory Innovation ( 
HYPERLINK "http://www.ecos.org/files/1426_file_Agreement.pdf" 
http://www.ecos.org/files/1426_file_Agreement.pdf ); and at the State
whole-regulatory program-level through the Agency’s State Innovation
Grant Program, EPA has been working effectively with partners to test
innovative approaches to environmental regulation that focus on better
environmental outcomes and better efficiency. Under prior Information
Collection Requests (ICRs), EPA has been gathering data on performance
under the earlier, facility-specific innovation projects identified
under Project XL (http://www.epa.gov/projctxl/). Project experience
gained in these earlier projects is helping the Agency redesign current
approaches in pursuit of improved public health and environmental
protection and more efficient use of limited resources.  Through these
projects, sponsors (private facilities, multiple facilities, industry
sectors, Federal facilities, communities, universities, Tribes and
States) are implementing innovative strategies that produce superior
environmental performance, provide flexibility, cost savings, paperwork
reduction or other benefits to sponsors, and promote greater
accountability to the public.  

The intent of conducting and supporting innovative pilot projects is to
allow EPA to experiment with untried, potentially promising regulatory
approaches, both to assess whether they provide superior environmental
performance or other benefits, and whether they should be considered for
wider application.  Using this piloting approach, EPA can rely on
carefully controlled, but smaller scale tests to evaluate methodically
the broader applicability of any specific regulatory innovation. This
piloting approach provides EPA with a structured, applied policy
laboratory where tests of innovation at a manageable scale can be
controlled and evaluated carefully much the same as engineering
innovations require component-by component tests and evaluation to bring
an innovation to implementation.  The piloting, or applied policy
laboratory approach allows EPA to propose and adopt changes based upon
an actual assessment of success at a small scale. Thus, the careful
piloting of a regulatory innovation allows EPA to identify possible new
policy approaches within the general statutory directive, and suggest
alternative regulatory approaches aimed at better results and better
efficiency, so long as the alternative proposed is permissible under
statute.

The adoption of such alternative approaches or interpretations in the
context of a pilot project does not, however, signal EPA's willingness
to adopt that interpretation as a general matter, or even in the context
of other pilot projects. It would be inconsistent with the
forward-looking nature of these pilot projects to adopt such innovative
approaches prematurely on a widespread basis without first determining
whether or not they are viable in practice and successful for the
particular projects that embody them. These pilot projects are not
intended to be a means for piecemeal revision of entire programs.
Depending on the results of these projects, EPA may or may not be
willing to consider adopting the alternative approach or interpretation
again, either generally or for other specific facilities.  EPA believes
that testing alternative policy approaches and/or interpretations, on a
limited basis (e.g., in a site-specific circumstance or within a
specific, state-managed permitting program) and under the tight control
of a carefully selected pilot project is consistent with the
expectations of Congress about EPA's role in implementing the
environmental statutes (so long as EPA acts within the discretion
allowed by the statute). Congress' recognition that there is a need for
experimentation and research, as well as ongoing reevaluation of
environmental programs, is reflected in a variety of statutory
provisions.

EPA’s National Center for Environmental Innovation (NCEI) receives
proposals for innovative pilot projects through formal mechanisms such
as the State Innovation Grant Program and previously under Project XL,
as well as informally by states, tribes and regulated entities. NCEI and
has been given responsibility for managing a careful program to pilot
test, evaluate and implement select innovations in support of the
Agencies regulatory programs. Since 1995, EPA has implemented pilot
projects to test innovative ideas working with EPA headquarters, EPA
regions, Federal, State, and local government agencies, as well as
individual facilities and whole business sectors.  The renewal of this
ICR is important as it will allow the Agency to continue its work with
regulated entities that are interested in participating in innovative
pilot projects as well as allow the Agency to continue its commitment to
testing innovation and regulatory flexibility with facilities,
communities, States, and Tribes to achieve improved environmental
results.  The renewal of this ICR will allow OEPI to continue to work
with project sponsors on proposals for innovation, including those
directly through EPA, as well as other state-led mechanisms such as the
Joint EPA-State Agreement to Pursue Regulatory Innovation.  In addition,
the renewal of this ICR is necessary to allow EPA to continue
information collection supporting its commitments to current projects
under previous approved ICR iterations (1755.03-1755.07). 

