                           Information Collection Request for the 

                     Clean Water Act State Revolving Fund Program

                            Section 606 of the Clean Water Act

                                  EPA ICR Number 1391.10

                           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

    	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 (Renewal)"

	(OMB Control Number 2040-0118, EPA ICR Number 1391.10)

1(b) SHORT CHARACTERIZATION (ABSTRACT)

The information collection activities will occur primarily at the
program level, Clean Water State Revolving Fund (CWSRF) Base Program and
the CWSRF American Recovery and Reinvestment Act (ARRA) Program, 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 Intended Use Plan
(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 the
Environmental Protection Agency (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 Clean Water State Revolving
Fund (CWSRF) National Information Management System.  The Report also
describes the extent to which the existing CWSRF financial operating
policies, alone or in combination with other State financial assistance
programs, will provide for the long-term fiscal health of the Fund.

c. State Annual Audit

The State annual audit report will contain opinions on the financial
statements of the CWSRF, a report on the internal controls, and whether
the CWSRF 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 CWSRF Financing Assistance

Local communities have the responsibility for preparing and submitting
applications for CWSRF assistance to their respective State Agency which
manages the CWSRF 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
CWSRF.



1(c)	Terms of Clearance

For the prior ICR 1391.09, OMB provided the following Terms of Clearance
(TOC):

“This change to the Clean Water State Revolving Fund (CWSRF) Program
ICR, to implement provisions of the American Recovery and Reinvestment
Act of 2009 (ARRA), is approved. This change transfers 455,318 hours of
burden from Emergency ICR 2030-0046, which expires on Sept 30, 2009, to
this ICR, and approves EPA’s collection of 6 additional data items
required by EPA to meet the requirements of ARRA that were not
previously approved under this ICR. These are: Principal
Forgiven/Negative Interest/Grant Amount (subsidy); Last Construction
Contract Executed (Date); Construction Start Date; Construction
Completed Date; Is Project Green Infrastructure; and Green
Infrastructure Amount. The additional burden primarily reflects the
increase in grant applicants and awards expected as a result of ARRA, as
well as accounting for the new reporting requirements. Additionally, OMB
notes that EPA is providing States with the options of entering
information required under ARRA Section 1512 into the CWSRF Benefits
Reporting System (CBRS). This option provides states with an ARRA data
entry mechanism to improve data quality and consistency of reported
information. Once the information is entered in CBRS, States can
download a spreadsheet formatted for direct upload into
FederalReporting.gov. However, since recipients are required to submit
the Section 1512 data directly to FederalReporting.gov, States will need
to submit those data on their own accord on a quarterly basis beginning
in October 2009 as stipulated in the final OMB reporting guidance. The
collection of Section 1512 data in FederalReporting.gov is separately
authorized by OMB control number 0430-0004. This option (to report 1512
data to CBRS and download a spreadsheet formatted for
FederalReporting.gov) is purely voluntary; States wishing to use some
other method of reporting to FederalReporting.gov are free to do so. It
is intended merely to assist States in their 1512 reporting. OMB
understands that when EPA renews this collection (which expires on
12/31/2010), the above listed items will be incorporated into the
supporting statement for the ICR. Additionally, EPA will include these
specific items in the two requests for public comment that precede the
submission of the ICR to OMB.”

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.  The information activities are pursuant to Section 606
of the Act, EPA Initial Guidance for State Revolving Funds (January
1988), and CWSRF 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.

	EPA and the public, needs the information collected on the ARRA Program
to access whether funds under the Act were used for authorized purposes,
to evaluate whether program goals were achieved, and to ensure that
instances of fraud, waste, error, and abuse are mitigated.  EPA will
report information in recipient’s quarterly reports at a web site so
that recipients and uses of all funds are transparent to the public. 
EPA will report the public benefit of the funds in a clear, accurate,
and timely manner.   

	

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 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.  

