SECTION
I:
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
OF
THE
INFORMATION
COLLECTION
"
CLEAN
WATER
ACT
STATE
REVOLVING
FUND
PROGRAM"
(
OMB
Control
number
2040­
0118,
EPA
ICR
No.
1391.07)

1(
b)
SHORT
CHARACTERIZATION
(
ABSTRACT)

The
information
collection
activities
will
occur
primarily
at
the
program
level
through
the
State
"
Intended
Use
Plan"
and
"
Annual
Report".
The
information
is
needed
annually
to
implement
Section
606
of
the
Clean
Water
Act
(
CWA).
The
Act
requires
the
information
to
ensure
national
accountability,
adequate
public
comment
and
review,
fiscal
integrity,
and
consistent
management
directed
to
achieve
environmental
objectives.

The
individual
information
collections
are
described
as
follows:

a.
Capitalization
Grant
Agreement
and
Application
/
State
Intended
Use
Plan
The
capitalization
grant
agreement
and
application
is
the
principal
instrument
by
which
the
State
commits
to
manage
its
revolving
fund
program
in
conformity
with
the
requirements
of
the
CWA.
The
grant
agreement
contains
or
incorporates
by
reference
the
IUP,
application
materials,
payment
schedule,
and
required
certifications.
Information
on
hardship
grants,
Disadvantaged
Business
Enterprise
(
DBE),
environmental
indicators,
environmental
benefits,
core
measurements,
and
funding
framework
can
be
found
in
the
IUP.
The
grant
agreement
is
a
general
instrument
to
legally
commit
the
State
and
EPA
to
execute
their
responsibilities
under
the
Act.

b.
Annual
Report
The
annual
report
indicates
how
the
State
has
met
the
goals
and
objectives
of
the
previous
fiscal
year
as
stated
in
the
IUP
and
grant
agreement.
The
Report
provides
information
on
loan
recipients,
loan
amounts,
loan
terms,
hardship
grants,
DBE,
environmental
indicators,
environmental
benefits,
core
measurements,
funding
framework,
project
categories
of
eligible
costs,
and
similar
data
on
other
forms
of
assistance,
and
is
needed
for
input
into
the
SRF
National
Information
Management
System.
The
Report
also
describes
the
extent
to
which
the
existing
SRF
financial
operating
policies,
alone
or
in
combination
with
other
State
financial
assistance
programs,
will
provide
for
the
long­
term
fiscal
health
of
the
Fund
and
carry
out
other
provisions
specified
in
the
State
Clean
Water
Strategy.

c.
State
Annual
Audit
The
State
annual
audit
report
will
contain
opinions
on
the
financial
statements
of
the
SRF
and
reports
on
the
internal
controls,
and
whether
the
SRF
program
compliance
requirements
have
been
met.
Separate
financial
audits
may
be
done
in
conjunction
with
the
guidelines
of
the
Single
Audit
Act
of
1996.

d.
Applications
for
SRF
Financing
Assistance
Local
communities
have
a
responsibility
for
preparing
and
submitting
applications
for
SRF
assistance
to
their
respective
State
agency
which
manages
the
SRF
program.
The
State
has
sole
responsibility
for
reviewing
the
applications,
entering
into
loan
and
other
financing
arrangements
with
applicants,
and
otherwise
managing
operations
of
the
SRF.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
The
Clean
Water
Act,
as
amended
by
"
The
Water
Quality
Act
of
1987"
(
33
U.
S.
C.
1381­
1387
et.
seq.),
created
a
Title
VI
which
authorizes
grants
to
States
for
the
establishment
of
State
Water
Pollution
Control
Revolving
Funds
(
SRF's).
The
information
activities
are
pursuant
to
Section
606
of
the
Act,
EPA
Initial
Guidance
for
State
Revolving
Funds
(
January
1988),
and
SRF
Interim
Final
Rule
(
March
1990).

The
1987
Act
declares
that
water
pollution
control
revolving
loan
funds
shall
be
administered
by
an
instrumentality
of
the
State
subject
to
the
requirements
of
the
Act.
This
means
that
each
State
has
a
general
responsibility
for
administering
its
revolving
fund,
and
must
take
on
certain
specific
responsibilities
in
carrying
out
its
administrative
duties.

2(
b)
USE/
USERS
OF
THE
DATA
In
order
for
a
State
to
receive
a
capitalization
grant
for
its
revolving
fund,
it
must
enter
into
an
agreement
(
Capitalization
Grant
Agreement)
with
the
U.
S.
Environmental
Protection
Agency
(
EPA).
State
responsibilities
include:
a.
Contributing
20
Percent
Matching
Funds;
b.
Committing
Funds
Expeditiously;
c.
Jointly
Establishing
a
Payment
Schedule
With
the
Federal
Government;
d.
Ensuring
That
Enforceable
Requirements
are
Fulfilled
Before
Assistance
is
Provided
to
2
Recipients
for
Other
Purposes;
and
e.
Monitoring
Assistance
Recipient
Compliance
With
Program
Requirements
and
Other
Federal
Crosscutting
Authorities
During
the
Period
of
the
Assistance
Agreement.

A
State,
as
a
federal
grant
recipient,
must
also
agree
to
follow
generally
accepted
government
accounting
standards.
A
State
is
expected
to
have
an
annual
financial
audit
conducted
and
must
assure
that
assistance
recipients
adhere
to
appropriate
accounting
and
auditing
procedures.

