  SEQ CHAPTER \h \r 1 

Information Collection Request:

Recognition Application for Sustainable Water Leadership Program

EPA ICR No. 1287.10

OMB Control No. 2040-0101

June 2010

Prepared for

U.S. Environmental Protection Agency

Office of Wastewater Management

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Prepared by

Tetra Tech, Inc.

10306 Eaton Place, Suite 340

Fairfax, VA 22030

EPA Contract Number EP-C-05-046

EPA Work Assignment Number 2-43



Contents

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc251146109"  1.
Identification of the Information Collection	  PAGEREF _Toc251146109 \h 
1  

  HYPERLINK \l "_Toc251146110"  1(a) Title of the Information Collection
  PAGEREF _Toc251146110 \h  1  

  HYPERLINK \l "_Toc251146111"  1(b) Short Characterization/Abstract	 
PAGEREF _Toc251146111 \h  1  

  HYPERLINK \l "_Toc251146112"  2. Need For and Use of the Collection	 
PAGEREF _Toc251146112 \h  2  

  HYPERLINK \l "_Toc251146113"  2(a) Need/Authority for the Collection	 
PAGEREF _Toc251146113 \h  2  

  HYPERLINK \l "_Toc251146114"  2(b) Practical Utility/Users of the Data
  PAGEREF _Toc251146114 \h  3  

  HYPERLINK \l "_Toc251146115"  3. Non-duplication, Consultations, and
Other Collection Criteria	  PAGEREF _Toc251146115 \h  3  

  HYPERLINK \l "_Toc251146116"  3(a) Non-duplication	  PAGEREF
_Toc251146116 \h  3  

  HYPERLINK \l "_Toc251146117"  3(b) Public Notice Required Prior to ICR
Submission to OMB	  PAGEREF _Toc251146117 \h  3  

  HYPERLINK \l "_Toc251146118"  3(c) Consultations	  PAGEREF
_Toc251146118 \h  3  

  HYPERLINK \l "_Toc251146119"  3(d) Effects of Less Frequent Collection
  PAGEREF _Toc251146119 \h  4  

  HYPERLINK \l "_Toc251146120"  3(e) General Guidelines	  PAGEREF
_Toc251146120 \h  4  

  HYPERLINK \l "_Toc251146121"  3(f) Confidentiality	  PAGEREF
_Toc251146121 \h  4  

  HYPERLINK \l "_Toc251146122"  3(g) Sensitive Questions	  PAGEREF
_Toc251146122 \h  4  

  HYPERLINK \l "_Toc251146123"  4. The Respondents and the Information
Requested	  PAGEREF _Toc251146123 \h  5  

  HYPERLINK \l "_Toc251146124"  4(a) Respondents/SIC and NAICS Codes	 
PAGEREF _Toc251146124 \h  5  

  HYPERLINK \l "_Toc251146125"  4(b) Information Requested	  PAGEREF
_Toc251146125 \h  5  

  HYPERLINK \l "_Toc251146126"  4(b)(i) Data Items, Including Record
Keeping Requirements	  PAGEREF _Toc251146126 \h  5  

  HYPERLINK \l "_Toc251146127"  4(b)(ii) Respondent Activities	  PAGEREF
_Toc251146127 \h  5  

  HYPERLINK \l "_Toc251146128"  5. The Information Collected—Agency
Activities, Collection Methodology, and Information Management	  PAGEREF
_Toc251146128 \h  5  

  HYPERLINK \l "_Toc251146129"  5(a) Agency Activities	  PAGEREF
_Toc251146129 \h  5  

  HYPERLINK \l "_Toc251146130"  5(b) Collection Methodology and
Management	  PAGEREF _Toc251146130 \h  6  

  HYPERLINK \l "_Toc251146131"  5(c) Small Entity Flexibility	  PAGEREF
_Toc251146131 \h  6  

  HYPERLINK \l "_Toc251146132"  5(d) Collection Schedule	  PAGEREF
_Toc251146132 \h  6  

  HYPERLINK \l "_Toc251146133"  6. Estimating the Burden and Cost of the
Collection	  PAGEREF _Toc251146133 \h  7  

  HYPERLINK \l "_Toc251146134"  6(a) Estimating Respondent Burden	 
PAGEREF _Toc251146134 \h  7  

