Information Collection Request

Supporting Statement

for the National Listing of Fish Advisories

Renewal ICR

OMB Control No. 2040-0226

(Non-Regulatory)

June 11, 2007

U.S. Environmental Protection Agency

Office of Water

Office of Science and Technology

Standards and Health Protection Division

1200 Pennsylvania Avenue, NW

Washington, DC 20460

TABLE OF CONTENTS

Section	Page

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc155688967"  1.
Identification of the Information Collection	  PAGEREF _Toc155688967 \h 
1  

  HYPERLINK \l "_Toc155688968"  1(a)	Title of the Information Collection
  PAGEREF _Toc155688968 \h  1  

  HYPERLINK \l "_Toc155688969"  1(b)	Short Characterization/Abstract	 
PAGEREF _Toc155688969 \h  1  

  HYPERLINK \l "_Toc155688970"  2.	Need for and Use of the Collection	 
PAGEREF _Toc155688970 \h  4  

  HYPERLINK \l "_Toc155688971"  2(a)	Need/Authority for the Collection	 
PAGEREF _Toc155688971 \h  4  

  HYPERLINK \l "_Toc155688972"  2(b)	Practical Utility/Users of the Data
  PAGEREF _Toc155688972 \h  4  

  HYPERLINK \l "_Toc155688973"  3.	Non-duplication, Consultations, and
Other Collection Criteria	  PAGEREF _Toc155688973 \h  5  

  HYPERLINK \l "_Toc155688974"  3(a)	Non-duplication	  PAGEREF
_Toc155688974 \h  5  

  HYPERLINK \l "_Toc155688975"  3(b)	Public Notice Required Prior to ICR
Submission to OMB	  PAGEREF _Toc155688975 \h  6  

  HYPERLINK \l "_Toc155688976"  3(c)	Consultations	  PAGEREF
_Toc155688976 \h  6  

  HYPERLINK \l "_Toc155688977"  (i)	Initial Federal Register Notice	 
PAGEREF _Toc155688977 \h  6  

  HYPERLINK \l "_Toc155688978"  (ii)	Questionnaire Preparation and
Consultation	  PAGEREF _Toc155688978 \h  6  

  HYPERLINK \l "_Toc155688979"  (iii)	National Conferences	  PAGEREF
_Toc155688979 \h  6  

  HYPERLINK \l "_Toc155688980"  3(d) 	Effects of Less Frequent
Collection	  PAGEREF _Toc155688980 \h  7  

  HYPERLINK \l "_Toc155688981"  3(e)	General Guidelines	  PAGEREF
_Toc155688981 \h  7  

  HYPERLINK \l "_Toc155688982"  3(f) 	Confidentiality	  PAGEREF
_Toc155688982 \h  7  

  HYPERLINK \l "_Toc155688983"  3(g)	Sensitive Questions	  PAGEREF
_Toc155688983 \h  7  

  HYPERLINK \l "_Toc155688984"  4.	The Respondents and the Information
Requested	  PAGEREF _Toc155688984 \h  7  

  HYPERLINK \l "_Toc155688985"  4(a)	Respondents/SIC Codes	  PAGEREF
_Toc155688985 \h  8  

  HYPERLINK \l "_Toc155688986"  4(b)	Information Requested	  PAGEREF
_Toc155688986 \h  8  

  HYPERLINK \l "_Toc155688987"  (i)	Data items, including record keeping
  PAGEREF _Toc155688987 \h  8  

  HYPERLINK \l "_Toc155688988"  (ii)	Respondent Activities	  PAGEREF
_Toc155688988 \h  9  

  HYPERLINK \l "_Toc155688989"  5. 	The Information Collected–Agency
Activities, Collection Methodology, and Information Management	  PAGEREF
_Toc155688989 \h  9  

  HYPERLINK \l "_Toc155688990"  5(a)	Agency Activities	  PAGEREF
_Toc155688990 \h  9  

  HYPERLINK \l "_Toc155688991"  5(b)	Collection Methodology and
Management	  PAGEREF _Toc155688991 \h  10  

  HYPERLINK \l "_Toc155688992"  5(c)	Small Entity Flexibility	  PAGEREF
_Toc155688992 \h  11  

  HYPERLINK \l "_Toc155688993"  5(d)	Collection Schedule	  PAGEREF
_Toc155688993 \h  12  

  HYPERLINK \l "_Toc155688994"  6.	Estimating the Burden and the Cost of
the Collection	  PAGEREF _Toc155688994 \h  12  

  HYPERLINK \l "_Toc155688995"  6(a)	Estimating Respondent Burden	 
PAGEREF _Toc155688995 \h  12  

  HYPERLINK \l "_Toc155688996"  6(b)	Estimating Respondent Costs	 
PAGEREF _Toc155688996 \h  15  

  HYPERLINK \l "_Toc155688997"  (i)	Estimating Labor Costs	  PAGEREF
_Toc155688997 \h  15  

  HYPERLINK \l "_Toc155688998"  (ii)	Estimating Capital and Operations
and Maintenance Costs	  PAGEREF _Toc155688998 \h  15  

  HYPERLINK \l "_Toc155688999"  (iii)	Capital/Start-up vs. Operating and
Maintenance Costs	  PAGEREF _Toc155688999 \h  16  

  HYPERLINK \l "_Toc155689000"  (iv)	Annualizing Capital Costs	  PAGEREF
_Toc155689000 \h  16  

  HYPERLINK \l "_Toc155689001"  6(c)	Estimating Agency Burden and Cost	 
PAGEREF _Toc155689001 \h  18  

  HYPERLINK \l "_Toc155689002"  6(d)	Estimating the Respondent Universe
and Total Burden and Costs	  PAGEREF _Toc155689002 \h  22  

  HYPERLINK \l "_Toc155689003"  6(e)	Bottom Line Burden Hours and Cost
Tables	  PAGEREF _Toc155689003 \h  22  

  HYPERLINK \l "_Toc155689004"  (i)	Respondent Tally	  PAGEREF
_Toc155689004 \h  22  

  HYPERLINK \l "_Toc155689005"  (ii)	The Agency Tally	  PAGEREF
_Toc155689005 \h  22  

  HYPERLINK \l "_Toc155689006"  (iii)	Variations in the Annual Bottom
Line	  PAGEREF _Toc155689006 \h  23  

  HYPERLINK \l "_Toc155689007"  6(f)	Reasons for Change in Burden	 
PAGEREF _Toc155689007 \h  23  

  HYPERLINK \l "_Toc155689008"  6(g)	Burden Statement	  PAGEREF
_Toc155689008 \h  23  

  HYPERLINK \l "_Toc155689009"  7.	Response to OMB’s “Terms of
Clearance”	  PAGEREF _Toc155689009 \h  23  

 Appendix A – Relevant Sections of Statues, Regulations, or
Judicial/Administrative Decrees Enabling the Collection of Information
for the National Listing of Fish Advisories	A-1

Appendix B – 2004 Fish Advisory Fact Sheet	B-1

Appendix C – Federal Register Notice for Original and Renewal ICR
(2000, 2003, 2007)	C-1

Appendix D – Survey Instrument for 2007–2009 NLFA Reporting Cycles
and the State Fish Advisory Program Questionnaire	D-1

1.	Identification of the Information Collection

1(a)	Title of the Information Collection

National Listing of Fish Advisories (Renewal)

1(b)	Short Characterization/Abstract

The National Listing of Fish Advisories is an integral component of
several key environmental assessment activities. In February 1998, U.S.
President Bill Clinton announced the Clean Water Action Plan to protect
public health and restore the nation’s waterways by providing states,
Tribes, and communities with appropriate tools and resources. Under the
Clean Water Action Plan, the U.S. Environmental Protection Agency (EPA)
implemented a series of key actions to ensure effective public notice of
fish and shellfish consumption risks and reduce chemical contamination
to levels that assure that locally caught fish and shellfish are safe to
regularly eat. This survey is one of the key actions under the Clean
Water Action Plan. In April 1999, the Agency sent letters concerning
fish consumption advisories to the heads of all state public health,
environmental, and natural resource management agencies, as well as to
Tribes that operate the National Water Program. This letter emphasized
the importance of a risk-based fish advisory program to protect the
health of women of child-bearing age, children, and people who eat large
amounts of locally caught fish for economic or cultural reasons. 