A State, as a federal grant recipient, 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 CWSRF program.  Once the CWSRF is
operational, the State will receive and review applications for CWSRF
financing assistance submitted by local communities.  The State will
review the applications for conformance with the CWSRF 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 CWSRF Initial Guidance and other CWSRF 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 CWSRF programs as
part of its Annual Review process, the Agency does not have any
responsibility for reviewing or approving individual applications for
CWSRF financial assistance.

EPA and the public will use the ARRA Program information to oversee the
recipient’s programmatic and financial performance under the Act.  For
example, the information in a recipient’s quarterly report will enable
EPA and the public to assess whether program goals were achieved,
including specific program outcomes and improved results on broader
economic indicators.

3.  NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION   	     

CRITERIA

3(a)	NONDUPLICATION

          

	The information collection elements are specific to Title  VI,
established under the amendments to the CWA.  The information in the
Intended Use Plan, Annual Report, and State Audit is unique to each
State participating in the CWSRF 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.

3(b)  PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

          	The first Federal Register Notice soliciting public comment
on this ICR was published July 11, 2011 (76 FR 40723) under Document ID:
EPA-HQ-OW-2004-0015.

3(c)	CONSULTATIONS

The information collection requirements were developed during the
initial stages of the program, and were reviewed and commented on by the
groups that would be impacted; such as State officials, representatives
of local government, private concerns involved with municipal finance,
EPA regional and Headquarters’ offices, and the Office of Management
and Budget.  The Association of State and Interstate Water Pollution
Control Administrators (ASIWPCA) also reviewed and commented on the
requirements.  As the program progressed through the years, there were
minor changes made to the requirements, mostly due to reporting burden
increases resulting from an increase in the number of loan applicants. 
These changes were reviewed and commented on by the impacted
organizations as a result of the Federal Register postings every 3 years
during the renewal process.  

The burden hours did double for one year in 2009, due to the infusion of
$4 billion dollars into the SRF program from the American Recovery and
Reinvestment Act of 2009.  However, these burden hours were approved by
OMB on a separate ICR developed by the EPA Grants Administration
Division; and these hours allowed have since been dropped from the
Agency’s data collection budget for the SRF program.   

3(d)	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 CWSRF assistance. 
Preparation of an application is only necessary if the community wishes
to receive financial assistance.  In view of the limitation of funds
available from the CWSRF and the option of other sources, a limited
number of communities will likely receive assistance in a particular
year.  The impact on communities generally is quite limited.

3(e)	GENERAL GUIDELINES

The data collections covered by this ICR are in compliance with the OMB
General Guidelines for information collections.

 

3(f)	CONFIDENTIALITY 

No confidential data is collected. 

3(g) 	SENSITIVE QUESTIONS

No such information is required.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	RESPONDENTS/SIC CODES

State and local governments; local communities and tribes (SIC Code #99)

4(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 CWSRF 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 CWSRF 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 CWSRF 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 CWSRF Management Manual.

	c.	State Annual Audit

Most States have agreed to conduct or to have conducted an independent
financial audit of its CWSRF 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 CWSRF Financing Assistance 

Local communities and other eligible entities have to prepare and submit
applications for CWSRF assistance to their respective State Agency which
manages the CWSRF program.  Title VI outlines eligibilities under the
CWSRF program in terms of potential recipients, types of projects and
activities which may receive CWSRF assistance, and the types of
financial assistance which an CWSRF may provide.  The Clean Water Act
provides significant flexibility to the States regarding the development
of specific procedures for reviewing and approving applications for
CWSRF assistance and for managing the CWSRF program.

e.	National Program Evaluation

EPA has the responsibility of evaluating the overall effectiveness of
the CWSRF program.  Studies will be conducted annually on program
progress and environmental outcomes.  Much of the data to support such
studies is available in capitalization grant applications, annual
reports and audits.  However, in limited circumstances, it is necessary
to get information directly from communities that have received
assistance.  For instance, data on the application experience, data on
post construction project performance, etc.  These studies will complete
the public program development, implementation, and evaluation.  The
evaluation serves as a feedback loop so that the program efficiency and
effectiveness can be improved.  

