﻿Supporting Statement for an Information Collection Request (ICR) Under the Paperwork Reduction Act (PRA)
EXECUTIVE SUMMARY
Title: Clean School Bus (CSB) Rebates Program: Application, Payment Request, and Close Out Forms 
EPA ICR No.: 2461.05
OMB Control No.: 2060-0686 (Renewal)
Docket ID No.: EPA-HQ-OAR-2012-0103
Abstract
This supporting statement is for the Information Collection Request (ICR) renewal for the Clean School Bus (CSB) Rebates Program. The CSB Rebates Program currently collects information under an existing ICR; namely the Diesel Emissions Reduction Act (DERA) and Clean School Bus Rebate Program ICR No. 2060-0686. The Environmental Protection Agency (EPA) currently uses ICR No. 2060-0686 to collect information for the CSB Rebate Program to ensure its successful administration and management. An Emergency ICR No. 2780.01 was approved by OMB in September 2023 that included additional data necessary to adequately review and administer the CSB Rebate Program. This ICR renewal consolidates all components of the CSB Rebate Program collection. 
School buses collectively travel over four billion miles each year. They provide safe transportation to and from school for more than 25 million American children every day. While new buses meet the U.S. Environmental Protection Agency's (EPA's) tighter emission standards, most school buses on the road emit pollutants, including nitrogen oxides (NOx) and particulate matter (PM), in diesel exhaust. These pollutants can contribute to poor air quality and negatively impact human health, especially for children, as well as for bus drivers, other school staff, and other community members. The CSB Rebate Program funds the replacement of existing school buses with cleaner buses, the operation of which result in better air quality throughout the communities in which they operate. 
EPA uses approved procedures and forms to collect necessary information to operate the CSB Rebate Program and has been providing these rebates since 2022. For each rebate program, EPA utilizes three online forms for the three phases of the rebate lifecycle: 1) Application Form for eligible entities to apply to a new rebate program, 2) Payment Request Form for selectees to submit order documentation and receive funds, and 3) Close Out Form for selectees to document completion of the rebate-eligible activity. In Fall 2023, EPA launched the 2023 CSB Rebate Application for applicants, and the 2022 CSB Rebate Close Out Form for existing 2022 program participants; EPA is currently preparing to launch the 2023 CSB Rebate Payment Request Form in early spring of 2024. EPA will subsequently launch the 2023 CSB Rebate Close Out Form, as well as each rebate form for any future rebate programs (e.g., 2024 CSB Rebate Program). The data collected in these forms are needed to operate the rebate program as authorized by Congress under the CSB statute. 
Summary of Burden and Costs
To estimate public burden for the CSB Rebate Program, EPA based estimates on knowledge of the existing program, as well as the burden associated with recently added data fields under the Emergency ICR No. 2780.01. EPA has determined the information collected in the Application, Payment Request Form, and Close Out Form to be the minimum information necessary to determine applicant eligibility, project alignment with the CSB Rebate Program, and reporting necessary to determine project progress and completion.
As shown in the following table, EPA estimates approximately 2,400 respondents will spend approximately 20,000 hours annually fulfilling the CSB rebate program reporting requirements at an annual cost of approximately $1M. Over the ICR period, total burden amounts to approximately 59,000 hours at a cost of approximately $3M.
Respondent Type
Number of Respondents/Responses per Year
Total Burden and Cost - Annual
Total Burden and Cost - Over ICR Period


Hours
Cost (2022$)
Hours
Cost (2022$)
 
 
 
 
 
 
State governments (includes tribal)
                        125 
             960 
$55,623
             2,879 
$166,869
Local governments (includes school districts)
                        955 
           8,708 
$508,287
           26,123 
$1,524,861
Private Fleets
                     1,320 
         10,096 
$465,533
           30,287 
$1,396,599
Total
                     2,400 
         19,763 
$1,029,443
           59,289 
$3,088,328
 
