ICR SUPPORTING STATEMENT

1. Identification of the Information Collection

   1(a) Title of the Information Collection

      CEQ-EPA Presidential Innovation Award for Environmental Educators and the President's Environmental Youth Awards Application (Renewal)
      EPA ICR Number 2524.03, OMB Control Number 2090-0031

   1(b) Short Characterization/Abstract

      This ICR package is being submitted to renew collection activities related to the Presidential Innovation Award for Environmental Educators (PIAEE) and President's Environmental Youth Awards (PEYA) programs previously approved under the OMB Control Number 2090-0031.  
      
      The U.S. Environmental Protection Agency (EPA or the Agency), in conjunction with the White House Council on Environmental Quality (CEQ), established the PIAEE program to meet the requirements of Section 8(e) of the National Environmental Education Act (20 U.S.C. § 5507(e). 
      
      The Agency established the PIAEE program to meet the requirements of Section 8(d) of the National Environmental Education Act (20 U.S.C. § 5507(d)). 
      
      Agency officials developed the "Application for the Presidential Innovation Award for Environmental Educators" and "Application for the President's Environmental Youth Awards" as a tool for selecting awardees. Teachers and students can participate by visiting http://www2.epa.gov/education/piaee-application and https://www.epa.gov/education/presidents-environmental-youth-award-peya-application, respectively and completing and submitting the application form. Application forms can be filled electronically and submitted by email or printed and mailed. EPA anticipates that the number of respondents completing the form during the period of this ICR will average 75 per year for the Presidential Innovation Award for Environmental Educators program and 250 per year for the President's Environmental Youth Awards program. 
      
      Information gathered from the applications will be collected and stored in electronic format at EPA headquarters within secured Agency information technology resources. The information collected from this ICR will continuously help EPA and CEQ to select the top awardees for the Presidential Innovation Award for Environmental Educators (PIAEE) and the President's Environmental Youth Awards (PEYA). The selected winners of the PIAEE will benefit from small cash prizes, which will help them to continue their mission of advancing innovative approaches to environmental education to grades K-12. The selected winners of the PEYA also receive a Presidential plaque, while all qualified applicants will receive a recognition from EPA leadership honoring them for their efforts to protect human health and the environment. 
      
2. Need For and Use of the Collection

   2(a) Need/Authority for Collection

      The National Environmental Education Act Section 8(e) (20 U.S.C. § 5507(e)) dictates that EPA and CEQ provide cash awards for elementary and secondary education teachers and local education agencies. Specifically:
      
             The Chairman of the Council on Environmental Quality, on behalf of the President, is authorized to develop and administer an awards program to recognize elementary and secondary education teachers and their local educational agencies who demonstrate excellence in advancing environmental education through innovative approaches. One teacher, and the local education agency employing such teacher, from each State, including the District of Columbia and the Commonwealth of Puerto Rico, are eligible to be selected for an award pursuant to this subsection.
         
             The Chairman is authorized to provide a cash award of up to $2,500 to each teacher selected to receive an award pursuant to this section, which shall be used to further the recipient's professional development in environmental education.
            
             The Chairman is also authorized to provide a cash award of up to $2,500 to the local education agency employing any teacher selected to receive an award pursuant to this section, which shall be used to fund environmental educational activities and programs. Such awards may not be used for construction costs, general expenses, salaries, bonuses, or other administrative expenses.
      
      Additionally, the National Environmental Education Act Section 8(d) (20 U.S.C. § 5507(d)) states that the Administrator may provide for the "President's Environmental Youth Awards" to be given to young people in grades kindergarten through twelfth for an outstanding project to promote local environmental awareness.
      
      For the PIAEE program, the application form is completed by candidates for consideration as awardees. The application form is completed as part of the awardee selection process. The application form is reviewed by the program manager and a panel of EPA and CEQ officials to determine eligibility and fulfillment of selection criteria. Using the application form benefits EPA by allowing for the selection of qualified awardees.
      
      For the PEYA, each applicant must be represented by a sponsor. The sponsor must be an adult at least 21 years of age and may be a parent, teacher, youth group adviser, summer camp counselor, community leader, or other education professional who is aware of the applicant's project. For the purpose of this ICR, we assume that the adult sponsor is a teacher.
   
   
   2(b) Practical Utility/Users of the Data

      Information gathered under the application form will continuously help EPA and CEQ select the top awardees for the Presidential Innovation Award for Environmental Educators. Using this form enables program managers and reviewers to select viable candidates for the awards.

