Attachment B

SUPPORTING STATEMENT FOR INFORMATION COLLECTION 

REQUEST NUMBER 0938.18 (2030-0020)

1.	Identification of the Information Collection

1(a).  Title of the Information Collection.  “GENERAL ADMINISTRATIVE
REQUIREMENTS FOR ASSISTANCE PROGRAMS”

 

1(b).  Short Characterization/Abstract.  This is a request for a renewal
of an existing Information Collection Request (ICR) due to expire on
April 30, 2012.  This ICR authorizes the collection of information under
EPA’s General Regulation for Assistance Programs that establishes the
minimum management requirements for all recipients of EPA grants or
cooperative agreements (assistance agreements).  40 CFR Part 30,
“Grants and Agreements with Institutions of Higher Education,
Hospitals, and Other Non-Profit Organizations,” establishes the
management requirements for institutions of higher education, hospitals,
and other non-profit organizations, as well as procurement requirements
for non-governmental recipients.  40 CFR Part 31, “Uniform
Administrative Requirements for Grants and Cooperative Agreements to
State and Local Governments,” includes the management requirements for
States, local governments, and Indian Tribal governments.  These
regulations include only those provisions mandated by statute, required
by Office of Management and Budget (OMB) Circulars, or added by EPA to
ensure sound and effective financial assistance management.  This
renewal request also incorporates reporting and audit requirements
associated with assistance programs funded under the American Recovery
and Reinvestment Act (ARRA) of 2009.

In addition, under Executive Orders 11625, 12138, and 12432, EPA is
required to promote and report on programs to assist minority and
women-owned enterprises.  Under P.L. 101-507 and P.L. 102-389, EPA is
required to set aside funds for socially and disadvantaged
individuals/firms under the Small Business Act, 15 U.S.C. 537(a) (5) and
(6).  This ICR combines all of these requirements under OMB Control
Number 2030-0020.  EPA award officials will use the information required
by these regulations to make assistance awards, to make assistance
payments, and to verify that the recipient is using Federal funds
appropriately to comply with Federal requirements.

This request renews the “General Administrative Requirements for
Assistance Programs” ICR by consolidating and updating the information
contained in the following ICRs previously approved by OMB: 

“General Administrative Requirements for Assistance Programs” ICR
Number 0938.11 (base ICR) - requested approval for collection of
information under EPA’s assistance programs.

“General Administrative Requirements for Assistance Programs” ICR
Number 0938.12 (amendment ICR) - requested approval of EPA Form 6600-01,
“EPA Administrative and Financial Onsite Review Questionnaire.” 

“General Administrative Requirements for Assistance Programs” ICR
Number 0938.13 (amendment ICR) - eliminated EPA Form 5700-53 and
adjusted the burden hours under the ICR accordingly.

“General Administrative Requirements for Assistance Programs” ICR
Number 0938.14 (amendment ICR) - requested approval of nonsubstantive
modifications to existing EPA Form 4700-4, “Preaward Compliance Review
Report for All Applicants and Recipients Requesting Federal Financial
Assistance.” 

“General Administrative Requirements for Assistance Programs” ICR
Number 0938.15 (amendment ICR) - requested approval of nonsubstantive
modifications to existing EPA Form 4700-4, “Preaward Compliance Review
Report for All Applicants and Recipients Requesting Federal Financial
Assistance.”

“General Administrative Requirements for Assistance Programs” ICR
Number 0938.16 (amendment ICR) – eliminated NCER Form 3212,
“Itemized Budget for EPA STAR Grant Applications” and requested
approval of EPA Form 6600-06, “Certification Regarding Lobbying.”  

“General Administrative Requirements for Assistance Programs” ICR
Number 0938.17 (amendment ICR) – increased burden estimates by
incorporating the following program areas under which grants were funded
for the ARRA (previously approved under Emergency ICR Number 2351.01):

Diesel Emissions Reduction Act

Superfund Cooperative Agreement

Leaking Underground Storage Tank Enforcement and Cleanup Program

Other assistance programs involving ARRA funds, including the Wastewater
Treatment Construction Program, Water Quality Management Planning
(Sections 205(j)(1) & 604(b)), and Clean Water Tribal Set-Aside Program

In approving the “General Administrative Requirements for Assistance
Programs” ICR Number 0938.11, OMB issued terms of clearance.  Each
term is enumerated below in bold, followed by EPA’s response
explaining how it was addressed. 

1) “EPA Administrative Capability Questionnaire” Form.  While EPA
may retain question 2a and ask applicants to identify affiliated
organizations, EPA should seriously explore performing validations of
the information via reports from Dunn and Bradstreet on all affiliations
of the applicant.  This validation could be a one-time check on new
applicants, and repeated when/if EPA wishes to recheck.

EPA response:  EPA thanks OMB for the suggestion to validate
applicants’ affiliations using Dunn and Bradstreet reports.  EPA has
carefully evaluated this option and found that obtaining Dunn and
Bradstreet data and performing the validations would be too expensive
given the resources available to the Agency.  In addition, EPA notes
that Dunn and Bradstreet may issue different numbers to the affiliates
and subsidiaries of an organization.  Because of this, it can be
difficult to determine affiliations among grant applicants based on Dunn
and Bradstreet data.  Therefore, EPA has retained its current practice
of asking applicants to complete question 2a on each questionnaire
submitted.

2) EPA Form 5700-53 “Lobbying and Litigation Certification for Grants
and Cooperative Agreements” is approved only until this data
collection is no longer required under statute or applicable
appropriations requirements.  If EPA determines that this data
collection is no longer required by applicants, the Agency should submit
a change worksheet (Form 83-C) consistent with OMB guidelines.

EPA response: EPA Form 5700-53 is necessary to certify that federal
funds have not been used to engage in the lobbying of the Federal
Government or in litigation against the United States.   

3) EPA “Lobbying Cost Certificate for Indirect Costs” Form.  This
new data collection has been approved for use by EPA until the standard,
government-wide data collection is completed.  EPA should integrate its
current indirect cost rate efforts with the interagency team currently
working on standard indirect cost rate guidance that will be used
government-wide, in order to ensure that EPA’s needs are considered in
the government-wide guidance.

EPA response:  EPA thanks OMB for its suggestion to integrate our
current indirect cost rate efforts with the interagency team’s
activities.  EPA notes, however, that no substantial movement toward
establishing a standard, government-wide data collection has been made. 
Therefore, EPA will continue to use the EPA form.

4) NCER Form 3212, “Itemized Budget for EPA STAR Grant
Applications.”  This data collection has been approved for use by EPA
until the SF-424A “Budget Information” has been updated and
incorporated into the Grants.gov forms library for grant application use
government-wide.  EPA is advised to participate in the Grants.gov
Standard Forms team to ensure EPA’s needs are considered in the
SF-424A update.

EPA response: NCER Form 3212 has been eliminated.  EPA has reflected
elimination of the form in this ICR.

2.	Need For and Use of the Collection

2(a). Need/Authority for the Collection.  This ICR is necessary because
of the information collection and reporting requirements included in EPA
regulations at 40 CFR Parts 30 and 31.  These regulations implement OMB
Circulars A-21, A-87, A-102, A-110, A-122, and A-133.  These regulations
set forth the pre-award, post-award, and after-the-grant requirements. 
This information is needed by EPA project officers, grant specialists,
and finance officials to manage/oversee recipient programmatic and
financial performance under all EPA assistance agreements.

Without the data compiled by the use of the forms, it would be
impossible for EPA to manage any of its Federal assistance programs. 
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.  Lessening the frequency of data
collection would have similar negative impacts.

