                      Information Collection Request for
                 Water Quality Standards Regulation (Renewal)

	

	
                                   May 2018 
                                    (Draft)


                                       


                            EPA ICR Number 0988.13
                         OMB Control Number 2040-0049







                     U.S. Environmental Protection Agency
                                Office of Water
                       Office of Science and Technology
                         1200 Pennsylvania Avenue, NW
                            Washington, D.C. 20460


Contents

1.	Identification of the Information Collection	4
1.1	Title of the Information Collection	4
1.2	Short Characterization/Abstract	4
2.	Need for and Use of the Collection	6
2.1	Need and Authority for the Collection	6
2.2	Practical Utility/Users of the Data	9
3.	Non-Duplication, Consultations, and Other Collection Criteria	11
3.1	Non-Duplication	11
3.2	Public Notice Required Prior to ICR Submission to OMB	11
3.3	Consultations	11
3.4	Effects of Less Frequent Collection	12
3.5	General Guidelines	13
3.6	Confidentiality and Sensitive Questions	13
4.	The Respondents and the Information Requested	14
4.1	Respondents/NAICS Codes	14
4.2	Information Requested	15
4.3	Respondent Activities	19
5.	The Information Collected  -  Agency Activities, Collection Methodology, and Information Management	20
5.1	Agency Activities	20
5.2	Collection Methodology and Management	20
5.3	Small Entity Flexibility	21
5.3.1	Indian Tribes	21
5.3.2	Small Dischargers	22
5.4	Collection Schedule	22
6.	Estimating the Burden and Cost of the Collection	23
6.1	Estimating Respondent Burden and Costs	23
6.2	Estimating Agency Burden and Cost	31
6.3	Reasons for Change in Respondent Burden	32
6.4	Burden Statement	33
7.	Summary Tables	34
Table 1:  Total annual burden and cost for states, tribes and dischargers	34
Table 2:  Total agency burden and cost	37
Table 3:  Change in Respondent Burden	38

Identification of the Information Collection
Title of the Information Collection
The title of this Information Collection Request (ICR) is Water Quality Standards Regulation (Renewal).
Short Characterization/Abstract
Water quality standards (WQS) are provisions of state, tribal, or federal law which consist of designated uses for waters of the United States, water quality criteria to protect those uses, and antidegradation requirements. WQS are established to protect public health or welfare, protect and enhance the quality of water, and serve the purposes of the Clean Water Act. Such standards serve the dual purposes of establishing the water quality goals for water bodies, and serving as a regulatory basis for establishing water quality-based treatment controls and strategies beyond technology-based treatment required by sections 301 and 306 of the Act.
The WQS Regulation establishes the framework for states and authorized tribes to adopt standards, and for the EPA to review and approve or disapprove them. For the purposes of this ICR, the Regulation consists of 40 CFR part 131 (Water Quality Standards), and the portions of 40 CFR part 132 (Water Quality Guidance for the Great Lakes System) that are related to WQS. This ICR is for information collections needed to implement the WQS Regulation and required to obtain or retain benefits (e.g., relaxed regulatory requirements) under the Regulation. 
This ICR renews the WQS Regulation ICR, OMB control no. 2040-0049, expiration date 6/30/2019, and consolidates the burden and costs associated with activities previously reported in two related ICRs, which upon OMB approval will be discontinued as separate ICRs: 
 WQS Regulatory Revisions ICR, OMB control no. 2040-0286, expiration date 12/31/2018; and, 
 Revised Interpretation of Clean Water Act Tribal Provision ICR, OMB control no. 2040-0289, expiration date 7/31/2019.
This consolidated ICR includes the following information collection activities: 
   (A) WQS Adoption, Review, and Revision (WQS Base Program) (from original ICR 2040-0049) 
   (B) Specific WQS Regulation Requirements (consolidated from ICR 2040-0286)
 Rulemaking
 Designated Uses: Identifying the Highest Attainable Use
 Triennial Review: Criteria Explanations
 Antidegradation: Implementation Methods
 Antidegradation: Tier 2 Waters Designations
 Antidegradation: Alternatives Analyses
 Antidegradation: Additional Tier 2 Reviews
 WQS Variances: Submission Requirements
 WQS Variances: Reevaluations
   (C) Great Lakes WQS Requirements (from original ICR 2040-0049)
 Great Lakes Bioassay Tests
 Great Lakes Antidegradation Demonstrations
 Great Lakes Regulatory Relief Requests
   (D) Tribal-Related Dispute Resolution Requests and TAS Applications 
 Dispute Resolution Requests (from original ICR 2040-0049)
 Tribal Applications for TAS (from original ICR 2040-0049, updated by consolidation from ICR 2040-0289)
   (E) Periodic Requests for WQS Program Information (new in this ICR)
  




Need for and Use of the Collection
Need and Authority for the Collection
This section describes the need and authority for the collections of information described in this ICR. Table 1 summarizes the collections and authorities.
(A) WQS Adoption, Review, and Revision (WQS Base Program) 
Authorities: Section 303(c) of the Clean Water Act (CWA or "the Act"), 33 U.S.C. 1313(c); 40 CFR part 131, especially §§ 131.5, 131.6, 131.20 - 131.22.
The CWA under section 303(c) and the EPA's WQS Regulation under 40 CFR parts 131 and 132 govern the WQS program. They require states and authorized tribes to review and, as appropriate, revise their WQS (or adopt new standards) at least once every three years, and to submit to the EPA the results and WQS revisions or new standards resulting from the reviews. The Agency then reviews each state or tribal submission for approval or disapproval. Once approved by the EPA, the standards become applicable for all purposes under the Act.
Specifically, 40 CFR 131.20 establishes the requirement for state or tribal review and revision of WQS. 40 CFR 131.6 establishes the minimum requirements for states and authorized tribes to submit new and revised WQS and supporting materials to the Agency for review and approval or disapproval. 40 CFR 131.5 prescribes the EPA's review of such submissions. The EPA must review these materials to determine: (a) whether the state or tribe has adopted designated water uses which are consistent with the requirements of the Clean Water Act; (b) whether the state or tribe has adopted criteria that protect the designated water uses based on sound scientific rationale consistent with the regulation; (c) whether the state or tribe has adopted an antidegradation policy consistent with the regulation and whether any adopted antidegradation implementation methods are consistent with the regulation; (d) whether any adopted WQS variance is consistent with the regulation; (e) whether any adopted provision authorizing the use of schedules of compliance for water quality-based effluent limits in NPDES permits is consistent with the regulation; (f) whether the state or tribe has followed applicable legal procedures for revising or adopting standards; (g) whether state or tribal WQS which do not include the uses specified in section 101(a)(2) of the Act are based on appropriate technical and scientific data and analyses; and, (h) whether the state or tribal submission meets the requirements included in § 131.6, and, for Great Lakes states or tribes, the requirements of 40 CFR part 132. This information collection will ensure that the EPA has the needed information to review WQS as required to make approvals or disapprovals, and to make Administrator determinations that new or revised WQS are necessary.
(B) Specific WQS Regulation Requirements
Authorities: 40 CFR part 131, especially §§ 131.10, 131.12, 131.14, 131.15, and 131.20
In 2015, the EPA revised 40 CFR part 131 to clarify certain specific requirements of the WQS Regulation. This ICR incorporates potential additional information collections by states and authorized tribes to implement a number of requirements, including: 
      (1) rulemaking activities to modify antidegradation requirements, revise any adopted requirements governing the issuance of WQS variances, or adopting provisions authorizing the use of permit compliance schedules; 
      (2) identifying and adopting the highest attainable use (HAU) whenever adopting new or revised WQS based on a required use attainability analysis, and submitting "use and value demonstrations" when removing designated uses not specified in CWA section 101(a)(2);
      (3) providing an explanation for why the state or authorized tribe is not adopting new or revised criteria for parameters for which the EPA published new or updated CWA section 304(a) criteria recommendations; 
      (4) involving the public when developing or revising antidegradation implementation methods; 
      (5) involving the public when a state or authorized tribe uses the water body-by-water body approach to identify waters receiving Tier 2 antidegradation protection; 
      (6) performing/evaluating more extensive Tier 2 antidegradation reviews because they now must evaluate a range of non-degrading and less degrading practicable alternatives; 
      (7) performing/evaluating more Tier 2 antidegradation reviews because more water bodies may be receiving Tier 2 protection pursuant to new requirements for designating Tier 2 waters on a water body-by-water body basis;  
      (8) additional documentation of WQS variances; and, 
      (9) reevaluating WQS variances with a term longer than five years no less frequently than every five years. 