Supporting Statement
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
The CSB Rebate Program is amended under the Infrastructure Investment and Jobs Act, Public Law 117-58, and provides $5 billion for the replacement of existing school buses with clean and zero-emission (ZE) school buses. School buses collectively travel over four billion miles each year, providing safes transportation to and from school for more than 25 million American children every day. While new buses meet the U.S. Environmental Protection Agency's (EPA's) tighter emission standards, most school buses on the road emit pollutants, including nitrogen oxides (NOx) and particulate matter (PM), in diesel exhaust. These pollutants can contribute to poor air quality and negatively impact human health, especially for children, as well as for bus drivers, other school staff, and other community members. The CSB Rebate Program funds the replacement of existing school buses with cleaner buses that result in better air quality on the bus, in bus loading areas, and throughout the communities in which they operate. 
This ICR renewal is necessary to ensure that EPA can collect information that is essential to appropriately administer the CSB program. Specifically, for each rebate funding opportunity under the CSB Program, EPA requires the collection of information on three online rebate forms: 1) the Application, 2) Payment Request Form, and 3) the Close Out Form. The information enables EPA to ensure that only eligible applicants receive funds under this program and the funds are used in accordance with program requirements. The online rebate forms also ensure fiscal control and accountability for EPA funds, and deter waste, fraud, and abuse. In addition, the information collected in the online rebate forms supports EPA submitting an annual report to that evaluates the implementation of the CSB Program, as required under 42 U.S.C. § 16091(b)(8). 
Indicate how, by whom, and for what purpose the information is to be used.  Except for a new collection, indicate the actual use the Agency has made of the information received from the current collection.
The purpose of the online rebate forms (Application, Payment Request Form, and Close Out Form) for the CSB Program are to verify that rebate recipients are eligible and use the CSB Rebate Program funds to purchase eligible zero-emissions school buses, clean school buses, electric vehicle supply equipment (EVSE) (where applicable), and other applicable program costs (e.g., workforce training). Applicants to any CSB rebate program (FY22, FY23, and future funding rounds) are required to submit a completed Rebate Application; those selected for funding are then required to submit a Payment Request Form with order documentation showing new vehicle/equipment orders meet program requirements. By the end of the project period, selectees must submit a Close Out Form to document completion of the rebate-eligible activity. These forms must all be signed by an Authorized Representative for the entity applying for or receiving the rebate funds. 
Under the 2022 CSB Rebate Program, EPA used information submitted in the Application and Payment Request Forms to verify applicant and equipment eligibility and ensure that funds requested in the Payment Request Form conformed to program requirements. EPA further used information submitted in the 2022 CSB Rebate forms to improve information collected in subsequent programs (e.g., streamline and clarify data fields). EPA launched the Close Out Form for 2022 CSB Rebate selectees in September 2023, and this information collection is ongoing. Similarly, the FY23 CSB Rebate Program is still in the early phases of being administered after being launched in September 2023. 
Each of the three online forms is briefly outlined below with representative screen shots of the three forms included in Attachments 3-5. 
Application Information
Application data fields collect information in several areas to ensure EPA has the information necessary to confirm an applicant's eligibility, the feasibility of the project, and ensure that the greatest number of applicants and projects are funded through the CSB Rebate Program. Information collected in the application falls into several categories, including: 1) general applicant information and school district information, 2) information on partnership agreements, 3) funding amounts, 4) existing bus details, and 5) acknowledgment of key program guidelines and requirements.
First, General information collected in the application includes the applicants Unique Entity Identifier for sam.gov, the Electronic Funds Transfer indicator, contact information for the primary applicant and partners, and type of organization. In addition, EPA requests information on the school district that would be served by the new buses funded under the CSB program. For instance, applicants provide the National Center for Education Statistics (NCES) school district ID, which allows EPA to identify school districts meeting one or more prioritization criteria identified in the CSB statue (e.g., high-need, rural, Tribal). This information supports a key program goal to ensure that buses are distributed to school districts that meet one or more of the prioritization criteria included in the CSB statue (e.g., high-need, rural, Tribal). In instances where the NCES ID does not automatically identify a school district as prioritized, applicants may self-certify as prioritized by attesting to their self-certification in the online rebate application form. 
Second, EPA requires information on partnership agreements to support the successful deployment of clean school buses, should the applicant be selected for a rebate. Data collected under this category includes three supplemental documents to ensure that 1) all applicants certify school board awareness of and support to pursue the new bus project; 2) applicants applying for electric school buses have initiated communication with their local utility early in the planning process for electric school bus deployment; 3) third party applicants certify that they have approval to apply on behalf of school districts. 
Third, EPA collects information on funding amounts to ensure that EPA is can appropriate allocate available funds and maximize the impact of the Clean School Bus program. To do so, EPA collects information on sources of non-EPA funding involved in the project, whether the applicant is requesting funds for charging infrastructure, whether the applicant is requesting lower levels of funding than they are eligible for, if they are requesting an American Disabilities Act (ADA) compliant bus, and if they are requesting funds to ship one or more buses to non-lower 48 states and territories. 
Fourth, EPA collects information on buses to be replaced to ensure that they meet the eligibility requirements for EPA to fund an applicant under the CSB Rebate Program. Collecting eligibility information will ensure funds are disbursed according to statutory requirements, as well as allow EPA to better estimate emissions reductions and public health benefits. Examples of data collected on buses to be replaced includes: Vehicle identification number (VIN); current bus ownership; estimated life of equipment to be replaced; year, make, and model; and estimated mileage and idling time. 
Finally, the application includes data fields for the applicant to confirm they understand and agree to follow program requirements. For instance, applicants must attest to the importance of developing workforce training plan. Additionally, the EPA plans to ensure future applicants understand the firm requirement that electric vehicle charging infrastructure funded in part or in full by CSB must comply with Build America, Buy America (BABA) requirements. 
Payment Request Form Information
Fields in the Payment Request Form are used to confirm that the applicant understands and agrees to follow Program requirements. An important aspect of this form is the submission of the order documentation between the selectee and equipment vendors. Data fields include make, model, and costs of vehicles, and, where applicable, equipment for electric charging infrastructure; contact information for the vendor selling the vehicle or equipment; estimated delivery date of new vehicles and/or equipment; and estimated annual fuel use and miles traveled for new buses. Selectees will also be required to upload appropriate documentation from infrastructure vendors to verify BABA compliance. The information collected on the Payment Request Form is necessary to ensure fiscal control and accountability for EPA funds, as well as to deter waste, fraud, and abuse. See Attachment 4 for a representative screen shot of the Payment Request Form. 
Close Out Form Information
By separating the Payment Request Form from the Close Out Form, EPA can disburse funds based on order documentation and associated information submitted with the Payment Request Form, which allows selectees to move forward with purchasing new buses and equipment; EPA then subsequently collects the remaining necessary information to administer the CSB Rebate Program in the Close Out Form. EPA utilizes the Close Out Form to document completion of the rebate-eligible activity. For instance, selectees must provide documentation to verify that existing buses to be replaced have been scrapped, new buses funded under the program have been delivered, and, where applicable, electric vehicle charging infrastructure has been delivered and installed. The Close Out Form also provides, where appropriate, detailed information on new equipment funded by the program and partners involved in the project. The exact information needed may vary depending on the type of applicant (i.e., Third-party, school district, or tribal). 
Importantly, information that has already been submitted will be carried over into the Close Out Form from the Application and Payment Request Forms, thereby reducing respondent burden and avoiding duplication. Additional contact information for the primary and alternate business contact may be collected as relevant to each rebate project. Further reducing burden, selectees also have the opportunity to edit information previously entered into the Application Form related to the buses that were replaced in the project period if they decided to replace a different existing bus (i.e., swap one existing bus for another). Similarly, if necessary, selectees may edit information applicable charging infrastructure that they entered in the Payment Request Form. See Attachment 5 for a representative screen shot of the Close Out Form.
 
