                           SUPPORTING STATEMENT FOR 
                    AN INFORMATION COLLECTION REQUEST (ICR)
                                        
1.	IDENTIFICATION OF THE INFORMATION COLLECTION

      1(a)	School Integrated Pest Management Awards Program 
      
      EPA ICR No.: 2531.02 	OMB Control No.: 2070-0200
      
      Docket ID No.: EPA-HQ-OPP-2019-0356
      
      1(b)	Short Characterization
      This is a renewal information collection request (ICR) that will cover the paperwork activities associated with the U.S. Environmental Protection Agency's new program to encourage the use of Integrated Pest Management (IPM) as the preferred approach to pest control in the nation's schools. IPM is a smart, sensible, and sustainable approach to pest control that emphasizes the remediation of pest conducive conditions. IPM combines a variety of pest management practices to provide effective, economical pest control with the least possible hazard to people, property, and the environment. These practices involve exclusion of pests, maintenance of sanitation, and the judicious use of pesticides.
      The EPA's vision is that all students in the U.S. will experience the benefits provided by an IPM program in their school district. The Agency's IPM implementation efforts are based on a wholesale approach aimed at kindergarten through 12[th] grade public and Tribal schools. The Agency intends to use the information collected through this ICR to encourage school districts to implement IPM programs and to recognize those that have attained a notable level of success. Since IPM implementation occurs along a continuum, the School IPM (SIPM) incentive program will recognize each milestone step a school district must take to begin, grow, and sustain an IPM program. 
      This program has five award categories - Great Start, Leadership, Excellence, Sustained Excellence, and Connector. The first four categories are stepwise levels that are reflective of the effort, experience, and, ultimately, success that results from implementing EPA-recommended IPM tactics that protect human health and the environment. Schools with pest infestations are not only exposed to potential harm to health and property, but also to stigmatization. The School IPM recognition program will give districts across the nation the opportunity to receive positive reinforcement through public recognition of their efforts in implementing pest prevention and management strategies. 
      When this information collection request was first created in 2016, the School IPM Awards was never launched, however with the renewal, the Agency is working to implement this program. The School IPM awards program currently follows the model of the Agency's Indoor Air Quality Tools for Schools program that recognized schools for achievements in improving indoor air quality. The highly successful Tools for Schools program was active for ten years and employed the same tiered approach as the School IPM awards program. The awards program will connect the Agency with school districts to encourage reciprocal learning around IPM and foster models for other districts to utilize when implementing a sustainable IPM program. 
      The awards program, as a whole, provides incentives for sustainable IPM practices in schools at the individual for districts as well as individuals, including non-school entities. School districts and other participating entities seeking recognition for their IPM programs will need to maintain detailed records on a variety of activities and send completed applications to EPA for each award to which they aspire. As part of their activities, participants will need to develop an IPM policy and update their IPM plans annually. Applicants will provide information describing how they have met the requirements for the award category to which they are applying. There are four progressive levels of award for school districts (i.e., Great Start, Leadership, Excellence, and Sustained Excellence); the Connector award is open to non-school entities and individuals.
      Comprehensive school IPM programs create safer and healthier learning environments by helping to effectively manage pests, reduce children's unnecessary exposure to pests and pesticides, and reduce pest complaints. A relatively small percentage of U.S. K-12 schools currently have verifiable IPM programs. The information collected will substantiate the implementation of the actions required along the IPM continuum from program initiation to robust, sustained implementation. 
The School IPM awards program will initially place more focus on school districts rather than individual schools. This is primarily due to the resource requirements to process applications from individual schools on a national scale.

2.	NEED FOR AND USE OF THE COLLECTION
      2(a)	Need/Authority for the Collection
	Section 13101(b) of the Pollution Prevention Act of 1990, 42 U.S.C. sets forth "the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible." Section 13102(4) defines source reduction as any practice that "reduces the amount of any hazardous substance ... released into the environment" and "reduces the hazards to public health and the environment associated with the release of such substances." To implement this policy, Section 13103(b)(5) of the Act directs the Administrator of EPA to, among other things; "facilitate the adoption of source reduction techniques by business" (see Attachment A).
	Section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. 136a, requires EPA to regulate pesticides to prevent "unreasonable adverse effects" on human health and the environment (Attachment B). IPM strategies, such as removing sources of food, water, and shelter for pests, reduce pest problems and the unnecessary use of pesticides. 
	The Food Quality Protection Act (FQPA) of 1996 (7 USC 136r - 1) requires the U.S. Department of Agriculture and EPA to implement programs in research, demonstration, and education to support the adoption of IPM, make information on IPM widely available to pesticide users, use IPM techniques in carrying out pest management activities, as well as promote IPM through procurement, regulatory policies and other activities (Attachment C). The School IPM awards program is a non-regulatory approach to meet the goals of the Pollution Prevention Act, FIFRA and FQPA to reduce pesticide risks in non-agricultural settings.
	The collection of information that documents and measures applicant accomplishments enables EPA to fairly and accurately assess program effectiveness and benefits of awards. Completed applications, including contact information, are preliminary to EPA's formal recognition. The applications will allow EPA to understand and promote each school district's efforts. In addition, this program will measure individual and collective program progress in School IPM implementation.
      2(b)	Practical Utility/Users of the Data
The information collected by the School IPM awards program is not designed or intended to support EPA regulatory decision-making. EPA intends to use the information collected through award program applications to:
          Determine applicant eligibility for award recognition. 
          Identify school districts' commitment to promoting and implementing IPM practices.
          Verify participation in promoting and implementing IPM practices.
          Define the existing landscape and implementation status of IPM practices in school districts nationally.
          Measure environmental outcomes.
   The Agency will use this data to:
          Develop case studies that demonstrate the importance of IPM implementation in school districts.
          Encourage replication of best practices for adopting, implementing and sustaining comprehensive school IPM programs.
          Share information on IPM practices that school districts can incorporate into other environmental health initiatives (for example, indoor air quality management, asthma management, etc.) Provide a better understanding of how schools can effectively manage environmental issues when faced with budgetary and personnel challenges.
         