States and authorized tribes that do not currently meet these requirements may need to begin doing so, thus increasing the information submitted to the EPA. These information collections will ensure that the EPA has the needed information to review WQS as required to make approvals or disapprovals, and to make Administrator determinations that new or revised WQS are necessary.
(C) Great Lakes WQS Requirements
Authorities: 40 CFR part 132, especially §§ 132.1 - 132.5, and Appendices A  -  E, and procedures 1 and 2 of Appendix F.
Special WQS requirements for waters of the Great Lakes system were enacted in the Great Lakes Critical Programs Act of 1990, and are specified in 40 CFR part 132 (Water Quality Guidance for the Great Lakes System). States and authorized tribes in the Great Lakes basin must establish certain water quality criteria, implementation procedures, and antidegradation provisions that are as protective as the requirements in 40 CFR part 132. The information collections in this ICR consist of three activities that water dischargers may initiate in accordance with 40 part 132 provisions to obtain or maintain benefits in the form of relaxed regulatory requirements:
      (1) Great Lakes bioassay tests to enable states and tribes to develop site-specific water quality criteria and values; 
      (2) Great Lakes antidegradation demonstrations to enable states and tribes to approve certain discharger activities that would lower water quality in high quality waters; and 
      (3) Great Lakes regulatory relief requests, such as modifications to water quality criteria, or discharge variances from WQS.
(D)Tribal-Related Dispute Resolution Requests and TAS Applications
Authorities: CWA section 518(e) and 40 CFR part 131, §§ 131.7 and 131.8.
      (1) 40 CFR 131.7 establishes a mechanism in for resolution of disputes which arise between states and tribes over differing WQS on common bodies of water. Where an authorized tribe or state desires a formal EPA dispute resolution action, an information collection is necessary to enable the EPA to fulfill its responsibilities under CWA section 518(e) in a reasonable and timely manner. The state or tribe's request constitutes an information collection to obtain a benefit. 
      (2) 40 CFR 131.8 specifies requirements for Indian tribes to administer a WQS program. To be found eligible, a tribe must apply to the EPA to be treated in a similar manner as a state (TAS) and demonstrate that it meets certain criteria. The tribe's application constitutes an information collection to obtain a benefit. 
(E) Periodic Requests for WQS Program Information
Authorities: Ensuring effective and efficient administration of the WQS program. 
From time to time, the EPA may request states and tribes to provide information voluntarily that would assist in administering state, tribal, regional and national WQS programs effectively and efficiently, and further cooperative federalism. For example, the Agency may request technical information to assist in developing guidance or other materials; technical comments on draft program-related policies and guidance documents; and information concerning program operations to assist in information sharing and improving program efficiency. The Agency may also invite state and tribal participation in program-related work groups. Submission of state or tribal information and participation by states and tribes in workgroups is voluntary. 
Practical Utility/Users of the Data
        (A) WQS Adoption, Review, and Revision (Base Program)
        (B) Specific WQS Regulation Requirements
The EPA will use the information collected under (A) WQS Base Program and (B) Specific WQS Regulation Requirements of this ICR to carry out its oversight responsibilities under the CWA and the WQS Regulation. Specifically, 40 CFR 131.21 requires the Agency to review any state or tribal submissions of new or revised WQS, and all supporting materials, and to approve or disapprove the WQS. The decision criteria for approving or disapproving the submitted WQS are specified in the WQS Regulation, including 40 CFR 131.5, as described in section 2.1 above, and 40 CFR 131.6.
Once approved by the EPA, state and authorized tribal WQS generally become effective for all CWA purposes.  WQS serve as the basis for water quality-based effluent limitations in National Pollutant Discharge Elimination System (NPDES) permits for point source dischargers (including publicly-owned treatment works and industrial facilities) under sections 301(b)(1)(C) and 402 of the Act. In addition, under CWA section 303(d), states and authorized tribes must identify which waters are not meeting their WQS. For waters identified under section 303(d), WQS serve as the basis for establishing total maximum daily loads (TMDLs). WQS are also used as the basis to protect wetlands and other aquatic resources by providing states and authorized tribes an opportunity to address the aquatic resource impacts of federally issued permits and licenses under section 401 of the Act.  
If new or revised WQS adopted by states or tribes are not approved by the EPA, they do not become effective for CWA purposes. Thus, if the information collection activities in this ICR are not performed, it would be difficult for the Agency to review the WQS, and the state or tribal WQS would likely not go into effect and could not serve as the basis for CWA regulatory actions to restore and maintain water quality. 
(C) Great Lakes WQS Requirements
Great Lakes states and authorized tribes and the EPA will use the information collected under (C) Great Lakes WQS Requirements, to help determine whether to approve requests for regulatory relief and certain changes in WQS requested by Great Lakes dischargers under provisions of 40 CFR part 132. Specifically, the information will assist states, tribes, and the EPA in: (1) reviewing and approving or disapproving changes in water quality criteria supported by bioassay tests; (2) making antidegradation decisions which determine whether an activity a discharger is about to undertake will be allowed, even though it may lower high water quality; and (3) reviewing whether to grant discharger requests for certain types of regulatory relief. The Agency could not make such decisions without the information collected.
(D) Tribal-Related Dispute Resolution Requests and TAS Applications
The EPA will use information collected under (D) Tribal-Related Dispute Resolution Requests and TAS Applications to determine whether to initiate the dispute resolution mechanism in 40 CFR 131.7 to resolve disputes between states and authorized tribes that may arise as a result of differing EPA-approved water quality standards on common bodies of water, and whether to find an applicant tribe eligible for TAS to administer the WQS program under 40 CFR 131.8. The Agency could not make such decisions without the information collected.

(E) Periodic Requests for WQS Program Information
The EPA will use state and tribal information provided voluntarily under (E) Periodic Requests for WQS Program Information to advance cooperative federalism. This includes developing guidance or other materials to help make program-related policies and guidance documents useful and technically accurate; to facilitate sharing of information; and to improve program efficiency.
Non-Duplication, Consultations, and Other Collection Criteria
Non-Duplication
The information collection requirements described in this ICR do not duplicate the information collection requirements described in other EPA ICRs. 
Two collections  -  (C)(2) Great Lakes Antidegradation Demonstrations and (C)(3) Great Lakes Regulatory Relief Requests  -  appear in both this ICR (WQS Regulation) and a separate ICR (NPDES Program), OMB Control Number 2040-0004. This ICR covers the WQS portion of the collections, and the NPDES Program ICR covers the NPDES portion of the collections.
Public Notice Required Prior to ICR Submission to OMB
The EPA is publishing a Federal Register notice to solicit comments and information to enable it to (1) evaluate whether the proposed collection of information in this proposed ICR is necessary and will have practical utility; (2) evaluate the accuracy of the Agency's estimate of the burden estimates and the validity of the methodology and assumptions used; (3) enhance the quality, utility, and clarity of the information to be collected; and, (4) minimize the burden of the collection of information on those who are to respond. The Agency will consider the comments received and amend the proposed ICR as appropriate. See section 6.4 for instructions on providing comments on this ICR.
Consultations
The EPA has consulted with states, tribes, and stakeholders continually on all aspects of the WQS program, including information collection, since the inception of the Clean Water Act, and particularly since the WQS Regulation was finalized in 1983. The consultations most relevant to this ICR are as follows: 
During the initiation of the program, the Agency consulted with 11 states to develop burden estimates for the purposes of the WQS Regulation ICR. The 11 states represented various geographical areas, differing levels of water quality management activities, and differing approaches to controlling priority toxic pollutants for consultation. The results of this consultation are discussed in section 6.1 under (A) Standards Adoption, Review, and Revision.
The EPA also consulted with states, tribes, dischargers, and the public in the Great Lakes area to develop the final 1995 rule, Water Quality Guidance for the Guidance System, now codified as 40 CFR part 132. In developing the ICR for the final rule, the Agency relied on these consultations to help develop burden estimates for the rule's provisions. The resulting burden estimates are discussed in section 6.1 under (C) Great Lakes WQS Requirements.
