            Supporting Statement for a Request for OMB Review under
                          the Paperwork Reduction Act
1.	Identification of the Information Collection
1(a).  Title of the Information Collection.  
     Title:  Reporting in the FIFRA Cooperative Agreement Work Plan and Report Template 
     EPA ICR No.:  2511.02
     OMB Control No:  2070-0198
     Docket ID No.: EPA-HQ-OPP-2018-0418 
     
1(b).  Short Characterization/Abstract.  
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 U.S.C. 136u) see Attachment A.

This ICR augments the ICR entitled "EPA's General Regulation for Assistance Programs ICR" (OMB Control No. 2030-0020; EPA ICR 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 ICR provides the burden assessment for the FIFRA program specific activities associated with using a standardized electronic format for only the STAG program reporting.
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 U.S.C. 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.    
      
The burden is accounted for in the EPA's General Regulation for Assistance Programs ICR (OMB Control No. 2030-0020; EPA ICR No. 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. 

The benefits of using the template format include a reduction of the administrative burden on grantees and EPA by streamlining the workplan and report development. In addition, the use of a standardized template provides certainty of work expectations and aids EPA's oversight responsibility by aligning the grant guidance and the workplan. Lastly, the use of the template to report information to EPA standardizes the reporting information nationally by increasing national consistency in work plans and reports; and facilitates national compilation of data to be able to use data analytics, look for trends, significant issues or innovations

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 Federal Register notice and provide a 60-day public comment on this proposed Information Collection activity. Any public comment EPA receives will be placed in the docket for this action, EPA-HQ-OPP-2018-0418.  
        
3(c).  Consultations.  
As required under 5 CFR 1320.8(d)(1), the Agency will consult with stakeholders who actively interact with the Agency through the use of this collection instrument and will solicit stakeholder assessment of the regulatory burden estimates expressed by the Agency in this ICR. A record of the consultations will be placed in the EPA docket for this action 

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. 

3(h).  Use of Technology to Minimize Burden.  
The Template was developed at the suggestion of and in collaboration with several STAG participants. The standardized Template for use in creating the work plan and subsequent reporting was created to help reduce the administrative burden of the cooperative agreement process on both the participants and EPA. By increasing consistency in the work plans and reports throughout the country, the Template is also expected to facilitate national compilation of data, and receiving the information in a standardized format does facilitate the Agency's review and use of the information provided. 

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. 
         
Instructions for completing the Template are shown in Attachment E.  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 Requested  -  Respondent Activities for FIFRA Cooperative Agreements. 
Whereas the information collection activities approved under OMB Control No. 2030-0020 (EPA ICR No. 0938.18) generally apply to grantees across multiple program areas, this new ICR addresses only 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. In February of 2017, a workgroup comprised of EPA, state and tribal representatives began work to convert the FIFRA Work Plan and Report Template (FIFRA Template), which was in Excel, into a web-based system housed in the Central Data Exchange (CDX) platform, called the FIFRA Continuing Environmental Grant Program (FCEPG).  FCEPG incorporates the exact same information as the FIFRA Template, including: proposed work activities from the FIFRA Cooperative Agreement Guidance; the grantee's workplan; the grantee's yearend report; as well as the EPA regional project officer's yearend report.  FCEPG will be used by the same stakeholders as the FIFRA Template, and will provide a better customer experience. At this time, the FCEPG template is set to be available for Fiscal year 2020. Respondents/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. To assist the states, tribes, and territories Template guidance is provided to the grantees, https://www.epa.gov/compliance/federal-insecticide-fungicide-and-rodenticide-act-state-and-tribal-assistance-grant.  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 will be reviewed periodically to identify and eliminate duplication in reporting requirements. The Agency will conduct periodic on-site reviews to ensure recipients are compliant with applicable requirements.  The Template will be reviewed in accordance with the requirements of 40 CFR Parts 30 and 31, see Attachment D. A summary of the annual Agency burden hours and costs are summarized in Table 2.     

5(b).  Collection Methodology and Management.   
The Agency's burden activities and methodology for collecting the template information include consultation with grantees with questions about template completion, developing mid-year and year-end reports, providing template submissions to Regional Management and Headquarters and working with Regional Grants offices.    
      
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 information is outlined in the Cooperative Agreement Guidance, 2018-2021. See https://www.epa.gov/compliance/federal-insecticide-fungicide-and-rodenticide-act-state-and-tribal-assistance-grant.  Biannual reporting is the average reporting period.  
	
6.	Estimating the Burden and Cost of the Collection

6(a).  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 2017 base data from the Bureau of Labor Statistics (BLS).

