Information
Collection
Request
for
the
State
Water
Quality
Program
Management
Gap
Analysis
March
14,
2000
Prepared
by:

The
Cadmus
Group,
Inc.
135
Beaver
St.
Waltham,
MA
02452
Prepared
for:

U.
S.
Environmental
Protection
Agency
Office
of
Wastewater
Management
401
M
Street,
S.
W.
Washington,
D.
C.
20460
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
i
CONTENTS
A.
1
Identification
of
the
Information
Collection
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1
A.
1.
a
Title
of
the
Information
Collection
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1
A.
1.
b
Short
Characterization
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1
A.
2
Need
for
and
Use
of
the
Collection
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2
A.
2.
a
Authority
and
Need
for
the
Collection
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2
A.
2.
b
Practical
Utility/
Users
of
the
Data
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2
A.
3
Nonduplication,
Consultations
and
Other
Collection
Criteria
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4
A.
3.
a
Nonduplication
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4
A.
3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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4
A.
3.
c
Consultations
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4
A.
3.
d
Effects
of
Less
Frequent
Collection
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5
A.
3.
e
General
Guidelines
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5
A.
3.
f
Confidentiality
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6
A.
3.
g
Sensitive
Questions
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6
A.
4
The
Respondents
and
the
Information
Requested
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7
A.
4.
a
Respondents
and
SIC
Codes
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7
A.
4.
b
Information
Requested
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7
(
i)
Data
Items,
Including
Recordkeeping
Requirements
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8
(
ii)
Respondent
Activities
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8
A.
5
The
Information
Collected
 
Agency
Activities,
Collection
Methodology
and
Information
Management
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10
A.
5.
a
Agency
Activities
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10
A.
5.
b
Collection
Methodology
and
Management
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10
A.
5.
c
Small
Entity
Flexibility
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12
A.
5.
d
Collection
Schedule
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13
A.
6
Estimating
the
Burden
and
Cost
of
the
Collection
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14
A.
6.
a
Estimating
Burden
and
Costs
to
the
States
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14
A.
6.
b
Estimating
Agency
Burden
and
Cost
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15
A.
6.
c
Bottom
Line
Burden
Hours
and
Cost
Table
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17
A.
6.
d
Reasons
for
Change
in
Burden
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18
A.
6.
e
Burden
Statement
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18
Attachment
1:
Federal
Register
Notice
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20
Attachment
2:
Burden
and
Cost
Tables
for
State
Water
Quality
Program
Management
Gap
Analysis
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21
Attachment
3:
State
Water
Quality
Program
Management
Gap
Analysis
Activity­
Based
Workload
Model
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24
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
2
PART
A
OF
THE
SUPPORTING
STATEMENT
A.
1
Identification
of
the
Information
Collection
A.
1.
a
Title
of
the
Information
Collection
The
title
of
this
ICR
is
the
Information
Collection
Request
for
the
State
Water
Quality
Program
Management
Gap
Analysis
(
EPA
ICR
Number
1945.01)

A.
1.
b
Short
Characterization
The
Environmental
Protection
Agency
(
EPA),
in
partnership
with
States,
is
conducting
the
State
Water
Quality
Management
Gap
Analysis
(
Gap
Analysis)
to
help
enumerate
current
and
future
funding
needs
and
to
help
identify
innovative
strategies
for
reducing
resource
gaps.
To
gather
preliminary
information
in
a
short
time
frame,
the
Gap
Analysis
was
divided
into
two
phases.
Phase
I
consisted
of
the
development
of
an
initial,
national
estimate
of
the
resource
gap
faced
by
water
quality
management
programs
to
provide
a
general
idea
of
the
magnitude
of
the
resource
gap
faced
by
States.

Phase
II
of
the
Gap
Analysis
involves
developing
a
detailed,
activity­
based
workload
model
to
provide
a
common
framework
and
consistent
methodology
for
States
and
EPA
to
estimate
what
it
costs
the
States
to
meet
the
objectives
of
the
Clean
Water
Act
(
CWA).
In
order
to
complete
the
model,
EPA's
Office
of
Wastewater
Management
(
OWM)
needs
to
gather
data
on
the
resources
needed
by
each
State
for
water
quality
management
activities.

This
is
a
one
time
collection
effort
by
OWM
and
responses
to
this
ICR
are
voluntary.
The
collection
is
necessary
to
develop
a
detailed
activity­
based
workload
model
that
will
provide
an
estimate
of
the
resource
needs
facing
water
quality
management
programs,
both
for
individual
States
and
the
nation.
EPA
will
use
the
collected
information
to
estimate
resource
needs
for
water
quality
management
activities.

