INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
FOR
REGION
7
LEAD
EDUCATION
AND
AWARENESS
PROJECT
IN
ST.
LOUIS,
MISSOURI
(
Agency
Information
Collection)

December
10,
2004
U.
S.
Environmental
Protection
Agency
Office
of
Enforcement
and
Compliance
Assurance
TABLE
OF
CONTENTS
Part
A
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
1(
b)
Short
Characterization/
Abstract
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
2(
b)
Practical
Utility/
Users
of
the
Data
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
3(
c)
Consultations
3(
d)
Effects
of
less
Frequent
Data
Collection
3(
e)
General
Guidelines
3(
f)
Confidentiality
3(
g)
Sensitive
Questions
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
4(
b)
Information
Requested
5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
5(
b)
Collection
Methodology
and
Management
5(
c)
Small
Entity
Flexibility
5(
d)
Collection
Schedule
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
and
Costs
6(
b)
Estimating
Agency
Burden
6(
c)
Bottom
Line
Burden
and
Cost
Table
6(
d)
Reasons
for
Changes
in
Burden
6(
e)
Burden
Statement
Part
B
1.
SURVEY
OBJECTIVES,
KEY
VARIABLES,
AND
OTHER
PRELIMINARIES
1(
a)
Survey
objectives
1(
b)
Key
Variables
1(
c)
Statistical
Approach
1(
d)
Feasibility
2.
SURVEY
DESIGN
2(
a)
Target
Population
and
Coverage
2(
b)
Sample
Design
2(
c)
Precision
Requirements
2(
d)
Questionnaire
Design
3.
PRETESTS
AND
PILOT
TESTS
4.
COLLECTION
METHODS
AND
FOLLOW­
UP
4(
a)
Collection
Methods
4(
b)
Survey
Response
and
Follow­
up
5.
ANALYZING
AND
REPORTING
SURVEY
RESULTS
5(
a)
Data
Preparation
5(
b)
Analysis
5(
c)
Reporting
Results
Part
A
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
ICR:
Region
7
Lead
Education
and
Awareness
Project
in
St.
Louis,
Missouri
(
EPA
ICR
Number
2161.01).

1(
b)
Short
Characterization/
Abstract
The
U.
S.
Environmental
Protection
Agency
(
EPA
or
Agency)
is
interested
in
determining
the
status
of
compliance
by
lessors
with
Title
X,
Requirements
for
Disclosure
of
Known
Lead­
Based
Paint
and/
or
Lead­
Based
Paint
Hazards
in
Housing
rule
(
Disclosure
Rule)
and
in
determining
whether
lessees
of
target
housing
are
reading
the
EPA
pamphlet,
Protect
Your
Family
From
Lead
In
Your
Home,
and
are
making
behavioral
changes
to
reduce
lead
exposure
as
a
result.
Many
entities,
including
the
U.
S.
Department
of
Housing
and
Urban
Development
(
HUD)
and
the
Missouri
Department
of
Health
(
MDoH)
are
interested
in
assessing
the
effectiveness
of
their
education
and
outreach
efforts
in
high
risk
areas
of
St.
Louis,
Missouri.

The
EPA
Region
7
is
planning
to
collaborate,
via
a
cooperative
agreement,
with
an
interested
state
agency
or
multi­
jurisdictional
state
organization
to
conduct
surveys
of
lessors
conducting
business
in
areas
of
St.
Louis,
Missouri
identified
as
high
risk
for
lead
poisoning
in
children.
(
A
lessor
is
defined
as
any
entity
that
offers
target
housing
for
lease,
rent,
or
sublease.)
The
collaboration
is
designed
as
a
tri­
fold
approach:
to
identify
the
study
population,
to
conduct
site
visits,
and
to
tabulate
the
data.
This
data
will
identify
the
rate
of
lessor
noncompliance
with
the
Disclosure
Rule
in
high
risk
areas
of
St.
Louis
and
will
assist
Region
7
in
determining
the
effectiveness
of
the
Federal
regulation
and
in
targeting
lead­
based
paint
inspections
and
compliance
assistance
for
FY05
and
beyond.
The
data
will
also
support
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
in
collecting
statistically
valid
compliance
assistance
outcome
data
needed
to
present
the
impacts
of
compliance
assistance
for
Government
Performance
and
Results
Act
(
GPRA)
reporting
purposes.
A
secondary
activity
in
the
collaboration
will
be
for
the
Recipient
to
conduct
surveys
and
focus
groups
with
lessees
regarding
whether
disclosure
actually
occurred,
to
find
out
if
the
lessees
read
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
and
if
the
lessees
implemented
methods
to
reduce
lead
exposure
as
a
result.

