SUPPORTING STATEMENT FOR THE NATIONAL ESTUARY PROGRAM

A. JUSTIFICATION

1.  Identification of the Information Collection

1(a)  Title - National Estuary Program

1(b) Characterization/Abstract

            Section 320 of the Clean Water Act (CWA) amendments of 1987
established the National Estuary Program (NEP) to promote long-term
planning and management in nationally significant estuaries threatened
by pollution, development, or overuse.  The NEP(s objectives are to
protect, preserve, and restore estuaries.  The strategy of the program
is to focus on estuaries that are nationally significant in recreational
and commercial value, and of great importance for fish and wildlife
resources.  Another facet of national significance is whether lessons
learned in working with the estuary can be applied to other coastal
areas.  The NEP strategy emphasizes estuaries with problems which
detract from the estuary(s value and where there is a greater likelihood
that NEP efforts will result in improvements in water and sediment
quality, as well as in the abundance and variety of living resources.

Nationally significant estuaries are identified in one of two ways: 1)
the estuary is nominated by the State in which it lies; or 2) the
Administrator identifies an estuary and decides to convene a Management
Conference (the local managing entity of an NEP).  When the Governor of
the State in which the estuary is located nominates the estuary for
acceptance into the NEP, the EPA then evaluates the Governor(s
nomination.  If the EPA approves the addition of an estuary to the NEP,
a Management Conference is convened which involves community
stakeholders including Federal, State, local, and interstate agencies
with jurisdiction over the estuary, and other interested groups.

The addition of estuaries into the NEP has been conducted in five groups
or (tiers.(  The first two tiers included twelve estuaries which the
Congress recommended for priority consideration: in 1987,
Albemarle-Pamlico Sounds in North Carolina, Buzzards Bay in
Massachusetts, Long Island Sound in New York and Connecticut,
Narragansett Bay in Rhode Island, Puget Sound in Washington, and San
Francisco Bay in California; and in 1989 Delaware Inland Bays in
Delaware, Delaware Bay in Delaware, New Jersey and Pennsylvania,
Galveston Bay in Texas, New York-New Jersey Harbor in New York and New
Jersey, Santa Monica Bay in California and Sarasota Bay in Florida.  The
nominations were evaluated using EPA guidance on the content of
Governor(s nominations.  In 1991, a third tier of estuaries was
designated based on Governor(s nominations: Indian River Lagoon in
Florida, Tampa Bay in Florida, Barataria-Terrebonne Estuarine Complex in
Louisiana, Casco Bay in Maine, and Massachusetts Bays.  

The first 17 estuaries were established on the basis of completing a
Comprehensive Conservation and Management Plan (CCMP) in five years.  In
an effort to maximize successes of these, the Administrator opened a
fourth tier of nominations in 1991 which called for the completion of
the planning process in four years.  In 1992, four estuaries were
designated under this streamlined approach:  Peconic Bay in New York,
San Juan Harbor in Puerto Rico, Corpus Christi Bays in Texas and
Tillamook Bay in Oregon.  Continuing the theme of streamlining, the
Administrator designated seven new estuaries in 1995 which were to
complete their CCMPs in three years: Great Bay in New Hampshire,
Barnegat Bay in New Jersey, Maryland Coastal Bays in Maryland, Charlotte
Harbor in Florida, Mobile Bay in Alabama, Morro Bay in California and
Lower Columbia River in Washington.

Once an estuary is designated by the Administrator, an agreement of
intent between the EPA and the State or States, called a Conference
Agreement, establishes the governing entity for the project which is
called a Management Conference.  The Management Conference performs an
objective, technical assessment of the condition of the estuary.  Based
on this assessment, the Conference summarizes the estuary(s problems and
indicates which problems will be addressed by the Conference.  After the
estuary(s programs are identified, the Management Conference establishes
goals and objectives for the estuary.  Goals may range from improving
the current status of the estuary to maintaining pristine quality. 
Specific actions and commitments to protect and restore the estuary are
developed and the costs and benefits of options are evaluated.  This
information is used by the Management Conference to develop a CCMP for
the estuary.  Once the CCMP is approved by the Administrator, the NEP is
responsible for oversight, coordination, and facilitation of CCMP
implementation activities.

To obtain funding to administer Management Conferences, to characterize
and define problems of the estuary, and to develop the CCMP, States and
other eligible applicants may apply for federal funds using a standard
General Federal Assistance application.  To ensure efficient use of
allotted resources, an annual work plan for each estuary program must be
developed by the Management Conference before individual awards can be
approved.  The approved work plan then becomes a part of the grant
agreement between EPA and the recipient.