3. Non-duplication, Consultations, and Other Collection Criteria

   3(a) Non-duplication

      Almost all information requested from respondents under this ICR is personal in nature, and in most cases, is not available from other sources.

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

      The EPA Office of Public Engagement and Environmental Education (OPEEE) announced a 60-day public comment period through publication of a Federal Register notice on October 18, 2021 (86 FR 57664) to gather public input on the renewal of the PIAEE and PEYA collection which ended December 17[th], 2021.  No comments were received.

   3(c) Consultations

      In the preparation of this update to the ICR renewal, the PIAEE program also provided past respondents the opportunity to comment on the estimated burden. Respondents from these consultations respondents reported that on average it takes 23 hours to complete the application form, which was not found to be overly burdensome. 
      
 Kelly Holtzman
            Oconomowoc High School
            2021 Presidential Innovation Award for Environmental Educators Winner
            holtzmans@att.net
      
 Jason Vanzant
            Ipswich High School
            2021 Presidential Innovation Award for Environmental Educators Winner jason.vanzant@carteretk12.org
      

      The PEYA program also sought feedback on the estimated burden from prior applicants. Respondents from prior consultations reported that on average it takes 3.5 hours to complete the application form, which was not found to be overly burdensome. 
      
      
      
 Jennifer Fetherston-Resch
            Applicant Sponsor for 2021 President's Environmental Youth Awards Winner
            jkresch13@gmail.com
            
 Brandy Caroway 
      Lancaster County School District
      Applicant Sponsor for 2021 President's Environmental Youth Awards Winner
            Brandy.Caroway@lcsd.k12.sc.us
      
 Tom McKee
            Woodlake UMC - Scouting Coordinator
            Applicant Sponsor for 2021 President's Environmental Youth Awards Winner
            asr.tom.mckee@gmail.com 
      
      
   3(d) Effects of Less Frequent Collection
      
The award program is conducted on an annual basis. The form is required to be completed once a year to select each year's awardees. The form allows government officials to select qualified awardees for the program, as required by the National Environmental Education Act (See Section 2 (a)). EPA would not be able to fulfill the requirements of the Act if the frequency of the collection period decreased.

   3(e) General Guidelines
      
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

   3(f) Confidentiality
      
The primary use of the information collected on this form is to allow EPA to review and select awardees in accordance with the National Environmental Education Act. Some information reported on the form is Personally Identifiable Information, which includes name, address and phone number. This information is required to be withheld from the public pursuant to Section 107(a) of the Ethics in Government Act of 1978. Agency personnel shall not publicly release the information contained therein.

   3(g) Sensitive Questions
      
      This information collection does not include questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private and none of the information collected by this action results in or requests sensitive information of any nature. 



4. The Respondents and the Information Requested

   4(a) Respondents/NAICS Codes

      The PIAEE program respondents are K-12 teachers who teach on a full-time basis in a public school that is operated by a local education agency, including schools funded by the Bureau of Indian Affairs. For this program, a local education agency is one as defined by section 198 of the Elementary and Secondary Education Act of 1965 (now codified at 20 U.S.C. 7801(26)). The NAICS code is 561311.
      
      The PEYA program respondents are student sponsors. Sponsors are usually K-12 teachers who teach on a full-time basis in a public school that is operated by a local education agency, including schools funded by the Bureau of Indian Affairs. Sponsors play an important role in helping a young person carry out a project and apply for PEYA.

   4(b) Information Requested

      Copies of both the PIAEE and PEYA application forms are attached as Attachment A. 
      
      (i) Data items, including record keeping requirements
      The Agency maintains lists of the names of the applicant respondents, their email address, and associated reviewer scores for selection purposes. These lists are for internal use only and not available to the public. Additionally, EPA retains electronic copies of completed application forms and stores them according to Agency guidelines. Completed applications that are distributed to reviewers will have any confidential information redacted. The Agency does not anticipate any record keeping activities on the part of the respondents under this ICR.
      
      (ii) Respondent Activities
      Respondents will be asked to complete the application form. Forms may be downloaded from EPA's environmental education website (https://www.epa.gov/education). Respondents can fill in the form electronically and may either print and mail a copy or they may attach the completed form by email. An option to submit the PEYA application online is planned. Each form will require the applicant to read the instructions, complete the application, write essay responses, compile supplementary materials, and gather letters of recommendation. 