The
surveys
will
be
focused
in
areas
that
have
high
lead
poisoning
levels
and
also
areas
that
have
a
large
minority
population
that
may
be
unaware
of
the
Disclosure
Rule
and/
or
lead
hazards
in
general.
The
project
will
yield
data
that
can
be
analyzed
by
EPA
headquarters
and
EPA
Region
7
to
serve
as
a
basis
for
better
educating
the
lessees
in
pre­
1978
housing
in
St.
Louis,
Missouri,
more
efficient
enforcing
of
the
EPA/
HUD
Disclosure
Rule,
and
for
evaluating
the
education
and
outreach
efforts
of
EPA,
HUD
and
MDoH.
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
There
are
four
main
purposes
for
these
information­
gathering
surveys:
°
To
collect
data
to
determine
the
rate
of
lessor
non­
compliance
with
the
Disclosure
Rule
in
high­
risk
areas
in
St.
Louis.
For
this
sector,
for
which
Region
7
is
planning
to
initiate
compliance
assistance,
a
baseline
level
of
performance
and
regulatory
awareness
is
needed
to
measure
future
progress.
°
To
collect
data
to
target
Disclosure
Rule
inspections
in
FY05
and
beyond.
°
To
collect
data
to
determine
if
families
are
reading
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
and
implementing
methods
to
reduce
exposure
as
a
result.
°
To
assist
EPA,
HUD
and
MDoH
in
evaluating
their
education
and
outreach
efforts.

The
rate
of
lessor
non­
compliance
with
the
Disclosure
Rule;
the
rate
at
which
lessees
read
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
and
modify
behavior
to
reduce
exposure
as
a
result;
and
the
effectiveness
of
HUD's
education
and
outreach
efforts,
all
requested
by
these
surveys,
are
not
currently
in
federal
or
state
databases.
These
surveys
will
help
OECA
evaluate
the
effectiveness
of
compliance
assistance
outreach
and
will
enable
OECA
to
report
compliance
assistance
outcome
data
that
is
statistically
valid
and
can
be
used
for
GPRA
reporting
purposes.
The
surveys
will
also
assist
EPA,
HUD
and
MDoH
in
assessing
the
effectiveness
of
their
education
and
outreach.

The
EPA
is
permitted
to
collect
the
information
under
the
following
statute:
Toxic
Substances
Control
Act.
The
information
collected
through
this
Information
Collection
Request
(
ICR)
will
aid
EPA
in
achieving
the
Agency's
Strategic
Plan
goal
of
protecting
the
environment
through
sector­
based
approaches.
This
goal
was
developed
in
response
to
the
1993
Government
Performance
and
Results
Act
and
is
described
in
EPA's
2000
Strategic
Plan,
Chapter
2,
Protecting
the
Environment
Through
the
Sector­
Based
Approach.

2(
b)
Practical
Utility/
Users
of
the
Data
The
EPA
Region
7,
EPA
Headquarters,
HUD
and
MDoH
will
be
the
users
of
the
data
collected
by
the
surveys
covered
under
this
ICR.
The
EPA
OECA
and
Region
7
will
use
the
lessor
data
to
determine
a
baseline
and
follow­
up
level
of
regulatory
awareness
and
environmental
performance
which
EPA
cannot
determine
using
existing
databases.
The
EPA
Region
7
will
also
use
the
data
collected
from
the
lessor
sector
to
plan
compliance
assistance
to
this
sector
and
to
target
inspections
in
FY05
and
beyond.
This
information
will
then
be
used
to
measure
if
compliance
assistance
efforts
undertaken
by
Region
7
in
the
lessor
sector
improved
the
level
of
regulatory
awareness
and
regulatory
compliance
for
this
sector.
This
information
will
be
of
sufficient
quality
for
reporting
under
the
GPRA.

The
EPA
OECA
will
use
the
information
collected
on
the
lessor
sector
to
identify
compliance
assistance
mechanisms
effective
for
this
sector.
HUD
will
use
the
information
to
evaluate
their
outreach
efforts.
MDoH
will
use
the
information
to
target
both
their
own
education
and
outreach
and
to
partner
with
other
entities
involved
in
resolving
the
childhood
lead­
poisoning
problem
in
St.
Louis,
Missouri.
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
federal
agency.
The
sector
to
be
studied
using
this
ICR
comprises:
°
Lessors
conducting
business
in
high­
risk
areas
of
St.
Louis,
Missouri
who
are
impacted
by
the
Title
X
Disclosure
Rule.
°
Lessees
of
target
housing
located
in
high­
risk
areas
of
St.
Louis,
Missouri.

The
EPA
has
reviewed
its
databases
to
identify
information
for
evaluating
Disclosure
Rule
compliance
for
this
segment
of
lessors
and
for
evaluating
lessee
awareness
and
behavior
regarding
lead
education.
Currently,
EPA
does
not
have
sufficient
information
for
these
evaluations,
since
EPA
has
not
collected
this
information
to
date.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
On
September
22,
2004,
EPA
posted
a
pre­
ICR
Federal
Register
Notice
announcing
its
intent
to
submit
an
ICR
to
OMB
regarding
compliance
assistance
surveys
for
the
lessor
sector
in
the
highest­
risk
areas
of
St.
Louis,
Missouri.
The
EPA
received
two
comments
in
response
to
this
website
posting.
The
first
was
advising
EPA
that
the
Federal
Register
Notice
had
been
forwarded
to
subscribers
to
the
Food
Industry
Environmental
Network
(
FIEN)
regulatory
and
policy
E­
mail
alert
service
for
food
industry
trade
associations,
professional
societies,
food
and
agriculture
departments
of
universities
and
colleges,
government
offices,
and
consulting
and
law
firms.
This
comment
required
no
response.
The
second
comment
came
from
an
EPA
employee
inquiring
whether
funds
would
be
available
for
additional
studies
in
other
geographical
areas
similar
to
the
statistically
valid
survey
to
be
conducted
in
St.
Louis,
Missouri.
The
EPA
lead­
based
paint
program
responded
that
additional
funds
are
not
available
at
this
time,
but
that
he
would
be
contacted
if
funds
became
available
in
the
future
for
similar
studies.