The
information
to
be
provided
to
EPA
by
the
States
include:
a.
Capitalization
Grant
Agreement
and
Application
/
Intended
Use
Plan;
b.
Annual
Report;
and
c.
State
Annual
Audit.

Upon
approval
of
the
capitalization
grant
application,
each
State
has
the
responsibility
to
establish
its
State
Revolving
Fund
(
SRF)
program.
Once
the
SRF
is
operational,
the
State
will
receive
and
review
applications
for
SRF
financing
assistance
submitted
by
local
communities.
The
State
will
review
the
applications
for
conformance
with
the
SRF
Intended
Use
Plan,
environmental
impacts,
and
financial
capability
of
the
applicant.
For
those
projects
funded
with
monies
directly
made
available
by
the
Federal
capitalization
grant,
the
State
will
also
review
the
proposed
project
for
consistency
with
applicable
Title
II
requirements
and
other
Federal
cross­
cutting
authorities
as
described
in
the
SRF
Initial
Guidance
and
other
SRF
program
materials.
The
specific
procedures
for
preparation
and
review
of
application
materials
will
be
developed
by
each
State.
If
an
application
is
acceptable,
the
State
prepares
the
appropriate
loan
agreement
documents.

Although
EPA
oversees
the
general
operations
of
the
SRF
programs
as
part
of
its
Annual
Review
process,
the
Agency
does
not
have
any
responsibility
for
reviewing
or
approving
individual
applications
for
SRF
financial
assistance.

3.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
3(
a)
RESPONDENTS/
SIC
CODES
State
and
local
governments;
local
communities
and
tribes
(
SIC
Code
#
99)

3(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
3
In
general,
the
information
collections
are
required
to
ensure
compliance
with
Title
VI
of
the
Clean
Water
Act
and
to
ensure
that
self­
sufficient
SRF
programs
are
established
in
perpetuity.
These
information
elements
also
provide
the
accountability
needed
to
detect
and
remedy
situations
of
waste,
fraud,
and
abuse
of
Federal
funds.

The
individual
information
collections
are
described
as
follows:

a.
Capitalization
Grant
Agreement
and
Application
/
State
Intended
Use
Plan
The
capitalization
grant
application
is
made
on
EPA
short
form
No.
5700­
33
(
OMB
No.
2030­
0020).
The
minimal
increase
in
State
burden
associated
with
use
of
this
form
is
being
handled
separately
by
the
Grants
Administration
Division
in
their
information
collection
budget
request.

The
SRF
Management
Manual
includes
a
model
IUP
which
should
improve
program
efficiency
and
reduce
the
burden
on
States
and
EPA
Regions.

b.
Annual
Report
Section
606
(
d)
requires
the
States
to
submit
an
annual
report
at
the
end
of
each
fiscal
year
that
identifies
how
the
State
has
met
the
goals
and
objectives
of
the
previous
fiscal
year
as
stated
in
the
IUP
and
grant
agreement.
The
annual
report
provides
information
on
loan
recipients,
loan
amounts,
loan
terms,
DBE,
project
categories,
and
similar
data
on
other
forms
of
assistance.
The
annual
report
describes
the
extent
to
which
the
existing
SRF
financial
operating
policies,
alone
or
in
combination
with
other
State
Financial
assistance
programs,
will
provide
for
the
long
term
fiscal
health
of
the
Fund
and
carry
out
other
provisions
specified
in
the
grant
operation
agreement.

To
reduce
the
burden
on
the
States,
EPA
developed
a
model
annual
report,
patterned
after
the
model
IUP.
This
model
is
included
in
the
SRF
Management
Manual.

c.
State
Annual
Audit
Most
States
have
agreed
to
conduct
or
to
have
conducted
a
separate
financial
audit
of
the
capitalization
grant
which
will
provide
opinions
on
the
financial
statements,
and
a
report
on
the
internal
controls
and
compliance
with
program
requirements.
The
remaining
States
will
be
covered
by
audits
conducted
under
the
requirements
of
the
Single
Audit
Act
by
the
EPA
Office
of
Inspector
General.
4
d.
Applications
for
SRF
Financing
Assistance
Local
communities
and
other
eligible
entities
have
to
prepare
and
submit
applications
for
SRF
assistance
to
their
respective
State
Agency
which
manages
the
SRF
program.
Title
VI
outlines
eligibilities
under
the
SRF
program
in
terms
of
potential
recipients,
types
of
projects
and
activities
which
may
receive
SRF
assistance,
and
the
types
of
financial
assistance
which
an
SRF
may
provide.
The
Clean
Water
Act
provides
significant
flexibility
to
the
States
regarding
the
development
of
specific
procedures
for
reviewing
and
approving
applications
for
SRF
assistance
and
for
managing
the
SRF
program.

Specific
reporting
requirements
which
are
statutorily
based
relate
only
to
the
relationship
between
the
State
as
recipient
of
the
Federal
capitalization
grant
and
the
Agency
as
grantor.
Similarly,
the
SRF
Initial
Guidance,
the
Interim
Final
Rule,
SRF
Management
Manual,
and
other
SRF
program
materials
do
not
provide
guidance
or
direction
to
the
States
regarding
the
development
of
application
materials
or
specific
procedures
for
the
processing
and
disposition
of
applications
for
SRF
assistance.