In addition, EPA will analyze the data, to the extent possible, to look for environmental trends and highlight program successes by posting information on the Agency's School IPM website.
As will be discussed in Section 3(f) of this ICR, the EPA will not publish business information reported by award program applicants. Data will only be shared publicly in aggregate form unless otherwise specified and agreed to by the affected school district or awardee.

3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
      3(a)	Non-Duplication
      The information to be collected by EPA's School IPM awards program is unique and is not duplicative of other collections. For example, data submitted through the award applications are specific to the tasks required to implement an IPM programs in schools. Applicants will not be asked to provide information that has been, or is currently being collected by EPA, other federal or state agencies, or proprietary sources. While some state and local government agencies may require pesticide users to maintain records of pesticide use and IPM, they may not require it to be reported. As detailed below, in those instances when a government or private entity collects pesticide use and IPM data, it is not of the scope or detail needed to operate the School IPM awards program. The EPA consulted with trade associations, nonprofit groups, school districts, and other potential participants to confirm that the information being collected by the School IPM program does not exist elsewhere.
      While developing the IPM measures, the Agency consulted with the Pesticide Program Dialogue Committee (PPDC), a Federal Advisory Committee Act advisory board to the Agency's Office of Pesticide Programs. The PPDC is a cross-section of entities with interest in pesticide-related matters, including IPM, with representatives from the private sector, nongovernmental entities, and the federal government. Within the PPDC, there is a workgroup focused on IPM. While EPA did not provide the PPDC with details on the information being requested from award program applicants, the committee provided advice on long-term program goals. (Link at the bottom of page 3)
      The level of detailed information required for the School IPM award program is not available through other organizations. Some states collect pesticide use information. Of these, California's data collection is one of the most comprehensive. Even so, its scope is too limited for the purpose of this award program because: 1) the reporting is not focused on School IPM; and 2) the reporting only applies to California while the Agency's award program is a nationwide program. 
      State governments' pest management reports may also not be consistently available due to changes in reporting requirements or states' priorities. An example of a state government pesticide data collection program with such limitations is Oregon. In 2009, Oregon canceled its pesticide use reporting requirements because budgetary constraints limited the state's ability to use the data to develop and publish reports.
      Some states currently have school IPM requirements based on legislation. These laws vary in breadth and rigor but all deal with some element of pesticide application in or around schools, for example pesticide use notification requirements. Alabama, Louisiana, North Carolina, and Texas have regulations on restricted spray zones that impact schools. Some states require IPM training for those applying pesticides in schools, others define the type of pesticide products that can be used in schools, while others require detailed IPM programs for all schools.  The variety of School IPM-related requirements and pesticide data collection mechanisms across all states make it difficult for the EPA to access and use these data. Furthermore, the EPA School IPM award applications are designed to assess only those activities required to implement an IPM program in a school district. No governmental entity is collecting the data the Agency needs to assess IPM implementation in school districts across the nation. Thus, the EPA believes that the information requested through the ICR is not duplicative.
      3(b)	Public Notice Required Prior to ICR Submission to OMB
Pursuant to 5 CFR 1320.8(d), the EPA will publish a Federal Register Notice announcing this proposed information collection activity and provide a 60-day public comment period. The comments received and any additional public comment for this action will be posted in the docket.

      3(c)	Consultations
       In addition to the initial survey for SIPM, following the publication of the first Federal Register Notice for this new ICR, EPA staff will contact appropriate stakeholders and ask them for their assessment of the regulatory burden estimates expressed by the Agency in this ICR. A summary of these consultations will be provided in the supporting statement during the second comment period. (Attachment D).
	
	3(d)	Effects of Less Frequent Collection
      The EPA requests that School IPM awardees submit applications at least every two years to maintain their award status level. Because of the intended high visibility of the program, less frequent resubmission could compromise program integrity. It will also take time for a school district to implement their IPM program and report on its results. The Agency believes that the two-year timeframe gives schools the flexibility needed to complete a School IPM award application and, subsequently begin or further develop their IPM program.
	3(e)	General Guidelines
The information collection activities discussed in this ICR comply with all regulatory guidelines under 5 CFR 1320.5(d) (2). School IPM award program applicants will not need to retain records for this program for more than one year with the exception if the applications are committed to maintain awardee status or to move to the next award in the program. School IPM award program participants may resubmit applications every two years to maintain awardee status or to move to the next level in the program.
	3(f)	Confidentiality
      EPA has implemented procedures to protect any confidential, trade secret or proprietary information from disclosure that provide strict instructions regarding access to and contact with documents confidential business information (CBI). These procedures comply with EPA's CBI regulations at 40 CFR Part 2, Subpart B. The reporting method and system prevents access to and distribution of business information reported by School IPM awardees. Data will only be shared publicly in aggregate form unless otherwise specified and agreed to by the affected awardee.
	3(g)	Sensitive Questions
      This information collection activity complies with the provisions of the Privacy Act of 1974 and OMB Circular A-108, as amended, "Responsibilities for the Maintenance of Records about Individuals by Federal Agencies." No information of a sensitive or private nature is requested in conjunction with this information collection activity. EPA aggregates data before sharing it with any party outside of the Agency. School IPM data sharing activities protect an organization's data by presenting them in a general and unidentifiable manner unless otherwise specified and agreed to by the affected awardee.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a)	Respondents and NAICS codes
School districts, or entities that represent them, are the target applicant pool for the School IPM award program.
Below is a list of North American Industry Classification System (NAICS) codes and associated industries that may be affected by information collection requirements covered under this ICR. This list is intended to be illustrative; entities from other industries may elect to apply for recognition through the School IPM award program. However, EPA expects that most applications will come from public kindergarten through 12[th] grade schools.
                                  NAICS Code
Affected Industry
                                     6111
Elementary and Secondary Schools 
                                     6244
Child Day Care Services
                                     56172
Janitorial Services
                                     56173
Landscaping Services
                                     56171
Exterminating and Pest Control Services
                                     5617
Services to Buildings and Dwellings