  HYPERLINK \l "_Toc251146135"  6(b) Estimating Respondent Costs	 
PAGEREF _Toc251146135 \h  8  

  HYPERLINK \l "_Toc251146136"  6(b)(i) Estimating Labor Costs	  PAGEREF
_Toc251146136 \h  8  

  HYPERLINK \l "_Toc251146137"  6(c) Estimating Agency Burden and Cost	 
PAGEREF _Toc251146137 \h  8  

  HYPERLINK \l "_Toc251146138"  6(d) Estimating the Respondents Universe
and Total Burden and Cost	  PAGEREF _Toc251146138 \h  9  

  HYPERLINK \l "_Toc251146139"  6(e) Bottom Line Burden Hours and Cost
Estimates	  PAGEREF _Toc251146139 \h  9  

  HYPERLINK \l "_Toc251146140"  6(e)(i) Respondent Tally	  PAGEREF
_Toc251146140 \h  9  

  HYPERLINK \l "_Toc251146141"  6(e)(ii) The Agency Tally	  PAGEREF
_Toc251146141 \h  9  

  HYPERLINK \l "_Toc251146142"  6(f) Reasons for Change in Burden	 
PAGEREF _Toc251146142 \h  10  

  HYPERLINK \l "_Toc251146143"  6(g) Burden Statement	  PAGEREF
_Toc251146143 \h  11  

  

Appendices

A. 40 CFR Part 105

B. Section 501(e) of the CWA

C. Current Application

D. Respondents and Other Assumptions

E. Respondent Activities Exhibits

F. Agency Activities Exhibits

Tables

  TOC \h \z \t "Table Title,1"    HYPERLINK \l "_Toc251146144"  Table 1.
Respondent Tally	  PAGEREF _Toc251146144 \h  9  

  HYPERLINK \l "_Toc251146145"  Table 2. Summary of Agency Cost for the
ICR Approval Period	  PAGEREF _Toc251146145 \h  10  

  HYPERLINK \l "_Toc251146146"  Table 3. Burden Change	  PAGEREF
_Toc251146146 \h  10  

 1. Identification of the Information Collection

1(a) Title of the Information Collection

Title: Recognition Application for Sustainable Water Leadership Program

OMB Control No. 2040-0101

EPA ICR No. 1287.10

1(b) Short Characterization/Abstract

This Information Collection Request (ICR) calculates the burden and
costs associated with the recognition application for the Environmental
Protection Agency's (EPA) Sustainable Water Leadership Program, formerly
the National Clean Water Act Recognition Awards Program and prior to
that, the National Wastewater Management Excellence Awards Program. 

This voluntary program has been updated to reflect new industry
practices consistent with EPA’s sustainable infrastructure initiatives
and is now called the Sustainable Water Leadership Program. It is
authorized by Section 501(e) of the Clean Water Act (CWA). The
Sustainable Water Leadership Program maintains elements from the
previous Clean Water Act Recognition Awards Program, namely, excellence
in operations and maintenance, biosolids, combined sewer overflows,
pretreatment, and stormwater management, and also expands eligibility to
community drinking water utilities and systems, as well as managed
decentralized treatment systems (public or private). The development of
the Sustainable Water Leadership Program is the latest evolution in
EPA’s commitment to recognize and award outstanding and innovative
utility management practices.

In 1985, EPA established the Operations and Maintenance (O&M) awards
program to provide a positive incentive for compliance with the National
Pollutant Discharge Elimination System (NPDES). Because of the successes
of the O&M Awards program, in 1988, EPA amended the program to include
the Beneficial Biosolids Use awards (formerly Sludge awards). In 1989,
the Pretreatment awards were added.  Pretreatment Program activities are
covered under a separate ICR (OMB Control No. 2040-0009, EPA ICR No.
0002.14).  In 1990, EPA established the Combined Sewer Overflow (CSO)
and Stormwater Management awards programs and added these programs to
the Clean Water Act Recognition Awards Program.

The Sustainable Water Leadership Program consists of two components: 1)
a recognition program that acknowledges applicants that are moving
toward sustainable operations and meet specified criteria identified in
the application, and 2) a competitive awards program to showcase the
“best of the best” in a specific topic area selected in advance by
EPA. This ICR addresses the application burden for the recognition
component; the awards component is still under development. An update to
this ICR will be provided following finalization of the awards
component. The recognition component requires that an applicant meet
criteria under specific categories. One category Effective Utility
Management, is mandatory for all applicants, and is based on the
Attributes of Effectively Managed Systems that EPA and members of the
water sector have endorsed. In addition, applicants are asked to
describe activities in other areas of their choice including: biosolids,
pretreatment, decentralized systems, energy management, water
efficiency, climate change adaptation and or mitigation, and watershed
approaches, including source water protection and stormwater.  

