Renewal
of
an
Information
collection
request
for
Regulatory
Reinvention
Pilot
Projects
Under
Project
XL
OMB
Control
No.
2010­
0026
EPA
ICR
No.
1755.06
The
United
States
Environmental
Protection
Agency
April
2002
Table
of
Contents
Title
Page
1.
Identification
of
the
Information
Collection
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
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2
2(
b)
Practical
Utility/
Users
of
the
Data
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2
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
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3
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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3
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Collection
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3
3(
e)
General
Guidelines
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3
3(
f)
Confidentiality
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3
3(
g)
Sensitive
Questions
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3
4.
The
Respondents
and
The
Information
Requested
4(
a)
Respondents/
NAICS
Codes
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3
4(
b)
Information
Requested
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4
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I)
Data
items,
including
record
keeping
requirements
(
II)
Respondent
Activities
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
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5
5(
b)
Collection
Methodology
and
Management
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5
5(
c)
Small
Entity
Flexibility
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6
5(
d)
Collection
Schedule
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6
6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
and
Cost
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6
6(
b)
Estimating
Agency
Burden
and
Cost
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8
6(
c)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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9
6(
d)
Reason
for
Burden
Hour
Change
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10
7.
Burden
Statement
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10
1
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
Regulatory
Reinvention
Pilot
Projects
Under
Project
XL
(
ICR)
(#
1755.06)

1.
Identification
of
the
information
collection
1(
a)
Title
and
Number
of
the
Information
Collection
Title:
Regulatory
Reinvention
Pilot
Projects
Under
Project
XL,
ICR
No.
1755.06,
OMB
Control
No.
2010­
0026.

1(
b)
Short
Characterization
This
is
a
request
for
renewal
of
currently
approved
ICR
No.
1755.05,
which
authorizes
the
solicitation
of
proposals
for
innovative
pilot
projects.
A
60­
day
comment
period
for
this
ICR
renewal
in
the
Federal
Register
concluded
on
January
8,
2002,
during
which
no
comments
were
received.
In
1995,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
began
to
solicit
innovative
pilot
projects
in
response
to
a
challenge
to
transform
the
environmental
regulatory
system
to
better
meet
the
needs
of
a
rapidly
changing
society
while
maintaining
the
nation's
commitment
to
protect
human
health
and
safeguard
the
natural
environment.
Through
site­
specific
agreements
with
project
sponsors,
EPA
is
gathering
data
and
project
experience
that
is
helping
the
Agency
redesign
current
approaches
in
pursuit
of
improved
public
health
and
environmental
protection
and
more
efficient
use
of
limited
resources.

The
intent
of
innovative
pilot
projects
is
to
allow
EPA
to
experiment
with
untried,
potentially
promising
regulatory
approaches,
both
to
assess
whether
they
provide
superior
environmental
performance
and
other
benefits
at
the
specific
facility
affected,
and
whether
they
should
be
considered
for
wider
application.
Such
pilot
projects
allow
EPA
to
proceed
more
quickly
than
would
be
possible
when
undertaking
changes
on
a
nationwide
basis.
EPA
may
modify
rules,
on
a
site­
or
state­
specific
basis,
that
represent
one
of
several
possible
policy
approaches
within
a
more
general
statutory
directive,
so
long
as
the
alternative
being
used
is
permissible
under
the
statute.