3(
c)
Consultations
The
EPA
Region
7
consulted
with
Lynn
Vendinello,
National
Planning/
Measures
and
Analysis
Staff,
Office
of
Compliance,
Toxics
and
Pesticides
Enforcement
Division,
OECA/
ORE,
EPA,
(
202)
564­
7066;
Carl
Eichenwald,
Branch
Chief,
Toxics
and
Pesticides
Enforcement
Division,
EPA,
(
202)
564­
4036;
Department
of
Housing
and
Urban
Development;
Susan
Thomas,
Missouri
Department
of
Health
and
Senior
Services,
(
573)
526­
4911
and
Scott
Clardy,
Missouri
Department
of
Health
and
Senior
Services,
(
573)
751­
6102.

3(
d)
Effects
of
Less
Frequent
Data
Collection
The
survey
and
site
visit
program
for
the
lessor
sector
includes
a
baseline
survey
and
an
additional
survey
in
FY2007
to
determine
the
effectiveness
of
compliance
assistance.
Also,
interviews
with
lessees
of
lessors
declaring
their
compliance
with
the
Disclosure
Rule
will
be
conducted
after
the
lessor
baseline
survey.
This
data
collection
request
does
not
require
periodic
reporting
or
record
keeping.

3(
e)
General
Guidelines
This
information
collection
is
consistent
with
OMB
guidelines
contained
in
5
CFR
1320.5(
d)(
2).
3(
f)
Confidentiality
The
EPA
does
not
expect
that
any
confidential
business
information
or
trade
secrets
will
be
required
from
the
lessors
or
lessees.
In
addition,
lessors
to
be
surveyed
will
be
chosen
such
that
the
identify
of
the
lessor
submitting
the
survey
information
and
the
location
of
his/
her
properties
will
be
unknown
to
the
Agency.

3(
g)
Sensitive
Questions
The
surveys
and
site
visits
addressed
in
this
ICR
do
not
contain
any
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
The
respondents
for
this
ICR
will
be
the
following:
°
100
lessors
conducting
business
in
high­
risk
areas
of
St.
Louis,
Missouri.
These
lessors
fall
under
SIC
codes
6513,
6514
and
6531
and
NAICS
codes
531190,
531110,
531210
and
531311.
°
50
lessees
leasing
property
in
high­
risk
areas
of
St.
Louis,
Missouri.
The
lessees
do
not
have
an
SIC
or
NAICS
designation.

4(
b)
Information
Requested
The
lessor
site
visit
program
will
request
information
related
to
compliance
or
non­
compliance
with
the
Disclosure
Rule.
The
lessee
site
visit
program
and
lessee
focus
groups
will
result
in
information
related
to
the
compliance
or
non­
compliance
of
the
lessor
before
the
lessee
was
obligated
under
a
lease
and
also
whether
the
lessee
read
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
after
receiving
it
from
the
lessor
and
implemented
methods
to
reduce
lead
exposure
as
a
result.

(
1)
The
EPA
Region
7
and
the
Recipient
have
developed
a
survey
instrument
to
be
used
to
determine
lessor
compliance
or
the
level
of
noncompliance
with
the
Disclosure
Rule.

The
Interview
portion
of
the
survey
instrument
addresses
such
topics
as:
°
Is
the
lessor
familiar
with
the
Disclosure
Rule
°
Did
the
lessor
distribute
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
°
Does
the
lessor
have
knowledge
of
lead
hazards
in
his/
her
property
°
Did
the
lessee
receive
reports,
etc.
regarding
lead­
based
paint
inspections
The
Records
Review
portion
of
the
survey
instrument
addresses
such
topics
as:
°
The
appropriateness
of
the
lead
disclosure
itself
°
Whether
knowledge
of
lead
hazards
was
disclosed
°
Whether
the
lead
disclosure
information
was
properly
documented
See
Part
B,
Section
2(
d)
for
the
specific
survey
instrument
developed
for
the
lessor
sector.

(
2)
The
Recipient
will
develop
a
survey
to
determine
whether
the
lessees
read
and
understood
the
pamphlet,
Protect
Your
Family
From
Lead
In
Your
Home,
and
whether
they
modified
their
behavior
to
reduce
lead
exposure
as
a
result.
4(
c)
Respondent
Activities
Lessor
survey
respondent
activities
include
answering
questions
posed
by
the
Recipient
to
determine
the
level
of
compliance
or
noncompliance
with
the
Disclosure
Rule.
The
site
visit
respondents
will
participate
in
an
estimated
thirty­
minute
to
two
hour
site
visit;
the
length
of
the
site
visit
may
depend
on
the
level
of
compliance
or
noncompliance
with
the
Disclosure
Rule.
Some
lessor
respondents
may
also
attend
a
compliance
assistance
presentation.
Lessee
survey
respondent
activities
include
answering
questions
posed
by
the
Recipient
to
determine
whether
the
lessee
read
and
understood
the
pamphlet,
Protect
Your
Family
From
Lead
In
Your
Home,
and
whether
s/
he
modified
behavior
to
reduce
lead
exposure
as
a
result.
Some
lessee
respondents
may
also
attend
a
focus
group
meeting.