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
All three rebate forms outlined above (Application, Payment Request Form, Close Out Form) are in an online web portal with user-friendly interface. The online forms ensure that all required data fields are completed to avoid an applicant or selectee needing to resubmit information at a later date due to an incomplete form. Further, each of the online forms can accommodate information related to several vehicles, which avoids applicants or selectees needing to complete a unique form for each vehicle for which they are requesting funding. Importantly, the online forms significantly reduce burden on rebate recipients and EPA staff by auto-populating information already submitted in previous steps within a form, as well information provided in a previous form (e.g., auto-populate information from Application to Payment Request Form), and by enabling the editing of previous submissions where appropriate. EPA will use information submitted in the online rebate forms to ensure the CSB Program is properly administered and to fulfill the reporting requirements of the Program. EPA will store information entered in to the three forms in the same database used to store data collected under the existing ICR (EPA ICR No. 2461.04).
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
Information requested from respondents under this ICR is not available from other sources. There are no existing rebate programs at EPA where this information may have been previously collected. Some rebate recipients may have applied for and/or received grants or rebates from EPA; however, information currently held in EPA's Integrated Management System that could pertain to the current rebate program may not reflect current contact information for rebate recipients and would not include necessary information related to the specific vehicle(s) targeted for rebate funding. Where possible, EPA will look to allow applicants applying to multiple rebate funding opportunities under the CSB Rebate Program to utilize relevant information (e.g., applicant contact information) when applying to a future rebate funding program. The CSB Program's technology-based facilitation of the information collection will reduce the need for respondents to submit identification data and other data fields more than once. 
If the collection of information impacts small businesses or other small entities, describe the methods used to minimize burden.
The Application, Payment Request Form, and Close Out Form collect the minimal information needed to verify that rebate recipients are eligible for a Clean School Bus award, experience a fair and equal selection process, and that applicants use the funds received to purchase approved clean school buses and/or EVSE. The burden represented by the Application, Payment Request Form, and Close Out Form cannot be further reduced for small businesses. EPA needs certain basic information to make decisions regarding rebate payments, and this information is not dependent on an operator's size. EPA believes the reporting requirements included in this ICR do not place an unreasonable burden on small businesses. In general, CSB rebates offer a simpler funding mechanism for small entities compared to the processes involved in many federal grants. Additionally, EPA minimizes the burden on small entities by providing User Guides for the Application, Payment Request Form, and Close Out Form. Please refer to Attachment 6-8 for User guide reference 
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
EPA recognizes the importance of balancing the need for data collection efforts against respondent burden and costs. If the information in the rebate Application, Payment Request, and Close Out Forms outlined above is not collected, then EPA would be unable to assess whether a rebate applicant is eligible to receive a rebate, appropriately allocate funding, and ensure that all parties involved in the potential new bus deployment project are in alignment on project planning. Further, EPA would be unable to appropriately verify the eligibility of buses to be replaced and requested new vehicles and, where applicable, electric vehicle charging infrastructure. Moreover, EPA would be unable to verify that rebate recipients used the program funds consistent with program requirements, and would be limited in gathering data that will be used to evaluate the implementation of the CSB statute for Congress, as well as to inform future research (e.g., quantifying emission reduction benefits of the program and estimating CSB performance in the field) and policy decisions (e.g., improving the cost-effectiveness of rebate funds). 
In essence, not collecting the information in the rebate forms outlined in this Supporting Statement would severely limit or preclude EPA from appropriately administering a rebate program to address the requirements in the CSB statue and avoid fraud, waste, and abuse of federal funds, thereby frustrating the congressionally-established Clean School Bus Program. Information in each rebate form will be submitted one time for each rebate funding opportunity; therefore, a less frequent collection is not applicable.  
 
