                             SUPPORTING STATEMENT

   1.       IDENTIFICATION OF THE INFORMATION COLLECTION

         (a) TITLE OF THE INFORMATION COLLECTION

      Exchange Network Grants Progress Reports (Renewal) 
      EPA ICR Number 2207.06, OMB Control Number 2025-0006
   
   (b) SHORT CHARACTERIZATION
   
       The Environmental Protection Agency's (EPA) Office of Environmental Information (OEI) provides funding to EPA's Exchange Network partners (states, territories, and federally recognized Indian tribes) to support the development of the National Environmental Information Exchange Network (Exchange Network, or EN).
       
      As a stipulation of the award, recipients are required to submit semi-annual and final progress reports.  EPA also requires recipients to submit a quality assurance report within 90 days of award.  Since 2006, EPA has used standard forms for these reports (EPA Form 5300-26: Semi-Annual Progress Report Form and EPA Form 5300-27: Quality Assurance Reporting Form).

2.	NEED FOR AND USE OF THE COLLECTION

      (a) AUTHORITY/NEED FOR THE COLLECTION

	The authority to gather progress performance for assistantship programs is derived from 2 CFR Part 200, "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards."   

	Section 200.328 "Monitoring and reporting program performance," paragraphs (b)(1) and (b)(2) state:
            	"(1) The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report will be due 90 calendar days after the period of performance end date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.
            	(2) The non-Federal entity must submit performance reports using OMB-approved governmentwide standard information collections when providing performance information. As appropriate in accordance with above mentioned information collections, these reports will contain, for each Federal award, brief information on the following unless other collections are approved by OMB:
            	     (i) A comparison of actual accomplishments to the objectives of the Federal award established for the period. Where the accomplishments of the Federal award can be quantified, a computation of the cost (for example, related to units of accomplishment) may be required if that information will be useful. Where performance trend data and analysis would be informative to the Federal awarding agency program, the Federal awarding agency should include this as a performance reporting requirement.
            	     (ii) The reasons why established goals were not met, if appropriate.
            	     (iii) Additional pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs."
    
	The authority to gather quality assurance information for assistantship programs is derived from 2 CFR Part 1500, "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards." 

      Section 1500.11 "Quality Assurance," paragraphs (a) through (d), state:
            	"(a) Quality assurance applies to all assistance agreements that involve environmentally related data operations, including environmental data collection, production or use.
            	(b) Recipients shall develop a written quality assurance system commensurate with the degree of confidence needed for the environmentally related data operations.
            	(c) If the recipient complies with EPA's quality policy, the system will be presumed to be in compliance with the quality assurance system requirement. The recipient may also comply with the quality assurance system requirement by complying with American National Standard ANSI/ASQ E4:2014: Quality management systems for environmental information and technology programs.
            	(d) The recipient shall submit the written quality assurance system for EPA review. Upon EPA's written approval, the recipient shall implement the EPA-approved quality assurance system."

      OEI needs these reports to ensure that grants are making progress consistent with their work plans and that grantees have the policies, procedures, specifications, standards, and documentation to produce data of sufficient quality to meet project objectives. 
      
      (b) PRACTICAL UTILITY/USERS OF THE DATA
      
      The information provided on Semi-Annual Progress Report Forms will be used by the Regional Exchange Network Coordinators to monitor grant project development and performance.  The reports will be attached to the applicable grantee's file in the Integrated Grants Management System (IGMS). The same reporting form will also be used for the final progress report, and will be used to rate performance for future grant awards.
      
      The Quality Assurance Reporting Form will be used to ensure grantees will use quality assurance measures outlined in the grant's administrative terms and conditions.
      
3.	NON DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	(a) NONDUPLICATION

	The information a grantee provides in their semi-annual progress report is unique to each project.  Information concerning the status of goals and outputs for each project is not available from any other source.  

      (b) PUBLIC NOTICE

      The notice for this collection renewal was published in the Federal Register on January 15, 2015 (80 FR 2099).  No comments were received.
      
      (c) CONSULTATIONS

      For this ICR action, we consulted with the EN's ten Regional Exchange Network Coordinators (RENCs), as well as OEI staff.  The RENC's are EPA employees, one in each of the EPA's ten regions, who specialize in environmental information, and serve as project officers for EN grants.  The RENCs and OEI staff suggested several changes to the form, which we have incorporated into Exhibit A.  
      