The
adoption
of
such
alternative
approaches
or
interpretations
in
the
context
of
a
given
project
does
not,
however,
signal
EPA's
willingness
to
adopt
that
interpretation
as
a
general
matter,
or
even
in
the
context
of
other
pilot
projects.
It
would
be
inconsistent
with
the
forward­
looking
nature
of
these
pilot
projects
to
adopt
such
innovative
approaches
prematurely
on
a
widespread
basis
without
first
determining
whether
or
not
they
are
viable
in
practice
and
successful
for
the
particular
projects
that
embody
them.
These
pilot
projects
are
not
intended
to
be
a
means
for
piecemeal
revision
of
entire
programs.
Depending
on
the
results
of
these
projects,
EPA
may
or
may
not
be
willing
to
consider
2
adopting
the
alternative
approach
or
interpretation
again,
either
generally
or
for
other
specific
facilities.
EPA
believes
that
adopting
alternative
policy
approaches
and/
or
interpretations,
on
a
limited,
site­
or
state­
specific
basis
and
in
connection
with
a
carefully
selected
pilot
project
is
consistent
with
the
expectations
of
Congress
about
EPA's
role
in
implementing
the
environmental
statutes
(
so
long
as
EPA
acts
within
the
discretion
allowed
by
the
statute).
Congress'
recognition
that
there
is
a
need
for
experimentation
and
research,
as
well
as
ongoing
reevaluation
of
environmental
programs,
is
reflected
in
a
variety
of
statutory
provisions.

Innovative
pilot
project
proposals
are
collected
by
EPA's
Office
of
Environmental
Policy
Innovation
(
OEPI)
[
formerly
the
Office
of
Reinvention],
which
has
been
given
responsibility
for
implementation
of
this
program.
Since
1995,
EPA
has
implemented
pilot
projects
to
test
innovative
ideas
working
with
EPA
headquarters,
EPA
regions,
Federal,
State,
and
local
government
agencies.
The
renewal
of
this
ICR
is
important
as
it
will
allow
the
Agency
to
work
with
additional
regulated
entities
who
are
interested
in
participating
in
innovative
pilot
projects
as
well
as
allow
the
Agency
to
continue
its
commitment
to
innovation
and
regulatory
flexibility
with
facilities,
communities,
States,
and
Tribes
in
achieving
environmental
results.
The
renewal
of
this
ICR
will
allow
OEPI
to
continue
to
receive
and
work
with
project
sponsors
on
proposals
for
innovation,
including
those
directly
through
EPA
and
those
through
the
Joint
EPA­
State
Agreement
to
Pursue
Regulatory
Innovation.
In
addition,
the
renewal
of
this
ICR
is
necessary
to
allow
EPA
to
continue
its
commitments
to
current
projects,
including
three
specified
in
recently
approved
ICR
amendments:
the
NYSDEC
ICR
amendment
(
1755.03),
the
US
Filter
ICR
amendment
(
1755.04)
and
the
POTWs
ICR
amendment
(
1755.05).

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
information
is
needed
to
continue
to
allow
the
Agency
to
work
with
additional
regulated
entities
who
are
interested
in
participating
in
innovative
pilot
projects
as
well
as
allow
the
Agency
to
continue
its
commitment
to
innovation
and
regulatory
flexibility
with
facilities,
communities,
States
and
Tribes
in
achieving
environmental
results.
Under
this
ICR,
EPA
is
to
solicit
its
regulated
entities
for
their
best
ideas
on
regulatory
innovation,
and
for
pilot
projects
to
test
those
ideas.
Potential
project
sponsors
will
continue
to
submit
completed
proposals
to
the
Office
of
Environmental
Policy
Innovation
at
EPA.

2(
b)
Practical
Utility/
Uses
of
the
Data
The
proposals
to
be
collected
pursuant
to
this
renewal
are
used
to
develop
full­
fledged
pilot
projects
and
then
to
document
the
implementation
of
the
projects.
A
competitive
process
ensures
that
EPA
can
choose
from
a
pool
of
useful
project
ideas.
Moreover,
the
simple
and
flexible
proposal
format
used
allows
a
diversity
of
regulated
entities,
small
as
well
as
large
firms,
agencies,
and
communities,
to
develop
proposals.
EPA
uses
the
proposal
submissions
to
screen
ideas
and
select
the
most
promising
ones
for
further
project
development.
3
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
Federal
agency.

3(
b)
Public
Notice
Required
Prior
to
ICR
3(
c)
Consultations
This
notice
was
developed
by
a
team
consisting
of
EPA
headquarters
personnel.