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

   5(a) Agency Activities

      Agency (EPA) activities associated with the collection of information include:
      
      Program Manager:
             Internal development, review and approval of application form
             Taking actions to review the form, ascertain improvements, and revise periodically (approximately 2-year intervals or more if needed)
             Providing copies of the application form
             Answering any respondent questions, follow-up
             Gathering respondents' completed forms
             Screening respondents' completed forms
             Recordkeeping/storing the completed form
             Forwarding form to EPA's Reviewers
      
      Reviewers:
             Review of respondents' completed forms
             Ranking awardee selections
      
      To respond to this ICR, we estimate that the Program Manager will spend 3.5 hours per respondent screening applications and answering respondent questions. 
      
      EPA assumes that each application will be scored by 3 EPA staff reviewers. EPA also estimates that each reviewer spends 2 hours reviewing each application form, including completing a written evaluation of the application package and discussing winner selections.
      
   5(b) Collection Methodology and Management

      In collecting and analyzing the information associated with this ICR, EPA will use computers, e-mail, and websites. Respondents can obtain a blank application form from the EPA website. They may fill out the application form either electronically or in hard copy. The respondents can type essays in a Word document and attach them to the application form. Respondents can either print and mail in the application form and essay responses or send them as an email attachment. While respondents may type their information on the form, they must complete the signature page. In this case, respondents can print the signature page, sign, and scan the page as an attachment.  An online application for PEYA is planned.
      
EPA will ensure the accuracy and completeness of collected information by reviewing each submittal and screening for missing components. EPA will enter basic contact information from the completed application form (name, school, email address) into the respective tracking tools used by PEYA and PIAEE Program Managers. Each application form and essay responses are reviewed by a minimum of two EPA reviewers. Each reviewer submits the score to the EPA Regional Program Manager using a standardized Excel score sheet. This information is aggregated to select the respondents with the highest average scores from each EPA region as awardee finalists. This information is not available to the public.  An online review process is planned for PEYA.
      
      
      
      

   5(c) Small Entity Flexibility
      
      The impact of small entities was taken into consideration during the development of application forms. The number of questions asked is the minimum amount of information needed to reach a decision on the awards.  

   5(d) Collection Schedule
      EPA anticipates having the following annual collection schedule.

	PIAEE
             January -  Application period opens. Respondents can download the application form from the EPA website and submit the completed form and essay responses via hard copy or email.
             March 30  -  Application period closes.
             May 1  -  May 30  -  EPA screens and reviews applications. 
             June 1  -  EPA aggregates reviewer scores and submits selected finalists to CEQ.
             June 1-30  -  CEQ reviews and screens finalists' applications.
             Second week of July  -  EPA announces award winners.

	PEYA
             October 1  -  Application period opens. Respondents can download the application form from the EPA website and submit the completed form and essay or submit the application online.  HQ screens applications as they come in. 
             January 15[th]  -  Application period closes.
             January 15[th]  -  March 2[st]  -  EPA Regions review applications. 
             March 5[th]  -  All regions report winners to HQ for PEYA 
             March 30[th]  -  EPA announces award winners.
      
      After the initial completion of the application form, respondents who are selected as finalists may be asked to provide additional information, including, for PIAEE, proof of the number of years teaching and may undergo screening by CEQ.

6. Estimating the Burden and Cost of the Collection

   6(a) Estimating Respondent Burden

The estimated labor cost for elementary and secondary school employees is $26.91, which including the standard overhead factor of 1.6, produces a loaded wage rate of $43.06. The estimated labor cost for non-special education elementary school employees is $31.45, which including the standard overhead factor of 1.6, produces a loaded wage rate of $50.32. The estimated labor cost for non-special education secondary school employees is $32.38, which including the standard overhead factor of 1.6, produces a loaded wage rate of $51.80. https://www.bls.gov/oes/current/oes250000.htm

To respond to this ICR, we estimated that each respondent will take 10 hours to complete the PIAEE application form and 6 hours to complete the PEYA application form. 

For PIAEE, we estimate that approximately 75 teachers will respond to this request each year. Multiplying the estimated number of respondents (75) by the estimated respondent labor cost ($43.06) by the number of hours (10), we estimate the annual average dollar burden estimate for this awards program to be $32,295. The grand total for all 3 years is estimated at $96,885.

For PEYA (K-5), we estimate that approximately 100 applicant sponsors will respond to this request each year. Multiplying the estimated number of respondents (100) by the estimated respondent labor cost ($50.32) by the number of hours (6), we estimate the annual average dollar burden estimate for the K-5 category of the awards program to be $30,192. The total for all 3 years is estimated at $90,576.

