1
July
6,
2000
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
Revision
to
the
National
Water
Quality
Inventory
Reports
(
Clean
Water
Act
Sections
305(
b)
and
Revisions
to
EPA's
Regulations
Implementing
Section
303(
d).

ICR
Number
1560.06
1(
b)
SHORT
CHARACTERIZATION
Section
303(
d)
of
the
Clean
Water
Act
requires
States
to
identify
and
rank
waters
which
cannot
meet
water
quality
standards
(
WQS)
following
the
implementation
of
technology­
based
controls.
Under
Section
303(
d),
States
are
also
required
to
establish
total
maximum
daily
loads
(
TMDLs)
for
listed
waters
not
meeting
standards
as
a
result
of
pollutant
discharges.
In
developing
the
Section
303(
d)
lists,
States
are
required
to
consider
various
sources
of
water­
quality
related
data
and
information,
including
the
Section
305(
b)
State
water
quality
reports.
The
Section
305(
b)
reports
contain
information
on
the
extent
of
water
quality
degradation,
the
pollutants
and
sources
affecting
water
quality,
and
State
progress
in
controlling
water
pollution.

EPA's
Assessment
and
Watershed
Protection
Division
(
AWPD)
works
with
its
Regional
counterparts
to
review
and
approve
or
disapprove
State
Section
303(
d)
lists
and
TMDLs
from
56
respondents
(
the
50
States,
the
District
of
Columbia,
and
the
five
Territories).
Section
303(
d)
specifically
requires
States
to
develop
lists
and
TMDLs
"
from
time
to
time"
and
EPA
to
review
and
approve
or
disapprove
the
lists
and
the
TMDLs.
EPA
also
collects
State
305(
b)
reports
from
59
respondents
(
the
50
States,
the
District
of
Columbia,
five
Territories,
and
3
River
Basin
commissions).

The
Office
of
Management
and
Budget
(
OMB)
previously
approved
information
collection
authority
for
the
submission
of
State
305(
b)
reports
under
40
CFR
130.10(
a)
of
the
EPA
Water
Quality
Management
Standards
under
OMB
Number
2040­
0071
(
ICR
Number
1560.1).
In
1992,
OMB
approved
an
addendum
to
ICR
1560.1
clarifying
the
burden
associated
with
preparing
State
303(
d)
lists
of
waters
for
inclusion
in
the
305(
b)
reports.
OMB
reapproved
the
ICR
for
the
period
1993
­
1995,
1996
­
1998,
and
then
again
from
March
1999
­
April
2003
(
ICR
Number
1560.05,
approved
April
5,
2000).
This
proposed
ICR
covers
the
period
for
July
2000
­
June
2003.

This
Supporting
Statement
revises
the
currently
approved
ICR
based
on
changes
EPA
is
making
to
the
Section
303(
d)
regulations.
These
revisions
increase
the
burden
to
States
for
four
Section
303(
d)
activities
related
to
preparation
of
the
Section
303(
d)
lists:
revising
the
listing
methodology,
establishing
schedules
for
TMDL
development,
increased
public
participation,
and
providing
the
listing
methodology
in
a
new
format.
EPA's
currently
approved
ICR
for
the
period
March
1999
through
April
2003
was
based
on
the
burden
to
respondents
of
the
current
program
and
did
not
include
consideration
of
the
impact
of
the
revised
regulations
(
however,
the
additional
burden
to
the
Agency
of
the
revised
regulations
was
included
in
the
ICR).
The
revisions
contained
2
in
this
Supporting
Statement
include
the
increased
303(
d)
listing
burden
to
States
that
would
result
under
the
final
regulations.

As
required
by
OMB's
Terms
of
Clearance
for
the
approved
ICR
for
March
1999
to
April
2003,
this
Supporting
Statement
includes
the
respondent
burden
associated
with
developing
TMDLs.
This
burden
was
not
estimated
in
previous
ICRs,
but
can
now
be
included
due
to
recent
advances
in
EPA's
ability
to
estimate
the
cost
of
developing
TMDLs.
In
this
ICR,
the
burden
for
developing
TMDLs
is
divided
into
two
parts:
the
burden
associated
with
the
current
TMDL
regulations,
and
the
additional
burden
associated
with
the
new
requirements
for
the
final
revisions
to
the
TMDL
regulations.
The
new
requirements
add
two
additional
TMDL
development
tasks:
preparation
of
an
implementation
plan,
and
written
response
to
public
comments
regarding
the
TMDL.

As
also
required
by
OMB's
Terms
of
Clearance
for
the
approved
ICR
for
March
1999
to
April
2003,
this
Supporting
Statement
estimates
the
burden
to
respondents
of
providing
information
as
required
by
305(
b)
on
the
costs
and
benefits
of
attaining
water
quality
standards,
and
the
burden
to
the
Agency
of
providing
guidance
to
respondents
for
preparing
this
information.
Although
this
is
not
a
new
requirement,
the
burden
of
providing
this
information
has
not
been
estimated
in
previous
ICRs,
whether
based
on
the
effort
associated
with
the
current
practices
of
respondents
in
providing
this
information
or
whether
based
on
the
availability
of
improved
guidance
for
developing
this
information.

This
Supporting
Statement
does
not
include:
1)
the
reduction
in
respondent
burden
resulting
from
the
final
regulations'
adoption
of
a
4­
year
303(
d)
listing
cycle
instead
of
the
current
2­
year
303(
d)
listing
cycle
because
the
savings
(
although
substantial
over
time)
would
likely
not
be
realized
for
the
period
covered
by
this
ICR;
2)
the
reduction
in
respondent
burden
resulting
from
EPA's
March
27,
2000
rule
removing
the
federal
requirement
for
States
to
submit
their
303(
d)
lists
in
2000
(
skipping
this
listing
cycle)
because
the
timing
of
the
rule's
issuance
makes
it
difficult
to
estimate
the
extent
to
which
savings
occurred;
and
3)
the
Agency's
burden
associated
with
the
final
revisions
to
the
regulations
because
these
were
already
included
in
the
Agency's
approved
ICR
for
March
1999
to
April
2003.
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
Section
303(
d)
of
the
CWA
establishes
the
total
maximum
daily
load
(
TMDL)
process
to
provide
for
more
stringent
water­
quality
based
controls
when
required
controls
are
inadequate
to
achieve
State
water
quality
standards.
States
must
identify
waterbodies
that
do
not
or
are
not
expected
to
meet
applicable
water
quality
standards
solely
through
the
implementation
of
technology
based
controls.
These
waterbodies
are
referred
to
as
water­
quality
limited
waterbodies.

"(
d)(
1)(
A)
Each
State
shall
identify
those
waters
within
its
boundaries
for
which
the
effluent
limitations
required
by
section
301(
b)(
1)(
A)
and
section
301(
b)(
1)(
B)
are
not
stringent
enough
to
implement
any
water
quality
standard
applicable
to
such
waters.
The
State
shall
establish
a
priority
ranking
for
such
waters,
taking
into
account
the
severity
of
the
pollution
and
the
uses
to
be
made
of
such
waters.

(
B)
Each
State
shall
identify
those
waters
or
parts
thereof
within
its
boundaries
for
which
controls
on
thermal
discharges
under
section
301
are
not
stringent
enough
to
assure
protection
and
propagation
of
a
balanced
indigenous
population
of
shellfish,
fish,
and
wildlife.

(
C)
Each
State
shall
establish
for
the
waters
identified
in
paragraph
(
1)(
A)
of
this
subsection,
and
in
accordance
with
the
priority
ranking,
the
total
maximum
daily
load,
for
those
pollutants
which
the
Administrator
identifies
under
section
304(
a)(
2)
as
suitable
for
calculation.
Such
load
shall
be
established
at
a
level
necessary
to
implement
the
applicable
water
quality
standards
with
seasonal
variations
and
a
margin
of
safety
which
takes
into
account
any
lack
of
knowledge
concerning
the
relationship
between
effluent
limitations
and
water
quality.

(
D)
Each
State
shall
estimate
for
the
waters
identified
in
paragraph
(
1)(
B)
of
this
subsection
the
total
maximum
daily
thermal
load
required
to
assure
protection
and
propagation
of
a
balanced,
indigenous
population
of
shellfish,
fish,
and
wildlife..."

Section
303(
d)(
2)
requires
States
to
submit
the
lists
of
water­
quality
limited
waterbodies
and
associated
TMDLs
to
the
EPA
"
from
time
to
time."

"(
2)
Each
State
shall
submit
to
the
Administrator,
from
time
to
time,
with
the
first
submission
not
later
than
one
hundred
and
eighty
days
after
the
date
of
publication
of
the
first
identification
of
pollutants
under
section
304(
a)(
2)(
D),
for
his
approval
the
waters
identified
and
the
loads
established
under
paragraphs
(
1)(
A),
(
1)(
B),
(
1)(
C),
and
(
1)(
D)
of
this
subsection..."

EPA's
Water
Quality
Planning
and
Management
regulation
(
40
CFR
130)
currently
defines
"
from
time
to
time"
as
a
biennial
reporting
requirement
for
submitting
prioritized
lists
of
water­
quality
limited
waters
still
requiring
TMDLs.
The
revised
final
regulation
adopts
a
4­
year
listing
cycle
instead
of
the
biennial
listing
cycle,
starting
with
the
listing
required
for
2002.
4
TMDLs
are
required
for
303(
d)­
listed
waterbodies
when
other
Federal,
State
and
local
controls
will
not
lead
to
the
achievement
of
water
quality
standards.
TMDLs
provide
a
rational
method
for
weighing
competing
water
quality
concerns
and
developing
an
integrated
strategy
for
point
and
nonpoint
sources.
TMDLs
encourage
a
holistic
view
of
water
quality
problems
considering
all
contributions
and
the
in
stream
water
quality
and
provides
a
method
to
allocate
those
contributions
so
that
water
quality
standards
will
be
met.

Section
305(
b)(
1)
of
the
CWA
requires
States
in
their
biennial
water
quality
assessment
reports
to
estimate
the
costs
and
benefits
of
achieving
water
quality
standards,
specifically:

"(
D)
an
estimate
of
(
i)
the
environmental
impact,
(
ii)
the
economic
and
social
costs
necessary
to
achieve
the
objective
of
this
Act
in
such
State,
(
iii)
the
economic
and
social
benefits
of
such
achievement
and
(
iv)
an
estimate
of
the
date
of
such
achievement;"

2(
b)
USE
/
USERS
OF
THE
DATA
The
Watershed
Branch
of
AWPD
uses
the
information
submitted
under
Section
303(
d)
to
track
State
progress
in
preparing
TMDLs
for
water­
quality
limited
waterbodies
still
requiring
TMDLs.
Consistent
with
the
requirements
of
Section
303(
d),
the
Watershed
Branch
of
AWPD
and
its
Regional
counterparts
review
the
Section
303(
d)
lists
submitted
by
the
States
to
review
whether
they
comply
with
the
requirements
of
the
statute
and
EPA's
regulations
and
reflect
an
accurate
State­
by­
State
accounting
of
waterbodies
not
meeting
water
quality
standards
(
WQS)
after
the
application
of
technology­
based
controls.
Also
as
required
by
Section
303(
d),
EPA
reviews
TMDLs
developed
and
submitted
by
the
States
to
determine
their
technical
sufficiency
and
whether
they
otherwise
comply
with
the
requirements
of
Section
303(
d)
and
the
EPA
regulations.

AWPD
uses
the
biennial
305(
b)
reports
as
a
principal
information
source
to
prepare
the
National
Water
Quality
Inventory
Report
to
Congress.
The
Office
of
Water
uses
the
Report
to
Congress
to
target
persistent
and
emerging
water
quality
problems
with
new
initiatives
and
to
improve
or
eliminate
ineffective
programs.
5
3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
RESPONDENTS
/
SIC
CODES
The
respondent
community
for
303(
d)
consists
of
50
States,
the
District
of
Columbia,
and
the
five
Territories
(
Puerto
Rico,
the
Virgin
Islands,
Guam,
American
Samoa,
and
the
Northern
Mariana
Islands).
The
SIC
code
for
respondents
is
9511
(
Administration
of
Environmental
Quality
Programs:
Air
and
Water
Resources
and
Solid
Waste
Management).
Although
Indian
Tribes
are
not
exempt
from
303(
d)
requirements,
there
is
not
a
process
currently
in
place
to
designate
them
for
this
purpose.
Further,
very
few
Tribes
have
established
water
quality
standards,
and
EPA
is
currently
in
the
process
of
preparing
standards
where
they
are
needed.
Therefore,
we
assume
that
there
would
no
burden
to
Indian
Tribes
over
the
period
covered
by
this
ICR.

