Stormwater 
Construction
NOI
ICR
June
2006
INFORMATION
COLLECTION
REQUEST:
NOTICE
OF
INTENT
FOR
STORMWATER
DISCHARGES
ASSOCIATED
WITH
CONSTRUCTION
ACTIVITY
UNDER
A
NPDES
GENERAL
PERMIT
June
2006
Prepared
for
U.
S.
Environmental
Protection
Agency
Office
of
Wastewater
Management
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
EPA
Contract
Number
EP­
C­
05­
046
EPA
Work
Assignment
Number
0­
24
Stormwater 
Construction
NOI
ICR
June
2006
This
page
intentionally
left
blank
Stormwater 
Construction
NOI
ICR
June
2006
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
.....................................................
1
1(
a).
TITLE
OF
THE
INFORMATION
COLLECTION..................................................................
1
1(
b).
SHORT
CHARACTERIZATION/
ABSTRACT...................................................................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION............................................................................
2
2(
a).
NEED/
AUTHORITY
OF
THE
COLLECTION
......................................................................
2
2(
b).
PRACTICAL
UTILITY/
USERS
OF
THE
DATA...................................................................
3
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA................
4
3(
a).
NONDUPLICATION..............................................................................................................
4
3(
b).
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
............................
4
3(
c).
CONSULTATIONS................................................................................................................
4
3(
d).
EFFECTS
OF
LESS
FREQUENT
COLLECTION..................................................................
5
3(
e).
GENERAL
GUIDELINES......................................................................................................
5
3(
f).
CONFIDENTIALITY.............................................................................................................
5
3(
g).
SENSITIVE
QUESTIONS......................................................................................................
5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
..............................................
5
4(
a).
RESPONDENTS/
SIC
CODES................................................................................................
5
4(
b).
INFORMATION
REQUESTED
.............................................................................................
6
5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT......................................................
8
5(
a).
AGENCY
ACTIVITIES
.........................................................................................................
8
5(
b).
COLLECTION
METHODOLOGY
AND
MANAGEMENT...................................................
9
5(
c).
SMALL
ENTITY
FLEXIBILITY
...........................................................................................
9
5(
d).
COLLECTION
SCHEDULE
................................................................................................
10
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION.........................................
10
6(
a)
ESTIMATING
RESPONDENT
BURDEN...........................................................................
10
6(
b).
ESTIMATING
RESPONDENT
COST
.................................................................................
13
6(
c).
ESTIMATING
AGENCY
BURDEN
AND
COST
................................................................
15
6(
d).
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS..
16
6(
e).
BOTTOM
LINE
BURDEN
HOURS
AND
COST
TABLES
.................................................
19
6(
f).
REASONS
FOR
CHANGE
IN
BURDEN
AND
COST.........................................................
20
6(
g).
BURDEN
STATEMENT......................................................................................................
20
ATTACHMENTS
ATTACHMENT
A.
Summary
of
Response
to
National
Association
of
Homebuilders
(
NAHB)
Comments
on
Draft
ICR
ATTACHMENT
B.
Calculation
of
National
Estimate
of
Construction
NOIs
(
2004)
Stormwater 
Construction
NOI
ICR
June
2006
LIST
OF
TABLES
Table
1.
Burden
on
Each
Respondent
................................................................................................
12
Table
2.
Burden
on
NPDES­
authorized
States...................................................................................
12
Table
3.
Costs
to
Each
Respondent
...................................................................................................
14
Table
4.
Costs
to
NPDES­
Authorized
States.....................................................................................
15
Table
5.
Agency
Costs
......................................................................................................................
15
Table
6.
Relative
Number
of
Respondents
.........................................................................................
16
Table
7.
Total
Respondent
Burden
and
Cost
Estimates......................................................................
17
Table
8.
Total
NPDES­
Authorized
State
Burden
and
Costs...............................................................
18
Table
9.
Annual
Respondent
Burden
and
Cost
Summary
...................................................................
19
Table
10.
Total
Agency
Burden
and
Costs...........................................................................................
19
Table
11.
Change
in
Annual
Burden
....................................................................................................
20
Table
12.
Burden
Statement
................................................................................................................
21
Stormwater 
Construction
NOI
ICR
June
2006
Page
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a).
TITLE
OF
THE
INFORMATION
COLLECTION
Title:
Notice
of
Intent
for
Stormwater
Discharges
Associated
with
Construction
Activity
Under
a
NPDES
General
Permit
EPA
ICR
No:
1842.05
OMB
Control
No:
2040­
0188
1(
b).
SHORT
CHARACTERIZATION/
ABSTRACT
This
Information
Collection
Request
(
ICR)
renews
OMB
Number
2040­
0188
(
Notice
of
Intent
for
Stormwater
Discharges
Associated
with
Construction
Activity).

EPA's
National
Pollutant
Discharge
Elimination
System
(
NPDES)
Permitting
Program,
as
authorized
by
the
Clean
Water
Act
(
CWA),
establishes
regulations
for
the
discharge
of
pollutants
or
combinations
of
pollutants
to
waters
of
the
United
States,
including
discharges
of
stormwater.
Phase
I
of
the
stormwater
program,
promulgated
on
November
16,
1990
(
55
FR
47990),
applied
to
eleven
categories
of
stormwater
discharges
associated
with
industrial
activity
(
including
construction
activities
disturbing
five
acres
or
more)
and
to
discharges
from
large
and
medium
municipal
separate
storm
sewer
systems.
Phase
II
of
the
regulatory
development
effort,
promulgated
on
December
8,
1999
(
64
FR
68722),
regulates
stormwater
discharges
from
small
municipal
separate
storm
sewer
systems
and
construction
sites
with
activities
disturbing
one
to
five
acres
of
land.
Together,
Phase
I
and
Phase
II
of
the
NPDES
Stormwater
Program
now
regulate
all
construction
activities
of
one
acre
or
more.
However,
this
ICR
only
covers
the
burden
on
construction
sites
of
five
or
more
acres,
as
small
construction
activities
are
addressed
in
the
Stormwater
Phase
II
ICR
(
OMB
Control
Number
2040­
0211,
EPA
ICR
No.
1820.03).

The
primary
permitting
mechanism
for
construction
site
operators
is
the
Construction
General
Permit
(
CGP),
issued
by
EPA
or
a
state
authorized
to
administer
the
NPDES
Program.
To
obtain
coverage
under
the
CGP,
a
construction
site
operator
must
submit
a
Notice
of
Intent
(
NOI)
to
the
permitting
authority.
Upon
submission
of
a
complete
NOI,
operators
meeting
the
CGP
eligibility
requirements
are
authorized
to
discharge
at
some
pre­
determined
point
in
time
(
e.
g.,
7­
days
after
submission
of
a
complete
NOI).

One
of
the
main
components
of
the
CGP
is
the
requirement
for
permittees
to
develop
a
Stormwater
Pollution
Prevention
Plan
(
SWPPP).
The
SWPPP
serves
as
the
primary
condition
of
the
permit
of
which
facilities
must
comply.
Although
the
SWPPP
is
not
typically
submitted
to
the
permitting
authority,
burden
and
costs
associated
with
its
preparation
is
included
in
this
ICR
because
it
must
be
prepared
at
the
time
of
permit
application
(
i.
e.,
when
the
NOI
is
submitted).
The
permitting
authority
is
not
required
to
review
and
approve
these
plans;
rather,
these
are
to
be
implemented
by
the
permitted
facility,
and
generally
must
be
available
for
review
as
requested.

The
information
collection
and
reporting
activities
covered
in
this
ICR
include
only
those
activities
related
to
completing
and
submitting
an
NOI
form,
developing
a
SWPPP,
and
conducting
routine
biweekly
inspections.
Other
activities,
such
as
monitoring
or
submission
of
a
Notice
of
Termination
(
NOT)
upon
the
cessation
of
the
stormwater
discharge
associated
with
construction
activity,
are
addressed
in
Stormwater 
Construction
NOI
ICR
June
2006
Page
2
other
NPDES
ICRs
(
i.
e.,
monitoring
burden
is
addressed
in
the
"
DMR
ICR"
(
OMB
Control
No.
2040­
0004)
and
NOT
burden
is
addressed
in
the
"
NPDES
Applications
ICR"
(
OMB
Control
No.
2040­
0086).

It
is
expected
that
respondents
will
submit
information
in
hard
copy
or
electronic
form.
The
information
will
be
entered
into
a
database
and
any
original
document
filed.
The
information
is
submitted
by
the
respondents
directly
to
each
NPDES­
authorized
state
or
Territory,
or
to
EPA
in
areas
where
EPA
is
the
NPDES
permitting
authority.
In
2003
EPA
launched
an
electronic,
completely
paperless,
online
permit
application
system
(
eNOI)
to
be
used
in
areas
where
EPA
is
the
NPDES
permitting
authority.
In
2005
approximately
70%
of
applications
from
these
areas
were
filed
electronically.
Several
authorized
states
have
also
developed
and
are
implementing
similar
electronic
systems
while
many
other
states
are
in
various
stages
of
planning
and
development
of
these
electronic
systems.
EPA
estimates
a
similar
burden
for
operators
to
prepare,
submit,
and
retain
this
information.
The
benefit,
however,
is
that
operators
are
able
to
obtain
authorization
to
discharge
much
more
quickly
using
the
electronic
system
for
three
primary
reasons:
(
1)
an
electronic
submission
arrives
at
EPA
instantaneously
unlike
paper
forms
that
must
come
through
the
mail
system;
(
2)
handwritten
forms
submitted
on
paper
are
often
difficult
to
read;
and
(
3)
the
electronic
system
incorporates
certain
data
check
functions
that
prevent
operators
from
submitting
incomplete
forms
or
certain
incorrect
information.