A critical concern to EPA is water quality in our nation’s waters. The
release of chemical contaminants from industrial production, increasing
urbanization, and the introduction of new pesticides in agriculture pose
potentially serious human health problems for the nation’s
recreational waters. These adverse effects have been one of EPA’s
long-standing concerns. They are also directly related to such Clean
Water Act (CWA) responsibilities as water quality standards and surface
water quality, and to the Agency’s effort to ensure that U.S. waters
are “fishable” and “swimmable.” In addition, recent studies have
confirmed that adverse health effects can result from consumption of
fish from chemically contaminated waters. Based on results from the 2004
National Listing of Fish Advisories (NLFA) database, there are currently
3,221 advisories in effect in 48 of the 50 states, the District of
Columbia, the U.S. Territory of American Samoa, and three Tribes,
advising consumers to limit or avoid consumption of certain species of
chemically contaminated fish. 

EPA believes there is a continuing need to maintain the overall quality
and availability of public information concerning fish advisories, which
includes, but is not limited to, water quality standards, monitoring and
assessment activities, and the issuance of advisories and bans. Primary
responsibility for these activities lies with each state; however,
several state agencies often share responsibilities for these activities
and the advisory results have not always been consistently reported. In
1993, EPA began compiling information on fish advisories provided by the
states in its biannual 305(b) Water Quality Inventory Reports; however,
EPA soon determined that some states did not report up-to-date
information about fish advisories in their 305(b) reports. In many
states, the water quality or environmental agencies were responsible for
preparing the 305(b) report, while the state health department was
generally primarily responsible for issuing the advisories. To obtain
the most updated information, EPA’s Office of Water began conducting a
voluntary annual Fish Advisory Survey in 1994 as part of the data
collection activities of the National Water Quality Inventory Reports
(CWA Sections 305[b], 303[d], 314[a], and 106[e]) (EPA ICR No. 1560.04;
Office of Management and Budget [OMB] Control No. 2040-007) to obtain
the most up-to-date information on fish advisories. The Agency began
surveying the state health departments or other state agencies
specifically responsible for the issuance of fish advisories. This
information has been archived in EPA’s NLFA database since 1994.

In 2000, a new collection instrument was developed for the state Fish
Advisory Program Survey because there were material changes in the
proposed collection instrument that required the inclusion of additional
questions in the fish advisory program’s areas of concern (State Fish
Advisory Program Questionnaire), and the number of respondents from
which the information was to be collected included additional Tribal
groups that have issued advisories, Tribal groups with delegated power
with respect to water quality standards, and Tribal groups with
delegated power pending. 

The changes to the 2004 to 2006 survey instrument were not substantive
material changes from the previously approved 2000 survey instrument.
The current instrument contains the same number of questions (98) as the
2000 and 2003 OMB-approved survey instrument. The only changes made to
the 2000 questionnaire for the 2004 to 2006 reporting cycles were as
follows: minor grammatical changes or revised wording to clarify the
question for the respondent and the addition of checkable boxes to
reflect additional choices where respondents previously were required to
type in answers under an “Other (please specify)” category. The
addition of new answer boxes was made after an analysis of the state
responses from 2001 to 2003. New boxes were added only when five or more
states provided the same response in the “Other (please specify)”
category. The minor rewording of the 2004 to 2006 survey instrument
included questions and answers changes. Minor changes to the questions
were made in 2003 to provide clarification of the question, and changes
to the answer categories were made to add selections that could be
easily checked by the respondents, thereby removing the need for
respondents to key in lengthier answers.

The current NLFA survey questionnaire for the 2007 to 2009 cycles
collects quantitative advisory information on the number of new
advisories issued by each state, territory, and Tribal organization
annually using the same basic survey questionnaire that was developed in
2000 (with only minor rewording), including information on the

Waterbody under advisory, including the geographic location and extent
of the advisory

Fish or shellfish species (and size ranges) included in each advisory

Chemical contaminant(s) identified in the advisory and the chemical
residue levels detected in various fish species sampled

Waterbody type encompassed by advisory (e.g., lake, river, estuary,
coastal waters)

Target populations (e.g., general population, pregnant women, nursing
mothers, and young children) to which the advisory refers. 

As in previous years, this information will be used to update the 2007,
2008, and 2009 NLFA narrative advisory information, compile and update
the geographic information system (GIS) database for all advisories, and
enhance and update the electronic fish tissue contaminant residue
datafile.

In addition, the State Fish Advisory Program Questionnaire part of the
survey will request information on the

Differences in monitoring procedures used to collect fish and shellfish
samples

Types of advisories issued by the state

Sample preparation and chemical analysis procedures used to assess
chemical residues 

State fish advisory program funding sources

Other uses of state fish advisory data

Risk assessment methodologies used to evaluate chemical residue data and
issue fish consumption advisories and bans 

State efforts for targeting fish consumers (e.g., recreational and
subsistence fishers)

Risk management practices and authority for issuing fish advisories
within the state

Risk communication procedures used to communicate the human health risks
associated with the consumption of chemically contaminated fish and
shellfish species.

From this information, EPA can determine what steps to take, if any, to
provide assistance to state, territorial, and Tribal fish advisory
programs to improve consistency in fish advisory programs among entities
through the use of consistent sampling and analysis procedures and risk
assessment, risk management, and risk communication procedures. Note:
The current survey instrument proposed for use in the 2007 through 2009
reporting cycles is the same basic instrument that was developed for the
previous 2004 to 2006 reporting cycles. 

EPA assembled the information collected under the previous Information
Collection request (ICR) into an electronic database and graphic formats
that can be readily analyzed and shared with responsible parties (e.g.,
EPA program and regional offices and other federal, state, territorial,
and Tribal agencies), as well as with the general public. Survey results
are distributed in Fish Advisory Fact Sheets and are available on the
Internet at EPA’s “National Listing of Fish Advisories” Web site
at http://www.epa.gov/waterscience/fish. Information from these surveys
has stimulated nationwide dialogue on fish consumption advisories
involving agencies and the public; it is being used to identify and
clarify issues that will lead to the continued development of national
guidance for states on sampling and analysis, risk assessment
procedures, risk management practices, and risk communication procedures
that will further protect human health.

The nationwide collection of fish advisory information began in 1994
with a survey of the 50 states, the District of Columbia, and U.S.
territories (Guam, American Samoa, Puerto Rico, and the U.S. Virgin
Islands) and the Great Lakes Indian Fish & Wildlife Commission,
involving a total of 56 potential respondents. In 2000, the fish
advisory survey added 36 Tribal agencies during the first year and will
continue to survey these same Tribal agencies, as well as the original
56 respondents over the 3-year period of this ICR (2007 to 2009); thus
the EPA estimates that a total of 92 questionnaires will be sent out the
first year and in the two succeeding years. The actual cost for a
respondent to complete the questionnaire is anticipated to decrease each
year because each person will be requested to provide only information
that has changed during the preceding year. When the survey is
implemented, the total annual respondent cost under this ICR is
estimated to be $124,755.08 (38.76 hours per year at an average labor
rate of $34.83 per hour per respondent for 92 respondents).

2.	Need for and Use of the Collection 

2(a)	Need/Authority for the Collection

EPA needs this information to determine whether recreational and
subsistence fishers are at additional risk of exposure to chemical
contaminants through their consumption of locally caught fish and
shellfish. The survey will provide data on the types of contaminants
that trigger the issuance of advisories, the monitoring designs the
states used with respect to the numbers of samples collected and number
of stations surveyed, the number of chemical contaminants being analyzed
in fish tissue, the risk assessment methodology currently being used to
evaluate the potential health risk to fish consumers, and how advisory
information is being communicated to the target fish-consuming
population.