This
effort
will
involve
an
estimated
20
Respondents,
requiring
an
average
of
$
7,220
and
180.5
hours
per
Respondent
for
each
Respondent
that
chooses
to
submit
information.
Section
A.
6
Estimating
the
Burden
and
Cost
of
the
Collection,
provides
a
detailed
description
of
the
unit
burden
and
costs
for
this
collection.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
3
A.
2
Need
for
and
Use
of
the
Collection
A.
2.
a
Authority
and
Need
for
the
Collection
EPA
is
collecting
the
information
to
estimate
the
total
State
resources
needed
to
address
specific
water
quality
management
problems
and
meet
the
objectives
of
the
CWA.
This
effort,
supported
by
EPA
and
the
States,
is
necessary
to
develop
strategies
for
better
managing
state
water
quality
programs
implementing
the
CWA.
Responses
to
this
collection
are
voluntary.
The
activity­
based
workload
model
will
provide
an
estimate
of
the
resource
need
and
the
resource
gap,
both
for
individual
States
and
the
nation,
for
water
quality
management
activities.
EPA
will
use
the
information
to
estimate
resource
needs
for
the
management
and
administration
of
the
water
quality
programs
under
33
U.
S.
C.
Section
1251
et.
seq.

A.
2.
b
Practical
Utility/
Users
of
the
Data
The
information
will
be
collected
by
EPA
and
made
available
to
the
States
and
to
the
public
in
accordance
with
the
requirements
of
the
Freedom
of
Information
Act.
EPA
will
use
the
collected
data
to
develop
a
workload­
based
national
estimate
of
the
resources
needed
to
achieve
the
objectives
of
the
CWA.
The
estimates
will
improve
the
Agency's
and
State's
abilities
to
administer
and
manage
water
quality
management
programs.

The
information
that
will
be
collected
from
each
Respondent
will
likely
have
several
secondary
uses,
both
inside
and
outside
of
EPA.
For
example:


States
may
use
the
model
for
workload
planning
and
budgeting.
The
model
will
be
flexible
enough
to
capture
State­
specific
programs
and
approaches.


States
and
EPA
may
use
the
collected
data
to
document
budget
requests.
Similar
models
have
been
developed
for
other
programs
and
State
program
managers
report
that
they
are
excellent
tools
for
explaining
their
budget
to
State
legislatures.


EPA
and
States
may
use
the
data
to
identify
efficiencies
that
can
be
realized
in
State
water
quality
management
programs.
For
example,
as
States
share
pricing
information
for
various
program
activities,
it
may
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
4
become
apparent
that
a
particular
State
has
developed
a
more
efficient
means
of
accomplishing
a
particular
activity.


EPA
and
States
may
use
the
data
to
develop
a
framework
for
prioritization
by
linking
staffing
and
resource
needs
to
watersheds,
which
will
enable
States
to
estimate
specific
environmental
or
economic
benefits
that
might
be
achieved
by
meeting
these
staffing
and
resource
needs.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
5
A.
3
Nonduplication,
Consultations
and
Other
Collection
Criteria
The
following
sections
verify
that
this
information
collection
satisfies
the
Office
of
Management
and
Budget's
(
OMB's)
nonduplication
and
consultation
guidelines.

A.
3.
a
Nonduplication
The
information
will
be
created
by
the
Respondents;
it
does
not
duplicate
information
otherwise
reasonably
accessible
to
EPA.

.
A.
3.
b
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
EPA
published
a
notice
in
the
Federal
Register
(
Attachment
1)
on
January
13,
2000.
The
notice
requested
public
comment
on
this
ICR.
No
comments
were
received.

A.
3.
c
Consultations
EPA
has
consulted
with
several
State
water
quality
management
personnel
on
the
burden
and
cost
estimates
provided
in
this
ICR
including:

New
York
Department
of
Environmental
Conservation,
Texas
Natural
Resource
Conservation
Commission,
and
Wisconsin
Department
of
Natural
Resources.
.
Their
comments
and
suggestions
have
been
carefully
considered
in
the
development
of
this
document.
None
anticipated
any
capital,
start­
up,
or
operation
and
maintenance
costs,
or
any
change
in
record
keeping
practices.