The
calculations
performed
for
this
ICR
cover
the
burden
and
costs
for
the
Agency
(
EPA),
NPDESauthorized
states,
and
operators
of
construction
sites
of
five
acres
or
more.
This
ICR
estimates
a
burden
of
8,098,958
hours
annually
for
157,500
respondents,
excluding
state
respondents.
Burden
for
the
state
respondents
is
148,680
hours
annually.
Agency
burden
is
17,780
hours.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a).
NEED/
AUTHORITY
OF
THE
COLLECTION
The
purpose
of
the
CWA
is
to
restore
and
maintain
the
chemical,
physical
and
biological
integrity
of
the
nation's
waters.
To
meet
that
end,
the
CWA
established
the
NPDES
program
to
regulate
the
discharge
of
any
pollutant
or
combination
of
pollutants
from
point
sources
into
waters
of
the
United
States.

EPA
and
NPDES
permitting
authorities
issue
permits
to
discharge
stormwater
from
construction
sites
under
the
NPDES
stormwater
program
and
need
the
information
collection
in
order
to:

 
Ensure
coverage
of
construction
sites
under
an
NPDES
general
permit
for
construction
activity,
 
Identify
the
location
of
the
construction
activity,
 
Identify
the
responsible
party
or
parties
on
site,
 
Identify
the
need
to
issue
an
individual
permit
in
cases
where
a
general
permit
will
not
adequately
meet
the
objectives
of
the
CWA,
 
Provide
a
data
source
from
which
future
NPDES
stormwater
general
permits
will
be
developed
with
appropriate
requirements
and
permit
conditions
that
meet
the
objectives
of
the
CWA,
 
Determine
compliance
with
general
permits
and
no
exposure
requirements,
 
Compile
statistics
on
national
permit
issuance,
backlog,
and
compliance
rates,
 
Evaluate
nationwide
or
area­
wide
water
quality,
 
Ensure
consistency
in
stormwater
permitting,
 
Prioritize
permit
issuance
activities,
Stormwater 
Construction
NOI
ICR
June
2006
Page
3
 
Develop
appropriate
policy
and
budgets,
 
Perform
cost­
benefit
analyses,
 
Respond
to
complaints
from
the
public
of
possible
non­
compliance
with
permit
conditions,
and
 
Respond
to
Congressional
and
public
inquiries.

CWA
Section
402(
a),
as
amended,
authorizes
the
EPA
Administrator
to
issue
permits
for
the
discharge
of
pollutants
if
those
discharges
meet
all
applicable
requirements
of
CWA
Sections
301,
302,
306,
307,
308,
and
403,
or
any
conditions
the
Administrator
determines
are
necessary
to
carry
out
the
provisions
and
objectives
of
the
CWA.
The
authorization
to
issue
permits
for
stormwater
discharges
in
particular
is
provided
at
Section
402(
p).
NPDES
stormwater
regulations
are
found
in
40
CFR
§
122.26.

2(
b).
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
Generally,
construction
general
permit
applicants
submit
similar
basic
information:
the
NOI
for
construction
activities.
The
data
contained
in
the
NOI
can
be
split
into
two
types:
locational
information
details
(
e.
g.,
name,
location,
description
of
the
construction
activity),
and
site
characteristics
(
e.
g.,
site
size,
estimated
construction
start
and
end
dates).

Permitting
authorities
use
locational
information
to
uniquely
identify
the
construction
activities
requesting
coverage
under
the
CGP.

Permitting
authorities
gather
site
characteristics
from
the
CGP
NOI
to
use
in
estimating
environmental
impacts.
Permitting
authorities
can
also
use
the
data
from
the
CGP
NOI,
as
well
as
from
the
SWPPP,
as
part
of
a
compliance
evaluation
to
ensure
that
the
permittee
adheres
to
conditions
as
stated
in
the
CGP
and
SWPPP.

For
construction
sites
permitted
by
EPA,
the
agency
stores
all
information
submitted
on
the
NOI
in
a
database
housed
at
the
NOI
Processing
Center.
The
NOI
database
provides
an
inventory
of
construction
sites
permitted
by
EPA.
EPA
uses
the
information
contained
in
the
NOI
database
to
develop
reports
on
permit
issuance,
backlog,
and
compliance
rates.
EPA
also
uses
the
information
to
respond
to
public
and
Congressional
inquiries,
develop
and
guide
its
policies,
formulate
its
budgets,
and
manage
its
programs
to
ensure
national
consistency
in
permitting.
The
database
serves
as
a
source
of
general
information
and
a
mailing
list.
This
provides
EPA
with
a
comprehensive
recordkeeping
system
on
permit
issuance
and
the
overall
implementation
of
the
NPDES
permitting
program.
For
the
most
part,
States
and
territories
authorized
to
implement
the
NPDES
permitting
program
manage
and
use
the
data
in
a
similar
fashion
to
EPA
and
as
such
incur
similar
types
of
burden.

Facilities
must
reapply
for
coverage
under
the
CGP
at
least
every
five
years.
The
re­
application
process
is
the
only
mechanism
for
obtaining
up­
to­
date
information
on
discharges.

To
meet
its
obligations
under
the
Clean
Water
Act,
National
Historic
Preservation
Act
(
NHPA),
and
Endangered
Species
Act
(
ESA),
and
to
promote
those
Acts'
goals,
EPA
is
seeking
to
ensure
that
discharges
covered
under
the
CGP
are
protective
of
historic
properties,
endangered
and
threatened
species,
and
critical
habitat.
Applicants
for
coverage
under
the
CGP
are
required
to
assess
the
impacts
of
their
stormwater
discharges
on
historic
properties,
federally­
listed
endangered
and
threatened
species,
and
designated
critical
habitat.
Information
from
this
assessment
is
provided
in
the
NOI
and
therefore
Stormwater 
Construction
NOI
ICR
June
2006
Page
4
contained
in
the
NOI
database.
NPDES­
authorized
states
are
not
required
by
EPA
to
meet
the
ESA
and
NHPA
obligations
and
as
such,
no
ESA
or
NHPA
burden
is
associated
with
State
(
or
Territory)
issued
permits.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a).
NONDUPLICATION
EPA
has
examined
all
other
reporting
requirements
contained
in
the
Clean
Water
Act
and
40
CFR
Parts
122,
123,
124,
125,
403,
501,
and
503.
The
Agency
also
has
consulted
the
following
sources
of
information
to
determine
if
similar
or
duplicate
information
is
available
elsewhere:

 
the
EPA
Information
Systems
Inventory;
 
the
EPA
Inventory
of
Information
Collection
Requests;
and
 
the
Federal
Information
Locator
System.

Examination
of
these
databases
revealed
no
duplicate
requirements.
EPA
has
concluded
that
it
has
no
other
way
to
obtain
the
information
addressed
in
this
ICR.

3(
b).
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
This
ICR
was
published
in
the
Federal
Register
on
March
7,
2006.
The
notice
included
a
request
for
comments
on
the
content
and
impact
of
the
proposed
rule
on
the
regulated
community.
EPA
received
one
set
of
comments
on
this
ICR,
specifically,
from
the
National
Association
of
Homebuilders
(
NAHB).
In
general,
NAHB
comments
that:

­
EPA
incorrectly
used
estimates
based
on
data
from
2003­
2006
rather
than
from
the
period
to
be
covered
by
this
ICR,
namely
2006­
2008,
­
EPA
underestimate
the
universe
of
covered
sites,
and
­
EPA
underestimates
costs
for
completion
of
NOIs,
SWPPPs,
and
NOTs.

EPA's
response
to
NAHB's
comments
are
addressed
by
this
ICR
and
summarized
in
Attachment
A
of
this
supporting
statement.

3(
c).
CONSULTATIONS
EPA
finalized
the
requirements
addressed
in
this
ICR
after
receiving
comments
from
the
public
and
the
regulated
community.
In
addition,
the
Agency
actively
solicits
comments
when
it
develops
its
regulations.
EPA
holds
public
meetings,
assembles
workgroups
of
experts
and
potential
respondents,
and
consults
government
agencies,
such
as
OMB,
before
finalizing
requirements.

In
developing
regulations
for
stormwater
dischargers,
EPA
met
with
potential
respondents,
industry
and
trade
organizations,
environmental
groups,
and
municipal,
state,
and
public
works
associations.
EPA
made
several
changes
to
its
regulations
based
on
comments
presented
at
meetings.
For
example,
at
a
meeting
in
1987,
the
National
Homebuilders
Association
pointed
out
that
sampling
data
for
construction
sites
would
be
extremely
variable
because
construction
activities
are
continually
changing.
Based
on
this
comment,
EPA's
CGP
does
not
include
monitoring
requirements.
EPA
expects
that
adequately
Stormwater 
Construction
NOI
ICR
June
2006
Page
5
implemented
BMPs
will
be
protective
of
water
quality.
Additionally,
several
data
fields
on
the
CGP
NOI
were
included
per
comments
from
the
Urban
Wet
Weather
Flows
Federal
Advisory
Committee.