5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
Recipient
will
use
2000
census
data
to
determine
the
number
of
pre­
1970
residential
properties
within
the
study
area
and
to
estimate
the
number
of
rental
properties.
Results
will
be
provided
to
EPA
headquarters
to
assist
in
determining
the
validity
of
the
study
population.
The
EPA
headquarters
will
create
the
project
list
of
visits
to
be
conducted
by
statistically
selecting
lessors
and
the
number
of
associated
properties
to
be
visited.
This
list
of
site
visit
candidates
will
include
backup
candidates
in
the
event
that
some
lessors
do
not
wish
to
cooperate
with
the
study.
°
Region
7
will
use
standard
protocol
when
determining
the
record
review
period
for
this
project.
°
Region
7
will
train
the
Recipient
to
properly
use
the
checklist,
etc.
°
Region
7
will
determine
what
constitutes
compliance.
The
final
evaluation
can
rate
different
questions
on
the
checklist
to
determine
compliance,
e.
g.,
4
out
of
7
questions
incorrect
constitutes
noncompliance.
°
No
enforcement
actions
will
be
taken
as
a
result
of
information
obtained
from
the
lessor
survey
visits.
°
Region
7
will
develop
an
exception
statement
that
addresses
egregious/
criminal
situations.
°
Region
7
will
determine
how
to
deal
with
tips/
complaints
regarding
residences
in
the
study
area
during
the
study
period
and
will
communicate
the
decision
to
the
lessors.
°
The
EPA
will
use
in­
house
resources
to
conduct
data
evaluation
of
site
visit
results.

5(
b)
Collection
Methodology
and
Management
Upon
approval
of
this
ICR:
°
The
EPA's
Recipient
will
identify
the
study
population
and
obtain
the
names/
addresses
of
lessors
and
the
addresses
of
the
associated
rental
properties
within
the
study
population.
The
Recipient
will
develop
a
coded
companion
list
that
conceals
the
identify
of
the
lessor
and
associated
properties.
°
The
Recipient
will
conduct
lessor
compliance
site
visits
to
determine
compliance
with
the
Disclosure
Rule
using
a
checklist
approved
by
EPA
Region
7.
A
site
visit
will
include
interviewing
lessors
and
reviewing
lessor
files.
°
The
Recipient
will
design
a
checklist
for
the
lessee
visits
to
determine
if
families
are
reading
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
and
implementing
methods
to
reduce
exposure
as
a
result.
Recipient
will
have
the
checklist
approved
by
Region
7
prior
to
lessee
visits.
°
The
Recipient
will
conduct
lessee
visits
to
determine
if
families
are
reading
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
and
implementing
methods
to
reduce
exposure
as
a
result.
°
Information
will
be
collected
on
survey
forms
and
entered
into
a
database.
Data
entry
will
be
double­
checked
to
ensure
accurate
data
transcription.
The
sector
databases
created
from
these
surveys
will
be
accessible
to
EPA
and
other
governmental
agencies.
°
The
Recipient
will
conduct
a
series
of
lessor
seminars.
°
The
lessee
site
visit
survey
will
be
used
to
assess
the
quality
of
the
information
provided
by
the
lessors.
A
comparison
of
the
results
between
the
lessor
and
lessee
surveys
will
give
EPA
a
sense
of
whether
lessor
respondents
are
providing
accurate
information
in
their
lead
disclosure
activities.
°
The
Recipient
will
tabulate
responses
from
lessor
compliance
visits
and
lessee
visits
and
generate
a
report
that
summarizes
responses.
°
The
Recipient
will
send
survey
checklists
to
EPA
headquarters
electronically.

Lessor
Seminars:
°
The
Recipient
will
conduct
seminars
for
lessors.
There
will
be
a
pre­
and
post­
test
conducted
at
each
seminar.

Lessee
Focus
Groups:
°
The
Recipient
will
identify
potential
participants
and
will
conduct
a
series
of
lessee
focus
groups.
The
focus
groups
will
be
located
in
the
particular
neighborhoods
of
the
study.
Every
effort
will
be
made
to
select
lessees
with
children
under
age
6,
or
those
who
have
grandchildren
under
age
6.
°
The
participants
will
be
shown
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
and
will
be
given
a
brief
survey
to
identify
their
knowledge
of
lead
hazards
and
the
Disclosure
Rule.
°
The
feedback
from
each
focus
group
will
be
compiled
into
a
report
and
submitted
as
part
of
the
project
findings.

5(
c)
Small
Entity
Flexibility
The
lessor
and
lessee
surveys
should
have
minimal
impact
on
the
respondents
since
the
surveys
are
one­
time
information
requests
for
any
given
respondent.
The
lessor
surveys
will
require
on
average
30
minutes
to
two
hours
to
complete
and
the
lessee
surveys
will
require
no
more
than
one
hour
to
complete.