In March 2014, the EPA consulted with seven states to gather input regarding burden estimates related to the WQS base program and the anticipated requirements under WQS Regulatory Revision rule that the Agency later finalized in 2015. The resulting burden estimates are discussed in section 6.1 under (B) Specific WQS Regulation Requirements. 
In July 2014, the EPA consulted with eight tribes with experience in applying for TAS for the WQS program regarding anticipated burden reductions under the interpretive rule, Interpretation of Clean Water Act Tribal Provision, that the Agency later finalized in 2016. Information from these tribes was used in developing the burden estimates that appear in section 6.1 under (D)(2) Tribal Applications for TAS.
In 2014, the EPA and the states recognized that (a) some of the estimates for the WQS base program likely required updating, and (b) that simply adding the burden estimates for implementing the WQS Regulatory Revision Rule to the burden for the WQS base program might not reflect the burden that would result after integrating and optimizing the new and existing activities. Thus, the states preferred that the EPA wait until the revisions to 40 CFR part 131 regulations were proposed, finalized and implemented before consulting in-depth with states to update burden estimates for the WQS program as a whole. As of 2018, states and tribes continue to be in the early stages of implementing the 2015 regulation revisions and the 2016 interpretive rule, with progress varying from state to state and tribe to tribe. Therefore, the EPA is renewing this ICR with the recognition that the burden estimates herein are the best available estimates at this time, and that consultations will continue with states and tribes on adjusting the estimates and finding ways to minimize reporting burden.
Effects of Less Frequent Collection
        (A) WQS Adoption, Review, and Revision (WQS Base Program)
        (B)(2) Designated Uses: Identifying the Highest Attainable Use
        (B)(3) Triennial Review: Criteria Explanations
        (B)(4) Antidegradation: Implementation Methods
The reporting frequency of the above four collections (see section 4 for descriptions of all information collection categories) is generally established by statute in CWA section 303(c), which requires states and authorized tribes to hold public hearings from time to time (but at least once every three year period) for the purpose of reviewing applicable WQS, and, as appropriate, modifying and adopting standards. Results of such reviews shall be made available to the Administrator. This triennial frequency is not adjustable by the EPA. States and authorized tribes may schedule more frequent WQS reviews than required at their discretion. 
(B)(1) Rulemaking
        (B)(5) Antidegradation: Tier 2 Waters Designations
These two collections are one-time activities triggered by the final rule, Water Quality Standards Revisions, published in 2015.
(B)(6) Antidegradation: Alternatives Analyses
        (B)(7) Antidegradation: Additional Tier 2 Reviews
        (B)(8) WQS Variances: Submission Requirements
        (B)(9) WQS Variances: Reevaluations
        (C)(1) Great Lakes Bioassay Tests
        (C)(2) Great Lakes Antidegradation Demonstrations
        (C)(3) Great Lakes Regulatory Relief Requests
        (D)(1) Dispute Resolution Requests 
        (D)(2) Tribal Applications for TAS
These nine collections are for one-time activities that are primarily driven by initiatives to obtain or retain benefits pursuant to the WQS Regulation. The EPA has no control over the frequency of these collections. 
(E) Periodic Requests for WQS Program Information
For this collection, the EPA's practice is to limit the number of periodic requests for WQS program information from states and authorized tribes as much as possible. Such requests are generally cleared by EPA senior managers before being initiated. The Agency often coordinates in advance with state and tribal associations to determine the nature and timing of such requests. Additionally, the EPA has been working with states and authorized tribes to ensure that the operation of the WQS Program uses a cooperative federalism approach. As such, the Agency offers states and tribes the opportunity to participate in workgroups to provide accurate information regarding implications of implementing potential technical approaches or policy directions. In all cases, states' and tribes' submission of information and participation in workgroups is voluntary. 
General Guidelines
The EPA reviewed this ICR for compliance with OMB's information collection guidelines in 5 CFR 1320.5(d)(2) and concludes it is in compliance.
Confidentiality and Sensitive Questions
State and authorized tribal submissions to the EPA under this ICR will contain no confidential or sensitive information. 
Most information from dischargers will contain no confidential or sensitive information. In some cases, however, dischargers may elect to submit confidential business information to help support antidegradation alternatives analyses, designated use revisions, and WQS variances. If this is the case, the discharger may request that such information be treated as confidential. All confidential data will be handled in accordance with 40 CFR 122.7 and the EPA's Security Manual Part III, chapter 9, dated August 9, 1976. 
The Respondents and the Information Requested
This section describes the respondents for this ICR and the information that the EPA will collect.
Respondents/NAICS Codes
The following describes the universe of potential respondents. The actual numbers estimated to submit information annually are described in section 6.
"States" described as respondents in this ICR refers to the 50 states, the District of Columbia, and five territories (i.e., 56 "states").
"States and authorized tribes" refers to the 56 states and any federally-recognized Indian tribes that have EPA-approved WQS. As of May 2018, there were 44 such tribes, making a total of 100 "states and authorized tribes."  
"Great Lakes states and tribes" refers to the states of Illinois, Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania, and Wisconsin, and tribes that have adopted EPA-approved WQS for waters of the Great Lakes system (five tribes to date). These respondents are in NAICS code 92411 "Administration of Air and Water Resources and Solid Waste Management Programs," formerly SIC code #9511.
Any of over 300 federally recognized tribes with a reservation could potentially apply for TAS to administer a WQS program under collection (D)(2) Tribal Applications for TAS if they have not already been found eligible. As of May 2018, 58 applicant tribes have been found eligible for TAS to administer a WQS program. The respondents affected by this collection activity are in NAICS code 92411 "Administration of Air and Water Resources and Solid Waste Management Programs." 
Any Indian tribes with EPA-approved WQS, or the states that share common water bodies with such tribes, can potentially submit dispute resolution requests under collection (D)(1) Dispute Resolution Requests. The respondents affected by this collection activity are in NAICS code 92411 "Administration of Air and Water Resources and Solid Waste Management Programs."
The potential "Discharger" respondents affected by elements of this ICR under (C) Great Lakes WQS Requirements include the following NAICS codes: Mining (except oil and gas) (212), Food manufacturing (311), Paper manufacturing (322), Chemical manufacturing (325), Petroleum refineries (32411), Primary metal manufacturing (331), Fabricated metal product manufacturing (332), Machinery manufacturing (333), Computer and electronic product manufacturing (334), Electrical equipment, appliance, and component manufacturing (335), Transportation equipment manufacturing (336), Electric power generation, transmission, and distribution (2211), and Sewage treatment facilities (22132).
Information Requested
(A) WQS Adoption, Review, and Revision (WQS Base program)
40 CFR 131.20 requires that whenever a state or authorized tribe adopts new or revised WQS, it must submit the WQS to the EPA for review and approval. 40 CFR 131.6 of the WQS Regulation establishes the following minimum requirements for a WQS submission, in addition to the new or revised WQS themselves: 
 Use designations consistent with sections 101(a)(2) and 303(c)(2) of the Act; 
 Methods used and analyses conducted to support WQS revisions; 
 Water quality criteria sufficient to protect the designated uses; 
 An antidegradation policy consistent with 40 CFR 131.12; 
 Certification by the state or tribal Attorney General or other appropriate legal authority within the state or tribe that the WQS were duly adopted pursuant to state or tribal law; and,
 General information which will aid the EPA in determining the adequacy of the scientific basis of the standards which do not include the uses specified in section 101(a)(2) of the Act as well as information on general policies applicable to state standards which may affect their application and implementation.
40 CFR 131.20 of the WQS Regulation requires states and authorized tribes to review applicable WQS  -  those adopted into state or tribal law pursuant to the WQS Regulation as well as federally promulgated WQS  -  at least once every three years and submit the following information to the EPA:
 The results of the review;
 Any supporting analysis for the use attainability analysis;
 The methodologies used for site-specific criteria development;
 Any general policies applicable to WQS;
 Any revisions of the WQS; and, 
 An explanation for not adopting new or revised criteria for parameters for which the EPA published new or updated CWA section 304(a) national recommended water quality criteria (see (B)(3) Triennial Review: Water Quality Criteria Explanations below). 