3(
d).
EFFECTS
OF
LESS
FREQUENT
COLLECTION
The
CWA
prohibits
NPDES
permits
from
having
terms
longer
than
five
years.
It
is
a
statutory
requirement
that
permitted
entities
reapply
for
coverage
under
NPDES
stormwater
permits
before
their
existing
permits
expire,
generally
once
every
five
years.
Therefore,
less
frequent
collection
of
information
could
be
a
violation
of
the
CWA.

3(
e).
GENERAL
GUIDELINES
This
information
collection
complies
with
PRA
guidelines
[
5
CFR
1320.5(
d)(
2)].
Requests
for
supplemental
information
for
the
purposes
of
emergency
response
or
enforcement
activities
are
exempt
from
the
PRA
requirements.

3(
f).
CONFIDENTIALITY
Permit
applications
may
contain
confidential
business
information.
If
this
is
the
case,
the
respondent
may
request
that
such
information
be
treated
as
confidential.
All
confidential
data
will
be
handled
in
accordance
with
40
CFR
§
122.7,
40
CFR
Part
2,
and
EPA's
Security
Manual
Part
III,
Chapter
9,
dated
August
9,
1976.
However,
CWA
§
308(
b)
specifically
states
that
effluent
data
may
not
be
treated
as
confidential.

3(
g).
SENSITIVE
QUESTIONS
Reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a).
RESPONDENTS/
SIC
CODES
Entities
that
wish
to
apply
for
coverage
of
stormwater
discharges
related
to
large
construction
activity
under
the
EPA
NPDES
CGP
must
complete
and
submit
an
NOI,
develop
and
maintain
a
SWPPP,
and
perform
routine
site
inspections.
Construction
activities
that
result
in
a
disturbance
of
less
than
5
acres
of
total
land
area
are
also
required
to
submit
an
NOI
and
develop
a
SWPPP,
but
the
burden
on
those
respondents
is
accounted
for
in
the
Stormwater
Phase
II
ICR
(
OMB
Control
Number
2040­
0211,
EPA
ICR
Number
1820.03).
Typically,
construction
site
operators
are
required
to
submit
one
NOI
for
their
role
in
construction
activities
that
are
part
of
a
common
plan
of
development
or
sale
that
in
total
disturbs
more
than
five
acres
(
e.
g.,
an
operator
disturbing
100
acres
as
part
of
a
common
plan
would
submit
one
NOI
while
an
operator
disturbing
3
acres
as
part
of
a
larger
common
plan
of
development
which
disturbs
five
acres
or
more
would
also
be
required
to
submit
one
NOI
for
their
activities).
Operators
working
on
multiple
common
plans
generally
are
required
to
submit
NOIs
for
their
role
in
each
common
plan.

The
largest
portion
of
construction
activities
will
be
carried
out
by
builders,
local
developers,
and
contractors.
Relevant
SIC
codes
include
the
following:
1531,
1541,
1542,
1611,
1622,
1623,
1629,
and
1764.
Stormwater 
Construction
NOI
ICR
June
2006
Page
6
At
present,
45
states
and
one
Territory
have
received
authorization
from
EPA
to
act
as
the
NPDES
permitting
authority
in
those
respective
areas.
Because
they
incur
burden
in
administering
the
program,
permitting
authorities
are
considered
respondents
for
the
purposes
of
this
ICR.

4(
b).
INFORMATION
REQUESTED
This
section
presents
the
data
items,
including
recordkeeping
requirements,
and
required
respondent
activities
involved
in
preparing
and
submitting
those
data
items.

Data
Items,
Including
Recordkeeping
Requirements
Notice
of
Intent
Construction
site
operators
are
required
to
complete
an
NOI
or
an
individual
application
and
develop
and
implement
a
stormwater
pollution
prevention
plan
that
includes
proper
erosion
and
sediment
controls.

Stormwater
discharges
associated
with
construction
activity
exist
in
vast
numbers.
EPA
has
recognized
that
the
burden
to
issue
individual
permits
to
each
discharger
would
be
prohibitive.
EPA
currently
uses,
and
expects
to
continue
and
encourage
the
use
of,
a
general
permit
option
and
standardized
application
forms
for
construction
activities.
EPA
expects
that
all
operators
of
construction
sites
of
five
or
more
acres
will
submit
a
Notice
of
Intent
(
NOI)
for
coverage
under
a
general
permit
consistent
with
the
requirements
of
40
CFR
§
122.28(
b)(
2).

Although
the
NPDES
regulations
allow
the
option
of
submitting
individual
applications
instead
of
an
NOI,
EPA
does
not
anticipate
any
operator
will
choose
this
option.
Because
EPA
expects
no
respondents
for
this
activity,
the
burden
and
costs
associated
with
the
preparation
and
submittal
of
an
individual
application
are
not
necessary
for
this
ICR.
However,
the
information
required
for
an
individual
application,
Forms
1
and
2F,
was
estimated
in
the
ICR
that
was
developed
to
assess
the
information
collection
burden
of
the
stormwater
regulations
as
promulgated
in
1990.
Federal
regulations
require,
at
a
minimum,
that
applicants
provide
the
following
information
in
their
NOI:

 
the
legal
name
and
address
of
the
operator,
 
the
facility
name
and
address,
 
the
type
of
facility
or
discharges,
and
 
the
name
of
the
receiving
water(
s).

When
NPDES
permitting
authorities
issue
general
permits,
they
may
require
additional
information
to
be
submitted
with
the
NOI
that
is
deemed
necessary
to
ensure
that
facilities
covered
under
the
permits
comply
with
the
objectives
and
provisions
of
the
CWA.
However,
NPDES
permitting
authorities
typically
use
general
permits
to
minimize
the
burden
associated
with
reviewing
application
information.
Consequently,
applicants
are
usually
required
to
provide
simple,
easily
obtainable
data
in
their
NOIs.

EPA
has
developed
an
NOI
form
that
applies
to
both
Phase
I
and
Phase
II
of
the
construction
stormwater
program.
Entities
within
the
construction
industry
and
their
industry
organizations
are
familiar
with
an
NOI
as
a
means
of
seeking
coverage
under
Phase
I
of
the
stormwater
program.

Generally,
the
following
type
of
information
is
requested
from
Phase
I
construction
operators:
Stormwater 
Construction
NOI
ICR
June
2006
Page
7
 
Name,
address,
and
phone
number
of
the
construction
site
operator,
 
Ownership
class
of
the
construction
site
(
i.
e.,
Federal,
state,
public,
or
private),
 
Name
and
location
of
the
construction
site,
 
Whether
the
facility
is
located
on
Indian
Lands,
 
Latitude
and
longitude
of
the
construction
site,
 
Whether
a
SWPPP
has
been
developed,
 
Address
of
the
location
of
the
SWPPP,
 
Estimated
construction
start
date
and
completion
date,
 
Estimated
land
area
to
be
disturbed,
 
Whether
any
endangered
or
threatened
species
are
in
proximity
to
stormwater
discharges
or
best
management
practices
(
BMPs)
to
be
constructed
for
the
discharges,
and
 
Whether
any
historic
properties
are
in
proximity
to
stormwater
discharges
or
BMPs
to
be
constructed
for
the
discharge.

Stormwater
Pollution
Prevention
Plan
(
SWPPP)
As
an
NPDES
construction
permit
condition,
EPA
requires
operators
of
construction
sites
to
develop
a
SWPPP.
A
SWPPP
is
typically
kept
on
site
and
not
submitted.
The
development
of
a
SWPPP
is
unique
to
each
construction
site
even
though
it
is
based
on
common
required
elements.
The
SWPPP
typically
includes:

 
a
site
plan,
including
proper
erosion
and
sediment
controls
and
stormwater
management,
 
a
pollution
prevention
site
map,
and
 
an
inspection
and
maintenance
plan.

EPA
requires
SWPPPs
consistent
with
the
best
management
practices
requirements
specified
in
40
CFR
§
122.44(
k)(
2).

The
CGP
also
requires
that
operators
perform
routine
site
inspections
to
assess
the
effectiveness
of
the
SWPPP
and
associated
BMPs
and
maintain
records
of
those
inspections
on­
site
as
part
of
the
SWPPP
documentation.

Record
Maintenance
The
CGP
requires
that
the
SWPPP
and
copies
of
the
NOI
(
or
other
permit
application)
are
kept
on­
site.
The
SWPPP
also
requires
the
construction
site
operator
to
keep
records
of
bi­
weekly
inspections
of
BMPs
used
for
erosion
and
sediment
control.
These
requirements
are
consistent
with
the
requirements
of
§
§
122.41(
h)(
j)
&
(
l).