2. Need for and Use of the Collection

2(a)	Need/Authority for the Collection

The information is needed to allow the Agency to continue its ongoing
work with states, regulated entities, and other stakeholders that are
already engaged in innovative regulatory piloting projects. The
information is of value to the Agency in meeting its commitment to
document and transfer practical innovation and regulatory flexibility
for attainment of compliance and superior environmental results in
partnership with regulated facilities, communities, states and tribes. 
The information will support the reporting of improved environmental
results and the analysis of pilot projects to determine their efficacy
and potential for broader use.  States implementing innovative
regulatory pilot tests in projects funded by a State Innovation Grant
are required to report on progress during the operation of a project and
to provide a final project report summarizing outcomes and major
findings of each project.  EPA’s policy on performance measurement in
assistance agreements is an implementation outcome under the Government
Performance and Results Act (GPRA § 1115 (a)(4) and §1116(c) ).  The
renewal of this ICR will allow OEPI to continue to receive and work with
project sponsors on proposals for innovation as well as document results
from those projects.

Responses related to inquiries by EPA about Project XL pilot projects
are voluntary, as are any responses by state environmental agencies to
EPA’s request for input for the design of the annual competition.  
Under this ICR, EPA would be allowed to solicit its co-regulators and
the regulated entities for their best ideas on regulatory innovation,
for pilot projects to test those ideas, and for information that will
document the processes and environmental outcomes of pilot testing. 
Potential project sponsors for new projects will continue to submit
proposals to the National Center for Environmental Innovation at EPA. 

2(b)	Practical Utility/Uses of the Data

Information collected under this ICR renewal will have two purposes. 
First, EPA seeks to document the results of regulatory innovation pilot
projects: to provide accountability reflected in environmental results;
to understand the circumstances under which these innovative approaches
work best; and to fully document the projects and their outcomes in a
way that allows other states or tribes to work with regulated entities
to adopt successful approaches. Second, new project proposals to be
collected pursuant to this renewal will be used to articulate
full-fledged pilot projects and then to document the implementation of
the projects.  The information collection supports the competitive
identification of new innovation as well as supporting the collection of
performance information essential for documenting success in providing
improved environmental results.  

A competitive process ensures that EPA can choose from a pool of useful
project ideas.  In the State Innovation Grant Program, EPA has adopted a
simple and flexible proposal format that allows State co-regulators,
working with a diversity of regulated entities, small as well as large
firms, agencies, and communities, to develop proposals. EPA uses the
proposal submissions to screen ideas and select the most promising ones
for further project development.  

Similarly, EPA requires states and other project sponsors to report on
results in ways that allow the Agency to characterize the benefits of
the innovation being tested and document the innovation process to allow
for transferability to other states and regulated entities.

3.  Nonduplication, Consultations, and Other Collection Criteria

3(a) 	Nonduplication

The information to be obtained under this ICR has not been collected by
EPA or any other Federal agency.

3(b)	Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act (44 U.S.C. 3501 et seq.),
EPA is currently soliciting comments on specific aspects of this ICR.  A
Federal Register (FR) notice for this ICR package was first published in
the Federal Register on June 15, 2007, (Volume 72, Number 115 page
33218.  No public comments were received.

3(c)	Consultations

This notice was developed by the National Center for Environmental
Innovation in consultation with EPA Regional personnel.   

3(d) 	General Guidelines

This ICR complies with OMB’s general guidelines for the collection of
information.

3(e)	Confidentiality 

The nature of the data being requested as part of this information
collection is not confidential.

3(f) 	Sensitive Questions

The information gathering activities discussed in this ICR do not
involve any sensitive questions.

4. The Respondents and the Information Requested

4(a)	Respondents/NAICS Codes

EPA works with a variety of businesses, organizations, and communities
within the regulated community, as well as Federal facilities, states,
tribes, and local governments.  Potential respondents include all
entities regulated by EPA and its co-regulators in state and tribal
agencies pursuant to its authority under the various environmental
statutes who wish to participate in innovative pilot projects.

4(b)	Information Requested

No new proposals are being accepted through Project XL. For new projects
in development, EPA currently relies on its State Innovation Grant
program as the principal mechanism to support and stimulate innovation
testing.  Therefore the information collection activities fall generally
into three categories within this ICR: (1) results reporting for
projects in implementation under Project XL and the ECOS-EPA Joint
Agreement on Environmental Innovation; (2) new proposals developed under
the ECOS-EPA Joint Agreement on Environmental Innovation and the State
Innovation Grant Program, and; (3) progress and final reporting under
the State Innovation Grant Program.