The
respondent
community
for
305(
b)
consists
of
50
States,
the
District
of
Columbia,
the
five
Territories
(
Puerto
Rico,
the
Virgin
Islands,
Guam,
American
Samoa,
and
the
Northern
Mariana
Islands)
and
3
River
Basin
Commissions
(
the
Ohio
River
Valley
Sanitation
Commission,
the
Delaware
River
Basin
Commission,
and
the
Interstate
Sanitation
Commission
have
jurisdiction
over
basins
that
lie
in
multiple
States).
The
SIC
code
for
respondents
is
9511
(
Administration
of
Environmental
Quality
Programs:
Air
and
Water
Resources
and
Solid
Waste
Management).
Indian
Tribes
are
exempt
from
the
305(
b)
reporting
requirement,
and
so
no
burden
is
estimated
for
them
in
this
ICR.

3(
b)
INFORMATION
REQUESTED
Data
Items
Consistent
with
Section
303(
d)(
1),
States
submit
to
EPA
for
review
and
approval/
disapproval
action
a
list
of
waterbodies
not
attaining
standards
after
the
application
of
technology­
based
controls.
The
statute
requires
States
to
establish
a
priority
ranking
for
these
waterbodies
taking
into
account
the
severity
of
the
pollution
problems
and
the
designated
uses
of
each
waterbody.
In
conformance
with
the
CWA,
States
apply
individual
approaches
to
assign
priority
to
the
order
in
which
TMDLs
will
be
established
for
each
identified
waterbody.

Consistent
with
Section
303(
d)(
2),
States
establish
TMDLs
for
waterbodies
not
meeting
water
quality
standards
as
a
result
of
pollutant
discharges.
A
TMDL
is
a
written,
quantitative
assessment
of
water
quality
problems
and
contributing
pollutant
sources.
It
specifies
the
amount
that
pollutant
loadings
need
to
be
reduced
for
the
waterbody
to
attain
water
quality
standards
and
allocates
pollutant
load
reductions
among
sources
in
a
watershed.
Section
303(
d)
requires
States
to
submit
TMDLs
to
EPA
for
review
and
approval/
disapproval
action.

Consistent
with
Section
305(
b)(
1)(
D),
States
must
provide
in
their
biennial
water
quality
reports
an
estimate
of
the
environmental
impact,
the
benefits
and
economic
and
social
costs
of
achieving
the
CWA
goals
in
the
State,
and
an
estimate
of
the
date
when
the
State
will
achieve
the
goals.
In
previous
ICRs,
EPA
has
recognized
that
this
information
may
not
be
readily
available
due
to
the
complexities
of
the
analysis
involved.
Therefore,
respondents
provide
information
(
to
the
extent
possible)
on
the
costs
of
pollution
control
activities,
capital
investment
in
municipal
and
industrial
facilities
(
including
the
cost
of
operating
these
facilities),
and
the
costs
of
administering
State
and
local
water
pollution
control
activities.
Respondents
also
provide,
if
possible,
6
information
on
the
beneficial
actions
taken
to
maintain
or
improve
water
quality
conditions.
As
a
Term
of
Clearance
for
the
ICR
for
the
current
305(
b)
and
303(
d)
programs
covering
the
period
March
1999
through
April
2003,
OMB
has
required
that
an
estimate
be
made
in
this
ICR
of
the
burden
associated
with
estimating
costs
and
benefits.
This
ICR
estimates
the
burden
that
would
be
associated
with
a
more
significant
activity
than
EPA
has
previously
expected
or
estimated.

Respondent
Activities
The
burden
associated
with
the
current
program
was
already
included
in
the
approved
ICR
(
Number
1560.05)
for
the
period
March
1999
through
April
2003.
Further,
the
final
revisions
to
the
regulations
do
not
require
the
collection
of
any
additional
data
beyond
the
current
program.

The
revised
regulations
include
four
additional
tasks
associated
with
the
development
of
303(
d)
lists
as
follows:

1.
Revise
the
Methodology
for
Setting
Priorities.
The
current
program
already
requires
that
priorities
be
set
for
listed
waterbodies.
The
revised
regulation
requires
that
listed
waterbodies
be
grouped
into
4
Parts
(
1­
4).
Only
Part
1
waterbodies
(
those
impaired
by
pollutants)
require
TMDLs
and
these
must
have
high,
medium
and
low
priorities
set
for
them.
Any
additional
public
participation
costs
related
to
this
are
included
in
task
3
below.
This
is
a
one­
time
burden
that
would
not
be
included
in
future
ICRs.

2.
Establish
a
Schedule.
Lists
must
include
schedules
for
establishing
the
required
TMDLs
over
the
next
10
years,
replacing
the
existing
requirement
to
target
only
those
TMDLs
that
will
be
completed
within
the
next
2
years.
However,
EPA
will
only
review
and
approve
the
schedule
for
those
TMDLs
that
are
expected
to
be
completed
within
the
next
4
years.
Any
additional
public
participation
costs
related
to
this
are
included
in
task
3
below.
The
initial
effort
to
establish
these
schedules
is
included
in
this
ICR.
The
burden
needed
to
revise
these
schedules
in
future
periods
is
expected
to
be
lower
than
estimated
for
this
ICR.

3.
Additional
Public
Participation.
A
State's
listing
methodology
must
be
subject
to
public
review
and
submitted
to
EPA
by
April
1
two
years
prior
to
the
listing
year.
In
addition,
there
may
be
a
need
for
additional
public
participation
regarding
the
other
revisions
to
the
State's
listing
program
resulting
from
the
revised
regulation.
The
additional
public
participation
is
estimated
to
be
most
significant
for
the
period
covered
by
this
ICR
because
this
will
be
the
public's
first
opportunity
to
review
any
changes
resulting
from
the
revised
regulations.
However,
the
additional
public
participation
in
future
periods
resulting
from
the
revised
regulations
is
expected
to
be
much
less
than
the
amount
estimated
for
the
period
covered
in
this
ICR.

4.
New
Format
for
the
Listing
Methodology.
A
State's
listing
methodology
must
be
presented
in
a
specific,
new
format.
The
cost
of
adopting
the
new
format
is
a
onetime
burden
that
would
not
be
included
in
future
ICRs.

The
revised
regulations
include
two
additional
tasks
associated
with
the
development
of
TMDLs:
7
1.
Implementation
Plans.
TMDLs
must
include
an
implementation
plan
providing
a
framework,
in
a
level
of
detail
appropriate
to
the
circumstances,
for
actions
needed
to
implement
the
TMDL
and
achieve
and
maintain
WQS.

2.
Written
Response
to
Public
Comments.
The
revised
regulations
require
that
TMDLs
include
a
written
summary
of
public
comments
and
the
response
to
them.

These
additional
burdens
are
incurred,
to
varying
degrees,
with
every
TMDL
that
is
developed.
These
are
burdens
that
are
additional
to
that
already
required
for
the
development
of
TMDLs
under
the
current
program.

The
current
program
already
requires
the
development
of
TMDLs
for
impaired
waterbodies.
The
burden
associated
with
developing
TMDLs
is
not
attributable
to
the
revised
regulations.
However,
estimates
for
the
burden
of
developing
TMDLs
under
the
current
program
have
not
been
included
in
previous
ICRs,
and
so
this
ICR
includes
an
estimate
of
that
burden.
The
tasks
for
developing
a
TMDL
under
the
current
program
include:

1.
Watershed
characterization,

2.
Modeling
and
analysis,

3.
Allocation
analysis,

4.
Development
of
TMDL
document
for
public
review,

5.
Public
outreach,

6.
Formal
public
participation
and
response
7.
Contingency
for
planning,
tracking,
legal
support,
extra
outreach,
etc.

The
burden
associated
with
these
tasks
under
the
current
program
is
estimated
in
this
ICR,
both
for
individual
TMDLs,
as
well
as
for
the
total
number
of
TMDLs
that
may
be
submitted
during
the
period
covered
by
this
ICR.

The
current
program
also
requires
that
the
305(
b)
biennial
water
quality
reports
include
an
estimate
of
the
environmental
impact,
the
benefits
and
economic
and
social
costs
of
achieving
the
CWA
goals
in
the
State,
and
an
estimate
of
the
date
when
the
State
will
achieve
the
goals.
In
previous
ICRs,
EPA
has
recognized
that
this
information
may
not
be
readily
available
due
to
the
complexities
of
the
analysis
involved.
Therefore,
respondents
provide
information
(
to
the
extent
possible)
on
the
costs
of
pollution
control
activities,
capital
investment
in
municipal
and
industrial
facilities
(
including
the
cost
of
operating
these
facilities),
and
the
costs
of
administering
State
and
local
water
pollution
control
activities.
Respondents
also
provide,
if
possible,
information
on
the
beneficial
actions
taken
to
maintain
or
improve
water
quality
conditions.
As
a
Term
of
Clearance
for
the
ICR
for
the
current
305(
b)
and
303(
d)
programs
covering
the
period
March
1999
through
April
2003,
OMB
has
required
that
an
estimate
be
made
in
this
ICR
of
the
burden
that
would
be
associated
with
all
States
estimating
costs
and
benefits
for
achieving
WQS.
This
ICR
estimates
the
burden
consistent
with
respondents'
current
practice,
as
well
as
the
effort
that
would
be
consistent
with
applying
the
data
and
methodologies
that
have
been
developed
for
this
purpose
in
8
recent
years.
This
ICR
estimates
the
burden
to
the
Agency
of
providing
States
with
data,
methods,
templates
and
workshops
for
use
in
estimating
costs
and
benefits
(
consistent
with
Section
305(
b)(
1)(
D)),
and
the
burden
to
States
of
applying
this
guidance
to
improve
their
estimates.

This
ICR
does
not
include
the
reduction
in
respondent
burden
resulting
from
the
final
regulations'
adoption
of
a
4­
year
303(
d)
listing
cycle
instead
of
the
current
2­
year
303(
d)
listing
cycle
because
the
savings
(
although
substantial
over
time)
would
likely
not
be
realized
for
the
period
covered
by
this
ICR.
9
4.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4(
a)
AGENCY
ACTIVITIES
The
Agency's
burden
for
the
current
TMDL
program
and
for
the
revised
regulations
has
already
been
included
in
the
current
approved
ICR
for
the
period
March
1999
to
April
2003.
With
regard
to
303(
d)
listings:
EPA
must
review
and
approve
or
disapprove
each
State
list
of
waters
not
meeting
standards
after
the
application
of
technology­
based
controls
and
the
State's
priority
ranking;
EPA
must
also
review
the
State's
listing
methodology,
and
act
on
a
State
list
submission
within
30
days
 
if
EPA
disapproves
a
State
list,
it
has
30
days
to
establish
the
list
for
the
State.
With
regard
to
TMDL
submitted
to
EPA
for
approval:
EPA
must
review
and
act
on
the
TMDL
submissions
within
30
days
of
the
State
submission
and,
if
it
disapproves
a
State
TMDL,
EPA
must
issue
a
TMDL
for
the
State
within
30
days
of
its
disapproval.

In
conformance
with
OMB's
Terms
of
Clearance
for
the
current
approved
ICR,
this
ICR
includes
the
additional
burden
to
the
Agency
associated
with
developing
guidance
for
States
to
use
in
estimating
for
their
305(
b)
biennial
water
quality
reports,
the
benefits
and
economic
and
social
costs
of
achieving
the
CWA
goals
in
the
State.

This
ICR
does
not
include
the
reduction
in
the
Agency's
burden
resulting
from
the
final
regulations'
adoption
of
a
4­
year
303(
d)
listing
cycle
instead
of
the
current
2­
year
303(
d)
listing
cycle
because
the
savings
(
although
substantial
over
time)
would
likely
not
be
realized
for
the
period
covered
by
this
ICR.