        (B) Specific WQS Regulation Requirements
(B)(1) Rulemaking
The 2015 WQS Regulation Revisions final rule may potentially require states and authorized tribes to perform a WQS rulemaking to modify antidegradation requirements, revise any adopted requirements governing the issuance of WQS variances, or adopt provisions authorizing the use of permit compliance schedules. Such provisions are WQS subject to EPA review and approval. States and authorized tribes must submit such provisions to the Agency.
(B)(2) Designated Uses: Identifying the Highest Attainable Use
The 2015 WQS Regulation Revisions final rule requires states and authorized tribes to adopt the highest attainable use (HAU) whenever adopting new or revised WQS based on a required use attainability analysis (UAA). Additionally, the regulation requires states and authorized tribes to submit a "use and value demonstration" when removing non-101(a)(2) uses, but this requirement may be satisfied with a UAA. Consequently, the rule may require some states and authorized tribes to modify their designated use revision process to include identification and adoption of the HAU, thus increasing the information submitted to the EPA. 
(B)(3) Triennial Review: Criteria Explanations
As noted above, the WQS Regulation requires states and authorized tribes to review applicable WQS at least once every three years. The 2015 WQS Regulatory Revisions final rule, added a requirement to 40 CFR 131.20 of the WQS Regulation for states and authorized tribes to provide an explanation if they are not adopting new or revised criteria for parameters for which the EPA published new or updated CWA section 304(a) national recommended water quality criteria, thus increasing the information submitted to the Agency.
(B)(4) Antidegradation: Implementation Methods
        (B)(5) Antidegradation: Tier 2 Waters Designations
        (B)(6) Antidegradation: Alternatives Analyses
        (B)(7) Antidegradation: Additional Tier 2 Reviews
The 2015 WQS Regulatory Revisions final rule requires states and authorized tribes not to exclude water bodies from Tier 2 antidegradation protection solely because water quality does not exceed levels necessary to support all of the uses specified in CWA section 101(a)(2). The Regulation also provides that before allowing a lowering of high water quality, states and authorized tribes must evaluate a range of non-degrading and less degrading practicable alternatives. Furthermore, the 2015 final rule specifies that, where states and authorized tribes identify waters to receive Tier 2 protection on a water body-by-water body basis, states and authorized tribes must involve the public on any decisions pertaining to when they will provide Tier 2 protection, and the factors considered in such decisions. Finally, the Regulation requires states' and authorized tribes' antidegradation implementation methods to be consistent with these requirements, and provide an opportunity for public involvement during the development and any subsequent revisions of antidegradation implementation methods. These requirements could potentially result in incremental information collection associated with the following activities:
 Involving the public when developing or revising antidegradation implementation methods;
 Involving the public when a state or authorized tribe uses the water body-by-water body approach to identify waters receiving Tier 2 antidegradation protection;
 Performing/evaluating more extensive Tier 2 antidegradation reviews because they now must evaluate a range of non-degrading and less degrading practicable alternatives; and,
 Performing/evaluating more Tier 2 antidegradation reviews because more water bodies may be receiving Tier 2 protection.
(B)(8) WQS Variances: Submission Requirements
        (B)(9) WQS Variances: Reevaluations
The 2015 WQS Regulation Revisions final rule provided more specificity and clearer submission requirements for the development and use of WQS variances. Most of the revisions specify or clarify when and how WQS variances should be used, and thus are unlikely to result in significant incremental administrative burden and cost to states and authorized tribes. However, two revisions potentially result in increased information collection:
 Specification of the documentation that states and authorized tribes must submit to the EPA when requesting EPA review and approval of a WQS variance; and,
 Requirement that states and authorized tribes reevaluate WQS variances with a term longer than five years no less frequently than every five years and to submit the results of those reevaluations to the EPA. 
(C) Great Lakes WQS Requirements
(C)(1) Great Lakes Bioassay Tests
40 CFR 132.3 of the WQS Regulation specifies that Great Lakes states and tribes must adopt certain water quality criteria published by the EPA, or criteria that they develop using methodologies published by the EPA. Dischargers may choose to conduct bioassay tests or other studies to assist the states and tribes in developing such criteria. Any bioassay tests or other studies must conform to the methodologies in Appendices A, B, C, and D of 40 CFR part 132. 
(C)(2) Great Lakes Antidegradation Demonstrations
Appendix E to 40 CFR part 132 of the Regulation specifies that any entity seeking to lower water quality in a high-quality water of the Great Lakes system, or proposing a new or increased discharge to Outstanding International Resource Waters (OIRWs) of the Lake Superior Basin, must submit an antidegradation demonstration to the NPDES permitting authority (normally the state or the EPA). The Regulation specifies that the demonstration include:
 A pollution prevention alternatives analysis;
 An alternative or enhanced treatment analysis; and
 An important social or economic development analysis.
Appendix E to 40 CFR part 132 contains additional requirements where OIRWs or certain remedial actions are involved. 
(C)(3) Great Lakes Regulatory Relief Requests
Appendix F to 40 CFR part 132 of the Regulation specifies at least two ways that the Great Lakes WQS adopted pursuant to 40 CFR part 132 may be modified to provide regulatory relief: site-specific modifications to criteria and values (Procedure 1), and variances from WQS (Procedure 2). 
Dischargers seeking site-specific water quality criteria modifications would need to provide data to the state or tribe in accordance the methodologies in Appendices A, B, C, and D to 40 CFR part 132. 
Point source dischargers seeking variances from WQS would need to submit an application to the state or tribe that includes information demonstrating that attaining the standards is not feasible based on one or more of six specified factors, including natural conditions, human-caused conditions that cannot be remedied, certain hydrologic modifications, or controls that would result in substantial and widespread economic and social impact.
(D)(1) Dispute Resolution Requests 
40 CFR 131.7 of the WQS Regulation specifies that an authorized tribe or state interested in having the EPA initiate a formal dispute resolution action must submit a written request to the lead EPA Regional Administrator. Information that a state or tribe must submit with the request includes: 
 A concise statement of the unreasonable consequences that are alleged to have arisen because of differing WQS; 
 A concise description of the actions which have been taken to resolve the dispute without EPA involvement; 
 A concise indication of the state/tribal WQS provision which has resulted in the unreasonable consequences;
 Factual data to support the alleged unreasonable consequences; and,
 A statement of the relief sought from the alleged unreasonable consequences. 
(D)(2) Tribal Applications for TAS
40 CFR 131.8(b) of the WQS Regulation specifies the information a tribe must provide in its program application for TAS. Specifically, an interested tribe must submit:
 A statement that the tribe is recognized by the Secretary of the Interior; 
 A descriptive statement demonstrating that the tribal governing body is currently carrying out substantial governmental duties and powers over a defined area; 
 A descriptive statement of the Indian tribe's authority to regulate water quality, and an identification of the surface waters for which the tribe proposes to establish WQS; 
 A narrative statement describing the capability of the Indian tribe to administer an effective WQS program; and, 
 Any additional documentation required by the Regional Administrator, which in the judgment of the Regional Administrator, is necessary to support the application. 
Approvals for tribes to administer standards programs are valid unless rescinded. Therefore, an interested tribe normally needs to apply only once. Where a tribe has previously qualified for TAS under another program, the tribe need only provide the required information which has not been submitted in a previous application.
(E) Periodic Requests for WQS Program Information
Under this collection, states and tribes may provide information to the EPA voluntarily that would assist the Agency in administering regional and national WQS programs effectively and efficiently, and further cooperative federalism. For example, the EPA may request technical information to assist in developing guidance or other materials; technical comments on draft program-related policies and guidance documents; and information concerning program operations to assist in information sharing and improving program efficiency. The EPA may also invite state and tribal participation in program-related work groups. Submission of state or tribal information or participation by state and tribes in workgroups is voluntary.
Respondent Activities
The EPA identified the following activities respondents may need to undertake under this ICR:
 Reviewing instructions, guidance, and regulations necessary for each collection; 
 Planning of information collection activities, including identifying required analyses, gathering and analyzing existing water quality data, effluent data, and waterbody use information as needed; 
 Generating, gathering, and organizing information needed for each collection; 
 Planning for and conducting public hearings required by the Regulation for triennial reviews and/or proposing and adopting new or revised WQS; 
 Conducting public outreach and obtaining public input where appropriate. Includes issuing public notices, managing information for the public on websites, soliciting comments, and documenting, reviewing, and responding to comments;
 Preparing submissions to the EPA, including assembling all materials and, where required, obtaining attorney general certifications that WQS have been adopted according to state or tribal law and the EPA's requirements;
 Organizing and implementing recordkeeping as required; and,
 Providing voluntary information in response to requests, providing voluntary technical comments on draft policies and guidance documents, and participating voluntarily in workgroups on WQS program implementation. 