For projects in implementation under Project XL and the ECOS-EPA Joint
Agreement on Environmental Innovation, EPA anticipates collection of
information to allow the Agency to document and evaluate the outcomes of
the pilot project, including measurements of environmental outcomes. 
For implemented projects underway through the auspices of Project XL or
the ECOS-EPA Joint Agreement on Environmental Innovation, a final
project report, as identified in a Final Project Agreement or a project
work plan will provide the information required to assess the success
and outcomes of each project.

	For new proposals developed under the ECOS-EPA Joint Agreement on
Environmental Innovation and the State Innovation Grant Program, EPA
generally solicits initial input from states on topic areas to be
included in the annual solicitation and asks states on a voluntary basis
to submit proposals for innovation projects.  

	

For progress and final reporting under the State Innovation Grant
Program, States receiving an assistance agreement supporting an
innovative pilot project under this program are required to prepare a
brief progress report each quarter to synopsize progress on the approved
work plan and report financial expenditures.  States are also required
to provide a final project report to document environmental outcome
measures and steps and impediments involved in implementation of their
project.  A final financial report is also required to document the
expenditure for Federal funds and provide accountability for those
expenditures.

5.  The Information Collected.  Agency Activities, Collection
Methodology, and Information Management.

5(a) 	Agency Activities    	

Agency activities associated with the collection of information for
innovative pilot projects include:

Gather information from sponsors regarding innovative ideas during
pre-proposal and final proposal phases;

Evaluate pre-proposal ideas with cross-Agency team;

Gather additional information from sponsor entities regarding innovative
pilot projects ideas to assist sponsor entities in developing proposals;


Distribute proposals across Agency; and

Evaluate proposals with cross-Agency team.

5(b)	Collection Methodology and Information Management

For projects implemented through for all projects under Project XL:
progress reports, correspondence, and final reports are submitted by
each project sponsor by email or mail and following review these reports
are kept in project files by EPA project personnel. For projects
submitted under the ECOS-EPA Joint Agreement on Environmental
Innovation, a project final report is generally prepared by the state
and submitted to EPA at the completion or termination of the
state-initiated innovation pilot project.  For projects conducted under
the State Innovation Grant Program, States voluntarily submit brief
pre-proposals under the annual solicitation/ competition.  State’s
with projects selected in the competition must prepare and submit a
final, detailed project workplan/ final proposal, quarterly reports and
a final project report.  All of these progress and final reports are
sent to EPA electronically.  Project pre-proposals and final workplans
are submitted through the Department of Commerce   HYPERLINK
"http://www.grants.gov"  www.grants.gov  website.

5(c)	Small Entity Flexibility. 	

Facilities participating in innovation projects under all projects under
Project XL participate on a voluntary basis and entities can choose not
to participate at any time if undue burden exists. Facilities
participating under the ECOS-EPA Joint Agreement for Environmental
Innovation or State Innovation Grant Program may participate under the
auspices of both a voluntary program or in the context of  compliance
with a required permitting program.

5(d)	Collection Schedule.

No new proposals are being accepted through Project XL.  For regulatory
innovation projects in implementation under Project XL, a final project
report is required as specified under their final project agreement
(FPA).  Projects implemented under the ECOS-EPA Joint Agreement on
Environmental Innovation may require a final project accomplishments
report.  Projects implemented by States under the State Innovation Grant
Program are required to provide quarterly progress reports as well as a
final project report within 90 days of project completion or
termination.

6. Estimating the Burden and the Cost of the Collection

6(a) 	Estimating Respondent Burden and Cost to State Agencies

This section presents EPA’s estimates of the burden and costs
necessary to complete the information collection activities associated
with this collection. Burden hours and costs were based upon estimates
provided by EPA staff with extensive experience working with State
agencies funded for projects under the State Innovation Grant Program
and innovative pilot project sponsors in industry.

EPA estimates average hourly respondent labor cost (including fringe and
overhead) for State Innovation Grant solicitation response and reporting
by State agencies to be $61.05 for legal staff, $59.48 for managerial
staff, $34.60 for technical staff, and $22.74 for clerical staff.  EPA
estimates the hourly respondent labor cost for industry staff providing
periodic reporting on best environmental business practices under these
projects to be approximately the same.

