            Supporting Statement for a Request for OMB Review under
                          the Paperwork Reduction Act
                 OMB Control No. 2070-NEW; EPA ICR No. 2511.01
                                       
1.	Identification of the Information Collection

1(a).  Title of the Information Collection.  
"Reporting in the FIFRA Cooperative Agreement Work Plan and Report Template under the FIFRA Section 23(a) Grant Programs"
       
1(b).  Short Characterization/Abstract.  
This is a request for a new Information Collection Request (ICR).  This ICR describes the burden activities for the electronic collection of information for the pre-award burden activity for creating a work plan and the post-award and after-the-grant award activities related to reporting accomplishments to implement EPA's Federal Insecticide Fungicide and Rodenticide Act State and Tribal Assistance Grant (STAG) program (7 USC sec. 136u) see Attachment A.

This ICR augments the ICR entitled "EPA's General Regulation for Assistance Programs ICR" (OMB number 2030-0020; EPA No. 0938.18) which accounts for the current PRA burden for the minimum management requirements for all recipients of EPA grants or cooperative agreements (assistance agreements). This new ICR provides OMB the burden assessment for collecting the same information in the parent ICR (OMB no. 2030-0020), and provides a burden breakout for FIFRA program specific activities while using a standardized electronic format for only the STAG program reporting.  This ICR is also requesting approval for the FIFRA Grant Reporting Template that was developed in conjunction with the States and EPA Regions.  
      
2.	Need For and Use of the Collection

2(a). Need/Authority for the Collection. 
This ICR documents the PRA burden for STAG grantees to use a standardized electronic template to comply with work plan and reporting requirements which grantees complete and submit to the Agency via email.  
      
Under the STAG program (7 USC sec. 136u) and in EPA regulations at 40 CFR Parts 30 and 31, grantees are required to provide reports on grant activities to the Office of Pesticide Programs.   These regulations implement OMB Circulars A-21, A-87, A-102, A-110, A-122, and A-133. Specifically, the PRA burden related activities set forth for the pre-award, post-award and after-the-grant requirements associated with submitting a work plan, biannual reporting and reporting enforcement violations of program specific activities ( e.g., endangered species, worker protection  and container containment) and general record keeping and grant closing requirements.    
      
Currently, grantees provide this information to EPA via paper copy.  The burden is accounted for in the EPA's General Regulation for Assistance Programs ICR, OMB Number 2030-0020; EPA number 0938.18) see Attachment B.  
      
This information is utilized by EPA project officers, grant specialists, and finance officials to manage/oversee recipient programmatic and financial performance under all EPA assistance agreements. Without the collection information, rational, fair grant awards would be extremely difficult to make, and financial and technical managerial information would not be available to judge the status of grant efforts. 

2(b). Practical Utility/Users of the Data.  
The pre-award information (work plan) is used to negotiate with and ensure that the applicants are proposing work activities that align with both national and regional guidance documents and priorities. The post-award information (interim reporting on work activities and updates to work plan) is used to meet the statutory and regulatory requirements concerning monitoring recipient performance.  The after-the-grant information is used to meet reporting and recordkeeping requirements and to close out awards. The information is necessary to ensure accountability of EPA funds and to deter waste, fraud, and abuse.
      
3.	Non Duplication, Consultations, and Other Collection Criteria
      
3(a).  Non Duplication.  
There is no other source for this information. Pursuant to the individual Cooperative Agreements, grantees must fulfill the work plan and reporting requirements by utilizing the template.  Thus, grantees do not need to submit reports via paper copy.  
      
3(b).  Public Notice Required Prior to ICR Submission to OMB.  
Pursuant to 5 CFR 1320.8(d) EPA will publish a notice soliciting public comment on this proposed Information Collection activity. Any public comment received will be posted in the docket for this action.
        