Respondent
Activities
Respondent
activities
can
vary
depending
on
the
characteristics
of
the
applicant
and
of
the
particular
authorized
state
or
Territory.
This
ICR
explains
these
activities
for
each
set
of
application
requirements
(
see
Section
6
of
this
ICR,
"
Estimating
Respondent
Burden").
Respondent
activities
are
summarized
below
for
both
permittees
and
NPDES­
authorized
states
and
territories.
Stormwater 
Construction
NOI
ICR
June
2006
Page
8
Construction
Permittees
Any
particular
construction
respondent
preparing
and
submitting
an
NOI
may
engage
in
the
following
types
of
activities:

 
Preparing
basic
information
for
the
NOI.
This
includes
reading
and
reviewing
instructions
and
regulations
for
the
current
CGP
NOI,
reviewing
guidance
materials,
gathering
general
information,
typing/
completing
the
CGP
NOI
form,
submitting
the
form,
and
maintaining
a
record
of
the
NOI.
 
Preparing
basic
information
for
the
SWPPP.
This
includes
reading
and
reviewing
instructions
and
regulations
for
SWPPP
requirements,
gathering
general
information,
and
developing
a
plan
for
SWPPP
preparation.
 
Generating
detailed
information
for
the
SWPPP.
Detailed
information
may
include
topographic
maps,
data
on
effluent
characteristics,
management
programs,
financial
estimates,
engineering
data,
or
other
information
required
to
be
included
in
SWPPPs.
 
Performing
routine
inspections.
The
CGP
requires
operators
to
perform
routine
site
inspections
to
assess
the
effectiveness
of
the
SWPPP
and
associated
BMPS
in
protecting
water
quality.
 
Maintaining
records.
The
CGP
requires
that
the
permittee
keep
records
for
at
least
three
years
from
the
date
that
the
site
is
finally
stabilized.
Also,
SWPPPs
must
be
maintained
on­
site
from
the
date
of
project
initiation
to
the
date
of
final
stabilization.
Applicants
may
need
to
develop
a
recordkeeping
system,
enter
data,
train
personnel,
and
file
information.

NPDES­
Authorized
States
and
Territories
Respondent
activities
can
vary
depending
on
the
characteristics
of
the
particular
authorized
state
or
Territory
and
the
methodology
they
chose
in
administering
the
program.
However,
any
NPDES
permitting
authority
may
be
expected
to
engage
in
the
following
types
of
activities:

 
Maintaining
records.
States
and
territories
need
to
develop
a
recordkeeping
system,
develop
a
master
database,
train
personnel,
enter
data,
and
distribute
the
information
to
interested
parties,
such
as
reviewers
and
enforcement
personnel.
 
Reviewing
submitted
data.
States
and
territories
may
need
to
answer
respondent
questions
and
provide
a
review
of
CGP
NOIs
for
completeness
and
technical
accuracy.
In
addition,
states
and
territories
need
to
notify
applicants
of
receipt/
approval
of
CGP
NOI
submissions.
Because
the
NPDES
regulations
do
not
require
SWPPPs
to
be
submitted
to
the
permitting
authority,
there
are
no
SWPPP­
related
respondent
activities
for
any
NPDES­
authorized
state
or
territory.

5.
THE
INFORMATION
COLLECTED 
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a).
AGENCY
ACTIVITIES
The
Agency's
activities
as
the
NPDES
permitting
authority
for
five
states,
the
District
of
Columbia,
and
all
U.
S.
territories
except
the
Virgin
Islands
are
the
same
as
the
activities
performed
by
the
45
NPDESauthorized
states
and
the
Virgin
Islands.
The
sole
activity
is
the
processing
and
review
of
CGP
NOIs.
Stormwater 
Construction
NOI
ICR
June
2006
Page
9
The
development
of
information
collection
forms
by
the
NPDES­
authorized
states
has
not
been
included
in
this
ICR.
For
the
active
ICR
(
OMB
Control
Number
2040­
0188,
EPA
ICR
Number
1842.04)
EPA
expected
that
all
necessary
forms
had
been
developed
as
part
of
EPA
Headquarters'
rule
implementation
efforts.
Furthermore,
because
the
NPDES
permitting
authorities
could
simply
adopt
the
EPA
forms
or
use
their
pre­
existing
NOI
forms,
EPA
estimated
that
the
NPDES
permitting
authorities
would
not
incur
any
additional
burden
for
the
development
of
forms.

As
EPA
receives
NOIs,
they
must
be
reviewed
for
completeness.
If
an
NOI
is
incomplete,
applicants
are
notified
and
instructed
to
submit
the
missing
information.
If
the
NOI
is
complete,
an
acceptance
letter
is
sent
to
the
permittee,
along
with
a
unique
permit
number.
The
NOI
data
is
maintained
in
the
NOI
database
at
the
NOI
Processing
Center.

The
Fish
and
Wildlife
Service
(
FWS)
and
National
Marine
Fisheries
Service
(
NMFS)
must
assist
some
applicants
with
obtaining
information
relating
to
endangered
species
and
critical
habitat
and
participate
in
formal
and
informal
Endangered
Species
Act
(
ESA)
consultations
when
endangered
species
or
critical
habitat
are
present
or
will
be
impacted
by
construction
activity.
NPDES­
authorized
states
are
not
required
to
include
these
requirements
in
their
general
permits,
and
therefore
neither
the
NPDESauthorized
states
nor
the
construction
sites
within
those
states
incur
any
burden
for
ESA
consultations.

As
mentioned
previously,
permittees
are
not
required
to
submit
SWPPPs
to
EPA
for
review.
These
plans
are
to
be
maintained
on­
site
where
the
construction
activities
are
taking
place
and
must
be
available
for
EPA
review
as
requested.
Therefore,
for
the
purposes
of
this
ICR,
the
pollution
prevention
plans
are
integral
to
the
day­
to­
day
operational
control
of
each
construction
site,
but
are
not
included
as
a
component
of
Agency
activities.

5(
b).
COLLECTION
METHODOLOGY
AND
MANAGEMENT
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
will
use
the
electronic
eNOI
system,
paper­
based
forms,
personal
computers,
and
a
database
to
ultimately
store
the
information.
EPA
will
ensure
accuracy
and
completeness
of
the
information
by
reviewing
each
submittal.
Any
form
that
is
considered
inaccurate
or
incomplete
will
not
be
accepted
and
will
be
returned
to
the
sender
with
a
letter
requesting
the
missing
and/
or
inaccurate
information.

5(
c).
SMALL
ENTITY
FLEXIBILITY
For
many
reasons,
EPA
believes
the
reporting
requirements
discussed
in
this
ICR
do
not
place
an
unreasonable
burden
on
small
business.
Over
the
last
decade,
EPA
has
reduced
reporting
burdens
on
businesses
of
all
sizes.
The
Agency
developed
the
general
permit
procedures
to
reduce
burdens
associated
with
the
application
process,
especially
the
burden
associated
with
stormwater
discharges.

The
NOI
requests
minimal
information
required
to
characterize
the
site
and
construction
activity.
Most
site
related
information
is
contained
in
the
SWPPP,
which
is
not
required
to
be
submitted
to
the
Agency.
Furthermore,
sites
submit
NOIs
once
every
five
years
and
the
burden
represented
by
these
NOIs
cannot
easily
be
reduced
for
small
businesses
because
EPA
needs
certain
basic
information
to
make
permitting
decisions.
This
basic
information
is
not
dependent
on
an
organization's
size.
One
of
the
measures
taken
by
EPA
to
reduce
burden
and
costs
is
that
facilities
submitting
NOIs
for
coverage
under
EPA's
CGP,
for
instance,
do
not
need
to
submit
any
sampling
data.
Stormwater 
Construction
NOI
ICR
June
2006
Page
10
The
CGP
NOI
(
EPA
form
3510­
9)
was
developed
specifically
to
reduce
the
burden
for
construction
activities.
The
pre­
existing
NOI
form
(
EPA
form
3510­
6)
that
was
replaced
in
1998
required
more
detailed
information
since
the
form
was
also
used
for
industrial
activities
requesting
coverage
under
a
general
permit.
The
current
NOI
is
simplified
and
only
relevant
information
for
construction
activities
is
requested.

5(
d).
COLLECTION
SCHEDULE
Federal
regulations
require
permittees
to
reapply
for
permits
at
least
every
five
years,
although
the
regulations
also
grant
permit
writers
the
authority
to
impose
more
frequent
reissuance.
General
permits
are
issued
only
for
a
five­
year
term.
All
facilities
that
wish
to
be
covered
under
the
general
permit
must
reapply
or
notify
EPA
once
every
five
years
using
the
CGP
NOI.
When
calculating
burden,
this
ICR
assumes
that
all
permit
applicants
follow
this
schedule.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
In
this
section,
EPA
presents
estimated
burden
for
each
information
request
on
construction
sites
disturbing
five
or
more
acres.
Per
EPA
ICR
guidance,
the
45
NPDES­
authorized
states
and
the
Virgin
Islands
are
also
included
as
respondents
in
this
section.

Burden
on
Construction
Respondents
The
respondent
activities
for
construction
sources
are
preparation
and
submittal
of
an
NOI,
the
development
of
a
SWPPP,
conduct
of
routine
site
inspections,
and
associated
recordkeeping.
Burden
for
other
activities
associated
with
permit
coverage
for
stormwater
discharges
from
large
construction
activities
(
such
as
the
preparation
and
submittal
of
a
NOT)
is
included
in
other
ICRs
(
e.
g.,
NPDES
Applications
ICR
­
OMB
Control
Number
2040­
0086
for
NOTs).