For activities related to the collection of State input into the design
of the innovation grants solicitation target areas, EPA anticipates that
States and Tribes may expend up to 16 hours each to develop and submit
comment to the Agency for a total annual burden of 768 hours costing
approximately $36,193. 

For activities related to the collection of progress reports and final
reports for projects under the State Innovation Grant Program, EPA
estimates that States would expend up to 2,060 hours in total costing
approximately $55,091.

The total annual burden to States during the period of this ICR is
expected to be approximately 2,828 hours with an estimated cost of
$91,284.

Staff in the Office of Environmental Policy Innovation that work on the
development of innovative pilot projects have reviewed the cost findings
of the report and found them to be reasonable and sound estimates of
current and future costs. 

No capital expenditures are needed for states to respond since responses
may be made using existing equipment (telephone, fax, email or paper
correspondence).  Similarly, no operating or maintenance costs are
needed since the activities can be conducted using existing equipment,
as well.

Table 1.  Average Annual Burden and Cost to Respondents

Table 1.  Average Annual Burden and Cost to State Agency Respondents

	Collection Activity	

	Burden Hours and Individual Costs per Recipient	

	Total Costs

	

Hours per Respondent per Activity	

	Costs per

	Respondent

	per Activity	

	Total Hours

	for all

	Respondents 	

	Total Costs

	for all

	Respondents

	

	Legal	

	Mgmt	

     Tech	

	Cler



	

STATE INNOVATION GRANT SPONSORS: PRE-PROPOSAL PHASE	

	

	





Preliminary discussions with EPA on projects, solicitation strategic
focus, and pre-proposal submission (24)	

8	

8	

16	

	

$ 1,508.08	

768	

    $ 36,193



TOTAL	

8	

8	

16	

	

$ 1,508.08	

768	

    $ 36,193



STATE INNOVATION GRANT SPONSORS: PROGRESS AND OUTCOME REPORTING PHASE



	

Quarterly and Final Project Reporting on State Innovation Grant Projects
 (140 annually)

	

     1	

     2	

     8	

   2	

    $ 322.28	

   1,820	

   $ 45,119



Final Project Reports on State Innovation Grant Projects  (4 annually)

	

      4	

     16	

     32	

   8	

   $2,493.00	

      240	

   $   9,972



TOTAL

	

      5	

    18	

      40	

   10	

   $2,815.28	

    2060	

   $ 55,091



ANNUAL BURDEN TOTAL FOR STATES

	

13	

26	

56	

10	

$ 4,323.36	

2,828	

$ 91,284



6(b) 	Estimating Respondent Burden  for Participating Facilities
(Private Entities)

This section provides our estimate of the burden and costs for
facilities participating in the regulatory pilot projects.  There are
information collection activities related to two groups of projects: the
close-out of Project XL projects; and, projects proposed and implemented
under the State Innovation Grant program.  

Only final reporting is anticipated for a small number of the Project XL
pilots. In these cases, EPA estimates that facility operators
(principally private sector) have an average hourly labor rate of $85.42
for legal staff, $70.16 for managerial staff, $24.06 for technical
staff, and $18.51 for clerical staff.  To derive these estimates, EPA
considered the general ICR announcement, “Agency Information
Collection Activities: Request for Comments on Thirty-One Proposed
Information Collection Requests (ICRs)”, from March 9, 2007 [Docket ID
Numbers EPA-HQ-OECA-2007-0032 to 0035, 0043 to 0065 and 0125 to 0128;
FRL-8285-8] and on the 2005 Employment Cost Indexes developed by the
U.S. Bureau of Labor Statistics. 

In using this analysis EPA considered that some respondents will be
asked to provide information related to certification of compliance with
permit requirements and that activity is covered under ICRs relating to
compliance reporting across the many EPA programs.  Other facilities
will be asked to report to States on the success of adopting best
environmental business practices for their business sector.  In both
instances, facilities reporting to States under the State Innovation
Grant Program, or directly to EPA under project XL have some expected
value attached with their participation.  Not unlike a contracts-based
Request for Proposals, one would not expect a response from any entity
where the burdens associated with preparing the response outweigh the
expected benefits to the sponsor.

EPA anticipates final project reports from 18 XL Projects during the
lifetime of this ICR that will provide information key to closing out
and documenting the results of these projects and evaluating the further
applicability of the ideas tested in these demonstrations.   