Explain any special circumstances that require the collection to be conducted in a manner: 
Requiring respondents to report information to the agency more often than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
CSB Rebate recipients must retain all financial records, supporting documents, accounting books and other evidence of CSB Rebate Program activities for five years after submission of the Close Out Form. This requirement to retain records for more than three years is to comply with 42 U.S.C. § 16091(b)(5), which requires buses funded by the program to serve the school district listed on the application for not less than five years. If any litigation, claim, or audit is started before the expiration of the five-year period, the recipient must maintain all appropriate records until these actions are completed and all issues resolved.
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If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken in response to the comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside EPA to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
Over the course of the DERA and CSB Rebate Programs, EPA has consulted with representatives from industries that have received rebates from previous rebate funding opportunities to determine availability of the information requested on the rebate forms and the typical process and time required to procure a new vehicle or retrofit an existing vehicle. 
Additionally, for the Emergency CSB Rebate Program ICR (ICR No. 2780.01), EPA developed estimates of the time needed to provide the required information. EPA based estimates on in-depth knowledge of the existing reporting forms, as well as burden associated with completing checkboxes and uploading forms.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
Not applicable.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
Applicants will not be required to submit confidential business information. If an applicant feels that any information requested would be confidential business information, the applicant may request that such information be treated as confidential. All confidential data will be handled in accordance with 40 CFR 122.7, 40 CFR Part 2, and EPA's Security Manual Part III, Chapter 9, dated August 9, 1976. Any claim of confidentiality must be asserted at the time of submission.
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
No information of a sensitive or private nature is requested in conjunction with these information collection activities, and these information collection activities comply with the provisions of the Privacy Act of 1974 and OMB Circular A-108.
Provide estimates of the hour burden of the collection of information. The statement should: 
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens. 
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included under `Annual Cost to Federal Government'. 
For this ICR renewal, EPA combined currently approved reporting burden estimates with incremental reporting burden estimated in the Emergency CSB Rebate Program ICR No. 2780.01. These estimates are provided for the three applicant types: state, local, and private organizations. See Appendix A for additional details on the derivation of reporting burden. 
Notably, EPA ensures a lower burden for entities completing an Application to request funding than entities that have been selected for funding and are completing a  Payment Request Form or Close Out Form; this approach both lowers burden for the larger number of entities applying for funding than those selected for funding, as well as ensures the information necessary to properly administer the program is collected from the Payment Request Form and Close Out Form.
Table 1: Application Form Estimated Unit Burden
 
Hours
Respondent Type/Activity
Management
Technical 
Clerical
Total
State governments (includes tribal) 
 
 
 
 
1a. Review instructions
0.40
0.15
0.85
1.40
1b. Gather information about existing vehicle(s) to replace or retrofit
0.00
0.75
1.50
2.25
1c. Fill out Application to Reserve Funds
0.25
0.50
0.50
1.25
1d. Sign and submit to EPA
0.10
0.00
0.00
0.10
1e. Submit Purchase Order to EPA within 60 days of application approval
0.10
0.00
0.40
0.50
Total
0.85
1.40
3.25
5.50
Local governments (includes school districts)
 
 
 
 
1a. Review instructions
0.50
0.15
0.95
1.6
1b. Gather information about existing vehicle(s) to replace or retrofit
0.00
0.75
1.90
2.65
1c. Fill out Application to Reserve Funds
0.25
0.50
0.70
1.45
1d. Sign and submit to EPA
0.30
0.00
0.00
0.3
1e. Submit Purchase Order to EPA within 60 days of application approval
0.20
0.00
0.50
0.7
Total
1.25
1.40
4.05
6.70
Private Fleets
 
 
 
 
1a. Review instructions
0.40
0.90
0.10
1.40
1b. Gather information about existing vehicle(s) to replace or retrofit
0.00
2.25
0.00
2.25
1c. Fill out Application to Reserve Funds
0.25
0.90
0.60
1.75
1d. Sign and submit to EPA
0.10
0.00
0.00
0.10
1e. Submit Purchase Order to EPA within 60 days of application approval
0.10
0.25
0.15
0.50
Total
0.85
4.30
0.85
6.00