This survey is one of the key actions under the Clean Water Action Plan.
In February 1998, the Clean Water Action Plan was initiated to protect
public health and restore the nation’s waters by providing states,
territories, and Tribes with appropriate tools and resources. Under the
Clean Water Action Plan, EPA is implementing a series of key actions to
ensure that recreational and subsistence caught fish are safe for human
consumption. The national survey is central to EPA’s efforts to assess
and improve existing fish advisory programs nationwide and to provide
important public health information.

EPA is collecting this information under the authority of CWA 104, which
provides for the collection of information to be used to protect human
health and the environment. Copies of the relevant section of the CWA
are provided in Appendix A. 

2(b)	Practical Utility/Users of the Data

EPA uses information collected in the NLFA to address issues in three
specific areas for state fish advisory programs

Enhancing the public’s right-to-know about the safety of fish and
shellfish harvested from local waters by making this information
available on a NLFA database

Improving the scientific and policy foundation in support of state,
territorial, Tribal, and local actions

Providing up-to-date sampling and analysis methods, risk assessment,
risk management, and risk communication procedures for the states to use
to better protect the health of recreational and subsistence fishers in
a more timely and comprehensive manner.

The information collected in this survey will be used to update the
existing NLFA database. This information will be compiled to determine
the status and nature of chemical contamination in the nation’s
waters, the level of effort directed by jurisdictions to monitor and
evaluate fish tissue residue data at their monitoring sites, and the
location and geographic extent of the fish advisories and bans issued
each year. EPA will use the analysis to plan more effective research and
policies to reduce risks to consumers of locally caught, chemically
contaminated fish.

The Office of Water uses and will continue to use the information,
especially the state and national summary data, to examine the success
of current advisory programs. The Office of Water will share this
information with other program offices, such as the Office of Research
and Development and the Office of Policy, Planning, and Evaluation, to
evaluate scientific research needs and policy implications. EPA Regions
will use the information to address concerns regarding fish advisories
and monitoring programs. The Centers for Disease Control and Prevention
and other federal agencies will also be able to use this information.
The information compiled in this survey will permit state, Tribal, and
local agencies, such as public health agencies, environmental protection
agencies, and fish and wildlife departments, to easily review cumulative
information on monitoring programs and fish advisories for the purpose
of developing public information materials (e.g., state fish advisory
Web sites and/or fishing regulation brochures) and prioritizing
resources to address water quality concerns directly related to chemical
contamination of fish.

Summary and individual state data will also be made available to
non-governmental organizations and to the public. By accessing the data
through the Internet, the fishing public will be able to readily
determine whether the waterbody they want to fish has been monitored to
assess the level of chemical contamination in the fish and whether an
advisory or ban has been issued. This will provide the consumers with
information that they can use to make informed decisions concerning the
waterbodies they fish in and the amount and types of fish they consume.

The information to be collected from all respondents includes the name,
address, and other contact information for the agency responsible for
issuing the fish advisories and answering public or technical inquiries.
These references provide a means for obtaining current fish advisory
information, as well as professional networking resources and referrals
for improving water quality at our nation’s fishable waterbodies. A
copy of the most recent fish advisory fact sheet distributed to the
public via the Internet is provided in Appendix B. 

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

3(a)	Non-duplication

The fish advisory program information requested from respondents under
this renewal ICR has been collected in some form since 1994 and is not
currently available from any other sources. The survey of fish
advisories has been performed since 1994 under previously approved ICRs
for the 305(b) Water Quality Collection Effort (OMB Control No.
2040-007; EPA ICR No. 1560.03 and 1560.04); however, Tribal
organizations had not been comprehensively targeted by these surveys.
EPA examined the information collected from each of the previous surveys
and determined that none of them addressed all of its needs to inventory
the locations of the nation’s waterbodies under advisories, as well as
to compile nationwide information on state, territory, and Tribal fish
advisory programs.

In 2000, because the Office of Water wanted to obtain additional
information on fish advisories from the 50 states, the District of
Columbia, five U.S. territories, and additional Tribal groups, a new ICR
was submitted to OMB for approval to cover additional questions and
respondents not covered by the 305(b) Water Quality Collection Effort.
Since 2000, the survey of fish advisories has been performed under an
approved ICR for the National Listing of Advisories (OMB Control No.
2040-0226; EPA ICR No. 1959.01, expiring on 01/31/2004; EPA ICR No.
1959.02, expiring on 09/30/2007). A copy of these Federal Register
notices is provided in Appendix C. 

EPA developed a new questionnaire in 2000, which was reviewed by fish
advisory contacts from nine states. To reduce respondent burden and
eliminate duplication, EPA worked to design concise and comprehensive
questions for the 2000 State Fish Advisory Program Questionnaire. The
2003 questionnaire was modified only slightly for the survey effort to
be covered under the ICR for 2004–2006. The questionnaire has not been
modified for the survey effort to be covered under the current ICR for
2007–2009 reporting cycles. EPA anticipates no change in the
survey’s ability to meet the needs of the federal government and other
interested parties.

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

The notice was published in the Federal Register on April 12, 2007
(Volume 72, Number 70), pages 18475-18477, requesting comments on the
National Listing of Fish Advisories, EPA ICR Number 1959.03, OMB Control
Number 2040-0226 for the current renewal ICR.  A copy of the notice is
provided in Appendix C. One comment was received, and is addressed in
the following section.

3(c)	Consultations

(i)	Initial Federal Register Notice

The initial Federal Register notice for this renewal ICR was published
on April 12, 2007, as noted above.  One set of comments was received
concerning this ICR.  The one reviewer indicated concern over whether
states are reporting accurate information regarding the contamination
levels in fish.  EPA has provided extensive guidance to states and
tribes for scientifically defensible methods for fish sampling and
analysis as well as for conducting risk assessments and determining fish
consumption limits.  The issuance of fish consumption advisories for
locally caught recreational fish is within the jurisdictional
responsibility of the states, which have a fundamental charge to serve
and protect public health.  The commenter also questioned where they
could obtain the 2005 and 2006 information.  EPA collects these data on
an annual basis, and the Agency makes these data available to the public
periodically based on public interest and available funding. 

(ii)	Questionnaire Preparation and Consultation

To prepare the survey for the collection effort covered under this
renewal ICR, EPA reviewed all questionnaires that had previously been
used to collect information for the 2004–2006 NLFA data collection
efforts, as well as respondent comments from these surveys. The results
were used to refine the questionnaire in order to encourage greater
respondent participation, and improve data analysis and interpretation.
The final survey for the 2007–2009 cycles is based on these reviews,
consultation with the states and Tribes at the 2000, 2001, 2002, 2004,
and 2005 annual EPA Fish Forums attended by state fish advisory
contacts, recent internal EPA discussions with various program offices,
and other considerations.

(iii)	National Conferences

EPA’s Office of Water has sponsored a National Forum on Chemical
Residues in Fish typically held every eighteen months. These forums,
which are national conferences on fish advisory issues, assemble fish
advisory contacts from the 50 states, District of Columbia, territories,
and Tribes, as well as EPA Headquarters staff, EPA Regional staff, and
experts in various fish advisory issues. At these meetings, state fish
contacts receive fish advisory summaries for their jurisdictions and
review fish advisory survey results from other states. The
representation includes experts from state health departments,
environmental agencies, Tribal organizations, the American Fisheries
Society, and EPA. Representative from all parts of the country have
attended these forums. Conference attendees have discussed a variety of
topics, including the continuing need for developing a more consistent
approach for monitoring programs, risk assessment, risk management, and
risk communication issues dealing with fish consumption advisories
nationwide. During these conferences, information about EPA’s national
survey is presented. No objections were raised to the survey at the Fish
Forums in 2000, 2001, 2002, 2004, or 2005.