Generally,
the
applications
for
SRF
assistance
require
local
communities
to
provide
the
following
information:
o
Project
description;
o
Project
cost
estimate;
o
Estimated
construction
schedule;
o
Projected
disbursement
schedule;
o
Description
of
environmental
benefits;
o
Estimation
of
cost
impacts
on
users;
o
Identification
of
repayment
source;
o
Description
of
community
financial
capability;
and
o
For
certain
projects,
certifications
and
demonstrations
regarding
compliance
with
applicable
Title
II
requirements
and
other
Federal
cross­
cutting
authorities.

(
ii)
Respondent
Activities
The
respondents
(
State
and
local
governments)
prepare
and
submit
the
following
in
order
to
apply
for
Federal
financial
assistance:
o
Capitalization
Grant
Agreement
and
Application
/
Intended
Use
Plan;
o
Annual
Report;
o
State
Annual
Audit;
and
o
Applications
for
SRF
Financing
Assistance.
5
4.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
4(
a)
AGENCY
ACTIVITIES
The
Agency
reviews
the
submissions
from
the
State
and
local
governments
and
analyzes
the
data
provided
on
the
Capitalization
Grant
Agreement
and
Application
/
Intended
Use
Plan
in
order
to
base
its
decisions
for
approval.
The
Agency
reviews
the
annual
reports
and
the
annual
audits
from
each
state
to
ensure
that
the
intended
financial
and
programmatic
objectives
of
the
program
are
being
met.

4(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
The
SRF
Management
Manual
includes
a
model
agreement
which
draws
from
the
existing
Construction
Grant
Agreement.
Use
of
this
example
is
likely
to
reduce
the
information
burden
on
States
and
EPA
Regions.

Section
606(
c)
requires
the
State
to
prepare
a
plan
identifying
the
intended
uses
of
the
funds
in
the
SRF
and
describing
how
those
uses
support
the
goals
of
the
SRF.
This
Intended
Use
Plan
(
IUP)
must
be
submitted
annually,
after
the
State
has
provided
an
opportunity
for
public
comment
and
review.
The
primary
purpose
of
the
IUP
is
the
identification
of
proposed
annual
intended
uses
of
the
amounts
available
to
the
SRF.
The
secondary
purpose
of
the
IUP
is
the
facilitation
of
the
negotiation
process
for
the
capitalization
grant
agreement
and
schedule
of
grant
payments
(
Section
606(
b)).

Under
section
606(
c)(
l),
the
IUP
must
contain
a
list
of
publicly­
owned
treatment
works
projects
on
the
State's
priority
list
that
are
eligible
for
SRF
construction
assistance.
This
IUP
list
includes:
the
community
name;
the
permit
number
or
other
applicable
enforceable
requirement;
the
type
of
financial
assistance;
and
the
projected
amount
of
eligible
assistance.

Under
section
606(
c)(
2),
the
State
must
describe
long
and
short
term
goals
and
objectives
of
its
water
pollution
control
revolving
fund.

Under
section
606(
c)(
3),
the
IUP
must
include
information
on
the
types
of
activities
to
be
supported
by
the
SRF.

Section
606(
c)(
4)
requires
that
assurances
and
specific
proposals
be
contained
in
the
IUP
to
describe
how
the
State
6
intends
to
meet
the
following
requirements:

­
Section
602(
a)­­
State
certification
that
it
will
conduct
environmental
reviews
on
treatment
works
projects
and
submit
the
specific
procedures
it
will
use.

­
Section
602(
b)(
3)­­
State
certification
that
it
will
enter
into
binding
commitments.
The
estimated
schedule
for
the
binding
commitments
is
a
part
of
the
IUP.

­
Section
602(
b)(
4)
­
State
certification
that
all
funds
in
the
SRF
will
be
expended
in
an
expeditious
and
timely
manner.

­
Section
602(
b)(
5)­­
State
identification
of
all
projects
expected
to
be
funded
with
"
first
use"
funds
to
meet
the
enforceable
requirements
of
the
Act.
All
States
have
certified
compliance
with
this
requirement.

­
Section
602(
b)(
6)­­
State
certification
that
it
will
ensure
compliance
with
Title
II
requirements.
In
cases
where
the
State
will
not
be
following
EPA
regulations,
it
will
submit
a
description
of
its
own
specific
procedures
for
ensuring
that
the
Title
II
requirements
are
met.
It
is
expected
that
individual
State
procedures
will
not
differ
substantially
from
procedures
already
being
followed
by
all
the
delegated
States.

Section
606(
c)(
5)
requires
that
the
IUP
describe
the
criteria
and
methods
established
for
the
distribution
of
the
SRF
funds.
The
first
part
describes
the
distribution
of
the
various
types
of
assistance
offered
by
the
State
(
e.
g.,
loans,
guarantees,
insurance,
refinancing
of
existing
debt,
leveraging).
The
second
part
describes
the
process
the
State
will
use
to
select
section
212
POTW
construction
projects
from
the
project
priority
list,
and
projects
or
programs
to
be
funded
as
eligible
activities
for
nonpoint
source
(
NPS)
and
estuary
protection
management
programs.
This
section
also
includes
how
the
State
will
provide
opportunity
for
public
comment
and
review
of
the
IUP
before
submitting
it
in
final
form
to
EPA.