EPA
estimates
that
all
construction
sources
required
to
seek
coverage
will
use
the
NOI
rather
than
seek
coverage
using
an
application
for
an
individual
permit.
To
determine
the
average
burden
for
the
NOI,
EPA
developed
an
estimate
of
the
time
increment
necessary
to
complete
the
form.
A
poll
of
contractor
and
EPA
staff
familiar
with
the
NOI
requests
indicated
that
the
current
form
would
take
a
typical
applicant
a
total
of
1.5
hours
to
complete
if
there
were
no
endangered
species
or
critical
habitat
listed
for
the
project
area.
Should
the
permittee
need
to
informally
consult
with
the
Fish
and
Wildlife
Service
(
FWS)
or
National
Marine
Fisheries
Service
(
NMFS)
to
determine
if
species
or
critical
habitat
may
be
present
and
if
an
adverse
impact
is
likely
to
occur,
then
an
average
of
6
hours
would
be
needed
to
complete
the
form.
EPA
estimates
that
37.3%
of
applicants
would
need
to
perform
informal
consultations.
Based
on
information
provided
by
FWS,
EPA
estimates
that
2.7
percent
of
applicants
would
need
formal
consultation
for
actions
that
are
likely
to
adversely
affect
species
or
critical
habitat,
and
thus
incur
20
hours
of
burden
preparing
biological
evaluations
and
related
correspondence.
EPA
assumes
that
60
percent
would
not
have
listed
endangered
species
or
critical
habitat
in
the
project
area.
A
discussion
with
FWS
staff
confirmed
this
assumption
was
a
good
estimate
given
the
areas
that
the
permit
covered.
However,
in
NPDES­
authorized
states,
the
ESA
requirement
of
the
CGP
does
not
necessarily
apply,
unless
specifically
provided
for
by
the
state.
Therefore,
for
the
purposes
of
this
ICR,
Stormwater 
Construction
NOI
ICR
June
2006
Page
11
only
construction
sites
in
non­
NPDES­
authorized
states
might
incur
burden
in
consultations
with
FWS
and/
or
NMFS.
In
other
words,
in
NPDES­
authorized
states,
the
burden
is
1.5
hours
for
completion
of
the
NOI,
while
in
areas
where
EPA
is
the
permitting
authority,
the
burden
is
dependent
on
the
required
level
of
consultation
with
FWS
and
NMFS.

The
burden
to
develop
a
SWPPP
was
estimated
using
best
professional
judgment
of
contractor
staff
familiar
with
the
stormwater
CGP
process
and
the
design
of
SWPPPs.
Despite
the
fact
that
the
components
of
a
SWPPP
are
similar,
the
design,
size,
function,
and
level
of
effort
involved,
will
vary
for
each
site.
To
calculate
the
burden
to
prepare
a
SWPPP,
EPA
and
EPA
contractor
staff
identified
a
"
typical"
respondent
and
then
estimated
the
burden
for
that
respondent
to
prepare
a
SWPPP.
The
various
activities
carried
out
in
the
preparation
of
a
SWPPP
are
presented
in
Section
4(
b).
EPA
estimates
that
the
average
time
for
a
respondent
to
develop
a
SWPPP
is
36.4
hours.
This
is
a
one­
time
development
activity.
The
breakdown
of
cost
and
burden
by
labor
category
is
provided
in
Section
6(
b).

The
burden
to
conduct
routine
site
inspections
was
estimated
using
best
professional
judgment
This
ICR
assumes
inspections
will
be
conducted
by
a
project
manager,
bi­
weekly,
with
each
inspection
expected
to
take
30
minutes,
including
documentation
of
findings.
Based
on
data
from
EPA's
NOI
database,
the
median
and
mean
large
construction
projects
lasts
approximately
one
year
and
as
such,
assumes
26
biweekly
inspections
will
be
conducted.

The
estimated
recordkeeping
burden
for
the
CGP
NOI
and
SWPPP
is
expected
to
be
0.4
hours
per
construction
start,
based
on
a
poll
of
contractor
and
EPA
staff
familiar
with
the
recordkeeping
activities
associated
with
the
construction
stormwater
program.
The
burden
is
estimated
at
0.2
hours
each
for
the
CGP
NOI
and
SWPPP,
respectively.

A
summary
of
estimated
respondent
burden
is
presented
below
in
Table
1.
Stormwater 
Construction
NOI
ICR
June
2006
Page
12
Table
1.
Burden
on
Each
Respondent
Information
Collection
Activity
Annual
Burden
on
Each
Respondent
(
hours)
In
NPDES­
Authorized
States
NOI
preparation
&
submittal
1.5
Development
of
SWPPP
36.4
Routine
site
inspection
13.0
Recordkeeping
0.4
Annual
Total
51.3
In
States
where
EPA
is
the
Permitting
Authority
For
sites
where
no
ESA
consultation
is
necessary
NOI
preparation
&
submittal
1.5
Development
of
SWPPP
36.4
Routine
site
inspection
13.0
Recordkeeping
0.4
Annual
Total
51.3
For
sites
where
an
informal
ESA
consultation
is
necessary
NOI
preparation
&
submittal
6.0
Development
of
SWPPP
36.4
Routine
site
inspection
13.0
Recordkeeping
0.4
Annual
Total
55.8
For
sites
where
a
formal
ESA
consultation
is
necessary
NOI
preparation
&
submittal
20.0
Development
of
SWPPP
Routine
site
inspection
36.4
13.0
Recordkeeping
0.4
Annual
Total
69.8
Burden
on
NPDES­
Authorized
States
The
Office
of
Management
and
Budget
requires
the
state
administrative
burden
and
cost
to
be
included
in
the
respondent
burden
section
of
the
ICR.
The
burden
incurred
by
the
NPDES­
authorized
states
in
managing
and
implementing
the
construction
stormwater
program
is
consistent
with
that
incurred
by
the
Agency.
Burden
and
costs
will
impact
the
Agency
where
it
is
the
NPDES
permitting
authority,
and
NPDES­
authorized
states
will
incur
burden
and
costs
where
EPA
is
not
the
permitting
authority.

The
sole
activity
required
for
administration
of
the
construction
program
in
NPDES­
authorized
states
is
the
processing
and
review
of
NOIs.
This
includes
data
entry
of
the
NOI
information
into
a
database
and
for
responding
to
any
inquiries.
Most
NPDES­
authorized
states
and
territories
use
a
CGP
NOI
process
similar
to
that
implemented
by
EPA.
This
greatly
reduces
the
burden
upon
governments
to
develop
new
forms
and
new
databases
to
record
information
and
track
applicants.
The
burden
estimate
for
administration
of
the
construction
program
is
based
on
a
poll
of
contractor
and
EPA
staff
familiar
with
the
conditions
of
the
waivers
and
the
level
of
review
necessary.
It
is
presented
below
in
Table
2.

Table
2.
Burden
on
NPDES­
authorized
States
Information
Collection
Activity
Burden
Per
Respondent
(
hours)
NOI
processing
&
review
1.0
Stormwater 
Construction
NOI
ICR
June
2006
Page
13
Total
NOI
processing
&
review
1.0
6(
b).
ESTIMATING
RESPONDENT
COST
Because
EPA
has
determined
that
there
are
no
capital
or
operation
and
maintenance
costs
associated
with
any
of
the
respondent
activities,
this
ICR
only
includes
labor
costs
in
its
estimates.
The
CGP
does
not
require
construction
site
operators
to
expend
funds
for
capital
assets.
Respondents
are
not
required
to
pay
for
capital
equipment
or
operations
and
maintenance
to
respond
to
the
additional
information
requests.

Hourly
wage
rates
are
fully
loaded
(
i.
e.,
including
fringe
benefits
and
overhead
and
profit,
if
applicable)
in
January
2006
dollars
and
are
derived
from
statistics
provided
by
the
U.
S.
Department
of
Labor.

Costs
to
Construction
Respondents
EPA
used
the
following
labor
categories
and
hourly
rates
to
estimate
labor
costs
for
activities
by
construction
sources.
Hourly
wage
rates
are
inflated
to
January
2006
dollars
using
the
Employment
Cost
Index
and
fully
loaded
assuming
overhead
costs
of
52
percent.
1
°
Project
manager:
$
65.60,
°
Engineering
assistant,
$
46.46,
°
Drafter,
$
31.73,
and
°
Clerical
support,
$
27.19.

For
purposes
of
this
analysis,
EPA
used
data
provided
by
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
in
a
table
entitled
November
2004
National
Industry­
Specific
Occupational
and
Employment
Wage
Estimates:
NAICS
236000
 
Construction
of
Buildings.
EPA
assumes
that
a
project
manager's
compensation
equates
to
the
"
Engineering
Managers"
level
of
Management
Occupations
shown
in
the
table.
Similarly,
an
Engineering
Assistant's
compensation
is
assumed
to
be
the
same
as
the
"
Civil
Engineers"
level,
and
a
Drafter's
compensation
equates
to
the
"
Architectural
and
Civil
Drafters"
level
of
Architecture
and
Engineering
Occupations.
Clerical
Support
personnel's
compensation
is
equal
to
the
"
Executive
Secretaries
and
Administrative
Assistants"
level
of
Office
and
Administrative
Support
Occupations
in
the
table.