3(d) 	Effects of Less Frequent Collection

The survey will be sent to respondents once per year, in the early
spring. The information is needed annually to provide up-to-date
information on monitoring and fish advisories that occurred during the
previous 12-month (calendar year) fishing season. Pollution sources and
other circumstances change regularly, so it is important to document the
changes in fish advisories as soon as possible after the states’ issue
their yearly fishing regulations, including advisories, typically during
spring. Jurisdictions that are responsible for fish monitoring generally
collect fish each year during summer and fall, and then send the fish
tissue samples for analysis during fall and winter. Risk assessments are
conducted when residue analysis of the fish tissue samples has been
completed typically in late winter. 

Regular annual collections of this information over a period of several
years have shown that the number of fish advisories continues to
increase nationwide. In addition, this information has helped to
characterize the pollutants that triggered these advisories. For
example, as of 2004, mercury was the chemical contaminant responsible
for 76 percent of all advisories issued nationwide and five pollutants
(mercury, dioxins/furans, polychlorinated biphenyls [PCBs], chlordane,
and dichlorodiphenyltrichloroethane [DDT]) accounted for 98 percent of
the advisories issued. Regular annual collection of this information has
also permitted the identification of advisory trends within various
waterbodies so that trends can be identified and resources allocated to
deal with the most pressing problems. Less frequent or irregularly
scheduled reporting of advisory information is not sufficient to obtain
information for the purposes of this survey because longer periods
between reports or unequal periods of reporting would decrease the value
of the information obtained, and respondents might have more difficulty
in completing the survey if past yearly records were archived. In
addition, regular annual collection of this information over several
years will permit the evaluation of water quality standards compliance
and pollution problems occurring in waterbodies under advisory, so that
trends can be identified and resources allocated to deal with the
problems of greatest concern.

3(e)	General Guidelines

This survey adheres to OMB’s general guidelines for information
collection.

3(f) 	Confidentiality

Information sought is maintained for public record by the state public
health agency or other state agencies and no sensitive material is
involved.

3(g)	Sensitive Questions

No questions concerning sexual behavior or attitudes, religious beliefs,
or other matters usually considered private are included in this
information collection.

4.	The Respondents and the Information Requested

4(a)	Respondents/SIC Codes 

The following categories of respondents will be surveyed:

State (or other entity) health departments

9431	Administration of public health programs (Administration of public
health programs, including the following: Categorical health program
administration—government, communicable disease program
administration—government, environmental health programs—government,
and public health agencies—non-operating).

State (or other entity) EPAs

9511	Air and Water Resource and Solid Waste Management (Administration
of Environmental Quality, including the following: Water control and
quality agencies—government and environmental protection
agencies—government).

4(b)	Information Requested

(i)	Data items, including record keeping

(1) Specific Information on Each Advisory or Ban within the Jurisdiction
(records to be maintained by the jurisdiction for the public record at
least 2 years following completion of the survey each year that the
questionnaire is conducted)

Waterbody name, location, and narrative description of geographic extent
of advisory

Waterbody type (lake, river, estuary, coastal marine waters, Great Lakes
waters, multi-class, bayou, canal) 

Chemical pollutant(s) detected in fish tissue samples that resulted in
issuance of the advisory

Species of fish and size ranges sampled for which the advisory was
issued 

Type of advisory issued and population that is targeted (no consumption
for the general population, no consumption for sensitive subpopulations,
such as pregnant or nursing women and children, restricted consumption
for the general population, restricted consumption for sensitive
subpopulation, or commercial fishing ban)

(2) General Information on State Fish Advisory Programs within the
Jurisdiction

Name, address, phone number, fax number, and e-mail address of
respondent (State fish advisory contact)

Agency or agencies with overall responsibility for fish advisories or
bans in the jurisdiction

Establishment of risk assessment procedures for issuing advisories

Monitoring and chemical analysis program implementation and costs

Advisory program implementation and costs

Agency responsibility for risk management and for issuing advisories or
bans

Public notification procedures for communicating information on
advisories and bans.

(3) Mapping the Location of Each Fish Consumption Advisory or Ban
(latitude/longitude coordinates for the advisory or hard copy of a
marked map that shows the location and extent of the advisory or
electronic shapefile/coverage of advisory locations)

A copy of the proposed survey instrument for the 2007 through 2009 NLFA
reporting cycles and the State Fish Advisory Program Questionnaire is
included as Appendix D. 

(ii)	Respondent Activities

The following activities are required for a respondent to assemble and
submit the above-mentioned data items:

Review instructions for entering updated advisory data into EPA’s NLFA
database

Gather advisory data to update the NLFA database (including waterbody
name and geographic extent, fish species/size class, pollutant, and type
of advisory), and fish tissue residue data files 

Gather geographic data by creating shapefiles/GIS coverages, providing
latitude/longitude coordinates, and/or by marking locations of current
fish advisories on electronic or hard copy maps

Update fish advisory data on the electronic NLFA data entry tool

Review instructions and questions in the State Fish Advisory Program
Questionnaire (approximately 100 questions)

Gather information needed to complete all questions on the survey

Complete survey answers electronically by typing in information on an
electronic questionnaire

Return marked maps, shapefiles/GIS coverages showing advisory locations,
or listing of latitude/longitude coordinates, and fish tissue residue
data for new advisories by email or on diskette by mail to EPA.

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

5(a)	Agency Activities

Agency activities associated with the collection of information by this
survey consist of the following:

Update current mailing list of all state, territory, and Tribal
organizations, and develop survey tracking database to track responses

Develop the transmittal letter, the State Fish Advisory Program
Questionnaire, instructions for completing updates to the NLFA database,
procedures for providing mapping/locational information, and recommended
fish tissue data format 

Create a database for storing and analyzing fish advisory information
collected 

Load the electronic questionnaire into a data entry tool

Record receipt of completed State Fish Advisory Program Questionnaires,
advisory revisions, marked map(s) or shapefiles/GIS coverages or
latitude/longitude files, and fish tissue residue data; submit reminders
to nonrespondents via e-mail and telephone calls; review State Fish
Advisory Program Questionnaires for completeness and correctness of
responses; review/verify advisory boundary markings on map(s); and
review and reformat fish tissue residue data files as appropriate

Enter appropriate geographic information on location of updated or new
advisories into GIS database, and review/verify data entries

Perform data analysis summaries of national and state advisory
information

Prepare an annual update of the Fish Advisory Fact Sheet and an annual
update of the State Fish Advisory Program Summary Report of information
obtained from the State Fish Advisory Program Questionnaire 

Distribute results of the advisory updates in the Fish Advisory Fact
Sheet electronically on the Internet and results of the Fish Advisory
Program Questionnaire in the State Fish Advisory Program Summary Report
in hard copy reports to the 92 state and Tribal participants and other
interested members of the general public (total of 200 copies)

Archive the State Fish Advisory Questionnaire responses, fish advisory
locational data (maps, shapefile/GIS coverages, or electronic
latitude/longitude files), and fish tissue residue data for at least 2
years.

5(b)	Collection Methodology and Management

To collect and analyze the information associated with this ICR, EPA
will primarily use an electronic questionnaire, paper maps, PCs, and
applicable database and digitizing software.