Except
for
the
NPS
and
estuarine
management
programs
under
Sections
319
and
320,
the
procedures
for
selecting
projects
from
the
State
priority
list
and
for
providing
for
public
participation
have
already
been
established
under
the
existing
Construction
Grant
Program.
Therefore,
the
burden
connected
with
this
part
of
the
IUP
will
also
be
minimal.

Payment
Schedule
­­
Based
on
its
projection
of
binding
7
commitments
in
its
Intended
Use
Plan,
the
State
must
propose
a
draft
payment
schedule.
The
payment
schedule
and
the
specific
criteria
establishing
the
conditions
under
which
the
State
may
draw
cash
from
ASAP
(
Automated
Standard
Application
for
Payments
system)
must
be
jointly
established
by
EPA
and
the
State.
A
schedule
of
estimated
disbursements
is
also
required
to
allow
a
forecast
of
the
amount
of
funds
to
be
drawn
from
ASAP
during
the
upcoming
Federal
fiscal
year.
This
forecast
is
necessary
to
plan
the
outlay
of
Federal
funds
from
the
Treasury
due
to
the
Title
VI
program.

In
its
Annual
Report,
the
State
verifies
that
it
has:

­
Reviewed
all
SRF
funded
section
212
projects
in
accordance
with
the
approved
environmental
review
procedures
(
section
602(
a));

­
Deposited
its
matching
funds
on
or
before
the
date
on
which
each
EPA
quarterly
grant
payment
was
made
(
section
602(
b)(
2));

­
Made
binding
commitments
to
provide
assistance
equal
to
120
percent
of
the
amount
of
each
grant
payment
within
one
year
after
receiving
the
grant
payment
(
section
602(
b)(
4));

­
Expended
all
monies
in
the
fund
in
an
expeditious
and
timely
manner
(
section
602(
b)(
4));

­
First
used
all
monies
in
the
fund
as
a
result
of
capitalization
grants
to
assure
maintenance
of
progress
toward
compliance
with
the
enforceable
requirements
of
the
Act
(
section
602(
b)(
5));
and
­
Complied
with
the
Title
II
and
other
Federal
crosscutting
requirements
applicable
to
those
eligible
treatment
works
funded
in
whole
or
in
part
before
fiscal
year
1995
with
an
amount
equivalent
to
the
capitalization
grant
(
section
602(
b)(
6)).

Under
section
606(
b),
at
least
once
a
year
the
Administrator
(
through
the
Office
of
the
Inspector
General)
will
expect
the
State
to
independently
conduct
or
to
have
conducted
a
financial
and
compliance
audit
of
the
SRF
and
its
operations.
The
State
may
designate
an
independent
auditor
of
the
State
to
carry
out
the
audit
or
may
contractually
procure
the
service.
If
the
State
fails
to
conduct
the
audit
or
if
the
review
is
unsatisfactory,
the
Office
of
Inspector
General
(
OIG)
may
arrange
for
an
EPA
audit.
The
OIG
is
currently
developing
an
audit
guide
for
SRFs,
which
should
reduce
the
burden
on
States
that
wish
to
conduct
their
own
audits
and
improve
the
efficiency
of
EPA
reviews.
8
Title
VI
outlines
eligibilities
under
the
SRF
program
in
terms
of
potential
recipients,
types
of
projects
and
activities
which
may
receive
SRF
assistance,
and
the
types
of
financial
assistance
which
an
SRF
may
provide.
The
Clean
Water
Act
provides
significant
flexibility
to
the
States
regarding
the
development
of
specific
procedures
for
reviewing
and
approving
applications
for
SRF
assistance
and
for
managing
the
SRF
program.

Specific
reporting
requirements
which
are
statutorily
based
relate
only
to
the
relationship
between
the
State
as
recipient
of
the
Federal
capitalization
grant
and
the
Agency
as
grantor.
Similarly,
the
SRF
Initial
Guidance,
the
Interim
Final
Rule,
SRF
Management
Manual,
and
other
SRF
program
materials
do
not
provide
guidance
or
direction
to
the
States
regarding
the
development
of
application
materials
or
specific
procedures
for
the
processing
and
disposition
of
applications
for
SRF
assistance.

The
Initial
Guidance
and
Interim
Final
Rule
on
State
Revolving
Funds
impose
virtually
no
requirements
on
States
that
go
beyond
those
imposed
by
the
Clean
Water
Act
itself.
The
guidance
and
rule
were
designed
to
promote
flexibility
for
States
in
establishing
and
operating
their
SRF
programs,
within
the
bounds
of
the
Act.

Because
the
SRF
is
a
dynamic
State­
led
program,
EPA
has
undertaken
many
activities
to
support
the
Regions
and
States
with
implementation.
EPA
has
prepared
model
documents
relating
to
intended
use
plans,
capitalization
grant
agreements,
and
annual
reports.
EPA
Regional
personnel
are
regularly
in
contact
with
their
State
counterparts
and
are
currently
working
to
determine
efficient
ways
to
communicate
needed
information
and
reduce
the
burden.
The
information
collection
activities
will
occur
primarily
at
the
program
level
through
the
State
Intended
Use
Plan
and
Annual
Report.
The
information
is
needed
annually
to
implement
Section
606
of
the
Clean
Water
Act
(
CWA).
The
Act
requires
the
information
to
ensure
national
accountability,
adequate
public
comment
and
review,
fiscal
integrity,
and
consistent
management
directed
to
achieve
environmental
objectives.