3(
d)
Effects
of
Less
Frequent
Collection
For
proposal
solicitation,
there
will
be
sufficient
time
between
information
requests
related
to
innovative
pilots
to
reflect
actions
taken
in
response
to
participant
and
stakeholder
comments.
There
are
no
technical
or
legal
obstacles
to
reducing
the
burden.

3
(
e)
General
Guidelines
This
ICR
complies
with
OMB's
general
guidelines
for
the
collection
of
information.

3(
f)
Confidentiality
The
nature
of
the
data
being
requested
as
part
of
this
information
collection
is
not
confidential.

3(
g)
Sensitive
Questions
The
information
gathering
activities
discussed
in
this
ICR
do
not
involve
any
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
NAICS
Codes
EPA
works
with
a
variety
of
businesses,
organizations,
and
communities
within
the
regulated
community,
as
well
as
Federal
facilities,
States,
Tribes,
and
local
governments.
Potential
4
respondents
include
all
entities
regulated
by
EPA
pursuant
to
its
authority
under
the
various
environmental
statutes
who
wish
to
participate
in
innovative
pilot
projects.

4(
b)
Information
Requested
Information
collection
activities
fall
generally
into
two
categories:
the
Pre­
proposal
phase
and
the
Proposal
development
phase.

During
the
Pre­
proposal
phase,
sponsors
typically
engage
in
the
following
information
collection
activities:

°
Review
innovative
pilot
project
proposal
instructions.
This
will
contain
information
about
how
to
apply
to
obtain
EPA
approval
in
order
to
test
an
innovative
idea,
requiring
EPA
approval,
as
well
as
details
and
requirements
regarding
EPA's
innovative
pilot
program.

°
Discuss
innovative
pilot
project
pre­
proposal
idea
with
EPA
and
the
appropriate
State
or
Tribe.
EPA
encourages
sponsors
to
engage
in
substantive
dialogues
with
EPA
and
the
appropriate
State
or
Tribe
before
fully
developing
a
proposal
to
be
formally
submitted
for
EPA
consideration.
During
these
dialogues,
EPA
expects
to
ask
the
sponsor
to
discuss:


General
information
such
as
the
facility,
nearby
community,
geographic
area,
as
well
as
facility
contact
information.


A
general
description
of
the
innovative
idea
including
a
summary
or
overview
of
the
potential
project
and
specific
project
elements.


How
the
potential
project
meets
specific
innovative
pilot
project
criteria
such
as
superior
environmental
performance,
cost
savings,
stakeholder
involvement,
innovation
or
pollution
prevention,
transferability,
feasibility,
evaluation,
monitoring,
accountability,
and
shifting
of
risk
burden.


A
description
of
the
flexibility
from
regulations
that
the
sponsor
is
requesting
(
if
necessary),
an
enforcement
and
compliance
profile
and
project
schedule
information.

During
the
Proposal
development
phase,
sponsors
typically
engage
in
the
following
information
collection
activities:

°
Conduct
innovative
pilot
project
proposal
development
discussions
with
EPA
and
the
appropriate
State
or
Tribe.
During
these
discussions,
EPA
expects
sponsors
to
provide
more
details
regarding
how
the
potential
innovative
pilot
project
will
be
implemented;
and
how
the
sponsor
will
meet
innovative
pilot
project
program
criteria.
These
discussions
will
enable
the
sponsor
to
better
understand
how
an
innovative
pilot
project
could
realistically
be
structured,
and
therefore,
develop
a
proposal
that
will
more
likely
gain
acceptance
by
EPA.
Further,
these
discussions
will
enable
the
entity
to
better
understand
how
the
innovative
pilot
5
project
idea
aligns,
or
could
be
aligned,
with
the
appropriate
State's
or
Tribe's
environmental
priorities.