The Information Collected  -  Agency Activities, Collection Methodology, and Information Management
Agency Activities
The EPA conducts a full range of activities associated with this ICR, including the following.
 Assembling relevant information to conduct the EPA review of new or revised WQS submitted by states and authorized tribes;
 Reviewing new or revised WQS standards for consistency with the CWA and the WQS Regulation; 
 Preparing and sending a letter to the state or tribe conveying the EPA's approval or disapproval decision(s);
 Making any Administrator determinations that federal WQS are necessary;
 Proposing and promulgating federal standards where state or tribal WQS are disapproved or where the Administrator has determined that federal WQS are necessary;
 Proposing and finalizing the withdrawal of federal standards when a state or tribe adopts corresponding WQS that the EPA has approved;
 Notifying appropriate governmental entities and others, where appropriate, that a tribe has applied for TAS, and providing an opportunity for them to comment on the tribe's assertion of authority; 
 Evaluating the tribe's TAS application and relevant comments to determine whether the tribe meets statutory and regulatory criteria for TAS eligibility, and notifying the tribe if the application is approved; and,
 Reviewing requests for EPA assistance to resolve disputes regarding differing state and tribal WQS on common bodies of water. Managing the dispute resolution process where the Agency determines that an EPA dispute resolution action under 40 CFR 131.7 is justified. 
See also section 2.2, Practical Utility/Users of the Data. 
Activities related to, but not included in, this ICR include revising the WQS Regulation as needed; developing policies, guidance, and technical resources for states and tribes; developing national recommended water quality criteria; assisting states and tribes in interpreting and implementing regulations, policies and initiatives; and, coordinating activities related to standards with other CWA programs and with other federal agencies. The EPA's website, Water Quality Standards: Regulations and Resources, provides more information. See https://www.epa.gov/wqs-tech.
Collection Methodology and Management
States and authorized tribes submit their new and revised WQS to the appropriate EPA regional office. Likewise, tribes applying for TAS, and states or tribes requesting dispute resolution, submit their requests to the EPA regional office. Responsibility for EPA decisions on WQS, TAS applications, and dispute resolution requests has been delegated to Regional Administrators, or in some cases, redelegated to officials designated by the Regional Administrator. 
The WQS staffs in EPA regional offices work closely with states and authorized tribes on WQS issues, and are available to review and offer comments on draft proposed and final WQS submissions. EPA headquarters provides support to the regional offices in the review of these submissions. 
The EPA posts approved WQS adopted by states and authorized tribes, and federally promulgated WQS on its website. See https://www.epa.gov/wqs-tech/state-specific-water-quality-standards-effective-under-clean-water-act-cwa. 
The EPA also maintains the Great Lakes Initiative (GLI) Clearinghouse. The Clearinghouse is a central resource for developing water quality standards in the Great Lakes watershed. It contains information on criteria, toxicity data, exposure parameters and other supporting documents. It can be used to help establish water quality criteria, permit discharge limits, Total Maximum Daily Loads, Remedial Action Plans and Lakewide Management Plans. The Clearinghouse is accessible on the EPA's website. See https://www.epa.gov/gliclearinghouse. 
Small Entity Flexibility
The reporting requirements discussed in this ICR do not place an unreasonable burden on small entities. 
Indian Tribes
The EPA has long recognized that tribes require special considerations considering their generally small size and their unique status as sovereign entities. For the WQS program, the EPA has provided special guidance, training, and technical assistance tailored to the unique needs of tribes to help build their capacity to apply for and administer the WQS program. In addition, the EPA provides substantial funding to tribes through the Indian General Assistance Program (GAP) and tribal allocations of CWA section 106 Water Pollution Control Program grants that tribes can use to develop WQS capabilities and administer WQS programs.
In 1994, the EPA established a "simplification rule" (59 FR 64339) to make it easier for tribes to obtain EPA approval for TAS to administer CWA regulatory programs. This rule enabled tribal applications to be combined with other administrative steps, simplified certain showings that a tribe needs to make, simplified jurisdictional analyses, and gave more flexibility to determining whether a tribe has program capability. Each of these steps helped minimize information to be collected. 
In 2016, the EPA further simplified the process of applying for TAS. It issued a final interpretive rule, Revised Interpretation of Clean Water Act Tribal Provision, 81 FR 30183, May 16, 2016. The rule concluded that CWA section 518 includes an express delegation of authority by Congress to Indian tribes to administer regulatory programs over their entire reservations, subject to the eligibility requirements in section 518. This eliminated the need for applicant tribes to demonstrate inherent authority, which was found to be burdensome for many applicants. Further, the EPA provided customizable templates for tribes to prepare TAS applications and draft WQS for adoption, and posted them on its website. See https://www.epa.gov/wqs-tech/tribes-and-water-quality-standards. 
Small Dischargers
The WQS Regulation at 40 CFR part 131 only applies to states and authorized tribes and not to dischargers, while the WQS Regulation at 40 CFR part 132 applies to states, authorized tribes and dischargers in the Great Lakes.  This ICR includes three elements that involve information collection from dischargers: (C)(1) Great Lakes Bioassay tests, (C)(2) Great Lakes Antidegradation Demonstrations, and (C)(3) Great Lakes Regulatory Relief Requests. With these three information collections, dischargers to the Great Lakes system may seek various forms of regulatory relief. The Great Lakes elements of the WQS Regulation do not specify different requirements for small dischargers compared to the requirements for other Great Lakes dischargers. Requests for regulatory relief are generally voluntary. A small discharger to waters in the Great Lakes System that seeks to expand operations in a way that triggers antidegradation provisions, or that conducts bioassay testing, or requests a variance from effluent limitations, does so based on its assessment that the benefits of doing so outweigh the burdens. The time and effort required to prepare a small facility's antidegradation demonstration or variance request might be less than that required to develop similar information for a larger, more complex facility. The EPA is developing resources and tools that may assist small dischargers develop such information. For example, see the WQS Variance Building Tool on the EPA's website at https://www.epa.gov/wqs-tech/water-quality-standards-variance-building-tool. 
Collection Schedule
The CWA and the WQS Regulation require state and authorized tribes to conduct triennial reviews every three years. For WQS variances with terms longer than five years, the WQS Regulation requires reevaluations of the variances no less frequently than every five years. No other WQS activities in this ICR must occur on a fixed schedule. See section 3.4 for a discussion of these other activities.
Estimating the Burden and Cost of the Collection
Estimating Respondent Burden and Costs
In this section, the EPA calculates respondent burden and costs. 
 The respondent burden for each collection is based on estimates of the number of responses expected times estimates of the burden hours for each response.
 The respondent labor cost for each collection is based on the burden hours calculated above multiplied by estimated personnel compensation rates for each class of respondent. These rates are estimated as follows:
 State or tribal employee costs were estimated using the hourly rate of a GS-9, Step 10 federal employee, of $27.32. Overhead costs are expected to be 60 percent, or $16.39 per hour, yielding a total hourly rate of $43.71; and, 
 Wastewater treatment workers (to oversee contractor work) were estimated using the hourly rate of a GS-7, Step 1 federal employee, of $17.18. Overhead costs are expected to be 50 percent, or $8.59, yielding a total hourly rate of $25.77.
 The respondent Operations and Maintenance (O&M) expenses are estimated separately. See (D)(2) Tribal Applications for TAS below.
There are no Capital Expenses in this ICR.
(A) WQS Adoption, Review, and Revision (WQS Base Program)
State and tribal burden: The CWA and the WQS Regulation require a WQS review and associated information collection at least once every three years from the 56 states and 44 authorized tribes with EPA-approved WQS. In the consultation with states at the initiation of the program, described in section 3.3, the EPA asked the states to quantify the reporting and recordkeeping burden on an annualized basis because of differing practices regarding the three-year requirement in the CWA. Because of the limited time available to develop them, these estimates were considered "rough," ranging from 81 hours to 7,375 hours per state. For this reason, the lowest and highest estimates for each burden item were not considered in the calculation for the average burden per state per year (that is, a modified mean was used). As a result, the average burden per state or tribe per year was estimated to be 2,500 hours. No comments on this figure have been received at any ICR renewal since the 1980s. Based on a total of 56 states plus 44 tribes, the total annual burden hours are (100 responses) * (2,500 hours) = 250,000 hours.