In addition, NEPs must also prepare an implementation review report
every three years.  The purpose of these implementation review reports
is to document progress made in implementing the CCMPs, to highlight
successes, strengths, and environmental results, as well as to identify
areas for improvement.  This information is used by EPA to make sound
decisions regarding continued funding to NEPs implementing their
management plans, to transfer lessons learned in the NEPs to other
coastal watersheds and EPA programs, and to provide guidance and
programmatic support to NEPs based on needs identified in the report.

           Individual NEPs must also develop Government Performance
Results Act (GPRA) reports that provide information about environmental
results and progress implementing their CCMPs.  These are submitted
annually with the information being presented to the Office of
Management and Budget (OMB) with other EPA GPRA measures.



2. Need for and use of the Collection

2(a) Need/Authority for the Collection

            Statutory authority for the NEP is provided by (320 of the
Clean Water Act, as amended.  The terms and conditions of grants under
the NEP are provided in 40 CFR (35.9040 and (35.9045, including the
requirement for the 50 percent matching funds from non-Federal sources
and applications that are consistent with the annual work plan prepared
by each Management Conference.

For each NEP, other than standard application data, EPA needs: 1) the
Governor(s voluntary nomination to determine whether an estuary should
be included in the NEP; 2) the annual work plan to determine how the
Federal and non-Federal matching funds will be spent; 

3) an implementation review report documenting program implementation
progress to justify continued EPA funding under section 320; and 4)
annual GPRA reports to show environmental results being achieved.  

The State(s participation in the NEP is voluntary.  A Governor nominates
an estuary for the NEP on his or her own initiative using guidance which
EPA has established.  The information from the Governor presents already
available knowledge about the estuary and its importance.  The
nomination also contains the Governor(s views concerning the
significance of the estuary, the need for the designation, and the
State(s goals and objectives for the estuary and its strategy for
meeting them.  To select an estuary for designation, EPA uses
information in the nomination and other existing public information on
the national significance of the estuary, the importance of the estuary
on a regional scale, the environmental problems facing the estuary, and
the most likely causes of these problems.

To obtain funding under the NEP, the General Federal Assistance Grant
application must be filed and an annual work plan must be prepared.  The
burden of the actual grant application is covered under the ICR for
General Federal Assistance applications (ICR No. 0938.11; OMB No.
2030-0020).  The only burdens covered under this ICR are the burdens of
preparing the annual work plan, the implementation review, and GPRA
reports which are specific to the NEP.  General Federal Assistance Grant
application burdens are not unique to the NEP and are not covered by
this document.  

The annual work plan identifies and discusses the major goals and
milestones and projects to be pursued in the year to come.  The goals
are comprehensive and broad, based on the program goals established by
the Management Conference.  In addition, the work plan must document the
kinds, amounts, and sources of funds for the upcoming year(s activities,
including a demonstration of how the required matching funds will be
provided from non-Federal sources.

NEPs must report every three years to EPA on their progress in
implementing the CCMP and achieving environmental results.  

            

NEPs must also annually prepare a GPRA report estimating the number of
acres of habitat being restored within their study areas and also
indicate the number of CCMP priority actions being initiated.  

2(b)     Practical Utility/Users of the Data

The EPA Administrator uses the information collected under this
information collection request (ICR) to: 1) evaluate Governor(s
voluntary nominations of estuaries for the NEP; and 2) evaluate whether
grant applications under the NEP should be approved.  The following
paragraphs describe information required by the NEP:

$	Respondents

$	Processes and techniques used to obtain this information

$	How and by whom the information is used

$	Flow of information(where it is submitted, filed etc.

(A)  Governor(s Nomination

A Governor(s nomination is submitted on a one-time basis only by States
that wish to participate in the NEP, and nominations are accepted only
when the Administrator determines that additional programs are needed
and that sufficient resources are available to support them. At this
time, the EPA does not anticipate soliciting nominations in the
information collection period of 2006-2009.  A Governor(s nomination is
submitted by a State in which the target estuary lies.  If the estuary
is located in more than one State, a single nomination may be submitted
for the estuary which combines the information from all the
participating States.

EPA(s guidance concerning the contents of the Governor(s nomination (The
National Estuary Program Final Guidance on the Contents of the
Governor(s Nomination,( states that three general topics should be
addressed.