4(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
The
States
submit
the
Section
303(
d)
lists
and
priority
rankings
to
the
EPA
Regions.
The
Regions
review
the
State
submissions
and
then
issue
a
decision
document
approving
or
disapproving
the
State
list.
If
EPA
disapproves
a
State
list,
it
must
issue
a
public
notice
identifying
the
waters
it
is
proposing
to
add
to
the
State
list.
The
final
revisions
would
require
the
States
to
also
submit
TMDL
development
schedules
to
EPA
along
with
the
lists
and
priority
rankings.
Under
the
final
revisions,
State
submission
of
listing
methodologies
would
occur
two
years
prior
to
the
deadline
for
submission
of
the
list.
States
must
submit
each
completed
TMDL
to
the
EPA
Regions
for
review
and
action.
If
EPA
disapproves
the
State
submission,
it
must
establish
the
TMDL
for
the
State.

The
States
submit
copes
if
their
final
305(
b)
reports
to
their
Regional
305(
b)
Coordinators,
who
forwards
them
to
Headquarters.
States
also
submit
their
use
support
information
(
and
303(
d)
lists)
in
WBS
compatible
format.
EPA
developed
the
WBS
to
reduce
the
State
burden
associated
with
summarizing
use
support
information
and
to
automate
national
summaries
needed
to
prepare
the
Report
to
Congress.

4(
c)
SMALL
ENTITY
FLEXIBILITY
This
section
is
not
applicable
because
the
respondents
are
States
and
Territories
which
are
not
small
businesses
or
organizations
as
defined
by
the
Regulatory
Flexibility
Act,
5
U.
S.
C.
Sections
601
(
3)
and
(
4).
10
4(
d)
COLLECTION
SCHEDULE
Prior
to
the
revised
regulations,
States
were
required
to
submit
Section
303(
d)
lists
(
including
the
State
listing
methodology
and
priority
ranking
and
targeting)
to
EPA
on
April
1
of
even­
numbered
years.
The
final
revisions
would
require
States
to
submit
303(
d)
lists
on
April
1
every
4
years
starting
in
2002,
but
the
listing
methodology
must
be
submitted
to
EPA
for
review
by
April
1
two
years
prior
to
submission
of
the
listing
 
however,
for
the
list
due
by
April
1,
2002,
the
listing
methodology
must
be
submitted
by
May
1,
2001.

Under
the
proposed
revisions,
States
would
be
required
to
develop
TMDLs
consistent
with
the
State
schedule
and
submit
the
TMDLs
to
EPA
for
review
and
approval/
disapproval
action.

The
schedule
for
305(
b)
submissions
remains
the
same
as
in
the
currently
approved
ICR
for
March
1999
to
April
2003.
The
improved
analyses
of
the
benefits
and
costs
of
attaining
water
quality
standards
should
be
included
in
the
305(
b)
reports
for
2002.
11
5.
NONDUPLICATION,
CONSULTATIONS.
AND
OTHER
COLLECTION
CRITERIA
5(
a)
NONDUPLICATION
The
Section
303(
d)
lists
are
the
only
State­
by­
State
public
accounting
and
ranking
of
waterbodies
not
meeting
water
quality
standards
after
the
application
of
technology­
based
controls.
Under
Section
303(
d),
States
must
submit
the
Section
303(
d)
lists
to
EPA
for
review
and
approval/
disapproval
action.
TMDLs
are
a
unique
and
valuable
tool
that
quantifies
the
maximum
amount
of
a
pollutant
that
a
waterbody
can
absorb
and
still
meet
water
quality
standards.
They
specify
the
amount
that
pollutant
loadings
need
to
be
reduced
for
the
waterbody
to
attain
water
quality
standards
and
allocate
pollutant
load
reductions
among
sources
in
a
watershed.
Section
303(
d)
also
requires
EPA
to
review
and
approve
or
disapprove
State­
submitted
TMDLs.

The
State
305(
b)
reports
are
the
only
direct
vehicle
for
transmitting
water
quality
information
between
States
and
EPA,
or
information
about
the
benefits
and
costs
associated
with
achieving
water
quality.
Without
the
State
305(
b)
reports,
EPA
could
not
report
to
Congress
on
national
attainment
of
beneficial
uses,
as
required
by
the
CWA
5(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
This
is
a
revision
of
an
existing
ICR
for
a
proposed
rulemaking.
In
compliance
with
the
1995
Paperwork
Reduction
Act
(
PRA),
EPA
will
solicit
comments
on
the
proposed
rulemaking
and
the
burden
associated
with
the
rule's
information
collection
requirements
during
the
normal
public
comment
period.

5(
c)
CONSULTATIONS
Before
beginning
to
develop
the
proposed
revisions
to
the
regulations,
EPA
convened
a
Federal
Advisory
Committee
to
make
recommendations
for
improving
the
efficiency
and
effectiveness
of
listing
and
TMDL
development.
The
TMDL
FACA
Committee
was
composed
of
20
members
with
diverse
backgrounds,
including
State
and
local
government,
industry,
agriculture,
forestry,
and
environmental
advocacy.
Over
one
and
one­
half
years,
the
TMDL
FACA
Committee
held
six
meetings
at
locations
throughout
the
country.
These
meetings
were
open
to
the
public
and
most
included
public
comment
sessions.
The
TMDL
FACA
Committee
focused
its
deliberations
on
four
broad
issue
areas:
identification
and
listing
of
waterbodies;
development
and
approval
of
TMDLs;
EPA
management
and
oversight;
and
science
and
tools.
On
July
28,
1998,
the
TMDL
FACA
Committee
submitted
its
final
report
to
EPA
containing
more
than
100
consensus
recommendations
for
changes
and
improvements
to
listing
and
TMDL
development.
EPA
carefully
reviewed
the
TMDL
FACA
Committee's
consensus
recommendations
and
incorporated,
in
whole
or
in
part,
many
of
those
recommendations
into
the
proposed
revisions.

EPA
has
received
numerous
comments
on
the
proposed
revisions
to
the
Water
Quality
Planning
and
Management
Regulation
and
has
given
these
careful
consideration.
This
ICR
fully
reflects
the
final
revisions
to
the
rule.
In
addition,
this
ICR
also
reflects
public
comment
on
the
proposed
ICR
(
approved
for
March
1999
to
April
2003)
by
including
an
estimate
of
the
burden
to
States
for
preparing
analyses
of
the
benefits
and
costs
of
attaining
WQS
as
required
under
section
305(
b).

5(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
12
As
indicated
earlier,
the
final
revisions
change
the
two­
year
listing
cycle
to
a
four­
year
listing
cycle,
resulting
in
substantial
reductions
in
burden
over
time
to
both
States
and
the
Agency.
However,
these
are
not
reflected
in
this
ICR,
because
savings
will
not
accrue
during
the
period
covered
by
this
ICR.

5(
e)
GENERAL
GUIDELINES
The
proposed
activities
(
i.
e.,
submission
by
the
States
and
review
by
EPA
of
Section
303(
d)
lists
and
TMDLs)
do
not
include
any
information
collection
activities
that
exceed
the
Paperwork
Reduction
Act­
imposed
guidelines
contained
in
5
CFR
1320.6.

!
Information
is
not
collected
more
often
than
quarterly.

!
Responses
are
not
required
in
less
than
30
days.

!
Respondents
are
not
required
to
submit
more
than
one
original
and
two
copies
of
any
document.

!
The
collection
does
not
provide
for
renumeration
of
respondents.

!
The
collection
does
not
require
records
to
be
kept
for
more
than
three
years.

!
The
collection
is
not
in
conjunction
with
a
statistical
survey.

!
Provisions
for
small
businesses
and
other
small
entities
are
appropriate.

!
Confidentiality
is
protected.

!
The
collection
does
not
require
submission
of
information
in
a
format
other
than
that
in
which
it
is
customarily
maintained.

5(
f)
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
(
i)
Confidentiality
Information
collected
through
the
proposed
activities
is
not
confidential
because
all
respondents
are
State
agencies,
Territorial
agencies,
and
Tribes
working
entirely
in
a
public
forum.

(
ii)
Sensitive
Questions
The
proposed
information
collection
activities
do
not
request
information
of
a
sensitive
nature
from
the
State
respondents.
13
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
The
respondent
burden
is
calculated
in
Worksheet
1
(
based
on
the
more
detailed
information
provided
in
Attachments
A,
B
and
C).

The
average
additional
burden
associated
with
the
revised
303(
d)
rule
requirements
is
estimated
to
be
6,497
hours
per
respondent,
and
the
total
annual
burden
for
all
56
respondents
is
estimated
to
be
363,845
hours.
This
estimate
does
not
include
any
of
the
savings
that
will
accrue
to
respondents
in
future
years
resulting
from
the
Agency's
adoption
of
a
4­
year
303(
d)
listing
cycle
instead
of
the
current
2­
year
303(
d)
listing
cycle.

The
average
current
burden
associated
with
developing
TMDLs
under
the
current
303(
d)
program
is
estimated
to
be
68,577
hours
per
respondent,
and
the
total
annual
burden
for
all
56
respondents
is
estimated
to
be
3,840,332
hours
The
average
current
burden
associated
with
developing
benefit­
cost
information
for
the
305(
b)
biennial
reports
is
estimated
to
be
45
hours,
and
the
total
annual
burden
for
all
59
respondents
is
estimated
to
be
2,655
hours.

The
average
potential
additional
burden
associated
with
developing
improved
benefit­
cost
information
for
the
305(
b)
biennial
reports
is
estimated
to
be
621
hours
per
respondent,
and
the
total
annual
potential
additional
burden
for
all
59
respondents
is
estimated
to
be
36,639
hours.

6(
b)
ESTIMATING
RESPONDENT
COSTS
Respondent
costs
are
also
calculated
in
Worksheet
1.

The
average
additional
cost
associated
with
the
revised
303(
d)
rule
requirements
is
estimated
to
be
$
252,676
per
respondent,
and
the
total
annual
cost
for
all
56
respondents
is
estimated
to
be
$
14,149,932.
This
estimate
does
not
include
any
of
the
savings
that
will
accrue
to
respondents
in
future
years
resulting
from
the
Agency's
adoption
of
a
4­
year
303(
d)
listing
cycle
instead
of
the
current
2­
year
303(
d)
listing
cycle.

The
average
current
cost
associated
with
developing
TMDLs
under
the
current
303(
d)
program
is
estimated
to
be
$
2,666,975
per
respondent,
and
the
total
annual
cost
for
all
56
respondents
is
estimated
to
be
$
149,350,512.

The
average
current
cost
associated
with
developing
benefit­
cost
information
for
the
305(
b)
biennial
reports
is
estimated
to
be
$
1,750,
and
the
total
annual
cost
for
all
59
respondents
is
estimated
to
be
$
103,253.

The
average
potential
additional
cost
associated
with
developing
improved
benefit­
cost
information
for
the
305(
b)
biennial
reports
is
estimated
to
be
$
24,151
per
respondent
and
the
total
annual
potential
additional
cost
for
all
59
respondents
is
estimated
to
be
$
1,424,891.
14
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
Agency
burden
and
costs
for
the
current
and
revised
303(
d)
and
305(
b)
programs
were
included
in
the
Agency's
approved
ICR
Number
1560.05.
The
Agency's
additional
burden
for
preparing
information
and
guidance
for
States
to
develop
improved
analyses
of
the
benefits
and
costs
of
attaining
water
quality
standards
are
estimated
in
Attachment
B
and
summarized
in
Worksheet
2.
The
Agency's
additional
burden
is
estimated
to
be
2,323
hours
annually
over
the
period
for
this
ICR
representing
an
annual
cost
of
$
100,000.