State and tribal labor costs: Total annual cost = (250,000 hours) * ($43.71/hour) = $10,927,500.
(B) Specific WQS Regulation Requirements
Based on the March 2014 consultations described in section 3.3 above, as well as information otherwise available, the EPA has developed the burden and cost estimates described in (B)(1) through (B)(9) below.
(B)(1) Rulemaking
State and tribal burden: In 2015 when issuing the final rule, Water Quality Standards Regulation Revision, the EPA estimated that each state or authorized tribe would need to perform a one-time WQS rulemaking as described in this ICR within the first three years. The Agency estimates that half of these rulemakings, or (56 states and 44 tribes) * 50% = 50, have been delayed and will occur in the next three years, at a rate of 16.33 (rounded to 17) per year. Based on the consultation described in section 3.3, the Agency estimates that 500 to 1,000 hours are required for each rulemaking. The total annual burden hours range from (17 rulemakings) * (500 hours per rulemaking) = 8,500 hours, to (17 rulemakings) * (1,000 hours per rulemaking) = 17,000 hours.
State and tribal labor costs: Total annual costs range from (8,500 hours) * ($43.71/hour) = $371,535, to (17,000 hours) * ($43.71/hour) = $743,070.
(B)(2) Designated Uses: identifying the Highest Attainable Use
State and tribal burden: Based on the consultation described in section 3.3, the EPA estimates that 15 states and tribes conduct an average of one UAA per year that needs additional work to identify the HAU. The Agency estimates that identifying the HAU for a UAA requires from 150 to 300 hours. The total annual burden hours range from (15 responses) * (150 hours per response) = 2,250 hours, to (15 responses) * (300 hours per response) = 4,500 hours.
State and tribal labor costs: Total annual costs range from (2,250 hours) * ($43.71/hour) = $98,348, to (4,500 hours) * ($43.71/hour) = $196,695.
(B)(3) Triennial Review: Criteria Explanations
State and tribal burden: The EPA has issued an average of 9 new or updated national water quality criteria recommendations per year under CWA section 304(a), based on EPA records from 1972 to 2014. States and authorized tribes are required to adopt new or revised water quality criteria into their WQS for all parameters for which such recommendations have been issued, or to provide an explanation for why they have not done so. The EPA estimates that states and authorized tribes adopt half of such criteria; this work is covered under collection (A) WQS Adoption, Review, and Revision. For the remainder, the Agency estimates that each state or tribe will need to provide an average of 4.5 criteria explanations per year, or 450 total responses, at from 10 to 50 burden hours per explanation. The total annual burden hours range from (450 responses) * (10 hours per response) = 4,500 hours, to (450 responses) * (50 hours per response) = 22,500 hours.
State and tribal labor costs: Total annual costs range from (4,500 hours) * ($43.71/hour) = $196,695 to (22,500 hours) * ($43.71/hour) = $983,475.
(B)(4) Antidegradation: Implementation Methods
State and tribal burden: In 2015 when issuing the final rule, Water Quality Standards Regulation Revision, the EPA had information available about the practices of 40 states for identifying waters to receive Tier 2 antidegradation protection. Of the 40, the practices of 18 states were identified as generally not consistent with the rule's requirements for identifying Tier 2 waters. The EPA estimated that the states and authorized tribes for which it did not have available information (now 60 states and tribes) were likely to have the same proportion of non-consistent practices. Thus, the Agency estimates that (18/40) * (40 plus 60) = 45 potentially affected states and tribes would need to revise antidegradation implementation methods (AIMs) and revise their lists of Tier 2-protected waters (see (B)(5) Tier 2 Waters Designations below) to comply with the WQS Regulation. 
To revise AIMs, these 45 states and tribes would need to conduct additional public involvement activities, such as notification, documentation, and recordkeeping. The EPA estimates that such revisions will occur on the average of once every 10 years to bring their AIMs into compliance with the Tier 2 designation requirements and to make other adjustments to keep their methods up to date in the future, for a total of 4.5 responses (rounded to 5) per year. The Agency estimates that 150 to 300 hours are needed per response. The total annual burden hours range from (5 responses) * (150 hours per response) = 750 hours, to (5 responses) * (300 hours per response) = 1,500 hours.
State and tribal labor costs: Total annual costs range from (750 hours) * ($43.71/hour) = $32,783, to (1,500 hours) * ($43.71/hour) = $65,565.
(B)(5) Antidegradation: Tier 2 Waters Designations
State and tribal burden: As noted above, the EPA estimates that 45 states and authorized tribes have antidegradation practices inconsistent with the WQS Regulation's requirements for designating waters for Tier 2 protection. To become consistent, these states and tribes would need to perform a one-time WQS rulemaking within three years to identify Tier 2 water bodies on a water body-by-water body basis to comply with the WQS Regulation. The EPA estimates that half of these rulemakings, or 22.5, have been delayed and will occur in the next three years, at a rate of 7.5 (rounded to 8) per year. The Agency estimates that 150 to 300 hours are required for each rulemaking. The total annual burden hours range from (8 responses) * (150 hours per response) = 1,200 hours, to (8 responses) * (300 hours per rulemaking) = 2,400 hours.
State and tribal labor costs: Total annual costs range from (1,200 hours) * ($43.71/hour) = $52,452, to (2,400 hours) * ($43.71/hour) = $104,904.
(B)(6) Antidegradation: Alternatives Analyses
State and tribal burden: In 2015 when issuing the final rule, Water Quality Standards Regulation Revision, the EPA had information available about the practices of 40 states in analyzing alternatives when conducting Tier 2 antidegradation reviews. Of the 40, the practices of 19 states were identified as generally not consistent with the rule's requirements for conducting alternatives analyses. A total of 41,618 individual NPDES dischargers are located in those 40 states, of which 19,059 are located in the 19 states with practices inconsistent with the alternatives analysis requirements. A total of 8,684 permits are located in the remaining 56 states and tribes without sufficient information. The EPA estimated that the 60 states and authorized tribes for which it did not have available information were likely to have the same proportion of NPDES permits subject to consistent and non-consistent state and tribal practices. Thus, (50,302 individual NPDES permits nationally) * (19,059/41,618) = 23,036 permits are estimated to be in jurisdictions that would require additional work to provide adequate alternatives analyses when conducting Tier 2 antidegradation reviews. Based on information from the states of Iowa and Missouri, as discussed in the ICR for the final 2015 WQS Regulatory Revisions rule, the EPA estimates that about 2 percent, or (23,026 * 2%) = 461 dischargers, will require Tier 2 antidegradation reviews per year in these states. The EPA estimates that 30 to 90 hours are required per response. The total annual burden hours range from (461 responses) * (30 hours per response) = 13,830 hours, to (461 responses) * (90 hours per response) = 41,490 hours.
State and tribal labor costs: Total annual costs range from (13,830 hours) * ($43.71/hour) = $604,509, to (41,490 hours) * ($43.71/hour) = $1,813,528.
(B)(7) Antidegradation: Additional Tier 2 Reviews
State and tribal burden: As discussed in (B)(4) Implementation Methods above, in 2015 the EPA had information available about the practices of 40 states for identifying waters to receive Tier 2 antidegradation protection. Of the 40, the practices of 18 states were identified as generally not consistent with the rule's requirements for identifying Tier 2 waters. A total of 38,232 individual NPDES dischargers are located in those 40 states, of which 19,594 are located in the 18 states with practices inconsistent with requirements for Tier 2 waters identification. A total of 12,070 permits are located in the remaining 60 states and tribes without sufficient information. The EPA estimated that the 60 states and tribes for which it did not have available information were likely to have the same proportion of NPDES permits subject to non-consistent state and tribal practices. Thus, the EPA estimates that (50,302 individual NPDES permits nationally) * (19,594/38,232) = 25,780 individual NPDES dischargers are located in jurisdictions that were not in compliance with requirements for Tier 2 waters identification. As states and tribes come into compliance, The EPA estimates that an additional 1 percent of these dischargers per year, or 258, will require a Tier 2 review. The EPA estimates that the additional work needed will require 130 to 390 hours. The total annual burden hours range from (258 responses) * (130 hours per response) = 33,540 hours, to (258 responses) * (390 hours per response) = 100,620 hours.