1. The national significance of the estuary

2. The need for a conference

3. The likelihood of success

Much of the information included in a Governor(s nomination is available
from work already accomplished by States, EPA Regions, and local
organizations.  Some information is also available in EPA(s 305(b)
reports, NOAA(s National Estuarine Inventory, NOAA(s Coastal Zone
Management, Estuarine Research and Marine Sanctuary Programs, and
university studies.  In the guidance, States are urged to use existing
and readily available information in the nominations.  New research and
studies are not required.  For example, data attained from the State
economic development agency or a community business group can be used to
evaluate recreational and/or commercial value of the estuary.  The uses
of the specific information recommended for inclusion in the nomination
by the program guidance are described below.

Describe estuary(s boundaries

-To determine if estuary meets CWA definition.

Describe estuary(s value

-To determine if estuary is nationally significant.

Demonstrate how problems will yield transferable results

-To determine how an estuary will enhance results that can be applied to
other estuarine or coastal watersheds.

Data on economic and living resources

-To determine if estuary has significant local or regional value.

Data on problems

-To determine if problems reduce value of estuarine resources.

Discussion of cause and effect

-To determine if the problem is sufficiently understood so as to be
addressed effectively.

Assess existing laws, regulations, control programs, enforcement and
coordination

-To determine if the proposed estuary program entails studies and
control efforts beyond these programs.

List overall goals for the estuary, and provide examples of specific
objectives and action plans

-To demonstrate whether State has an understanding of the work which
must be done to mitigate problems.

List structure and membership of proposed Management Conference

-To demonstrate broad stakeholder support for the program.

Document existence of and/or potential for generating public support

- To determine whether there is or will be sufficient public support for
successful implementation of the program.

Discuss interests and agencies already working in the estuary

-To determine these public entities( interest in and commitment to
protecting or restoring estuarine water quality.

Discuss ability to fund the management of the conference and action
plans

-To determine if the non-Federal cost share requirement of the statute
can be met and if sufficient funding exists to implement the program.

After an estuary is accepted into the program, the information in the
Governor(s nomination is then used to initiate consensus among
Management Conference members on priority problems to be addressed by
the program and to set goals and objectives.

(B)  Annual Work Plan

In order to receive funds, grantees must submit an annual work plan to
EPA.  The contents of annual work plans are specified in 40 CFR Section
35.9045.  Work plans should include a listing and discussion of
completed projects and projects planned for the upcoming year, as well
as describe the types of funding and amounts to be supplied by each
funding source. The work plan is reviewed by EPA and also serves as the
scope of work for the grant agreement. Annual work plans must be
approved by the EPA after they are approved by the Management Conference
so that assistance funding can be awarded.  EPA also uses these work
plans to track performance of each of the 28 estuary programs currently
in the NEP. 

Information presented in the work plan is based on the EPA/State
Conference Agreement developed for the Management Conference, but may
further define the goals and milestones in the overall plan and modify
them based on the success or failure of activities completed in the
previous years.  The information is available from the Management
Conferees and from the Conference Agreement.  EPA uses the work plan to
determine whether the monies requested in the grant application serve
the seven statutory purposes of the Management Conference, whether they
fund activities consistent with the individual program goals, and
whether their expenditure is an efficient use of resources.  The budget
information is also used to determine whether 50 percent of the funding
is provided by non-Federal sources as required by 40 CFR 35.9040.

(C)   Implementation Reviews

NEPs must submit a report documenting the implementation progress that
has been made by the program.  The purpose of these reviews is to
highlight progress, identify opportunities and issues, and determine
whether some level of continued base funding is warranted.  These
reviews must be conducted and a report on implementation progress
submitted every three years. 

Each NEP should provide written information on the following set of
topics:

$	Status of CCMP implementation (programmatic progress)

$	Environmental results and monitoring, including environmental
indicators

$	Technical assistance and public education

$	Resources

$	Institutional coordination and public involvement

$	Overall program strengths and limitations

$	Feedback on EPA(s involvement in CCMP implementation

While annual work plans are submitted as a component of the
implementation reviews, they cannot serve in place of the implementation
review because annual work plans are limited to the activities of the
grant recipient.  The implementation review encompasses the progress
made by the overall estuary program which is a collaboration of many
stakeholders each contributing to the implementation of the management
plan and the restoration and protection of the estuary.  Only the NEP
can collect this information from many stakeholders because, according
to purpose (6) of (320 of the CWA, the NEP is responsible for monitoring
the effectiveness of actions taken to implement the management plan.  In
addition, (320(h) of the CWA requires grant recipients to report on the
progress made under (320. The standard recordkeeping requirement for EPA
grants is 3 years after the date the recipient submits the final
Financial Status Report (FSR).