The
following
list
indicates
the
States,
other
interested
stakeholders,
and
the
EPA
Regions
that
EPA
consulted
to
develop
the
workload
model
that
will
be
used
in
this
collection.
Each
of
the
Regions,
States,
organizations,
or
associations
assisted
EPA
with
determining
the
activities
and
the
default
values
for
each
of
the
programs
areas;
the
development
of
the
necessary
linkages
between
the
modules
so
that
the
final
model
covered
all
the
activities
in
State
water
quality
management
programs;
and
reviewing,
commenting
on,
and
testing
the
accuracy,
utility,
and
usability
of
the
model.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
6
States
Connecticut
Department
of
Environmental
Protection
Delaware
Department
of
Natural
Resources
and
Environmental
Control
Georgia
Department
of
Natural
Resources
Illinois
Environmental
Protection
Agency
Maine
Department
of
Environmental
Protection
Maryland
Department
of
Natural
Resources
Massachusetts
Department
of
Environmental
Conservation
Michigan
Department
of
Environmental
Quality
New
Jersey
Department
of
Environmental
Protection
New
York
Department
of
Environmental
Conservation
North
Carolina
Department
of
Environment
and
Natural
Resources
Oklahoma
Department
of
Environmental
Quality
Oregon
Department
of
Environmental
Quality
Texas
Natural
Resource
Conservation
Commission
Wisconsin
Department
of
Natural
Resources
Associations
American
Clean
Water
Federation
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
Environmental
Council
of
States
Water
Environment
Federation
Wisconsin
Association
of
Lakes
EPA
Regions
Region
V
Region
X
A.
3.
d
Effects
of
Less
Frequent
Collection
This
is
a
one­
time
collection
of
information
from
the
Respondents
with
no
record
keeping
requirements.

A.
3.
e
General
Guidelines
This
collection
does
not
violate
any
of
the
OMB
guidelines
for
information
collection
activities.
Specifically,
the
Respondents
are
not
required
to:

1.
Report
information
to
EPA
more
than
quarterly;
ICR
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2.
Prepare
a
written
response
to
a
collection
of
information
in
fewer
than
30
days
after
receipt
of
a
request;

3.
Submit
more
than
an
original
and
two
copies
of
any
document;

4.
Retain
records,
other
than
health,
medical,
government
contract,
grant­
inaid
or
tax
records,
for
more
than
three
years;

5.
Participate
in
a
statistical
survey
that
is
not
designed
to
produce
data
that
can
be
generalized
to
the
universe
of
the
study;

6.
Use
a
statistical
data
classification
that
has
not
been
reviewed
and
approved
by
OMB;

7.
Receive
a
pledge
of
confidentiality
that
is
not
supported
by
authority
established
in
statute
or
regulation,
that
is
not
supported
by
disclosure
and
data
security
policies
that
are
consistent
with
the
pledge,
or
which
unnecessarily
impedes
sharing
of
data
with
other
agencies
for
compatible
confidential
use;
or
8.
Submit
proprietary,
trade
secret,
or
other
confidential
information
unless
EPA
can
demonstrate
that
it
has
instituted
procedures
to
protect
the
information's
confidentiality
to
the
extent
permitted
by
law.

A.
3.
f
Confidentiality
This
information
collection
does
not
require
Respondents
to
disclose
confidential
information.
Respondents
are
not
obliged
to
respond
to
this
strictly
voluntary
information
collection.

A.
3.
g
Sensitive
Questions
This
information
collection
does
not
ask
questions
pertaining
to
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
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A.
4
The
Respondents
and
the
Information
Requested
A.
4.
a
Respondents
and
SIC
Codes
The
Respondents
to
this
information
collection
include
personnel
from
State
water
quality
management
programs.
The
Standard
Industrial
Classification
(
SIC)
code
for
the
State
agencies
that
include
the
water
quality
management
programs
are
classified
under
either
9511
 
Air
and
Water
Resources
and
Solid
Waste
Management
or
9431
 
Administration
of
Public
Health
Programs.
State
licensing/
certification
agencies
are
classified
under
9651.

A.
4.
b
Information
Requested
EPA
is
asking
States
to
provide
estimates
of
resource
needs
for
water
quality
management
program
activities.
EPA
will
provide
the
States
with
four
integrated
modules
(
the
Gap
Analysis
model)
that
cover
activities
in
the
following
program
areas:
(
1)
point
source
controls
(
permitting,
compliance,
and
enforcement);
(
2)
total
maximum
daily
loads
(
TMDLs),
reporting
(
as
required
under
CWA
303(
d)
and
(
305(
b)),
water
quality
standards,
and
monitoring;
(
3)
nonpoint
source
and
coastal
nonpoint
source
management,
clean
lakes,
and
wetlands;
(
4)
coastal
and
marine
programs
(
related
to
the
objectives
of
the
CWA),
clean
water
state
revolving
fund
and
grants
management,
data
management,
planning,
and
special
regional
initiatives.
All
modules
were
designed
to
capture
the
total
workload
need
required
to
perform
all
activities
associated
with
the
development,
planning,
coordination,
management,
and
implementation
of
State
water
quality
management
programs.

Each
of
the
four
modules
are
composed
of
sub­
modules
which
contain
lists
of
activities
in
each
of
the
program
areas.
The
four
modules
will
be
integrated
so
that
estimates
for
various
program
areas
can
be
combined
into
a
total
estimate
across
all
program
areas.