All potential state, territorial, or Tribal respondents in the mailing
list database will be provided access to the EPA NLFA database reporting
system, and an electronic survey will be developed and made available.
The transmittal letter will explain the purpose of the NLFA update
survey and the State Fish Advisory Program Questionnaire and provide
procedures to permit the respondents to complete the State Fish Advisory
Program Questionnaire electronically. It is anticipated that use of the
electronic version should decrease respondent burden because paper
copies will not have to be prepared for each fish advisory and the
survey will not have to be mailed back to the Agency. However, at a
minimum, each respondent is requested to return the marked map or a
shapefile/GIS coverage or latitude/longitude coordinates of advisory
locations and tissue residue data supporting the issued advisories to
EPA by email or on a diskette by mail. An email reminder will be sent to
respondents who have not returned their advisory map(s), electronic
shapefile/GIS coverage, or electronic file of tissue residue data, have
not entered updated fish advisory data into the NLFA database; or have
not completed the electronic State Fish Advisory Program Questionnaire
within 30 days.

EPA will ensure the accuracy and completeness of collected information
by reviewing each submission. Fish advisory data will be entered into
the data entry screen, but data will not be added to the existing
database until approved by EPA. The Internet version is currently linked
to the NLFA database so that data entry is automatic. In the event that
a state, territory, or Tribal agency cannot access the survey
electronically, entry of the fish advisory data and completion of the
survey will be manually performed through EPA’s data entry tool so
that all data will be incorporated into the same database. Manual data
entries will be double-checked to ensure the accuracy and completeness
of data entry. Data entries of survey answers made electronically by
respondents will also be reviewed to ensure that all questions were
completed. Tissue residue data will be reviewed and reformatted into a
Microsoft Access file as necessary to make it compatible in structure
with other state fish tissue residue data in the NLFA tissue residue
data repository.

Data analyses will be performed through queries and simple compilations
of summary statistics (e.g., number of fish advisories reported, number
of advisories issued for a specific chemical contaminant, such as
mercury, number of advisories issued for the general population as
opposed to number of advisories issued to protect pregnant women,
nursing mothers, and children, or number of rivers, lakes, estuaries, or
coastal marine waters under advisory). Marked maps received from
respondents will be checked to determine whether instructions were
followed and the maps marked so that the information can be entered into
a GIS database. Back-up copies of the data will be made regularly during
the survey and maintained in a separate location for at least 2 years.

Summary results of the annual surveys will be posted on EPA’s NLFA Web
page. Individual state reports will be accessible by the public through
querying EPA’s Web page. Annual Fish Advisory Fact Sheets summarizing
the most current information on fish advisories will also be available
on the same Web site. Summary results of the State Fish Advisory Program
Questionnaire will be summarized in an annual State Fish Advisory
Program Summary Report and will be distributed in hard copy to the state
fish advisory contacts and interested members of the general public
(total of 200 hard copies).

5(c)	Small Entity Flexibility

No alternatives have been found to be more cost effective than direct
solicitation of the state health departments or other state,
territorial, or Tribal entities responsible for issuing fish advisories
and that generate this information as a matter of public information for
distribution to their state, territorial, or Tribal residents. No
additional gathering of information is required by the state health
departments or other entities responsible for each fish advisory because
advisories and records are their public health responsibilities.
“Small Governmental Jurisdictions” (defined for the purpose of this
information collection as a government or territories or Tribes having a
population of less than 50,000) may be included in this survey.

The completion of the survey (including the addition of updated advisory
information, marking maps, providing fish tissue residue data, and
completing the State Fish Advisory Program Questionnaire) is voluntary.
Thus, smaller entities that cannot provide the staff and resources to
complete the survey are not required to do so. Identification of such
smaller entities that do not initially respond will permit the
development of options to assist the smaller entities in completing the
survey, such as permitting more time for responding, simplifying the
response procedures, or providing contractor assistance in completing
the survey. The option of completing the fish advisory survey and State
Fish Advisory Program Questionnaire electronically will be encouraged,
which should provide an easier and more effective means for transmitting
and receiving the information, provided the entities have email or
Internet access. Based on past experience with state health departments
and other state, territorial, and Tribal entities involved in issuing
fish advisories, the vast majority have email or Internet access.

5(d)	Collection Schedule

The survey materials will be available to the respondents in early
spring to obtain information on the previous year’s fish advisories,
sampling, and analysis programs, and risk assessment, risk management,
and risk communication procedures. If the completed survey materials
have not been returned within 30 days, then an e-mail reminder will be
sent to all nonrespondents. In addition, follow-up telephone calls will
be made to the nonrespondents to determine what, if any, assistance they
need to complete the questionnaire. If the completed survey materials
have not been returned within 60 days, the survey will be considered to
be unobtainable. Data will be analyzed, and summary advisory information
will be made available to the public by September each year.

6.	Estimating the Burden and the Cost of the Collection

6(a)	Estimating Respondent Burden

EPA reviewed burden estimates generated by an e-mailed inquiry of nine
state health departments in 2000 and made the following assumptions in
determining respondent burden based on responses obtained from four
states. (The annual respondent burden table presented in Table 1
reflects the estimated average annual labor hours and costs, calculated
to occur during the 3-year OMB-approved period of this ICR).

Labor hours are based on initial assumptions that 92 potential
respondents will be asked to participate in the survey annually. Thus,
the total number of surveys that might be processed during this ICR is
276 (3-year approval period).

Senior-level managers (e.g., director, chief) are most likely to receive
the survey materials and review instructions for entering new advisories
or updating existing advisory data; however, it is anticipated that a
lower-level technical staff member would actually enter the new advisory
data into the NLFA database, copy fish residue data onto a diskette for
mailing to EPA, fill out the State Fish Advisory Program Questionnaire
electronically, and mark the fish advisory locations on the maps,
provide shapefiles/GIS coverages or latitude/longitude coordinates.
Thus, it is estimated that both the manager and the technical person
could spend 1.25 hours each year reviewing the instructions for entering
new advisory data into the NLFA database; therefore, the average
annualized respondent hour burden to review instructions to enter data
into the NLFA is 1.25 hours, as shown below. 

	(0.25 hour–manager/year + 1.0 hour–technician/year) = 1.25 hours

The amount of time needed to gather advisory data to update the NLFA
varies considerably, depending on how many new fish advisories have been
issued within the jurisdiction during the past year and/or how many
revisions there are to previously issued advisories. For example, during
the 2003 cycle, 25 states reported no new advisories for the year, while
the 31 remaining states reported from 1 to 73 new advisories. However,
approximately 20 states also made revisions to existing advisory files.
Similar differences among the states in the number of new and revised
advisories reported have been observed over the past several years.
Because the amount of time needed to complete the new advisory
information or update existing information will vary depending on the
number of advisories within the respondent’s jurisdiction, a
respondent with one fish advisory might require 0.25 hours while a
respondent with 20 advisories might require 5 hours. The number of
respondents with “low” and “high” fish advisory reporting
burdens is unknown at this time. For the purposes of this ICR, EPA
estimates (based on the responses from four states), on the average,
that it will require 9.25 hours to complete the new advisory information
and revise existing data. Information requested is compiled by each
jurisdiction for the public record, hence little, if any, additional
time will be needed to gather the information. We estimate that 9.25
hours will be needed each year to gather the advisory information as
shown below.

(1.0 hour–manager/year + 6.25 hour–technician/year + 2.0
hour–clerical/year) = 9.25 hours

The amount of time needed to gather geographic data develop
shapefiles/GIS coverages, determine latitude/longitude coordinates, or
manually mark locations of the advisories on a map also varies
considerably, depending on how many new fish advisories have been issued
within the jurisdiction during the past year. For example, during the
2003 cycle, 25 states reported no new advisories for the year while the
remaining states reported from 1 to 73 new advisories. Similar
differences among the states in the number of new advisories reported
have been observed over the past several years. Information requested is
compiled by each jurisdiction for the public record; hence little, if
any, additional time will be needed to gather the information. We
estimate (based on the responses from four states) that 7 hours will be
needed each year to gather the geographic data, create a shapefile/GIS
coverage, determine latitude/longitude coordinates, or mark advisory
locations on a map as shown below.

(0.5 hour–manager/year + 4.5 hour–technician/year + 2.0
hour–clerical/year) = 7.0 hours.