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 CWSRF
Initial Guidance, the Interim Final Rule, CWSRF Management Manual, and
other CWSRF 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 CWSRF assistance.

Generally, the applications for CWSRF 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 impacts and 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
Capitalization Grant Agreement and Application / Intended Use Plan when
applying for Federal financial assistance.

For the Clean Water State Revolving Fund ARRA Program, EPA estimates
that 51 recipients will prepare / submit reports to EPA, prepare work
plans and annual reports, and participate in audit activities.  EPA
estimates that 3,060 organizations will submit applications for funding
and 1,400 sub-recipients will prepare / submit reports to the prime
recipient.  In addition, EPA estimates that 56 recipients will submit
reports under 604(b) of the Clean Water Act. 

	

5.	THE INFORMATION COLLECTED--AGENCY ACTIVITIES, 	COLLECTION
METHODOLOGY, AND INFORMATION 	MANAGEMENT

5(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.

5(b)	COLLECTION METHODOLOGY AND MANAGEMENT

The CWSRF 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 CWSRF and describing how these uses
support the goals of the CWSRF.  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 CWSRF.  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 CWSRF 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 CWSRF.  

	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 CWSRF
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 606(c)(5) requires that the IUP describe the criteria and
methods established for the distribution of the CWSRF 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 CWSRF 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 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));
crosscutters still apply

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
CWSRF 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 CWSRFs, 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 CWSRF program in terms of
potential recipients, types of projects and activities which may receive
CWSRF assistance, and the types of financial assistance which an CWSRF
may provide.  The CWA provides significant flexibility to the States
regarding the development of specific procedures for reviewing and
approving applications for CWSRF assistance and for managing the CWSRF
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 CWSRF
Initial Guidance, 

Interim Final Rule, CWSRF Management Manual, and other CWSRF 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 CWSRF 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 CWA itself.  The guidance and rule were designed to promote
flexibility for States in establishing and operating their CWSRF
programs, within the bounds of the Act.

Because the CWSRF 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 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(c)	SMALL ENTITY FLEXIBILITY

A majority of the reporting burden (IUP, annual report, annual audit,
falls on the States.  For those communities / municipalities desiring
financial assistance from the CWSRF, 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.

5(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 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.	

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 CWSRF assistance will likely
increase.

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

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 2012: 51 States X 400 hrs = 20,400 burden hours

FY 2013: 51 States X 400 hrs = 20,400 burden hours

FY 2014: 51 States X 400 hrs = 20,400 burden hours

			Total		1,200 hrs		61,200 hrs

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 CWSRF program.  The annual report will include information
on hardship grants, DBE, environmental benefits, core measurements,
funding framework, and input for the CWSRF National Information
Management System.  

FY 2012: 51 States X 275 hrs = 14,025 burden hours

FY 2013: 51 States X 275 hrs = 14,025 burden hours

FY 2014: 51 States X 275 hrs = 14,025 burden hours

	Total		825 hrs		42,075 hrs

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 2012: 51 States X 80 hrs = 4,080 burden hours	

FY 2013: 51 States X 80 hrs = 4,080 burden hours

FY 2014: 51 States X 80 hrs = 4,080 burden hours

			Total		240 hrs		12,240 hrs	

It is important to note that respondents may use CWSRF administrative
monies to pay for costs resulting from the State Annual Audit.  Section
603(d)(7) of the Act allows money in the CWSRF 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 CWSRF.  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. 	CWSRF Assistance Application Preparation and Review

States have total responsibility for reviewing and approving local
applications for assistance from the CWSRF 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 CWSRF assistance applications.