For PEYA (6-12 grade), we estimate that approximately 150 applicant sponsors will respond to this request each year. Multiplying the estimated number of respondents in each grade group (150) by the estimated respondent labor cost ($51.81) by the number of hours (7), we estimate the annual average dollar burden estimate for the 6-12 grade category of the awards program to be $54,401. The total for all 3 years is estimated at $163,202.

The yearly total respondent cost for all age groups of PEYA is estimated at $84,593. The grand total for all 3 years for all age groups of PEYA is estimated at $253,779.

   6(b) Estimating Respondent Costs

 Estimating Labor Costs
                                            
                   Annual Cost for Teacher Award Respondents
                    Respondent Activities to Complete Form
                          Burden Hours Per Respondent
Burden for Respondent ($26.91 per labor hour multiplied by 1.6 for overhead equals $43.06)
                        Number of Respondents Per Year
                        Total Respondent Cost Per Year
Read instructions
                                      0.5
                                    $43.06
          75
                                                                        $1,615 
Fill out form
                                       1
                                    $43.06
                                      75
                                                                        $3,230 
Write essays
                                      4.5
                                    $43.06
                                      75
                                                                       $14,533 
Gather recommendations
                                       1
                                    $43.06
                                      75
                                                                        $3,230 
Written sample materials
                                       2
                                    $43.06
                                      75
                                                                        $6,459 
Submit application package
                                       1
                                    $43.06
                                      75
                                       
                                                                        $3,230 
                                     TOTAL
                                   10 hours
                                    $43.05 
                                      75
                                                                        $32,297
                                       
                                       
                                       
                                       
                                       
                    Annual Cost for PEYA (K-5) Respondents
                      Sponsor Activities to Complete Form
                          Burden Hours Per Respondent
Burden for Respondent ($31.45 per labor hour multiplied by 1.6 for overhead equals $50.32)
                        Number of Respondents Per Year
                        Total Respondent Cost Per Year
Read instructions
                                      0.5
                                    $50.32
                                      100
                                    $2,516 
Fill out form
                                     0.75
                                    $50.32
                                      100
                                    $3,774 
Support writing project summary
                                     0.75
                                    $50.32
                                      100
                                    $3,774
Support writing a detailed description of project
                                     1.50
                                    $50.32
                                      100
                                    $7,548
Collect and review supporting materials
                                     2.00
                                    $50.32
                                      100
                                   $10,064 
Submit application package
                                     0.50
                                    $50.32
                                      100
                                    $2,516
                                     TOTAL
                                    6 hours
                                    $50.32
                                      100
                                   $30,192 
                                       
                                       
                 Annual Cost for PEYA (6-12 Grade) Respondents
                      Sponsor Activities to Complete Form
                          Burden Hours Per Respondent
Burden for Respondent ($32.38 per labor hour multiplied by 1.6 for overhead equals $51.81)
                        Number of Respondents Per Year
                        Total Respondent Cost Per Year
Read instructions
                                      0.5
                                    $51.81
                                      150
                                    $3,886
Fill out form
                                     0.75
                                    $51.81
                                      150
                                    $5,829
Collect and Review Project Summary
                                     1.50
                                    $51.81
                                      150
                                    $11,657
Collect and Review Project Summary
                                     1.75
                                    $51.81
                                      150
                                   $13,600 
Collect and review supporting materials
                                     2.00
                                    $51.81
                                      150
                                    $15,543
Submit application package
                                     0.50
                                    $51.81
                                      150
                                    $3,886
                                     TOTAL
                                    7 hours
                                    $51.81
                                      150
                                    $54,401
                                       
                                       
                                       
                                       
                                       
                                       
                                       


       (ii) Estimating Capital and Operations and Maintenance Costs
      
      There are no capital or operations and maintenance costs.
      
      (iii) Capital/Start-up Operating and Maintenance (O&M) Costs
      
      There are no capital/startup operating and maintenance costs.
      
      (iv) Annualizing Capital Costs
      
      There are no capital costs.

   6(c) Estimating Agency Burden and Cost
      A Program Manager's hourly labor cost is equated to a GS-13, Step 8 in the Washington, DC metropolitan area. The hour labor rate is $61.28 according to Office of Personnel Management salary tables (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2021/DCB_h.pdf). This ICR uses the hourly wage of $61.28 in cost calculations for Program Managers which, when including the standard overhead factor of 1.6, produces a loaded wage rate of $98.05.
      