Respondents using the electronic data entry tool to log in their fish
advisory data will require less clerical time than in the past for
preparing and copying advisory information. EPA knows from results of
the 2003 survey that 90 percent of the potential respondents have access
to the Internet and can complete the advisory information electronically
(during the 3-year OMB approval period). Thus, only 10 percent of the
potential respondents will need to make copies of their advisory
information. Respondents completing the data entry electronically to log
in their advisory information will not require as much clerical time as
in the past for preparing paper copies of advisory information. We
estimate that 4.25 hours will be needed each year to update advisory
data as shown below.

(0.5 hour–manager/year + 2.75 hour–technician/year + 1.0
hour–clerical/year) = 4.25 hours

Senior-level managers (e.g., director, chief) are most likely to receive
the survey materials relating to the State Fish Advisory Program
Questionnaire; however, it is anticipated that a lower-level technical
staff member would actually complete the questionnaire electronically.
Thus, it is estimated that both the manager and the technical person
could spend 3.13 hours each year reviewing the instructions and
questions on the State Fish Advisory Program Questionnaire; therefore,
the average annualized respondent hour burden to review instructions and
answer questions is 3.13 hours, as shown below.

	( 0.5 hour-manager/year + 2.63 hour-technician/year) = 3.13 hours

The amount of time needed to gather all information to update the State
Fish Advisory Program Questionnaire should be relatively comparable
across jurisdictions depending on how many state agencies are involved
in the fish advisory activities. All states are requested to complete
every question to their best knowledge. Information requested is
compiled by each jurisdiction for the public record, hence little, if
any, additional time will be needed to gather the information. We
estimate that 7.25 hours will be needed each year to gather the advisory
information needed to complete the State Fish Advisory Program
Questionnaire as shown below.

	(1.5 hour–manager/year + 5.75 hour–technician/year) = 7.25 hrs.

For the 2007 through 2009 survey reporting cycles, each state fish
contact will receive an electronic copy of the questionnaire with the
previous year’s answers filled in. In this way, respondents will only
need to report information that has changed during the previous
reporting period, based on a review of their questionnaire responses
submitted for the 2006 cycle. We estimate that 5.0 hours will be needed
each year to complete the answers to the State Fish Advisory Program
Questionnaire electronically as shown below.

	(4.25 hour–technician/year + 0.75 hour–clerical/year) = 5.0 hours

Respondents using the electronic data entry tool to complete their
surveys will not require as much clerical time as in the past for
preparing and copying paper questionnaires. EPA knows from results of
the 2000–2003 cycle survey that 90 percent of the potential
respondents have Internet access and can complete the questionnaire
electronically (during the 3-year OMB approval period). Thus, only 10
percent of the potential respondents (9 respondents) will need to make
copies of their surveys.

All respondents will likely have to mail back some types of information
to EPA each year even if they report the fish advisory data and complete
the State Fish Advisory Program Questionnaire electronically. Products
that may need to be mailed back to EPA include hard copies of new
advisory information (if a respondent cannot enter data electronically),
hard copies of maps with advisories marked, or electronic shapefiles/GIS
coverages, or hard copy listings or electronic listings of
latitude/longitude coordinates (all respondents with new advisories), a
diskette containing fish tissue residue data that supports new
advisories (all respondents with new advisories), and/or the hard copy
of the State Fish Advisory Program Questionnaire (if a respondent cannot
enter data electronically). Based on the responses from four states, we
estimate 1.63 hours will be needed to complete this activity as shown
below: 	

	(1.38 hour–technician/year + 0.25 hour–clerical/year) = 1.63 hours

6(b)	Estimating Respondent Costs

The following resources and assumptions were made to estimate respondent
costs for this information collection:

(i)	Estimating Labor Costs

Labor rates were obtained from the Bureau of Labor Statistics’
Employment Cost Trends at
http://stats.bls.gov/news.release/ecec.t04.htm, and the following
categories were used:

Manager (White collar: Executive, administrative,

and managerial)

$32.96/hour

Technical (White collar)

$21.31/hour

Clerical (Administrative support, including clerical)

$16.04/hour

				

A benefits/overhead multiplication factor of 1.6 was used to obtain the
total cost of employment for state (or other entity) respondents.

(ii)	Estimating Capital and Operations and Maintenance Costs

No capital/start-up costs are anticipated for the jurisdictions
participating in the survey because they already collect the information
requested for the public record. Ninety percent of all respondents who
were surveyed in 2002 (during the 2003 reporting cycle) have Internet
access; however, it is not required for participating in the survey.

The only operations and maintenance (O&M) cost required for this
information collection by the respondent is the purchase of a state map
(estimated to cost $5.00), which will be used to mark the advisories,
and a compact disk (estimated to cost $0.60), which will be used to
download his or her latitude/longitude coordinate data, shapefiles/GIS
coverages, or fish tissue residue data. Jurisdictions already maintain
the information requested in this collection for the public record. EPA
will provide return postage for the map, the tissue residue data
diskette, fish advisory information (as applicable), and the State Fish
Advisory Program Questionnaire (as applicable).  Currently, most
jurisdictions provide these data electronically via email.

EPA estimates that 90 percent of the potential respondents have Internet
access and would complete the survey electronically. Thus, fewer
respondents would need to return a hard copy of the fish advisory survey
and the State Fish Advisory Program Questionnaire by mail, although it
is anticipated that all states, at a minimum, will be returning the
marked up state map showing advisory locations and one diskette
containing shapefile/GIS coverage, latitude/longitude coordinates, or
tissue residue data. We assume an average of five fish advisories per
jurisdiction and a 20-page questionnaire at $0.10 per page copying
charge ($2.50). This is based on the average number of new advisories
issued nationwide during the 2000–2002 reporting years. For the
purpose of estimating O&M costs for those states that do not have
Internet access, the total respondent number was multiplied by 10
percent and then multiplied by $2.50 per year for photocopy charges.

(iii)	Capital/Start-up vs. Operating and Maintenance Costs

It is believed that the capital/start-up and O&M costs have been
appropriately derived for this information collection.

(iv)	Annualizing Capital Costs

No capital costs are anticipated for this information collection. The
electronic version of the NLFA survey and the State Fish Advisory
Program Questionnaire is offered as an option, not as a requirement.
Completion of either the electronic version or a paper version is
voluntary.

Table 1. Annual Respondent Burden and Cost

Information Collection Activity	Hours and Costs Per Respondent 

(Years 1-3)	Total Hours and Costs 

(Year 1)	Total Hours and Costs 

(Year 2)	Total Hours and Costs 

(Year 3)

	Mgr. Hours at $32.96/ hour	Tech. Hours at $21.31/ Hour	Cler. Hours at
$16.04/ Hour	Resp. Hours	Labor Cost	Capital Start-Up Cost	O&M Cost	No.
of Resp.	Total Resp. Hours	Total Resp. Cost	No. of Resp.	Total Resp.
Hours	Total Resp. Cost	No. of Resp.	Total Resp. Hours	Total Respond.
Cost

Review instructions for new advisories	0.25	1.00	0.00	1.25	$47.28	$0.00
$0.00	92	115	$4,349.76	92	115	$4,349.76	92	115	$4,349.76

Gather advisory data including fish tissue data	1.00	6.25	2.00	9.25
$317.16	$0.00	$0.60	92	851	$29,234.29	92	851	$29,234.29	92	851
$29,234.29

Gather geographic information and mark maps	0.50	4.50	2.00	7.00	$231.13
$0.00	$5.00	92	644	$21,723.78	92	644	$21,723.78	92	644	$21,723.78

Enter advisory data electronically or via paper copy2	0.50	2.75	1.00
4.25	$145.80	$0.00	$0.00	92	391	$13,417.73	92	391	$13,417.73	92	391
$13,417.73