°
Write
the
project
proposal.
EPA
has
no
pre­
determined
format
for
proposals.
However,
EPA
expects
that
sponsors
will
formally
describe
relevant
entity
background
information,
the
innovative
pilot
project
idea,
how
the
idea
fits
criteria
for
EPA
innovative
pilot
projects,
and
expected
timeframe
of
the
potential
project.

°
Conduct
internal
project
proposal
review.
Project
sponsors
typically
seek
approval
from
key
decision
makers
within
the
sponsor
organization
and
make
necessary
modifications.

°
Send
the
pilot
project
proposal.
At
the
conclusion
of
proposal
development,
the
sponsor
will
make
the
proposal
available
to
EPA
and
the
appropriate
State
or
Tribe.

As
mentioned
above,
States
or
Tribes
may
ask
for,
and
provide,
information
during
both
the
preproposal
and
proposal
development
phases.

Many
more
entities
will
discuss
their
pre­
proposal
ideas
for
innovative
pilot
projects
than
those
who
actually
gain
EPA's
and
the
State's
or
Tribe's
acceptance
to
move
forward
on
developing
a
formal
proposal
for
EPA
consideration.

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

5(
a)
Agency
Activities
Agency
activities
associated
with
the
collection
of
information
for
innovative
pilot
projects
include:

°
Gather
information
from
sponsors
regarding
innovative
ideas
during
pre­
proposal
phase;

°
Evaluate
pre­
proposal
ideas
with
cross­
Agency
team;

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

°
Distribute
proposals
across
Agency;
and
°
Evaluate
proposals
with
cross­
Agency
team.

5(
b)
Collection
Methodology
and
Information
Management
The
collection
process
for
proposal
solicitation
and
development
is
as
follows.
EPA
places
this
solicitation
in
the
Federal
Register.
EPA
also
distributes
copies
upon
request,
and
participates
where
invited
in
workshops
designed
to
assist
potential
project
proponents
in
development
of
6
proposals.
Sponsors
engage
in
discussions
with
EPA
to
gauge
whether
their
ideas
require
approval
by
EPA
and/
or
the
appropriate
State
or
Tribe
before
moving
forward,
and,
if
so,
whether
their
ideas
could
realistically
gain
approval
by
EPA
and
the
appropriate
State
or
Tribe.
If,
based
upon
these
discussion,
a
sponsor
determines
that
a
full
proposal
should
be
submitted
to
EPA,
the
sponsor
may
then
develop,
and
then
submit
the
proposal
to
EPA.
Proposals
are
sent
to
an
EPA
docket
where
they
are
logged
in
and
catalogued.
Additional
copies
are
then
sent
to
OEPI
for
screening,
reference
purposes,
and
distribution
to
a
cross­
agency
committee
for
proposal
review.

5
(
c)
Small
Entity
Flexibility.

The
flexible
proposal
process
described
earlier
is
designed
to
be
useful
to
large
as
well
as
small
entities.
Innovative
pilot
projects
are
voluntary
and
entities
can
choose
not
to
participate
at
any
time
if
undue
burden
exists.
It
was
designed
to
be
simple
to
respond
to,
with
no
undue
burden
on
entities
without
full­
time
environmental
managers,
etc.

5(
d)
Collection
Schedule.

The
collection
schedule
for
proposal
solicitation
and
development
is
on
a
rolling
basis.
EPA
maintains
an
open
solicitation
for
proposals
that
was
initiated
in
1995
with
the
publication
of
the
initial
notice
and
has
no
set
end
date.

6.
Estimating
the
Burden
and
the
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
and
Cost
This
section
presents
EPA's
estimates
of
the
burden
and
costs
necessary
to
complete
the
information
collection
activities
associated
with
this
collection.
Burden
hours
and
costs
were
based
upon
estimates
provided
by
EPA
staff
with
extensive
experience
working
with
innovative
pilot
project
sponsors
and
States
to
assess
innovative
pilot
project
ideas
and
proposals.