4(b)	Information Requested
	School districts seeking recognition in the EPA School IPM award program must fill out one or more of five award applications (Attachment E). These applications are: 
 The Great Start application is required for the Great Start award. This award recognizes districts that are starting an IPM program.
        
 The Leadership award application is required for the Leadership award. This award requires a school district to demonstrate how its IPM program was implemented to include staff education and the definition of roles and responsibilities.
       
 The Excellence award application is required for the Excellence award. This is the middle tier of the award program. For this award, applicants must show how employees have received IPM education, how IPM-related maintenance is performed, and pest monitoring is being tracked. 
       
 The Sustained Excellence award application is required for the Sustained Excellence award. This level builds on the Excellence award by requiring school districts to provide documentation of pest proofing or pest prevention by design. This is in addition to documenting how employees are educated on IPM, how pest proofing repairs are made, and that pest monitoring is being conducted and tracked.
       
 The Connector award application is required for the Connector award. This award is reserved for the individual or organization that can demonstrate playing a key role in implementing an IPM program in a school district.  
    The time and effort to complete the application form for each type of data collection varies. For example, the Great Start award only requires applicants to complete a narrative for an IPM plan and commit to appointing an IPM coordinator. It does not require the specific measures and progress tracking elements present in the Excellence award. Consequently, completing the application for the Great Start award is less burdensome than completing the application for the Excellence award. 
      The School IPM information collection instrument assumes that a number of different employees or contractors can complete the data collection task for the school district. These could include the IPM coordinator, health and safety coordinator, quality assurance specialist, pest management professional, campus facility supervisor, custodian, groundskeeper, and food service personnel. Each award has a different information collection demand.
      The EPA assumes that all the paperwork burden incurred by individual schools as well as by their districts to maintain records and to report (apply) for the incentive program are included in the burden estimates provided in the survey responses submitted by the school districts. This assumption is since many schools are already positioned for such school-to-district reporting either because of existing pesticide, IPM, or school environmental health reporting requirements. In such cases, information reported by individual schools are already compiled and maintained at the district level.
      The School IPM awards allow for rolling applications, i.e., applications can be submitted at any time during the year. EPA will process each application within 60 days of submission. EPA will make award presentations to awardees monthly as applications are approved.
      The standard threshold for the four-tiered awards that recognize school districts increases as an applicant seeks higher levels of recognition. The exception is for the Connector award which recognizes an organization or individual for "connecting" school districts to help implement an IPM program. This award program recognizes the incremental steps it takes to implement IPM in a school district. Each award category and its requirements are explained in section 4(c) of this ICR. 
      4(c) 	Incentive Program Conditions and Criteria		
The School IPM Awards conditions and criteria, which are summarized below, are detailed in Attachment F.
      Great Start Award
      The Great Start award is presented to school districts that are in the initial stages of implementing an effective IPM program. Applicants must have selected an IPM coordinator for the district and created a written IPM policy to receive this award.
      Leadership Award
      The Leadership award is presented to school districts with a senior-level commitment to establish and maintain an IPM program as well as to relate their IPM strategies to the framework for effective school IPM programs (i.e., Organize, Assess, Plan, Act, Evaluate, and Communicate).
      Excellence Award
      To merit an Excellence award, applicants need to tell the story of their IPM program in a way that demonstrates the program is comprehensive, effective, and moving towards being institutionalized as part of a comprehensive environmental health program in the district. Specifically, the EPA will look for evidence that: 
          The critical components of the framework for effective school IPM programs (i.e., Organize, Assess, Plan, Act, Evaluate, and Communicate) are embodied in the school environmental health management program; 
          An established system exists to ensure consistent and sustained action to identify, address and prevent pest problems; and
          Evidence that the program is achieving results. 
   Sustained Excellence Award
      To merit a Sustained Excellence award, applicants must meet the requirements of the previous levels of award criteria for at least two years after receiving Excellence award recognition. Applicants must demonstrate that its IPM program is sustainable by providing documentation for pest reduction, health improvements, and financial benefits. Lastly, Sustained Excellence award applicants must show how the school district communicates about its IPM program, both to its internal community (students, parents, employees) and to the external community (other districts, surrounding neighborhood, and community leaders).
      Connector Award
      The Connector award is designed to give national recognition to individuals and organizations whose actions and initiatives support improved school environmental health in their community, region, state, or even nationally, with a special focus on actions and initiatives that reflect the spirit of the award. Examples include the following: 
          Development of innovative initiatives, approaches, tools, or resources that have contributed to improved school IPM and indoor environments; 
          Outstanding individuals and groups who have played a coordinating function to bring people or IPM programs together to provide mutual assistance and support in school IPM implementation; 
          Leadership/mentorship of school or school district's IPM program; 
          Technical assistance in IPM program implementation;
          Increasing student involvement in IPM, such as integration of science clubs; and 
          Other actions and initiatives that foster interconnectedness and mutual support and demonstrate results as part of these efforts.
         