The updated application provides the mechanism for the applicants to
demonstrate how they meet the required criteria. Organizations applying
for recognition will be evaluated on the basis of the criteria described
in the application but will not compete directly with other applicants
for recognition. 

The regulation which establishes the framework to implement the
recognition program is at 40 CFR Part 105. A copy is attached in
Appendix A. 

The respondent will read the instructions for completing the
application. It is anticipated that respondents will use existing files,
planning and progress reports, and institutional knowledge to complete
the application. Based on the instructions provided with the
application, the respondent will compile the requested information and
write up to a 10-page narrative on how the facility meets the specified
criteria in the application.  

The information collection will be used by EPA’s Office of Water, led
by the Office of Wastewater Management, to evaluate and determine if the
required criteria are met for recognition. Based on the collection,
national panels will evaluate the nominee's efforts and recommend
finalists. 

Utilities that are recognized will receive a letter and certificate
signed by the EPA Administrator or Assistant Administrator for Water,
their utility name will be posted on EPA and outside organization web
sites, and announced at national conferences. EPA regions may also opt
to hold Regional ceremonies. Additional recognition will be made through
a Federal Register notice, and other national publications.

During the 3 years covered by this ICR, the information collection for
the Sustainable Water Leadership Program would involve responses from an
estimated total of 2,036 respondents and cost approximately $1.8 million
(all labor cost), with annual averages of 679 respondents, 13,574 burden
hours, and costs of $614,919 per year (for additional detail, see
Section 6). EPA estimates assume that water systems in multiple
size-categories will have different response rates to Program outreach.
The cost to the Agency is estimated to be approximately $56,575 per
year, with no anticipated capital or operation and maintenance (O&M)
costs.

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection

Section 501(e) of the CWA (copy attached in Appendix B) authorizes a
program to recognize political subdivisions of states and industrial
organizations that demonstrate outstanding technological achievements,
innovative processes, devices or other outstanding methods in their
waste treatment and pollution abatement programs. Recognition is given
through EPA's voluntary Sustainable Water Leadership Program. EPA will
recognize applicants that are moving toward sustainable operations and
meet specific criteria identified in the application. Applicants will be
asked to describe activities in the area of Effective Utility Management
and in other areas of their choice related to Resource Protection and
Efficiency. A narrative description of how the utility meets the
criteria is needed to complete the application and determine whether to
recognize the utility.

2(b) Practical Utility/Users of the Data

Information collected will be used for the Sustainable Water Leadership
Program by EPA’s Office of Water. The information collected will be
used by EPA to evaluate and determine if the required criteria are met
for recognition. Based on the collection, national panels will evaluate
the nominee's efforts and recommend finalists who have demonstrated that
they are moving toward sustainable operations and are implementing
practices identified in the application.

3. Non-duplication, Consultations, and Other Collection Criteria

3(a) Non-duplication

The design, operating, and environmental information needed to complete
the application is not immediately available in databases or files of a
State or Federal office. If such data is available, it may exist in an
outdated report or database which cannot be timely or readily
cross-referenced to the requested data. Demonstrations of program
accomplishments required by the Sustainable Water Leadership Program
must be provided from the water and wastewater management facilities and
programs as it is not available from any other source. 

3(b) Public Notice Required Prior to ICR Submission to OMB

In compliance with the 1995 Paperwork Reduction Act (PRA), any agency
developing a non-rule-related ICR must solicit public comments before
submitting the ICR to OMB. These comments, which are used partly to
determine realistic burden estimates for respondents, must be considered
when completing the Supporting Statement that is submitted to OMB.

This ICR was published in the Federal Register on Feb. 19, 2010 (75 FR
7476). The notice included a request for comments on the content and
impact of these information collection requirements on the regulated
community.  No comments were received.