2(b). Practical Utility/Users of the Data.  The pre-award information is
used to qualify and select grant/cooperative agreement applicants for
funding.  The post-award information is used to meet the statutory and
regulatory requirements and monitor 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 minimum fiscal control and accountability for 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. 
  

3(b).  Public Notice Required Prior to ICR Submission to OMB.  A notice
was published on page 64942 of the October 19, 2011, Federal Register,
announcing that EPA was beginning to prepare this ICR.  One comment was
received in response to the notice, but it was not substantive and
therefore did not require a formal response.

  

3(c).  Consultations.  We have received continuous feedback from
recipients on this information collection.  Administering EPA grants
requires constant recipient contact (e.g. written, telephone, face to
face, etc.).  The EPA Office of Grants and Debarment (OGD) is both
sensitive and responsive to recipient concerns involving burden,
duplication, availability of data, clarity of instructions, etc., and
revises EPA grant forms and collection methods in an effort to address
recipient concerns and streamline their activities.  

Frequent applicant and recipient feedback and informal consultations
have been a significant part of EPA grant forms evaluation.  These
contacts have been particularly useful in developing burden estimates. 
However, the bulk of recipient burden involves completing Federal
Standard Forms (e.g., SF 424).  All of the basic information
requirements under these regulations have already been subject to
considerable comment by recipients through OMB’s revisions to Circular
A-102.

This ICR is requesting clearance for a number of EPA grant forms.  They
are used by respondents on a regular basis and made publicly available
in several different locations (e.g., various web sites) in both
electronic and hardcopy format.  

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

3(e).  General Guidelines.  In 1996, the regulations of Part 30 were
revised to reflect “plain English.”  EPA has continued to use plain
English since then.  As a result, EPA’s grant regulations and other
documents are easier to understand by all organizations, large and
small.  The information collection is consistent with 5 CFR
1320.5(d)(2).

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, Indian Tribes, educational institutions,
and not-for-profit institutions.  The information requested is used to
make awards, pay recipients, and collect information on how Federal
funds are being spent.

Standard Industrial Classification Codes for respondents include 8211,
8221, 8399, and 919.  The corresponding North American Industry
Classification System (NAICS) Codes for respondents include 61111,
61131, 813212, 813219, 813311, 813312, 813319 and 92119.

4(b)(i).  Information Requested - Data Items, Including Record Keeping
Requirements.

The following identifies the application forms and non-form reporting
requirements contained in this regulation.  A detailed justification for
each reporting requirement immediately follows.  Burden estimates are
summarized in Exhibit A.

(1)	EPA Form 6600-09, “EPA Administrative Capability Questionnaire,”
is completed by non-profit organizations seeking EPA grant awards of
more than $200,000 and under certain special conditions (e.g., high-risk
recipients and to other applicants below these thresholds in special
circumstances).  Based on the information provided, EPA assesses the
adequacy of an applicant’s administrative and financial management
systems (i.e., administrative capability) and determines whether to
award the grant.  Applicants that provide information that demonstrates
that they are administratively and financially capable are
“certified” for the next four years.  The questionnaire is necessary
because it assists organizations identify potential system weaknesses
and compliance problems and correct them before grant award.  This helps
applicants avoid potential EPA corrective actions (e.g., freezing grant
funds), which could place their project in jeopardy.

In 2004, we conducted 267 post-award administrative reviews of
recipients, which resulted in 127 or 48% reviews with findings.  In
response to concerns about EPA’s oversight of non-profit recipients
raised in Congressional Hearings and by the Government Accountability
Office, as well as EPA’s Office of Inspector General, EPA prepared the
Administrative Capability Questionnaire to be used in the pre-award
review process.  

 

In January 2005, EPA conducted two pilot tests of the questionnaire. 
The tests were designed to evaluate whether the questionnaire would
provide information to enable the Agency to effectively evaluate the
ability of prospective applicants to comply with applicable EPA and OMB
requirements.  Based on the completed questionnaires, EPA identified a
total of eight weaknesses in the two organizations in the pilot tests. 
These weaknesses included deficiencies in administrative/accounting
procedures (e.g., withdrawal/payment of funds, determination of
allowable costs), property/procurement procedures (e.g., lack of an
established written policy for procurements), and personnel/travel
procedures (e.g., missing code of conduct and fringe benefit policy). 
From the pilot tests, EPA has concluded that the questionnaire provides
information that is needed by the Agency to evaluate prospective
applicants so that weaknesses/deficiencies are corrected before grants
are awarded.

Because of the success of the pilots, EPA has continued to use the
questionnaire.  EPA has used the form to evaluate more than 250
organizations, resulting in more than 300 weaknesses/deficiencies
identified.  

 

We estimate that the form will impose 4 burden hours on the applicant
and 3 burden hours on EPA.  

(2)	EPA Form 4700-4, “Preaward Compliance Review Report for All
Applicants and Recipients Requesting Federal Financial Assistance,” is
used to collect information that enables EPA to determine whether
applicants are developing projects, programs, and activities on a
non-discriminatory basis.  We estimate that this form will impose 0.5
burden hours on the applicant and 0 burden hours on EPA.  

	

(3)	EPA Form 5700-54, “Key Contacts Form,” and EPA Form 5700-55,
“Key Contacts Form for Multiple Principal Investigators.”  These
forms are used to collect contact information for individuals
responsible for various aspects of the proposed work, including
authorized representative, payee, administrative contact, and
investigators.  A recipient must complete either form as applicable.  We
estimate that a form imposes 0.5 burden hours on the applicant and 0
burden hours on EPA.

(4)	EPA Form 5770-2, “Fellowship Application,” is the basic
application form for individuals seeking fellowships and requires
information on the applicant’s educational and work experience
background.  We estimate that this form imposes 3 burden hours on the
applicant and 3 burden hours on EPA.

(5)	EPA Form 5770-3, “Fellowship Facilities and Commitment
Statement,” requires information about the institution that will
sponsor the fellowship applicant, the sponsor’s summarized plans for
the applicant’s training, and the institution’s commitment to
provide that training.  We estimate that this form imposes 1 burden hour
on the applicant and 1 burden hour on EPA.

(6)	EPA Form 5770-5, “Agency Fellowship Certification,” is used by
applicants who are current or prospective employees of a regional,
State, or local environmental pollution control or regulatory agency. 
The form asks the agency director or designee for the kind of help
(financial, leave of absence, etc.) the agency will be providing the
applicant if he receives an EPA fellowship.  We estimate that this form
imposes 0.5 burden hours on the applicant and 0.5 burden hours on EPA.

(7)	EPA Form 5770-7, “EPA Fellowship Activation Notice,” is used by
EPA to inform EPA’s Regional Services Staff to begin payment on the
fellowship award.  We estimate that this form imposes 0.5 burden hours
on the recipient and 0.5 burden hours on EPA.

(8)	EPA Form 5770-8, “Fellowship Agreement,” contains the terms of
the fellowship agreement, and is used by the applicant to formally
accept an EPA fellowship.  We estimate that this form imposes 1 burden
hour on the recipient and 1 burden hour on EPA.

(9)	EPA Form 5770-9, “Completion of Studies Notice,” is used to
officially terminate the fellowship.  The form requires the recipient to
provide EPA with two reprints of any publication work done under the
fellowship, when available, and asks for constructive criticism from the
recipient or his sponsor on EPA’s fellowship program.  We estimate
that this form imposes 1 burden hour on the recipient and 1 burden hour
on EPA.