6(
d)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
/
MASTER
TABLE
(
i)
Respondent
Tally
(
all
respondents)

Total
Annual
Burden
for
the
revised
303(
d)
rule
=
363,845hrs/
yr
Total
Annual
Cost
for
the
revised
303(
d)
rule
=
$
14,149,932
/
yr
Total
Annual
Burden
for
current
program
TMDL
development
=
3,840,332
hrs/
year
Total
Annual
Cost
for
the
current
program
TMDL
development
=
$
149,350,512
/
yr
Total
Annual
Burden
for
the
current
305(
b)
BC
Analysis
=
2,655
hrs/
yr
Total
Annual
Cost
for
the
current
305(
b)
BC
Analysis
=
$
103,253
/
yr
Total
Potential
Annual
Burden
for
new
305(
b)
BC
Analysis
=
36,639
hrs/
yr
Total
Potential
Annual
Cost
for
new
305(
b)
BC
Analysis
=
$
1,424,891
/
yr
(
ii)
Agency
Tally
Total
Annual
Burden
=
2,323
hours
per
year
Total
Annual
Costs
=
$
100,000
per
year
6(
e)
REASONS
FOR
CHANGE
IN
BURDEN
As
explained
above,
EPA
is
finalizing
revisions
to
the
303(
d)
regulations
which
would
increase
the
burden
to
States
for
preparing
303(
d)
lists.
EPA's
recently
approved
request
for
information
collection
authority
for
the
period
March
1999
through
April
2003
was
based
on
the
burden
to
States
of
the
current
303(
d)
listing
program
and
did
not
include
consideration
of
the
impact
of
the
revised
regulations
(
however,
the
additional
burden
to
the
Agency
of
the
revised
regulations
was
included).

In
addition,
previous
ICRs
did
not
include
estimates
for
the
burden
associated
with
developing
TMDLs.
This
ICR
includes
the
additional
burden
that
the
revised
regulation
imposes
regarding
the
development
of
TMDLs,
as
well
as
the
burden
under
the
current
program
associated
with
development
of
TMDLs.

Finally,
this
ICR
also
includes
the
additional
burden
in
preparing
biennial
reports
pursuant
to
305(
b)
that
would
be
associated
with
an
increased
effort
by
States
(
and
the
corresponding
effort
by
the
Agency)
to
provide
estimates
of
the
costs
and
benefits
of
achieving
water
quality
standards.
15
The
current
program
has
always
required
the
development
of
these
estimates,
but
this
ICR
includes
the
burden
that
would
be
associated
with
States
estimating
costs
and
benefits
in
a
manner
that
is
consistent
with
the
data
and
methodologies
that
have
been
developed
for
this
purpose
in
recent
years.

6(
e)
i.
Increased
Burden
For
303(
d)
Listing
The
Agency's
report,
Analysis
of
the
Incremental
Cost
of
Proposed
Revisions
To
The
TMDL
Program
Regulations
(
December
21,
1998),
provided
a
detailed
analysis
and
explanation
of
the
additional
burden
to
States
that
would
result
if
the
proposed
revisions
are
promulgated.
The
Agency's
revised
analysis
for
the
final
revisions
improves
upon
these
estimates,
reflecting
the
availability
of
additional
data
and
more
detailed
analysis.
As
detailed
in
the
final
EA,
for
the
listing­
related
requirements,
States
would
bear
a
one­
time
transition
cost
that
would
be
incurred
for
the
2002
listing,
and
a
smaller
ongoing
cost
for
subsequent
listings
as
follows:

Incremental
Effort
Per
Respondent
Per
Listing
Due
to
the
Revised
Regulations
Activity
Description
of
the
Regulatory
Revision
Affecting
the
Burden
to
Respondents
for
this
ICR
Change
in
Burden
Per
Respondent
(
hours)

2002
Listing
Subsequent
Listings
(
2006,
2010,
etc)

1
Revise
the
methodology
for
setting
priorities
80
0
2
Prepare
a
schedule
for
developing
TMDLs
8
­
16*
8
3
Additional
public
participation
480
80
4
Adopt
new
format
for
the
listing
methodology
40
0
Total
Additional
Hours
Per
Listing:
612.6
108
*
The
burden
ranges
from
8
hours
for
the
24
States
that
already
have
schedules
to
16
hours
for
the
32
States
that
don't
already
have
schedules.

Over
the
3­
year
period
of
this
ICR,
the
2002
listing
will
be
submitted.
The
additional
effort
associated
with
subsequent
listings
will
not
occur
until
late
2003
(
for
the
2006
listing).
Therefore,
the
only
additional
burden
for
this
ICR
will
be
for
the
2002
listing,
amounting
to
an
average
of
612.6
hours
per
respondent.
To
annualize
this
effort
over
the
period
of
the
ICR,
we
divide
by
three
to
get
204.2
hours
per
year.

This
ICR
does
not
include
any
allowance
for
the
reduced
burden
associated
with
the
revised
regulation's
adoption
of
a
4­
year
listing
cycle
instead
of
the
current
2­
year
listing
cycle
 
over
time,
the
savings
associated
skipping
a
listing
cycle
every
2
years
exceeds
the
additional
burden
from
the
other
revisions
that
increase
the
burden
of
preparing
303(
d)
lists.

6(
e)
ii.
Increased
303(
d)
Burden
For
Developing
TMDLs
If
all
respondents
develop
TMDLs
at
a
steady
pace
in
accordance
with
the
schedules
they
committed
to
in
their
1998
303(
d)
lists,
approximately
13,238
TMDLs
would
be
developed
over
the
period
for
this
ICR,
as
estimated
in
Attachment
A.
This
represents
nearly
1/
3
of
the
total
16
number
of
TMDLs
that
are
expected
to
be
developed
for
the
impaired
waterbodies
identified
in
the
1998
303(
d)
lists.
As
shown
in
detail
in
Exhibit
A­
6b
of
Attachment
A,
the
two
additional
TMDL
development
tasks
(
development
of
an
implementation
plan
and
written
response
to
public
comments)
required
by
the
revised
regulation
result
in
an
average
increased
burden
of
78
hours
per
TMDL,
taking
into
consideration
the
extent
that
respondents
would
perform
these
tasks
anyway
in
the
absence
of
the
revised
requirements.
While
the
number
of
TMDLs
that
are
expected
to
be
developed
by
different
respondents
varies
widely
over
the
period
of
this
ICR,
the
average
number
of
TMDLs
across
all
respondents
would
be
approximately
79
TMDLs
per
respondent
per
year
representing
an
average
annual
burden
of
6,293
hours
per
respondent
per
year.

6(
e)
iii.
Current
303(
d)
Program
Burden
For
Developing
TMDLs
As
shown
in
detail
in
Attachment
A,
the
current
program
requires
the
development
of
TMDLs,
generally
requiring
the
completion
of
7
tasks:
watershed
characterization,
modeling
and
analysis,
allocation
analysis,
development
of
the
TMDL
document
for
public
review,
public
outreach,
formal
public
participation
and
response,
and
contingency
task
covering
planning,
tracking,
legal
support,
and
extra
outreach.
As
estimated
in
detail
in
Attachment
A,
the
average
burden
associated
with
developing
a
TMDL
is
870
hours.
If
all
respondents
develop
TMDLs
at
a
steady
pace
in
accordance
with
the
schedules
they
committed
to
in
their
1998
303(
d)
lists,
approximately
13,238
TMDLs
would
be
developed
over
the
period
for
this
ICR,
as
estimated
in
Attachment
A.
While
the
number
of
TMDLs
that
are
expected
to
be
developed
by
different
respondents
varies
widely
over
the
period
of
this
ICR,
the
average
number
of
TMDLs
across
all
respondents
would
be
approximately
79
TMDLs
per
respondent
per
year
representing
an
average
annual
burden
of
68,577
hours
per
respondent
per
year.

6(
e)
iv.
305(
b)
Burden
For
Estimating
the
Costs
and
Benefits
of
Achieving
WQS
The
Agency
will
develop
new
detailed
guidance,
information
and
tools
for
States
that
will
assist
them
in
improving
their
benefit­
cost
analyses,
while
minimizing
the
additional
cost
of
doing
so.
As
shown
in
detail
in
Attachment
B
and
summarized
in
Worksheet
1,
the
additional
burden
for
States
to
apply
the
new
guidance
depends
on
the
level
of
detail
and
sophistication
that
the
States
choose
to
provide
as
well
as
factors
such
as
the
number
of
impaired
waterbodies
in
the
State,
the
State's
diversity
of
water
resources,
and
the
intensity
of
use
of
those
resources.
The
additional
cost
to
States
of
applying
the
new
guidance
is
estimated
to
result
in
an
average
increase
in
State
burden
of
621
hours
annually
in
addition
to
the
estimated
average
current
burden
of
45
hours
for
the
States'
current
efforts
to
prepare
this
information.

6(
f)
BURDEN
STATEMENT
The
projected
average
additional
cost
associated
with
the
revised
303(
d)
rule
requirements
is
estimated
to
be
$
252,677
per
respondent,
and
the
total
annual
cost
for
all
56
respondents
is
estimated
to
be
$
14,149,932
­­
this
estimate
does
not
include
any
of
the
savings
that
will
accrue
to
respondents
in
future
years
resulting
from
the
Agency's
adoption
of
a
4­
year
303(
d)
listing
cycle
instead
of
the
current
2­
year
303(
d)
listing
cycle.
The
average
current
cost
associated
with
developing
TMDLs
under
the
current
303(
d)
program
is
estimated
to
be
$
2,666,973
per
respondent,
and
the
total
annual
cost
for
all
56
respondents
is
estimated
to
be
$
149,350,512.
The
average
current
cost
associated
with
developing
benefit­
cost
information
for
the
305(
b)
biennial
reports
is
estimated
to
be
$
1,750,
and
the
total
annual
cost
for
all
59
respondents
is
estimated
to
be
17
$
103,253.
The
average
potential
additional
cost
associated
with
developing
improved
benefit­
cost
information
for
the
305(
b)
biennial
reports
is
estimated
to
be
$
25,901
per
respondent
(
depending
on
the
level
of
detail
and
sophistication
of
the
analyses),
and
the
total
annual
potential
additional
cost
for
all
59
respondents
is
estimated
to
be
$
1,424,891.
Overall,
the
burden
associated
with
the
new
requirements
amounts
to
a
total
of
400,484
hours
at
a
cost
of
$
15,574,823
and
the
burden
associated
with
the
current
program
requirements
amounts
to
a
total
of
3,842,987
hours
at
a
cost
of
$
149,453,765.
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
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
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
C.
F.
R.
Part
9
and
48
C.
F.
R.
Chapter
15.

Send
comments
on
EPA's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
OP
Regulatory
Information
Division;
U.
S.
Environmental
Protection
Agency
(
2137);
401
M
Street,
S.
W.;
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.;
Washington,
D.
C.
20503,
marked
"
Attention:
Desk
Officer
for
EPA."
Include
the
ICR
number
in
any
correspondence.

PART
B:
COLLECTIONS
OF
INFORMATION
EMPLOYING
STATISTICAL
METHODS
This
section
is
not
applicable
because
no
statistical
procedures
are
employed
for
the
information
collection.
18
Worksheet
1:
Average
Annual
Burden
and
Cost
Estimates
for
Respondents
Information
Collection
Activity
A
Number
of
Respondents
B
Ave
Annual
Burden
Per
Respondent
(
hours)
(
A)
x(
B)
=
C
Total
Annual
Respondent
Burden
(
hours)
D
Loaded
Hourly
Labor
Cost1
(
2000
$)
(
C)
x(
D)
=
E
Annual
Cost
(
2000
$)

Revised
303(
d)
Rule
­
new
requirements:

Requirements
for
listing2
56
204.2
11,435
$
38.89
$
444,707
Requirements
for
TMDL
development3
56
6,293.0
352,410
$
38.89
$
13,705,225
Revised
303(
d)
Rule
Annual
Subtotal
56
6,497.2
363,845
$
38.89
$
14,149,932
Current
303(
d)
Rule
TMDL
Development4
56
68,577.4
3,840,332
$
38.89
$
149,350,512
TOTAL
303(
d)
BURDEN
56
75,074.6
4,204,177
$
38.89
$
163,500,444
305(
b)
benefit­
cost
analysis5
Current
practice
59
45
2,655
$
38.89
$
103,253
Improved
BC
analysis
at
the
State
level
59
621
36,639
$
38.89
$
1,424,891
TOTAL
305(
B)
BC
ANALYSIS
BURDEN
59
666
39,294
$
38.89
$
1,528,144
TOTAL
BURDEN
FOR
THIS
ICR
­­­
75,741
4,243,471
$
38.89
$
165,028,588
1
Source:
As
explained
in
detail
in
Attachment
C,
the
respondents'
fully
loaded
labor
rates
are
the
"
average"
State
fully
loaded
labor
rates
(
March,
2000)
estimated
in
the
Gap
Analysis
Effort's
State
Water
Quality
Management
Workload
Model,
which
represent
the
consensus
estimate
of
18
States,
3
EPA
regions,
8
Associations,
and
included
input
from
an
additional
14
States.
This
fully
loaded
hourly
labor
rate
represents
the
total
cost
for
obtaining
an
hour's
worth
of
work,
and
includes:
direct
salary
paid,
paid
or
accrued
vacation,
paid
or
accrued
sick
leave,
cost
of
other
fringe
benefits
(
e.
g.,
health,
pension,
etc.),
general
training,
indirect
expenses
such
as
professional
support
(
e.
g.,
clerical,
accounting,
supervisory,
etc.),
office
space,
utilities,
telephone
service,
equipment
(
e.
g.,
fax
machines,
basic
computing
needs
such
as
hardware
and
software,
etc.),
etc..
This
rate
does
not
include
the
costs
associated
with
computer
maintenance,
support
or
periodic
upgrades
of
hardware
or
software.