 	 	 	 	 	 	 	$0.50	9	 	 	9	 	 	9	 	 

Review instructions and questionnaire questions	0.50	2.63	0.00	3.13
$116.04	$0.00	$0.00	92	287.96	$10,675.72	92	287.96	$10,675.72	92	287.96
$10,675.72

Gather information for questionnaire	1.50	5.75	0.00	7.25	$275.16	$0.00
$0.00	92	667	$25,314.35	92	667	$25,314.35	92	667	$25,314.35

Enter answers to questionnaire electronically or on paper2	0.00	4.25
0.75	5.00	$164.16	$0.00	$0.00	92	460	$15,120.35	92	460	$15,120.35	92	460
$15,120.35

 	 	 	 	 	 	 	$2.00	9	 	 	9	 	 	9	 	 

Return maps, residue data, diskette, advisory information and
questionnaire by mail	0.00	1.38	0.25	1.63	$53.47	$0.00	$0.00	92	149.96
$4,919.10	92	149.96	$4,919.10	92	149.96	$4,919.10

Subtotals	4.25	28.51	6.00	38.76	$1,350.19	$0.00	$8.10	varies	3,565.92
$124,755.08	varies	3,565.92	$124,755.08	varies	3,565.92	$124,755.08

1	Labor cost includes a benefits/overhead multiplication factor of 1.6.

2	EPA estimates that 90 percent of the respondents will use the
electronic version of the NLFA survey and the State Fish Advisory
Program Questionnaire and will not have to perform this step.

6(c)	Estimating Agency Burden and Cost

Agency burden is estimated based on the assumption that 10 percent of
the labor hours per year for each activity will be work done by EPA and
90 percent of the labor hours per year will be work done by a
contractor. In addition, management oversight of work performed by
technical and clerical staff is estimated to require 20 percent of the
labor hours for each activity. 

Federal employee rates were obtained from the 2007 OPM General Schedule
(GS) Salary Table for the Washington, DC, area for the midpoint of each
salary grade (Available at the Web site
http://www.opm.gov/oca/07tables/pdf/dcb_h.pdf), and the following
categories were used:

Manager (GS 15)

$59.93/hour

Technical (GS 14)

$50.95/hour

Clerical (GS 7)

$20.44/hour



A benefits/overhead multiplication factor of 1.6 was used to obtain the
total labor cost for EPA.

No capital/startup costs are anticipated for the Agency.

O&M costs include costs of contractor services (including printing
survey materials and computer time) and outgoing and return postage for
each survey to return map(s) and/or survey and/or State Fish Advisory
Program Questionnaires each year.

One table is presented in this section (representing estimated costs for
each year of the ICR period) and the following resources and assumptions
were used to prepare the burden estimate for each activity:

Preparation of the mailing list and survey tracking database is
estimated based on initial assumptions that 92 potential respondents
nationwide will be sent the survey each year. Agency labor includes
identifying potential respondents and sources for contact information
(name, agency, address, phone number, fax number, and e-mail address)
and is estimated to take 0.04 hours per respondent. O&M costs include
contractor services to revise the mailing list and the survey and
questionnaire tracking database, and enter and verify contact
information, based on approximately 0.2 hours per respondent, with an
estimated rate of $80.00/hour (labor, overhead, and other direct costs).
Agency labor and contractor service estimates are based on an estimated
100 edits to the respondent contact names and addresses annually. It is
not likely that the number of respondents will change significantly
after the first year because all state, territorial, and Tribal
organizations will be identified and contacted for the first mailing.
Because the contact information will likely only need to be entered
once, the Agency labor and contractor services are divided by three to
provide an annualized estimate for the ICR.

To revise the existing 2006 survey package including the transmittal
letter, survey, instructions, and mapping procedures requires an
estimated number of Agency hours of 0.11 hours per respondent. Fixed O&M
costs include 40 contractor hours per year to modify survey materials.

Setting up a database for storing and analyzing the fish advisory
information collected and preparing the electronic data entry tool
option for collection of this information is already in place as part of
the NLFA database. Setting up a database for storing and analyzing the
survey responses and preparing the electronic data entry tool option for
collection of state fish advisory program data are in place. Agency
labor for this activity is estimated at 0.02 hours per respondent.
Fixed O&M costs include 80 contractor hours per year to modify the
survey database and electronic data entry tool options. 

Each year, the Agency will submit the survey materials to respondents.
(The materials to be submitted will include a request for information on
advisories that have been issued or revised during the preceding 12
months, map(s) and fish tissue residue data only need to be submitted
for the new advisories issued during the previous year, and the previous
year’s State Fish Advisory Program Questionnaire with the request that
responses be updated to reflect information that has changed during the
preceding calendar year. EPA’s oversight of this activity is estimated
to be 0.02 hours per respondent. Contractor services required to conduct
this activity include 0.25 hours per respondent per year to prepare the
materials and answer respondents’ questions about the survey. O&M
costs also include outgoing and return postage paid by the Agency ($2.00
per survey x 2 = $4.00 per year).

Survey operations include recording receipt of completed questionnaires
and marked map(s), electronic shape files/GIS coverages, and electronic
fish tissue residue files; sending e-mail reminders to nonrespondents
and making telephone contacts with nonrespondents and respondents in
situations where additional information is required for clarification,
if needed; e-mailing acknowledgment of materials that are received; and
reviewing survey materials for completeness and accuracy of responses.
EPA estimates that it will not be involved in these operations except
for minor oversight (0.02 hours per respondent per year). Contractor
services to perform these operations are based on 1 hour per respondent
per year.

EPA estimates that 10 percent of the respondents (9 respondents) may not
have Internet access, and therefore that information from the fish
advisory survey, State Fish Advisory Program Questionnaires, and maps
may need to be entered into the database manually (this activity is not
needed for electronic submissions as data entry is automatic). In
addition, fish tissue residue files from all states will have to be
reviewed and reformatted for uploading to the fish tissue database, and
all data entries (fish advisory, mapping, fish tissue residue data, and
State Fish Advisory Program Questionnaire responses) will have to be
reviewed and verified (including electronic submissions). EPA estimates
that it will not be involved in these operations except for minor
oversight (0.03 hours per respondent per year). Contractor services to
enter data for those respondents without Internet access (fish advisory
data and mapping information and completion of State Fish Advisory
Questionnaire), are expected to be 3 hours per respondent per year.
Information for respondents who choose the electronic option does not
need to be manually entered into the database, and therefore electronic
submissions are not reflected in the data entry costs for this task.
Contractor services to reformat fish tissue data files for all
respondents are expected to be 6 hours per respondent per year and
contractor services for reviewing/revising all fish advisory data,
mapping data, State Fish Advisory Program Questionnaires, and fish
tissue data are estimated to be 2 hours per respondent.

Data analysis of new and updated advisory information and state fish
advisory program information will be performed to obtain summary
statistics for inclusion in the Fish Advisory Fact Sheet and the annual
State Fish Advisory Program Summary Report, respectively. The Agency
will provide technical direction to a contractor to perform the analyses
and discuss and review the results, estimated at 0.06 hours per
respondent per year. Contractor services will require 0.5 hours per
respondent per year for analysis.

EPA will prepare a summary report of fish advisory information (Fish
Advisory Fact Sheet) and a summary report of information obtained from
the survey (State Fish Advisory Program Summary Report). EPA will
provide technical direction to a contractor to prepare both the fact
sheet and the summary report, including reviewing drafts and the final
fact sheet and report, which is estimated at 0.55 hours per respondent
per year. It is anticipated that the contractor will require 2 hours per
respondent per year to produce the fact sheet and summary report,
including a hard copy and an electronic version of each suitable for
posting on the NLFA Web site.