      (d) EFFECTS OF LESS FREQUENT COLLECTION

      EN grants are usually awarded for three-year project periods.  The Quality Assurance Reporting Form is completed only once, no more than 90 days after the award is made.  As a stipulation of the EN grant award, a progress report is completed every six months and a final report is submitted no later than 90 days after the expiration or termination of the approved project period.  Less frequent reporting could result in project mismanagement.  For some Project Officers with many grants to manage, the semi-annual progress report is the best opportunity to ensure the project is on schedule to meet its goals.
      
      (e) GENERAL GUIDELINES
 
 	Both the Semi-Annual Progress Report Form and the Quality Assurance Reporting Form covered in this ICR adhere to OMB general guidelines.
 
      (a) CONFIDENTIALITY
      
      No pledge of confidentiality is given for grantee responses in either the Semi-Annual Progress Report Form or the Quality Assurance Reporting Form.
      
      (b) SENSITIVE QUESTIONS

      No sensitive questions are asked on either the Semi-Annual Progress Report Form or Quality Assurance Reporting Form.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

      (a) RESPONDENTS/SIC CODES
      
      Our respondents are generally employees of state, tribal, or territorial environmental government offices.  For instance, the current grants awarded to the state of Maryland are managed by an employee of the Maryland Department of the Environment.
      
      According to the 2002 NAICS codes available at www.naics.com, our respondents would fall into one of three categories:
      921150 American Indian and Alaska Native Tribal Governments
      921190 Other General Government Support
      924120 Administration of Conservation Programs
      
      (b) INFORMATION REQUESTED
      
      Please see attachments for specific data elements (Exhibits A and B).  FY 2015 guidance for quality assurance plans are described in the FY 2015 Exchange Network Solicitation Notice, Section VI-B, which requires each recipient to "submit a tailored Quality Assurance Project Plan (QAPP) to the EPA Regional Project Officer within 90 days of the award issuance date" as a condition of each grant. 
      
      (c) RESPONDENT ACTIVITIES

	As previously stated, grantees are already required to report progress semi-annually on their projects.  EN grantees have been submitting semi-annual progress reports and final reports to EPA Regional Offices since the National Environmental Information Exchange Network grant program began in 2002.  EPA implemented the requirement to submit the Quality Assurance Reporting Form for new EN grants beginning in 2006, but the measures for quality assurance in a grantees' project have been explained in the EN Solicitation Notice since 2002.  

	According to the 1995 Paperwork Reduction Act (PRA) definition of burden §3502, the only time and effort that the forms required from grantees are:
 	(A)	Reviewing instructions;
 	(E)	Completing and reviewing the collection of information; and
 	(F)	Transmitting through email.
  
5.	INFORMATION COLLECTED

     (a) AGENCY ACTIVITIES

	Once the semi-annual report and quality assurance report are received by the RENC, they are attached to the grant's file in the IGMS database.  Semi-annual reports are also entered into EPA's Central Data Exchange, which Headquarters Exchange Network staff and management may use to track and report grant status.
     
     (b) COLLECTION METHODOLOGY
     
 	This information collection is form-related.  The Semi-Annual Progress Report Form is changing and is attached in Exhibit A.  The Quality Assurance Reporting Form is changing to clarify the instructions and is attached in Exhibit B.
 
 	Beginning with grants awarded in FY 2008, EPA requires, through the administrative terms and conditions, the recipients to submit semi-annual and final progress reports online via EPA's Central Data Exchange (CDX) system, which replaced the former paper reports.  For those grants awarded prior to FY 2008, the award recipient has the option of submitting semi-annual progress reports to the EPA Regional Project Officer electronically (i.e., through CDX) or in Microsoft Word, emailed to their RENC.  These progress reports must be submitted within one month of the end of the each reporting period.  The first reporting period is from the award issuance date to March 31, 2015, and the first report will be due to the EPA Regional Project Officer on April 30, 2015.  Subsequent reports will be due every six months thereafter, until the project is completed, and the reporting periods will be as follows: April 1 through September 30 (report due October 31) and October 1 through March 31 (report due April 30).  The RENC will upload the forms in IGMS, a Lotus Notes database that has been used by the EPA since 2000.  To reduce burden, EPA asks that grantees not re-write their entire semi-annual progress report, but simply add their recent outcomes, outputs and modified dates into their semi-annual progress report from the previous six months. 
 
 	Recipients of all new grants must submit the Quality Assurance Reporting Form to their RENC via email within 90 days of receiving the award.
     
     (a) SMALL ENTITY FLEXIBILITY
        
        There are no small entities affected because the respondents are states. 
        