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 46.5% 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 46.5% 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 BLS (unloaded) wage rates used to calculate the respondent costs for this renewal are $42.17 and $29.54 per hour for managerial and technical labor hour costs, respectively, which equates to $92.65 and $64.90, when calculated on a fully loaded basis as described above. There are no clerical costs estimated for respondents in this ICR. These wage rates reflect the average hourly wage rate estimate provided by BLS for the North American Industry Classification System (NAICS) code for State Government (NAICS code 999200).

6(b).  Estimating Respondent Burden. 

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, 7 of which (Oregon, New York, Massachusetts, New Mexico, Pennsylvania, Virginia, and Vermont) provided a detailed breakdown by activity for the Template. The responses of these 7 FIFRA STAG grantees is the basis for estimating the burden hours and costs for completing all grant reporting using the Template. Table 1 displays the "per Template" (one complete annual reporting cycle using the Template) burden and cost of the specific FIFRA program grant reporting activities as reported on the Template. 

There are no capital costs related to completing EPA grant applications and the related reporting requirements in the FIFRA Template and there are no operating and maintenance costs associated with these activities. The previous section, 6 (a), describes how the labor costs are derived. The total estimated burden hours per Template is 323.40. The total estimated burden cost per Template is $25,953. Since there is only one Template per grantee, the total number of Templates is the same, 81. The total annual burden hours for all respondents is 26,195 (323.40 X 81 Templates/respondents). The total annual burden cost for all respondents is $2,102,179 ($25,953 X 81 Templates/respondents). 
	






Table 1  -   Annual Average Burden Hour and Cost Estimate "per Template" for each FIFRA Grantee

                            Annual Burden Activity
                                 Burden hours
                              (by Labor category) 
                  Total Estimated Burden Hours (by activity)
                                 Burden Costs
                              (by Labor category)
                   Total Estimated Burden Cost (by activity)
                             T5(Each Template Tab)




                                       
Managerial
Technical 

Manager
Technical

 



92.65 /hr
64.90/hr

Start[1] 
                                     11.25
                                       8
                                     19.25
 $     1,042 
 $       519 
 $      1,561 
Narrative
                                     14.25
                                      20
                                     34.25
 $     1,320 
 $     1,298 
 $      2,618 
Budget
                                     21.25
                                       0
                                     21.25
 $     1,969 
 $         0  
 $      1,969 
Work Plan  
                                      27
                                      32
                                      59
 $     2,502 
 $     2,077 
 $      4,578 
Outcomes
                                     22.2
                                     28.5
                                     50.7
 $     2,057 
 $     1,850 
 $      3,906 
5700 Main
                                      5.7
                                     11.5
                                     17.2
 $       528 
 $       746 
 $      1,274 
5700 WPS
                                       2
                                       3
                                       5
 $       185 
 $       195 
 $         380 
5700 Container Containment (CC)
                                      1.5
                                      7.5
                                       9
 $       139 
 $       487 
 $         626 
Endangered Species
                                      12
                                       4
                                      16
 $     1,112 
 $       260 
 $      1,371 
Performance Measures
                                      11
                                      10
                                      21
 $     1,019 
 $       649 
 $      1,668 
Review Template for accuracy/errors
                                      28
                                     14.5
                                     42.5
 $     2,594 
 $       941 
 $      3,535 
Management final review and submittal to EPA  
                                     21.5
                                       1
                                     22.5
 $     1,992 
 $         65 
 $      2,057 
File Template report (record keeping)
                                     1.25
                                      4.5
                                     5.75
 $       116 
 $       292 
 $         408 
Total (per Template) 
                                    178.90
                                    144.50
                                    323.40
 $   16,575 
 $    9,378 
 $    25,953
Numbers may not add due to rounding. 
[1] Includes time spent in consultation with EPA to help the grantee with this process. 

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 is 498.3 to assist and process all the annual paperwork for STAG grantees. The program is implemented in 10 EPA regional offices. A regional office may oversee one or more STAG grants within the region. 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 (NAICS code 999100). Similar to the respondent labor cost data, 2017 BLS base data is used. The unloaded wage rates from BLS are $59.10, $38.92, and $21.93 per hour for managerial, technical, and clerical labor hour costs, respectively. The fully loaded wage rates used to calculate the Agency labor costs for this renewal are $129.84, $85.51, and $48.18 per hour for managerial, technical, and clerical labor hour costs, respectively. Please see section 6(a) for details on how fully loaded wages are calculated. 
The total estimated Agency burden hours (per grantee) per Template is 498.3. The total estimated Agency burden cost (per grantee) per Template is $44,253. Since there is only one Template per grantee, the total number of Templates is the same, 81. The total annual Agency burden hours is 40,362 (323.40 X 81 Grantees/ Templates). The total annual Agency burden cost is $3,584,515 ($25,953 X 81 Grantees/ Templates).
	