(10)	EPA Form 6600-01, “EPA Administrative and Financial Onsite Review
Questionnaire,” requests information about an organization’s
administrative and financial policies, procedures, accounting and
management of EPA assistance agreements..  EPA uses the information to
determine if recipients are in compliance with government-wide and
EPA-specific rules, regulations and guidelines promulgated in the
various OMB Circulars, Code of Federal Regulations, and Agency
directives.  Additionally, it is reviewed to determine if recipients
have good business practices, such as consistently applied policies and
procedures that safeguard the management and use of Federal funds.  The
form provides the Agency with information needed to conduct and complete
its statistical analyses and evaluation of recipients.  The information
is collected on a statistically determined and random basis spread over
the various types of organizations receiving funds from EPA.  We
estimate that the form imposes 30 burden hours on the recipient and 40
burden hours on EPA. 

(11) 	EPA Form 6600-06, “Certification Regarding Lobbying,” is
completed by grant applicants and contains certifications about the use
of Federal appropriated funds in connection with lobbying, as specified.
 The form is used by EPA to confirm that no funds have been used for
lobbying activities and, if applicable, to direct the recipient to
complete Standard Form-LLL, Disclosure Form to Report Lobbying.”  We
estimate that this form imposes 0.25 burden hours on the recipient and
0.03 burden hours on EPA.

(12)	EPA Form 6600-08, “Lobbying Cost Certificate for Indirect
Costs/Certificate of Indirect Costs for State and Local Governments.” 
The “Lobbying Cost Certificate for Indirect Costs” portion is
completed by non-profit grant recipients and contains the certification
required by OMB Circular A-122.  The form is used by EPA to ensure
compliance with the requirements and standards on lobbying costs in OMB
Circular A-122.  The “Certificate of Indirect Costs for State and
Local Governments” portion is completed by state, local, and tribal
grant recipients and contains the certification required by OMB Circular
A-87.  The form is used by EPA to ensure compliance with the
requirements and standards on lobbying costs in OMB Circular A-87.  We
estimate that this form will impose 0.25 burden hours on the recipient
and 10 minutes of burden on EPA.

(13)	NCER Form 5, “Current and Pending Support,” is used by EPA’s
National Center for Environmental Research to determine whether the
principal investigator has available capability to handle the additional
workload proposed by EPA under the grant.  We estimate that this form
will impose 0.5 burden hours on the applicant and 0.25 burden hours on
EPA.

(14)	SF-270, “Request for Advance or Reimbursement.”  This is the
standard form prescribed by OMB Circular A-102 for recipients to use to
request advances or reimbursement on all non-construction programs when
the advance payment or reimbursement methods are used.  We estimate that
this form will impose 1 burden hour on the recipient and 1.5 burden
hours on EPA.

(15)	SF-271, “Outlay Report and Request for Reimbursement for
Construction Programs.” This is the standard form prescribed by OMB
Circular A-102 for recipients of a construction grant to request
reimbursements.  We estimate that this form imposes 1 burden hour on
recipients and 0.5 burden hours on EPA.

(16)	SF-424, “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 (name, address, telephone number,
type of applicant, etc.), including a list of sources of proposed
funding and a description of the proposed project.  Supplemental
information is provided in SF-424A, “Budget Information -
Non-Construction Programs,” SF-424B, “Assurances - Non-Construction
Programs,” SF-424C, “Budget Information - Construction Programs,”
and/or SF-424D, “Assurances - Construction Programs,” as applicable.

We estimate that, collectively, these forms will impose 4 burden hours
on the recipient and 5 burden hours on EPA.  

(17)	The SF-LLL, “Disclosure of Lobbying Activities,” is used by
applicants to disclose lobbying activities that have been secured to
influence the outcome of a Federal action (e.g., contract, grant,
cooperative agreement, etc.).  We estimate that this form will impose 10
minutes of burden on the recipient and 0 burden hours on EPA.

(18)	SF 425, “Federal Financial Report,” is used by applicants to
submit reports on their grant’s financial progress.  We estimate that
this form will impose 1.5 burden hours on the recipient and 1.5 burden
hours on EPA.

(19)	SF 425A, “Federal Financial Report Attachment,” is used by
applicants for reporting on cash management activity for multiple
grants.  We estimate that this form will impose 0.5 burden hour on the
recipient and 0.5 burden hours on EPA.

(20)	SF 428, “Tangible Personal Property,” is used by recipients to
report on tangible personal property (equipment and supplies) when
required by a Federal financial assistance award.  We estimate that this
form will impose 2.75 burden hours on the recipient and 2.75 burden
hours on EPA.

(21)	SF 429, “Real Property Status Report,” is used by recipients of
Federal financial assistance to report real property status or to
request agency instructions on real property that was/will be provided
as Government Furnished Property (GFP) or acquired (i.e. purchased or
constructed) in whole or in part under a Federal financial assistance
award.  We estimate that this form will impose 4 burden hours on the
recipient and 4 burden hours on EPA.

(22)	SF SAC, “Data Collection Form for Single Audits,” requires
non-federal entities that expend $500,000 or more in a year in federal
awards to conduct an audit in accordance with OMB Circular A-133,
“Audits of States, Local Governments, and Non-Profit Organizations.”
 We estimate that this form will impose 59 hours of burden for large
auditees (i.e., auditees most likely to administer a large number of
Federal awards), 17 hours for all other auditees, and 21.2 burden hours
on EPA.   

(23)	Research Performance Progress Report, is used by Office of Research
and Development grantees to submit interim progress reports.  We
estimate that this form will impose 6 burden hours on the recipient and
2 burden hours on EPA.  See Subsection “Justification for EPA
Modifications of RPPR Instructions” below for information on how this
for was revised to accommodate EPA reporting requirements.  

(24)	SF 3881, “ACH Vendor/Miscellaneous Payment Enrollment Form,” is
completed by grant recipients to enable the U.S. Treasury Department to
transmit payment data, by electronic means, to vendor's financial
institution.  We estimate that this form will impose 0.25 burden hours
on the recipient and 1 burden hour on EPA.  

(25)	EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment
Form,” is completed by fellowship recipients to enable the Treasury
Department to transmit payment data, by electronic means, to vendor's
financial institution.  We estimate that this form will impose 0.5
burden hours on the recipient and 0.5 burden hours on EPA.  

(26)	EPA Form 190-F-04-001, “EPA Payment Request,” is used to
request payment from EPA for Assistance Agreements or grants.  We
estimate that this form will impose 0.25 burden hours on the recipient
and 0.5 burden hours on EPA.     

 (27)	EPA Form 5700-53, “Lobbying and Litigation Certification for
Grants and Cooperative Agreements,” is completed at project completion
to certify that funds have not been used to engage in the lobbying of
the Federal Government or in litigation against the United States.   We
estimate that this form will impose 5 minutes of burden on the recipient
and 5 minutes of burden on EPA.     

(28) 	EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants and
Cooperative Agreements,” is completed by recipients of Federal grants,
cooperative agreements, or other Federal financial assistance which
involve procurement of supplies, equipment, construction or services to
accomplish Federal assistance programs.  We estimate that this form will
impose 1.5 burden hours on the recipient and 1.5 burden hours on EPA.   
  

Reporting and Recordkeeping Requirements

(1)	SECTIONS 30.50, 30.52, and 31.42 require recipients to 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.

(2)	SECTIONS 30.51 and 31.40 require recipients to 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.

(3)	The reporting and record requirements burden estimates of Sections
30.25 through 31.36(h) (below) are not listed in Exhibit A due to low
frequency of applicability and /or minimal response burden to applicants
and recipients of EPA grants.

(4)	SECTIONS 30.25 and 31.32 require recipients to 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.

(5)	SECTIONS 30.30-37 and 31.32 require recipients to 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.

(6)	SECTIONS 30.33 and 31.32 contain the requirements on how recipients
are to manage Federally-owned property.  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.