2
Source:
See
the
summary
table
in
6(
e)
i.

3
Source:
See
the
detailed
discussion
in
Attachment
A
and
the
summary
in
6(
e)
ii.

4
Source:
See
the
detailed
discussion
in
Attachment
A
and
the
summary
in
6(
e)
iii.

5
Source:
See
the
detailed
discussion
in
Attachment
B
and
the
summary
in
6(
e)
iv.
19
Worksheet
2:
Annual
Agency
Burden
and
Cost
Estimates
Information
Collection
Activity
A
Total
Annual
Burden
(
hours)
B
Loaded
Hourly
Labor
Cost1
(
2000
$)
(
A)
x(
B)
=
C
Annual
Cost
(
2000
$)

Revised
303(
d)
Rule
­
current
&
new
requirements
NA2
Not
Applicable2
305(
b)
benefit­
cost
analysis
guidance3
Current
review
and
revision
of
guidance4
NA2
$
43.05
Not
Applicable2
Development
of
additional
guidance
for
States5
2,323
$
43.05
$
100,000
TOTAL
305(
b)
BC
ANALYSIS
GUIDANCE
2,323
$
43.05
$
100,000
1
Source:
As
explained
in
detail
in
Attachment
C,
the
Agency's
fully
loaded
labor
rates
are
based
on
the
current
salary
rate
of
a
Federal
Grade
10
Step
7
and
an
overhead
rate
of
110%,
as
used
in
all
the
previous
ICRs
for
the
305(
b)
and
303(
d)
programs.

2
The
Agency's
burden
for
both
the
current
303(
d)
and
305(
b)
programs
and
the
revised
303(
d)
requirements
were
already
included
in
the
recently
approved
ICR
Number
1560.05,
approved
April
5,
2000.

3
Estimates
are
discussed
in
detail
in
Attachment
B.

4
Routine
review
and
revision
of
guidance
regarding
benefit­
cost
analysis
for
305(
b).

5
The
cost
of
the
Agency's
additional
burden
to
develop
new
guidance
that
would
minimize
the
additional
efforts
required
by
States
to
improve
their
estimates
of
the
benefits
and
costs
of
achieving
WQS
is
estimated
at
approximately
$
300,000
which
would
be
incurred
during
2000
and
2001.
Over
the
3­
year
period
of
this
ICR,
the
annual
cost
would
be
$
100,000
which
translates
into
a
burden
of
2,323
hours
annually.
ATTACHMENT
A
303(
d):
Hours
Burden
for
Developing
TMDLs
1Environomics
and
Tetra
Tech,
Inc.,
Estimate
of
the
National
Cost
to
Develop
TMDLs,
prepared
for
the
U.
S.
EPA,
Office
of
Wetland,
Oceans
and
Watersheds.
In
preparation.

2This
does
not
include
costs
for
monitoring
before,
during
or
after
the
TMDL
development
process.
It
is
assumed
that
the
TMDL
is
developed
using
available
data
or
that
the
State
will
identify
monitoring
needs
to
support
TMDL
development
to
be
collected
under
other
program
activities
(
i.
e.,
statewide
monitoring,
106).
The
cost
to
States
of
implementing
TMDLs
is
also
not
included.

Attachment
A­
1
THE
HOURS
BURDEN
FOR
DEVELOPING
TMDLS
This
Attachment
provides
the
basis
for
estimating
the
burden
associated
with
the
current
303(
d)
program's
requirement
for
developing
TMDLs,
as
well
as
the
added
burden
associated
with
the
revised
rules
additional
requirements.
The
discussion
is
organized
as
follows:

A.
Tasks
for
developing
TMDLs
B.
Overview
of
approach
and
sources
for
estimates
C.
Unit
burden
estimates
for
individual
tasks
D.
Number
of
TMDLs
to
be
developed
and
their
characteristics
E.
Total
burden
for
developing
TMDLs
A.
Tasks
for
Developing
TMDLs
EPA
is
in
the
process
of
estimating
the
States'
total
program
burden
for
developing
TMDLs1
(
the
"
TMDL
Development
Cost
Analysis").
The
methodology
for
the
TMDL
Development
Cost
analysis
was
developed
in
consultation
with
State,
EPA
and
contractor
representatives
and
was
validated
by
comparing
the
resulting
estimated
costs
with
the
known
actual
costs
for
131
TMDLs.
The
tasks
that
were
identified
for
developing
TMDLs
represent
the
full
range
of
activities
needed
for
the
current
program2:

1.
Watershed
characterization,

2.
Modeling
and
analysis,

3.
Allocation
analysis,

4.
Development
of
TMDL
document
for
public
review,

5.
Public
outreach,

6.
Formal
public
participation
and
response
7.
Contingency
for
planning,
tracking,
legal
support,
extra
outreach,
etc.
3Environomics,
Analysis
of
the
Incremental
Cost
of
Final
Revisions
to
the
Water
Quality
Planning
and
Management
Regulation
and
the
National
Pollution
Discharge
Elimination
System
Program,
prepared
for
the
U.
S.
EPA,
Office
of
Wetland,
Oceans
and
Watersheds,
In
preparation.

Attachment
A­
2
EPA's
Economic
Analysis
of
the
final
rule3
(
the
"
EA")
estimates
the
burden
associated
with
the
additional
tasks
required
by
the
revised
Water
Quality
Planning
and
Management
regulations:

a.
Development
of
an
implementation
plan
b.
Written
response
to
public
comments.

This
ICR
draws
upon
both
studies
(
the
TMDL
Development
Cost
Analysis
and
the
EA)
to
develop
the
respondents'
burden
estimates
for
this
ICR
for
developing
TMDLs
under
the
current
program
and
the
additional
burden
associated
with
the
revised
rule.

B.
Overview
of
Approach
and
Sources
for
Estimates
1.
Estimating
Unit
Costs
The
approach
developed
in
the
TMDL
Development
Cost
Analysis
is
used
in
this
ICR
to
estimate
the
additional
cost
associated
with
the
new
provisions
that
affect
the
cost
of
developing
TMDLs.
There
are
two
key
considerations
to
accurately
estimating
the
unit
costs
for
any
task
associated
with
developing
TMDLs:

°
unit
costs
can
vary
widely
across
TMDLs,
and
°
there
are
efficiencies
associated
with
developing
multiple
TMDLs
at
once.

Each
of
these
is
discussed
below.

a.
Wide
variability
in
unit
costs
For
this
analysis,
estimates
of
unit
costs
are
based
upon
the
judgment
of
State
and
contractor
personnel
that
are
familiar
with
the
tasks
involved.
However,
it
can
be
difficult
to
estimate
an
"
average"
cost
for
any
given
TMDL
development
task,
because
the
effort
associated
with
developing
a
TMDL
can
span
a
large
range
for
a
number
of
reasons,
including:
the
size
of
the
geographic
area
and
type
of
waterbody,
the
number
and
type
of
sources,
the
types
of
pollutants,
the
sophistication
of
the
modeling
and
analysis
tools,
the
level
of
public
interest,
etc.
Rather
than
attempt
to
estimate
an
appropriate
"
average"
that
takes
all
of
this
into
account,
it
is,
it
is
easier
to
develop
more
accurate
estimates
of
typical
unit
costs
for
three
categories
of
TMDLs
representing
three
levels
of
difficulty:

°
Level
1
represents
relatively
simple
TMDLs
with
limited
public
interest,

°
Level
2
represents
mid­
range
TMDLs,
and
°
Level
3
represents
TMDLs
requiring
detailed
and
sophisticated
analysis
as
well
as
being
the
subject
of
greater
public
interest.
4The
Agency's
Gap
Analysis
Effort,
which
developed
the
Water
Quality
Management
Workload
Model
(
version
3.0,
March
2000)
is
the
result
of
a
joint
effort
by
EPA,
States
and
other
interested
stakeholders
to
develop
a
tool
for
estimating
the
State's
resource
needs
for
State
water
quality
management
programs.
The
Gap
Model
is
designed
to
allow
States
to
enter
the
specifics
of
their
own
circumstances,
but
includes
"
defaults"
for
all
estimates
that
were
judged
to
be
representative
of
the
"
average,"
"
median,"
or
"
typical"
State.
The
Gap
defaults
were
based
on
the
consensus
of
a
focus
group
of
participants
including
representatives
from
18
States,
3
EPA
regions,
8
associations,
and
included
consideration
of
comments
from
an
additional
14
States.
However,
the
Gap
model
does
not
take
efficiencies
into
account,
which
can
represent
significant
savings
in
the
cost
of
developing
TMDLs.

Attachment
A­
3
This
approach
facilitates
developing
more
accurate
estimates,
communication
of
the
estimates,
and
their
validation.
The
approach
of
categorizing
TMDLs
by
three
levels
of
difficulty
was
also
adopted
by
the
Gap
Water
Quality
Management
Workload
Model4
for
its
TMDL
workload
module.

Using
this
approach
requires
that
three
unit
cost
estimates
be
developed
for
any
task.
In
addition,
it
is
necessary
to
estimate
the
portion
of
TMDL
workload
that
is
represented
by
each
level.

b.
Efficiencies
associated
with
developing
multiple
TMDLs
at
once
States
can
reduce
the
cost
of
developing
TMDLs
by
logically
grouping
TMDLs.
In
some
cases,
savings
result
because
a
task
can
be
performed
at
the
same
time
for
all
of
the
TMDLs,
while
in
other
cases
savings
result
because
the
work
performed
for
the
first
TMDL
(
or
waterbody)
can
be
applied
to
subsequent
TMDLs
(
or
waterbodies).
When
estimating
the
cost
associated
with
the
revisions
affecting
TMDL
development,
we
included
consideration
of
three
specific
types
of
cost
efficiencies:

°
Submissions
with
multiple
TMDLs
involving
more
than
one
waterbody.
Increasingly,
States
are
using
a
watershed
approach
to
developing
TMDLs
in
which
TMDLs
for
logical
groupings
of
waterbodies
are
clustered
together
into
a
single
submission.
To
estimate
this
efficiency,
we
assume
that
there
are
no
efficiencies
for
the
first
waterbody
in
a
clustered
submission,
but
that
there
are
efficiencies
for
the
remaining
waterbodies
in
a
clustered
submission.
Examples
of
tasks
that
would
experience
efficiencies
include
holding
a
joint
public
hearing
and
reusing
parts
of
the
TMDL
document
(
or
providing
a
single
submission).

°
Submissions
for
a
single
waterbody
involving
multiple
TMDLs.
For
the
impaired
waterbodies
identified
in
the
1998
303(
d)
lists,
about
42%
require
the
development
of
multiple
TMDLs.
Increasingly,
States
are
also
developing
together
all
of
the
TMDLs
for
waterbodies
that
require
more
than
one
TMDL.
To
estimate
this
efficiency,
we
assume
that
there
are
no
efficiencies
for
the
first
TMDL
in
a
clustered
submission,
but
that
there
are
efficiencies
for
the
remaining
TMDLs
for
the
waterbody.
Examples
of
tasks
that
would
experience
efficiencies
include
holding
a
joint
public
hearing
and
reusing
parts
of
the
TMDL
document
(
or
providing
a
single
submission
for
all
of
the
TMDLs).