Table 2: Payment Request Form Estimated Unit Burden
 
Hours
Respondent Type/Activity
Management
Technical 
Clerical
Total
State governments (includes tribal)
 
 
 
 
2a. Review instructions
0.00
0.00
0.20
0.20
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.00
0.00
0.40
0.40
2c. Fill out Payment Request forms, sign submit
0.44
0.00
1.76
2.20
2d. Record keeping
0.04
0.00
0.16
0.20
Total
0.48
0.00
2.52
3.00
Local governments (includes school districts)
 
 
 
 
2a. Review instructions
0.00
0.00
0.24
0.24
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.28
0.00
0.46
0.74
2c. Fill out Payment Request forms, sign submit
0.35
0.00
1.91
2.26
2d. Record keeping
0.04
0.00
0.20
0.24
Total
0.67
0.00
2.81
3.48
Private Fleets
 
 
 
 
2a. Review instructions
0.20
0.00
0.00
0.20
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.40
0.40
0.10
0.90
2c. Fill out Payment Request forms, sign submit
0.44
0.66
1.10
2.20
2d. Record keeping
0.00
0.00
0.10
0.10
Total
1.04
1.06
1.30
3.40


Table 3: Close-Out Form Estimated Unit Burden
 
Hours
Respondent Type/Activity
Management
Technical 
Clerical
Total
State governments (includes tribal)
 
 
 
 
2a. Review instructions
0.13
0.06
0.61
0.79
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.00
1.33
1.95
3.28
2c. Fill out Close Out forms, sign submit
1.14
0.38
1.49
3.00
2d. Record keeping
0.10
0.00
0.72
0.82
Total
1.36
1.76
4.77
7.89
Local governments (includes school districts)
 
 
 
 
2a. Review instructions
0.13
0.06
0.67
0.85
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.42
1.33
2.04
3.79
2c. Fill out Close Out forms, sign submit
1.14
0.38
1.58
3.09
2d. Record keeping
0.10
0.00
0.78
0.88
Total
1.78
1.76
5.07
8.61
Private Fleets
 
 
 
 
2a. Review instructions
0.43
0.06
0.31
0.79
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.60
1.93
1.50
4.03
2c. Fill out Close Out forms, sign submit
1.14
0.47
1.40
3.00
2d. Record keeping
0.04
0.00
0.63
0.67
Total
2.20
2.45
3.84
8.49

To estimate total respondent cost associated with this ICR renewal, Bureau of Labor Statistics (BLS) data on wages and fringe benefits (total compensation) are used. Specifically, wages are estimated for labor types (management, technical, and clerical) for state and local governments and for private fleets. EPA uses average wage data for state and local governments available from Table 3 in the Employer Costs for Employee Compensation for state and local government workers (See http://www.bls.gov/news.release/ecec.t03.htm). EPA uses average wage data for private fleets available from Table 4 in the Employer Costs for Employee Compensation for private industry workers (See https://www.bls.gov/news.release/ecec.t04.htm).
Overhead costs are assumed to equal 20% of the sum of wages plus fringe benefits. This loading factor is described in Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and other U.S. EPA Actions. Table 4 presents the fully loaded wage rates used in this ICR.
Table 4: State, Local, Private Loaded Wage Rates (2022$)
Labor Category
Wage1
Fringe Benefit1
Total Compensation
Over-head % wage2
Overhead
Hourly Loaded Wages3
BLS Occupational Group

(a)
(b)
(c) =(a)+ (b)
(d)
(e)= (c) *(d)
(f)=(c)+(e)

State & local governments (including schools)
Managerial
$43.87 
$24.70 
$68.57 
20%
$13.71
$82.28 
State and Local Government Workers: Management, Professional, and Related
Professional / Technical
$32.32 
$23.56 
$55.88 
20%
$11.18
$67.06 
State and Local Government Workers: Public Administration
Clerical
$23.05 
$17.18 
$40.23 
20%
$8.05
$48.28 
State and Local Government Workers: Office and Administrative Support
 
 
 
 
 
 
 
 
Private fleets
Managerial
$46.70 
$20.55 
$67.25 
20%
$13.45
$80.70 
Service Providing Industries: Management, Professional, and Related Occupations
Professional / Technical
$22.66 
$10.35 
$33.01 
20%
$6.60
$39.61 
Service Providing Industries: Transportation and Material Moving Occupations
Clerical
$21.63 
$9.43 
$31.06 
20%
$6.21
$37.27 
Service Providing Industries: Office and Administrative Support Occupations
Footnotes:
1Source: State and Local Governments - Bureau of Labor Statistics Economic News Release Table 3. State and local government, by occupational and industry group, December 2022. http://www.bls.gov/news.release/ecec.t03.htm Private Fleets - Bureau of Labor Statistics Economic News Release Table 4. Private industry workers by occupational and industry group, December 2022. https://www.bls.gov/news.release/ecec.t04.htm
2An overhead rate of 20% is used based on assumptions in Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and other U.S. EPA Actions (EPA, 2020).
3Values may not sum due to rounding. Wage rates are rounded to the nearest cent.