3(c) Consultations

EPA has spent over two years consulting with other water and wastewater
professionals on the development of this new program. EPA headquarters
convened an EPA Regional Workgroup that assisted in the program
development including the criteria and content of the new recognition
application. In addition, EPA had several meetings with outside
stakeholders and trade associations that represent the potential
respondents for this application. Feedback from these consultation
groups was considered and is reflected in the new application being used
for information collection.

EPA strives to minimize the burden on all respondents, especially small
communities/businesses. In previous years, EPA asked the Regional and
State personnel to assist the respondents where necessary in completing
the application. For the new program, EPA will continue to request that
the Regions assist the respondents where necessary. In addition, EPA
tentatively plans to conduct at least one webcast on completing the
application and will be available for specific questions from potential
respondents. Guidance on completing the application will also be
provided on EPA’s web site.

For the previous program, EPA managers solicited feedback on its
application from non-Federal panelists and from past municipal winners
in a very informal manner. EPA managers also received indirect comments
from Regional EPA employees, who were also in contact with municipal and
industrial entities and State officials. Positive and negative feedback
were both evaluated. Feedback from the State’s facility operators
stated that the old application form for awards was too complex and was
a significant burden for the plant staff. Based on these comments and
feedback from Regions, EPA has attempted to make the new application
form for the Sustainable Water Leadership Program more streamlined. 

3(d) Effects of Less Frequent Collection

Recognition will be determined every other year, with recognition
lasting a total of three years. The EPA recognition program manager
sends out the application and instructions in May/June of each
recognition-year. The completed application is received by EPA
headquarters in September/October, and an EPA panel reviews the
applications in November/December. Recognition letters and certificates
are sent in January/February [final schedule to be determined]. Since
the program is designed to recognize the current state of treatment
facilities, less frequent collection of information would impact the
goals of the program to recognize and incentivize innovative and
effective practices for water treatment.

3(e) General Guidelines

This information collection request is consistent with guidelines
contained in 5 CFR 1320.5(d)(2).  

3(f) Confidentiality

Respondents are not being asked to submit any confidential information
in the recognition application. As a result, no confidential information
is involved for this collection activity. However, any claim of
confidentiality must be asserted at the time of submission. If any
confidential information is submitted, all confidential data will be
handled in accordance with 40 CFR 122.7, 40 CFR Part 2. 

3(g) Sensitive Questions

Sensitive questions are defined in EPA’s ICR Handbook, Guide to
Writing Information Collection Requests Under the Paperwork Reduction
Act of 1995 as “questions concerning sexual behavior or attitudes,
religious beliefs, or other matters usually considered private.” The
requirements addressed in this ICR do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC and NAICS Codes 

The Standard Industrial Classification (SIC) and North American Industry
Classification System (NAICS) codes for the respondents affected by this
information collection activity are as follows:

SIC: 4952; NAICS: 22131 - Water Supply and Irrigation Systems  

SIC: 4952; NAICS: 22132 - Sewage Treatment Facilities  

SIC: 8711; NAICS: 54133 - Engineering Services

SIC: 4953; NAICS: 56292, 562211-262213, 562219 - Refuse Systems

SIC: 8221; NAICS: 61131 - Colleges, Universities, Professional Schools

SIC: 9511; NAICS: 92411 - Air and Water Resource and Solid Waste
Management (Administration of Environmental Quality)

4(b) Information Requested

This section presents the data items, including recordkeeping
requirements, and required respondent activities involved in preparing
and submitting those data items. 

4(b)(i) Data Items, Including Record Keeping Requirements

The requested information should be readily available from facility
operating records. Respondents may include flow, permit, operating, and
environmental compliance data with the required narrative description of
the facility’s activities.

4(b)(ii) Respondent Activities

To be considered for recognition, the respondent will read the
instructions for completing the application. The respondent will use
existing files when possible, planning and progress reports, and
institutional knowledge to complete the application. The respondent will
prepare a written narrative description on how the facility meets the
criteria stated in the application. A copy of the current application is
attached in Appendix C.

5. The Information Collected—Agency Activities, Collection
Methodology, and Information Management

5(a) Agency Activities

The completed application is sent directly to EPA headquarters by the
specified application deadline. EPA is strongly requesting that
applications be sent electronically to the specified email address on
the application. The review of electronic applications will reduce the
burden on the agency. EPA will still accept hand-written applications.