3(c).  Consultations.  
The FIFRA Cooperative Agreement Work Plan and Report Template (a.k.a. "template") is the result of a collaborative effort that began in the fall of 2011 at the request of the State FIFRA Issues, Research and Evaluation Group (SFIREG) to EPA to help reduce the administrative burden of the cooperative agreement process, and to increase consistency in work plans and reports throughout the country.  The template will also facilitate national compilation of data.  Workgroup participants included representatives from Office of Pesticide Programs, the Office of Compliance, 8 EPA regional offices, and one SFIREG representative.  In the spring of 2012 several FIFRA state lead agencies volunteered to test the template either by testing it in-house or by using it as a work plan or year-end report. Periodic meetings were held via adobe connect to receive feedback and suggestions for improvement until the fall of 2013 - see Attachment C for copies of the survey data and consultation questions. The following states participated in the pilot phase:
      
   * Arizona Department of Agriculture  -  Jack Peterson, Associate Director, 602-542-3575
   * California Department of Pesticide Regulation - Scott Benson, 916 322-7269
   * Office of the Indiana State Chemist  -  Dave Scott, Pesticide Administrator, 765-494-1593
   * New Jersey Department of Environmental Protection  -  Roy Meyer, Bureau Chief for Pesticide Compliance, 609-984-6982
   * New York State Department of Environmental Conservation  -  Anthony Lamanno, Section Chief, 518-402-8727
   * New Mexico Department of Agriculture  -  Bonnie Rabe, Director, Division of Agricultural and Environmental Services, 575-646-2134
   * North Dakota Department of Agriculture  -  Jim Gray, Division Director, 701-328-1505
   * Virginia Department of Agriculture and Consumer Services  -  Liza Fleeson, Program Manager, 804-371-6559
   * Wisconsin Department of Agriculture, Trade and Consumer Protection  -  Lori Bowman, Director, Bureau of Agrichemical Management, 608-224-4550
      
EPA received positive feedback from States for developing the template as a reporting mechanism.  For most states the template provided increase efficiency for completing the work plan and reporting requirements and for some grantees a way to reduce the paperwork burden. This ICR is requesting approval for the EPA template that was developed in conjunction with the States and EPA Regions. 

3(d).  Effects of Less Frequent Collection.  
No less frequent collection is possible in accordance with OMB requirements.

3(e).  General Guidelines. 
Recipients keep their records for three (3) years after the date they submit the final SF 269, "Financial Status Report" unless otherwise directed by EPA. Therefore the recordkeeping activities briefly described herein are in compliance with OMB's guideline that agencies not require that records be retained for more than 3 years (5 CFR 1320.5(d)(2)(iv)). 

3(e)(1). Forms 
Respondents (grantees) fill out the "FIFRA Cooperative Agreement Work Plan and Report," a template that is available via the internet and available to the States, territories and Tribes who have FIFRA cooperative agreements with EPA. 
        
3(f).  Confidentiality.  
No pledge of confidentiality is given for applicant responses.
      
3(g).  Sensitive Questions.  
No sensitive information is collected under this ICR. 

4.	The Respondents and the Information Requested   

4(a).  Respondents/SIC Codes.  
The primary recipients of EPA grants are State and local governments and Indian tribes.  The information requested is used to make awards, pay recipients, and collect information on how Federal funds are being spent.  The corresponding North American Industry Classification System (NAICS) Codes for respondents include: 9241 - Administration of Environmental Quality Programs; 921150 American Indians and Alaska Native Tribal Governments.  
      
4(b)(i).  Information Requested - Data Items, Including Record Keeping Requirements.
The following describes the Respondent burden activities when using the template to submit the status of the work plan and other reporting activities. Under 40 CFR part 35.107 grantees are required to submit a work plan. The FIFRA Work Plan and Report Template contains a work plan tab for the grantee to insert the exact activities the grantee will be completing based upon the priorities as specified in the National FIFRA Cooperative Agreement Guidance that is revised on a three (3) year cycle, and as negotiated between the regions and grantees. These priorities fall broadly under the categories of programmatic work, compliance and enforcement, and certification and training of pesticide applicators. Under 40 CFR part 35.115 grantees are required to submit an end of year report. The Template contains specific reporting tabs for enforcement outputs, as well as space within the work plan tab to discuss accomplishments as measured against work plan commitments. 
         