To
reduce
the
burden
of
the
collection,
the
Gap
Analysis
model
is
being
designed
to
maximize
State
flexibility.
It
will
contain
default
values
developed
for
the
national
estimate
of
the
resource
gap
faced
by
State
water
quality
management
programs.
Respondents
can
accept
the
default
values
or
enter
an
appropriate
value
for
their
individual
State.
For
example,
if
the
default,
average,
fully­
loaded
salary
for
an
FTE
is
$
70,000,
the
individual
Respondent
can
accept
this
value
or
alter
the
cost
of
an
FTE
based
on
the
FTE
cost
in
their
State.
If
the
default
value
is
altered,
the
change
will
cascade
throughout
the
rest
of
the
module.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
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There
are
no
record
keeping
requirements
associated
with
this
information
collection.

(
i)
Data
Items,
Including
Recordkeeping
Requirements
For
each
activity
listed
in
the
sub­
modules,
each
State
will
be
asked
to
provide
an
estimate
of:


The
unit
of
analysis
(
e.
g.
annual,
one­
time,
grants
issued,
permits
issued,
sample
events,
special
studies,
FTEs,
square
miles
etc.)


Units
per
year

The
required
effort
(
FTE
hours/
unit)


Other
Unit
costs
(
dollars/
unit)

Based
on
the
information
provided
by
each
State,
the
Gap
Analysis
model
will
automatically
calculate
the
total
annual
effort
(
FTEs/
yr),
total
other
costs
(
dollars/
yr),
and
the
total
annual
costs
for
each
line
item
(
dollars/
yr).

(
ii)
Respondent
Activities
In
order
to
provide
the
data
items
listed
above
each
Respondent
will:
,


Review
the
workload
modules,
instructions,
and
accompanying
materials;
coordinate
with
program
area
managers
to
determine
the
appropriate
personnel
for
providing
estimates;
and
distribute
the
modules
to
the
appropriate
program
area
staff.
Some
States
may
contact
EPA
to
obtain
assistance
in
responding
to
this
ICR.


Develop
estimates
of
resource
needs
by
searching
data
sources
(
e.
g.
water
quality
program
management
budgets)
and
consulting
personnel
who
are
familiar
with
the
activities
listed
in
each
sub­
module.


Enter
estimates
of
resource
needs
into
the
module.
Once
estimates
have
been
developed,
the
State
will
need
to
enter
the
data
into
the
model.
Estimates
can
be
provided
in
hard
copy,
on
the
web­
site,
or
though
other
electronic
means.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
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10

Review
estimates,
make
any
necessary
revisions,
and
submit
the
modules
to
EPA.


Respond
to
questions
from
EPA
about
the
estimates
and
provide
additional
information,
if
necessary.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
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11
A.
5
The
Information
Collected
 
Agency
Activities,
Collection
Methodology
and
Information
Management
A.
5.
a
Agency
Activities
The
following
EPA
activities
are
associated
with
this
information
collection
for
the
State
Water
Quality
Program
Gap
Analysis:


Creating
a
letter
requesting
information
from
State
agencies

Developing
the
modules
listing
activities
and
default
values
to
send
to
the
States

Responding
to
questions
from
States
about
the
information
collection

Reviewing
the
submitted
information
from
States

Auditing
information
to
assess
quality

Compiling
and
storing
the
data

Requesting,
if
necessary,
additional
information
from
States

Analyzing
and
extrapolating
the
data
A.
5.
b
Collection
Methodology
and
Management
This
section
describes
the
steps
EPA
has
taken
to
ensure
that
the
collected
information
is
accurate,
reliable,
and
retrievable.
The
steps
have
been
developed
based
on
comments
and
advice
from
EPA
staff,
State
staff,
and
other
interested
Stakeholders.

Development
of
the
Gap
Analysis
Model
During
the
initial
development
of
the
Phase
II
Gap
Analysis
model,
EPA
worked
with
focus
groups
that
consisted
of
State
and
EPA
representatives.
Because
of
the
size
and
complexity
of
State
water
quality
management
programs,
there
were
four
focus
group
sessions,
each
addressing
particular
ICR
for
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12
program
areas.
The
four
sessions
covered
point
source
controls,
including
permitting,
compliance,
and
enforcement;
standards,
ambient
monitoring,
303(
d)
listing,
305(
b)
reports
and
total
maximum
daily
loads
(
TMDLs);
nonpoint
source
controls,
wetlands,
and
clean
lakes;
and
coastal
and
marine
programs,
clean
water
state
revolving
fund
(
CWSRF)
and
grants
management,
data
management,
planning,
and
regional
initiatives.

Focus
groups
met
four
times,
in
Albany,
NY;
Renton,
WA;
Madison,
WI;
and
Atlanta,
GA.
The
outcome
of
each
session
was
a
draft
workload
module
for
a
particular
group
of
program
areas.
The
groups
determined
the
activities
and
default
values
that
should
be
included
in
each
of
the
modules
and
then
reviewed,
commented
on,
and
tested
the
accuracy,
utility,
and
usability
of
each
of
the
modules.
The
focus
groups
also
developed
the
necessary
linkages
between
the
modules
so
that
the
final
model
incorporated
all
of
the
applicable
State
water
quality
management
activities.