4(
c)
SMALL
ENTITY
FLEXIBILITY
A
majority
of
the
reporting
burden
(
IUP,
annual
report,
annual
audit,
etc.)
is
imposed
on
the
States.
For
those
communities/
municipalities
desiring
financial
assistance
from
the
SRF,
they
will
have
a
smaller
reporting
burden
requirement
(
loan
applications).
For
those
small
or
local
businesses
requiring
assistance
(
and
which
may
be
non­
point
source),
they
will
also
prepare
loan
applications
similar
to
9
the
communities/
municipalities
requirement
for
submittal
to
the
State
program
office.

4(
d)
COLLECTION
SCHEDULE
The
information
collection
activities
will
occur
primarily
at
the
program
level
through
the
State
Intended
Use
Plan
and
Annual
Report.
The
information
is
needed
annually
to
implement
Section
606
of
the
Clean
Water
Act
(
CWA).
The
Act
requires
the
information
to
ensure
national
accountability,
adequate
public
comment
and
review,
fiscal
integrity,
and
consistent
management
directed
to
achieve
environmental
objectives.

5.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
5(
a)
NONDUPLICATION
The
information
collection
elements
are
specific
to
Title
VI,
established
under
the
amendments
to
the
Clean
Water
Act.
The
information
in
the
Intended
Use
Plan,
Annual
Report,
and
State
Audit
is
unique
to
each
State
participating
in
the
SRF
program.
Therefore,
duplication
of
effort
is
not
experienced.
The
information
activities
herein
are
based
upon
program
specific
State
sources
which
are
not
duplicated
anywhere
else.

5(
b)
CONSULTATIONS
The
information
requirements
were
subjected
to
the
same
reviews
as
the
other
requirements
and
procedures
contained
in
the
Initial
Guidance
in
the
process
of
development.
The
Concept
Paper,
draft
Initial
Guidance,
and
draft
Interim
Final
Rule
were
commented
on
by
members
of
the
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
(
ASIWPCA),
other
State
officials,
representatives
of
local
government,
private
concerns
involved
with
municipal
finance,
EPA
Regional
and
Headquarters'
offices,
and
the
Office
of
Management
and
Budget
(
OMB).

Some
commentators
objected
to
the
level
of
detail
required
by
the
Draft
Initial
Guidance,
particularly
the
implied
need
for
project­
by­
project
disbursement
schedules.
EPA
is
requiring
the
proposed
payment
schedule
to
be
supported
by
an
estimate
of
cash
disbursements
from
the
SRF
at
a
level
of
detail
sufficient
to
allow
negotiations
on
the
payment
process.
It
is
crucial
that
EPA
have
estimates
of
cash
disbursements
from
each
State
in
order
to
accurately
project
and
manage
the
cash
outlays
on
a
national
level.
10
5(
c)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
The
statute
(
Clean
Water
Act)
requires
the
information
to
be
provided
at
least
annually.
EPA
is
not
requesting
the
information
more
frequently,
although
a
State
may
submit
it
more
frequently
if
it
wishes
(
e.
g.,
semi­
annual
audit
instead
of
annual
audit).

The
information
is
indispensable
for
prudent
administration
and
sound
fiscal
management
of
the
State
Revolving
Fund
Program.
EPA
will
use
the
information
to
respond
to
OMB
and
Congressional
requests
and
requirements
for
accurate
analysis
and
projection
of
national
budget
impacts
and
needs.
It
will
be
relied
upon
by
State
managers
for
key
planning
decisions
and
by
EPA
managers
for
essential
program
evaluation
and
corrective
measures.

Local
communities
are
not
required
to
apply
for
SRF
assistance.
Preparation
of
an
application
is
only
necessary
if
the
community
wishes
to
receive
financial
assistance.
In
view
of
likely
funding
availability
at
the
State
level,
only
a
limited
number
of
communities
will
likely
receive
assistance
in
a
particular
year.
The
impact
on
communities
generally
is
quite
limited.

5(
d)
GENERAL
GUIDELINES
The
data
collections
covered
by
this
ICR
are
in
compliance
with
the
OMB
General
Guidelines
for
information
collections.

5(
e)
CONFIDENTIALITY
AND
SENSITIVE
QUESTIONS
(
i)
Confidentiality
No
confidential
data
is
collected.

(
ii)
Sensitive
Questions
No
such
information
is
required.

5
(
f)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
The
first
Federal
Register
Notice
soliciting
public
comment
on
this
ICR
was
published
August
5,
2004.
No
comments
were
received.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
The
respondent
burden
estimates
are
based
on
the
incremental
effort
associated
with
the
information
collection
activity.
As
program
activity
increases
at
the
local
and
State
level
the
preparation
and
review
of
local
community
applications
11
for
SRF
assistance
will
likely
increase.

The
estimation
of
State
respondents'
burden
for
the
four
information
collections
are
shown
below:

a.
Capitalization
Grant
Agreement
and
Application
/
State
Intended
Use
Plan
We
estimate
that
States
will
spend
an
average
of
400
hours
each
to
prepare
the
Capitalization
Grant
Agreement
and
Application
/
State
Intended
Use
Plan
for
submission
to
EPA.
The
information
provided
for
hardship
grants,
environmental
benefits,
core
measurements
and
funding
framework
is
included
in
the
burden
hour
estimate.
The
following
chart
represents
the
total
national
burden
from
the
Capitalization
Grant
Agreement
and
Application
/
State
Intended
Use
Plan.