No capital expenditures are needed by the respondent to complete the
interview since the responses can be made using existing equipment
(e.g., telephone). Moreover, no operating and maintenance costs are
needed since the activities (reviewing instructions, writing,
discussions, and submissions of proposals) can be conducted in with
existing equipment (e.g., phone, computer).

For final reporting on XL Projects, EPA projects that each project will
require up to 20 hours to compile, compose and edit material to fulfill
the commitment made by the project sponsors in the Final Project
Agreement to report fully on the outcomes of these voluntary projects. 
Thus, approximately 360 hours will be required over the lifetime of this
ICR (120 hours annually) for these reports.   The cost of this is
estimated to be $5,300 annually. 

Facilities participating in projects implemented by states supported
under the State Innovation Grant Program will be required to report on
their environmental performance in order to allow states to meet their
obligation under the assistance agreements to measure the environmental
outcomes of their projects.  The nature of the metrics and reports vary
with the type of projects proposed.  They may range from pre- and
post-implementation compliance reporting which is generally covered
under programmatic ICR to reporting with innovative measures such as the
adoption of best environmental business practices that result in
pollution prevention through elimination of waste and business process
change.  This ICR is intended to allow the collection of this type of
information which provides a more reliable measure of the results of
innovative practice.  EPA anticipates that up to 1200 facilities
annually may be asked to provide information on performance measures
related to adoption of innovation requiring 4800 hours annually at an
estimated cost of $ 240, 176 .

Table 2.  Average Annual Burden and Cost to Facility Respondents

Collection Activity

	

Burden Hours and Individual Costs Per Facility

	

Total Costs

	

Hours per Respondent per Activity	

 Costs per Respondent 

per Activity	

Total Hours 

    for all Respondents	

Total Costs 

    for all Respondents

	

Legal	

Mgmt	

Tech	

Cler



	

PROJECT XL FINAL REPORTING	





Compile project information and develop final project report and
closeout  (assume 6 annually)	

2	

6	

8	

2	

$805.26	

108	

$4,831.56



Consult with EPA to resolve any questions on final report and respond to
brief evaluation survey for closeout activities (assume 6 annually)	

	

	

2	

	

$78.12	

12	

$468.72



TOTAL	

2	

6	

10	

2	

$883.38	

120	

$5,300



STATE INNOVATION GRANT FACILITY REPORTING









	

Collection of Annual Compliance and Other Performance Information By
Participating Facilities to Report to State Agencies (Assumes 1200
Facilities Annually)

	

      1	

      1

	

     2



     $195.73

	

   4,800	

   $234,876



EXTERNAL BURDEN TOTAL (PRIVATE)	

3	

7	

12	

2	

$ 1,079.11	

4,920	

$ 240,176



6(c) 	Estimating Agency (EPA) Burden and Cost

Agency burden hours and costs were based upon estimates provided by EPA
staff with extensive experience working with innovative pilot project
sponsors and States to assess innovative pilot project ideas and
proposals. The rate EPA used to estimate agency hourly wage was based
upon 2007 GS-13/01 salary of $79,397 (or $38.17/hour) with an additional
overhead  multiplier of 1.6 factored in, resulting in a cost of 
$61.07/hour. 



Staff in the Office of Environmental Policy Innovation that work on the
development of innovative pilot projects have reviewed the cost findings
of the report and found them to be reasonable and sound estimates.

EPA estimates that, annually, 30 State, Tribal, local and other
stakeholder respondents will be involved in pre-proposal concept
information collection activities prior to the release of a grants
solicitation and that EPA will expend approximately 60 hours to analyze
that information at a cost of $3,664.  Similarly, based upon its
experience in five previous competitions under the State Innovation
Grant Program, EPA estimates that approximately 20 States will respond
annually to the solicitation and that EPA will expend 160 hours of time
evaluating those pre-proposals at a cost of $ 9,771.

EPA currently has 35 projects funded through the Grant Program and their
quarterly reporting will provide 140 short progress reports to the
Agency and 4 final project reports annually based upon the projected
terms of the projects under the assistance agreements for the next 3
years. EPA estimate that it will expend 140 hours annually at a cost of
$ 8,550 to review those quarterly reports and 40 hours annually to
review  the final project reports at a cost of $ 1,954.