      5.	THE INFORMATION COLLECTED  -  AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
      
      5(a)	Agency Activities
      
      Under the SIPM Award program, the EPA engages in the following activities:
      
      Award Application Processing 
         
 Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet
 Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets.
 Determine who will be participating on the review panel. Preferably an odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application.
 Provide regional staff PDF file versions of applications for their review and weigh-in as personnel that may have worked with the districts specifically.
 In two weeks, assimilate all score and hold a half day consensus meeting to determine what school districts are worthy of awards. During this meeting each applicant is discussed, and the strengths and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year's application, if they were not chosen.
 Provide a list of selected applicant recommendations to the EPA regional office and to headquarters' senior management for approval.
 Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application.
 If there is an event designated for highlighting the award-winning school districts and invitational travel involved, convey logistics to selected applicants.
 Using award winning applications, create communications materials to showcase these award-winning programs. Initiate comprehensive outreach communications plan (develop press release, secure Sr. level quote, FB, Twitter postings). If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories.
	In addition to the above listed activities, the Agency also performs an environmental and criminal compliance screening to ensure that all members are good actors. The EPA performs this task by checking Agency data bases both at headquarters and the regions.

5(b)	Collection Methodology and Management

Prospective applicants can obtain the SIPM award application form upon request from the Agency. The Agency is currently designing a website where the SIPM award application form will be available online. The application form was designed to have a minimum burden on the user.
      
Once complete, the form is submitted online through email to EPA. Application processing can take up to 60 days because of compliance screening. The EPA will review each applicant's environmental compliance history. To receive recognition, school districts must pass the compliance screening and the criteria set forth by the award level.    

In collecting and analyzing the information associated with this ICR, the EPA will use a telephone system, personal computers, email and applicable PDF software.
    
      
5(c)	Small Entity Flexibility

The EPA expects to receive applications to the SIPM program from a variety of school districts and organizations. Award applications are designed to minimize respondent burden while obtaining enough and accurate information. The Agency will review members' applications, making allowances on a case-by-case basis for the inapplicability of certain elements and the applicants' abilities to provide the information. 

Since membership in the SIPM award program is voluntary, applicants may also elect to withdraw from the program, at any time, if they do not wish to submit applications needed to maintain their award status. The EPA requires that all awardees submit applications every two years to maintain recognition status. 

5(d)	Collection Schedule

Organizations may submit application forms at any time. The SIPM program is a rolling admission program. The EPA will approve or reject all applications within 60 days of submission. School districts may submit the Great Start, Leadership, Excellence, Sustained Excellence, and Connector Award at any time of the year. The EPA will seek to hold an annual recognition ceremony for awardees at a conference that attracts school districts and key stakeholders' leadership.


6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	Estimating Respondent Burden

      Respondent paperwork burden of participating in the SIPM recognition program consists primarily of the administrative burden associated with applying for the different types of awards. This involves preparation, submission, and recordkeeping of an application form.  
      To estimate average annual paperwork burden on respondents, estimated cost per respondent is multiplied by the total number of respondents, which are projected based on past data. However, since this is a new program there are no past data on the number of applicants to develop such projections. Therefore, as a proxy for the School IPM awards program, the Agency used the data on the number of applicants from its Indoor Air Quality (IAQ) project. As discussed in previous sections of this ICR, the Agency modelled the School IPM program after the IAQ Tools for Schools program and believes the initial level of participation may be similar.  
Annual Respondent Numbers (Data from EPA's IAQ Tools for Schools Awards Program)
                                     Year
                            Great Start Applicants
                            Leadership Applicants 
                             Excellence Applicants
                         Model of Sustained Applicants
                        Special Achievement Applicants*
                          Total Applications Received
                                     2009
                                      18
                                      12
                                      13
                                       3
                                       5
                                      51
                                     2008
                                      14
                                      12
                                       6
                                       4
                                       3
                                      39
                                     2007
                                      42
                                       6
                                       8
                                       6
                                       8
                                      70
                                Annual Average
                                      25
                                      10
                                       9
                                       4
                                       5
                                      53
     * IAQ Connector Award started in 2009

Burden estimates were prepared for the average time necessary to perform each activity in preparation, submission, and recordkeeping of an application for each award type. Burden estimates are based on interviews conducted with representative respondents. Each of the three school districts surveyed and the non-profit organization were provided detailed instructions on how to obtain each requested burden estimate through both phone conversations and written correspondence. Respondents were allowed 30 days to acquire the requested information and provide comments and/or suggestions on program improvement when interacting with potential school districts.

As shown in Section 6(b), Tables 1  -  5, the total annual burden hours associated with applying for an award are 90, 375, 198, 134, and 72 for Great Start Award, Leadership Award, Excellence Award, Sustained Excellence Award, and Connector Award, respectively.  

The EPA estimates that, on average, a total of 53 entities per year would participate in the SIPM during a three-year period. Since the past data from the EPA's IAQ project (2000-2010) show high variability without an increasing or decreasing trend, and the data for 2010 is not complete, the three-year average data over 2007-2009 are used as the projected annual number of applicants for the three-year ICR period. For respondents, the EPA estimates an average of 875 hours for all award categories combined, at a total cost of approximately $81,000 annually.

6(b) Estimating Respondent Costs

Consistent with recent ICR submissions, OPP is using labor cost estimates from 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 and current publicly available data to provide more accurate estimates and allow easy replication of the estimates.

Methodology: The calculation of the wage rate uses base 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) based on that data. Fully loaded wage rates are used to calculate respondent costs. Cost estimates are based on 2018 wage data.