EPA
used
an
hourly
labor
cost
of
$
65.60
for
the
project
manager
to
prepare
and
submit
the
NOI
and
perform
routine
site
inspections,
and
a
combination
of
all
four
staff
labor
categories
for
the
development
of
a
SWPPP.
Specifically,
EPA
assumed
the
following
hourly
distribution
for
SWPPP
development:
project
manager
(
1.0
hours),
engineering
assistant
(
13.0
hours),
drafter
(
22.0
hours),
and
clerical
support
(
0.4
hours).
That
labor
mix
equates
to
an
effective
hourly
rate
of
$
37.87.
Recordkeeping
activities
for
both
the
CGP
NOI
and
SWPPP
are
based
on
hourly
rates
for
clerical
staff.

EPA
calculated
the
administrative
costs
for
each
of
the
information
collection
activities
by
multiplying
the
estimated
burden
by
the
appropriate
hourly
labor
rate.
The
results
are
presented
below
in
Table
3.

1
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
Employer
Costs
for
Employee
Compensation 
December
2005,
Table
9.
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
Private
industry
workers,
goods­
producing
and
service­
providing
industries,
by
occupational
group,
December
2005.
Stormwater 
Construction
NOI
ICR
June
2006
Page
14
Table
3.
Costs
to
Each
Respondent
Information
Collection
Activity
Annual
Burden
for
Each
Respondent
(
hours)
Labor
Rate
($
per
hour)
Annual
Cost
to
Each
Respondent
In
NPDES­
Authorized
States
NOI
preparation
&
submittal
1.5
$
65.60
$
98.40
Development
of
SWPPP
36.4
$
37.87
$
1,378.47
Routine
site
inspections
13.0
$
65.60
$
852.80
Recordkeeping
0.4
$
27.19
$
10.88
Annual
Total
51.3
­
$
2,340.55
In
States
where
EPA
is
the
Permitting
Authority
For
sites
where
no
ESA
consultation
is
necessary
NOI
preparation
&
submittal
1.5
$
65.60
$
98.40
Development
of
SWPPP
36.4
$
37.87
$
1,378.47
Routine
site
inspections
13.0
$
65.60
$
852.80
Recordkeeping
0.4
$
27.19
$
10.88
Annual
Total
51.3
­
$
2,340.55
For
sites
where
an
informal
ESA
consultation
is
necessary
NOI
preparation
&
submittal
6.0
$
65.60
$
393.60
Development
of
SWPPP
36.4
$
37.87
$
1,378.47
Routine
site
inspections
13.0
$
65.60
$
852.80
Recordkeeping
0.4
$
27.19
$
10.88
Annual
Total
55.8
­
$
2,635.75
For
sites
where
a
formal
ESA
consultation
is
necessary
NOI
preparation
&
submittal
20.0
$
65.60
$
1,312.00
Development
of
SWPPP
36.4
$
37.87
$
1,378.47
Routine
site
inspections
13.0
$
65.60
$
852.80
Recordkeeping
0.4
$
27.19
$
10.88
Annual
Total
69.8
­
$
3,554.15
Costs
to
NPDES­
Authorized
States
The
hourly
labor
rate
for
NPDES­
authorized
states
was
based
on
the
average
hourly
wage
for
state
employees
as
determined
by
the
U.
S.
Department
of
Labor.
2
The
mean
hourly
cost
of
employment
for
all
occupations
is
$
36.55,
including
benefits.
This
hourly
rate
was
used
for
all
activities
performed
by
NPDES­
authorized
states
in
this
ICR.

EPA
calculated
the
administrative
costs
of
the
information
collection
activities
by
multiplying
the
estimated
burden
by
the
hourly
labor
rate.
The
results
are
presented
below
in
Table
4.

2
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
Employer
Costs
for
Employee
Compensation,
Table
4­
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
State
and
local
government
workers,
by
occupational
and
industry
group,
December
2005.
Stormwater 
Construction
NOI
ICR
June
2006
Page
15
Table
4.
Costs
to
NPDES­
Authorized
States
Information
Collection
Activity
Annual
Burden
Per
Respondent
(
hours)
State
Labor
Cost
($/
hr)
Annual
Cost
Per
Respondent
($)
NOI
processing
&
review
1.0
$
36.55
$
36.55
6(
c).
ESTIMATING
AGENCY
BURDEN
AND
COST
The
Agency
burden
and
costs
are
included
where
EPA
is
the
NPDES
permitting
authority
in
the
non­
NPDES­
authorized
states
and
territories.
An
estimate
of
the
burden
and
costs
for
the
Agency
result
from
activities
as
described
in
Section
5(
a).
These
burden
and
costs
are
identical
to
those
for
NPDESauthorized
states
and
territories,
with
the
exception
of
the
need
to
provide
FWS
and
NMFS
consultations
in
areas
where
threatened
or
endangered
species
may
be
in
the
project
area.

Burden
Estimates
For
NOIs,
Agency
burden
is
expected
to
be
1.0
hours
per
respondent
for
data
entry
of
the
NOI
information
into
a
database
and
to
respond
to
any
inquiries.
The
FWS
and
NMFS
will
incur
a
burden
due
to
ESA­
related
questions
and
consultations.
EPA
estimates
that
the
FWS
and
NMFS
will
incur
10
hours
of
burden
for
formal
consultations
and
2
hours
for
informal
consultations.

No
burden
is
included
for
SWPPPs
as
described
in
Section
5(
a).

Cost
Estimates
All
cost
calculations
in
this
ICR
account
for
labor
costs
only.
The
hourly
labor
rate
for
the
Federal
government
is
based
on
the
following:

The
hourly
employment
cost
of
Federal
employees
was
determined
using
methodology
established
in
previous
ICRs.
According
to
the
U.
S.
Office
of
Personnel
Management,
2006
General
Schedule
(
2006­
GS),
the
average
annual
salary
of
a
government
employee
at
the
GS­
9,
Step
10
level
is
$
49,632.
At
2,080
hours
per
year,
the
hourly
wage
is
$
23.86.
Assuming
overhead
costs
of
50
percent,
or
$
11.93
per
hour,
the
fully
loaded
cost
of
employment
for
a
federal
employee
is
$
35.79.
Costs
incurred
by
the
Agency
are
presented
in
Table
5.

Table
5.
Agency
Costs
Information
Collection
Activity
Annual
Burden
Per
Respondent
(
hours)
Agency
Labor
Cost
($/
hr)
Annual
Cost
Per
Respondent
($)

NOI
processing
&
review
1.0
$
35.79
$
35.79
FWS/
NMFS
informal
consultation
2.0
$
35.79
$
71.58
FWS/
NMFS
formal
consultation
10.0
$
35.79
$
357.90
Stormwater 
Construction
NOI
ICR
June
2006
Page
16
6(
d).
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
The
total
burden
and
cost
on
the
all
respondents
as
a
group
can
be
calculated
by
multiplying
the
burden
and
cost
per
respondent
by
the
number
of
respondents
in
the
regulated
universe.

Estimating
the
Universe
of
Construction
Respondents
EPA
estimates
that
nationwide,
there
will
be
an
annual
average
of
157,500
construction
starts
of
five
acres
or
more
in
2006,
2007,
and
2008.
This
number
was
calculated
based
on
permittee
data
from
2004
and
communication
with
EPA
and
state
permitting
authorities.
As
documented
in
Attachment
B,
EPA
estimates
approximately
100,000
NOIs
are
received
annually
by
all
NPDES
permitting
authorities
combined.
Based
on
communication
with
EPA
Regional
offices,
the
Agency
estimates
a
non­
filer
rate
of
approximately
60
percent
for
this
industry.
This
equates
to
a
total
regulated
universe
of
250,000
construction
sites
annually
disturbing
greater
than
one
acre
of
land.
Based
on
the
Economic
Analysis
(
EA)
for
the
Final
Phase
II
Stormwater
Rule,
approximately
63
percent
of
construction
sites
disturb
five
acres
or
above.
The
Agency
believes
this
estimate
provides
a
reasonable
estimate
of
the
universe
of
large
construction
activities
regulated
by
the
NPDES
program
for
the
next
three
year
period.

Estimating
the
NPDES­
Authorized
State
Universe
To
determine
what
percentage
of
the
157,500
annual
construction
starts
take
place
in
NPDES­
authorized
states,
where
the
burden
of
administering
the
program
falls
on
the
state,
EPA
assembled
data
from
the
U.
S.
Census
Bureau.
3
According
to
the
2000
Census,
approximately
5.6
percent
of
the
population
lives
in
the
five
non­
NPDES­
authorized
states,
Washington,
DC,
and
all
non­
NPDES­
authorized
territories.
Applying
this
percentage
to
the
total
universe
of
construction
sites
yields
approximately
8,820
sites
in
non­
NPDES­
authorized
states
and
territories,
and
148,680
sites
(
94.4
percent)
in
NPDES­
authorized
states
and
the
Virgin
Islands.
These
estimates
are
summarized
in
Table
6.