2004:
51
States
X
400
hrs
=
20,400
burden
hours
2005:
51
States
X
400
hrs
=
20,400
burden
hours
2006:
51
States
X
400
hrs
=
20,400
burden
hours
b.
Annual
Report
EPA
estimates
that
over
the
three
year
period
covered
by
this
ICR
the
States
will
spend
an
average
of
275
hours
to
put
together
their
Annual
Report
on
the
SRF
program.
The
annual
report
will
include
information
on
hardship
grants,
DBE,
environmental
benefits,
core
measurements,
funding
framework,
and
input
for
the
SRF
National
Information
Management
System.

2004:
51
States
X
275
hrs
=
14,025
burden
hours
2005:
51
States
X
275
hrs
=
14,025
burden
hours
2006:
51
States
X
275
hrs
=
14,025
burden
hours
c.
State
Annual
Audit
The
estimated
average
burden
for
each
State
Annual
Audit
was
80
hours
per
year.
It
should
be
noted
that
all
States
are
expected
to
have
an
annual
financial
audit
of
their
program
conducted,
including
opinions
on
the
financial
statements,
and
reports
on
internal
controls
and
compliance
with
program
requirements.
This
estimate
is
based
on
the
extra
increment
of
effort
caused
by
the
federal
requirement.
Some
States
will
build
on
the
Single
Audit
Act
audits
while
others
will
simply
have
annual
financial
audits
conducted
on
their
program.

2004:
51
States
X
80
hrs
=
4,080
burden
hours
2005:
51
States
X
80
hrs
=
4,080
burden
hours
2006:
51
States
X
80
hrs
=
4,080
burden
hours
It
is
important
to
note
that
respondents
may
use
SRF
12
administrative
monies
to
pay
for
costs
resulting
from
the
State
Annual
Audit.
Section
603(
d)(
7)
of
the
Act
allows
money
in
the
SRF
to
be
used
for
the
reasonable
costs
of
administering
the
Fund,
provided
that
the
amount
does
not
exceed
four
percent
of
the
Federal
grant
awards
received
by
the
State
SRF.
If
the
effort
required
under
the
State
Audit
exceeds
the
requirements
under
the
Single
Audit
Act,
the
incremental
costs
associated
with
the
additional
effort
may
be
paid
from
the
administrative
monies.

d.
SRF
Assistance
Application
Preparation
and
Review
States
have
total
responsibility
for
reviewing
and
approving
local
applications
for
assistance
from
the
SRF
program.
We
estimate
that
States
will
spend
an
average
of
40
hours
in
reviewing
and
approving
each
assistance
application.
The
following
chart
represents
the
total
national
State
burden
in
processing
SRF
assistance
applications.

2004:
51
States
X
54
appl.
X
40
hrs
=
110,160
hours
2005:
51
States
X
59
appl.
X
40
hrs
=
120,360
hours
2006:
51
States
X
64
appl.
X
40
hrs
=
130,560
hours
States
develop
specific
procedures
and
reporting
and
application
materials
for
SRF
assistance
applicants.
We
estimate
that
local
communities
and
tribes
will
spend
an
average
of
60
hours
in
collecting
information
and
preparing
their
SRF
assistance
applications.
The
following
chart
represents
the
total
national
local
community
burden
in
preparing
SRF
assistance
applications.

2004:
2,754
Comm.
X
60
hrs
=
165,240
burden
hours
2005:
3,009
Comm.
X
60
hrs
=
180,540
burden
hours
2006:
3,264
Comm.
X
60
hrs
=
195,840
burden
hours
Average
Annual
State
Burden
Hours
(
FY
2004­
2006):

Hours
Hours
ICR
per
State
all
States
Capitalization
Grant
Agreement
1,200
61,200
and
Application
/
State
Intended
Use
Plan
Annual
Report
825
42,075
State
Annual
Audit
240
12,240
Application
Review
7,080
361,080
13
Total
Burden
Hrs.(
FY
2004­
2006)
9,345
476.595
Average
Annual
Burden
Hours
(
FY
2004­
2006)
3,115
158,865
Total
Local
Community
Burden
Hours
(
FY
2004­
2006):

Hours
Hours
ICR
per
Comm.
all
Comm.

Application
Preparation
180
541,620
Average
Annual
Local
Community
Burden
Hours
(
FY
2004­
2006):

Hours
Hours
ICR
per
Comm.
all
Comm.

Application
Preparation
60
180,540
6(
b)
ESTIMATING
RESPONDENT
COSTS
a.
Costs
To
State
Respondents
The
average
annual
State
Costs
for
the
three­
year
period
is
estimated
to
be
$
1,642,200.

It
is
important
to
note
that
costs
to
the
States
are
grant
eligible,
and
therefore,
are
indirect
Federal
costs
paid
out
of
the
SRF.
Under
section
603(
d)(
7),
money
in
the
SRF
may
be
used
for
the
reasonable
costs
of
administering
the
Fund,
provided
that
the
amount
does
not
exceed
four
percent
of
all
grant
awards
received
by
the
SRF.
SRF
administrative
monies
may
be
used
for
all
reasonable
costs
that
would
be
eligible
under
section
205(
g)
for
delegated
program
and
project
management,
to
the
extent
those
types
of
costs
are
incurred
for
management
of
the
SRF
and
for
projects
receiving
financial
assistance
from
the
SRF.
(
If
actual
State
expenditures
for
administrative
costs
of
managing
the
SRF
exceed
the
four
percent
limit,
the
excess
costs
must
be
paid
from
other
State
monies.)