      A reviewer's hourly labor cost is equated to a GS-13, Step 1 in the Washington, DC metropolitan area. The hourly rate is $49.68 according to Office of Personnel Management salary tables (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2021/DCB_h.pdf). This ICR uses the average wage of $49.68 in cost calculations for reviewers which, when including the standard overhead factor of 1.6, produces a loaded wage rate of $79.49. The federal costs have increased to from $56,382 to $270,217, because of the addition of the PEYA application to this ICR.

                      PIAEE Annual Agency Burden and Cost
                                       
                          Agency Hours Per Respondent
                        Total No. Respondents Per Year
                              Labor Cost Per Year
Program Manager Activities
                                                                $98.05 per hour
                                                                               
                                                                               
Distribute form to respondents and answer their questions
                                                                    60 minutes 
                                                                       (1 hour)
                                                                             75
                                                                         $7,354
Recordkeeping
                                                                    30 minutes 
                                                                    (0.5 hours)
                                                                             75
                                                                         $3,677
Screening of applications
                                                                    60 minutes 
                                                                       (1 hour)
                                                                             75
                                                                         $7,354
Distribution of applications for review
                                                                    30 minutes 
                                                                    (0.5 hours)
                                                                             75
                                                                         $3,677
Forwarding awardee selections to CEQ for vetting
                                                                    30 minutes 
                                                                    (0.5 hours)
                                                                             75
                                                                         $3,677
Announcing winners
                                                                    30 minutes 
                                                                    (0.5 hours)
                                                                             75
                                                                         $3,677
Program Manager Subtotal
                                                                        4 hours
                                                                             75
                                                                        $29,416
Reviewer Activities
                                                                $79.49 per hour
                                                                               
                                                                              
Reviewing applications
                                                                      1.5 hours
                                                                             75
                                                                         $8,943
Discuss and rank winners
                                                                      0.5 hours
                                                                             75
                                                                         $2,981
Reviewer Subtotal
                                                                        2 hours
                                                                             75
                                                                        $11,924
Subtotal for 3 Reviewers
                                                                        6 hours
                                                                             75
                                                                        $35,772
EPA Grand Total (Program Manager & Reviewers)
                                                                       10 hours
                                                   750 hours for 75 respondents
                                                                        $65,188

                      PEYA Annual Agency Burden and Cost
                                       
                          Agency Hours Per Respondent
                        Total No. Respondents Per Year
                              Labor Cost Per Year
Program Manager Activities
                                                                $98.05 per hour
                                                                               
                                                                               
Distribute form to respondents and answer their questions
                                                                    60 minutes 
                                                                       (1 hour)
                                                                            250
                                                                       $24,513 
Recordkeeping
                                                                    30 minutes 
                                                                    (0.5 hours)
                                                                            250
                                                                       $12,256 
Screening of applications
                                                                    60 minutes 
                                                                       (1 hour)
                                                                            250
                                                                       $24,513 
Distribution of applications for review
                                                                    30 minutes 
                                                                    (0.5 hours)
                                                                            250
                                                                       $12,256 
Announcing winners
                                                                    30 minutes 
                                                                    (0.5 hours)
                                                                            250
                                                                       $12,256 
Program Manager Subtotal
                                                                      3.5 hours
                                                                            250
                                                                       $85,794 
Reviewer Activities
                                                                $79.49 per hour
                                                                              
                                                                              
Reviewing applications
                                                                      1.5 hours
                                                                            250
                                                                       $29,809 
Discuss and rank winners
                                                                      0.5 hours
                                                                            250
                                                                        $9,936 
Reviewer Subtotal
                                                                        2 hours
                                                                            250
                                                                       $39,745 
Subtotal for 3 Reviewers
                                                                        6 hours
                                                                            250
                                                                      $119,235 
EPA Grand Total (Program Manager & Reviewers)
                                                                      9.5 hours
                                                2,375 hours for 250 respondents
                                                                      $205,029 


   6(d) Estimating the Respondent Universe and Total Burden and Costs
   
   See 6(a) and (b).
   