Each application is first reviewed by EPA for completeness. The
completed applications will then be sent to EPA’s Office of
Enforcement and Compliance Assurance for a criminal compliance check. In
addition to criminal compliance, information for each application will
also be entered into EPA’s Online Tracking Information System (OTIS)
for an administrative compliance check. It is assumed that 20 percent of
the completed applications will not be in compliance with applicable
water quality requirements for the past year and will not have a
satisfactory record with respect to environmental quality. The remaining
80 percent of the applications will then move forward in the review
process.

The applications that are deemed complete and without compliance
violations will be provided to the respective review panels consisting
of representatives from EPA's headquarters and Regions and also
potentially non-EPA technical professionals. The panels will review each
application to determine if it meets the specified criteria. The panels
will make recommendations to EPA management on which facilities to
recognize.

The facilities that are recognized will receive a letter and certificate
signed by the EPA Administrator or Assistant Administrator for Water,
their utility name will be posted on EPA and outside organization web
sites, and announced at national conferences. EPA regions may also opt
to hold Regional ceremonies. Additional recognition will be made through
a Federal Register notice, and other national publications.

5(b) Collection Methodology and Management

All nominees are screened for environmental compliance by EPA. Data
quality information will be retrieved from the Agency's Permit
Compliance System (PCS), OTIS, Safe Drinking Water Information System
(SDWIS), the new Integrated Compliance Information System (ICIS-NPDES)
database, other environmental reports, and professional knowledge of the
facility or program.

5(c) Small Entity Flexibility

This information collection activity does not concern a rulemaking. A
framework to implement the awards recognition program is at 40 CFR Part
105. EPA strives to minimize the burden on all respondents, especially
small communities/businesses. The recognition application for the
Sustainable Water Leadership Program includes reduced requirements for
small entities. EPA headquarters and some EPA Regions will be available
to assist respondents to answer the application. 

5(d) Collection Schedule

The information collection schedule is contained in the respondents'
application. The EPA recognition program manager sends out the
application and instructions in May/June of each year. The completed
application is received by EPA headquarters in September/October, and
the panel reviews the applications in November/December. Recognition
letters and certificates are sent in January/February [schedule to be
determined by EPA].

6. Estimating the Burden and Cost of the Collection

The following sections present the rationale, assumptions made, and
results of EPA’s estimation of burden and costs for the Sustainable
Water Leadership Program. See Appendix D for specific assumptions made
to estimate the burden and cost of the Program. 

6(a) Estimating Respondent Burden

This section describes the burden estimates for facilities to complete
the application, as well as the methods used and assumptions made to
derive them. Respondent activities are separated into those activities
that will occur in year 1 of the program and those activities that will
occur in year 3 of the program. The reason for this is that applications
for recognition are submitted every 2 years. The Respondent Activity
Exhibits E.1-E.6 in Appendix E presents all calculations and results
discussed in this subsection. EPA estimates that the total annual burden
to applicant respondents is approximately 13,600 hours.  

To calculate the total annual applicant respondent burden, EPA first
calculated the burden for each type of applicant respondent in years 1
and 3 of the program. The Agency then added these together. Then, the
sum of the burdens for each respondent expected over the next three
years was divided by three to obtain the estimated total annual burden. 

For those applicants applying for recognition, this ICR only calculates
burden and cost for a three year period. At the end of that period, this
ICR will be revised with new calculations, as appropriate, for the
following three years. Therefore, for the burden and cost calculations
for respondents applying for recognition, the estimate of the total
number of applicants expected over the next three years is divided by
three to obtain the estimated number of applicants per annum. Exhibit
E.1 estimates the number of respondents that will provide application
information over the next three years. 

The total number of applicant respondents is estimated to be 2,037,
including 530 applicants in Year 1 and 1,507 in Year 3. The responses
are collected once every two years. EPA estimates the total annual
number of applicant respondents to be 679. 

The respondents reporting burden is estimated to be 20 hours per
response: 2 hours for manager to read instructions and search data; 16
hours for staff to gather information and complete the application; and
2 hours for administrative support staff to prepare forms. The average
annual burden is estimated to be 13,574 hours. For a more detailed
presentation of hourly burdens for applicant respondents see Exhibits
E.3-E.9 in Appendix E. 

In addition, states will not incur any burden and costs associated with
this ICR since EPA will conduct the review of applications. As a result,
the burden and cost for reviewing applications will belong to the
federal government exclusively.  