A
small
sample
of
State
respondents
were
selected
for
interviews
for
assessing
costs
and
hourly
burden.
The
respondents
provided
estimates
for
the
costs
associated
with
the
information
collection
activity.
The
estimates
were
averaged
for
the
four
individual
activities
involving
information
collections
that
have
already
been
described.
The
averages
were
multiplied
14
to
reflect
participation
by
all
States
in
the
SRF
program
and
by
the
States'
reported
FTE
(
full­
time
employee)
direct
labor
costs.

FY
2004
ICR
#
States
Hours
$/
Hour
$
Cost
Capitalization
Grant
Agreement
and
Application
/
Intended
Use
Plan
­
Initial
Plan
51
300
30.00**
459,000
­
Revised
Plan
51
60
30.00**
91,800
Annual
Report
51
175
30.00**
267,750
State
Audit
51
80
30.00**
122,400
Appl.
Review
51
320
30.00**
489,600
Total
FY
2004
State
Cost
$
1,430,550
**
State
salary
cost
is
figured
at
$
25.00
per
hour
to
cover
technically
trained
personnel
plus
an
additional
ADP
cost
of
$
5.00
per
hour
=
$
30.00
total
per
hour.

FY
2005
ICR
#
States
Hours
S/
Hour
$
Cost
Capitalization
Grant
Agreement
and
Application
/
Intended
Use
Plan
­
Initial
Plan
51
250
30.00**
382,500
­
Revised
Plan
51
50
30.00**
76,500
Annual
Report
51
200
30.00**
306,000
State
Audit
51
80
30.00**
122,400
Appl.
Review
51
480
30.00**
734,400
Total
FY
2005
State
Cost
$
1,621,800
FY
2006
ICR
#
States
Hours
$/
Hour
$
Cost
Capitalization
Grant
Agreement
and
Application
/
Intended
Use
Plan
­
Initial
Plan
51
250
30.00**
382,500
15
­
Revised
Plan
51
50
30.00**
76,500
Annual
Report
51
250
30.00**
382,500
State
Audit
51
75
30.00**
114,750
Appl.
Review
51
600
30.00**
918,000
Total
FY
2006
State
Cost
$
1,874,250
Total
State
costs
(
FY
2004­
2006)
$
4,926,600
Average
annual
cost
over
3­
year
period
$
1,642,200
b.
COSTS
TO
LOCAL
RESPONDENTS
Local
communities
may
incur
costs
in
identifying
and
evaluating
their
water
quality
problems.
Likewise,
communities
may
need
to
absorb
costs
related
to
the
development
and
evaluation
of
alternative
planning
and
engineering
approaches
for
solving
the
water
quality
problems.
These
planning
and
design
costs
may
be
eligible
for
SRF
assistance
at
a
State's
option.
For
the
purpose
of
this
information
collection,
only
the
direct
costs
associated
with
preparation
of
the
application
for
SRF
financial
assistance
are
reported.

During
the
period
of
this
information
collection
activity,
the
SRF
program
will
experience
growth
in
the
number
of
communities
which
receive
SRF
financial
assistance.
The
number
of
communities
in
each
State
will
vary
significantly
according
to
the
funding
available,
the
types
of
projects
to
be
assisted,
the
average
cost/
size
of
projects,
and
other
factors.
The
Agency
estimates
that
the
number
of
local
communities
to
receive
SRF
assistance
during
the
period
of
this
information
collection
to
be
as
follows:
2004
­
54
per
State;
2005
­
59
per
State;
2006
­
64
per
State.

Only
communities
which
desire
financial
assistance
from
the
SRF
will
prepare
applications.
Therefore,
this
information
collection
will
pertain
only
to
a
limited
number
of
communities.
The
specific
requirements
and
complexity
of
application
materials
varies
widely
among
the
States
which
are
responsible
for
SRF
program
implementation
and
management.
The
Agency
estimates
that
on
average,
communities
will
spend
approximately
60
hours
in
completing
their
SRF
assistance
applications.

FY
2004
ICR
#
Communities
Hours
$/
Hour
$
Cost
16
Appl.
Prep.
2,754
60
25.00
4,131,000
FY
2005
ICR
#
Communities
Hours
$/
Hour
$
Cost
Appl.
Prep.
3,009
60
25.00
4,513,500
FY
2006
ICR
#
Communities
Hours
$/
Hour
$
Cost
Appl.
Prep.
3,264
60
25.00
4,896,000
Total
Local
costs
(
FY
2004­
2006)
$
13,540,500
Average
annual
cost
over
3­
year
period
$
4,513,500
17
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
Estimation
of
the
direct
costs
to
EPA
to
implement
the
SRF
Program
covers
negotiation
and
analysis
of
the
Intended
Use
Plan
(
including
Capitalization
Grant
Agreement
and
Application),
and
assessment
of
State
performance
and
compliance
through
the
Annual
Report
and
State
Audit.
Analysis
of
documents,
information,
and
data
includes
receipt,
validation,
verification,
and
evaluation.