        
     (b) COLLECTION SCHEDULE
     
Table 1
                                      FORM
                                    SCHEDULE
 Quality Assurance Reporting Form	
 Due to RENC 90 days after award of grant
 Semi-Annual Progress Report Form
 oo  Due to RENC April 30 (Oct. 1- Mar. 31 period)
 oo  Due to RENC October 31 (Apr. 1  -  Sept. 30 period)
 oo  Final Due to the RENC 90 days after expiration/termination
 
 
 6.	BURDEN ESTIMATE AND COST OF COLLECTION
 
      (a) ESTIMATING RESPONDENT BURDEN
      
      The estimated hours for completing each form includes time for reviewing instructions, completing information and transmitting through email or via CDX.

Table 2
Form
                                Estimated Hours
                              Frequency per Year
                              Total Burden Hours
Semi-Annual Progress Report Form
                                     0.75
                                       2
                                      1.5
Quality Assurance Reporting Form
                                       1
                                       1
                                       1
 
 	(b) RESPONDENT UNIVERSE AND BURDEN
 	
 	At the beginning of fiscal year 2015, EPA estimates 200 grantees will be responding to the Semi-Annual Progress Report Form.  That number is derived from an estimate of the rolling number of "active grants." The number of active grants fluctuates throughout the year as projects are completed and grants are officially awarded and closed.  Starting in FY 2013, every EN grant is awarded for a three-year project period (increased from two years).  Including the grants that EPA awarded in FY 2014, open grants that have been extended, and grants still awaiting the submission or approval of technical reports, EPA estimates 200 Semi-Annual Progress Report Form respondents during any one given fiscal year.
 
 	The Quality Assurance Reporting Form will be completed once for each award by award recipients.  These respondents are not unique; they are the same respondents who will submit Semi-Annual Progress Report Forms after the first six months of their projects. Of the 200 respondents, it is anticipated that 40 of them will complete the quality assurance reporting form in addition to the semi-annual progress report forms. Assuming 40 new EN grant awards per year, EPA estimates 40 Quality Assurance Reporting Form respondents per fiscal year.
 
 	EPA's burden estimate per year is based on the government's fiscal year.  In one fiscal year, a respondent who receives an award in 2014 will complete one quality assurance report and two semi-annual progress reports for that grant.
					
Total Number of Responses:			
	Semi-Annual Progress Report Forms:	200 Respondents x 2 per year = 	400
	Quality Assurance Reporting Form:		40 Respondents x 1 per year = 	  40
	Total =											440
		
Total Burden:
	Semi-Annual Progress Report Forms:      200 Respondents x 1.5 hours = 		300
	Quality Assurance Reporting Form:	       40 Respondents x 1 hour = 		  40
	Total = 										340

Table 3 summarizes respondent burden.

Table 3  -  Respondent Burden

                                  Respondents
                                  Calculation
                       Semi-Annual Progress Report Form
                       Quality Assurance Reporting Form
                                     Total
a
Estimated Hours per Form
                                       
                                     0.75
                                       1
                                       
b
Frequency per Year
                                       
                                       2
                                       1
                                       
c
Annual Burden Hours per Form Type
                                   (a) x (b)
                                      1.5
                                       1
                                       


                                       
                                       
                                       
                                       
d
Respondents per Year
                                       
                                      200
                                      40
                                       
e
Responses per Year
                                   (b) x (d)
                                      400
                                      40
                                      440


                                       
                                       
                                       
                                       
f
Total Annual Burden Hours 
                                   (c) x (d)
                                      300
                                      40
                                      340

	(c) ESTIMATING RESPONDENT COST
 
	Respondent costs consist only of labor.  There are no capital, operating and maintenance, or annualizing capital costs incurred by this information collection.
	
 Respondent Wage Rate:			$35.26 1 x 1.50 = $52.88
 Quality Assurance Reporting Form:		40 Total Annual Burden Hours x $52.88 = $2,115
 Semi-Annual Progress Report Form:		300 Total Annual Burden Hours x $52.88 = $15,864




Table 4 summarizes respondent costs.