(D)  Government Performance Results Act (GPRA) Reporting

            The Government Performance and Results Act (GPRA) requires
that each agency report annually to Congress on the results of its
activities in each fiscal year. This Annual Performance Report forms the
bridge between the goals and objectives presented in the EPA Strategic
Plan and budgeted activities. The Annual Performance Report tracks the
progress made toward implementing goals and objectives in any single
fiscal year.  To assist in fulfilling this requirement, the NEPs are
asked to report on two items.  The first is determining the number of 

acres of habitat that have been restored within individual study areas;
information is provided on the type of restoration being performed and
type of habitat being restored.  The second item is how many priority
action items within the CCMP have been initiated.  This is a good
indicator of progress being made in implementing the CCMP.  NEP
reporting on these items helps to measure EPA(s overall goal of clean
and safe water.

Use of Improved Information Technology

States can access numerous computerized data bases to obtain information
necessary for the Governor(s nomination.  These data bases are
particularly useful in assessing water quality.  EPA data bases which
are available are the Surf Your Watershed, Index of Watershed Indicators
(IWI), Reach File, Water Quality File, Industrial Facilities Discharge
File, Permit Compliance System, BIOS, Complex Effluent Toxicity
Information System, Water Body File, Federal Reporting Data System,
Needs Survey File, and Grants Information Control System.  EPA
encourages the use of internet resources to the maximum extent in all
NEP transactions.  It is conceivable that nominations and work plans of
the near future could be transmitted to EPA electronically.

3.  Non Duplication, Consultations, and Other Collection Criteria

3(a) Non Duplication	

            The NEP is a program administered by the Office of Wetlands,
Oceans, and Watersheds (OWOW).  The Governor(s nomination, the annual
work plan, the implementation review, and GPRA reporting are unique
documents addressing particular requirements of the NEP.  No other
program or office at the EPA or any other Federal, State, or local
agency requests this same data organized in this particular manner.

Although there are no duplicative reporting requirements, some data
required for the Governor(s nomination may be available from other EPA
programs and from other Federal, State and local agencies.  However, no
one source contains all the data required for the Governor(s nomination.
 Therefore, the data must be compiled from other sources and organized
in a manner detailed in the NEP guidance and it must reflect the
Governor(s priorities and recommendations.  The nomination guidance also
affords the States considerable flexibility in style and interpretation.
 Some of the Federal agencies that compile information relevant to the
Governor(s nomination are the Department of Interior, National Oceanic
and Atmospheric Administration, and the Natural Resources Conservation
Service.  In addition, public interest groups, such as the Nature
Conservancy, may possess appropriate information.  For example, data on
declining fish catches to assess the estuary(s commercial and
recreational value can be obtained from the National Oceanic and
Atmospheric Administration sources.  Listings of participating sources
of data and information appear in the ICR for the National Estuary
Program, Appendix A, Nov. 22, 1989.  For annual work plans,
implementation reviews, and GPRA reporting, the NEP Management
Conferences are the only source of information.

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

            EPA Published a Federal Register notice on May 23, 2006 on
pages 29619 – 29621 to  announce the renewal of this ICR.  No comments
were received.

 

3(c) Consultations 

          EPA convenes two national conferences with the NEP each year. 
A main purpose is to meet with respondents and receive feedback on how
EPA can better provide service.  Discussions on how reporting can be
made less burdensome is also routine.  This offers an opportunity for
EPA to continually evaluate its policies and guidance to make them as
effective as possible. 

EPA also has regulations that address the grants portion of the NEP. 
These regulations require that a Management Conference be convened and
that certain program objectives are complete before funds are awarded to
program participants under section 320(g)(3) of the CWA.  In addition,
EPA has issued the guidance package entitled (The National Estuary
Program: Final Guidance on the Contents of a Governor(s Nomination.(  

3(d)  Effects of Less Frequent Collection              

A Governor(s nomination is submitted on a one-time basis only by States
that elect to participate in the NEP, and only when the Administrator
determines that there is a need for additional programs and that there
are sufficient resources to support these actions.  At this time, the
EPA does not anticipate soliciting nominations in the information
collection period of 2006-2009.  Therefore, frequency of collection is
not an issue for the reporting requirements contained in this ICR.  