The
outcome
of
this
process
was
the
development
of
a
model
that
includes
consensus­
based
definitions
of
activities
in
each
program
area
and
default
pricing
for
each
activity
(
i.
e.,
the
level
of
effort
required
to
produce
an
output).
EPA
and
the
focus
groups
have
also
identified
national
databases
that
can
provide
uniform
sources
of
information
on
critical
variables
that
affect
workload
(
e.
g.
National
Pollutant
Discharge
Elimination
System
permits
database).

Data
Quality
Data
quality
will
be
assured
by
implementing
the
following
mechanisms
throughout
the
collection
and
processing
phases
of
the
information
collection:

Detailed
Instructions.
Through
the
focus
group
process,
EPA
has
developed
detailed
instructions
and
supplemental
materials
that
explain
exactly
what
is
being
asked
of
States.
The
materials
include
explanations
of
the
assumptions
that
went
into
the
model's
development
and
a
frequently
asked
questions
document
that
further
explains
how
each
module
works,
the
scope
of
each
module,
how
the
module
relates
to
the
other
modules,
and
the
general
assumptions
underlying
each
module.

EPA
will
also
be
available
to
answer
any
questions
that
arise
once
the
model
and
supplemental
materials
are
sent
to
the
States.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
1These
definitions
were
taken
from
section
601
of
the
Regulatory
Flexibility
Act
(
RFA).

13
Data
Entry.
All
information
will
be
reviewed
for
completeness
and
internal
consistency.
States
will
be
contacted
for
additional
or
clarifying
information,
if
necessary.

Data
Systems.
EPA
is
developing
an
executable,
web
based
application
that
will
allow
States
to
access,
download,
and
verify
their
data.
EPA
will
use
a
commercial
"
off
the
shelf"
program,
such
as
Microsoft
Excel
 
,
to
manage
the
information.

Public
Access
to
Data
The
Agency
will
make
the
collected
information
available
to
the
public
in
accordance
with
the
Freedom
of
Information
Act
and
EPA
policies
and
procedures.

A.
5.
c
Small
Entity
Flexibility
In
developing
this
ICR,
EPA
considered
the
requirement
of
the
Regulatory
Flexibility
Act
(
RFA)
to
prepare
a
regulatory
flexibility
analysis
for
all
rules
that
have
a
"
significant
economic
impact
on
a
substantial
number
of
small
entities."
Under
the
RFA
small
entities
include
"
small
businesses,"
"
small
organizations"
and
"
small
government
jurisdictions."
These
terms
are
defined
below.
1
A
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field
as
defined
by
the
Small
Business
Administration
(
SBA)
regulations
under
Section
3
of
the
Small
Business
Act.

A
small
organization
is
any
non­
profit
enterprise
that
is
independently
owned
and
operated
and
not
dominant
in
its
field.

A
small
governmental
jurisdiction
is
the
government
of
a
city,
county,
town,
township,
village,
school
district
or
special
district
that
has
a
population
of
fewer
than
50,000.
This
definition
may
also
include
Indian
Tribes.
ICR
for
the
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14
EPA
is
not
promulgating
a
rule
for
any
activities
associated
with
the
ICR.
Therefore,
this
ICR
is
not
subject
to
a
regulatory
flexibility
analysis
requirements
of
the
RFA.
In
addition,
since
OWM
is
only
requesting
information
from
State
governments,
small
entities
will
not
be
significantly
impacted.

EPA
also
considered
the
requirement
of
the
Small
Business
Regulatory
Enforcement
Fairness
Act
(
SBREFA)
to
minimize
the
burden
of
the
information
collection
on
small
entities.
There
will
be
no
burden
placed
on
small
entities
by
this
ICR
and
therefore
EPA
has
met
the
requirements
of
SBREFA.

A.
5.
d
Collection
Schedule
Upon
receipt
of
approval
for
this
collection
from
OMB,
EPA
will
send
the
request
for
information
(
modules
with
default
values
and
detailed
instructions)
to
State
water
quality
management
personnel.
EPA
will
request
that
the
States
submit
their
values
or
accept
the
default
values
within
45
days
of
receiving
the
information
request.
ICR
for
the
State
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Quality
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Gap
Analysis
3/
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15
A.
6
Estimating
the
Burden
and
Cost
of
the
Collection
This
section
describes
the
annual
burden
and
cost
for
the
information
collection
activities
of
the
State
Water
Quality
Program
Management
Gap
Analysis.
The
burden
and
cost
estimates
for
the
States
are
shown
in
Section
A.
6.
a
and
the
Agency's
burden
and
cost
estimates
are
shown
in
Section
A.
6.
b.