(7)	SECTION 30.36 requires recipients to submit invention reports after
completion of each project.  

(8)	SECTIONS 30.4 and 31.6 contain the requirements recipients must
follow to request 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.

(9)	SECTIONS 30.63 and 40 CFR 31 Subpart F contain the procedures the
recipient must follow to appeal 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.

(10)	SECTIONS 30.40-48 and 31.36 contain the procurement requirements
recipients must follow. We estimate that this requirement imposes 0.5
burden hours on the recipient and 0.5 burden hours on EPA.

(11)	SECTION 31.11 requires recipients to follow 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.

(12)	SECTION 31.36(h) contains the bonding and reporting requirements
recipients must follow.  We estimate that this requirement imposes 0.5
burden hours on the recipient and 1 burden hour on EPA.

Information Collection under the Recovery and Reinvestment Act of 2009

In 2009, EPA submitted a request for emergency clearance to collect
information under the American Recovery and Reinvestment Act (ARRA) of
2009 (ICR Number 2351.01).  The purposes of the ARRA are to preserve and
create jobs and promote economic recovery, assist those most impacted by
the recession, provide investments needed to increase economic
efficiency as specified, invest in transportation, environmental
protection, and other infrastructure that will provide long-term
economic benefits, and stabilize State and local government budgets, in
order to minimize and avoid reductions in essential services and
counterproductive State and local tax increases.  The ARRA authorizes
the President and Federal departments and agencies to manage and expend
the funds made available in the ARRA so as to achieve its stated
purposes, including commencing expenditures and activities as quickly as
possible consistent with prudent management.  Title VII of the Act
appropriates funding for six EPA programs.  

While all funds under the ARRA have been appropriated, the reporting and
audit requirements associated with the ARRA are being incorporated under
this renewal request for the existing General Administrative
Requirements for Assistance Agreements Programs ICR (Number 0938.18).

Recipients of Federal funding are required to report specified
information to the Federal agency providing the award 10 days after the
end of each calendar quarter, as provided by Section 2.9 of the
Implementing Guidance.  These reports must include, for example, the
following additional data fields:

Detailed list of all projects or activities for which recovery funds
were expended or obligated, including:

Rationale of the activity

Number of jobs retained

Number of jobs created

Certifications at the state/local level

Quarterly completion status

Detailed information on any subcontracts or subgrants awarded by the
recipient, as specified, including: 

Rationale of the activity

Number of jobs retained

Number of jobs created

Contract/subgrant start/end date

EPA is implementing this requirement by asking recipients to submit
quarterly progress reports.  Recipients are required to submit progress
reports to EPA under existing 40 CFR 30.51 or 31.40.

Agencies are encouraged to undertake additional steps, beyond standard
practice, to mitigate the unique implementation risks associated with
ARRA funding, as provided in Section 5.3 of Implementing Guidance. 
Among other things, agencies should initiate additional measures, as
applicable, to address higher risk areas (e.g., audits and
investigations of ARRA funds occurring to identify wasteful spending and
minimize waste, fraud and abuse).  Certain recipients may be asked to
participate in such audits or investigations of their programs.

Under Section 2.6 of Implementing Guidance, agencies are responsible for
pre-dissemination review of all information that will appear on
Recovery.gov, and must ensure all reporting related to ARRA funding is
complete and accurate and complies with the agency’s Information
Quality Act guidelines.  Section 6.3 of the Implementing Guidance
requires agencies to monitor to ensure that quality assurance procedures
established for contracts are implemented.  Certain recipients may be
asked to provide information on their quality assurance/quality control
procedures, to characterize their data quality, and to assess the
implication of their data quality on the interpretation and use of
performance information reported to EPA.

Reporting Activities by ARRA Program Area

(1)  	Diesel Emissions Reduction Act.  Appropriated funds provide loans
to state and local governments for projects that reduce diesel
emissions, benefiting public health and reducing global warming.  EPA
estimates that 17 recipients will submit progress reports to EPA under
their agreement.  

(2)  	Superfund Cooperative Agreements.  Appropriated funds clean up
hazardous and toxic Superfund sites.  EPA estimates that 5 recipients
will submit progress reports to EPA under their existing agreement.  

(3)  	Leaking Underground Storage Tank Enforcement and Cleanup Program. 
Appropriated funds are used to enforce and cleanup petroleum leaks from
underground storage tanks.  EPA estimates that 13 recipients will submit
progress reports to EPA under their agreement.  

(4)	Other Assistance Programs Involving ARRA Funds. Includes
appropriated funds under other assistance programs involving ARRA funds,
including the Wastewater Treatment Construction Program, Water Quality
Management Planning (Sections 205(j)(1) & 604(b)), and Clean Water
Tribal Set-Aside Program.  EPA estimates that 30 recipients will submit
progress reports to EPA under their agreements for other assistance
programs involving ARRA funds.  

Justification for EPA Modifications of RPPR Instructions

	Effective with publication of notice in Federal Register Volume 75,
Number 8, agencies can utilize a uniform format for reporting
performance progress on Federally-funded research projects. The Research
Performance Progress Report (RPPR) directly benefits award recipients by
making it easier for them to administer Federal grant and cooperative
agreement programs through standardization of the types of information
required in interim performance reports—thereby reducing their
administrative effort and costs. The RPPR also makes it easier to
compare the outputs and outcomes of research programs across the
government.  EPA has modified the RPPR instructions to provide
Agency-specific context and to better direct recipients to the type of
information required for progress reporting.  The justification for
modifications to the RPPR form are outlined below. 

Page 2: “Include a comparison of actual accomplishments with the goals
and objectives described in the work plan.”

Justification: Per EPA’s current Environmental Results Order ( 
HYPERLINK "http://www.epa.gov/ogd/grants/award/5700.7.pdf"  Order 5700.7
), EPA’s award official must include in assistance agreements a term
and condition on recipient performance reporting specifying that the
recipient must include, among other things, a comparison of actual
accomplishments with the anticipated outputs/outcomes specified in the
assistance agreement work plan.  This is also consistent with 2 CFR
215.51.

Page 2: “If EPA determines that the recipient has not made sufficient
progress toward completing its research, EPA may terminate the
assistance agreement.  Sufficient progress is demonstrated by the
grantee meeting the milestones described in the research plan to the
maximum extent practicable, while taking into account any extenuating
factors that may have delayed progress.”

Justification:  EPA Policy 2520-03-P1, Responsibilities for Reviewing
Unliquidated Obligations, requires EPA Offices to include a term and
condition on all assistance agreements establishing clear progress
expectations.  The language we have inserted here references ORD’s
relevant term and condition, approved by EPA’s Office of Grants and
Debarment, which requires recipients to describe progress toward meeting
milestones identified in their work plans.

Page 2: “and 5) associated quality assurance and quality control
(QA/QC) functions and findings.

Briefly describe the results of QA/QC activities performed during this
reporting period including: Status of quality system implementation;
results of internal quality reviews/assessments; problems identified
that could adversely affect the quality of the work performed under the
agreement; corrective actions implemented; and significant revisions to
quality documentation.”

Justification: Federal Regulations (40 CFR Part 30) require recipients
of funds for work involving environmental data comply with the American
National Standard ANSI E4-2004, "Specifications and Guidelines for
Quality Systems for Environmental Data Collection and Environmental
Technology Programs." (ANSI E4).  EPA’s Quality Policies (CIO 2016.0
and CIO 2105.0) require EPA organizations funding extramural work to
ensure conformance to ANSI E4.  In order to monitor on-going grantee
compliance, we need recipients to include this information in their
progress reports.