Annual work plans are prepared every year and are submitted with the
grant application.  Priorities for Management Conferences can change
during a year, and numerous projects are tied to the results of projects
completed during the year.  Therefore, work plans must be developed
annually to plan and track the progress of this program.  			

Implementation reviews are now conducted every three years, which is
less frequent than in the past when they were required every two years. 
Three years is adequate time for significant progress to be made
implementing the CCMP.  Longer than three years poses the risk of not
identifying program issues which, left unaddressed, may result in
program failure before corrective action can be recommended.  This also
puts the Agency at risk of funding programs that are not using EPA funds
for appropriate purposes or achieving expected results.  Less than three
years would be a significant burden with nominal, if any, increases in
useful information.

           GPRA reporting is performed on an annual cycle, typically
around the beginning of the new fiscal year.  Therefore, the NEP GPRA
reports need to be provided annually to measure progress toward annual
targets.

3(e) General Guidelines

This information collection is consistent with OMB guidelines contained
in 5 CFR 1320.6 in that:

$	Information is not collected more often than quarterly.

$	Responses are not required in less than 30 days.

$	Respondents are not required to submit more than an original and two
copies of the document.

$	It does not provide for remuneration of respondents other than
contractors or grantees.

$	It does not require records to be kept for more than three years.

$	It is not in conjunction with a statistical survey.

$	Provisions for small businesses and other small entities are
appropriate.

$	Confidentiality is protected.

$	It does not require provision of information in a format other than
that which it is customarily maintained.

3(f)  Confidentiality

The Governor(s nomination is considered an application and is
confidential until a Management Conference is convened.  Similarly,
applications for 320(g)(3) grants are confidential until an offer or
award is accepted by the applicant.  After acceptance, all documents are
public.

3(g)  Sensitive Questions

No information of a sensitive nature is requested by this ICR.

4.  The Respondents and the Information Requested

4(a) Respondents/SIC Codes

            Respondents are mainly State and local government workers. 
The SIC code applicable to the State and local governments is 9511.

4(b) Information Requested 

(i) Data items:  Annual Work Plans, Implementation Review Report, GPRA
Reports.

 For annual workplans the standard recordkeeping requirement for EPA
grants is 3 years after the date the recipient submits the final
Financial Status Report (FSR).   

(ii) Respondent Activities: Compiling information on activities for each
NEP program  such as restoration projects, outreach material that has
been developed, and workshop proceedings.  This may include reviewing
and transmitting information or searching established databases.

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

5(a) Agency Activities

            For annual workplans, implementation review reports, and
GPRA reports, the Agency typically will answer respondent questions,
hold conference calls, review and analyze the submissions, record the
submissions, and store the information.

5(b) Collection Methodologies and Management

             Annual workplans serve as a scope of work for the grant
agreement and are submitted in hard copy form as part of the grant
application.  Implementation review reports are submitted partly in
paper because of examples of brochures, pictures, and other public
outreach tools that have been developed, and partly electronically. 
GPRA reports are mainly provided electronically in a standard Microsoft
Word table format.  Quality is checked by follow-up conversations with
the respondents.  For example, with the implementation review,
conference calls are set up to go over the specific submittals and
discuss overall progress being made implementing the CCMP.  This allows
for detailed scrutiny of the information provided.  The processing
technology at this time is standard desktop computer with word
processing software.  Agency staff will enter and store some data
electronically using these formats.  GPRA information is also stored in
a manner that allows the public access through the EPA website.  Much of
the other information is not electronic and will be disseminated at
conferences and workshops, as appropriate.  In the future there is a
possibility much of the information could be scanned to make it more
accessible to the public.

5(c) Small Entity Flexibility

            States and local governments are the most likely respondents
to this information request.  The burden on small organizations is
therefore not an issue for the reporting requirements contained in this
ICR.

5(d) Collection Schedule

            Annual workplans are required each year from the 28 NEPs by
February 28th.

Implementation Reviews are scheduled as follows: 12 programs are
scheduled for FY (07, nine for FY (08, and seven for FY (09.  GPRA
reports are submitted annually to correspond with the Agency reporting
process and are requested to be provided by the end of the fiscal year. 