A.
6.
a
Estimating
Burden
and
Costs
to
the
States
Upon
receiving
the
modules
and
additional
materials
from
EPA,
a
State
water
quality
senior
manager
will
review
the
information
and
decide
whether
to
respond.
Since
responding
to
this
ICR
is
voluntary,
EPA
estimates
that
20
States
will
provide
estimates
of
resource
needs.
This
response
rate
is
consistent
with
similar
voluntary
collection
efforts
conducted
in
the
past
and
with
feedback
provided
by
focus
group
participants.

The
senior
manager
receiving
the
materials
will
need
to
coordinate
with
program
managers
(
i.
e.
personnel
responsible
for
non­
point
source
activities,
coastal
zone
activities
etc.),
explain
the
request
and
the
Gap
Analysis
project,
and
distribute
the
various
components
of
the
model
to
appropriate
staff.
These
activities
are
estimated
to
take
6
hours.

The
various
program
managers
will
develop
estimates
of
resource
needs
by
examining
the
activities
and
default
values,
researching
data
sources
such
as
past
budgets
and
performance
summaries,
and
meeting
with
staff.
These
activities
are
estimated
to
take
145
hours.

Each
program
manager
will
then
enter
the
estimates
or
resource
needs
into
the
model
or
will
accept
the
default
values.
The
estimated
time
to
complete
these
activities
is
3
hours.

Once
the
model
is
complete,
EPA
assumes
that
each
State
will
review
the
estimates,
revise
the
information
if
necessary,
and
submit
the
final
product
to
EPA.
Reviewing
and
revising
the
estimates
may
involve
coordinating
with
various
program
managers
to
ensure
that
the
estimate
are
accurate.
These
activities
are
estimated
to
take
26
hours.

Once
the
model
has
been
submitted
by
the
participating
States,
EPA
estimates
that
5
States
will
need
to
be
contacted
for
additional
information
concerning
their
submissions.
Responding
to
EPA's
request
for
additional
information
is
estimated
to
take
0.5
hours.
ICR
for
the
State
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Quality
Management
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Gap
Analysis
3/
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2These
estimates
are
consistent
with
the
estimates
used
in
the
approved
Unregulated
Contaminant
Monitoring
Regulation
ICR,
EPA
ICR
#
1882.01,
June
1999,
and
the
1999
Drinking
Water
Infrastructure
Needs
Survey
ICR,
EPA
ICR
#
1708.02,
approved
October
1998.

16
Table
6.1
illustrates
the
estimated
average
annual
burden
and
costs
associated
with
responding
to
this
ICR.
For
purposes
of
calculating
State
burden,
EPA
assumed
that
one
FTE
is
equivalent
to
1,800
hours
worked
per
year
and
a
fully
loaded
cost
of
$
72,000
to
employ
one
State
full
time
equivalent
(
FTE)
with
managerial
responsibilities.
2
EPA
assumed
that
program
mangers
will
provide
the
requested
information
due
to
their
comprehensive
knowledge
of
water
quality
management
programs
and
their
detailed
understanding
of
each
program
area.
There
are
no
capital
or
operations
and
maintenance
costs
associated
with
this
ICR.

Table
6.1
­
State
Burden
and
Costs
Activities
Number
of
State
Respondents
Frequency
of
Response
Burden
per
State
(
Hours)
Labor
Cost
per
State
($)

Review
workload
model,
coordinate
distribution,
and
distribute
20
1
6
$
240
Develop
estimates
of
resource
needs
20
1
145
$
5,800
Enter
estimates
of
resource
needs
20
1
3
$
120
Review
estimates,
revise
if
necessary,
and
submit
workload
model
to
EPA
20
1
26
$
1,040
Responding
to
EPA
requests
for
additional
information
5
1
0.5
$
20
TOTALS
180.5
$
7,220
A.
6.
b
Estimating
Agency
Burden
and
Cost
Due
to
the
complexity
of
water
quality
management
programs,
certain
activities
associated
with
the
development
of
the
Gap
Analysis
will
fall
to
managerial
level
personnel.
These
activities
require
a
comprehensive
knowledge
of
program
activities,
how
these
activities
interrelate,
and
the
resources
necessary
to
manage
and
implement
State
water
quality
programs.
Other
tasks,
such
as
entering
data
into
a
database,
do
not
require
specialized
knowledge
and
therefore
will
be
completed
by
technical
level
staff.

EPA
is
currently
developing
the
activity­
based
workload
model
for
distribution
to
all
50
States.
EPA
will
update
the
modules
to
reflect
recent
regulatory
and
policy
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
17
requirements
that
may
have
impacted
the
assumptions
and
pricing
of
activities
included
in
the
draft
modules,
integrate
the
modules,
make
final
calibrations
to
the
model,
and
test
the
calibrated
model
for
accuracy
and
reliability.
EPA
will
also
prepare
a
User's
Guide
and
other
documentation
to
provide
to
the
States
with
the
final
model.
These
activities
are
estimated
to
take
200
hours
of
managerial
level
time.

