Information Collection Request for the

Clean Water Act State Revolving Fund Program

Section 606 of the Clean Water Act (Renewal)

EPA ICR Number 1391.08

OMB Control Number 2040-0118

U. S. Environmental Protection Agency

Office of Wastewater Management

State Revolving Fund Branch

1200 Pennsylvania Avenue (4204-M)

EPA East Building, 7th Floor

Washington, DC  20460

  SEQ CHAPTER \h \r 1     

	

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 Number 1391.08)

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, a report 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 the 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 the
Assistance is provided to Recipients for Other Purposes; and 

e. 	Monitoring Assistance Recipient Compliance with Program Requirements
and Other Federal Cross-cutting Authorities during the Period of the
Assistance Agreement.  

As a federal grant recipient, a state must also agree to follow
generally accepted accounting principles.  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                    
                                                                        
                

includes:

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 impact and benefits, 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

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
shall 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, environmental benefits, 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 an independent
financial audit of its SRF 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 or by the EPA
Office of Inspector General.

	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:

Project description;

Project cost estimate;

Estimated construction schedule;

Projected disbursement schedule;

Description of environmental impacts and benefits;

Estimation of cost impacts on users;

Identification of repayment source;

Description of community financial capability; and

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:

Capitalization Grant Agreement and Application/Intended Use Plan;

Annual Report;

State Annual Audit; and

Applications for SRF Financing Assistance. 

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 these uses
support the goals of the SRF.  The 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 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 non-point 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 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 cross-cutting
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) expects the State to independently
conduct or to have conducted a financial and compliance audit of its SRF
and operations.  The State may designate an independent auditor 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.

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 organizations requiring assistance (non-point source projects),
they will also prepare loan applications similar to 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 for use in 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.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION   	CRITERIA

5(a)	NON-DUPLICATION

          

	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 expected.  The information collection
activities herein are based upon program specific State sources which
are not duplicated anywhere else.

5(b)	CONSULTATIONS

	The information collection requirements are subjected to the same
review as the other requirements and procedures contained in the Initial
Guidance.  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.

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.  A copy of the Notice is
attached to the supporting statement.	 

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	ESTIMATING RESPONDENT BURDEN HOURS

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 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.

FY 2008: 51 States X 400 hrs = 20,400 burden hours

FY 2009: 51 States X 400 hrs = 20,400 burden hours

FY 2010: 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.  

FY 2008: 51 States X 275 hrs = 14,025 burden hours

FY 2009: 51 States X 275 hrs = 14,025 burden hours

FY 2010: 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.

FY 2008: 51 States X 80 hrs = 4,080 burden hours	

FY 2009: 51 States X 80 hrs = 4,080 burden hours

FY 2010: 51 States X 80 hrs = 4,080 burden hours

It is important to note that respondents may use SRF 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.

FY 2008: 51 States X 69 appl. X 40 hrs = 140,760 hours

FY 2009: 51 States X 74 appl. X 40 hrs = 150,960 hours

FY 2010: 51 States X 79 appl. X 40 hrs = 161,160 hours

		

		Total 		  177 appl.		   452,880 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.

FY 2008:   3,519 Comm. X 60 hrs = 211,140 burden hours

FY 2009:   3,774 Comm. X 60 hrs = 226,440 burden hours

FY 2010:   4,029 Comm. X 60 hrs = 241,740 burden hours

     	

	Total  11,322 Comm.            679,320 burden hours

	

Average Annual State Burden Hours (FY 2008-2010):

						    		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			  	 8,880	 	452,880

						  ___________________      	

	Total State Burden Hrs.                                                
                                                                        
                                                  	(FY 2008-2010)       
           			11,145	   	568,395

		Average Annual State Burden 

	Hours (FY 2008-2010)		   	 3,715     	189,465			   

                                            

	Total Local Community Burden Hours (FY 2008-2010):

								Hours		Hours

		ICR						per Comm.  all Comm.

		Application Preparation			 180	     	679,320

	

Average Annual Local Community Burden Hours (FY 2008-2010):

							Hours		Hours

		ICR			      	    	per Comm  all Comm.	 	

	

		Application Preparation		 60		 226,440

           

		Total Local Community Respondents

		(FY 2008 – 2010)					11,322

		Average Local Community Respondents

		(FY 2008 – 2010)					 3,774	 

	

6(b)	ESTIMATING RESPONDENT COSTS

	

a. Costs To State Respondents

The average annual State Costs for the three-year period is estimated to
be $5,457,000.

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 to reflect participation by all States in the SRF
program and by the States' reported FTE (full-time employee) direct
labor costs.