Table 4  -  Respondent Costs
Respondent Costs
Semi-Annual
Quality Assurance
Total
Labor Cost 
$15,864
$2,115
$17,979
Capital/Start-up Cost
$0
$0
$0
Operating and Maintenance
$0
$0
$0
Annualizing Capital
$0
$0
$0
Total Costs
$15,864
$2,115
$17,979
 
 	
 (d) ESTIMATING AGENCY BURDEN AND COST
	
 	To estimate the cost and burden to the RENCs, EPA assumes that each recipient will submit two Semi-Annual Progress Report Forms each year, and that each new grant recipient will submit one Quality Assurance Reporting Form each year.  EPA assumes that there are 200 active grants in any single fiscal year, that 40 new grants are awarded each year, and that there is an even distribution for each (active and new grants) across all 10 regions.   EPA estimates that it should take an RENC 0.5 hours to review/upload a Quality Assurance Reporting Form and 0.25 hours to review/upload a Semi-Annual Progress Report Form.  EPA estimates that each RENC will review (200/10) x 2 = 40 semi-annual forms and (40/10) x 1 = 4 quality assurance forms each year.  Each RENC will spend 40 x 0.25 = 10 hours reviewing/uploading semi-annual forms and 4 x 0.5 = 2 hours reviewing quality assurance forms.  The total number of hours that all of EPA's RENCs review/upload forms is 10 x 10 = 100 hours for the Semi-Annual Progress Report Form and 2 x 10 = 20 hours for the Quality Assurance Reporting Forms, for a total of 120 hours each year.  Assuming a fully burdened hourly rate of $55.99  for each RENC, the cost to review/upload forms is 100 x $55.99 = $5,599 for Semi-Annual Progress Report Forms and 20 x $55.99 = $1,120 for Quality Assurance Reporting Forms, for a total of $6,719 each year.   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Table 5 summarizes Agency burden.
 
 Table 5  -  Agency Burden

                                   EPA RENCs
                                  Calculation
                       Semi-Annual Progress Report Form
                       Quality Assurance Reporting Form
                                     Total
a
Estimated Hours per Form (Review/Upload)
                                       
                                     0.25
                                      0.5
                                       
b
Frequency per Year
                                       
                                       2
                                       1
                                       
c
Annual Burden Hours per Form Type
                                   (a) x (b)
                                      0.5
                                      0.5
                                       


                                       
                                       
                                       
                                       
d
Grants Subject to EPA Review/Upload per Year
                                       
                                      200
                                      40
                                       
e
EPA Reviews/Uploads per Year
                                   (b) x (d)
                                      400
                                      40
                                      440


                                       
                                       
                                       
                                       
f
Total Annual Burden Hours: EPA 
                                   (c) x (d)
                                      100
                                      20
                                      120
 
 Table 6 summarizes Agency cost.
 
Table 6  -  Agency Costs
EPA Costs
Semi-Annual
Quality Assurance
Total
Labor Cost 
$5,599
$1,120
$6,719
Capital/Start-up Cost
$0
$0
$0
Operating and Maintenance
$0
$0
$0
Annualizing Capital
$0
$0
$0
Total Costs
$5,599
$1,120
$6,719
 
 
      (e) BOTTOM LINE BURDEN HOURS AND COSTS
     
Table 7  -  Summary Burden Hours and Costs

Semi-Annual
Quality Assurance
Total
Total Annual Responses
400
40
440[*]
Total Burden Hours for Respondents
300  hours
40  hours
340  hours
Total Burden Hours for EPA
100  hours
20  hours 
120  hours
Total Respondent Cost
$15,864
$2,115
$17,979
Total EPA Cost
$5,599
$1,120
$6,719
Total Costs
$21,463
$3,235
$24,698

*Not all respondents complete every activity, every year.
     
     
     (f) REASONS FOR CHANGE IN BURDEN
     
	There is a decrease of 5 hours in the total estimated respondent burden compared with the ICR currently approved by OMB.  This decrease is due to a decrease in the number of grants that are awarded annually.  There is no change in respondent burden per response.  Total estimated respondent cost has increased as a result of inflationary increases and updated methodologies for estimating respondent salaries.

     Additionally, there is a decrease of 2.5 hours in the total estimated EPA burden.  This decrease is due to a decrease in the number of grants that are awarded annually.  There is no change in EPA burden per response.  Total estimated EPA cost has increased as a result of inflationary increases and updated methodologies for estimating EPA RENC salaries.

     (g) BURDEN STATEMENT
     
	The annual public reporting and recordkeeping burden for this collection of information is estimated to average .77 hours per response. Specifically, the estimate is 0.75 hours per response for the Semi-Annual Progress Report Form (total of 1.5 hours) and 1 hour per response for the Quality Assurance Reporting Form.  Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the 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.     
     
     The burden for the Semi-Annual Progress Report Form is based on time for reviewing instructions, collecting the information and entering it into the form, and transmitting on-line (via CDX) or through email.  For each Semi-Annual Progress Report Form, the respondent burden is 0.75 hours.  Respondents complete the form twice a year; thus the total annual burden is 1.5 hours.  For the Quality Assurance Reporting Form, the annual respondent burden is 1 hour for each new EN grant awarded. 
     