6. Estimating The Burden and Cost of the Collection

6(a) Estimating Respondent Burden

The total number of estuary programs in the NEP is limited by the
amount of funds appropriated from Congress.  Current status and budget
projections provide for up to a total of 28 estuaries in the NEP in FY
2006.  During the term of this ICR, all 28 are operating in the
post-CCMP implementation stage which, as discussed in the abstract in
section 1(b), concerns oversight and implementation of the CCMP.  During
the post-CCMP phase, the NEP programs receive significantly less funding
and the annual work plan encompasses less effort than those of the
pre-CCMP period.  Based on the experience of program participants to
date, we will continue to use the burden hour estimates developed for
the 2002 ICR calculations for the agency as well as respondents, except
for the GPRA hours which decreased slightly.

 (A) Annual Work Plans:  It is estimated that 100 burden hours are
required for State personnel to prepare and gather information to
summarize the previous years activities, to plan for the current year,
and to produce the annual work plan.  This is the same value used in the
previous review cycle.  It is expected that Management Conferences will
be moving to more improved records keeping and tracking, which should
result in a lower burden for the following cycle. 

The annual workplan burden to respondent is: 

FY 07:  28 Annual Work Plans       28 Annual Work Plans * 100
hrs/workplan = 2,800 hrs/year

FY 08:  28 Annual Work Plans       2,800 hrs/year * 3 years = 8,400
hrs/3 years

FY 09:  28 Annual Work Plans

(B) Implementation Review:  It is estimated that 250 burden hours are
required for respondents to prepare and gather information to summarize
the previous period(s activities.  Because it is expected that NEPs will
be continually reviewing and reassessing priorities within each program,
250 hours is considered to be an upper limit on the effort required to
prepare an implementation review report.  The 2002 ICR value of 250
burden hours will again be used for this cycle.  The personnel required
to complete this effort is a mix of white collar staff: approximately 55
percent technical, 5 percent secretarial and 40 percent administration
or managerial level. 

The implementation review report burden to the respondent is:

FY07: 12 Implementation Review Reports

FY08: 9 Implementation Review Reports

FY09: 7 Implementation Review Reports

28 Implementation Review Reports *  250 hours/report = 7,000/3 years

(C) Government Performance Results Act Reporting: Based on discussions
with respondents, it is estimated that an upper limit for burden hours
to the NEPs for reporting GPRA information is 60 hours with a lower
limit of 10 hours for those programs with established information
management systems in place.  As more programs have established tracking
systems and information management systems the burden hours have
decreased from the last reporting cycle.  The annual average estimate of
burden hours for the NEPs to collect and report GPRA information is
presently 25 hours per report.

The GPRA reporting burden to the respondent is:

FY07:  28 GPRA Reports      28 GPRA Reports * 25hrs/report = 700hrs/year

FY08:  28 GPRA Reports      700hrs/year * 3 years = 2,100hrs/3 years

FY09:  28 GPRA Reports

6(b) Estimating Respondent Costs 6(b)(I)   Estimating Labor Costs   

 (A) Annual Workplans:  The post-CCMP annual workplan is estimated to
take 100 hours of preparation time by State and local government
personnel.  In the last ICR cycle, in 2002, a labor rate of $60/hour was
used that included fringe benefits and other overhead costs as well as
travel and other material costs.  The average hourly 2006 rate for this
ICR is $66.96, as adjusted with the Employment Cost Index (ECI), using
the 2002 ICR baseline of $60/hour.  It reflects the total cost to employ
an individual and includes salaries, fringe benefits and other overhead
costs. 

      

The annual workplan cost to the respondent is: 

FY 07:  28 Annual Work Plans       28 Annual Work Plans * 100
hrs/workplan = 2,800 hrs/year

FY 08:  28 Annual Work Plans        2,800 * 3 years = 8,400 hrs/3 years

FY 09:  28 Annual Work Plans        2,800 hrs/year *  $66.96hr =
$187,488/year

(B) Implementation Review:  It is estimated that 250 burden hours are
required for respondents to prepare and gather information to summarize
the previous period(s activities.  Because it is expected that NEPs will
be continually reviewing and reassessing priorities within each program,
250 hours is considered to be an upper limit on the effort required to
prepare an implementation review report. The State and local government
labor rate of $66.96 which reflects adjustment from the 2002 ICR
baseline using the ECI, will be used (see Annual Workplan cost
description).   

The implementation review report cost to the respondent is:

FY07: 12 Implementation Review Reports      

FY08: 9 Implementation Review Reports

FY09: 7 Implementation Review Reports

28 Implementation Review Reports *  250 hours/report = 7,000/3 years

7,000/3 years * $66.96 = $468,720  $468,720/3 years =   $156,240/ year

(C)  Government Performance Results Act Reporting: Based on discussions
with respondents, it is estimated that an upper limit for burden hours
to the NEPs for reporting GPRA information is 60 hours with a lower
limit of 10 hours for those programs with established information

management systems in place.  As programs begin to establish tracking
systems and information management systems the burden hours should
decrease.  Presently, the annual average estimate of burden hours for
the NEPs collecting and reporting GPRA information is 25 hours per
report.