An example of a completed template is shown as Exhibit A and is located at the end of this document. Since the cooperative agreement priorities among the states, tribes and territories are not the same and the national priorities change depending on the Agency budget, the template provides a flexible format to accommodate the variety of activities and program changes over time.  Generally, the template is sectioned into a series of "tabs" or categories, including:  
      
Tab
Description
Start
Respondents provide responses to eight (8) basic questions: Name; Grantee; Agreement Type; Number of Years the Agreement Covers; Project Period; Which Budget Period the Work plan/Report Corresponds to; Work plan/Report Status and Date.
Narrative
Respondents have the option to submit additional narratives that do not fit anywhere else in the template, such as: authority to accept the cooperative agreement, legislative changes, QAPPs, neutral administrative inspection schemes, case review results, etc.
Budget
Grantees can either enter budget information directly into the spaces provided in the template or embed a separate document (Word, PPT, PDF files) into this tab.
Work plan
The required activities areas included in the national guidance from which the grantee must select priority work.
Outcomes
This chart includes all the program areas listed in the national FY15-17 cooperative agreement guidance, and links them to potential outcomes from work done in each program area, and to the appropriate goal in EPA's Strategic Plan.  The grantee adjusts the outcomes as necessary to match work contained in the grantee's Work Plan.
Enforcement (5700 Group reports)
This section of the template allows the grantee to complete three 5700 forms related to projections and accomplishments related to inspections for enforcement, worker protection and container/containment concerns.
Endangered Species
Grantees complete projections and accomplishments sections related to inspections for Endangered Species Inspections.
Performance Measures
Grantees collect information to help determine the effectiveness of the program; provide data for management decisions and inform Congress and the public on the value of the program.

4(b)(ii).  Information Collection Baseline - STAG Grant Program
The following selected sections of 40 CFR parts 30 and 31 (see Attachment D) are summarized here to highlight the burden hours that are covered by the template activities and are considered the baseline burden for the STAG Grant Program. These activities are already addressed in an ICR that accounts for the current PRA burden for the minimum management requirements for all recipients of EPA grants or cooperative agreements (assistance agreements) and that is currently approved under OMB Control No. 2030-0020 (EPA ICR No. 0938.18). A summary of the baseline activities and related burdens is also presented in Table 1.  

(a).  Application for Federal Assistance
The pre-award SF-424 form, Application for Federal Assistance is used by States, local governments and federally recognized Indian Tribal governments to apply for Federal financial assistance. SF-424 requires basic information about the applicant, including a list of sources of proposed funding and a description for the proposed project.  Supplemental information is provided in SF-424A, Budget Information  -  Non Construction Programs, and SF-424B, Assurances- Non Construction  -  Programs, as applicable.  The regulatory authority for using the SF-424 is in 40 CFR part 31, Subpart B as supplemented by 40 CFR 35.104 which governs applications for the continuing environmental program grants and refers back to part 31 and incorporates the work plan regulation in 35.107.  We estimate, collectively these forms will impose 4 burden hours on the recipient and 5 hours on EPA.    

(b).  Official Record Files (40 CFR 30.50, 30.52, and 31.42)
Recipients must establish an official record file for each assistance award to track how the recipient uses the project funds, to account for property purchased under the award or used as part of any in-kind contributions, to maintain time records, and to document compliance with applicable statutes and regulations (40 CFR Part 7).  We estimate that this requirement imposes 5 burden hours on the recipient and 1 burden hour on EPA.  

EPA project officers may use an evaluation instrument to perform reviews that pertain to programmatic components of assistance agreements.  This type of evaluation focuses on reviewing information that can help assess recipients' activities and progress toward meeting the goals and objectives outlined in the assistance agreements.  Programmatic reviews also ensure that the work to be performed under the agreement is on schedule, within budget, and consistent with the agreements' relevant programmatic regulation and/or programmatic terms and conditions.  For those who do complete these reviews, we estimate 1 burden hour on the recipient and 1 burden hour on EPA. The extent of the information gathered and reviewed through this type of instrument will vary according to the size and scope of each agreement.  Complex agreements that involve large financial grants and entail extensive staffing and complex tasks will require a greater degree of review and evaluation.  Regardless of the size or complexity of the assistance agreement, the review instrument creates a framework that allows EPA to ensure the sound and effective management of assistance agreements.

(c).  Interim and Final Progress Reports (40 CFR 30.51 and 31.40)
Recipients must submit interim and final progress reports, if required.  EPA uses the interim progress reports to determine progress in relation to the approved schedule and project milestones during the project.  The final progress report summarizes all of the work on the project and the extent to which the recipient has met the project's objectives.  We estimate that this requirement imposes a total of 6.5 burden hours on the recipient and 4 burden hours on EPA.
(d).  Obtaining Approval for Certain Purchases (40 CFR 30.25 and 31.32)
Recipients must obtain the award officials approval before purchasing property or equipment with a unit acquisition cost of $5,000 or more. We estimate that this requirement applies to about 20% of the non-construction assistance recipients, and that this requirement imposes 3 burden hours on those recipients and 2 burden hours on EPA.