Table
6.
Relative
Number
of
Respondents
Information
Collection
Activity
Number
of
Annual
Respondents
In
NPDES­
Authorized
States
NOI
preparation
&
submittal
148,680
Development
of
SWPPP
148,680
Routine
site
inspections
148,680
Recordkeeping
148,680
In
States
where
EPA
is
the
Permitting
Authority
For
sites
where
no
ESA
consultation
is
necessary
(
60%
of
starts
in
non­
NPDES­
authorized
states)
NOI
preparation
&
submittal
5,292
Routine
site
inspections
5,292
Development
of
SWPPP
5,292
Recordkeeping
5,292
3
http://
www.
census.
gov/
population/
cen2000/
tab02.
xls
http://
www.
census.
gov/
Press­
Release/
www/
2002/
GUAMSTATELEVEL.
xls
http://
www.
census.
gov/
Press­
Release/
www/
2002/
amsamstatelevel.
xls
http://
www.
census.
gov/
Press­
Release/
www/
2002/
USVISTATELEVEL.
xls
Stormwater 
Construction
NOI
ICR
June
2006
Page
17
For
sites
where
an
informal
ESA
consultation
is
necessary
(
37.3%
of
starts
in
non­
NPDES­
authorized
states)
NOI
preparation
&
submittal
3,290
Routine
site
inspections
3,290
Development
of
SWPPP
3,290
Recordkeeping
3,290
For
sites
where
a
formal
ESA
consultation
is
necessary
(
2.7%
of
starts
in
non­
NPDES­
authorized
states)
NOI
preparation
&
submittal
238
Routine
site
inspections
238
Development
of
SWPPP
238
Recordkeeping
238
Total
Burden
and
Costs
Table
7
presents
the
estimated
annual
average
burden
and
costs
for
construction
activities.
Table
8
presents
the
estimated
annual
average
burden
and
costs
for
NPDES­
authorized
states.
Total
burden
and
costs
are
calculated
by
multiplying
the
cost
associated
with
each
activity
by
the
number
of
estimated
respondents.

Table
7.
Total
Respondent
Burden
and
Cost
Estimates
Information
Collection
Activity
Annual
Number
of
Respondents
Annual
Burden
Hours
Per
Respondent
Annual
Burden
(
hours)
Respondent
Labor
Cost
($/
hr)
Annual
Cost
($)

In
NPDES­
Authorized
States
NOI
preparation
&
submittal
148,680
1.5
223,020
$
65.60
$
14,630,112
Development
of
SWPPP
148,680
36.4
5,411,952
$
37.87
$
204,950,622
Routine
site
inspections
148,680
13.0
1,932,840
$
65.60
$
126,794,304
Recordkeeping
148,680
0.4
59,472
$
27.19
$
1,617,044
Annual
Subtotal
51.3
7,627,284
$
347,992,082
In
States
where
EPA
is
the
Permitting
Authority
For
sites
where
no
ESA
consultation
is
necessary
NOI
preparation
&
submittal
5,292
1.5
7,938
$
65.60
$
520,733
Development
of
SWPPP
5,292
36.4
192,629
$
37.87
$
7,294,853
Routine
site
inspections
5,292
13.0
68,796
$
65.60
$
4,513,018
Recordkeeping
5,292
0.4
2,117
$
27.19
$
57,556
Annual
Subtotal
51.3
271,480
$
12,386,159
For
sites
where
an
informal
ESA
consultation
is
necessary
NOI
preparation
&
submittal
3,290
6.0
19,740
$
65.60
$
1,294,944
Development
of
SWPPP
3,290
36.4
119,756
$
37.87
$
4,535,160
Routine
site
inspections
3,290
13.0
42,770
$
65.60
$
2,805,712
Recordkeeping
3,290
0.4
1,316
$
27.19
$
35,782
Annual
Subtotal
55.8
183,582
$
8,671,598
For
sites
where
a
formal
ESA
consultation
is
necessary
NOI
preparation
&
submittal
238
20.0
4,760
$
65.60
$
312,256
Development
of
SWPPP
238
36.4
8,663
$
37.87
$
328,075
Routine
site
inspections
238
13.0
3,094
$
65.60
$
202,966
Recordkeeping
238
0.4
95
$
27.19
$
2,588
Annual
Subtotal
69.8
16,612
$
845,886
Stormwater 
Construction
NOI
ICR
June
2006
Page
18
ANNUAL
TOTAL
157,500
8,098,958
$
369,895,725
Table
8.
Total
NPDES­
Authorized
State
Burden
and
Costs
Information
Collection
Activity
Annual
Number
of
Respondents
Burden
Per
Respondent
(
hours)
Annual
Burden
(
hours)
Labor
Cost
($/
hr)
Annual
Cost
($)

NOI
processing
&
review
148,680
1.0
148,680
$
36.55
$
5,434,254
TOTAL
148,680
148,680
$
5,434,254
Stormwater 
Construction
NOI
ICR
June
2006
Page
19
6(
e).
BOTTOM
LINE
BURDEN
HOURS
AND
COST
TABLES
The
bottom
line
burden
hours
and
cost
are
the
sum
of
all
the
hours
and
costs
incurred
for
all
activities
by
construction
operators,
NPDES­
authorized
states,
and
the
Agency.

Respondent
Tally
This
ICR
calculated
burden
and
cost
for
two
types
of
respondents:
1)
construction
sites
disturbing
five
acres
or
more,
and
2)
NPDES­
authorized
states.
The
combined
bottom
line
totals
for
the
two
respondent
types
are
157,546
respondents
performing
5
information
collection
activities
resulting
in
an
average
of
8,247,638
annual
burden
hours
at
an
annual
cost
of
$
375,329,979.
The
respondent
tally
is
presented
in
Table
9.

Table
9.
Annual
Respondent
Burden
and
Cost
Summary
Respondent
Type
Annual
Number
of
Respondents
Number
of
Activities
Annual
Burden
(
hours)
Average
Annual
Cost
($)
Construction
sources
157,500
4
8,098,958
$
369,895,725
NPDES
authorized
states
a
46
1
148,680
$
5,434,254
TOTAL
157,546
5
8,247,638
$
375,329,979
a
45
states
and
one
territory
(
Virgin
Islands)

Agency
Tally
Agency
activities
associated
with
information
collection
burden
and
costs
are
similar
to
those
for
the
NPDES­
authorized
states.
The
difference
between
the
two
is
that
the
Agency
has
authorized
45
states
and
the
Virgin
Islands
to
implement
the
NPDES
stormwater
program
and
as
such,
Agency
burden
is
only
included
for
the
remaining
states
and
territories
(
as
described
in
6(
d)).

The
Agency's
total
burden
and
costs
is
presented
in
Table
10.
Bottom
line
annual
burden
is
17,780
hours
at
an
annual
cost
of
$
636,346.

Table
10.
Total
Agency
Burden
and
Costs
Information
Collection
Activity
Annual
Number
of
Respondents
Number
of
Activities
Annual
Burden
(
hours)
Average
Annual
Cost
($)
NOI
processing
&
review
8,820
1
8,820
$
315,668
FWS/
NMFS
informal
consultation
3,290
1
6,580
$
235,498
FWS/
NMFS
formal
consultation
238
1
2,380
$
85,180
TOTAL
12,348
3
17,780
$
636,346
Total
Tally
The
sum
of
respondent,
NPDES­
authorized
state,
and
Agency
bottom
line
totals
are
8,265,418
burden
hours
per
year
at
an
annual
cost
of
$
375,966,325.

Variations
in
the
Annual
Bottom
Line
There
will
not
be
a
significant
variation
in
the
annual
respondent
reporting/
recordkeeping
burden
or
cost
over
the
course
of
the
clearance
period.
Stormwater 
Construction
NOI
ICR
June
2006
Page
20
6(
f).
REASONS
FOR
CHANGE
IN
BURDEN
AND
COST
Table
11
presents
the
change
in
the
respondent
burden
from
the
previous
ICR
for
each
information
item
covered
by
this
ICR.
The
increase
in
applicant
respondent
and
NPDES­
authorized
state
burden
is
primarily
the
result
of
one
change,
that
being
the
addition
of
routine
site
inspection
burden
for
existing
large
construction
sites
(
previously
not
addressed
in
any
ICR).
A
portion
of
the
burden
is
reduced
based
on
EPA's
estimate
of
the
number
of
entities
affected
by
this
information
collection.

Based
on
data
collected
from
EPA
Regional
and
State
NPDES
permitting
authorities,
the
Agency
revised
its
estimate
of
the
number
of
large
construction
sites
covered
by
this
regulation
downward
from
190,549
to
157,500
sites
annually.

Table
11.
Change
in
Annual
Burden
Information
Collection
Activity
Current
ICR
Previous
ICR
Change
between
Previous
ICR
and
Current
ICR
Construction
Sources:
NOI
preparation
&
submittal
255,458
325,047
­
69,589
Development
of
SWPPP
5,733,000
7,324,164
­
1,591,164
Routine
site
inspections
2,047,500
2,047,500
Recordkeeping
63,000
80,485
­
17,485
Subtotal
8,098,958
7,729,696
369,262
NPDES­
Authorized
States
NOI
processing
&
review
148,680
190,549
­
41,869
Subtotal
148,680
190,549
­
41,869
Respondent
Total
8,247,638
7,920,245
327,393
Agency
NOI
processing
&
review
8,820
10,664
­
1,844
FWS/
NMFS
informal
consultation
6,580
7,956
­
1,376
FWS/
NMFS
formal
consultation
2,380
2,879
­
499
Agency
Total
17,780
21,499
­
3,719
No
capital
operations
and
maintenance
costs
are
associated
with
this
ICR.