 	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 Number EPA-HQ-OEI-2006-0037, which is available for online viewing at www.regulations.gov, or in person viewing at the Office of Environmental Information Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Office of Environmental Information Docket is (202) 566-1752.  An electronic version of the public docket is available at www.regulations.gov.  This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the Docket ID Number identified above.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-HQ-OEI-2006-0037 and OMB Control Number 2025-0006 in any correspondence.



                     U.S. ENVIRONMENTAL PROTECTION AGENCY
              Exchange Network Grant Program Progress Report Form
                for Use by Recipients of Assistance Agreements 
Please Check:
□ Semi-annual report
□ Final Report
Instructions: This form is for Exchange Network Grant recipients to report their progress. Recipients should send these to their regional grant project officer for spring reports by April 30 for the period October 1-March 31.  Fall reports are due to the regional project officer by October 31 for the period April 1-September 30.
Recipient Information: 
     
     Agency Name:
EPA Grant Number  -  Program Code, Number, and Amendment Number (e.g., OS  -  12345678  -  0):


For grants awarded before 2006 Exchange Network Grant Category (i.e., One Stop, Readiness, Implementation, or Challenge):    

Project Manager:     
     
    Name:     
     
    Phone:
     
    Email:

Funding Year:  
Award Amount:
Expenditures during this reporting period:
Funds Remaining:

Reporting Period (starting and ending dates, mm/dd/yyyy):  

Date Report Submitted (mm/dd/yyyy):   

EPA Project Officer to Whom Report is Submitted:  
     
     Name:  
     
     EPA Region/Program:
Focus:
Progress Report Instructions:
1. List major goals and each goal's outputs as described in the work plan
   (Note for recipients submitting through CDX: After you have submitted your first online progress report for a grant, any changes to goals or outputs that are needed must be made by your EPA Regional Project Officer. You should submit your change request directly to your Regional Project Officer.) 
2. In the "Scheduled Completion Date" column, enter the dates from the grant work plan
3. In the "Actual Completion Date" column, enter the date each output completed as of the period covered by this report
4. In the "Progress and Status" field below each output, enter any factor that has or will affect the recipient's ability to complete that output; also indicated whether a resource listed in RCS or ENDS was used or, if a resource was created, it was registered in ENDS or RCS.
EXAMPLE

Goals
Tasks/Outputs
Scheduled Completion Date
Actual Completion date
1. Flow ambient air quality data through the Exchange Network.
1. Develop XML schema
mm/yyyy
mm/yyyy

Progress and Status

2. Initiate first test data flow
mm/yyyy


Progress and Status

Goals
Tasks/Outputs
Scheduled Completion Date
Actual Completion date





Progress and Status:





Progress and Status:





Progress and Status:
	
Comments
 Instructions: If you have had any problems during the current period please report them here.  In accordance with 2 C.F.R. §200.328(d), a recipient of an EPA assistance agreement must notify EPA of any problems, delays, or adverse conditions.  If you have had any project-level problems or delays in spending grant funds during the current period, please report them in this section.
Problems during this reporting period:

Describe any actions your organization has taken or plans to take to resolve the problem:


If you need help from EPA you may request it here:  


Other comments:

Paperwork Reduction Act (PRA) Burden Statement:  The public reporting and recordkeeping burden for this collection of information is estimated to average forty-five minutes per response.  Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.  Include the OMB control number in any correspondence.  Do not send the completed form to this address.

	
	


                     U.S. ENVIRONMENTAL PROTECTION AGENCY
                       Quality Assurance Reporting Form
                for Use by Recipients of Assistance Agreements
Recipient Organization: 
Name:
Address:

EPA Award Number:


Project/Program Period(starting and ending dates, mm/dd/yyyy):


Activity Group: 
(check all that apply)


□ Infrastructure Development
□ Data Exchange, Analysis and Integration

□ Planning, Mentoring, and Training
□ Challenge
                                     Goal
                                     Task
                                    Output
                                    Outcome
                          Quality Assurance Measures















Instructions:     - Please submit electronically to your EPA Regional Project Officer within 90 days of award.
                           - For Quality Assurance Measures, please refer to most recent Solicitation Notice for Quality Assurance Guidelines.
                           - For Goals, please refer to goals outlined in your assistance agreement work plan.
Paperwork Reduction Act (PRA) Burden Statement:  The public reporting and recordkeeping burden for this collection of information is estimated to average one hour per response.  Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.  Include the OMB control number in any correspondence.  Do not send the completed form to this address.