°
Multiple
TMDLs
for
a
waterbody
involving
related
pollutants.
Further
efficiencies
are
realized
when
modeling
multiple
metals
or
multiple
nutrients
since
similar
models,
analytical
techniques
and
chemical
processes
are
considered.
Once
the
analysis
has
been
performed
for
the
first
metal
(
or
the
first
nutrient),
the
additional
effort
to
perform
the
analysis
for
additional
metals
(
or
nutrients)
is
only
a
fraction
of
the
initial
effort.
We
assume
that
there
are
no
efficiencies
for
the
first
metal
or
nutrient
TMDL,
but
that
there
would
be
efficiencies
for
the
modeling,
analysis
and
allocation
tasks
for
subsequent
metal
or
nutrient
TMDLs.
Attachment
A­
4
All
of
these
types
of
efficiencies
would
apply
to
the
additional
tasks
for
TMDL
development
required
in
the
revised
rule,
as
well
as
to
the
tasks
that
are
already
required
for
TMDL
development
in
the
current
program.
Information
regarding
the
extent
to
which
efficiencies
might
occur
and
their
magnitude
is
provided
in
the
forthcoming
EA
as
well
as
the
forthcoming
TMDL
Development
Cost
Analysis.

2.
Estimating
the
extent
to
which
current
practice
already
meets
these
requirements
To
determine
the
additional
burden
that
results
from
the
revised
regulations
(
or
the
requirements
of
the
current
program),
it
is
necessary
to
estimate
the
extent
to
which
current
practice
already
meets
these
requirements.
This
was
estimated
in
the
EA
for
the
final
rule
based
on
a
sample
of
466
approved
or
recently
submitted
TMDLs.
For
these
TMDLs,
about
22.6%
of
the
cost
of
these
new
requirements
were
met
anyway
even
in
the
absence
of
the
revised
rule.
Therefore,
it
is
reasonable
and
appropriate
to
attribute
77.4%
of
the
cost
of
these
requirements
to
the
final
revisions
(
to
reflect
the
fact
that
some
States
would
meet
these
requirements
to
varying
degrees
even
if
the
new
provisions
were
not
issued),
as
was
done
in
the
Agency's
analysis
of
the
final
rule.

3.
Estimating
the
resulting
national
cost.

A
key
input
are
the
nine
unit
costs
(
i.
e.,
cost
per
TMDL)
for
each
task
associated
with
developing
a
TMDL.
The
nine
unit
costs
represent
different
combinations
of
the
3
Levels
of
difficulty
and
the
3
types
of
efficiencies.
The
EA
for
the
final
rule
provides
the
unit
costs
for
the
2
new
TMDL
development
requirements,
while
the
TMDL
Development
Cost
Analysis
provides
the
unit
costs
for
the
7
TMDL
development
tasks
of
the
current
program.
These
unit
costs
in
combination
the
expected
number
of
TMDLs
to
be
developed
over
the
period
covered
by
this
ICR
provides
the
basis
for
estimating
the
respondent
burden.
These
are
summarized
next.

C.
Unit
Burden
Estimates
For
Individual
Tasks
1.
The
Unit
Burden
When
There
Are
No
Efficiencies
From
the
TMDL
Development
Cost
Analysis,
the
unit
costs
for
the
7
tasks
for
TMDL
Development
under
the
current
program,
assuming
no
efficiencies
whatsoever,
are
shown
on
the
next
page
in
Exhibit
A­
1a,
the
additional
2
tasks
required
by
the
revised
rule
are
shown
in
Exhibit
A­
1b,
and
the
combined
burden
is
shown
in
Exhibit
A­
1c.
These
unit
costs
apply
to
the
first
TMDL
for
a
waterbody
that
has
not
been
clustered
with
other
waterbodies.

The
estimates
shown
in
Exhibit
A­
1c
compare
closely
with
the
default
estimates
in
the
Gap
State
Water
Quality
Workload
Model
for
the
cost
of
"
typical"
Level
1,
2
and
3
TMDLs
(
although
the
individual
tasks
are
grouped
and
defined
differently,
both
this
ICR
and
the
Gap
model
cover
the
same
full
range
of
activities
needed
to
develop
TMDLs):
the
ICR's
estimate
for
Level
1
is
16%
higher
than
the
Gap
default,
the
ICR's
estimate
for
Level
2
is
the
same
as
the
Gap
default,
and
the
ICR's
estimate
for
Level
3
is
within
2%
of
the
Gap
default.
However,
the
Gap
Model
does
not
include
the
significant
efficiencies
that
can
be
achieved
by
clustering
multiple
TMDLs
as
described
earlier.
The
efficiencies
for
the
tasks
associated
with
the
current
program
are
estimated
and
verified
in
the
TMDL
Development
Cost
Analysis,
and
the
efficiencies
for
the
additional
tasks
associated
with
the
revised
rule
are
estimated
in
the
EA
as
summarized
next.
Attachment
A­
5
Exhibit
A­
1a
Hours
of
Effort
for
the
Current
Program
to
Develop
a
TMDL
at
3
Levels
of
Difficulty
Task
Level
1
Level
2
Level
3
Low
High
Low
High
Low
High
1.
Watershed
Characterization
160
200
200
240
240
320
2.
Modeling
and
Analysis
24
80
80
480
480
960
3.
Allocation
Analysis
8
40
40
80
80
120
4.
Develop
TMDL
Doc
for
Public
Review
160
240
240
480
480
640
5.
Public
Outreach
160
240
240
320
320
480
6.
Formal
public
participation/
response
40
80
80
240
240
480
7.
Tracking,
planning,
legal
support,
etc.
84
160
160
316
316
514
Subtotal
for
Range
636
1,040
1,040
2,156
2,156
3,514
Subtotal
for
Average
838
1,598
2,835
Exhibit
A­
1b
Hours
of
Effort
for
the
New
Tasks
to
Develop
a
TMDL
at
3
Levels
of
Difficulty
Task
Level
1
Level
2
Level
3
Low
High
Low
High
Low
High
a.
Development
of
an
implementation
plan
20
120
120
160
160
240
b.
Written
response
to
public
comments
10
40
40
80
80
200
Subtotal
for
Range
30
160
160
240
240
440
Subtotal
for
Average
95
200
340
Exhibit
A­
1c
Combined
Hours
of
Effort
for
All
Tasks
to
Develop
a
TMDL
at
3
Levels
of
Difficulty
Task
Level
1
Level
2
Level
3
Low
High
Low
High
Low
High
I.
Current
Program
Tasks
636
1,040
1,040
2,156
2,156
3,514
II.
New
Tasks
30
160
160
240
240
440
Subtotal
for
Range
666
1,200
1,200
2,396
2,396
3,954
Subtotal
for
Average
933
1,798
3,175
Attachment
A­
6
2.
Efficiencies
Associated
With
Developing
Multiple
TMDLs
At
Once
Exhibit
A­
2
summarizes
the
efficiencies
that
are
estimated
in
the
TMDL
Development
Cost
Analysis
and
the
EA
for
all
of
the
TMDL
development
tasks:

Exhibit
A­
2
Incremental
Unit
Costs
of
Successive
TMDLs
for
Waterbodies
where
Efficiencies
Exist
Tasks
%
of
Unit
Cost
of
Initial
TMDL
Multiple
Waterbodies
or
Multiple
TMDLs
for
a
Waterbody
Multiple
Metals
or
Nutrients
for
Multiple
TMDLs
for
a
Waterbody
current
program
1.
watershed
characterization
25%
25%

2.
modeling
&
analysis
100%
25%

3.
allocation
analysis
100%
25%

4.
develop
TMDL
document
25%
25%

5.
public
outreach
25%
25%

6.
formal
public
participation
25%
25%

7.
tracking,
planning,
etc
25%
25%

new
requirement
s
a.
implementation
plan
50%
15%

b.
written
response
to
comments
25%
25%

Using
the
implementation
plan
task
as
an
example,
if
3
TMDLs
are
developed
for
a
waterbody,
the
first
TMDL
bears
the
full
cost
of
the
preparation
of
the
implementation
plan,
but
the
cost
for
each
of
the
next
two
implementation
plans
is
50%
of
the
full
cost.
The
resulting
total
cost
is
equivalent
to
the
cost
of
2
plans
(
100%
+
50%
+
50%)
instead
of
3
plans,
and
the
resulting
savings
overall
for
preparing
implementation
plans
for
all
of
the
TMDLs
for
the
waterbody
in
this
example
is
33%.
If
the
3
TMDLs
were
for
one
nutrient
and
two
metals,
there
would
be
further
efficiencies
associated
with
the
second
metal,
and
the
resulting
total
cost
would
be
equivalent
to
1.65
plans
(
100%
+
50%
+
15%),
with
a
resulting
overall
savings
of
45%.

3.
Resulting
Unit
Burden
Taking
Efficiencies
Into
Account
Exhibits
A­
3a
through
A­
3d
on
the
next
page
show
the
resulting
burden
for
the
tasks
associated
with
the
current
TMDL
program,
taking
different
types
of
efficiencies
into
account.
Exhibit
A­
4a
through
A­
4d
that
follows
show
the
resulting
burden
for
the
new
tasks
associated
with
the
revised
regulations,
taking
different
types
of
efficiencies
into
account.
Attachment
A­
7
Exhibit
A­
3a
Current
Program:
Unit
Costs
to
Develop
a
TMDL
for
a
Single
Waterbody
with
1
Cause
%
Effort
Cost
Component
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

100%
modeling
&
analysis,
and
allocation
76
340
820
100%
all
remaining
tasks
762
1,258
2,015
Total
838
1,598
2,835
Exhibit
A­
3b
Current
Program:
Unit
Costs
to
Develop
TMDLs
for
Additional
Clustered
Waterbodies
or
Causes
%
Effort
Cost
Component
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

100%
modeling
&
analysis,
and
allocation
76
340
820
25%
all
remaining
tasks
191
315
504
Total
267
655
1,324
Exhibit
A­
3c
Current
Program:
Unit
Costs
to
Develop
TMDLs
for
Additional
Related
Causes
(
Multiple
Metals
or
Combinations
of
Nutrients/
BOD/
DO/
Ammonia)

%
Effort
Cost
Component
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

25%
modeling
&
analysis,
and
allocation
19
85
205
25%
all
remaining
tasks
191
315
504
Total
210
400
709
Exhibit
A­
3d
Current
Program:
Summary
of
Unit
Costs
to
Develop
TMDLs
Taking
Efficiencies
Into
Account
Extent
to
Which
Efficiencies
Are
Realized
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

A.
TMDLs
requiring
full
cost
 
the
only
cause
or
the
first
cause
838
1,598
2,835
B.
TMDLs
at
partial
cost
 
multiple
causes
for
a
water
or
clustered
waters
267
655
1,324
C.
TMDLs
with
additional
modeling
efficiencies
for
related
pollutants
210
400
709
Attachment
A­
8
Exhibit
A­
4a
New
Requirements:
Unit
Costs
to
Develop
a
TMDL
for
a
Single
Waterbody
with
1
Cause
%
Effort
Cost
Component
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

100%
implementation
plan
70
140
200
100%
written
response
to
public
comments
25
60
140
Total
95
200
340
Exhibit
A­
4b
New
Requirements:
Unit
Costs
to
Develop
TMDLs
for
Additional
Clustered
Waterbodies
or
Causes
%
Effort
Cost
Component
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

50%
implementation
plan
35
70
100
25%
written
response
to
public
comments
6
15
35
Total
41
85
135
Exhibit
A­
4c
New
Requirements:
Unit
Costs
to
Develop
TMDLs
for
Additional
Related
Causes
(
Multiple
Metals
or
Combinations
of
Nutrients/
BOD/
DO/
Ammonia)

%
Effort
Cost
Component
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

15%
implementation
plan
11
21
30
25%
written
response
to
public
comments
6
15
35
Total
17
36
65
Exhibit
A­
4d
New
Requirements:
Summary
of
Unit
Costs
to
Develop
TMDLs
Taking
Efficiencies
Into
Account
Extent
to
Which
Efficiencies
Are
Realized
Level
1
(
hrs)
Level
2
(
hrs)
Level
3
(
hrs)

A.
TMDLs
requiring
full
cost
 
the
only
cause
or
the
first
cause
95
200
340
B.
TMDLs
at
partial
cost
 
multiple
causes
for
a
water
or
clustered
waters
41
85
135
C.
TMDLs
with
additional
modeling
efficiencies
for
related
pollutants
17
36
65
Attachment
A­
9
Following
are
several
examples
of
how
these
costs
would
apply
to
different
situations.
To
simplify
comparison
among
these
examples,
all
of
them
are
for
Level
2
TMDLs
only,
and
they
only
involve
the
cost
of
the
new
requirements
as
summarized
in
Exhibit
A­
4d:

°
Single
Level
2
TMDL.
The
combined
effort
would
be
200
hours
as
shown
in
Exhibit
A­
4d.