EPA
estimates
average
hourly
respondent
labor
cost
(
including
fringe
and
overhead)
of
$
106
for
legal
staff,
$
83
for
managerial
staff,
$
55
for
technical
staff,
and
$
29
for
clerical
staff.
To
derive
these
estimates
EPA
referred
to
the
Supporting
Statement
for
ICR
#
801.14
entitled"
Requirements
for
Generators,
Transporters,
and
Waste
Management
Facilities
Under
the
RCRA
Hazardous
Waste
Manifest
System"
(
January
31,
2002:
http://
www.
epa.
gov/
icr/
icrs/
icrpages/
0801ss14.
htm).
These
estimates
were
"
based
on
industry
consultations
conducted
by
EPA
several
years
ago
and
updated
to
2001
levels
using
Employment
Cost
Indexes
developed
by
the
U.
S.
Bureau
of
Labor
Statistics."

To
estimate
State
and
Tribe
cost,
the
hourly
wage
was
based
upon
2002
GS­
9/
10
salary
of
$
49,924
(
or
$
24.00)
with
overhead
of
110%
factored
in,
resulting
in
$
50/
hour.

In
using
this
analysis
it
should
be
remembered
not
only
that
all
responses
to
this
solicitation
are
voluntary,
but
that
sponsors
have
some
expected
value
attached
with
their
participation.
Not
unlike
a
contracts­
based
Request
For
Proposals,
one
would
not
expect
a
response
from
any
entity
where
7
the
burdens
associated
with
preparing
the
response
outweigh
the
expected
benefits
to
the
sponsor.

EPA
expects
a
range
of
entities
 
facilities,
companies,
Federal
facilities,
municipalities,
States,
or
Tribes
 
to
provide
EPA
with
up
to
80
pre­
proposal
ideas
per
year
over
the
life
of
this
ICR.
From
these
80,
EPA
expects
40
formal
proposals
to
be
submitted
to
EPA
each
year
over
the
life
of
this
ICR.
Further,
EPA
expects
that
approximately
half
of
the
pre­
proposal
ideas
formally
discussed
(
40
of
80)
with
EPA
and
half
the
proposals
formally
submitted
(
20
of
40)
to
EPA
will
have
multi­
facility,
multi­
company,
multi­
Federal
facility,
multi­
State,
or
multi­
community
sponsors.
EPA
expects
that
multi­
facility
proposal
will
average
five
sponsors
per
pre­
proposal
idea
or
formal
proposal.

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

Assuming
that
sponsors
provide
EPA
with
80
pre­
proposal
ideas
per
year,
EPA
expects
that
engagement
in
Pre­
proposal
phase
activities
described
above
will
require
6,480
hours
of
sponsor
time
and
cost
sponsors
$
524,880
per
year.

Assuming
that
sponsors
provide
EPA
with
40
formal
proposals
per
year,
EPA
expects
that
engagement
in
proposal
development
activities
described
above
will
require
51,840
hours
of
sponsor
time
and
cost
sponsors
$
3,955,080
per
year.

EPA
expects
that
consultations
conducted
by
the
appropriate
State
or
Tribe
with
sponsors
for
both
Pre­
proposal
phase
activities
as
well
as
proposal
development
phase
activities,
will
require
2,520
hours
of
State
or
Tribal
time
and
cost
the
States
and
Tribes
$
337,800
per
year.