EPA will distribute the summary results of the NLFA database (Fish
Advisory Fact Sheet) in an electronic version that will be posted on the
NLFA Web site. EPA will distribute the summary results of the
questionnaire (State Fish Advisory Program Summary Report) in a paper
version (200 copies). EPA also will provide technical oversight of the
publication process, estimated at 0.05 hours per respondent per year.
Fixed O&M costs include estimated Government Printing Office costs of
$50 per paper report (approximately 500 pages) x 200 copies plus
postage of $4.30 per copy x 200 copies (total = $10,860). The Internet
version of the NLFA database containing the Fish Fact Sheet and the
updated fish advisory data will be designed so that the states,
territories, Tribes, and the general public can automatically view the
fish advisory information pertaining to the waterbody of interest. O&M
costs also include funds for contractor services to maintain the
database and perform troubleshooting, if needed, estimated at $5,000 per
year.

Table 2. Agency Burden and Cost

Information Collection Activity	Hours Burden and Cost (Year 1)	Total
Hours and Costs

	Mgr. Hours at $59.93/ Hour	Tech Hours at $50.95/ Hour	Clerical Hours at
$20.44/ Hour	Agency Hours/ Resp.	Labor Cost/Resp.	Capital/ Start-Up Cost
Fixed O&M Cost	Non_Fixed O&M Cost1	Number of Resp.	Total O&M (fixed and
non-fixed)	Total Agency Hours	Total Agency Cost

Prepare mailing list and survey tracking database	0.01	0.02	0.01	0.04
$2.92	$0.00 	$0.00 	$16.00 	92	$1,472.00 	3.68 	$1,740.30

Revise survey materials	0.01	0.1	0	0.11	$9.11	$0.00 	$3,200.00 	$0.00 
92	$3,200.00 	10.12 	$4,038.20

Set up database for storing and tracking questionnaire responses and
electronic options for answering the questionnaire	0.02	0	0	0.02	$1.92
$0.00 	$6,400.00 	$0.00 	92	$6,400.00 	1.84 	$6,576.43

Submit survey materials to respondents; answer respondents’ questions
0.01	0.01	0	0.02	$1.77	$0.00 	$0.00 	$24.00 	92	$2,208.00 	1.84 
$2,371.22

Record receipt of completed survey materials; perform follow-up and
quality control activities	0.01	0.01	0	0.02	$1.77	$0.00 	$0.00 	$80.00 
92	$7,360.00 	1.84 	$7,523.22

Enter information from survey materials into database, if needed2,
reformat tissue data and review/verify data entries	0	0.03	0	0.03	$2.45
$0.00 	$0.00 	$240.00 	9	$2,160.00 	2.76 	$61,062.01

 	 	 	 	 	 	 	 	$480.00 	92	$44,160.00 	 

	 	 	 	 	 	 	 	 	$160.00 	92	$14,720.00 	 

	Perform data analysis	0.01	0.05	0	0.06	$5.03	$0.00 	$0.00 	$40.00 	92
$3,680.00 	5.52 	$4,143.21

Prepare fact sheet and summary report of information obtained from the
survey	0.05	0.5	0	0.55	$45.55	$0.00 	$0.00 	$160.00 	92	$14,720.00 
50.60 	$18,911.00

Distribute results of the survey	0	0.05	0	0.05	$4.08	$0.00 	$15,860.00 
$0.00 	92	$15,860.00 	4.60 	$16,234.99

Store the advisory data, questionnaire responses and advisory location
data	0	0.03	0.03	0.06	$3.43	$0.00 	$1,000.00 	$0.00 	92	$1,000.00 	5.52 
$1,315.26

Subtotals	0.12	0.8	0.04	0.96	$78.03	$0.00 	$26,460.00 	$1,200.00 	Varies
$116,940.00 	88.32 	$123,915.84

1 	Includes costs of contractor services and postage.

2 	EPA estimates that 90 percent of respondents will use the electronic
version of the survey. The number of respondents was therefore reduced
by 90 percent for this step. Data entry may involve entering narrative
advisory and geographic information, reformatting fish tissue data, and
entering survey responses.

Data obtained from the NLFA survey, including mapping and fish tissue
residue data, and State Fish Advisory Program Questionnaire, will be
stored in appropriate media. EPA will provide technical oversight to
ensure that data storage meets its requirements and program objectives.
Labor is estimated at 0.06 hours per respondent per year. Fixed O&M
costs include an estimate for computer equipment maintenance for this
program of $1,000 per year.

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

The respondent universe for this ICR is calculated based on a total
number of 276 surveys to be completed during the 3-year ICR period for
an average of 92 respondents (representing fish advisory contacts from
50 states, District of Columbia, five U.S. territories and 36 Native
American Tribes). The number of respondents involved in each activity
varies because of the electronic option of logging in the advisory data
and completing the State Fish Advisory Program Questionnaire, which will
reduce respondent burden. It is anticipated that 90 percent of
respondents will exercise that option.

6(e)	Bottom Line Burden Hours and Cost Tables

(i)	Respondent Tally

Only one respondent table was prepared for this ICR.

Total Estimated Respondent Burden and Cost Summary

Technical and Financial Requirements	Number of Respondents	Number of
Activities	Total Hours	Total Labor Cost	Total Capital Costs	Total O&M
Costs	Total Costs

Year 1	92	8	3,565.92	$124,217.38	$0.00	$537.70	$124,755.08

Year 2	92	8	3,565.92	$124,217.38	$0.00	$537.70	$124,755.08

Year 3	92	8	3,565.92	$124,217.38	$0.00	$537.70	$124,755.08

TOTAL	276	24	10,697.76	$372,652.15	$0.00	$2,235.60	$374,265.24

AVERAGE	92	8	3,565.92	$124,217.38	$0.00	$537.70	$124,755.08



(ii)	The Agency Tally

The Agency and contractor tables are summarized in the following table.

Total Estimated Agency Burden and Cost Summary

Technical and Financial Requirements	Number of Respondents	Number of
Activities	Total Hours	Total Labor Cost	Total Capital Costs	Total O&M
Costs	Total Costs

Year 1	92	10	88.32	$6,975.84	$0.00	$116,940.00	$123,915.84

Year 2	92	10	88.32	$6,975.84	$0.00	$116,940.00	$123,915.84

Year 3	92	10	88.32	$6,975.84	$0.00	$116,940.00	$123,915.84

TOTAL	276	30	264.96	$20,927.52	$0.00	$350,820.00	$371,747.52

AVERAGE	92	10	88.32	$6,975.84	$0.00	$116,940.00	$123,915.84



(iii)	Variations in the Annual Bottom Line

No change in collection activities or burden and costs per respondent is
anticipated during the course of this ICR.	

6(f)	Reasons for Change in Burden

	There is a change in cost burden to remove $124,214 from that
identified in the ICR currently approved by OMB.  This is to correct a
mistake of including labor hours in the cost burden instead of just the
operations and maintenance costs of $538.

6(g)	Burden Statement

The annual public reporting and record keeping burden for this
collection of information is estimated to average 38.76 hours per
respondent. 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 Tribal or 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 requirement; 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. These numbers for EPA’s
regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on EPA’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,
it has established a public docket for this ICR under Docket ID No.
EPA-HQ-OW-2007-0201, which is available for online viewing at
www.regulations.gov, or in person viewing at the Water Docket in the EPA
Docket Center, EPA West, Room 3334, 1301 Constitution Avenue, NW,
Washington, DC 20460. The EPA Docket Center Public Reading Room is open
from 8 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. You may
submit your comments, referencing Docket ID No. EPA-HQ-OW-2007-0201,  to
(1) EPA online using www.regulations.gov (our preferred method), by
email to OW-Docket@epa.gov, or by mail to: Environmental Protection
Agency, EPA Docket Center, Water Docket (2822T), 1200 Pennsylvania Ave.,
NW, Washington, DC 20460, and (2) OMB by mail to: Office of Information
and Regulatory Affairs, Office of Management and Budget (OMB),
Attention: Desk Officer for EPA, 725 17th Street, NW, Washington, DC
20503.

Information Collection Request

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Information Collection Request

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