The
site
visits
are
designed
to
evaluate
regulatory
compliance
in
a
sector
that
is
not
wellrepresented
in
EPA's
databases.
One
of
the
reasons
that
the
sector
is
not
well­
represented
is
that
most
lessors
conduct
business
as
small
operations.
The
EPA
anticipates
that
small
operations
will
not
require
a
full
two
hours
to
complete
the
survey,
but
instead
will
likely
require
only
30
minutes
for
survey
completion.
Therefore,
EPA
has
built
small
entity
flexibility
into
the
site
visit
program
by
adapting
the
length
of
the
visit
and
the
burden
on
the
operation,
to
the
size
of
the
operation.

5(
d)
Collection
Schedule
&
Project
Schedule
Phase
I
 
Identification
of
Study
Population:
Within
3
months
of
ICR
approval
by
OMB
Phase
II
 
Conducting
of
Site
Visits
 
The
information
collection
activities
included
in
this
ICR
are
anticipated
to
occur
under
the
following
schedule
for
each
sector
covered:
Lessor
Sector:
Within
6
months
of
ICR
approval
by
OMB.
Lessee
Sector:
Within
9
months
of
ICR
approval
by
OMB.
Phase
III
 
Evaluate
Data/
Determine
Compliance
Rate:
Within
3
months
of
obtaining
site
visit
data
Project
Completion
 
Twenty­
four
months
from
cooperative
agreement
award
date
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
and
Costs
Attachment
A
includes
Tables
1,
2
and
3
which
illustrate
Respondent
Burden
and
Costs
(
Table
1),
Agency
Burden
and
Costs
(
Table
2)
and
Summary
of
Burden
and
Costs
to
Respondents
and
EPA
(
Table
3)

Table
1
presents
estimates
of
the
initial
respondent
burden
for
labor
hours
and
costs
associated
with
this
ICR.
There
is
no
recurring
respondent
burden
associated
with
this
ICR.
No
capital
or
operations
and
maintenance
costs
are
incurred
by
respondents
under
this
ICR.

6(
b)
Estimating
Agency
Burden
Table
2
presents
estimates
of
the
initial
Agency
burden
(
including
contractor
support)
associated
with
this
ICR.
There
is
no
recurring
agency
burden
associated
with
this
ICR.

6(
c)
Bottom
Line
Burden
and
Cost
Table
Table
3
presents
the
bottom
line
burden
hours
and
costs
for
respondents
and
EPA.

6(
d)
Reasons
for
Changes
in
Burden
Since
this
is
a
new
information
collection,
there
is
no
change
in
burden
for
this
collection.

6(
e)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
one
hour
per
lessor
survey
and
to
average
30
minutes
per
lessee
survey.
These
estimates
include
the
time
required
to
complete
the
surveys
and
for
the
site
visit
interview.
"
Burden"
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OECA­
2004­
0045,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
tot
he
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
NO.
OECA­
2004­
0045
and
EPA
ICR
number
2161.01
in
any
correspondence.

Part
B
1.
SURVEY
OBJECTIVES,
KEY
VARIABLES,
AND
OTHER
PRELIMINARIES
1(
a)
Survey
Objectives
The
goals
for
each
of
the
surveys
covered
by
this
information
collection
request
are
summarized
below
by
sector:

Lessor
Sector:
To
determine
the
rate
of
compliance
with
the
Disclosure
Rule
by
lessors
in
areas
at
high­
risk
for
lead
poisoning
in
St.
Louis,
Missouri
To
determine
if
additional
Disclosure
Rule
compliance
assistance
materials
should
be
developed
Lessee
Sector:
To
determine
if
lessees
read
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
To
determine
if
lessees
implemented
methods
to
decrease
lead
exposure
as
a
result
of
lead
hazard
awareness
1(
b)
Key
Variables
The
key
variables
in
each
survey
will
be
the
lessors'
compliance
with
the
Disclosure
Rule.
This
compliance
measurement
will
be
determined
as
a
percentage
of
lessor
respondents
within
the
sector
in
compliance
with
the
Disclosure
Rule.

1(
c)
Statistical
Approach
The
population
of
lessors
in
the
targeted
high­
risk
areas
in
St.
Louis
will
be
determined
in
Phase
I
of
the
project.
The
size
of
the
target
population
and
EPA
budget
constraints
require
a
statistical
analysis
using
a
subset
of
lessors
in
the
sector
(
a
minimum
of
100
lessors).
The
EPA
OECA
intends
to
use
Recipient
support
for
the
surveys
and
site
visits.

The
population
of
lessees
in
the
targeted
high­
risk
areas
in
St.
Louis
will
be
determined
during
Phase
I
of
the
project.
The
size
of
the
target
population
and
EPA
budget
constraints
require
a
statistical
analysis
using
a
subset
of
lessees
in
this
sector
(
a
minimum
of
50
lessees).
The
EPA
OECA
intends
to
use
recipient
support
for
the
surveys
and
site
visits.