The State and local government labor rate of $66.96, which reflects
adjustment from the 2002 ICR baseline using the ECI, will be used (see
Annual Workplan cost description).

The GPRA annual reporting cost to the respondent is:

FY07:  28 GPRA Reports       28 GPRA Reports * 25hrs/report =
700hrs/year

FY08:  28 GPRA Reports       700 hrs/year * 3 years = 2,100hrs/3 years

FY09:  28 GPRA Reports       700hrs/year * $66.96hr = $58,600

(6)(b)(ii) Estimating Capital and Operations and Maintenance Costs:

As in the last review cycle, 2002, no Capital and Operations and
Maintenance Costs are expected. 

(6)(b)(iii) Capital/Start-up Operating and Maintenance (O&M) Costs:

As in the last review cycle, 2002, no Capital and Operations and
Maintenance Costs are expected.

(6)(b)(iv) Annualizing Capital Costs:   N/A

6(c) Estimating Agency Burden and Cost

(A) Annual Workplans:

Part of the overall burden and cost to the Federal Government is based
on the number of annual work plans expected each year as estimated in
Item No. 6(a).  The burden and cost are also based on the last ICR cycle
in 2002.  In the last ICR cycle, reviewing the post-CCMP annual work
plan required 16 hours of Federal workers( time.  These estimates were
collected from several EPA Regional Offices and also from Headquarters
staff reviewers.  The 16 hour value is still applicable for this review
cycle.  Also in the last ICR cycle, 2002, a labor rate of $52/hour was
used which was lower than the State and local government rate because
the mix of staff requires less senior level involvement.  The average
hourly 2006 rate for a Federal worker is $58.03, as adjusted with the
Employment Cost Index (ECI) using the 2002 ICR baseline of $52/hour. 
The burden and cost to the Federal Government for reviewing annual
workplans is summarized below.

(A)  Post-CCMP Annual Work Plan

FY07:	28 NEP Annual Work Plans

FY08:	28 NEP Annual Work Plans

FY09:	28 NEP Annual Work Plans

28 Work Plans * 16 hours/plan = 448 hours/year

448 hours/year * 3 years = 1,344 hours/ 3 years

448 hours/year * $58.03/hour = $25,997/ year

(B) Implementation Reviews:

Part of the overall burden and cost to the Federal Government is based
on the number of implementation review reports expected each year as
estimated in Item No. 6(a).  The burden and cost are based on the last
ICR cycle.  In the last ICR cycle reviewing the implementation review
reports required 40 hours of Federal workers( time.  The burden is based
on experience with the implementation reviews conducted during the past
few years.  These estimates were collected from several EPA Regional
Offices and also from HQ staff reviewers.   The 40 hour value is still
applicable for this review cycle.  Also in the last ICR cycle, 2002, a
labor rate of $52/hour was used which was lower than the State and local
government rate because the mix of staff requires less senior level
involvement.  The average hourly Federal worker rate for this ICR is
$58.03/hour, adjusted with the Employment Cost Index (ECI) using the
2002 ICR baseline of $52/hour.  The burden and cost to the Federal
Government for reviewing implementation review reports is summarized
below. 

The implementation review report burden and cost to the Agency is:

FY07: 7 Implementation Review Reports      

FY08: 12 Implementation Review Reports

FY09: 9 Implementation Review Reports

28 Implementation Review Reports * 40 hours/report = 1,120hrs/3 years

1120hrs/3 years * $58.03/hour = $64,994     $64,994/3 years =  
$21,665/year

(C) Government Performance Results Act Reporting:

Part of the overall burden and cost to the Federal Government is based
on the number of GPRA reports expected each year as estimated in Item
No. 6(a).  Based on Headquarters experience approximately 8 hours of
Federal workers time is required to review a GPRA report.  The hourly
rate for staff is $58.03 per hour as described in (B) above.  The GPRA
review burden and cost is:

FY07:   28 GPRA Reports       28 GPRA Reports * 8hrs/report =
224hrs/year

FY08:   28 GPRA Reports       224 hrs/year * 3 years = 672hrs/3 years

FY09:   28 GPRA Reports       224hrs/year * $58.03/hr = $12,999

6(d) Estimating the Respondent Universe and Total Burden and Costs

The total universe of respondents is 28, as every NEP is required to
submit annual workplans, implementation reviews, and GPRA reports over
this three year cycle. 