FY 2012: 51 States X 74 Comm. appl. X 40 hrs = 150,960 hours

FY 2013: 51 States X 79 Comm. appl. X 40 hrs =  161,160 hours

FY 2014: 51 States X 84 Comm. appl. X 40 hrs = 171,360 hours

			Total 	      237 Comm. appl.	               483,480 hours	

States develop specific procedures and reporting and application
materials for CWSRF assistance applicants.  We estimate that local
communities and tribes will spend an average of 60 hours in collecting
information and preparing their CWSRF assistance applications.  The
following chart represents the total national local community burden in
preparing CWSRF assistance applications.

FY 2012:   3,774 Comm. X 60 hrs = 226,440 burden hours

FY 2013:   4,029 Comm. X 60 hrs = 241,740 burden hours

FY 2014:   4,284 Comm. X 60 hrs = 257,040  burden hours

     	Total        12,087 Comm.	                725,220 hrs

Average Annual State Burden Hours (FY 2012-2014):

						    		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			  	9,480 	 	483,480

						  ___________________      	

	Total State Burden Hrs.                                                
                                                                        
                                                  	(FY 2012-2014)       
           		11,745	   	598,995

		Average Annual State Burden 

	Hours (FY 2012-2014)		   	 3,915     	         199,665			   

                                            

Total Local Community Burden Hours (FY 2012-2014):

								Hours		Hours

		ICR						per Comm.  all Comm.

		Application Preparation			 60	     	725,220

	Average Annual Local Community Burden Hours (FY 2012-2014):

							Hours		Hours

		ICR			      	    	per Comm.  all Comm.	 	

	

		Application Preparation		 60		 241,740

           

		

Total Local Community Respondents

		(FY 2012 – 2014)					12,087

		Average Local Community Respondents

		(FY 2012 – 2014)					 4,029	 

	

6(b)	ESTIMATING RESPONDENT COSTS

	

a. Costs To State Respondents

The average annual State Costs for the three-year period is estimated to
be $6,389,280

It is important to note that costs to the States are CWSRF grant
eligible, and therefore, are indirect Federal costs paid out of the
CWSRF.  Under section 603(d)(7), money in the CWSRF 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 CWSRF. 
CWSRF 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 CWSRF and for projects receiving financial assistance
from the .  (If actual State expenditures for administrative costs of
managing the CWSRF exceed the four percent limit, the excess costs must
be paid from other State monies.)

A small sample of State respondents were initially selected during
program implementation 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 CWSRF program and by the
States' reported FTE (full-time employee) direct labor costs.

                                                                 

FY 2012

  	ICR		# States	  Hours	  $/Hour	  $ Cost

Capitalization Grant Agreement and Application/Intended Use Plan

  	

- Initial Plan	  	  51		  300		32.00**	    489,600

  	- Revised Plan	  51		  100 	 	32.00**	    163,200 

Annual Report	  51		  275	 	32.00**	    448,800

State Audit	 	 51		   80	 	32.00**	    130,560

Appl. Review		51   	  74* 	   40	 	32.00**	  4,830,720

Total FY 2012 State Cost	  			                   $6,062,880

         

* communities                                                          	

** State salary cost is figured at $27.00 per hour to cover technically
trained personnel plus an additional ADP cost of $5.00 per hour = $32.00
total per hour.

                                       FY 2013

  	ICR		# States	  Hours	  $/Hour     $ Cost

Capitalization Grant Agreement and Application/Intended Use Plan

  	

- Initial Plan	  	   51		  300		 32.00**      489,600

  	- Revised Plan	   51		  100 	 	 32.00**	163,200

Annual Report	  51		  275	   	32.00**       448,800

State Audit	 	 51		   80		32.00**      130,560

Appl. Review		51	79*	   40		32.00**   5,157,120

  

Total FY 2013 State Cost	 			            $6,389,280

	

*communities

				

				FY 2014

  	ICR		# States	  Hours	  $/Hour	 $ Cost

Capitalization Grant Agreement and Application/Intended Use Plan

  	