(e).  Property Management Standards (40 CFR 30.30-37 and 31.32)
Recipients must comply with specific property management standards.  The recipient is required to keep accurate records and carry out a physical inventory of property and reconcile the results, at least every two years.  We estimate that this requirement imposes 3 burden hours on the recipient and 2 burden hours on EPA.

(f).  Management of Federally-owned Property (40 CFR 30.33 and 31.32)
Recipients must comply with requirements for Federally-owned property management.  We estimate that this requirement affects only 1% of the projects, and imposes 2 burden hours on those recipients and 2 burden hours on EPA.

(g).  Invention Reports (40 CFR 30.36) 
If applicable, recipients must submit invention reports after completion of each project.  

(h).  Requests for deviations from EPA regulations (40 CFR 30.4 and 31.6) 
If applicable, recipients must comply with procedural requirements for requesting a deviation from an EPA regulation.  Only 5% of all recipients request deviations.  We estimate that a deviation imposes 8 burden hours on the recipient and 8 burden hours on EPA.

(j).  Assistance Agreement Dispute Appeals (40 CFR 30.63 and 40 CFR 31 Subpart F) 
If applicable, recipients must comply with procedural requirements for appealing an assistance agreement dispute between the recipient and the award official.  We estimate that this requirement imposes 16 burden hours on the recipient and 16 burden hours on EPA.  Less than 1% of EPA grant awards result in disputes.

(k).  Procedural Requirements (40 CFR 30.40-48 and 31.36)
Recipients must comply with procedural requirements. We estimate that this requirement imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(l).  Intergovernmental Review of Federal Programs (40 CFR 31.11) 
Recipients must comply 40 CFR Part 29, which implements Executive Order 12372, "Intergovernmental Review of Federal Programs," revokes OMB Circular A-95, and establishes new procedures for intergovernmental reviews.  OMB has determined that the new requirements are not subject to the reporting burden clearance process.

(m).  Bonding and Reporting Requirements (40 CFR 31.36(h))
Recipients must comply bonding and reporting requirements.  We estimate that this requirement imposes 0.5 burden hours on the recipient and 1 burden hour on EPA.

4(b)(iii).  Information Requested  -  Respondent Activities for FIFRA Cooperative Agreements 
Whereas the information collection activities approved under OMB Control No. 2030-0020 generally apply to grantees across multiple program areas, this new ICR addresses additional information collection activities that are undertaken by FIFRA grantees. Grantees complete a work plan at the beginning of the project period as part of the cooperative agreement application package. Respondent/grantees fill out the "FIFRA Cooperative Agreement Work Plan and Report," template that is available via the internet and available to all grantees, states, territories and tribes, participating in the STAG program.  The template can be downloaded free of charge for use.  The minimum requirement for use of the template is Excel[(C)] software which most states, territories and tribes currently use for business purposes. Biannually, states will fill out the template information and send an electronic copy of the completed template to the Agency via email. 

In accordance with 5 CFR 1320.5(b) (1), once OMB approves the template a valid OMB control number will be displayed on the template.  To assist the states, tribes, and territories template guidance is provided to the grantees. (see http://www.epa.gov/compliance/resources/policies/state/grants/fifra/fifra-coop-workplan-template-manual-2014.pdf.  As necessary, the Agency may also provide webinar training to assist states and tribes using the template.   

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

5(a).  Agency Activities.  
The data collected on the template is reviewed periodically to identify and eliminate duplication in reporting requirements. The Agency also conducts periodic on-site reviews to ensure recipient compliance with applicable requirements.  The template is reviewed in accordance with the requirements of 40 CFR Parts 30 and 31. A summary of the Agency burden hours and costs are summarized in Table 3.  

5(b).  Collection Methodology and Management.   
The information will be collected using the standardized template.  
      
5(c).  Small Entity Flexibility.  
EPA believes the reporting requirements discussed in this ICR do not place an unreasonable burden on small entities; the estimated burdens cannot be further reduced for small entities. EPA needs the information requested to make award decisions, properly manage assistance agreements, maintain records, and monitor performance. This requested information may, in some cases, be dependent on the type of entity (e.g., state agency, territory, or tribe.) but is not dependent on an entity's relative size. EPA takes active steps to minimize the burden on small entities in the form of guidance materials and electronic forms. In most cases, the requirements do not impose a large burden on small entities because the information required is simple and straightforward.
      