Page 3: “List any products, or outputs resulting from the project
during the reporting period.  The term “output” means an
environmental activity, effort, and/or associated work products related
to an environmental goal or objective, that will be produced or provided
over a period of time or by a specified date. Outputs may be
quantitative or qualitative but must be measurable during an assistance
agreement funding period.”

Justification:  EPA’s current Environmental Results Order (  HYPERLINK
"http://www.epa.gov/ogd/grants/award/5700.7.pdf"  Order 5700.7 )
establishes policy requiring program offices, to the maximum extent
practicable, to ensure that outputs and outcomes are appropriately
addressed in assistance agreement performance reports. 

Page 3:  “Provide links to publications, where available.  The
publication list should be cumulative of previous Annual Reports.”

Justification:  This is a clarification provided in our instructions. 
EPA provides links to publications and othe products of our assistance
agreements on our web site, therefore we are relaying our preference in
how we want to receive the information.

Page 5: “Include a discussion of the project’s outcomes.  The term
“outcome” means the results, effect, or consequence that will occur
from the activit(ies) discussed above that is related to an
environmental, behavioral or health-related objective.”

Justification:  EPA’s current Environmental Results Order (  HYPERLINK
"http://www.epa.gov/ogd/grants/award/5700.7.pdf"  Order 5700.7 )
establishes policy requiring program offices, to the maximum extent
practicable, to ensure that outputs and outcomes are appropriately
addressed in assistance agreement performance reports.

Page 5: “How does the research add to the understanding of or
solutions for environmental problems or is otherwise of benefit to the
environment and human health?”

Justification:  This is clarifying language to describe what an impact
means specifically for environmental research.  

Page 7:  “Please also address the following:

relevance to the Agency’s mission;

potential practical applications

Users of the information generated from your research (e.g., state,
local government; Academic institutions; Non-profit institutions); and

Whether research findings have had a direct impact on a community.”

Justification:  This is clarifying language to describe what an impact
means specifically for environmental research.

Page 7: “If the goals of the project have not changed from the
original application, state this.”

Justification:  This is a clarification that we want recipients to
explicitly state if there have been no changes, instead of answering
N/A, to avoid any ambiguity.

 

Page 7: “Describe problems or delays encountered during the reporting
period which may materially impair the ability to meet the results
(outputs/outcomes) specified in the application and the actions or plans
to resolve them.”

Justification:  Justification: Per EPA’s current Environmental Results
Order (  HYPERLINK "http://www.epa.gov/ogd/grants/award/5700.7.pdf" 
Order 5700.7 ), EPA’s award official must include in assistance
agreements a term and condition on recipient performance reporting
specifying that the recipient must notify EPA of problems, delays, or
adverse conditions which materially impair the ability to meet the
outputs/outcomes specified in the assistance agreement work plan.

Page 8: “Include a discussion of any absence or changes of key
personnel involved in the project.”

Justification:  This language provides clarification to also include
changes in key personnel if such changes were a cause of any delays.

Page 8:  “Discuss expenditures to date along with a comparison of the
percentage of the project completed to the project schedule and an
explanation of any costs which are higher than originally estimated.”

Justification:  This language is consistent with 2 CFR Part
215.51(d)(3).

4(b)(ii).  Information Requested – Respondent Activities.

Grants.gov, originally called the E-Grants Initiative, was a mandate of
the President’s Fiscal Year 2002 Management Agenda, which directed
agencies to “…allow applicants for Federal Grants to apply for and
ultimately manage grant funds online through a common Web site,
simplifying grants management and eliminating redundancies.”

Grants.gov implements the requirement in the Federal Financial
Assistance Management Improvement Act, Public Law 106-107, to develop a
simple, unified source to electronically find, apply, and manage grant
opportunities.  Grants.gov is the central Federal electronic portal
created in response to the Act.  

Grants.gov Apply allows an applicant to download a proposal/application
package from Grants.gov and complete the package offline based on agency
instructions.  The proposal/application package of forms generally
includes a standard set of core data elements based on the updated
version of the SF-424.  After an applicant completes the required
proposal/application package of forms, they can be submitted
electronically to Grants.gov, which transmits the proposal/application
to the funding agency.

The Office of Grants and Debarment has constructed a Grants.gov
Application Database (EAPPLY) that receives the proposal/application
data and stores them for program retrieval or review.  As
proposals/applications are selected for funding, the data will migrate
to the associated Integrated Grants Management System (IGMS) database
for eventual award.

EPA encourages use of Grants.gov for all competitive grants.

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

5(a).  Agency Activities.  These data collection forms are reviewed
periodically to identify and eliminate duplication in reporting
requirements.  Similar information is simply not available elsewhere.

These reports are reviewed in accordance with the requirements of 40 CFR
Parts 30 and 31.  The Agency also conducts periodic on-site reviews to
ensure recipient compliance with applicable requirements.  

5(b).  Collection Methodology and Management.  Most of the information
will be collected using standardized reports and appropriate
recordkeeping.  This information is entered into IGMS, the Agency’s
database for tracking the status of grant/cooperative actions.

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, non-profit
organization, individual, etc.) 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 data forms are outlined in grant solicitation notices for pre-award
application forms and in the grant terms and conditions for post-award
forms.  

6.	Estimating the Burden and Cost of the Collection

6(a).  Estimating Respondent Burden.  An estimation of the burden hours
per requirement is included in Exhibit A.

Type of Information	Number of Respondents

Competed Grants	Unsuccessful Applications	3,758

	Awards	1,359

Not Competed Grant Awards	1,634

Active ARRA Grant Awards	65

Fellowship Awards	1,575

TOTAL	8,391



6(b)(i).  Estimating Respondent Costs – Estimating Labor Costs.  

EPA estimates that 80% of burden hours for respondents will be used by
the applicant and the remaining 20% will be used by secretarial/clerical
staff.

Therefore:	Applicant Wage Rate:  $43.96 x 1.43 = $62.86.

Secretarial/Clerical Wage Rate:  $17.50 x 1.43 = $25.03.

                              	

6(b)(ii).  Estimating Respondent Costs – Estimating Capital and
Operations and Maintenance Costs.  Start-up costs for EPA grant
applications and associated forms are minimal and are part of customary
and usual recipient business expenses.  There are no capital costs
related to EPA grant applications and related reporting requirements.  

6(b)(iii).  Estimating Respondent Costs – Capital/Start-up Operating
and Maintenance Costs.  There are no capital costs related to EPA grant
applications and related reporting requirements.  Therefore, total
start-up and capital costs are zero (0). There are no O&M costs
required.

6(b)(iv).  Estimating Respondent Costs – Annualizing Capital Costs. 
Not applicable.

6(c).  Estimating Agency Burden and Cost.  The total annual burden hours
for EPA is estimated to be 170,326.  170,326 hours divided by 8,391
respondents = 20 hours per respondent for EPA.

 Thus:     8,391 respondents x 20 hours x $48.83  = $8,194,651 (labor
costs).

6(d).  Estimating the Respondent Universe and Total Burden and Costs

The total annual burden hours for recipients is estimated to be 205,365.
 205,365 hours divided by 8,391 respondents = 24 hours per respondent.

EPA estimates that 80% of these 24 hours will be used by the applicant
(19 hours) and the remaining 20% by secretarial/clerical staff (5
hours).

Thus: 	8,391 respondents x 19 hours x $62.86 = $10,021,706 and

8,391 respondents x 5 hours x $25.03 = $1,050,134. 

Total: 	$11,071,840 (labor costs).

	

6(e).  Bottom Line Burden Hours and Cost Tables.