State and tribal labor costs: Total annual costs range from (33,540 hours) * ($43.71/hour) = $1,466,033, to (100,620 hours) * ($43.71/hour) = $4,398,100.
(B)(8) WQS Variances: Submission Requirements
State and tribal burden: In the past five years (2013-2017), states and authorized tribes have issued 122 WQS variances, or an average of 24.4 (rounded to 25) per year. The 2015 rule, Water Quality Standards Regulation Revisions, added new provisions that raise the requirements for states and tribes to document variances for EPA review. Considering recent interest in variances, the EPA expects that the rate of variance development could potentially double, to 50 variances per year. Based on the ICR for the 2015 rule, the EPA estimates that the increased submission requirements range from 31 to 75 hours of additional burden per variance. The total annual burden hours range from (50 responses) * (31 hours per response) = 1,550 hours, to (50 responses) * (75 hours per response) = 3,750 hours.
State and tribal labor costs: Total annual costs range from (1,550 hours) * ($43.71/hour) = $67,751 to (3,750 hours) * ($43.71/hour) = $163,913.
(B)(9) WQS Variances: Reevaluations
State and tribal burden: The 2015 rule, Water Quality Standards Regulation Revisions, clarified that variances with terms longer than five years need to be reevaluated every three to five years. Under the conservative assumption that all variances will have terms longer than five years, the EPA estimates that this requirement, together with a potential doubling of the rate of variance issuance from 25 per year to 50 per year, will result in from 50 to 150 reevaluations per year. Based on the ICR for the 2015 Regulatory Revision rule, the EPA estimates that the increased reevaluation requirements will require 23 to 56 hours per variance reevaluated. The total annual burden hours range from (50 responses) * (23 hours per response) = 1,150 hours, to (150 responses) * (56 hours per response) = 8,400 hours.
State and tribal labor costs: Total annual costs range from (1,150 hours) * ($43.71/hour) = $50,267, to (8,400 hours) * ($43.71/hour) = $367,164.
(C) Great Lakes WQS Requirements
The burden estimates below were initially developed in conjunction with the final rule, Water Quality Guidance for the Great Lakes System, 60 FR 15366, March 23, 1995, and refined to reflect changes during subsequent implementation, including changes in the number of Great Lakes dischargers. 
(C)(1) Great Lakes Bioassay Tests
Discharger contractor burden: Based on the 1995 ICR, the EPA assumes that dischargers will use contractors to conduct bioassays to support the development of water quality criteria for an estimated 3 human health criteria and 11 aquatic life criteria each year. This results in 14 discharger responses per year. The EPA consulted with contractors with expertise in this specialized area to determine that conducting 14 bioassays of these types would require about 34,204 hours in aggregate. 
Discharger contractor costs: Contractor hourly rates were estimated using the Bureau of Labor Statistics estimate for civilian workers in the management, professional, and related category, of $40.61 per hour. Overhead costs and profit are expected to be 67 percent, or $27.21, yielding a total hourly rate of $67.82. The total labor cost = (34,204 hours) * ($67.82 per hour) = $2,319,715.
Discharger burden: The EPA estimates, based on the 1995 ICR, that the total annual burden hours for dischargers to oversee the contractors' 14 bioassay tests = 760 hours.
Discharger labor costs: Total annual labor costs = (760 hours) * ($25.77/hour) = $19,585.  
State or Tribal burden: The EPA assumes that the 14 studies to support the development of water quality criteria would be submitted to the states or tribes for review, resulting in 14 state or tribal responses. Based on the 1995 ICR, the EPA estimated the state/tribal application burden associated with review and data collection of the 14 studies to support the development of water quality criteria to be 2,714 hours in aggregate.
State or tribal labor costs: Review of water quality criteria = (2,714 hours) * ($43.71) = $118,629.
(C)(2) Great Lakes Antidegradation Demonstrations
Discharger burden: There are 2,689 dischargers to the Great Lakes system, of which 972 are municipal sources and 1,717 are non-municipal. The EPA estimates that 5 percent of these dischargers (approximately 49 municipal and 86 non-municipal) will discharge bioaccumulative chemicals of concern (BCCs). The EPA conservatively assumes that all the permittees that discharge BCCs will request an increase in permit limits and be required to perform an antidegradation demonstration. The EPA estimates that one-fifth of these permittees (10 municipal and 17 non-municipal) will prepare and submit an antidegradation demonstration each year. Likewise, the Agency estimates that another 10 municipal and 17 non-municipal permittees will submit antidegradation demonstrations for discharges of non-BCCs. The results are shown in Column (A) of the table below.
Based on the 1995 ICR, the EPA has developed estimates in Column (B) of the table below of the number of hours required to prepare the antidegradation demonstrations. These estimates vary, as shown, depending on whether the discharger is municipal or non-municipal, and whether the demonstration is for BCCs or non-BCCs. 
The antidegradation demonstration includes both WQS elements and NPDES permitting elements. Therefore, the EPA has split this activity equally between this ICR and the NPDES Program ICR. The share of the burden hours per demonstration for this WQS Regulation ICR is shown in column (C). The total discharger burden hours for antidegradation demonstrations hours  -  the number of antidegradation demonstrations per year in Column (A) times the share of burden hours charged to this ICR in column (C)  -  are shown in Column (D). 
Thus, the total discharger burden hours for Great Lakes Antidegradation Demonstrations, shown in Column (D) below, is 685 hours. 

Discharger and Pollutant Type
                            Demonstrations per year
                                  Column (A)
                               Unit Burden Hours
                                  Column (B)
                 WQS Regulation ICR's Share of Burden Hours 
                                  Column (C)
                   WQS Regulation ICR's Total Burden Hours
                                  Column (D)
Municipal  -  BCCs
                                      10
                                     44.4
                                     22.2
                                      222
Municipal non-BCCs
                                      10
                                     29.6
                                     14.8
                                      148
Non-municipal BCCs
                                      17
                                     22.2
                                     11.1
                                      189
Non-municipal non-BCCs
                                      17
                                     14.8
                                      7.4
                                      126
TOTAL
                                      54
                                       
                                       
                                      685

Discharger costs: Antidegradation demonstrations = (685 hours) * ($25.77/hour) = $17,652. 
State or Tribal Burden. The EPA estimates that it would take a Great Lakes state or tribe about 16 hours to review an antidegradation demonstration. The EPA has split this activity equally between this WQS ICR and the NPDES Program ICR (OMB Control No. 2040-0004) and assumes 50 percent of the 16 hours (8 hours) will be needed for the WQS-related work to review an antidegradation demonstration. This results in a total burden of (54 reviews) * (8 hours per review), or 432 hours for Great Lakes states and tribes for this WQS Regulation ICR.
State or Tribal costs: Review of antidegradation demonstrations = (432 hours) * ($43.71/hour) = $18,883. 
(C)(3) Great Lakes Regulatory Relief Requests
Discharger burden: To be granted relief from certain provisions adopted consistent with 40 CFR part 132, a permittee may perform additional work such as monitoring or special studies to support its request. The EPA estimates that 18 permittees per year will request regulatory relief. The EPA estimates that each request will entail a burden of 835.3 hours for a discharger. The EPA further assumes that the work is equally split between WQS elements and NPDES permitting elements. Therefore, the Agency has split this activity equally between this WQS Regulation ICR and the NPDES Program ICR (OMB Control No. 2040-0004) and assumes 50 percent of the 835.3 hours (417.67 hours) will be needed for the WQS-related work on regulatory relief requests. This results in a total burden of (417.67 hours/permittee) * (18 permittees) = 7,518 hours for dischargers for this ICR.
Discharger labor costs: (7,518 hours) * ($25.77/hour) = $193,739. 
State or Tribal burden: To process each of the 18 regulatory relief requests, the EPA estimates that a Great Lakes state or tribe will require 88 hours: 4 hours to review the request for completion, including any contact with the permittee for additional information; 4 hours for public notice and comment (assuming conservatively that this process is independent of regular permit public notice); and 80 hours to analyze the regulatory relief request, decide if it is justified, justify the decision, and prepare a permit modification if necessary. The EPA has split this activity equally between this WQS ICR and the NPDES Program ICR and assumes 50 percent of the 88 hours (44 hours) will be needed for the WQS-related work to review an antidegradation demonstration. This results in a total burden of (44 hours/permittee) * (18 permittees) = 792 hours for Great Lakes states and tribes for this ICR.