- Initial Plan	  	51		  300	 	32.00**   	489,600

  	- Revised Plan	51		  100		 32.00**	 163,200 

Annual Report	51		  275	 	32.00**   	448,800

State Audit	  	51		   80	 	32.00**	 130,560

Appl. Review	     	51	84*	   40	 	32.00**       5,483,520

Total FY 2014 State Cost	  	 	  $6,715,680

                                                                        
                                      

Total State costs (FY 2012-2014)		            $19,167,840

Average annual State cost over 

3-year period	   				    	  $6,389,280

                 

* communities     

                                       

	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 CWSRF assistance at a
State's option.  For the purpose of this information collection, only
the direct costs associated with preparation of the application for
CWSRF financial assistance are reported.

During the period of this information collection activity, the CWSRF
program will experience growth in the number of communities which
receive CWSRF 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 CWSRF assistance during the period of this
information collection to be as follows: 2012 - 74 per State; 2013 - 79
per State; 2014 - 84 per State.

Only communities which desire financial assistance from the CWSRF 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 CWSRF program implementation and
management.  The Agency estimates that on average, communities will
spend approximately 60 hours in completing their CWSRF assistance
applications.

                                                  

					 FY 2012

  	ICR	# Communities	  Hours	$/Hour	  $ Cost

Appl. Prep.	 	3,774              60	 	27.00       $6,113,880 	          
                                                        					

				FY 2013

  	ICR	# Communities	  Hours	$/Hour	  $ Cost

Appl. Prep.		4,029	   	   60 		27.00      $6,526,980 

                                                  

 FY 2014

  			ICR	# Communities	  Hours	$/Hour	  $ Cost

Appl. Prep.		4,284	   	    60 		27.00       	$6,940,080	 

                                                                   

Total Local costs (FY 2012-2014)		 	$19,580,940

Average annual local cost over 3-year period	     	$6,526,980

                                                                   

6(c)	ESTIMATING AGENCY BURDEN AND COST

Estimation of the direct costs to EPA to implement the CWSRF 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 CWSRF 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 $1,766,640 over the three-year
period was estimated as follows:



FY 2012

						ICR 	Hours		$/Hour	   $ Cost

EPA HQ Review of IUP	  765	  	48.00*	   36,720

and Agreement Materials

(15 hrs per State 

submission)

EPA Regions' Review of IUP 		17,850 	40.00**	  714,000

and Agreement Materials

(350 hrs per State 

submission)

EPA HQ Oversight Review	2,040	 	 48.00*	   97,920

of Annual Report/Audit

(40 hours per State 

submission)

EPA Regions' Oversight 	20,400	  40.00**	  816,000

Review of Annual 

Report/Audit (400 hours 

per State submission)						  

                                                                

Total FY 2012 Federal 	 		41,055		    $1,664,640

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

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

                                                              

	   

	

					   

FY 2013

	   	ICR			 Hours	$/Hour     $ Cost

EPA HQ Review of IUP 	   	 765	  	48.00*	36,720

and Agreement Materials

(15 hours per State 

submission)

EPA Regions' Review of   			 17,850	 40.00**     714,000

IUP and Agreement 

Materials (350 hours 

per State submission)

EPA HQ Oversight Review	  	2,040	  	48.00*	97,920

of Annual Report/Audit

(40 hours per State 

submission)

EPA Regions' Oversight   			 22,950	 40.00**	918,000

Review of Annual 

Report/Audit (450 hours 

per State submission)					  

                                                           

Total FY 2013 Federal 			43,605		    $1,766,640

                                                                  



FY 2014

ICR			  Hours	  S/Hour	   $ Cost

EPA HQ Review of IUP         	    765	 48.00*	   36,720

and Agreement Materials

(15 hours per State 

submission)

EPA Regions' Review of  		  17,850	  40.00**  	 714,000

IUP and Agreement 

Materials (350 hours 

per State submission)

EPA HQ Oversight Review	  2,040	  48.00*	 97,920

of Annual Report/Audit

(40 hours per State 

submission)