It
is
important
to
keep
in
mind
that
many
more
sponsors
will
discuss
their
pre­
proposal
ideas
for
innovative
pilot
projects
than
those
who
actually
gain
EPA
and
the
State
or
Tribe's
acceptance
to
move
forward
on
developing
a
formal
proposal
for
EPA
consideration.
Further,
some
pre­
proposal
ideas
and
formal
proposals
will
have
multiple
sponsors.
These
considerations
have
been
incorporated
into
the
development
of
burden
and
cost
estimates
described
in
the
table
below.
Staff
in
the
Office
of
Environmental
Policy
Innovation
that
work
on
the
development
of
innovative
pilot
projects
have
reviewed
the
cost
findings
of
the
report
and
found
them
to
be
reasonable
and
sound
estimates
of
current
and
future
costs.
8
Table
1.
Average
Annual
Burden
and
Cost
to
Respondents
Collection
Activity
Burden
Hours
and
Individual
Costs
per
Recipient
Total
Costs
Hours
per
Respondent
per
Activity
Costs
per
Respondent
per
Activity
Total
Hours
for
all
Respondents
Total
Costs
for
all
Respondents
Legal
Mgmt
Tech
Cler
SPONSORS:
PRE­
PROPOSAL
PHASE
Review
innovative
pilot
project
proposal
instructions
3
3
3
$
729
2160
$
174,960
Discuss
pre­
proposal
idea
with
EPA
3
3
3
$
729
2160
$
174,960
Discuss
pre­
proposal
idea
with
State/
Tribe
3
3
3
$
729
2160
$
174,960
TOTAL
9
9
9
$
2,187
6480
$
524,880
SPONSORS:
PROPOSAL
DEVELOPMENT
PHASE
Proposal
development
discussions
with
EPA
12
3
12
$
2,169
3240
$
260,280
Proposal
development
discussions
with
State/
Tribe
20
20
20
$
4,860
7200
$
583,200
Writing
project
proposal
80
10
120
5
$
15,930
25800
$
1,911,600
Internal
proposal
review
40
40
40
$
9720
14400
$
1,166,400
Send
proposal
10
$
280
1200
$
33,600
TOTAL
152
73
192
15
$
32,959
51840
$
3,955,080
STATE/
TRIBE:
CONSULTATION
WITH
PROPOSAL
SPONSORS
Pre­
proposal
discussions
with
sponsor
9
3
9
$
1,689
1680
$
135,120
Proposal
development
discussions
with
sponsor
9
3
9
$
1,689
840
$
202,680
TOTAL
18
6
18
$
3,378
2520
$
337,800
6(
b)
Estimating
Agency
Burden
and
Cost
Agency
burden
hours
and
costs
were
based
upon
estimates
provided
by
EPA
staff
with
extensive
experience
working
with
innovative
pilot
project
sponsors
and
States
to
assess
innovative
pilot
project
ideas
and
proposals.
The
rate
EPA
used
to
estimate
agency
hourly
wage
was
based
upon
2002
GS­
13/
01
salary
of
$
66,229
(
or
$
31.84)
with
overhead
of
110%
factored
in,
resulting
in
$
67/
hour.

To
perform
the
necessary
activities
associated
with
this
information
collection,
EPA
estimates
1EPA
expects
that
80
pre­
proposal
ideas
will
be
submitted
annually.
EPA
estimates
that,
of
these,
40
of
these
will
most
likely
have
multiple
sponsors.
EPA
estimates
that
the
number
of
sponsors
for
each
"
multi­
sponsor"
pre­
proposal
will
equal
five.
This
brings
the
number
of
pre­
proposal
respondents
to
240
(=
200+
40).

2
EPA
expects
that
40
formal
proposals
will
be
submitted
annually.
EPA
estimates
that,
of
these,
20
will
most
likely
have
multiple
sponsors.
EPA
estimates
that
the
number
of
sponsors
for
each
"
multi­
sponsor"
proposal
will
equal
five.
This
brings
the
number
of
pre­
proposal
respondents
to
120
(=
100+
20).

9
that
it
will
require
the
Agency
13,960
hours
and
cost
the
Agency
$
935,320
per
year.
It
is
important
to
remember
that
EPA
will
work
with
fewer
sponsors
after
screening
out
initial
preproposal
ideas.
Further,
some
ideas
and
formal
sponsor
will
be
associated
with
several
sponsors.
These
considerations
have
been
incorporated
into
the
estimates
below.