	Burden Hours	Cost

Respondents	205,365	$11,071,840

EPA	170,326	$8,194,651

          	

6(f)  Reasons for Change in Burden.  The overall respondent burden has
increased from the previous ICR by 90,834 hours (i.e., from 114,531
hours to 205,365 hours).  This change occurred for several reasons. 
Initially, EPA carefully reviewed the set of grant and fellowship forms
covered in this ICR.  Based on this review, EPA deleted nine existing
forms and added eleven new forms.  These program changes are outlined in
the table below.

 

The details and justification for the forms that were added is included
in Section 4 of this ICR.  

Program Changes	Total Respondent Hours

Deleted Forms

 40 CFR 30.50 and 52 and 31.42 Completion of desk review protocol (the
requirements of this form are included under EPA Form 6600-01, “EPA
Administrative and Financial Onsite Review Questionnaire”)   	-190

40 CFR 30.50 and 52 and 31.42 Completion of onsite protocol (the
requirements of this form are included under EPA Form 6600-01, “EPA
Administrative and Financial Onsite Review Questionnaire”)	-680

40 CFR 30.22 and 31.21 Establish separate bank account - ACH Payment
System (the requirements of this form are covered under SF 3881, "ACH
Vendor/Miscellaneous Payment Enrollment Form;” EPA Form 190-F-05-001,
"Fellowship Stipend Payment Enrollment Form;” and EPA Form
190-F-04-001, "US EPA Payment Request")	-802

40 CFR 30.33 and 31.32 Report on Federally-owned property (the
requirements of this form are included under the new SF 429, “Real
Property Status Report”)	-684

40 CFR 30.21 and 31.20 Maintain financial management system (these
requirements are covered under existing financial reporting elements)
-6,834

Meet OMB Circular A-133 Audit Requirements (these requirements are
included under SF SAC, "Data Collection Form for Single Audits")	-950

EPA Form 5770-4, “Fellowship Applicant Qualifications Inquiry” (this
form is no longer used by the Environmental Education Division’s
National Network for Environmental Management Studies Fellowship
Program)	-2,967

SfF-269, “Financial Status Report” (the requirements are replaced by
SF 425, “Federal Financial Report”)	-3,417

SF-272, “Federal Cash Transactions Report” (ACH Payment System) -
Family of Forms (the requirements of this form are included under SF
425, “Federal Financial Report”)	-840

Subtotal Deleted Forms	-17,364

Added Forms

SF 425, "Federal Financial Report

	8,979

SF-425A "Federal Financial Report Attachment"	571

SF-428 "Tangible Personal Property"	8,231

SF-429 "Real Property Status Report"	120

SF-SAC, "Data Collection Form for Single Audits"	4,282

Research Performance Progress Report	4,800

SF 3881, "ACH Vendor/Miscellaneous Payment Enrollment Form"	748

EPA Form 190-F-05-001, "Fellowship Stipend Payment Enrollment Form	50

EPA Form 190-F-04-001, "US EPA Payment Request"	17,958

EPA Form 5700-53," Lobbying and Litigation Certificate"	249

EPA Form 5700-52A, "MBE/WBE Utilization Under Federal Grants"	9,000

Subtotal Added Forms	54,988

Subtotal: Program Changes	37,624



In addition to reviewing the set of grant and fellowship forms included
under the ICR, EPA reviewed the burden assumptions in the ICR to ensure
that they reflect the Agency’s current experiences under its grant
programs.  Based on this review, EPA made significant adjustments in the
number of respondents, the annual submissions per respondent, and the
burden hours for completion for all of its grant forms.  This renewal
request also incorporates reporting and audit requirements associated
with assistance programs funded under ARRA.  These adjustment changes
are outlined in the table below.  Additional details about the revised
estimates are included in Exhibit A.

Adjustment Changes	Total Respondent Hours	Change from 2009 ICR

EPA Form 6600-09, "EPA Administrative Capability Questionnaire"	200	-600

EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants
and Recipients Requesting Federal Financial Assistance”	3,376	1,667

EPA Form 5700-54, “Key Contacts Form” and EPA Form 5700-55, “Key
Contacts Form for Multiple Principal Investigators”	3,376	1,667

EPA Form 5770-2, “Fellowship Application”	4,725	1,758

EPA Form 5770-3, “Fellowship Facilities and Commitment Statement”
1,575	586

EPA Form 5770-5, “Agency Fellowship Certification”	788	293

EPA Form 5770-7, “EPA Fellowship Activation Notice”	75	-1

EPA Form 5770-8, “Fellowship Agreement”	150	-2

EPA Form 5770-9, “Completion of Studies Notice”	150	-2

EPA Form 6600-06, “Certification Regarding Lobbying”	1,688	734

EPA Form 6600-08, "Lobbying Cost Certificate for Indirect
Costs/Certificate of Indirect Costs for State and Local Governments"	108
-517

NCER Form 5, “Current and Pending Support”	446	-204

SF-270, “Request for Advance or Reimbursement”  	11,972	10,072

SF-271, “Outlay Report and Request for Reimbursement for Construction
Programs”	600	-160

SF-424, “Application for Federal Assistance” (including SF-424A,
SF-424B, SF-424C, and SF-424D)	27,004	11,740

SF-LLL, “Disclosure of Lobbying Activities”	5	-157

40 CFR 30.50 and 52 and 31.42 Keep records	14,965	-2,120

40 CFR 30.50 and 52 and 31.42 Completion of project officer protocol	376
91

40 CFR 30.51 and 31.40 Submit progress reports	72,800	28,366

Subtotal: Adjustments	53,211



The net effect of these program changes and adjustments is an increase
of 90,834 hours from the previous ICR.

6(g).  Burden Statement.   The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 24
hours per respondent.  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.   

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OARM-2011-0795, which is available for public viewing at the
Office of Environmental Information Docket in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington,
DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Office of Environmental Information Docket is
(202) 566-1752.  An electronic version of the public docket is available
online at www.regulations.gov.  Use www.regulations.gov to submit or
view public comments, access the index listing of the contents of the
public docket, and to access those documents in the public docket that
are available electronically.  Once in the system, select “search,”
then key in the docket ID number identified above.  

EXHIBIT A

ANNUAL ESTIMATE OF EPA ASSISTANCE AGREEMENT AWARDS

Type of Information	Number of Respondents

Completed Grants	Unsuccessful Applications	3,758

	Awards	1,359

Not Competed Grant Awards	1,634

Active ARRA Grant Awards	65

Fellowship Awards	1,575

TOTAL	8,391



The above estimates were used to determine the number of actions per
year for each of the following reporting requirements.

BURDEN HOURS PER REPORTING REQUIREMENT

NOTES:	Column D = A x B x C

Column F = A x B x E

Burden estimates for analyzing, processing, and maintaining EPA grant
forms were derived from EPA employees directly responsible for
day-to-day grant operations.  Employee estimates were obtained shortly
after forms were approved for use and have been modified to reflect our
grant processing streamlining efforts.

Reporting and recordkeeping requirement burden estimates for Sections
30.25 through 33.211 of 40 CFR are not listed in Exhibit A due to the
low frequency or applicability and/or minimal response burden to
applicants and recipients of EPA grants.