Combining wage data with unit reporting time estimates yields unit cost estimates for CSB program reporting requirements as shown in Tables 5, 6, and 7.

Table 5: Application Form Estimated Unit Reporting Burden and Cost
 
Hours
Costs (2022$)
Respondent Type/Activity
Management
Technical 
Clerical
Total
Management
Technical 
Clerical
Total
 
 
 
 
 
 
 
 
 
State governments (includes tribal) 
 
 
 
 
 
 
 
 
1a. Review instructions
0.40
0.15
0.85
1.40
$32.91
$10.06 
$41.03 
$84.01
1b. Gather information about existing vehicle(s) to replace or retrofit
0.00
0.75
1.50
2.25
$0.00
$50.29 
$72.41 
$122.71
1c. Fill out Application to Reserve Funds
0.25
0.50
0.50
1.25
$20.57
$33.53 
$24.14 
$78.24
1d. Sign and submit to EPA
0.10
0.00
0.00
0.10
$8.23
$0.00 
$0.00 
$8.23
1e. Submit Purchase Order to EPA within 60 days of application approval
0.10
0.00
0.40
0.50
$8.23
$0.00 
$19.31 
$27.54
Total
0.85
1.40
3.25
5.50
$69.94
$93.88
$156.90
$320.72
Local governments (includes school districts)
 
 
 
 
 
 
 
 
1a. Review instructions
0.50
0.15
0.95
1.6
$41.14
$10.06 
$45.86 
$97.06 
1b. Gather information about existing vehicle(s) to replace or retrofit
0.00
0.75
1.90
2.65
$0.00
$50.29 
$91.72 
$142.02 
1c. Fill out Application to Reserve Funds
0.25
0.50
0.70
1.45
$20.57
$33.53 
$33.79 
$87.89 
1d. Sign and submit to EPA
0.30
0.00
0.00
0.3
$24.69
$0.00 
$0.00 
$24.69 
1e. Submit Purchase Order to EPA within 60 days of application approval
0.20
0.00
0.50
0.7
$16.46
$0.00 
$24.14 
$40.59 
Total
1.25
1.40
4.05
6.70
$102.86
$93.88
$195.52
$392.25
Private Fleets
 
 
 
 
 
 
 
 
1a. Review instructions
0.40
0.90
0.10
1.40
$32.28
$35.65 
$3.73 
$71.66
1b. Gather information about existing vehicle(s) to replace or retrofit
0.00
2.25
0.00
2.25
$0.00
$89.13 
$0.00 
$89.13
1c. Fill out Application to Reserve Funds
0.25
0.90
0.60
1.75
$20.18
$35.65 
$22.36 
$78.19
1d. Sign and submit to EPA
0.10
0.00
0.00
0.10
$8.07
$0.00 
$0.00 
$8.07
1e. Submit Purchase Order to EPA within 60 days of application approval
0.10
0.25
0.15
0.50
$8.07
$9.90 
$5.59 
$23.56
Total
0.85
4.30
0.85
6.00
$68.60
$170.33
$31.68
$270.61

Table 6: Payment Request Form Estimated Unit Reporting Burden and Cost
 
Hours
Costs (2022$) 
Respondent Type/Activity
Management
Technical 
Clerical
Total
Management
Technical
Clerical
Total
 
 
 
 
 
 
 
 
 
State governments (includes tribal)
 
 
 
 
 
 
 
 
2a. Review instructions
0.00
0.00
0.20
0.20
$0.00
$0.00 
$9.66 
$9.66
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.00
0.00
0.40
0.40
$0.00
$0.00 
$19.31 
$19.31
2c. Fill out Payment Request forms, sign submit
0.44
0.00
1.76
2.20
$36.20
$0.00 
$84.97 
$121.17
2d. Record keeping
0.04
0.00
0.16
0.20
$3.29
$0.00 
$7.72 
$11.02
Total
0.48
0.00
2.52
3.00
$39.50
$0.00
$121.66
$161.15
Local governments (includes school districts)
 
 
 
 
 
 
 
 
2a. Review instructions
0.00
0.00
0.24
0.24
$0.00
$0.00 
$11.59 
$11.59
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.28
0.00
0.46
0.74
$23.04
$0.00 
$22.21 
$45.25
2c. Fill out Payment Request forms, sign submit
0.35
0.00
1.91
2.26
$28.61
$0.00 
$92.32 
$120.93
2d. Record keeping
0.04
0.00
0.20
0.24
$3.29
$0.00 
$9.66 
$12.95
Total
0.67
0.00
2.81
3.48
$54.94
$0.00
$135.77
$190.71
Private Fleets
 
 
 
 
 
 
 