1(
d)
Feasibility
What
obstacles
might
the
respondents
face
in
completing
the
surveys?
A
goal
of
the
surveys
is
to
assess,
for
the
lessor
sector,
regulatory
awareness
and
compliance
with
respect
to
the
federal
Disclosure
Rule.
The
questions
have
been
structured
in
a
yes/
no
checklist
format
and
the
data
being
requested
should
be
readily
known
by
the
respondents.
In
some
cases
a
respondent
may
need
to
review
lease
records
to
determine
whether
they
have
met
total
compliance.
However,
these
types
of
questions
have
been
minimized
as
much
as
possible.

Are
sufficient
funds
available
to
complete
the
surveys
as
designed?
The
EPA
funds
are
available
for
the
survey
site
visits,
lessor
seminars,
lessee
focus
groups
and
follow­
up
surveys.

Will
the
survey
results
be
ready
in
time
to
serve
the
program's
decision­
making
needs?
Assuming
OMB
approval,
the
data
collection
will
be
completed
within
nine
months
of
the
IRC
approval.
For
the
lessor
sector,
survey
results
will
be
used
for
EPA/
OECA
enforcement
and
compliance
assistance
decisions
for
the
2005
and
beyond
time
frame.

2.
SURVEY
DESIGN
2(
a)
Target
Population
and
Coverage
A
discussion
of
the
target
populations
and
coverage
are
provided
by
sector
below:

Lessor
Sector:
For
the
lessor
sector,
the
target
population
is
lessors
doing
business
in
the
areas
of
St.
Louis,
Missouri
determined
to
be
at
highest
risk
for
childhood
lead
poisoning,
excluding
public
housing
and
other
HUD­
owned
housing.
This
subset
of
lessors
has
been
chosen
for
coverage
since
the
ICR
input
will
be
used
by
EPA
Region
7
in
their
section
1018
inspection
targeting
efforts.
Lessee
Sector:
For
the
lessee
sector,
the
target
population
is
lessees
leasing
rental
property
in
the
areas
of
St.
Louis,
Missouri
determined
to
be
at
highest
risk
for
childhood
lead
poisoning.
This
subset
of
lessees
has
been
chosen
for
coverage
since
the
ICR
input
will
be
used
by
EPA
Region
7
in
planning
the
nonregulatory
outreach
to
this
subset
of
respondents
and
will
be
used
by
EPA,
HUD
and
MDoH
to
assess
the
effectiveness
of
their
education
and
outreach.

2(
b)
Sample
Design
The
sampling
design
by
sector
to
be
surveyed
is
presented
below:

Lessor
Sector:
Sampling
Frame:
The
sampling
frame
for
this
sector
is
the
EPA
Region
7
lessors
which
have
been
identified
by
the
Recipient.

Sample
Size:
Based
on
standard
statistical
sampling
techniques,
EPA
has
estimated
that
a
sample
size
of
100
lessors
will
be
required
to
estimate
a
compliance
rate
for
lessors.
To
arrive
at
this
range,
EPA
began
by
determining
the
appropriate
equation
for
determining
the
sample
size
for
estimating
a
sample
proportion.

Stratification
Variables:
In
drawing
the
random
sample,
EPA
will
stratify
the
sample
size
among
the
targeted
high­
risk
areas
based
on
the
proportion
of
lessors
in
each
area.
The
EPA
is
not
intending
to
make
comparisons
between
the
areas
using
a
set
precision
or
calculate
a
valid
performance
rate
by
zip
code
areas
(
i.
e.,
EPA
is
not
drawing
a
valid
random
sample
by
zip
code).
Rather,
EPA
is
stratifying
the
sample
to
ensure
representation
among
all
zip
code
areas.
The
EPA
has
not
yet
determined
the
specific
percentages
that
will
be
applied
to
each
zip
code
area.

Sampling
Method:
The
Recipient
will
conduct
the
surveys
on
this
sector
as
a
voluntary
random
sample.
The
EPA
will
assign
each
lessor
a
random
number
(
using
a
random
number
generator
such
as
the
one
available
in
Microsoft
Excel)
and
then
sort
the
list
using
the
random
number.
The
first
100
lessors
in
this
sorted
list
will
constitute
the
random
sample
and
is
specified
below.

The
EPA
anticipates
that
each
lessor
visited
in
the
site
visit
survey
will
result
in
a
completed
survey.
In
the
event
that
some
lessors
do
not
agree
to
participate
in
the
site
visit
program,
EPA
will
continue
to
pull
lessors
from
the
sorted
list
of
lessors
until
the
desired
sample
size
is
attained
(
i.
e.,
100
lessors).
The
EPA
will
track
which
lessors
declined
to
participate
and
use
available
information
on
these
lessors
(
e.
g.
size,
location,
etc.)
to
determine
if
some
nonresponse
bias
exists.

Lessee
Sector:
Sampling
Frame:
The
sampling
frame
for
this
sector
is
EPA
Region
7
lessees
which
have
been
identified
through
the
lessor
surveys.

Sample
Size:
The
EPA
will
follow
the
same
methodology
and
assumptions
as
described
above
for
lessees
in
choosing
a
sample
size
for
the
lessees
sector.