Based
on
past
experience
in
developing
the
national
estimate
of
State
water
quality
management
program
needs,
EPA
estimates
that
20
States
will
have
questions
about
the
modules
and
the
Gap
Analysis
project.
EPA
estimates
that
it
will
take
20
minutes
of
an
Agency
program
managers
time,
per
State,
to
respond
to
questions
and
provide
additional
information.

Since
this
is
a
voluntary
request
for
information,
EPA
estimates
that
20
States
will
submit
responses.
An
EPA
technical
level
FTE
will
review
and
audit
the
submitted
information,
compile
the
responses,
and
store
the
submitted
data
in
a
database.
Reviewing
and
auditing
the
information
is
estimated
to
take
one
hour
per
response
and
compiling
and
storing
the
submitted
data
is
estimated
to
take
an
additional
30
minutes
per
response.

After
reviewing
the
responses,
EPA
assumes
that
additional
information
or
clarification
will
be
necessary
from
five
of
the
States
that
have
submitted
information.
These
activities
are
estimated
to
take
a
technical
level
FTE
15
minutes
per
State
to
complete.

To
complete
the
Gap
Analysis,
EPA
will
analyze
the
information
based
solely
on
the
default
values
in
the
model,
based
on
a
combination
of
the
default
values
and
State
data,
and
based
on
State
data
and
an
extrapolation
to
a
national
estimate.
EPA
will
coordinate
with
water
quality
management
program
personnel
to
ensure
accuracy
of
the
analysis.
These
activities
are
estimated
to
take
300
hours
of
managerial
level
time.

For
purposes
of
calculating
Agency
burden,
EPA
assumed
that
one
FTE
is
equivalent
to
1,800
hours
worked
per
year
(
see
footnote
#
2).
For
labor
costs,
EPA
assumed
a
fully
loaded
cost
of
$
71,043
(
GS­
11
Step
5)
to
employ
one
Agency
FTE
with
managerial
responsibilities
and
$
58,714
(
GS­
9
Step
5)
to
employ
one
Agency
FTE
with
technical
responsibilities.
EPA
multiplied
the
basic
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6
to
get
the
fully
loaded
labor
rates.

Table
6.2
illustrates
the
total
estimated
burden
and
costs
for
activities
associated
with
developing
an
estimate
of
the
resource
gap
for
State
water
quality
management
programs.

Table
6.2
­
Agency
Burden
and
Costs
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
3For
one
activity,
the
number
of
Respondents
is
5.
The
Total
Burden
represents
the
total
number
of
hours
needed
by
all
Respondents
for
all
activities.

18
Activities
Hours
per
Activity
Labor
Cost
per
Hour
Total
Cost
per
Activity
Develop
and
distribute
the
workload
model
200
$
39.47
$
7,894
Respond
to
questions
concerning
the
model
6.7
$
39.47
$
263
Review
and
audit
submitted
information
20
$
32.62
$
652
Compile
and
store
submitted
data
10
$
32.62
$
326
Review
and
audit
additional
information,
if
requested
1.25
$
32.62
$
41
Analyze
and
extrapolate
the
data
and
prepare
report
300
$
39.47
$
11,841
TOTALS
538
 
$
21,017
A.
6.
c
Bottom
Line
Burden
Hours
and
Cost
Table
EPA
will
request
information
from
50
States.
Based
on
the
expected
responses
from
20
States,
the
total
burden
for
submitting
the
information
is
estimated
to
be
3,602.5
hours
at
a
cost
of
$
144,100.
The
total
estimated
Agency
burden
is
538
hours
at
a
cost
of
$
21,017.

Table
6.3
illustrates
the
total
estimated
burden
and
labor
costs
for
both
the
States
and
the
Agency
for
activities
associated
with
developing
an
estimate
of
the
resource
gap
for
State
water
quality
management
programs.

Table
6.3
­
Total
Burden
and
Cost
for
the
ICR
for
the
State
Water
Quality
Program
Management
Gap
Analysis
Respondent
Number
of
Respondents
Total
Burden
(
hours)
Total
Cost
State
203
3,602.5
$
144,100
Agency
1
538
$
21,017
TOTALS
21
4,141
$
165,117
Burden
per
Response
197.17
Cost
per
Response
$
7,863
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
19
A.
6.
d
Reasons
for
Change
in
Burden
This
ICR
does
not
renew
or
modify
an
existing
ICR.

A.
6.
e
Burden
Statement
Burden
statement:
The
reporting
burden
for
a
State
water
quality
management
program
that
chooses
to
respond
to
this
ICR
is
estimated
to
average
180.5
hours.
The
estimate
includes
time
required
to:


Review
the
workload
modules,
instructions,
and
accompanying
materials;
coordinate
with
program
area
managers
to
determine
the
appropriate
personnel
for
providing
estimates;
and
distribute
the
modules
to
the
appropriate
program
area
staff.
Some
States
may
contact
EPA
to
obtain
assistance
in
responding
to
this
ICR.