                                                                     FY
2008

  		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		3,519	   	   40	 	30.00**	  4,222,280 

Total FY 2008 State Cost	  			                        $5,163,230

                                                                   	

** 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 2009

  		ICR		# States	  Hours	  $/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		3,774 	   	   40		30.00**       4,528,800

Total FY 2009 State Cost	 			                  $5,416,200

					

				FY 2010

  		ICR		# States	  Hours	  $/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		  250	 	30.00**   	382,500

State Audit	  	51		   75	 	30.00**	 114,750

Appl. Review		4,029	  	   40	 	30.00**         4,834,800 

Total FY 2010 State Cost	  	 		                    $5,791,050

                                                             

                                                             

Total State costs (FY 2008-2010)		   $16,370,480

Average annual State cost over                          $5,457,000

3-year period (rounded)                                         

   				                                                                 
                                   

	

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: 2008 - 69 per State; 2009 - 74
per State; 2010 - 79 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 2008

  	ICR	# Communities	  Hours	$/Hour	  $ Cost

Appl. Prep.	 3,519	              60	 	25.00       $5,278,500 	          
                                                        					

				FY 2009

  	ICR	# Communities	  Hours	$/Hour	  $ Cost

Appl. Prep.	3,774	   	   60 		25.00      $5,661,000 

                                                  

			                   FY 2010

  			ICR	# Communities	  Hours	$/Hour	  $ Cost

Appl. Prep.	4,029	   	    60 		25.00    	$6,043,500	 

                                                                   

Total Local costs (FY 2008-2010)		    $16,983,000

Average annual local cost over 3-year 

period		  					            $5,661,000

                                                                   

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
procedures, and alternative methods to assure compliance.	

	The average annual Federal cost of $1,571,140 over the three-year
period was estimated as follows:                         

					        FY 2008

	   	ICR		  		Hours	  	$/Hour	   $ Cost

EPA HQ Review of IUP	   	1,020	  	43.00*	   	   43,860

and Agreement Materials

(20 hrs per State 

submission)

EPA Regions' Review of IUP   	17,850	  	36.00**	  642,600

and Agreement Materials

(350 hrs per State 

submission)

EPA HQ Oversight Review		1,020	 	 43.00*	   43,860

of Annual Report/Audit

(20 hours per State 

submission)

EPA Regions' Oversight 		20,400	  	36.00**	  734,400

Review of Annual 

Report/Audit (400 hours 

per State submission)						  

                                                                

Total FY 2008 Federal 	 	40,290		    $1,464,720

* GS 13/5, including PC&B (personnel compensation and benefits).	  

** GS 12/5, including PC&B.

                                                                        
 FY 2009

	   	ICR				  Hours	  $/Hour     $ Cost

EPA HQ Review of IUP 	   	 765	  	 43.00*        32,895

and Agreement Materials

(15 hours per State 

submission)

EPA Regions' Review of   		 17,850	 36.00**    642,600

IUP and Agreement 

Materials (350 hours 

per State submission)

EPA HQ Oversight Review	  	1,530	  	43.00*	         65,790

of Annual Report/Audit

(30 hours per State 

submission)

EPA Regions' Oversight   		 22,950	 36.00**      826,200

Review of Annual 

Report/Audit (450 hours 

per State submission)					  

                                     

Total FY 2009 Federal 		43,095		    $1,567,485

                                                                  

FY 2010

ICR			  Hours	  S/Hour	   $ Cost

EPA HQ Review of IUP         	    765	 	43.00*	   	  32,895

and Agreement Materials

(15 hours per State 

submission)

EPA Regions' Review of  		  17,850	  36.00**  	 642,600

IUP and Agreement 

Materials (350 hours 

per State submission)

EPA HQ Oversight Review	  	2,040	  	 43.00*	   87,720

of Annual Report/Audit

(40 hours per State 

submission)

EPA Regions' Oversight 	 	25,500	  	36.00**	  918,000

Review of Annual 

Report/Audit (500 hours 

per State submission)					  

                                                           

Total FY 2010 Federal 		46,155		    $1,681,215

	

	Total Federal costs (FY 2008-2010)		    $4,713,420

   	Average annual cost over 3-year period	    $1,571,140	

    

	Total Federal Burden Hours (FY 2008-2010)	129,540

	Average Annual Federal Burden Hours		  43,180

	Hourly Federal Cost					  $36.38

     

6(d) BOTTOM LINE BURDEN HOURS AND COSTS / BURDEN 				     TABLES

		

	(i)	Respondent Burden (FY 2008-2010)

Total State Burden Hours		    568,395

		Average Annual State 

		Burden Hours	 		  	     189,465

		Total State Costs		           $16,371,000

		Average Annual State Costs		 $5,457,000

			

		Hourly State Cost  			        $28.80

		Total Local Burden Hours		      679,320

		Average Annual Local

		Burden Hours			                  226,440

Total Local Costs		           $16,983,000

		Average Annual Local Costs	 $5,661,000

			

		Hourly Local Cost				$25.00

		Total Average Annual

		Respondents (State and Local)		 3,825

		Total Average Annual 

		Respondent (State and local)

		Burden Hours	                   			415,905

			

              

	

Total Average Annual Respondent 

                    (State and Local)Cost 				 $11,118,000

	

		Total Number of Annual 

		Burden Hours / per respondent	            108.7333

	    	

	(ii)	The Agency Tally (FY 2008-2010)

Total Federal Costs				 $4,713,420

		Average Annual Federal Costs		 $1,571,140 

	

		Total Federal Burden Hours	   		 129,540

		Average Annual Federal

		Burden Hours				    	   43,180

		Federal Cost per hour				   $36.38

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 3,009, while this ICR
estimates the number of respondents to be 3,825.  More entities will be
applying for SRF loans than in previous years.

6(f)	BURDEN STATEMENT

Burden Statement:  The annual public reporting and recordkeeping burden
for this collection of information is estimated to average 108.7333
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-2004-0015, 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-2004-0015 and OMB Control Number
2040-0118 in any correspondence. 

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