Stratification
Variables:
The
EPA
will
stratify
the
random
sample
by
zip
code
area
for
the
on­
site
surveys
and
will
ensure
that
each
of
the
targeted
high­
risk
areas
in
St.
Louis,
Missouri
is
represented
in
the
survey.
The
EPA
will
use
the
information
contained
in
the
sampling
frame
to
determine
the
percentages
of
each
zip
code
area.
As
with
the
method
for
lessors,
EPA
is
not
intending
to
make
comparisons
between
zip
code
areas
with
known
precision,
but
is
only
concerned
with
ensuring
representation
for
all
lessees
in
the
high­
risk
areas
of
St.
Louis,
Missouri.

Sampling
Method:
The
Recipient
will
conduct
the
surveys
on
this
sector
as
a
voluntary
random
sample.
The
EPA's
recipient
will
assign
each
survey
lessee
a
random
number
(
using
a
random
number
generator
such
as
the
one
available
in
Microsoft
Excel)
and
then
sort
the
list
using
the
random
number.
The
first
50
lessees
in
this
sorted
list
will
constitute
the
random
sample
and
is
specified
below.

The
EPA
anticipates
that
each
lessee
visited
in
the
site
visit
survey
will
result
in
a
completed
survey.
In
the
event
that
some
lessees
do
not
agree
to
participate
in
the
site
visit
program,
EPA's
recipient
will
continue
to
pull
lessees
from
the
sorted
list
of
lessees
until
the
desired
sample
size
is
attained
(
i.
e.,
50).
The
EPA's
recipient
will
track
which
lessees
declined
to
participate
and
will
use
available
information
on
these
facilities
(
e.
g.,
location,
etc.)
to
determine
if
some
nonresponse
bias
exists.

2(
c)
Precision
Requirements
Precision:
The
EPA's
sample
size
estimates
are
based
on
ten
percentage
points
in
precision
and
a
90
percent
confidence
level.
That
is,
EPA
will
be
90
percent
certain
that
the
estimated
results
will
be
within
plus
or
minus
10
percentage
points
of
the
actual
(
population)
results.
This
precision
will
allow
for
the
identification
of
trends
in
the
results.
Greater
precision
in
the
results
is
not
practical
since
the
required
sample
sizes
for
a
small
sampling
error
are
significantly
greater
and
beyond
the
budget
available
to
EPA
for
these
studies.

2(
d)
Questionnaire
Design
Lessor
Survey:
A
draft
of
the
survey
for
the
lessor
sector
is
included
here
as
Attachment
B.
It
contains
both
an
interview
section
and
a
records
review
section.
The
lessor
survey
is
designed
to
provide
general
information
on
compliance
with
the
Disclosure
Rule
by
requesting
information
on
practices
related
to
Disclosure
Rule
requirements
and
by
reviewing
lessor
records.

The
interview
questions
of
the
survey
request
general
information
about
the
lessor's
awareness
of
the
Disclosure
Rule
and
whether
s/
he
is
in
compliance
or
his/
her
level
of
noncompliance.
The
records
review
portion
of
the
survey
is
designed
to
determine
whether
the
lease
contained
the
lead
warning
statement,
whether
reports
were
provided
to
the
lessee,
whether
the
lease
form
was
properly
documented,
etc.
The
following
sections
provide
a
detailed
description
of
the
rationale
for
the
questions
in
the
survey.
°
Questions
1
through
5
in
the
Interview
survey
request
information
about
the
lessor's
level
of
awareness
of
the
Disclosure
Rule,
knowledge
of
lead­
based
paint
hazards
in
his/
her
properties,
whether
they
provided
the
EPA/
HUD
lead­
hazard
pamphlet,
and
whether
certain
other
disclosure
information
was
provided
to
the
lessee.
°
Questions
1
and
2
of
the
Records
Review
survey
relate
to
the
appropriateness
of
the
lease
itself.
°
Questions
3
through
5
examine
whether
knowledge
of
lead
hazards
was
disclosed.
°
Questions
6
through
12
demonstrate
whether
the
lease
agreement
was
properly
documented.

Lessee
Survey:
The
EPA's
survey
for
the
lessee
sector
will
be
developed
by
the
Recipient
upon
ICR
approval
by
OMB.
This
survey
will
be
used
to
obtain
information
to
evaluate
the
level
of
behavior
change
occurring
in
the
lessee
sector
and
to
evaluate
the
impacts
of
nonregulatory
outreach
and
awareness.
The
second
component
is
a
checklist
that
will
be
used
during
the
site
visit
to
verify
information
obtained
during
the
lessors'
surveys.
This
checklist
will
compare
the
lessee
responses
to
the
lessor
responses.

The
lessee
survey
is
designed
to
provide
data
regarding
whether
the
lessee
read
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet
and
whether
the
lessee
implemented
methods
to
decrease
lead
exposure
as
a
result.

3.
PRETESTS
AND
PILOT
TESTS
The
EPA
Region
7
will
not
conduct
a
pre­
test
or
pilot
test
of
their
surveys.

4.
COLLECTION
METHODS
AND
FOLLOW­
UP
4(
a)
Collection
Methods
For
each
sector
survey,
EPA
intends
to
conduct
survey
collection
data
through
a
site
visit
program.
4(
b)
Survey
Response
and
Follow­
Up
For
the
site
visit
surveys,
EPA
expects
to
achieve
a
completed
survey
for
each
site
visited.
Survey
data
will
be
recorded
on
paper
survey
forms.