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

Sectors: The specific NAICS code and website for each sector is included in that sector's wage rate table in Attachment G. 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). The managerial labor rate is based on the SOC for management occupations, and the clerical labor rate is based on the SOC for office and administrative support occupations. The technical labor rate is based on the SOC for life, physical and social science occupations. For school IPM, the technical rate is based on first-line supervisors/managers of landscaping, lawn service, and grounds keeping workers.

Loaded Wage Rate: Benefits represent approximately 45.8% of unloaded wage rates, based on total benefits for all civilian non-farm workers from http://www.bls.gov/news.release/ecec.t01.htm 

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

A copy of the formula work sheets used to estimate the labor rates based on 2018 wage data and to derive the fully loaded rates and overhead costs for this new ICR are provided in Attachment G. 

Tables 1 - 5 below provide average annual respondent burden and cost estimates by award type.

Table 1. Average Annual Respondent Burden and Cost Estimates - Great Start Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                    $86.43 
                                    $65.36 
                                    $40.14 



                                   per hour
                                   per hour
                                   per hour


Average time to read instructions
                                      0.2
                                      0.0
                                      0.0
                                                                            0.2
                                                                           $16 
Average time to plan activities
                                      0.5
                                      0.0
                                      0.0
                                                                            0.5
                                                                           $49 
Average time to gather information
                                      1.0
                                      0.0
                                      0.0
                                                                            1.0
                                                                           $98 
Average time to compile and review
                                      1.0
                                      0.0
                                      0.0
                                                                            1.0
                                                                           $98 
Average time to complete and submit paperwork
                                      0.8
                                      0.0
                                      0.0
                                                                            0.8
                                                                           $73 
Average time to store/maintain data
                                      0.3
                                      0.0
                                      0.0
                                                                            0.3
                                                                           $24 
Total per applicant
                                       4
                                      0.0
                                      0.0
                                                                              4
                                                                          $358 
# of applicants/year (3-yr avg. over 2007-2009)
                                      25
                                       
                                       
                                                                             90
 
Total annual cost 
                                       
                                       
                                       
 
                                                                         $8,828
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300  -  Local Government. May 2014 data.

	In Table 1, the cost to apply for the Great Start Award is estimated to be $358 per applicant. Based on the data on the number of applicants from the Agency's Indoor Air Quality (IAQ) project, 25 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 90 hours and total cost is $8,828. 

Table 2. Average Annual Respondent Burden and Cost Estimates - Leadership Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                    $86.43 
                                    $65.36 
                                    $40.14 



                                   per hour
                                   per hour
                                   per hour


Average time to read instructions
                                      1.0
                                      0.0
                                      0.0
                                                                            1.0
                                                                           $98 
Average time to plan activities
                                      1.5
                                      0.0
                                      0.0
                                                                            1.5
                                                                          $146 
Average time to gather information
                                      5.0
                                      0.0
                                      0.0
                                                                            5.0
                                                                          $488 
Average time to compile and review
                                     14.0
                                      0.0
                                      0.0
                                                                           14.0
                                                                        $1,366 
Average time to complete and submit paperwork
                                     14.0
                                      0.0
                                      0.0
                                                                           14.0
                                                                        $1,366 
Average time to store/maintain data
                                      2.0
                                      0.0
                                      0.0
                                                                            2.0
                                                                          $195 
Total per applicant
                                      38
                                      0.0
                                      0.0
                                                                             38
                                                                        $3,660 
# of applicants/year (3-yr avg. over 2007-2009)
                                      10
                                       
                                       
                                                                            375
 
Total annual cost 
                                       
                                       
                                       
 
                                                                        $36,602
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300  -  Local Government. May 2014 data.

      In Table 2, the cost to apply for the Leadership Award is estimated to be $3,660 per applicant. Based on the data on the number of applicants from the Agency's Indoor Air Quality (IAQ) project, 10 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 375 hours and total cost is $36,602.

Table 3. Average Annual Respondent Burden and Cost Estimates - Excellence Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                    $86.43 
                                    $65.36 
                                    $40.14 



                                   per hour
                                   per hour
                                   per hour


Average time to read instructions
                                      0.5
                                       
                                       
         0.5 
                                                                           $49 
Average time to plan activities
                                      2.0
                                      2.0
                                       
         4.0 
                                                                          $338 
Average time to gather information
                                      8.0
                                      8.0
                                       
        16.0 
                                                                        $1,353 
Average time to compile and review
                                      0.5
                                       
                                       
         0.5 
                                                                           $49 
Average time to complete and submit paperwork
                                      0.5
                                       
                                       
         0.5 
                                                                           $49 
Average time to store/maintain data
                                      0.5
                                       
                                       
         0.5 
                                                                           $49 
Total per applicant
                                      12
                                      10
                                       0
         22 
                                                                        $1,886 
# of applicants/year (3-yr avg. over 2007-2009)
                                       9
                                       
                                       
                                                                            198
 
Total annual cost 
                                                                              
                                       
                                       
 
                                                                        $16,976
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300  -  Local Government. May 2014 data.

      In Table 3, the cost to apply for the Excellence Award is estimated to be $1,886 per applicant. Based on the data on the number of applicants from the Agency's Indoor Air Quality (IAQ) project, 9 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 198 hours and total cost is $16,976.
      