 

Information Collection Requirement	A	B	C	D	E	F

	Actions per Year	Submissions per Agreement	Burden Hours per Action
Total Burden Hours for Recipients	Burden Hours for EPA	Total Burden
Hours for EPA

EPA Form 6600-09, "EPA Administrative Capability Questionnaire"	50	1	4
200	3	150

EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants
and Recipients Requesting Federal Financial Assistance”	6,751	1	0.5
3,376	0	0

EPA Form 5700-54, “Key Contacts Form” and EPA Form 5700-55, “Key
Contacts Form for Multiple Principal Investigators”	6,751	1	0.5	3,376
0	0

EPA Form 5770-2, “Fellowship Application” 	1,575	1	3	4,725	3	4,725

EPA Form 5770-3, “Fellowship Facilities and Commitment Statement” 
1,575	1	1	1,575	1	1,575

EPA Form 5770-5, “Agency Fellowship Certification” 	1,575	1	0.5	788
0.5	788

EPA Form 5770-7, “EPA Fellowship Activation Notice” 	150	1	0.5	75
0.5	75

EPA Form 5770-8, “Fellowship Agreement” 	150	1	1	150	1	150

EPA Form 5770-9, “EPA Completion of Studies Notice” 	150	1	1	150	1
150

EPA Form 6600-01, “EPA Administrative and Financial Onsite Review
Questionnaire”	200	1	30	6,000	40	8,000

EPA Form 6600-06, “Certification Regarding Lobbying”	6,751	1	0.25
1,688	0.03	203

EPA Form 6600-08, "Lobbying Cost Certificate for Indirect
Costs/Certificate of Indirect Costs for State and Local Governments"	430
1	0.25	108	0.17	73

NCER Form 5, “Current and Pending Support”	892	1	0.5	446	0.25	223

SF-270, “Request for Advance or Reimbursement”  	2,993	4	1	11,972
1.5	17,958

SF-271, “Outlay Report and Request for Reimbursement for Construction
Programs” 	150	4	1	600	0.5	300

SF-424, “Application for Federal Assistance” (including SF-424A,
SF-424B, SF-424C, and SF-424D)	6,751	1	4	27,004	5	33,755

SF-LLL, “Disclosure of Lobbying Activities” 	30	1	0.17	5	0	0

40 CFR 30.50 and 52 and 31.42 Keep records	2,993	1	5	14,965	1	2,993

40 CFR 30.50 and 52 and 31.42 Completion of project officer protocol	376
1	1	376	1	376

40 CFR 30.51 and 31.40 Submit progress reports	2,800	4	6.5	72,800	4
44,800

SF 425, "Federal Financial Report	2,993	2	1.5	8,979	1.5	8,979

SF-425A "Federal Financial Report Attachment"	1,141	1	0.5	571	0.5	571

SF-428 "Tangible Personal Property"	2,993	1	2.75	8,231	2.75	8,231

SF-429 "Real Property Status Report"	30	1	4	120	4	120

SF-SAC, "Data Collection Form for Single Audits"	202	1	21.2	4,282	21.2
4,282

Research Performance Progress Report	200	4	6	4,800	2	1,600

SF 3881, "ACH Vendor/Miscellaneous Payment Enrollment Form"	2,993	1	0.25
748	1	2,993

EPA Form 190-F-05-001, "Fellowship Stipend Payment Enrollment Form	100	1
0.5	50	0.5	50

EPA Form 190-F-04-001, "US EPA Payment Request"	2,993	12	0.5	17,958	0.5
17,958

EPA Form 5700-53," Lobbying and Litigation Certificate"	2,993	1	0.08	249
0.08	249

EPA Form 5700-52A," MBE/WBE Utilization Under Federal Grants"	3,600	1.67
1.5	9,000	1.5	9,000



EXHIBIT B

EPA GRANT FORMS

Forms covered in this ICR include:

EPA Form 6600-09, “EPA Administrative Capability Questionnaire”

EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants
and Recipients Requesting Federal Financial Assistance” 

EPA Form 5700-54, “Key Contacts Form,” and EPA Form 5700-55, “Key
Contacts Form for Multiple Principal Investigators”  

EPA Form 5770-2, “Fellowship Application” 

EPA Form 5770-3, “Fellowship Facilities and Commitment Statement” 

EPA Form 5770-5, “Agency Fellowship Certification” 

EPA Form 5770-7, “EPA Fellowship Activation Notice” 

EPA Form 5770-8, “Fellowship Agreement” 

EPA Form 5770-9, “Completion of Studies Notice” 

EPA Form 6600-01, “EPA Administrative and Financial Onsite Review
Questionnaire” 

EPA Form 6600-06, “Certification Regarding Lobbying”

EPA Form 6600-08, “Lobbying Cost Certificate for Indirect Costs/
Certificate of Indirect Costs for State and Local Governments”

NCER Form 5, “Current and Pending Support”

SF-270, “Request for Advance or Reimbursement”  

SF-271, “Outlay Report and Request for Reimbursement for Construction
Programs” 

SF-424, “Application for Federal Assistance”

SF-424A, “Budget Information - Non-Construction Programs”

SF-424B, “Assurances - Non-Construction Programs”

SF-424C, “Budget Information - Construction Programs”

SF-424D, “Assurances - Construction Programs”

SF-LLL, “Disclosure of Lobbying Activities”

SF 425, “Federal Financial Report” 

SF 425A, “Federal Financial Report Attachment” 

SF 428, “Tangible Personal Property” 

SF 429, “Real Property Status Report” 

SF SAC, “Data Collection Form for Single Audits” 

Research Performance Progress Report 

SF 3881, “ACH Vendor/Miscellaneous Payment Enrollment Form”

EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form” 

EPA Form 190-F-04-001, “EPA Payment Request” 

5700-53, “Lobbying and Litigation Certification for Grants and
Cooperative Agreements” 

5700-52A, “MBE/WBE Utilization Under Federal Grants and Cooperative
Agreements” 

EXHIBIT C 

ENVIRONMENTAL PROTECTION AGENCY 

FINANCIAL ASSISTANCE PROGRAMS—CATALOG OF 

FEDERAL DOMESTIC ASSISTANCE (CFDA) NUMBER AND TITLE

Office of Administration and Resources Management (OARM)

66.508		Senior Environmental Employment Program

66.518		State Senior Environmental Employment Program

Office of Air Radiation (OAR)

										

66.001		Air Pollution Control Program Support

66.032 	State Indoor Radon Grants 

66.033 	Ozone Transport Commission

66.034 	Surveys, Studies, Research, Investigations, Demonstrations and
Special Purpose Activities Relating to the Clean Air Act

66.037	Internships, Training and Workshops for the Office of Air and
Radiation

66.038	Training, Investigations, and Special Purpose Activities of
Federally-Recognized Indian Tribes Consistent With the Clean Air Act
(CAA), Tribal Sovereignty and the Protection and Management of Air
Quality

66.039	National Clean Diesel Emissions Reduction Program

66.040	State Clean Diesel Grant Program

66.041	Climate Showcase Communities Grant Program

66.042	Temporally Integrated Monitoring of Ecosystems (TIME) and
Long-Term Monitoring (LTM) Program

Office of Chemical Safety and Pollution Prevention (OCSPP)

66.707 	TSCA Title IV State Lead Grants Certification of Lead-Based
Paint Professionals

66.708 	Pollution Prevention Grant Program

66.714 	Regional Agricultural IPM Grants

66.715 	Lead Educational Outreach and Baseline Assessment of Tribal
Children’s Exposure and Risks Associated With Lead

66.716	Research, Development, Monitoring, Public Education, Training,
Demonstrations, and Studies

66.717		Source Reduction Assistance

66.718		National Community-Based Lead Outreach and Training Grant
Program

Office of the Chief Financial Officer (OCFO)

66.202		Congressionally Mandated Projects

66.203		Environmental Finance Center Grants

Office of Enforcement and Compliance Assurance (OECA)

66.305	Compliance Assistance Support for Services to the Regulated
Community and Other Assistance Providers

66.309	Surveys, Studies, Investigations, Training and Special Purpose
Activities Relating to Environmental Justice

66.310	Capacity Building Grants and Cooperative Agreements for
Compliance Assurance and Enforcement Activities in Indian Country and
Other Tribal Areas