°
A
cluster
of
5
waterbodies,
each
with
a
single
Level
2
TMDL.
The
combined
effort
would
be
540
hours
(
200
+
4
x
85).

°
A
cluster
of
2
waterbodies:
one
waterbody
with
3
Level
2
TMDLs
and
one
waterbody
with
2
Level
2
TMDLs,
no
modeling
efficiencies.
The
combined
effort
would
be
540
hours
(
200
+
4
x
85).

°
A
cluster
for
1
waterbody
with
5
Level
2
TMDLs,
no
modeling
efficiencies.
The
combined
effort
would
be
540
hours
(
200
+
4
x
85).

°
A
cluster
for
1
waterbody
with
5
Level
2
TMDLs,
all
for
metals
(
or
all
for
nutrients)
with
modeling
efficiencies.
The
combined
effort
would
be
344
hours
(
200
+
4
x
36).

°
A
cluster
for
1
waterbody
with
5
Level
2
TMDLs,
composed
of
1
pollutant
with
no
efficiencies,
2
metals
with
efficiencies,
and
2
nutrients
with
efficiencies.
The
combined
effort
would
be
442
hours
(
200
+
85
+
36
+
85
+
36).

In
order
to
apply
the
unit
costs
for
the
current
program
from
Exhibit
A­
3d
and
for
the
new
requirements
from
Exhibit
A­
4d,
we
need
to
estimate
the
total
number
of
TMDLs
that
will
be
developed
in
each
of
the
nine
combinations
of
complexity
and
efficiency.

D.
Number
of
TMDLs
To
Be
Developed
and
Their
Characteristics
Based
on
a
detailed
analysis
of
1998
303(
d)
data
base,
the
EA
estimates
the
pace
and
characteristics
of
the
TMDL
workload
associated
with
the
causes
of
impairment
identified
in
the
1998
303(
d)
lists.
If
States
meet
the
schedules
they
committed
to
in
their
1998
303(
d)
submissions
by
developing
TMDLs
uniformly
over
the
course
of
their
schedules,
then
over
the
period
of
this
ICR
(
the
second
half
of
2000,
all
of
2001
and
2002,
and
the
first
half
of
2003),
States
may
complete
an
estimated
13,238
TMDLs,
representing
an
average
of
78.8
TMDLs
per
State
per
year.
The
distribution
of
these
TMDLs
among
the
different
combinations
of
complexity
and
efficiency,
as
estimated
in
the
EA,
are
summarized
in
Exhibit
A­
5:

Exhibit
A­
5
Total
Number
of
TMDLs
Scheduled
for
Submission
from
July
2000
to
June
2003
Extent
to
Which
Efficiencies
Are
Realized
Total
Level
1
Level
2
Level
3
A.
TMDLs
requiring
full
cost
 
the
only
cause
or
the
first
cause
3,583
1,615
1,074
894
B.
TMDLs
at
partial
cost
 
multiple
causes
for
a
water
or
clustered
waters
8,343
3,757
2,502
2,084
C.
TMDLs
with
additional
modeling
efficiencies
for
related
pollutants
1,312
586
395
331
Total
13,238
5,958
3,971
3,309
Attachment
A­
10
Attachment
A­
11
E.
Total
Burden
for
Developing
TMDLs
Combining
the
number
of
TMDLs
in
Exhibit
A­
5
with
the
unit
burdens
for
the
current
program
requirements
for
developing
TMDLs
in
Exhibit
A­
3d
results
in
the
total
burden
associated
with
the
current
program
of
11,520,996
hours
(
averaging
68,577
hours
per
respondent
per
year)
as
shown
in
Exhibit
A­
6a:

Exhibit
A­
6a
Current
Program:
Total
Hours
Burden
for
Developing
TMDLs
July
2000
to
June
2003
Extent
to
Which
Efficiencies
Are
Realized
Total
Level
1
Level
2
Level
3
A.
TMDLs
requiring
full
cost
 
the
only
cause
or
the
first
cause
5,604,112
1353370
1716252
2534490
B.
TMDLs
at
partial
cost
 
multiple
causes
for
a
water
or
clustered
waters
5,401,145
1003119
1638810
2759216
C.
TMDLs
with
additional
modeling
efficiencies
for
related
pollutants
515,739
123060
158000
234679
Total
11,520,996
2479549
3513062
5528385
Combining
the
number
of
TMDLs
in
Exhibit
A­
5
with
the
unit
burdens
for
the
new
program
requirements
for
developing
TMDLs
in
Exhibit
A­
4d
results
in
the
total
burden
of
1,365,929
hours
as
shown
in
Exhibit
A­
6b.
However,
this
does
not
yet
reflect
the
extent
to
which
States
currently
meet
some
of
these
requirements
already
and
therefore
are
not
considered
a
burden
attributable
to
the
revised
rule.
As
analyzed
in
detail
in
the
EA,
States
already
currently
incur
approximately
22.6
%
of
the
effort
associated
with
these
requirements,
and
therefore
this
burden
is
not
attributable
to
the
revised
rule.
As
shown
in
Exhibit
A­
6b,
the
additional
burden
associated
with
the
new
requirements
is
1,057,229
hours,
averaging
6,293
hours
per
respondent
per
year.

Exhibit
A­
6b
New
Requirements:
Total
Hours
Burden
for
Developing
TMDLs
July
2000
to
June
2003
Extent
to
Which
Efficiencies
Are
Realized
Total
Level
1
Level
2
Level
3
A.
TMDLs
requiring
full
cost
 
the
only
cause
or
the
first
cause
672,185
153,425
214,800
303,960
B.
TMDLs
at
partial
cost
 
multiple
causes
for
a
water
or
clustered
waters
648,047
154,037
212,670
281,340
C.
TMDLs
with
additional
modeling
efficiencies
for
related
pollutants
45,697
9,962
14,220
21,515
subTotal
1,365,929
317,424
441,690
606,815
less
the
extent
to
which
this
burden
would
be
incurred
in
the
absence
of
the
new
requirements
(
308,700)

Total
1,057,229
ATTACHMENT
B
305(
b):
Hours
Burden
for
Analysis
of
Benefits
and
Costs
of
Attaining
WQS
Attachment
B­
1
HOURS
BURDEN
FOR
ANALYSIS
OF
BENEFITS
AND
COSTS
OF
ATTAINING
WQS
Section
305(
b)(
1)(
D)
of
the
CWA
requires
States
in
their
biennial
water
quality
assessment
to
estimate
the
benefits
and
costs
of
achieving
water
quality
standards
by
estimating:

"
i.
the
environmental
impact,

ii.
the
economic
and
social
costs
necessary
to
achieve
the
objective
of
this
Act
in
such
State,

iii.
the
economic
and
social
benefits
of
such
achievement
and
iv.
an
estimate
of
the
date
of
such
achievement."

In
previous
ICRs,
EPA
recognized
that
this
information
may
not
be
readily
available
due
to
the
complexities
of
the
analyses
involved.
Therefore,
respondents
provide
information
(
to
the
extent
possible)
on
the
costs
of
pollution
control
activities,
capital
investment
in
municipal
and
industrial
facilities
(
including
the
cost
of
operating
these
facilities),
and
the
costs
of
administering
State
and
local
water
pollution
control
activities.
Respondents
also
provide,
if
possible,
information
on
the
beneficial
actions
take
to
maintain
or
improve
water
quality
conditions.
States
have
provided
varying
degrees
of
information
in
their
biennial
reports
regarding
the
costs
and
benefits
of
achieving
WQS.

As
a
Term
of
Clearance
for
the
ICR
for
the
current
305(
b)
and
303(
d)
programs
covering
the
period
March,
1999
through
April
2003
(
ICR
Number
1560.05),
OMB
has
required
that
an
estimate
be
made
in
this
ICR
of
the
burden
associated
with
estimating
benefits
and
costs
assuming
that
the
Agency
would
provide
additional
guidance
to
States
to
assist
them
in
preparing
the
analyses.
Therefore,
this
ICR
estimates
the
burden
that
would
be
associated
with
a
more
significant
activity
than
EPA
has
previously
expected
or
that
States
have
previously
provided.

The
Agency
will
develop
guidance
to
assist
States
to
develop
better
and
more
comprehensive
estimates
of
the
benefits
and
costs
of
attaining
water
quality
standards
(
BC
Analysis).
The
bulk
of
the
effort
required
for
both
the
Agency
and
for
the
States
generally
occurs
for
the
next
biennial
report
required
in
2002.
Thereafter,
the
effort
required
to
update
this
information
for
future
biennial
reports
may
be
only
25%
of
the
effort
associated
with
initially
developing
this
information
for
the
2002
report.

A.
Guidance
to
be
Developed
by
the
Agency
The
Agency
will
develop
guidance
for
the
States
that
will
assist
them
in
improving
their
BC
Analyses,
while
minimizing
the
additional
burden
of
doing
so.
The
Agency
plans
to
target
the
guidance
so
that
can
be
applied
by
a
mid­
level
analyst
(
consistent
with
the
fully
loaded
hourly
rates
in
Attachment
C).

The
guidance
for
performing
benefits
analysis
will
likely:

°
include
a
list
of
data
elements
required
to
conduct
a
benefits
analysis,
and
include
suggested
sources
and
techniques
for
each,

°
present
the
results
of
a
meta­
analysis
of
existing
valuation
studies,
with
recommended
values
for
different
water
body
types,
expected
changes
in
water
quality,
and
categories
of
benefits,
Attachment
B­
2
°
discuss
how
and
when
to
apply
different
values,
will
provide
default
values
where
there
is
no
basis
or
need
to
tailor
the
estimates
to
location­
specific
characteristics,
and
will
describe
circumstances
in
which
it
is
important
to
develop
location­
specific
estimates,
and
°
include
a
user­
friendly
spreadsheet
model
that
implements
the
proffered
analysis,
and
makes
it
easy
to
substitute
use­
selected
values
to
tailor
the
model
to
specific
States
and
to
conduct
sensitivity
analyses
to
address
key
uncertainties.

The
guidance
for
preparing
cost
analysis
will
provide
information
regarding
cost,
including
data
sources,
default
values
and
worksheets.

The
Agency
anticipates
that
States
will
have
the
opportunity
to
participate
in
the
review
of
draft
guidance
materials
to
help
ensure
that
the
guidance
and
the
tools
it
provides
are
useful
and
practical
from
the
States'
perspective.
If
appropriate,
the
Agency
may
provide
additional
training
materials
and/
or
workshops
to
further
assist
States
in
using
the
guidance.

The
Agency
estimates
that
the
cost
of
providing
this
additional
guidance
would
be
$
300,000.
Over
the
three
year
period
of
the
ICR,
the
annual
cost
would
be
$
100,000
which
translates
into
a
burden
of
2,323
hours
annually
(
at
the
fully
loaded
hourly
rate
of
$
43.05
as
discussed
in
Attachment
C).

B.
State
Burden
Associated
with
Applying
the
New
Guidance
The
new
guidance
will
assist
States
in
preparing
improved
BC
Analyses
for
their
States.