 
2a. Review instructions
0.20
0.00
0.00
0.20
$16.14
$0.00 
$0.00 
$16.14
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.40
0.40
0.10
0.90
$32.28
$15.84 
$3.73 
$51.85
2c. Fill out Payment Request forms, sign submit
0.44
0.66
1.10
2.20
$35.51
$26.14 
$41.00 
$102.65
2d. Record keeping
0.00
0.00
0.10
0.10
$0.00
$0.00 
$3.73 
$3.73
Total
1.04
1.06
1.30
3.40
$83.93
$41.99
$48.45
$174.37

Table 7: Close Out Form Estimated Unit Reporting Burden and Cost
 
Hours
Costs (2022$) 
Respondent Type/Activity
Management
Technical 
Clerical
Total
Management
Technical
Clerical
Total
 
 
 
 
 
 
 
 
 
State governments (includes tribal)
 
 
 
 
 
 
 
 
2a. Review instructions
0.13
0.06
0.61
0.79
$10.29
$4.19 
$29.27 
$43.74
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.00
1.33
1.95
3.28
$0.00
$88.99 
$94.14 
$183.13
2c. Fill out Close Out forms, sign submit
1.14
0.38
1.49
3.00
$93.39
$25.15 
$71.93 
$190.47
2d. Record keeping
0.10
0.00
0.72
0.82
$8.02
$0.00 
$34.82 
$42.84
Total
1.36
1.76
4.77
7.89
$111.70
$118.33
$230.16
$460.18
Local governments (includes school districts)
 
 
 
 
 
 
 
 
2a. Review instructions
0.13
0.06
0.67
0.85
$10.29
$4.19 
$32.16 
$46.64
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.42
1.33
2.04
3.79
$34.56
$88.99 
$98.48 
$222.03
2c. Fill out Close Out forms, sign submit
1.14
0.38
1.58
3.09
$93.39
$25.15 
$76.28 
$194.81
2d. Record keeping
0.10
0.00
0.78
0.88
$8.02
$0.00 
$37.72 
$45.74
Total
1.78
1.76
5.07
8.61
$146.26
$118.33
$244.64
$509.22
Private Fleets
 
 
 
 
 
 
 
 
2a. Review instructions
0.43
0.06
0.31
0.79
$34.30
$2.48 
$11.41 
$48.19
2b. Gather invoices and information for new vehicle(s) and/or equipment
0.60
1.93
1.50
4.03
$48.42
$76.34 
$55.91 
$180.66
2c. Fill out Close Out forms, sign submit
1.14
0.47
1.40
3.00
$91.59
$18.42 
$52.18 
$162.19
2d. Record keeping
0.04
0.00
0.63
0.67
$3.03
$0.00 
$23.53 
$26.55
Total
2.20
2.45
3.84
8.49
$177.34
$97.23
$143.03
$417.60

Unit burden and cost are then combined with the number of respondents to estimate the total burden and cost associated with CSB Rebate Program reporting requirements in Table 8, 9 and 10. Because the ICR period lasts for three years, total burden and cost are presented annually as well as the total for the ICR period. Table 11 totals all reporting requirement burden and cost.
Table 8: Application Form Estimated Total Burden and Cost
Respondent Type
Number of Respondents/Responses Per Year
Unit Burden and Cost
Total Burden and Cost - Annual
Total Burden and Cost - Over ICR Period


Hours
Cost (2022$)
Hours
Cost (2022$)
Hours
Cost (2022$)
State governments (includes tribal)
125
5.50
$320.72
688
$40,090
2,063
$120,269
Local governments (includes school districts)
955
6.70
$392.25
6399
$374,600
19,196
$1,123,800
Private Fleets
1320
6.00
$270.61
7920
$357,202
23,760
$1,071,607
Total for Application
2,400


15,006
$771,892
45,018
$2,315,675

Table 9: Payment Request Form Estimated Total Burden and Cost
Respondent Type
Number of Respondents/Responses Per Year
Unit Burden and Cost
Total Burden and Cost - Annual
Total Burden and Cost - Over ICR Period


Hours
Cost (2022$)
Hours
Cost (2022$)
Hours
Cost (2022$)
State governments (includes tribal)
25
3.00
$161.15
                 75 
$4,029
                 225 
$12,086
Local governments (includes school districts)
191
3.48
$190.71
               665 
$36,425
              1,994 
$109,275
Private Fleets
183
3.40
$174.37
               622 
$31,910
              1,867 
$95,729
Total for Application
399
 
 
             1,362 
$72,364
$4,086
$217,091

Table 10: Close Out Form Estimated Total Burden and Cost
Respondent Type
Number of Respondents/Responses Per Year
Unit Burden and Cost
Total Burden and Cost - Annual
Total Burden and Cost - Over ICR Period