Authorization
for
the
SRF
Program
expired
in
FY
1994,
however,
since
future
appropriations
for
the
program
are
anticipated,
States
will
continue
to
submit
applications
for
capitalization
grants.
Many
States
are
expected
to
make
modifications
to
their
programs.
These
changes
may
include
new
funding
approaches
(
e.
g.,
leveraging
funds,
alternative
sources
for
required
State
matching
funds),
revised
environmental
review
procedures,
and
alternative
methods
to
assure
compliance
with
program
requirements.
Review
and
approval
of
these
changes
will
require
Regional
and,
in
some
cases,
Headquarters
resources.

The
estimates
below
reflect
Agency
workloads
over
the
three
year
period
covered
by
this
ICR.
The
estimate
of
EPA
costs
is
based
on
average
hourly
expenditures,
including
Regional
and
Headquarters
personnel
compensation
and
benefits.
The
estimates
were
based
on
participation
by
all
States
in
the
SRF
Program.

The
average
annual
Federal
cost
of
$
1,476,360
over
the
three­
year
period
was
estimated
as
follows:

FY
2004
ICR
Hours
$/
Hour
$
Cost
EPA
HQ
Review
of
IUP
1,000
41.00*
41,000
and
Agreement
Materials
(
20
hrs
per
State
submission)

EPA
Regions'
Review
of
IUP
17,500
34.49**
603,575
and
Agreement
Materials
(
350
hrs
per
State
submission)

EPA
HQ
Oversight
Review
1,080
41.00*
44,280
of
Annual
Report/
Audit
(
20
hours
per
State
submission)
18
EPA
Regions'
Oversight
20,000
34.49**
689,800
Review
of
Annual
Report/
Audit
(
400
hours
per
State
submission)

Total
FY
2004
Federal
Cost
$
1,378,655
*
GS
13/
5,
including
PC&
B
(
personnel
compensation
and
benefits).
**
GS
12/
5,
including
PC&
B.

FY
2005
ICR
Hours
S/
Hour
$
Cost
EPA
HQ
Review
of
IUP
750
41.00*
30,750
and
Agreement
Materials
(
15
hours
per
State
submission)

EPA
Regions'
Review
of
17,500
34.49**
603,575
IUP
and
Agreement
Materials
(
350
hours
per
State
submission)

EPA
HQ
Oversight
Review
1,500
41.00*
61,500
of
Annual
Report/
Audit
(
30
hours
per
State
submission)

EPA
Regions'
Oversight
22,500
34.49**
776,025
Review
of
Annual
Report/
Audit
(
450
hours
per
State
submission)

Total
FY
2005
Federal
Cost
$
1,471,850
FY
2006
ICR
Hours
S/
Hour
$
Cost
EPA
HQ
Review
of
IUP
750
41.00*
30,750
and
Agreement
Materials
(
15
hours
per
State
submission)

EPA
Regions'
Review
of
17,500
34.49**
603,575
IUP
and
Agreement
Materials
(
350
hours
per
State
submission)
19
EPA
HQ
Oversight
Review
2,000
41.00*
82,000
of
Annual
Report/
Audit
(
40
hours
per
State
submission)

EPA
Regions'
Oversight
25,000
34.49**
862,250
Review
of
Annual
Report/
Audit
(
500
hours
per
State
submission)

Total
FY
2006
Federal
Cost
$
1,578,575
Total
Federal
costs
(
FY
2004­
2006)
$
4,429,080
Average
annual
cost
over
3­
year
period
$
1,476,360
6(
d)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
/
BURDEN
TABLES
(
i)
Respondent
Burden
(
FY
2004­
2006)

Total
State
Burden
Hours
476,595
Average
Annual
State
Burden
Hours
158,865
Total
State
Costs
$
4,926,600
Average
Annual
State
Costs
$
1,642,200
Total
Local
Burden
Hours
541,620
Average
Annual
Local
Burden
Hours
180,540
Total
Local
Costs
$
13,540,500
Average
Annual
Local
Costs
$
4,513,500
Total
Average
Annual
Respondents
(
State
and
Local)
3,060
Total
Average
Annual
Respondent
(
State
and
local)
Burden
Hours
339,405
Total
Average
Annual
Respondent
(
State
and
Local)
Cost
$
6,155,700
(
ii)
The
Agency
Tally
(
FY
2004­
2006)
20
Total
Federal
Costs
$
4,429,080
Average
Annual
Federal
Costs
$
1,476,360
Total
Federal
Burden
Hours
127,080
Average
Annual
Federal
Burden
Hours
42,360
6(
e)
REASONS
FOR
CHANGE
IN
BURDEN
The
change
in
the
State
and
local
respondent
burden
of
76,500
hours
is
attributed
to
an
increased
estimate
on
the
number
of
respondents
interested
in
receiving
SRF
loans
(
adjustment).
The
previous
ICR
estimated
the
number
of
respondents
to
be
2,295,
while
this
ICR
estimates
the
number
of
respondents
to
be
3,060.
More
entities
will
be
applying
for
SRF
loans
than
in
previous
years.

6(
f)
BURDEN
STATEMENT
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
111
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
21
Docket
ID
No.
OW­
2004­
0015,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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.
Once
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,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2004­
0015)
and
OMB
control
number
(
2040­
0118)
in
any
correspondence.