      
      
      
Table 4. Average Annual Respondent Burden and Cost Estimates - Sustained Excellence Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                    $86.43 
                                    $65.36 
                                    $40.14 



                                   per hour
                                   per hour
                                   per hour


Average time to read instructions
                                      2.0
                                      0.0
                                      0.0
                                                                            2.0
                                                                          $195 
Average time to plan activities
                                      4.0
                                      4.0
                                      0.0
                                                                            8.0
                                                                          $676 
Average time to gather information
                                      4.0
                                      4.0
                                      0.0
                                                                            8.0
                                                                          $676 
Average time to compile and review
                                      4.0
                                      4.0
                                      0.0
                                                                            8.0
                                                                          $676 
Average time to complete and submit paperwork
                                      2.0
                                      2.0
                                      0.0
                                                                            4.0
                                                                          $338 
Average time to store/maintain data
                                      1.0
                                      0.0
                                      0.0
                                                                            1.0
                                                                           $98 
Total per applicant
                                      17
                                      14
                                       0
                                                                             31
                                                                        $2,660 
# of applicants/year (3-yr avg. over 2007-2009)
                                       4
                                       
                                       
                                                                            134
 
Total annual cost 
                                       
                                       
                                       
 
                                                                       $11,528 
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300  -  Local Government. May 2014 data.

      In Table 4, the cost to apply for the Sustained Excellence Award is estimated to be $2,660 per applicant. Based on the data on the number of applicants from the Agency's Indoor Air Quality (IAQ) project, 4 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 134 hours and total cost is $11,528.
      
Table 5. Average Annual Respondent Burden and Cost Estimates - Connector Award
                             Collection Activities
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                    $86.43 
                                    $65.36 
                                    $40.14 



                                   per hour
                                   per hour
                                   per hour


Average time to read instructions
                                      0.5
                                       
                                       
         0.5 
                                                                           $49 
Average time to plan activities
                                      0.5
                                       
                                       
         0.5 
                                                                           $49 
Average time to gather information
                                      2.0
                                       
                                       
         2.0 
                                                                          $195 
Average time to compile and review
                                      6.5
                                       
                                       
         6.5 
                                                                          $634 
Average time to complete and submit paperwork
                                      4.5
                                       
                                       
         4.5 
                                                                          $439 
Average time to store/maintain data
                                      0.4
                                       
                                       
         0.4 
                                                                           $39 
 Total per applicant
                                      14
                                       0
                                       0
         14 
                                                                        $1,406 
# of applicants/year (3-yr avg. over 2007-2009)
                                      5.0
                                       
                                       
                                                                             72
 
Total annual cost 
 
 
 
 
                                                                         $7,496
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300  -  Local Government. May 2014 data.

      In Table 5, the cost to apply for the Sustained Excellence Award is estimated to be $1,406 per applicant. Based on the data on the number of applicants from the Agency's Indoor Air Quality (IAQ) project, 5 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 72 hours and total cost is $7,496.

      6(c) Estimating Agency Burden and Cost
      
As in the case of respondents, the burden hour data from the EPA's Indoor Air Quality program is used to estimate the Agency burden and cost.

To determine Agency costs, the EPA used the Bureau of Labor Statistics estimates of labor rates for 2018 for the NAICS code for the Federal Executive Branch (NAICS 999100). The managerial labor rate is based on the Standard Occupational Classification (SOC) for management occupations; the technical labor rate is based on the SOC for life, physical and social science occupations; and the clerical labor rate is based on the SOC for office and administrative support occupations. The labor rates are fully loaded and include benefits and overhead. Detailed labor costs for agency labor is included in Attachment G.

	Tables 6 to 10 summarize the Agency's burden hours and costs for the different award categories.

Table 6. Average Annual Agency Burden and Cost Estimates - Great Start Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                   $132.14 
                                    $87.24 
                                    $48.84 



                                   per hour
                                   per hour
                                   per hour


Average time to read application and determine if applicant met requirements.
                                     0.00
                                     0.13
                                     0.00
                                                                           0.13
                                                                           $12 
Average time to accept/deny, create a form letter and print paper certificate. Division Director signature.
                                     0.05
                                     0.08
                                     0.00
                                                                           0.13
                                                                           $14 
Average time to create mailing label, track applicant in the awards tracking spreadsheet, mail certificate and letter to applicant.
                                     0.00
                                     0.03
                                     0.00
                                                                           0.03
                                                                            $3 
Total per applicant
                                     0.05
                                     0.25
                                     0.00
                                                                           0.30
                                                                           $28 
# of applicants/year (3-yr average over 2007-2009)
                                      25
                                       
                                       
                                                                              7
 
Total annual cost 
                                       
                                       
                                       
 
                                                                           $701
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100  -  Federal Government. May 2014 data.

In Table 6, the Agency cost per applicant ($28) is estimated first and multiplied by the average annual total number of applicants (25) to obtain an estimate ($701) of the total Agency cost for the Great Start award. The per-applicant Agency cost is obtained by summing the products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours for each labor type (0.05 hours of managerial labor, 0.25 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed by the Agency includes those applications that are not chosen for award as well.

Table 7. Average Annual Agency Burden and Cost Estimates - Leadership Award.
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                   $132.14 
                                    $87.24 
                                    $48.84 



                                   per hour
                                   per hour
                                   per hour


Average time to read application and determine if applicant met requirements.
                                      0.0
                                     0.17
                                      0.0
                                                                           0.17
                                                                           $15 
Average time to accept/deny, create a form letter and print paper certificate. Division Director signature.
                                     0.05
                                     0.08
                                      0.0
                                                                           0.13
                                                                           $14 
Average time to create mailing label, track applicant in the awards tracking spreadsheet, mail certificate and letter to applicant.
                                      0.0
                                     0.03
                                      0.0
                                                                           0.03
                                                                            $3 
Total per applicant
                                     0.05
                                     0.28
                                     0.00
                                                                           0.33
                                                                           $31 
# of applicants/year (3-yr average over 2007-2009)
                                      10
                                       
                                       
                                                                              3
 
Total annual cost 
 
 
 
 
                                                                           $313
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100  -  Federal Government. May 2014 data.