5.
ANALYZING
AND
REPORTING
SURVEY
RESULTS
5(
a)
Data
Preparation
For
each
survey,
EPA
or
its
Recipient
will
enter
the
survey
results
into
an
electronic
database
using
off­
the­
shelf
software
(
e.
g.
Excel,
Access).
The
data
entry
will
be
double­
checked
to
ensure
that
data
were
entered
accurately
and
missing
data
items
will
be
flagged.
The
Recipient
will
attempt
to
collect
any
missing
data
items
in
the
lessor
sector
through
phone
contacts
with
the
lessors.

5(
b)
Analysis
The
survey
and
seminar
results
will
be
analyzed
to
determine:
°
Each
lessor's
compliance
with
the
federal
Disclosure
Rule.
°
Key
compliance
problem
areas
where
a
majority
of
lessors
sampled
appear
to
be
unaware
of
or
potentially
noncompliant
with
the
key
federal
requirement.
°
Compliance
assistance
outreach
methods
preferred
by
the
lessors.
°
Percentage
of
lessees
who
read
the
Protect
Your
Family
From
Lead
In
Your
Home
pamphlet.
°
Percentage
of
lessees
who
implement
methods
to
reduce
lead
exposure
as
a
result
of
lead
hazard
awareness.
°
Lead
information
nonregulatory
outreach
approaches
preferred
by
the
lessees.

To
look
at
these
issues,
EPA
will
employ
a
variety
of
statistical
techniques,
including:

Analysis
of
variance
 
EPA
will
use
analysis
of
variance
(
ANOVA)
techniques
to
explore
the
sources
of
variation
in
the
data.
EPA
may
employ
a
multiple
factor
ANOVA
to
look
for
significant
differences
across
both
the
sectors
and
survey
methods.

Other
 
EPA
will
explore
the
use
of
other
techniques
such
as
correlation
analysis
or
regression
analysis.
One
analysis
may
be
discriminant
analysis
which
attempts
to
derive
reliable
predictors
for
a
certain
variable.

These
statistical
techniques
are
described
and
found
in
a
variety
of
statistical
text
books
such
as
Kachigan,
Sam
Kash,
Statistical
Analysis,
New
York:
Radius
Press.

One
purpose
of
this
sampling
will
be
to
compare
the
responses
of
the
lessor
surveys
with
the
lessee
surveys.
The
EPA
will
have
confidence
in
the
site
visit
survey
responses
since
the
survey
takers
will
be
able
to
verify
that
the
responses
given
are
correct.
The
EPA
will
be
able
to
assess
the
quality
and
accuracy
of
the
information
collected
from
the
lessors
by
comparing
to
the
lessee
survey
responses.

In
addition,
EPA
will
assess
the
actual
burden
(
respondents
and
agency)
required
to
solicit,
respond,
and
review
surveys.

5(
c)
Reporting
Results
Each
set
of
survey
results
will
be
summarized
and
documented
in
a
sector­
based
report.
The
reports
will
be
made
available
to
other
EPA
personnel
and
to
HUD
and
MDoH.
The
databases
developed
under
these
survey
activities
will
be
publicly
available
upon
request.
ATTACHMENT
A
Table
1.
Respondent
Burden
and
Costs
Activity
Burden
Hours
and
Cost
Per
Recipient
Total
Burden
Hours
and
Cost
For
All
Recipients
Labor
Hours
Costs
(
a)
Labor
Hours
Costs
(
a)

Lessor
Surveys
2.0
$
95.24
200
$
9,524.00
Lessee
Surveys
0.5
$
23.81
25
$
1,190.50
Totals
225
$
10,714.50
(
a)
Assumes
a
$
47.62/
hr
rate
base
on
the
Bureau
of
Labor
Statics
"
Employer
Costs
for
Employment
Compensation."
[$
29.76
+
60%
overhead
=
$
47.62/
hr]
No
other
direct
costs
[
ODCs]
are
anticipated
for
the
sector
surveys.
ATTACHMENT
A
(
cont'd.)

Table
2.
Agency
Burden
and
Costs
Sector
Activity
Costs
Labor
Total
Costs
Hours
Costs
(
a)

Lessor
Survey
Oversight
&
Admin.
142
$
4,967.00
$
4,967.00
Lessee
Survey
Oversight
&
Admin
18
$
630.00
$
630.00
Totals
160
$
5,597.00
(
a)
Agency
$/
hr
rate
is
based
on
a
1998
GS
13/
01
salary
of
$
55,969
or
26.91/
hr.
with
a
30%
overhead.

The
resulting
hourly
rate
is
$
34.98/
hr.
ATTACHMENT
A
(
cont'd.)

Table
3.
Summary
of
Burden
and
Costs
to
Respondents
and
EPA
Category
Total
Labor
Hours
Total
Costs
($)

Respondent
Burden
225
$
10,715.00
Agency
Burden
160
$
5,597.00
Totals
385
$
16,312.00