6(b) Estimating Respondent Costs

This section describes cost estimates for respondents, as well as the
methods used to derive them. Because EPA has determined that there are
no capital or operation and maintenance costs associated with any of the
respondent activities, this ICR only includes labor costs in its
estimates.  

6(b)(i) Estimating Labor Costs

The costs to applicant respondents associated with the ICR activities
can be estimated by multiplying the time spent in each labor category by
an appropriately loaded hourly wage rate. 

EPA used the following categories and hourly rates to estimate labor
costs for activities by applicant respondents. A labor rate of $55.00
hour was used for managers, $46.86 for staff, and $23.12 for
administrative support. These rates are based on the mean hourly cost of
employment for all occupations, including benefits, and are adjusted
with the Employment Cost Index (ECI) for civilian workers to September
2009 dollars. These hourly rates were based on the average hourly wage
for civilian workers as determined by the U.S. Department of Labor. 

6(c) Estimating Agency Burden and Cost

EPA’s estimate of its burden and costs are from the activities
described in Section 5(a). When calculating the Agency cost, EPA makes
the following assumption:

EPA determined the hourly employment cost of federal employees using
methodology established in previous ICRs. According to the U.S. Office
of Personnel Management, 2009 General Schedule (2009-GS), the average
hourly wage of a federal employee at the GS-13, Step 5 level is $38.35.
Assuming overhead costs of 50 percent, or $19.18 per hour, the fully
loaded cost of employment for a program management-level federal
employee is $57.53. The average hourly wage for a federal employee at
the GS-8, Step 5 level is $20.13. Assuming overhead costs of 50 percent,
or $10.07 per hour, the fully loaded cost of employment for program
support-level federal employee is $30.20.  

Completeness Review  

EPA estimates that the Agency will spend approximately 0.17 hour (10
minutes) reviewing each application for completeness. In addition, EPA
estimates that 10 percent of the applications submitted will be
incomplete and will result in 0.5 hour each for additional follow-up.
The total annual burden for the completeness review is 147 hours and
$8,454. See Exhibits F.1, F.2 and F.9 in Appendix F.

Compliance Review

EPA estimates that the Agency will spend 0.33 hour (20 minutes)
reviewing each application for compliance. The total annual burden for
the compliance review is 204 hours and $11,717. See Exhibits F.3, F.4,
and F.9 in Appendix F.

Substantive Review

EPA estimates that the Agency will spend 0.33 hour (20 minutes) per
panel member for the substantive review. EPA assumed a total of three
panel members which results in a substantive review of 60 minutes for
each application. The total annual burden for the substantive review is
489 hours and $28,111. See Exhibits F.5, F.6 and F.9 in Appendix F.

 

Post-Review Recognition

The burden and cost for EPA is based on the time required to develop and
review the certificate and letter. EPA estimates that 0.33 hour (20
minutes) are required per recipient for certificates and letters. The
total annual burden for the post-review recognition is 122 hours and
$8,294. See Exhibits F.7, F.8, and F.9 in Appendix F.

6(d) Estimating the Respondents Universe and Total Burden and Cost

Detailed information describing the universe and basis for burden and
costs is provided in Section 6(a). Exhibits E.1 and E.2 in Appendix E
provides the respondents universe for all respondent categories used
throughout this ICR. The total burden and costs for respondents
submitting an application are summarized in Exhibit E.9 in Appendix E.  

6(e) Bottom Line Burden Hours and Cost Estimates

6(e)(i) Respondent Tally

The bottom line burden hours and costs for applicant respondents are the
average annual hours and costs collectively incurred for all activities
during the 3-year period covered by this ICR. Table 1 provides a summary
of the average annual number of respondents, burden hours, and costs.
See Exhibit E.9 in Appendix E for additional details.  

Table 1. Respondent Tally

 	Totals

Total Annual Number of Respondents	679

Total Annual Respondent Burden Hours	13,574

Average Burden Hours per Respondent	20.00

Costs (labor)	$614,919 

Costs (capital)-annualized	$0

Costs (O&M)	$0

Total Respondent Costs	$614,919 



6(e)(ii) The Agency Tally

The bottom line burden hours and costs for the Agency are the total
annual hours and costs collectively incurred for all activities during
the period covered by this ICR. Table 2 provides a summary for Appendix
F of the average annual Agency costs. See Exhibit F.9 in Appendix F for
additional details.  