Total Burden to Respondent:

                                                  Annual Workplans      
           8,400 hrs/3 years

                                                  Implementation Reviews
       7,000 hrs/3 years

                                                  GPRA Reports          
             2,100 hrs/3 years

                                                                        
      Total         17,500 hrs/3 years

                                                                        
      

                                                                        
     Annualized   5,833 hours/year

Total Cost to Respondent:      

                                                  Annual Workplans      
           $562,464/3 years

                                                  Implementation Reviews
       $468,720/3 years

                                                  GPRA Reports          
             $175,800/3 years

                                                                        
            Total  $1,206,984

                                                                        
      Annualized    $402,328/year

Total Burden for Agency: 

                                                  Annual Workplans      
            1,344 hours/3 years 

                                                  Implementation Reviews
        1,120 hours/3 years

                                                  GPRA Reports          
                 672 hours/3 years

                                                                        
             Total    3,136 hours/3 years

                                                                        
      Annualized    1,045 hours/year

Total Cost to Agency:               Annual Workplans                  $
77,992

                                                  Implementation Reviews
        $ 64,996

                                                  GPRA Reports          
              $ 38,998

                                                                        
              Total   $181,986

                                                                        
      Annualized    $60,662/year

6(e) Bottom Line Burden Hours and Cost Tables

(I) Respondent Tally             Total Burden:  5,833 hrs/year     
Total Cost: $402,328yr

(ii) The Agency Tally           Total Burden:  1,045 hours/year      
Total Cost:  $60,662/yr  

(iii) Variations in the Annual Bottom Line:   It is not anticipated that
there will be a significant variation (>25%) for the burden or cost to
either respondents or Agency over this ICR cycle.

6(f) Reasons for Change in Burden - 

EPA instituted an implementation review process for the NEPs to ensure
that continued EPA funding under section 320 is appropriate. 
Implementation review reporting was reduced from every two years to
every three years in 2002, thereby creating less burden on the
respondents.  This review is made periodically to ensure that each NEP
remains on track and continues to make progress implementing their CCMP
and reporting environmental results.  In the implementation of the CCMP
the GPRA reporting of environmental results is less burdensome as
reporting has become more streamlined and electronic submittals more
common.  

 

6(g) Burden Statement

            The public reporting and recordkeeping burden for this
collection of information is estimated to average 100 hours per response
for Annual Workplans, 250 hours per response for Implementation Review
reports, and 25 hours per response for GPRA reporting.  Burden means the
total time, effort, or financial resources expended by persons to
generate, maintain, retain, 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 No. EPA-HQ-OW-2006-0369, which is available for on-line
viewing at   HYPERLINK "http://www.regulations.gov"  www.regulations.gov
 or in person at the Water Docket in the EPA Docket Center (EPA/DC), EPA
West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA
Docket Center Public Reading Room  is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Water Docket is (202) 566-2426).  

An electronic version of the public docket is available through the
Federal Docket Management System (FDMS) at www.regulations.gov.  Use
FDMS to submit or view public comments, access the index listing of the
contents of the public docket, and to access those documents in the
public docket that are available electronically.  Once in the system,
select (search,( then key in the docket ID number identified above. 
Also, you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, DC 20503, Attention: Desk Office for EPA.  Please include
the EPA Docket ID No.  (EPA-HQ-OW-2006-0369) and OMB control number
2040-0138 in any correspondence. 

NOTE: The EPA Docket Center suffered damage due to flooding during the
last week of June 2006.  The Docket Center is continuing to operate. 
However, during the cleanup, there will be temporary changes to Docket
Center telephone numbers, addresses, and hours of operation for people
who wish to make hand deliveries or visit the Public Reading Room to
view documents.  Consult EPA’s Federal Register notice at 71 FR 38147
(July 5, 2006) or the EPA website at   HYPERLINK
"http://www.epa.gov/epahome/dockets.htm" 
http://www.epa.gov/epahome/dockets.htm  for current information on
docket operations, locations, and telephone numbers.  The Docket
Center’s mailing address for U.S. mail and the procedure for
submitting comments to   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov  are not affected by the flooding and will remain
the same.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

	This section is not applicable because no statistical procedures are
employed for the data collection.

 PAGE  17 