Table 2 - Agency Annual Average Burden Hour and Cost Estimate "per Template" 

                                  Activity  
                                    Manager
                                   Technical
                                   Clerical
                                    Totals 

                                     Hrs.
                                  $129.84/hr
                                     Hrs.
                                   $85.51/hr
                                     Hrs.
                                  $48.18 /hr
                                 Burden (hrs)
                                   Costs ($)
Consult with Grantee and respond to questions about Template completion
                                       2
                                     $260
                                      102
                                    $8,722
                                       0
                                       0
                                      104
                                    $8,982
Developing mid-year and year end reports (columns P-R)
                                      27
                                    $3,506
                                      212
                                    $18,128
                                      2.5
                                     $120
                                     241.5
                                    $21,754
Submit Template to regional management and HQ
                                      0.7
                                      $91
                                     20.1
                                    $1,719
                                       0
                                       0
                                     20.8
                                    $1,810
Working with the regional grants office (Region 1) 
                                       0
                                      $0
                                      12
                                    $1,026
                                       0
                                       0
                                      12
                                    $1,026
                                       
Region 6[1] 
                                      9.5
                                    $1,234
                                     110.5
                                    $9,449
                                       0
                                       0
                                      120
                                    $10,682
Total (per Template)
                                     39.2
                                    $5,090
                                     456.6
                                    $39,043
                                      2.5
                                     $120
                                     498.3
                                    $44,253
Numbers may not add due to rounding. 
[1]Region 6 did not provide a burden breakdown of activities so only a summary of the annual activities estimates are provided.  
	
6(d).  Estimating the Respondent Universe and Total Burden and Costs. 
For the FIFRA program specific ICR burden hour projections, the estimates and cost projected assume that all the grantees, 81 states, territories, and tribes, are using the Template for their work plan and reporting requirements and will continue to do so. Estimates of the burden are expressed as one complete annual reporting event using the Template, which includes a mid-year and year-end report (biannual reporting). The estimate assumes that all grantees will conduct all the activities in the Template. This is a conservative estimate since not all 81 FIFRA grantees will participate in all of the FIFRA grant program activities or have the same number of grant contract years (i.e., 3 years vs. 1 year).  

6(e).  Bottom Line Burden Hour and Cost.
Table 3 represents the annual grantee per Template burden of the required grant reporting for the FIFRA program specific activities. The total annual burden hours for all respondents (i.e. 81 STAG grantees) is 26,195 (323.40 X 81 Templates/respondents). The total annual burden cost for all respondents is $2,102,179 ($25,953 X 81 Templates/respondents). The total annual Agency burden hours is 40,362 (323.40 X 81 respondents). The total annual Agency burden cost is $3,584,515 ($25,953 X 81 respondents).

In this renewal ICR, the "per event" or Template burden estimates the burden will remain the same as the last ICR, at 46.15 hours to conduct the STAG grant activities. 

Table 3. Total Annual Burden Hour and Cost for Respondents and Agency

 
                              Annual Burden Hours
                              Annual Burden Costs
Respondents /Grantees (81 States, Tribes, territories  -  per event reporting in the FIFRA Template)
                                    26,195
                                  $2,102,179 



Agency processing burden for all 81 STAG grants annually 
                                    40,362
                                  $3,584,515 
          	
6(f) Reasons for Change in Burden.  
For this renewal ICR, there is no increase in the annual PRA burden hours for grantee to use the FIFRA grant Template over the last ICR. The FIFRA STAG Grant Template annual per respondent burden remains the same at 46.15 burden hours.  However, the burden cost in this ICR has increased relative to the previous ICR due to updating the wages (from 2012 to 2017) and using the fully loaded wage rate as described in section 6 (a). In the previous ICR, the unloaded wage rate was used. This is a program adjustment.

"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-2018-0418, 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. 2070-0198 (EPA ICR No. 2511.01) via email to oira_submission@omb.eop.gov. Include docket ID No. EPA-HQ-OPP-2018-0418 and OMB control number 2070-0198 (EPA ICR No. 2511.02) in any correspondence, but do not submit and any grant related information (e.g., forms, reports, etc.) to these addresses.
7.	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 U.S.C. 136u) is attached in the docket for this action.  
              
Attachment B:	"EPA's General Regulation for Assistance Programs ICR" (OMB Control No. 2030-0020; EPA ICR No. 0938.18) is attached as part of the docket for this action. 	 

Attachment C:	[Reserved for Consultation Summary]  
 
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.

Attachment E:  Instructions for completing the FIFRA Grant Work Plan and Report Template.

Attachment F:  Work Sheets used to Calculate Respondent Labor Costs for the State and Tribal Assistance Grant (STAG) program (OMB Control No. 2070-0198, EPA ICR No. 2511.02). 
					



            