5(d).  Collection Schedule. 
Specific schedules for the collection of the template are outlined in the Cooperative Agreement Guidance. Biannual reporting is the average reporting period.  
      
6.	Estimating the Burden and Cost of the Collection

6(a).  Estimating Respondent Burden. 
Since the burden activities associated with the work plan and reporting are already covered under the existing EPA's General Regulation for Assistance Programs ICR" (OMB number 2030-0020; EPA No. 0938.18), a summary of the baseline burden hours associated with only the STAG grantees was developed for comparison and is used as the burden baseline in Table 1. 

Currently, 81 states, tribes and territories are active FIFRA grantees under the current STAG program. To establish the burden hour estimate and costs for FIFRA grantees (states, tribes and territories, hereafter referenced as "grantees") to use the template, EPA solicited burden data from 9 states (Indiana, Oregon, New York, Massachusetts, New Mexico, Pennsylvania, Virginia, Wisconsin, and Vermont). FIFRA grantees responded to EPA's consultation by providing the total estimated burden for completing all grant reporting using the reporting template.  EPA identified the FIFRA program specific activities required to be reported under the grant. Table 4 displays the annual incremental burden and cost of the FIFRA program specific grant reporting activities as compared to the burden for the general grant reporting requirements in the existing ICR. 
       
There are no capital costs related to completing EPA grant applications and the related reporting requirements and there are no operating and maintenance costs associated with these activities.   
      
6(b).  Estimating Labor Costs 
OPP is using labor cost estimates generated by Agency economists with respect to wages, benefits and overhead for all labor categories for affected industries, state government, and EPA employees.  This approach uses a transparent and consistent methodology employing publicly-available data to provide more accurate estimates and allow easy replication of the calculations.

Methodology.	The methodology uses publicly available wage data for each sector and labor type for an Unloaded wage rate (hourly wage rate) and calculates the Loaded wage rate (unloaded wage rate + benefits) and the Fully loaded wage rate (loaded wage rate + overhead).  Fully loaded wage rates are used to calculate the Agency's staffing costs.  Costs use 2012 base data.

Unloaded Wage Rate.  Wages are estimated for labor types (management, technical, and clerical) within applicable sectors. The Agency uses average wage data for the relevant sectors available in the National Industry-Specific Occupational Employment and Wage Estimates from the Bureau of Labor Statistics (BLS).  (see http://www.bls.gov/oes/current/oes_nat.htm).  

Sectors.  The specific North American Industry Classification System (NAICS) code and website for each sector is included in that sector's wage rate table.  Within each sector, the wage data are provided by Standard Occupational Classification (SOC).  The SOC system is used by Federal statistical agencies to classify workers into occupational categories for the purpose of collecting, calculating, or disseminating data (see http://www.bls.gov/oes/current/oes_stru.htm).
      
Loaded Wage Rate.  Unless stated otherwise, all benefits represent 43% of unloaded wage rates, based on benefits for all civilian non-farm workers, from http://www.bls.gov/news.release/ecec.t01.htm. However, if other sectors are listed for which 43% is not applicable, the applicable percentage will be stated.

Fully Loaded Wage Rate.  The fully loaded wages include benefits and overhead costs. The loaded wage rate is multiplied by 50% (EPA guidelines 20-70%) to get overhead costs.  

Using these data and methodology, the fully loaded wage rates used to calculate the respondent costs for this renewal are $43.67, $31.80, and $18.37 per hour for managerial, technical, and clerical labor hour costs, respectively.  
Table 1  -  FIFRA baseline biannual work plan, reporting and record keeping burdens hours from OMB# 2030-0020  

                                    Manager
                                   Technical
                             Average Per Response
                             Number of Respondents
                            Responses / Respondent
                                 Annual Totals

                                     Hrs.
                                  $43.67/hr.
                                     Hrs.
                                  $31.80/hr.
                                      Hrs
                                   Costs ($)
                                       