EPA Regions' Oversight 	 25,500	  40.00**	1,020,000  

Review of Annual 

Report/Audit (500 hours 

per State submission)					  

                                                           

Total FY 2014 Federal 	        	46,155		          $1,868,640

	

	

Total Federal costs (FY 2012-2014)		    

Base Program  				$5,299,920

ARRA Program		  		$3,230,948

Average annual cost over 3-year period	    

Base Program  	$1,766,640

ARRA Program	$1,076,982	

    

	Total Federal Burden Hours (FY 2012-2014)	         

Base Program 				130,815

ARRA Program				 80,804

	Average Annual Federal Burden Hours		           

Base Program				43,605

ARRA Program				26,934

Hourly Federal Cost				         

Base Program				$44.00

ARRA Program			  	$39.99

     

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

		

	(i)	Respondent Burden (FY 2012-2014)

Total State Burden Hours		       

Base Program			598,995

				ARRA program			638,010

		

Average Annual State Burden Hours	 		  	      

Base Program			199,665

ARRA Program			212,670

		Total State Costs				

Base Program		$19,167,840

ARRA Program		  20,416,320

		Average Annual State Costs		 

Base Program		$6,389,280

ARRA Program		  6,805,440

			

		Hourly State Cost  			       

Base Program			$32.00

ARRA Program		  	  32.00	

		Total Local Burden Hours			    

Base Program		     725,220

ARRA Program		     455,316

		

Average Annual Local Burden Hours			             

Base Program			241,740

ARRA Program			151,772

Total Local Costs		                  

Base Program	          $19,580,940

ARRA Program		   12,291,142

		Average Annual Local Costs	         

Base Program		$6,526,980

ARRA Program		  4,097,047

					

Hourly Local Cost				

Base program			$27.00

ARRA Program		  	  27.00

		Total Average Annual Respondents (State and Local)	            

Base Program			8,262

ARRA Program			4,669

		Total Average Annual Respondent (State and local) Burden Hours	       
           

Base Program			441,405

ARRA Program			364,442

			

                  	Total Average Annual Respondent (State and Local)
Cost 	                  

		Base Program		$12,916,260

		ARRA Program		  10,902,487

	

Total Number of Annual Burden Hours / per respondent		    

Base Program			53.43

ARRA Program		 	78.06

	    	

	(ii)	The Agency Tally (FY 2012-2014)

Total Federal Costs			 

Base Program		$5,299,920

ARRA Program		  3,230,948

		Average Annual Federal Costs		 

Base Program		$1,766,640

ARRA Program		  1,076,982 

	

		Total Federal Burden Hours	   	  

Base Program		130,815

ARRA Program		 80,804

		Average Annual Federal

		Burden Hours				 

Base program		43,605

ARRA Program		26,934

		Federal Cost per hour			

Base Program		$44.00

ARRA Program		  39.99

6(e)	REASONS FOR CHANGE IN BURDEN

In the previous ICR 1391.09, the change in the State and local
respondent burden of 455,318 hours was attributed to an increased
estimate on the number of respondents receiving CWSRF loans under the
ARRA Program (adjustment). The previous ICR estimated the number of
respondents in the base program to be 3,825, while this ICR estimates
the number of respondents in the base program to be 8,262, plus an
additional 4,669 ARRA respondents.  More entities will be applying for
CWSRF loans in the base program than in previous years.

6(f)	BURDEN STATEMENT

Average annual State and local burden for this ICR is estimated to be
441,405 hours for the base program, and an additional 364,442 hours for
the ARRA Program.  The average annual Federal burden for the base
program is estimated to be 43,605 hours, with an additional 26,934 hours
for the ARRA program.  This includes the time for reviewing
instructions, searching existing data sources, gathering and maintaining
the data needed, and completing and reviewing the collection of
information.  

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 53.43 hours per response for the
base program and 78.06 hours per response for the ARRA program.  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
www.regulations.gov, or in person viewing at the Office of 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 Office of 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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