Develop
estimates
of
resource
needs
by
searching
data
sources
(
e.
g.
water
quality
program
management
budgets)
and
consulting
personnel
who
are
familiar
with
the
activities
listed
in
each
sub­
module.


Enter
estimates
of
resource
needs
into
the
module.
Once
estimates
have
been
developed,
the
State
will
need
to
enter
the
data
into
the
model.
Estimates
can
be
provided
in
hard
copy,
on
the
web­
site,
or
though
other
electronic
means.


Review
estimates,
make
any
necessary
revisions,
and
submit
the
modules
to
EPA.


Respond
to
questions
from
EPA
about
the
estimates
and
provide
additional
information,
if
necessary.

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
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
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
20
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulation
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency'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,
Collection
Stategies
Division,
Office
of
Environmental
Information,
U.
S.
EPA
(
2822),
401
M.
St.,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
(
1945.01)
and
OMB
control
number
in
any
correspondence.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
21
Attachment
1
Federal
Register
Notice
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
Insert
copy
of
the
actual
pages
from
the
Federal
Register
or
a
printout
from
the
Internet
version
to
prove
that
the
first
Federal
Register
notice
was
published.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
21
Attachment
2
Burden
and
Cost
Tables
for
State
Water
Quality
Program
Management
Gap
Analysis
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
22
Activities
Number
of
Respondents
Frequency
of
Response
Burden
per
Respondent
(
hrs)
Cost
per
Respondent
($)
Total
Burden
(
hrs)
Total
Cost
($)

Review
workload
model,
coordinate
distribution,
and
distribute
20
1
6
$
240
120
$
4,800
Develop
estimates
of
resource
needs
20
1
145
$
5,800
2,900
$
116,000
Enter
estimates
of
resource
needs
20
1
3
$
120
60
$
2,400
Review
estimates,
revise
if
necessary,
and
submit
workload
model
to
EPA
20
1
26
$
1,040
520
$
20,800
Responding
to
EPA
requests
for
additional
information
5
1
0.5
$
20
2.5
$
100
TOTALS
180.5
$
7,220
3,602.5
$
144,100
Assumptions:
Fully­
loaded
Program
Manager
Cost
$
72,000
Hours
per
FTE
per
year
1,800
Water
Quality
Program
Management
Gap
Analysis:
Information
Collection
Request
State
Burden
and
Cost
Estimates
EPA
estimates
that
20
States
will
submit
workload
estimates
that
differ
from
the
default
values.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
23
Activities
Number
of
Hours
(
hrs)
Cost
per
Hour
($)
Total
Cost
($)

(
1)
Develop
and
distribute
the
workload
model
200
$
39.47
$
7,894
(
2)
Respond
to
questions
concerning
the
model
6.67
$
39.47
$
263
(
3)
Review
and
audit
submitted
information
20
$
32.62
$
652
(
4)
Compile
and
store
submitted
data
10
$
32.62
$
326
(
5)
Review
and
audit
additional
information,
if
requested
1.25
$
32.62
$
41
(
6)
Analyze
and
extrapolate
the
data
and
prepare
report
300
$
39.47
$
11,841
TOTALS
538
$
21,017
Assumptions:
Basic
Salary
Multiplier
Fully­
loaded
Salary
for
GS­
11/
5:
$
44,402
1.60
$
71,043
Salary
for
GS­
9/
5:
$
36,696
1.60
$
58,714
Hours
per
FTE
per
year:
1,800
Water
Quality
Program
Management
Gap
Analysis:
Information
Collection
Request
Agency
Burden
and
Cost
Estimates
The
burden
estimate
for
activity
(
2)
assumes
that
20
States
will
request
more
information
about
the
module
and
the
gap
analysis
project.
EPA
estimates
that
20
States
will
submit
information.
Therefore,
burden
estimates
for
activities
(
3)
and
(
4)
were
based
on
20
States
submitting
responses.
The
burden
estimate
for
activity
(
5)
was
based
on
the
assumption
that
additional
information
would
be
required
from
5
of
the
20
States
submitting
responses.
Due
to
the
nature
of
the
activity
and
the
complexity
of
water
quality
programs,
EPA
estimates
that
a
manager
will
complete
tasks
(
1),
(
2),
and
(
6).
Since
tasks
(
3),
(
4),
and
(
5)
require
less
specialized
knowledge,
EPA
estimates
that
these
tasks
will
be
completed
by
technical
level
staff.
ICR
for
the
State
Water
Quality
Management
Program
Gap
Analysis
3/
14/
00
24
Attachment
3
State
Water
Quality
Program
Management
Gap
Analysis
Activity­
Based
Workload
Model