                                       
                                    Burden
                                     (hrs)
                                     Costs
                                      ($)
*Pre-award SF-424 
                                                                           2.14
                                                                         $93.45
                                                                           1.86
                                                                         $59.15
                                                                            4.0
                                                                        $152.60
                                      81
                                     .333
                                                                            108
                                                                      $4,116.07
40 CFR Sections 30.50, 52, and 31.42
                                                                           2.67
                                                                        $116.59
                                                                           2.33
                                                                         $74.09
                                                                            5.0
                                                                        $190.68
                                      81
                                       2
                                                                            810
                                                                     $30,890.16
40 CFR Sections 30.51 and 31.40
                                                                           3.47
                                                                        $151.53
                                                                           3.03
                                                                         $96.35
                                                                            6.5
                                                                        $247.88
                                      81
                                       2
                                                                           1053
                                                                     $40,156.56
40 CFR Section 30.25 (low frequency)
                                                                               
                                                                               
                                                                            N/A
                                                                               
                                                                            N/A
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
40 CFR Sections 30.25 and 31.32
                                                                            1.6
                                                                         $69.87
                                                                            1.4
                                                                         $44.52
                                                                            3.0
                                                                        $114.39
                                      81
                                       2
                                                                            486
                                                                     $18,531.18
30.30-37 and 31.32
                                                                            1.6
                                                                         $69.87
                                                                            1.4
                                                                         $44.52
                                                                            3.0
                                                                        $114.39
                                      81
                                       2
                                                                            486
                                                                     $18,531.18
40 CFR Sections 30.33 and 31.32  (low frequency %1 of all Agency projects)
                                                                           1.07
                                                                         $46.72
                                                                            .93
                                                                         $29.57
                                                                            2.0
                                                                         $76.29
                                      81
                                       2
                                                                            324
                                                                     $12,358.98
40 CFR Section 30.36 (invention reports)
                                                                               
                                                                               
                                                                             NA
                                                                               
                                                                            NA 
                                                                               
                                                                               
                                                                               
                                                                               
                                                                               
40 CFR Sections 30.4 and 31.6
                                                                           4.28
                                                                        $186.90
                                                                           3.72
                                                                        $118.29
                                                                            8.0
                                                                        $305.19
                                      81
                                       2
                                                                           1296
                                                                     $49,440.78
40 CFR Sections 30.63 and 31 subpart F (low frequency less than %1 of all Agency projects)
                                                                           8.56
                                                                        $373.81
                                                                           7.44
                                                                        $236.59
                                                                           16.0
                                                                        $610.40
                                      81
                                       2
                                                                           2592
                                                                     $98,884.80
40 CFR Section 30.40-48 and 31.36
                                                                           .267
                                                                         $11.65
                                                                           .233
                                                                          $7.40
                                                                            0.5
                                                                         $19.05
                                      81
                                       2
                                                                             81
                                                                      $3,086.10
40 CFR Section 31.11  (Ex. order 12372)
                                                                               
                                                                               
                                                                             NA
                                                                               
                                                                             NA
                                                                               
                                       
                                       
                                                                               
                                                                               
40 CFR Section 31.36(h)
                                                                           .267
                                                                         $11.65
                                                                           .233
                                                                          $7.40
                                                                            0.5
                                                                         $19.05
                                      81
                                       2
                                                                             81
                                                                      $3,086.10
Total 
                                                                          25.92
                                                                      $1,132.04
                                                                          22.58
                                                                        $717.88
                                                                           48.5
                                                                      $1,849.92
                                      --
                                      --
                                                                           7317
                                                                    $279,081.91
Numbers may not add due to rounding.   Wage rates reflect the average hourly wage rate estimate provide by the Bureau of Labor Statistics for the North American Industry Classification System (NAICS) code for all levels of government (NAIC code 999000). 2012 base data is used.  Under the current ICR, OMB 2030-0020, the average for one reporting event is 48.5 hours, most grantees report biannually or an estimated 89 hours annually. The current ICR does not provide a labor category break-out, so for this comparison we redistributed the total burden between the managerial (approximately 53% of the burden) and technical wage rate categories.  The clerical category was not used because the consultation with the grantees indicates this labor category is rarely used. 
*Pre-award SF-424 form burden hours and cost are amortized over the three year cycle because the pre-award application including the development of the work plan and assurances is only conducted once during the lifecycle of the grant.   