In Table 7, the Agency cost per applicant ($31) is estimated first and multiplied by the average annual total number of applicants (10) to obtain an estimate ($313) of the total Agency cost for the Leadership award. The per-applicant Agency cost is obtained by summing the products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours for each labor type (0.05 hours of managerial labor, 0.28 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed by the Agency includes those applications that are not chosen for award as well.

Table 8. Average Annual Agency Burden and Cost Estimates - Excellence Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                   $132.14 
                                    $87.24 
                                    $48.84 



                                   per hour
                                   per hour
                                   per hour


Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application.
                                     0.25
                                     0.25
                                     0.00
                                     0.50
                                     $55 
Provide regional staff PDFs of their applicants for their review and weigh-in as personnel that may have worked with districts specifically.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
In two weeks assimilate all score and hold half day consensus meeting to determine what schools districts are awards. During this meeting each applicant is discussed and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year's application if they were not chosen this year.
                                    0.00 
                                     5.00
                                     0.00
                                     5.00
                                     $436 
Provide a list of selected applicants to recognize; submit to EPA regions and senior management for approval.
                                     0.50
                                     0.50
                                     0.00
                                     1.00
                                     $110 
Conduct compliance scans on school districts and reconcile any issues that may arise.
                                    0.00 
                                     0.50
                                     0.00
                                     0.50
                                     $44 
Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application.
                                    0.00 
                                     0.50
                                     0.00
                                     0.50
                                     $44 
If there is an event designated for highlighting the award winning school districts and invitational travel involved, convey logistics to selected applicants.
                                     0.00
                                     0.17
                                     0.00
                                     0.17
                                     $15 
Using award winning applications create communications materials to showcase these award winning programs. Initiate comprehensive outreach communications plan. If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories.
                                     0.50
                                     1.00
                                    0.00 
                                     1.50
                                     $153 
Total per applicant
                                     1.25
                                     8.17
                                     0.00
                                                                           9.42
                                     $878 
# of applicants/year (3-yr average over 2007-2009)
                                       9
                                       
                                       
                                                                             85
 
Total annual cost 
 
 
 
 
                                    $7,899
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100  -  Federal Government. May 2014 data.

In Table 8, the Agency cost per applicant ($878) is estimated first and multiplied by the average annual total number of applicants (9) to obtain an estimate ($7,899) of the total Agency cost for the Excellence award. The per-applicant Agency cost is obtained by summing the products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours for each labor type (1.25 hours of managerial labor, 8.17 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed by the Agency includes those applications that are not chosen for award as well.

Table 9. Average Annual Agency Burden and Cost Estimates - Sustained Excellence Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                   $132.14 
                                    $87.24 
                                    $48.84 



                                   per hour
                                   per hour
                                   per hour


Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application.
                                     0.25
                                     0.25
                                     0.00
                                     0.50
                                     $55 
Provide regional staff PDFs of their applicants for their review and weigh-in as personnel that may have worked with a districts specifically.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
In two weeks assimilate all score and hold half day consensus meeting to determine what schools districts are awards. During this meeting each applicant is discussed and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year's application if they were not chosen this year.
                                     0.00
                                     5.00
                                     0.00
                                     5.00
                                     $436 
Provide a list of selected applicants to recognize; submit to EPA regions and senior management for approval.
                                     0.50
                                     0.50
                                     0.00
                                     1.00
                                     $110 
Conduct compliance scans on school districts and reconcile any issues that may arise.
                                     0.00
                                     0.50
                                     0.00
                                     0.50
                                     $44 
Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application.
                                     0.00
                                     0.50
                                     0.00
                                     0.50
                                     $44 
If there is an event for highlighting the award winning school districts and invitational travel involved, convey logistics to selected applicants.
                                     0.00
                                     0.17
                                     0.00
                                     0.17
                                     $15 
Using award winning applications create communications materials to showcase these award winning programs. Initiate comprehensive outreach communications plan). If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories.
                                     0.50
                                     1.00
                                     0.00
                                     1.50
                                     $153 
Total per applicant
                                     1.25
                                     8.17
                                     0.00
                                                                           9.42
                                     $878 
# of applicants/year (3-yr average over 2007-2009)
                                       4
                                       
                                       
                                                                             41
 
Total annual cost 
                                       
                                       
                                       
 
                                    $3,803
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100  -  Federal Government. May 2014 data.

In Table 9, the Agency cost per applicant ($878) is estimated first and multiplied by the average annual total number of applicants (4) to obtain an estimate ($3,803) of the total Agency cost for the Sustained Excellence award. The per-applicant Agency cost is obtained by summing the products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours for each labor type (1.25 hours of managerial labor, 8.17 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed by the Agency includes those applications that are not chosen for award as well.

Table 10. Average Annual Agency Burden and Cost Estimates - Connector Award
                            Collection Activities 
                                 Burden Hours
                                     Total

                                  Management
                                   Technical
                                   Clerical
                                     Hours
                                     Costs

                                   $132.14 
                                    $87.24 
                                    $48.84 



                                   per hour
                                   per hour
                                   per hour


Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application.
                                     0.25
                                     0.25
                                     0.00
                                     0.50
                                     $55 
Provide regional staff PDFs of their applicants for their review and weigh-in as personnel that may have worked with a districts specifically.
                                     0.00
                                     0.08
                                     0.00
                                     0.08
                                      $7 
In two weeks assimilate all score and hold half day consensus meeting to determine what schools districts are awards. During this meeting each applicant is discussed and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year's application if they were not chosen this year.
                                     0.00
                                     4.50
                                     0.00
                                     4.50
                                     $393 
Provide list of selected applicants to recognize to regions and senior management for approval.
                                     0.50
                                     0.50
                                     0.00
                                     1.00
                                     $110 
Conduct compliance scans on school districts and reconcile any issues that may arise.
                                     0.00
                                     0.50
                                     0.00
                                     0.50
                                     $44 
Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application.
                                     0.00
                                     0.50
                                     0.00
                                     0.50
                                     $44 
If there is an event for highlighting the award winning school districts and invitational travel involved, convey logistics to selected applicants.
                                     0.00
                                     0.17
                                     0.00
                                     0.17
                                     $15 
Using award winning applications create communications materials to showcase these award winning programs. Initiate comprehensive outreach communications plan. If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories.
                                     0.50
                                     1.00
                                     0.00
                                     1.50
                                     $153 
Total per applicant
                                     1.25
                                     7.67
                                     0.00
                                                                           8.92
                                     $834 
# of applicants/year (3-yr average over 2007-2009)
                                       5
                                       