The
effort
for
benefits
analysis
for
specific
States
depends
on
several
factors,
including
the
number
of
impaired
waterbodies,
differences
in
the
physical
characteristics
of
these
waterbodies,
differences
in
aquatic
habitat
types,
designated
uses,
and
recreational
importance
as
well
the
quality
of
existing
information
about
these
waterbodies.
For
a
small
state
with
a
small
number
of
the
303(
d)
listed
waters,
low
intensity
of
waterbased
recreation,
and
nonexistent
or
negligible
commercial
fishing/
shell
fishing,
the
cost
of
benefits
assessment
at
the
state
and
watershed
levels
may
not
be
very
different.
States
with
diverse
water
resources
and
intensive
uses
of
these
resources
(
i.
e.,
intensive
water­
based
recreation)
such
as
coastal
states
are
likely
to
incur
larger
costs
due
to
complexity
of
the
benefits
analysis.
The
level
of
effort
associated
with
developing
estimates
at
the
State
level
of
the
benefits
of
attaining
WQS
are
detailed
in
Exhibit
B­
1
on
the
next
page.
As
shown
in
the
exhibit,
the
Agency
estimates
that
the
range
the
burden
associated
with
estimating
benefits
at
the
State
level
ranges
from
432
to
1,224
hours.
Whether
States
undertake
Level
1,
2
or
3
analyses
depends
on
the
State
policy
and
on
the
complexity
of
the
State's
watershed
situations.
Most
coastal
watersheds
and
those
Great
Lakes
watersheds
would
be
more
likely
to
involve
Level
3
analyses,
while
inland
watersheds
would
be
more
likely
to
be
adequately
addressed
by
Level
1
and
2
analyses.

We
assume
for
this
ICR
that
States
will
undertake
efforts
to
estimate
costs
that
are
similar
to
the
efforts
that
they
apply
to
estimate
benefits,
amounting
to
an
additional
432
to
1,224
hours.

Therefore,
the
total
burden
per
State
associated
is
estimated
to
range
from
864
to
2448
hours
for
the
2002
biennial
report.
For
the
period
of
this
ICR,
we
assume
that
half
the
effort
for
preparing
this
information
for
the
2004
biennial
report
also
is
incurred
 
however,
the
effort
to
update
the
2002
report
is
estimated
to
be
an
additional
25%,
so
that
half
of
this
effort
amounts
to
108
to
306
hours.
Therefore,
the
total
effort
over
the
period
of
this
ICR
ranges
from
972
to
2,754
hours
per
State.
Annualizing
over
the
three
years
results
in
324
to
918
hours
annually
per
State.
To
estimate
the
national
cost,
we
assume
that
the
average
for
the
range
Attachment
B­
3
represents
the
typical
level
of
analysis
across
all
the
59
governmental
units
for
the
purpose
of
estimating
a
national
burden,
resulting
in
an
average
annual
burden
of
621
hours.

For
perspective,
the
Agency's
estimate
(
in
the
approved
ICR)
for
the
average
State's
total
annual
effort
for
305(
b)
is
3,937
hours
(
including
planning,
data
collection,
data
entry,
conducting
assessments,
public
participation,
preparing
the
biennial
report,
etc),
so
that
including
a
more
comprehensive
BC
Analysis
at
the
State
level
roughly
increases
the
average
State's
total
305(
b)
burden
by
16%.

Exhibit
B­
1
Hours
of
Effort
to
Estimate
at
the
State
Level
the
Benefits
of
Attaining
WQS
at
3
Levels
of
Difficulty
Task
Level
1
Level
2
Level
3
Low
High
Low
High
Low
High
1.
Characterize
affected
watersheds
96
120
128
144
160
192
2.
Water
quality
modeling
and
analysis
64
80
96
112
128
144
3.
Assess
ecological
improvements
32
48
56
64
64
72
Assess
recreational
improvements
32
40
56
64
72
88
Assess
changes
in
nearby
property
values
16
24
32
40
48
56
Assess
avoided
cost
of
water
treatment
24
32
48
64
64
80
Assess
other
economic
productivity
benefits
24
32
40
48
40
48
Assess
human
health
benefits
16
24
32
40
40
48
4.
Calibrate
to
local
conditions*
­­­
­­­
­­­
­­­
160
192
5.
Report
writing
72
80
88
96
120
144
6.
Contingency
@
15%
**
56
72
88
104
136
160
Subtotal
for
Range
432
552
664
776
1,032
1,224
Subtotal
for
Average
492
720
1,128
*
interviews
or
pilot
studies
**
Provision
for
additional
data
collection,
analysis,
review,
etc.
Attachment
B­
4
ATTACHMENT
C
Fully
Loaded
Hourly
Labor
Rates
5The
Cadmus
Group,
Inc.,
State
Water
Quality
Management
Workload
Model,
ver
3.0,
prepared
for
the
U.
S.
EPA's
Office
of
Wastewater
Management,
March,
2000.

6The
States
were
Arkansas,
Colorado,
Connecticut,
Delaware,
Georgia,
Illinois,
Maine,
Maryland,
Massachusetts,
Michigan,
New
Jersey,
New
York,
North
Carolina,
Oklahoma,
Oregon,
Texas,
Virginia,
and
Wisconsin.
The
associations
were
American
Clean
Water
Federation
(
ACWF),
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
(
ASIWPCA),
Association
of
State
Wetlands
Managers,
Coastal
States
Organization,
Environmental
Coalition
of
States
(
ECOS),
New
England
Interstate
Water
Pollution
Control
Commission
(
NEIWPCC),
Water
Environment
Federation
(
WEF),
and
the
Wisconsin
Association
of
Lakes.

Attachment
C­
1
FULLY
LOADED
HOURLY
LABOR
RATES
The
federal
and
State
fully
loaded
labor
rates
for
the
year
2000
used
in
this
analysis
were
derived
from:

1)
the
fully
loaded
State
and
federal
labor
rates
used
in
previously
approved
and
draft
Information
Collection
Requests
(
ICRs)
for
the
303(
d)
and
305(
b)
programs,
and
2)
estimates
from
the
Gap
Analysis
Effort
for
the
"
average,"
"
median"
or
"
typical"
fully
loaded
State
labor
rates
developed
in
the
State
Water
Quality
Management
Workload
Model
(
ver
3.0,
March
2000)
5.
This
model
is
the
result
of
a
joint
effort
by
EPA,
States
and
other
interested
stakeholders
to
develop
a
tool
for
estimating
the
States'
resource
needs
for
State
water
quality
management
programs.
The
Gap
Model
is
designed
to
allow
States
to
enter
the
specifics
of
their
own
circumstances,
but
includes
"
defaults"
for
all
estimates
that
were
judged
to
be
representative
of
the
"
average,"
"
median"
or
"
typical"
State.
The
Gap
defaults
were
based
on
the
consensus
of
a
focus
group
of
participants
including
representatives
from
18
States,
3
EPA
regions,
8
associations,
and
included
consideration
of
comments
from
an
additional
14
States.
6
The
definition
of
the
labor
rate,
as
well
as
the
use
of
these
two
sources
for
determining
the
appropriate
labor
rates
for
this
analysis
are
discussed
below.

A.
Fully
loaded
labor
rates
include
all
costs
associated
with
working
hours
A
fully
loaded
hourly
labor
rate
represents
the
total
cost
for
obtaining
an
hour's
worth
of
work.
A
"
fully
loaded"
labor
rate
includes:
direct
salary
paid,
paid
or
accrued
vacation,
paid
or
accrued
sick
leave,
cost
of
other
fringe
benefits
(
e.
g.,
health,
pension,
etc.),
general
training,
indirect
expenses
such
as
professional
support
(
e.
g.,
clerical,
accounting,
supervisory,
etc.),
office
space,
utilities,
telephone
service,
equipment
(
e.
g.,
fax
machines,
basic
computing
needs
such
as
hardware
and
software,
etc.),
etc.

One
way
to
estimate
a
fully
loaded
labor
rate
is
to
develop
an
overhead
rate
which
is
applied
to
an
hourly
salary
rate.
EPA's
previously
approved
ICRs
for
the
303(
d)
and
305(
b)
programs
were
based
on
an
overhead
rate
of
110%
for
both
State
and
federal
personnel
as
applied
the
salary
of
a
Federal
Grade
10,
Step
7
analyst
­­
the
time
period
for
the
currently
approved
ICR
(
ICR
Number
1560.05)
covered
the
period
from
1999
­
2002,
so
that
the
1999
salary
rate
of
$
19.22
applied,
resulting
in
a
fully
loaded
rate
of
$
40.37
per
hour
($
19.22
salary
plus
overhead
of
110%
x
$
19.22).
For
the
time
period
for
this
ICR
(
2000­
2003),
the
2000
federal
General
Schedule
applies:
for
2000,
the
hourly
salary
of
a
Federal
Grade
10,
Step
7
is
$
20.50
so
the
fully
loaded
labor
rate
using
this
approach
would
be
$
43.05.
Attachment
C­
2
Another
way
to
estimate
a
fully
loaded
labor
rate
is
to
estimate
all
of
the
costs
associated
with
an
employee
for
a
year,
and
then
divide
by
the
number
of
hours
worked.
Number
of
hours
worked
is
the
total
hours
in
a
year
(
generally
2080)
less
vacation
time,
sick
leave,
training
time,
etc.
The
Gap
Analysis
Effort
used
this
approach.
In
the
Gap's
Water
Quality
Management
Workload
Model
(
version
3.0,
March
2000),
the
"
average,"
"
median,"
or
"
typical"
working
hours
for
States
was
estimated
to
be
1,800
hours,
and
the
corresponding
fully
loaded
cost
for
the
1,800
hours
was
estimated
to
be
$
70,000
(
including
all
overhead
costs
as
described
above,
but
not
computer
maintenance,
support
or
periodic
upgrades
of
hardware
or
software)
resulting
in
a
fully
loaded
hourly
rate
of
$
38.89/
hour
($
70,000/
1,800
hours).

Both
approaches
are
legitimate
ways
to
estimate
fully
loaded
labor
rates,
and
both
approaches
would
provide
the
same
result
if
they
are
based
on
the
same
estimates
for
salary
and
overhead
costs.

B.
Available
estimates
of
fully
loaded
federal
and
State
labor
rates
Estimates
of
fully
loaded
State
and
federal
labor
rates
are
available
from
ICRs
for
the
305(
b)
and
303(
d)
programs,
and
estimates
for
fully
loaded
State
labor
rates
are
available
from
the
Gap
Water
Quality
Management
Workload
Model,
as
discussed
below.

1.
Estimates
of
fully
loaded
federal
and
State
labor
rates
from
previous
ICRs
As
discussed
earlier,
EPA's
previously
approved
ICRs
were
based
on
an
estimated
overhead
rate
of
110%
for
both
State
and
federal
personnel
as
applied
to
the
"
average"
salary
rate
believed
to
be
an
analyst
with
a
federal
grade
10,
Step
7
or
equivalent.
Previous
draft
ICRs,
using
a
1999
hourly
salary
rate
of
$
19.22,
resulted
in
an
estimated
fully
loaded
rate
of
$
40.37
per
hour.
Using
the
2000
federal
General
Schedule,
the
hourly
salary
of
a
Federal
Grade
10,
Step
7
is
$
20.50
so
the
fully
loaded
labor
rate
using
this
approach
would
be
$
43.05
per
hour.

2.
Estimates
of
fully
loaded
State
labor
rates
from
the
Gap
Analysis
Effort
As
discussed
earlier
in
this
Attachment,
the
defaults
for
the
State
Water
Quality
Management
Workload
Model
(
the
"
Gap
Model"
in
this
report)
are
considered
to
be
the
best
estimate
for
an
"
average,"
"
median"
or
"
typical"
State
for
their
water
quality
management
programs.
This
judgement
was
made
by
a
focus
group
of
participants
that
included
representatives
from
18
States,
3
EPA
regions,
8
Associations,
and
included
comments
from
an
additional
14
States.
The
resulting
fully
loaded
hourly
default
rate
for
the
March,
2000
version
of
the
Gap
Model
is
$
38.89
per
hour.

C.
The
loaded
federal
and
State
salary
rates
used
in
this
ICR
Both
the
federal
and
State
labor
rates
are
for
2000,
which
is
appropriate
for
the
time
period
for
this
ICR
(
2000­
2003).
The
rates
used
in
this
analysis
are
as
follows:

°
Loaded
federal
rate.
We
adopt
the
estimates
in
previously
approved
and
submitted
ICRs
for
this
program:
a
110%
overhead
rate
applied
to
the
hourly
salary
rate
of
the
"
average"
analyst
for
this
program,
a
Federal
Grade
10
Step
7.
Using
the
2000
federal
General
Schedule,
the
hourly
salary
of
a
Federal
Grade
10,
Step
7
is
$
20.50,
so
the
fully
loaded
labor
rate
using
this
approach
would
be
$
43.05.

°
Loaded
State
rate.
We
adopt
the
Gap
model's
default
of
$
38.89/
hr
as
of
March,
2000
for
the
typical
State.
Attachment
C­
3