Table 2 Total Estimated Annual Incremental FIFRA Grantee Burden 
                                       
                                    Manager
                                   Technical
                           Avg. Burden Per Response 
                               #  of Respondents
                        Annual Responses per Respondent
                                 Annual Totals

                                     Hrs.
                                  $43.67/hr.
                                     Hrs.
                                  $31.80/hr.
                                 Burden (hrs)
                                   Costs ($)
                                       
                                       
                                 Burden (hrs)
                                   Costs ($)
5700 Main
                                                                            4.5
                                                                           $198
                                                                            9.8
                                                                           $312
                                     14.3
                                     $510
                                      81
                                       2
                                    2,316.6
                                    $41,318
5700 WPS
                                                                            1.6
                                                                            $70
                                                                            2.8
                                                                            $88
                                      4.4
                                     $157
                                      81
                                       2
                                     712.8
                                    $12,723
5700 Container Containment (CC)
                                                                            1.2
                                                                            $52
                                                                            6.2
                                                                           $199
                                      7.4
                                     $251
                                      81
                                       2
                                    1,198.8
                                    $20,310
Endangered Species
                                                                            9.6
                                                                           $417
                                                                            3.3
                                                                           $105
                                     12.9
                                     $522
                                      81
                                       2
                                    2,089.8
                                    $42,278
Total 
                                                                           16.9
                                                                           $737
                                                                           22.1
                                                                           $704
                                     39.0
                                     $1440
                                       
                                      81
                                       
                                       2
                                    6,318.0
                                   $233,280
Numbers may not add due to rounding. Wage rates reflect the average hourly wage rate estimate provide by the Bureau of Labor Statistics for the North American Industry Classification System (NAICS) code for all levels of government (NAIC code 999000). 2012 base data is used. The labor wage category is only distributed between the managerial (approximately 53% of the burden) and technical wage rate categories.  The clerical category was not used because consultation with the grantees indicates this labor category is rarely used for these burden activities.  The average incremental burden for one reporting event is 39 hours, most grantees report biannually or an estimated 78 hours per grantee annually.  

                    	
6(b).  Estimating Agency Burden and Costs 
To calculate the Agency burden, in 2014 EPA surveyed its Regional offices.  The estimated average annual Agency burden hours per region is 498.3 to assist and process the annual paperwork for STAG grantees. 10 regions implement the program and oversee one or more STAG grants within the region. Numbers may not add due to rounding.  Wage rates reflect the average hourly wage rate estimate provide by the Bureau of Labor Statistics for the North American Industry Classification System (NAICS) code for the federal government (NAIC code 999100).  2012 base data used.  
Table 3 - Total Estimated Agency Burden and Cost 
                                       
                                    Manager
                                   Technical
                                   Clerical
                                   Average 
                                    Totals

                                     Hrs.
                                   55.66/hr
                                     Hrs.
                                   $36.11/hr
                                     Hrs.
                                   $20.59/hr
                                 Burden (hrs)
                                   Costs ($)
                                 Burden (hrs)
                                   Costs ($)
Consult with Grantee and respond to questions  about template completion
                                                                            2.0
                                                                           $111
                                                                          102.0
                                                                         $3,683
                                                                              -
                                                                             $0
                                                                          104.0
                                                                         $3,795
                                                                        1,040.0
                                                                        $37,945
Developing mid-year and year end reports (columns P-R)
                                                                           27.0
                                                                         $1,503
                                                                          212.0
                                                                         $3,683
                                                                            2.5
                                                                            $51
                                                                          241.5
                                                                         $5,238
                                                                        2,415.0
                                                                        $52,375
Submit template to regional management and  HQ
                                                                            0.7
                                                                            $39
                                                                           20.1
                                                                         $3,683
                                                                              -
                                                                             $0
                                                                           20.8
                                                                         $3,722
                                                                          208.0
                                                                        $37,222
Working with the regional grants office (Region 1) 
                                                                              -
                                                                             $0
                                                                           12.0
                                                                         $3,683
                                                                              -
                                                                             $0
                                                                           12.0
                                                                         $3,683
                                                                          120.0
                                                                        $36,832
 
Region 6 
                                                                            9.5
                                                                           $529
                                                                          110.5
                                                                         $3,683
                                                                              
                                                                             $0
                                                                          120.0
                                                                         $4,212
                                                                        1,200.0
                                                                        $42,120
Totals (due to rounding, totals may not add to 100%)   
                                                                           39.2
                                                                         $2,182
                                                                          456.6
                                                                         $3,683
                                                                            2.5
                                                                            $51
                                                                          498.3
                                                                         $5,917
                                                                        4,983.0
                                                                        $59,166