   6(e) Bottom Line Burden Hours and Cost Tables

      (i) Respondent Tally
                                       
           Bottom-Line Annual Burden and Cost for PIAEE Respondents
PIAEE Respondent Activities to Complete Application Form
Burden Hours/Respondent
Burden for Respondent ($26.91 per labor hour multiplied by 1.6 for overhead equals $43.06)
Number of Respondents Per Year
Total Annual Burden Hours
Total Cost Per Year
Total Per Year
10 hours
$43.06
75
1,725
$32,295
                                       
                                       
         Bottom-Line Annual Burden and Cost for PEYA Respondents (K-5)
Applicant Sponsor Activities to Complete Application Form
Burden Hours/Respondent
Burden for Respondent ($31.45 per labor hour multiplied by 1.6 for overhead equals $50.32)
Number of Respondents Per Year
Total Annual Burden Hours
Total Cost Per Year
                                Total Per Year
6 hours
 $50.32 
100
600     
                                    $30,192


                                       
     Bottom-Line Annual Burden and Cost for PEYA Respondents (6-12 grade)
Applicant Sponsor Activities to Complete Application Form
Burden Hours/Respondent
Burden for Respondent ($32.38 per labor hour multiplied by 1.6 for overhead equals $51.80) 
Number of Respondents Per Year
Total Annual Burden Hours
Total Cost Per Year
                                Total Per Year
                                    7 hours
                                     $51.81
                                      150
900
                                    $54,401


      (ii) The Agency Tally

                PIAEE Bottom-Line Annual Agency Burden and Cost
                                       
                       Agency Hours for Each Respondent
                           Number of Hours Per Year
                              Labor Cost Per Year
Agency Total (Program Manager & Reviewers) for 75 Respondents
                                   10 hours
                                      750
                                    $65,188
                                       
                                       
                                       
                PEYA Bottom-Line Annual Agency Burden and Cost
                                       
                       Agency Hours for Each Respondent
                           Number of Hours Per Year
                              Labor Cost Per Year
Agency Total (Program Manager & Reviewers) for 250 Respondents
                                   9.5 hours
                                     2,375
                                   $205,029

   
   6(e) Combined Bottom Line Burden Hours and Cost Tables for PIAEE and PEYA

      (i) Respondent Tally

  Combined Bottom-Line Annual Burden and Cost for PIAEE and PEYA Respondents
       PEYA and PIAEE Respondent Activities to Complete Application Form
  Burden for Respondent (base per labor hour multiplied by 1.6 for overhead)
                        Number of Respondents Per Year
                           Total Annual Burden Hours
                              Total Cost Per Year
                                     PIAEE
                                    $43.06
                                      75
                                     1,725
                                    $32,295
                                  PEYA (K-5)
                                    $50.32
                                      100
                                      600
                                    $30,192
                                  PEYA (6-12)
                                    $51.81
                                      150
                                      900
                                    $54,401
                                     TOTAL
                                      n/a
                                      325
                                     3,225
                                   $116,888


      (ii) The Agency Tally

      	Combined PIAEE and PEYA Bottom-Line Annual Agency Burden and Cost
                                       
                           Number of Hours Per Year
                              Labor Cost Per Year
Agency Total (Program Manager & Reviewers) for 325 Respondents
                                     3,125
                                   $270,217


      (iii) Variations in the Annual Bottom Line
      
      We do not anticipate major variations in the annual bottom line burden hours and costs for the respondents or the Agency.

   6(f) Reasons for Change in Burden
     	On October 7, 2019, a Federal Register notice (84 FR 53438) was published announcing the addition of the PEYA program to this ICR. However, due to an administrative error, the revision package was not submitted to OMB for approval, which was recently discovered as this ICR renewal was being finalized. The EPA is seeking to rectify this by including the PEYA application in this ICR.  The total burden has increased by 2,475 hours as a result of PEYA being included in this ICR. The individual cost per respondent for internal processing has also risen, due to increases in labor rate estimates.   
   
   6(g) Burden Statement

      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 10 hours per response for the PIAEE program application form and 6.5 hours per response for the PEYA program application form. 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 purpose of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjusting the existing ways to comply with any previously applicable applications 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 number 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 OCR under Docket Number EPA-HQ-OA-2018-0553, which is available for online viewing at www.regulations.gov, or in person viewing at the Office of Environmental Information Docket in the EPA Docket Center (EPA/DC), EPA William Jefferson Clinton West Building, Room 3334, 1301 Constitution Avenue, NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m.  -  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 Environmental Information Docket is (202) 566-9744. An electronic version of the public docket is available at www.regulations.gov. This site can be used 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. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17[th] Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OA-2015-0553and OMB Control No. 2090-0031 in any correspondence.