66.313		International Compliance and Enforcement Projects

66.604		Environmental Justice Small Grants Program

66.700 	Consolidated Pesticide Enforcement Cooperative Agreements

66.701 	Toxic Substances Compliance Monitoring Cooperative Agreements

66.709 	Multi-Media Capacity Building Grants for States and Tribes

Office of Environmental Information (OEI)

66.608	Environmental Information Exchange Network Grant Program and
Related Assistance

66.612	Survey, Studies, Investigations, Training Demonstrations and
Educational Outreach Related to Environmental Information and the
Release of Toxic Chemicals

Office of International and Tribal Affairs (OITA)

66.473	Direct Implementation Tribal Cooperative Agreements

66.926	Indian Environmental General Assistance Program (GAP)

66.931	International Financial Assistance Projects Sponsored by the
Office of International and Tribal Affairs 

Office of Research and Development (ORD)

66.509		Science to Achieve Results (STAR) Research Program

66.510	Surveys, Studies, Investigations and Special Purpose Grants
within the Office of Research and Development

66.511	Office of Research and Development Consolidated
Research/Training/Fellowships

66.513	Greater Research Opportunities (GRO) Fellowships For
Undergraduate Environmental Study

66.514		Science to Achieve Results (STAR) Fellowship Program

66.515		Greater Research Opportunities (GRO) Research Program

66.516		P3 Award: National Student Design Competition for Sustainability

66.517		Regional Applied Research Efforts (RARE)

Office of Solid Waste and Emergency Response (OSWER)

66.801 	Hazardous Waste Management State Program Support

66.802 	Superfund State, Political Subdivision, and Indian Tribe
Site-Specific Cooperative Agreements

66.804 	Underground Storage Tank Prevention, Detection and Compliance
Program

66.805 	Leaking Underground Storage Tank Trust Fund Corrective Action
Program

66.806 	Superfund Technical Assistance Grants (TAG) for Community Groups
at National Priority List (NPL) Sites

66.808 	Solid Waste Management Assistance Grants

66.809 	Superfund State and Indian Tribe Core Program Cooperative
Agreements

66.810 	Chemical Emergency Preparedness and Prevention (CEPP) Technical
Assistance Grants Program

66.812 	Hazardous Waste Management Grant Program for Tribes

66.813	Alternative or Innovative Treatment Technology Research,
Demonstration, Training and Hazardous Substance Research Grants

66.814	Brownfields Training, Research and Technical Assistance Grants
and Cooperative Agreements

66.815	Environmental Workforce Development and Job Training Cooperative
Agreements

66.816		Headquarter and Regional Underground Storage Tanks Program

66.817		State and Tribal Response Program Grants

66.818		Brownfields Assessment and Cleanup Cooperative Agreements

Office of Administration (OA)

66.605 	Performance Partnership Grants

66.609 	Protection of Children from Environmental Health Risks

66.610	Surveys, Studies, Investigations and Special Purpose Grants
within the Office of the Administrator

66.611	Environmental Policy and Innovation Grants

66.940		Environmental Policy and State Sustainability Grants

66.950 	National Environmental Education Training Program

66.951		Environmental Education Grants

66.952		National Network for Environmental Management Studies Fellowship
Program

66.953	Building Capacity to Implement EPA National Guidelines for School
Environmental Health Programs

Office of Water (OW)

66.305		Community Action for a Renewed Environment Program

66.418		Construction Grants for Wastewater Treatment Works

66.419 	Water Pollution Control State, Interstate, and Tribal Program
Support

66.424	Surveys, Studies, Investigations, Demonstrations, and Training
Grants - Section 1442 of the Safe Drinking Water Act

66.432 	State Public Water System Supervision

66.433 	State Underground Water Source Protection

66.436	Surveys, Studies, Investigations, Demonstrations, and Training
Grants and Cooperative Agreements - Section 104(b)(3) of the Clean Water
Act

66.437		Long Island Sound Program

66.439		Targeted Watersheds Grants

66.440		Urban Waters Small Grants	

66.454 	Water Quality Management Planning

66.456 	National Estuary Program

66.458 	Capitalization Grants for Clean Water State Revolving Funds

66.460 	Nonpoint Source Implementation Grants

66.461 	Regional Wetland Program Development Grants

66.462	National Wetland Program Development Grants and Five-Star
Restoration Training Grant

66.463 	Water Quality Cooperative Agreements

66.466 	Chesapeake Bay Program

66.467 	Wastewater Operator Training Grant Program

66.468 	Capitalization Grants for Drinking Water State Revolving Funds

66.469 	Great Lakes Program

66.471	State Grants to Reimburse Operators of Small Water Systems for
Training and Certification Costs

66.472 	Beach Monitoring and Notification Program Implementation Grants

66.474 	Water Protection Grants to the States

66.475 	Gulf of Mexico Program

66.478 	Water Security Training and Technical Assistance and Water
Security Initiative Contamination Warning System Pilots

66.479	Wetland Program Grants - State/Tribal Environmental Outcome
Wetland Demonstration Program

66.480		Assessment and Watershed Protection Program Grants

66.481		Lake Champlain Basin Program

Region 1

66.110		Healthy Communities Grant Program

Region 3

66.050		Potomac Highlands Implementation Grants

66.113		Region 3 Environmental Priority Projects

Region 4

66.127		Southeastern U.S. Regional Targeted Watershed Initiative

Region 6

66.124		Coastal Wetlands Planning Protection and Restoration Act

66.125		Lake Pontchartrain Basin Restoration Program (PRP)

Region 9

66.126		The San Francisco Bay Water Quality Improvement Fund

66.600	Environmental Protection Consolidated Grants for the Insular
Areas - Program Support

Region 10

66.119		West Coast Estuaries Initiative

66.120		Puget Sound Watershed Management Assistance

66.121	Puget Sound Protection and Restoration: Tribal Implementation
Assistance Program

66.122	Puget Sound Action Agenda Outreach, Education and Stewardship
Support Program

66.123	Puget Sound Action Agenda: Technical Investigations and
Implementation Assistance Program

 $43.96 represents the average wage rate of several occupations expected
to apply for grants or fellowships.  This information is derived from
Bureau of Labor Statistics; Occupational Employment and Wages, May 2010.
 Costs were then updated to current levels. Cost data available at: 
http://www.bls.gov/oes/current/oes_stru.htm (accessed 1/12/2012).  1.43
represents a 43% rate for benefits.  This figure is derived from the
Bureau of Labor Statistics’ “Table 1. Civilian Workers, by Major
Occupation Group; Management, Professional, and Related,” Employer
Costs for Employee Compensation – September 2011.”

  $17.50 represents the average hourly wage rate of two
administrative/clerical positions.	 This information is derived from
Bureau of Labor Statistics; Occupational Employment and Wages, May 2010.
 Costs were then updated to current levels.  Cost data available at: 
http://www.bls.gov/oes/current/oes_stru.htm (accessed 1/12/2012).  1.43
represents a 43% rate for benefits.  This figure is derived from the
Bureau of Labor Statistics’ “Table 1. Civilian Workers, by Major
Occupation Group; Management, Professional, and Related,” Employer
Costs for Employee Compensation – September 2011.”

	

 Office of Personnel Management; 2012 General Schedule (GS) Base (Hourly
Rate) for GS 11, Step 9 ($30.52).  Available at:    HYPERLINK
"http://www.opm.gov/oca/12tables/pdf/gs_h.pdf" 
http://www.opm.gov/oca/12tables/pdf/gs_h.pdf .  This was fully burdened
(x 60%), yielding a wage rate of $48.83.

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