Table 2. Summary of Agency Cost for the ICR Approval Period

 	Total Annual Costs (2009$)

Agency Totals	$56,575 



6(f) Reasons for Change in Burden

This ICR includes programmatic changes to the National Clean Water Act
Recognition Awards Program to develop the Sustainable Water Leadership
Program which are detailed below. 

The current burden approved by OMB for the previous Clean Water Act
(CWA) Recognition Awards ICR is 2,030 hours. In addition, the current
burden approved by OMB for pretreatment awards (whose burden will be
consolidated into this ICR) is 210 hours.  This ICR estimates a total
burden that is 11,544 hours more than the currently approved burden for
the previous ICR. Table 3 presents the change in burden.

Table 3. Burden Change

Respondent	Reported Annual Burden (hours)	Change

	Previous ICR OMB Inventory	Current ICR

	Respondents

Applicant Respondents	1,160	13,574	12,414

Subtotal	1,160	13,574	12,414

NPDES-Authorized States

NPDES-Authorized States	870	0	-870

Subtotal	870	0	-870

Total	2,030	13,574	11,544



Some reasons for the change in burden include the following:

Changes and adjustments in the number and types of applicants eligible
for recognition under the Sustainable Water Leadership Program. These
three changes are anticipated to increase the average annual number of
interested responses from 145 to 678.

The universe of eligible entities now includes community drinking water
utilities and systems, as well as managed decentralized treatment
systems (public or private), which were previously not addressed in any
ICR for the Clean Water Act Recognition Awards Program.  

Changes in the design of the program are expected to attract more
eligible applicants.

Additionally, it is anticipated that EPA’s active outreach will
increase the number of respondents interested in participating in the
program. 

EPA updated the estimated time spent by respondents to complete the
revised Recognition Application for Sustainable Water Leadership Program
to 20 hours per respondent based on staff input. 

Previously, EPA accounted for 870 hours for NPDES-Authorized States for
reviewing applications. EPA has assumed the burden and cost for this
activity since States are not expected to have requirements under the
Sustainable Water Leadership Program.

This ICR now encompasses burden hours for pretreatment awards. 
Historically, pretreatment burden hours were covered under a separate
ICR for the National Pretreatment Program (OMB Control No. 2040-0009,
EPA ICR No. 0002.14).  Burden hours for awards applications totaled 210
hours (120 for POTW’s and 90 for state agencies) in the most recent
Pretreatment ICR. These hours will be removed from the Pretreatment
Program ICR at its next renewal.

6(g) Burden Statement

The public reporting burden for respondents is estimated to average 20
hours per response. Burden means the total time, effort, or financial
resources expended by persons to generate, maintain, retain, or disclose
or provide information to or for a Federal agency. This includes the
time needed to review instructions; develop, acquire, install, and
utilize technology and systems for the purposes of collecting,
validating, and verifying information, processing and maintaining
information, and disclosing and providing information; adjust the
existing ways to comply with any previously applicable instructions and
requirements; train personnel to be able to respond to a collection of
information; search data sources; complete and review the collection of
information; and transmit or otherwise disclose the information. An
agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB control number. The OMB control numbers for EPA's regulations
are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OW-2003-0064, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Water Docket in the EPA Docket Center (EPA/DC),
EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The
EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal holidays.  The telephone
number for the Reading Room is (202) 566-1744, and the telephone number
for the Water Docket is (202) 566-2426.

An electronic version of the public docket is available at
www.regulations.gov.  This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the Docket ID Number identified above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OW-2003-0064 and OMB Control Number 2040-0101 in any
correspondence.

 Each type of applicant includes potential respondents from the
following types of utilities: publicly or privately owned wastewater
treatment plants or systems, community drinking water plants or systems,
managed decentralized treatment systems (public or private), and
municipally-owned stormwater systems.  These respondents encompass the
applicant pool from drinking water, wastewater, and pretreatment
facilities.

 From U.S. Department of Labor, Bureau of Labor Statistics, Employer
Costs for Employee Compensation, Table 2, “Employer costs per hour
worked for employee compensation and costs as a percent of total
compensation: Civilian workers, by occupational and industry group, June
2009.”: Management, business, and financial: $54.95, Professional and
related: $46.61, Office and administrative support: $23.04.
(http://stats.bls.gov/news.release/ecec.t02.htm)

OMB Review Draft--Do Not Quote, Cite, or Distribute

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