6(
g).
BURDEN
STATEMENT
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
51.3
hours
per
respondent
in
NPDES­
authorized
states
and
53.5
hours
per
respondent
in
states
and
territories
where
EPA
is
the
permitting
authority.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
Stormwater 
Construction
NOI
ICR
June
2006
Page
21
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

Table
12.
Burden
Statement
Respondent
Average
Annual
Burden
(
hours)
Construction
Sources
Each
Construction
Source
in
an
NPDES­
Authorized
State
51.30
Each
Construction
Source
in
a
non­
NPDES­
Authorized
State
53.48
Each
NPDES­
Authorized
State
3,232
Agency
(
EPA)
17,780
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
EPA­
HQ­
OW­
2003­
0011
which
is
available
for
online
viewing
at
www.
regulations.
gov,
or
in
person
at
the
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
at
www.
regulations.
gov.
This
site
can
be
used
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
EPA­
HQ­
OW­
2003­
0011
and
OMB
control
number
2040­
0188
in
any
correspondence.
Stormwater 
Construction
NOI
ICR
June
2006
Page
22
ATTACHMENT
A.

Summary
of
Response
to
National
Association
of
Homebuilders
(
NAHB)
Comments
on
Draft
ICR
On
May
8,
2006,
NAHB
submitted
comments
to
EPA
on
both
the
stormwater
construction
ICR
(
OMB
Control
No.
2040­
0188)
and
the
Stormwater
Phase
II
ICR
(
OMB
Control
No.
2040­
0211).
NAHB
also
references
comments
it
submitted
on
April
28,
2003
on
the
previous
version
of
this
ICR.
Following
is
a
summary
of
comments
and
EPA's
response
to
comments
specific
to
the
stormwater
construction
ICR.

NAHB
Comment:
EPA
has
not
met
its
obligation
to
repeat
the
review
required
for
a
new
collection
of
information;
rather,
the
Agency
simply
requested
comments
on
the
supporting
statement
document
from
2003.

EPA
Response:
EPA
did
provide
notice
of
the
ICR
using
burden
estimates
from
the
previous
ICR.
However,
this
ICR
includes
no
new
paperwork
requirements
and
the
Agency
expected
burdens
to
be
similar
to
those
of
past
ICRs.
EPA
is
incorporating
relevant
NAHB
comments
on
the
ICR
that
was
public
noticed
on
March
7,
2006
(
71
FR
11407­
11411),
consistent
with
public
notice
procedures
for
ICRs.

NAHB
Comment:
The
Agency
has
significantly
underestimated
the
regulated
universe.

EPA
Response:
The
Agency
has
updated
the
number
of
sites
covered
under
this
ICR
to
reflect
data
collected
from
EPA
Regional
and
State
NPDES
permitting
authorities.
As
detailed
in
Attachment
B,
Agency
data
suggests
the
actual
number
of
construction
sites
affected
by
the
Phase
I
rule
is
approximately
157,500.
This
estimate
is
lower
than
the
previous
ICR
but
reflects
actual
NOI
data
plus
communication
with
the
permitting
authorities
on
the
approximate
non­
filer
rate
(
60%)
for
this
segment
of
the
regulated
universe.
The
Agency
believes
its
prior
estimates
are
higher
than
actual.

NAHB
Comment:
EPA
fails
to
include
a
burden
estimate
for
inspections
(
including
recordkeeping)
to
be
conducted
by
site
operators
and
for
the
Notice
of
Termination
(
NOT).

EPA
Response:
EPA
is
adding
a
burden
for
routine
site
inspections
to
this
ICR.
EPA
is
estimating
26
routine
inspections
per
year
per
site
(
i.
e.,
bi­
weekly)
and
assumes
that
these
assessments
will
be
performed
by
a
site/
project
manager
and
will
take
approximately
30
minutes
per
inspection,
including
documentation
of
any
findings.
The
burden
for
the
annual
comprehensive
site
inspection
is
already
included
in
the
Compliance
Assessment/
Certification
ICR
(
OMB
Control
No.
2040­
0110).
Burden
hours
for
NOTs
are
included
in
the
NPDES
Applications
ICR
(
OMB
2040­
0086).

NAHB
Comment:
EPA
provides
misleading
information
on
the
number
of
NOIs
that
are
typically
submitted
within
a
five
year
period.
Small
businesses
will
generally
conduct
more
than
one
project
in
a
five
year
period
and
as
such,
are
subject
to
multiple
permits
and
absorb
the
costs
associated
with
the
activities
in
this
ICR
potentially
several
times
within
any
given
year.

EPA
Response:
EPA
clarifies
in
the
supporting
statement
the
fact
that
operators
generally
are
required
to
submit
an
NOI
for
their
role
in
each
common
plan
that
disturbs
five
acres
or
more.
Stormwater 
Construction
NOI
ICR
June
2006
Page
23
NAHB
Comment:
NAHB
believes
the
Agency
should
do
more
to
reduce
the
burden
associated
with
small
business
(
such
as
developing
a
permit
specific
to
single
lot
building).

EPA
Response:
The
ICR
is
not
the
proper
mechanism
for
the
Agency
to
modify
its
regulations
or
permits
to
address
public
comments.
The
Agency
is
aware
of
NAHB's
concerns
related
to
burdens
associated
with
small
businesses
and
will
consider
NAHB's
comments
during
the
next
construction
general
permit
drafting
process
(
to
commence
in
2006
with
permit
issued
in
2008).

NAHB
Comment:
The
Agency
underestimates
hourly
rates
charged
for
performing
activities
identified
under
this
ICR.

EPA
Response:
The
Agency
uses
data
supplied
by
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics
(
BLS)
for
estimating
labor
costs
associated
with
regulatory
burdens.
The
Agency
did
modify
the
appropriate
personnel
responsible
for
preparing
the
NOI
to
reflect
that
generally
this
would
be
prepared
by
a
project
manager
rather
than
an
engineering
assistant.
However,
EPA
does
not
have
BLS
information
to
suggest
hourly
rates
provided
by
NAHB
are
representative
of
the
nation.
NAHB
did
provide
information
in
its
2003
letter
suggesting
that
the
Agency's
estimated
burden
for
preparation
of
a
SWPPP
(
i.
e.,
~
36
hours)
is
reasonable.
Stormwater 
Construction
NOI
ICR
June
2006
Page
24
ATTACHMENT
B.

Calculation
of
National
Estimate
of
Construction
NOIs
(
2004)

Stat
e
EPA
Region
2004
NOIs
2000
Pop.
N/
A
1
1,720
N/
A
2
200
N/
A
3
37
N/
A
4
1
N/
A
5
45
N/
A
6
1,873
N/
A
7
6
N/
A
8
215
N/
A
9
127
N/
A
10
1,007
AK
Reg
10
x
626,932
ID
Reg
10
x
1,293,953
MA
Reg
10
x
6,349,097
NH
Reg
10
x
1,235,786
PR
Reg
2
x
EPA
3,808,610
EPA
DC
Reg
3
x
NOI
Total
572,059
NOI
Pop.
%
of
Total
Pop.
NM
Reg
6
x
5,231
1,819,046
15,705,483
5.5%
CT
1
150
3,405,565
VT
1
150
608,827
DE
3
410
783,600
WV
3
1,315
1,808,344
AL
4
4,500
4,447,100
FL
4
5,562
15,982,378
KY
4
1,738
4,041,769
MS
4
1,540
2,844,658
SC
4
1,690
4,012,012
TN
4
2,250
5,689,283
MN
5
3,229
4,919,479
AR
6
605
2,673,400
LA
6
415
4,468,976
OK
6
1,566
3,450,654
KS
7
790
2,688,418
NE
7
1,700
1,711,263
MT
8
699
902,195
UT
8
1,800
2,233,169
AZ
9
3,200
5,130,632
CA
9
6,773
33,871,648
HI
9
278
1,211,537
NV
9
1,600
State
1,998,257
State
OR
10
622
NOI
Total
3,421,399
NOI
Pop.
%
of
Total
Pop.
WA
10
350
42,932
5,894,121
118,198,684
41.4%
ME
1
*
1,274,923
RI
1
*
1,048,319
NJ
2
*
8,414,350
NY
2
*
18,976,457
Stormwater 
Construction
NOI
ICR
June
2006
Page
25
Stat
e
EPA
Region
2004
NOIs
2000
Pop.
MD
3
*
5,296,486
PA
3
*
12,281,054
VA
3
*
7,078,515
GA
4
*
8,186,453
NC
4
*
8,049,313
IL
5
*
12,419,293
IN
5
*
6,080,485
MI
5
*
9,938,444
OH
5
*
11,353,140
WI
5
*
5,363,675
TX
6
*
20,851,820
IA
7
*
2,926,324
MO
7
*
5,595,211
Total
CO
8
*
4,301,261
NOI
Pop.
%
of
total
Pop.
ND
8
*
642,200
133,904,167
46.9%
SD
8
*
754,844
Non­
NOI
Pop.
%
of
Total
Pop.
WY
8
*
493,782
151,326,349
53.1%
Total
48,163
285,230,516
*
­
Data
not
collected.
48,163
NOIs
from
29
states+
(
actual)
54,429
NOIs
from
50
states+
(
estimated)
102,592
Total
NOIs
100,000
Total
NOIs
received
nationwide
Assumed
based
on
1
significant
figure