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

Collection
Activity
Costs
Labor
Total
Hours
Total
Costs
Hours
Costs
EPA
Gather
information
from
sponsor
entities
regarding
innovative
idea
during
pre­
proposal
phase
through
discussions
24
$
1,608
1920
$
128,640
Evaluate
pre­
proposal
with
cross­
Agency
team
30
$
2,010
2400
$
160,800
Gather
additional
information
from
sponsor
entities
regarding
innovative
pilot
projects
ideas
to
assist
sponsor
entities
in
developing
proposals
180
$
12,060
7200
$
482,400
Distribute
proposals
across
Agency
1
$
67
40
$
2,680
Evaluate
proposal
with
cross­
Agency
team
60
$
4,020
2400
$
160,800
TOTAL
13960
$
935,320
6(
c)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
estimates
that,
annually,
240
respondents1
will
be
involved
in
pre­
proposal
idea
information
collection
activities.
To
complete
these
associated
activities,
EPA
estimates
that
it
will
cost
each
respondent
$
2,187
per
year
and
require
27
hours.
EPA
estimates
that,
annually,
120
respondents2
will
be
involved
in
proposal
development
information
collection
activities.
To
complete
these
associated
activities,
EPA
estimates
that
it
will
cost
each
respondent
$
32,959
per
year
and
require
432
hours.

EPA
estimates
that
States
and
Tribes
will
be
involved
in
120
consultations
with
sponsors
submitting
innovative
ideas
(
80)
and
proposals
(
40)
each
year.
Total
burden
hours
for
any
State
or
Tribe
participating
in
consultation
regarding
innovative
ideas
will
cost
each
State
or
10
Tribe
$
1,689
per
year
and
require
1,680
hours.
Total
burden
hours
for
any
State
or
Tribe
participating
in
consultation
regarding
the
submission
of
formal
proposals
for
innovative
will
cost
each
State
or
Tribe
$
1,689
per
year
and
require
21
hours.

The
total
number
of
respondents
including
those
submitting
ideas
and
proposals
and
those
providing
consultation
(
States
and
Tribes)
equals
480.
Total
annual
burden
hours
for
these
respondents
equals
60,840
at
a
cost
of
$
4,817,760
annually.

6(
d)
Reasons
for
Burden
Hour
Change
OMB
currently
has
approved
236,130
burden
hours
for
EPA
to
solicit
ideas
and
formal
proposals
to
develop
innovative
pilot
projects.
This
total
also
includes
annual
burden
hours
approved
as
part
of
three
amendments
to
ICR
(
1755.02).
EPA
requires
11,458
hours
annually
to
perform
information
collection
activities
described
in
the
ICR
amendments
(
1755.03,
1755.04,
and
1755.05).
With
the
renewal
of
this
ICR,
total
annual
hours
needed
to
conduct
information
collection
activities
described
in
this
ICR,
as
well
as
in
the
three
ICR
amendments
listed
above,
will
reduce
by
163,832
hours.
This
difference
is
a
result
of
a
better
understanding
of
the
burden
requirements
necessary
to
submit
proposals
for
innovative
pilot
projects,
and
an
improved
understanding
of
innovative
pilot
projects
and
how
to
develop
them.

7.
Burden
Statement
The
annual
public
reporting
and
record
keeping
burden
for
this
collection
of
information
is
estimated
to
average
18
hours
per
response
for
sponsors
submitting
pre­
proposal
ideas
to
EPA,
and
432
hours
per
response
for
sponsors
submitting
formal
proposals
to
EPA.
Further,
these
information
collection
activities
are
expected
to
result
in
21
hours
per
response
for
States
or
Tribes
consulting
on
pre­
proposal
ideas
submitted
to
EPA,
and
21
hours
per
response
for
States
and
Tribes
consulting
on
proposals
formally
submitted
to
EPA.

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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
11
burden
estimates,
and
any
suggested
methods
in
any
correspondence.