      

6(d).  Estimating the Respondent Universe and Total Burden and Costs
Table 1, presents a summary of the current reporting and recordkeeping burden from the parent ICR entitled  "EPA's General Regulation for Assistance Programs ICR" (OMB number 2030-0020; EPA No. 0938.18) OMB 2030-0020 - which was used to determine a baseline for the adjustment in the burden hours.  For the FIFRA program specific ICR burden hour projections, the estimates and cost projected assume that all the grantees, 81 states, territories and tribes, will use the template for their work plan and reporting requirements.  The burden also assumes that all grantees would report to EPA biannually, and will conduct all the activities. This is a conservative estimate, since not all 81 FIFRA grantees will participate in all of the FIFRA grant program activities.

6(e).  Bottom Line Incremental Burden Hour and Cost Table.
Table 4 below represents the annual incremental burden and cost of the required grant reporting for the FIFRA program specific activities.  This increment is an amount over the baseline burden and cost in the parent ICR OMB# 2030-0020. 

Table 4

                              Annual Burden Hours
                                     Costs
Respondents /Grantees  (81 States, Tribes, territories - biannual reporting; incremental cost over the baseline ICR )
                                       
                                     6318
                                       
                                   $233,280
          	
6(f) Reasons for Change in Burden.  
This is a new ICR. Relative to the baseline annual burden for reporting general management grant reporting requirements approved under OMB 2030-0020, the overall annual burden increase for FIFRA program specific activities is 6318 hours, or 78 hours per respondent for 2 submitted reports. This change documents the incremental burden for reporting FIFRA grant program specific activities (e.g. 5700 environmental enforcement and endangered species activities).  This is a program change.

"Burden" is defined in 5 CFR 1320.3(b).  The 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.  OMB control numbers for certain EPA regulations in title 40, after initial display in the final rule, are listed in 40 CFR part 9 and appear on the information collection instrument as applicable, i.e., form or instructions, and in the Federal Register.         
      
The Agency has established a public docket for this ICR under Docket ID No. EPA-HQ-OPP-2014-0479, which is available for online viewing at www.regulations.gov, or in person viewing at the OPP Docket in the EPA Docket Center, William Jefferson Clinton (WJC) West, Rm. 3334, 1200 Pennsylvania Ave, NW, Washington, DC 20460-0001. This docket facility is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The docket telephone number is (703) 305-5805.  You may submit comments regarding 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. Comments may be submitted to EPA electronically through http://www.regulations.gov or by mail to: EPA Docket Center, Environmental Protection Agency, Mail Code 28221T, 1200 Pennsylvania Ave., NW, Washington, DC 20460.  You can also send comments to OMB, addressed to "OMB Desk Officer for EPA" and referencing OMB Control No. 2070-NEW via email to oira_submission@omb.eop.gov. Include docket ID No. EPA-HQ-OPP-2014-0479 and OMB control number 2070-NEW in any correspondence, but do not submit and any grant related information (e.g., forms, reports, etc.) to these addresses. 
                                      Exhibit A
                                          
      An example of a completed FIFRA Grant Work Plan and Report Template is displayed in the docket for this action at: EPA-HQ-OPP-2014-0479, which is accessible electronically through http://www.regulations.gov 
                                          
                                          
                                          
                                          

Attachments to the Supporting Statement 

	The Attachments listed below can be found in the docket for this ICR, identified as Docket ID Number, EPA-HQ-OPP-2014-0479, which is accessible electronically through http://www.regulations.gov. Direct links are provided for those documents that are also available online elsewhere.

Attachment A: 	EPA's Federal Insecticide Fungicide and Rodenticide Act State and Tribal Assistance Grant (STAG) program (7 USC sec. 136 et. seq.) is attached in the docket for this action.  
              
Attachment B:	"EPA's General Regulation for Assistance Programs ICR" (OMB number 2030-0020; EPA No. 0938.18) is attached as part of the docket for this action. 	 

Attachment C:	Consultation Questions and Responses from States is attached in the docket for this action.  
 
Attachment D:	40 CFR part 30: Grant Agreements with Institutions of Higher Education, Hospitals and other non-profits, and 40 CFR part 31: Uniform Administrative Requirements for Grants and Cooperative agreements to States and Local Governments, available on line at: http://www.epa.gov/QUALITY/qa_cfrs.html