                                       
                                                                             45
 
Total annual cost 
 
 
 
 
                                    $4,170
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100  -  Federal Government. May 2014 data.

In Table 10, the Agency cost per applicant ($834) is estimated first and multiplied by the average annual total number of applicants (5) to obtain an estimate ($4,170) of the total Agency cost for the Connector award. The per-applicant Agency cost is obtained by summing the products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours for each labor type (1.25 hours of managerial labor, 7.67 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed by the Agency includes those applications that are not chosen for award as well.

 6(d) Bottom Line Burden Hours and Costs
 
 In this section, the total respondent and Agency burden hours and costs over all award types are summarized (Table 11).
 
Table 11: Total Annual Burden and Cost Summary

                              Total burden hours
                                  Total cost
Respondents
                                                                            875
 $    81,430 
  Great Start Award
                                                                             90
 $     8,828 
  Leadership Award
                                                                            375
 $    36,602 
  Excellence Award
                                                                            198
 $    16,976 
  Sustained Excellence Award
                                                                            124
 $    11,528 
  Connector Award
                                                                             72
 $     7,028 
Agency
                                                                            181
 $    16,886 
  Great Start Award
                                                                              7
 $      701 
  Leadership Award
                                                                              3
 $      313 
  Excellence Award
                                                                             85
 $     7,899 
  Sustained Excellence Award
                                                                             41
 $     3,803 
  Connector Award
                                                                             45
 $     4,170 
Source: Tables 1-10 in this document.

      For the respondents across all categories of awards, the total annual cost of applying for the School IPM recognition program is estimated at 875 burden hours and $81,430. These costs consist of preparing, submitting, and recordkeeping of applications. For the EPA, the total cost of administering this recognition program is estimated at 181 hours and $16,886 annually, most of which is the cost of reviewing the applications for awards (Table 11).
      
      6(e) Reasons for Changes in Burden

The costs associated with information collection increased for both the respondents and the Agency due to the increases in the wage rates since the creation of the ICR.  We note that in the creation of the ICR, the benefits (46.3 percent of the unloaded wage) was mistakenly excluded from the calculation of the fully loaded wages for the Agency, resulting in the latter being much lower than the actual values.  This led to the cost increase for the Agency disproportionately larger than the cost increase for the respondents.     
      
      6(f) Burden Statement
      
	The annual respondent burden for this ICR is estimated to average 875 hours. This includes average times to carry out activities in Tables 1  -  5 in the section 6(b) above. 

      The Agency has established a public docket for this ICR under Docket ID No. EPA-HQ-OPP-2019-0356, which is available for online viewing at http://www.regulations.gov, or in person viewing at the EPA Docket Center Public Reading Room, EPA West Building, Room 3334, 1301 Constitution Avenue, NW, Washington, DC 20004.  The EPA Docket Center is open from 8:30 a.m. to 4 p.m., Monday through Friday, excluding federal holidays.  The docket telephone number is (202) 566-1744. 
      
      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. Submit your comments, referencing Docket ID No. EPA-HQ- OPP-2019-0356, to EPA as follows: 
      :: To EPA online using http://www.regulations.gov (our preferred method),) or by mail to: EPA Docket Center, Environmental Protection Agency Docket Center (EPA/DC), Mail Code 28221T, 1200 Pennsylvania Ave., NW., Washington, DC 20460
	This address is for your comments - do not submit the information requested in this ICR to these addresses.

7. 	Attachments List: Supporting Statement (EPA-HQ-OPP-2019-0356)
	All the attachments listed below can be found in the docket for this ICR or via the hyperlink provided for the source documentation. The docket is accessible electronically through http://www.regulations.gov using the docket identifier EPA-HQ-OPP-2019-0356.

                  ATTACHMENT A:	42 UCS 133 Pollution Prevention Act of 1990, available at http://www.gpo.gov/fdsys/pkg/USCODE-2009-title42/pdf/USCODE-2009-title42-chap133.pdf
                  
                  ATTACHMENT B:	7 USC 136a, Registration of Pesticides, available at 
                  http://www.gpo.gov/fdsys/pkg/USCODE-2010-title7/pdf/USCODE-2010-title7-chap6-subchapII-sec136a.pdf

                  ATTACHMENT C:	7 USC 136r - 1, Integrated Pest Management, available at http://www.gpo.gov/fdsys/pkg/USCODE-2010-title7/pdf/USCODE-2010-title7- chap6-subchapII-sec136r-1.pdf.

                  ATTACHMENT D:	[Reserved for consultation]

                  ATTACHMENT E: 	SIPM Award Program Conditions and Criteria file:///C:/Users/csiu/Desktop/ICR/IPM%202019/2019%20Documents/2531.01_ss_Attachment%20G%20-%20Program%20Conditions%20and%20Criteria%20-%20SIPM.pdf

                  ATTACHMENT F:	SIPM Award Program Application Guide and Forms

ATTACHMENT G:	Wage Rates Worksheet