Similarly for projects implemented under earlier categories of
regulatory innovation, notably Project XL,.  EPA’s cost to collect,
analyze and manage information under all parts of this ICR will be
approximately $ 5,863 for an estimated 96 hours of labor. 

To perform the necessary activities associated with this information
collection, EPA estimates that it will require the Agency 488 hours and
cost the Agency $29,802 per year. 

Table 3.  Annual Average Burden and Cost to Agency

	Collection Activity	

	Costs

	

	Labor	

	Total Hours	

        Total

	Costs

	

	Hours	

	Costs





EPA



Gather information from potential sponsor entities regarding

innovative idea during pre-proposal phase through discussions (assume 30
State and Tribal responses annually)	

2	

$122	

60	

$3,664



Evaluation of State Innovation Grant Pre-proposals  (assume 20 annually)

	

        8	        

         $489	

           160	

   $9,771



Evaluation of State Innovation Grant Project Progress Reports (assume
140 quarterly annually)

	

       1	

     $  61	

        140	

    $8,550



Evaluation of State innovation Grant Final Reports (assume 4 annually)

	

        8	

     $489	

           32	

     $ 1,954



Evaluate Project XL and ECOS Joint Agreement Final Reports (assume 6
annually)	

16	

     $ 978	

96	

     $ 5,863



INTERNAL BURDEN TOTAL	

35	

$2,138	

488	

      $29,802



6(d)	Estimating the Respondent Universe and Total Burden and Costs

EPA is amending this ICR to address the continuing need for effective
documentation of pilot project results that was the subject of the
earlier requests, and to fulfill the requirement to effectively document
the results of  innovation projects supported under Agency assistance
agreements.  To fulfill these requirements, EPA anticipates a total
annual burden to all entities (states and tribes, participating private
facilities and the Agency itself) of 8,236 hours at an estimated annual
cost of $361,262.  Extended over the lifetime of the ICR, EPA 
anticipates a total burden to the universe of respondents  and to the
Agency itself of 24,708 hours at a cost of $1,083,786.  

		Table 4.  Summary of ICR Burdens for Respondent Universe

Summary of ICR Burdens and Costs



Entity

	Annual Hours Required	Annual Costs	Total Hours Over ICR Lifetime (3 yr)
Total Costs Over ICR Lifetime (3yr)

States and Tribes	   2,828	$ 91,284	   8,484	  $ 273,852

Private Facility Participants	   4,920	$ 240,176	 14,760	  $720,528

EPA

	    488	$ 29,802	  1,464	  $ 89,406

TOTAL	  8,236	$ 361,262	  24,708	$1,083,786



6(e)	Reasons for Burden Hour Change

EPA required 888 hours annually (2664 hours over the lifetime of the
ICR) from the public to perform information collection activities
described in previous iterations of this ICR (1755.03, 1755.04, 1755.05,
1755.06, and 1755.07).  With the renewal of this ICR, the total annual
burden on the public needed to conduct the information collection
activities described in this ICR will be increased by 6,860 hours.  This
difference is largely a result of the requirement to collect information
sufficient to provide measurement of beneficial outcomes in projects
funded by EPA cooperative agreements to states that support pilot
projects testing regulatory innovation by state environmental agencies. 


7. Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average approximately 6 hours per
response.  Burden means the total time, effort, or financial resources
expended by persons to generate, maintain, retain, or disclose or
provide information to or for a Federal agency.  This includes the time
needed to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control numbers for EPA's regulations are
listed in 40 CFR Part 9 and 48 CFR Chapter 15.  

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-AO-2007-0408, which is available for public viewing at the Office
of the Administrator Docket in the EPA Docket Center (EPA/DC), EPA West,
Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket
Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal holidays.  The telephone number for the
Reading Room is (202) 566-1744, and the telephone number for the Office
of the Administrator Docket is (202) 566-0219.  An electronic version of
the public docket is available through the Federal Docket Management
System (FDMS) at http://www.regulations.gov/.  Use FDMS to submit or
view public comments, access the index listing of the contents of the
public docket, and to access those documents in the public docket that
are available electronically.  Once in the system, key in the docket ID
number identified above.  Also, you can send comments to the Office of
Information and Regulatory Affairs, Office of Management and Budget, 725
17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. 
Please include the EPA Docket ID No. EPA-HQ-AO-2007-0408 and OMB control
number 2010-0026 in any correspondence.

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