Hours
Cost (2022$)
Hours
Cost (2022$)
Hours
Cost (2022$)
State governments (includes tribal)
25
7.89
$460.18
               197 
$11,505
                 592 
$34,514
Local governments (includes school districts)
191
8.61
$509.22
             1,644 
$97,262
              4,933 
$291,786
Private Fleets
183
8.49
$417.60
             1,554 
$76,421
              4,661 
$229,263
Total for Application
399
 
 
             3,395 
$185,187
            10,186 
$555,562

Table 11: Total CSB Rebate Program Reporting Burden and Cost
Respondent Type
Number of Respondents/Responses per Year
Total Burden and Cost - Annual
Total Burden and Cost - Over ICR Period


Hours
Cost (2022$)
Hours
Cost (2022$)
 
 
 
 
 
 
State governments (includes tribal)
                        125 
             960 
$55,623
             2,879 
$166,869
Local governments (includes school districts)
                        955 
           8,708 
$508,287
           26,123 
$1,524,861
Private Fleets
                     1,320 
         10,096 
$465,533
           30,287 
$1,396,599
Total
                     2,400 
         19,763 
$1,029,443
           59,289 
$3,088,328




Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
This ICR renewal accounts for labor costs only. There are no capital or operation and maintenance costs associated with this action. 
Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
EPA will review the Application, Payment Request Form, and Close Out Form data fields submitted by applicants and selectees. Table 12 presents the estimated Agency burden hours and costs associated with the information collection activities under this ICR renewal. EPA based its burden estimate on the professional judgement of CSB Program staff. This estimate is considered conservative. 
Agency wage rate data used to calculate labor costs were gathered from the U.S. Office of Personnel Management Salary Table 2023-DCB, for GS-13, step 10, employees in the Washington, D.C. area. Similar to respondent wages, Agency wage data are adjusted to account for both fringe benefits and overhead according to guidance provided in EPA's Handbook on Valuing Changes in Time Use induced by Regulatory Requirements and Other EPA Actions. The 2022 loaded wage rate of $131.31/hour is used in this analysis.

Table 12: Estimated Burden and Cost to the Agency
Collection Activity
Reporting Burden per Response
Number of Responses 
Total Agency Burden Over the ICR Period
Total Agency Cost Over the ICR Period (2022$)
Total Agency Burden Over the ICR Period
Total Agency Cost Over the ICR Period (2022$)
Application Form
1a. Review Application for eligibility with program requirements
0.50
             2,400 
                  1,200 
$157,572
                       3,600 
$472,717
1b. Reserve funds and update applicant status in tracking database
0.50
             2,400 
                  1,200 
$157,572
                       3,600 
$472,717
1c. Post Lottery Selected Application Review
6.00
600
                  3,600 
$472,717
                     10,800 
$1,418,152
Sub Total
 
 
                  6,000 
$787,862
                     18,000 
$2,363,587
Payment Request and Close Out Form
 
 
 
 
 
 
2a. Review Payment Request form materials to confirm compliance with program guidance
4.50
399
                  1,796 
$235,768
                       5,387 
$707,303
2b. Review Close Out form materials to confirm compliance with program guidance
4.50
399
                  1,796 
$235,768
                       5,387 
$707,303
2c. Release funds to applicant and update applicant status in tracking database
0.50
399
                     200 
$26,196
                          599 
$78,589
Sub Total
 
 
                  3,791 
$497,732
                     11,372 
$1,493,196
Total EPA Burden
 
 
                  9,791 
$1,285,594
                     29,372 
$3,856,783

Explain the reasons for any program changes or adjustments reported in hour or cost burden.
The change in reporting burden since the last ICR is due to the addition of certain data fields to the Application and Close Out Forms, as described in the Emergency ICR No. 2780.01, as well as an adjustment to the Payment Request Form reporting burden that was not included in the Emergency ICR No. 2780.01. Evidence from the initial program funding year indicates that current Payment Request Form estimates were too conservative by approximately two hours per form. Specifically, EPA Staff has adjustedpublic burden estimates to account for time needed for applicants to correct errors and re-submit the Payment Request Form. Applicant corrections are required to disperse correct funding amount and to deter fraud, waste and abuse. All data fields are reflected in Attachments 3 through 5. 
For collections whose results will be published, outline the plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
Not applicable.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.
Not applicable.
Explain each exception to the certification statement identified in "Certification for Paperwork Reduction Act Submissions."
EPA does not request an exception to the certification of this information collection. 
Supplemental Information
List of Attachments
Ref
Title
1.
Appendix A: ICR Renewal Calculations
2
Title XI, §71101 of the Infrastructure Investment and Jobs Act (Public Law 117-58)
3
Clean School Bus Application Form Screenshots with Summary of Changes
4.
Clean School Bus Payment Request Form Screenshots with Summary of Changes 
5.
Clean School Bus Close Out Form Screenshots with Summary of Changes
6.
Clean School Bus Program Application User Guide 
7.
Clean School Bus Payment Request User Guide
8.
Clean School Bus Close Out Form User Guide