State or tribal labor costs: Review of regulatory relief requests = (792 hours) * ($43.71 hour) = $34,618.
(D)Tribal-Related Dispute Resolution Requests and TAS Applications
(D)(1) Dispute Resolution Requests 
State or Tribal burden: When a state or authorized tribe requests the EPA to initiate a formal dispute resolution action, the tribe or state is required to submit a written request to the Agency. The EPA estimates that at most three tribes/states will request a formal dispute resolution action over a three- year period (one request per year). To date, there have been no such formal requests since the regulation went into effect in 1991. The estimated hour burden to a tribe or state to develop a dispute resolution request is 80 hours. The total annual burden hours = (1 application) * (80 hours/application) = 80 hours.
State or Tribal costs: Total annual cost = (80 hours) * ($43.71/hour) = $3,497. 
(D)(2) Tribal Applications for TAS
Tribal burden: Based on the 2016 ICR for the final interpretive rule, Interpretation of Clean Water Act Tribal Provision, the EPA estimates that six tribes will apply to administer the WQS program per year. Based on information from eight tribes with experience in developing TAS applications for CWA regulatory programs, the EPA estimates that developing a TAS application requires 1,607 tribal staff hours and additional $43,920 for contract costs to assist tribes. This results in a total burden of (6 tribes) * (1,607 hours) = 9,642 hours 
Tribal labor costs: Total annual labor costs = (9,642 hours) * ($43.71/hour) = $421,452.
Tribal Operations and Maintenance (O&M) costs: Tribal costs to cover contractual support: (6 tribes) * ($43,920) = $263,520 in contractor costs.
(E) Periodic Requests for WQS Program Information
State or Tribal burden: The program information in this collection includes: technical information to assist in developing guidance or other materials; technical comments on draft program-related policies and guidance documents; information concerning program operations to assist in information sharing and improving program efficiency; and state and tribal participation in program-related work groups. Submission of state or tribal information or participation by state and tribes in workgroups is voluntary. The EPA estimates that each Region will make requests for voluntary WQS program information from its states and authorized tribes about 6 times per year. The EPA estimates that EPA headquarters will make such requests nationally about 4 times per year. Thus, the total number of voluntary requests to each state or tribe is 10, for a national total of (10 requests) * (56 states plus 44 authorized tribes) = 1000 requests annually for voluntary information from states and tribes. The EPA estimates that responding to an individual request will require from 2 to 6 hours. The total annual burden hours range from (1000 responses) * (2 hours/response) = 2000 hours, to (1000 responses) * (6 hours/response) = 6000 hours.
State or Tribal costs: Total labor costs range from (2000 hours) * ($43.71 per hour) = $87,420, to (6000 hours) * ($43.71 per hour) = $262,260.
(F) Respondent Burden and Cost Totals
The annual number of information requests for all collections listed above in this ICR ranges from 2,593 to 2,693. The annual burden for states, tribes, and dischargers to respond to these requests ranges from 376,097 hours to 514,987 hours. The total labor costs to respond to these requests ranges from $17,103,064 to $23,173,945. The total O&M costs to respond to these requests is $263,520. These figures are summarized for each collection in Table 1 in section 7. 
Estimating Agency Burden and Cost 
The EPA's analysis of annual burden and costs to the federal government are detailed in this section. EPA employee costs were estimated assuming a GS-13 Step 5 federal employee earning $51.91 per hour. Overhead costs for federal employees are expected to be 60 percent, or $31.15 per hour, yielding a total hourly rate of $83.12. 
(A) WQS Adoption, Review, and Revision (WQS Base Program) 
The EPA estimates that each review of a state or tribal WQS submission of new or revised WQS will require 168 hours. Assuming that each state or tribe will submit one draft or final package of new or revised WQS every year, the total annual burden = (100 submissions) * (168 hours/submission) = 16,800 hours. Labor cost = (16,800 hours) * ($83.12/hour) = $1,396,416.
(B) Specific WQS Regulation Requirements
The EPA conservatively estimates the incremental cost to the Agency as approximately 20% of the annual cost to states and authorized tribes for collections (B)(1) through (B)(9), which ranges from $2,940,373 * 20% = $588,075, to $8,836,414 * 20% = $1,767,283. To estimate agency burden hours, the EPA divided the cost by the hourly rate. Thus, the EPA estimates that one-time incremental staff burden hours to the Agency could range from $588,075 divided by $83.12/hour = 7,075 hours, to $1,767,283 divided by $83.12 = 21,262 hours. 
(C) Great Lakes WQS Requirements
The EPA estimates it will require a total burden of approximately 80 hours annually to maintain the water quality database for the Great Lakes Clearinghouse. The total annual labor cost is (80 hours) * ($83.12/hour) = $6,650. In addition, the EPA estimates that web hosting for the Clearinghouse requires $400 annually in contract costs. The EPA estimated little additional federal government burden or cost because all the Great Lakes states are delegated NPDES permitting authorities. 
(D)(1) Dispute Resolution Requests
The EPA estimates that each review of a state or tribal request will require 20 hours. Annual Total burden = (1 request/year) * (20 hours/request) = 20 hours. Annual Labor cost = (20 hours) * ($83.12/hour) = $1,662.
(D)(2) Tribal Applications for TAS 
The EPA estimates that each review of a tribal program application will require 205 hours. Total annual burden = (6 applications/year) * (205 hours/application) = 1,230 hours. Annual Labor cost = (1,230 hours/year) * ($83.12/hour) = $102,238.
(E) Periodic Requests for WQS Program Information
The EPA estimates that EPA Regions will make (6 requests per Region) * (10 Regions) = 60 periodic requests annually for voluntary WQS program information from states and authorized tribes. The EPA estimates that EPA headquarters will make 4 such requests, for a total of (60 + 4) = 64 requests nationally per year. The EPA estimates that it will require 4 hours to 12 hours to compile and analyze the results of each periodic request. Thus, the total annual burden ranges from (64 requests/year) * (4 hours/request) = 256 hours, to (64 requests/year) * 12 hours/request) = 768 hours. Annual labor costs range from (256 hours/year) * ($83.12/hour) = $21,279 to (768 hours/year) * ($83.12/hour) = $63,836. 
(F) Agency Burden and Cost Totals
In summary, the total annual burden to the EPA in the collections listed above ranges from 25,461 hours to 40,160 hours. The total annual labor cost to the Agency ranges from (25,461 hours) * ($83.12/hour) = $2,116,319, to (40,160 hours) * ($83.12/hour) = $3,338,085. The total annual O&M cost to the Agency is $400. These figures are summarized for each collection in Table 2 in section 7.
       Reasons for Change in Respondent Burden
There is a decrease of 226,040 hours in the total estimated respondent burden compared to the burden contained in the three ICRs approved by OMB that have been consolidated in this ICR renewal. This decrease reflects the net effects of the following technical changes (no programmatic changes were made):
 A downward revision in the estimated number of state and tribal responses in (B)(8) WQS Variances: Submission Requirements and (B)(9) WQS Variances: Reevaluations to be submitted to the EPA annually (-221,130 hours);
 A decrease in one-time activities under (B)(1) Rulemaking and (B)(5) Antidegradation: Tier 2 Waters Designations that were completed in 2015-2017 (-16,900 hours);
 An increase of two authorized tribes with EPA-approved WQS, from 42 to 44, affecting state and tribal burden under (A) WQS Adoption, Review, and Revision (WQS Base Program) and (B)(3) Triennial Review: Criteria Explanations (+5,900 hours);
 An increase due to quantifying collection, (E) Periodic Requests for WQS Program Information, that was previously a non-quantified provision (+6,000 hours); and,
 An increase from minor adjustments including rounding (+90 hours). 
The changes in burden for each collection are provided in Table 3 in section 7.
Burden Statement
The annual public reporting and record keeping burden for this collection of information is estimated to average 191 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for the EPA 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, the EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OW-2011-0465, which is available for online viewing at www.regulations.gov, or in person viewing at the Office of Water Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Avenue, 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. An electronic version of the public docket is available online for viewing at http://www.regulations.gov. Use http://www.regulations.gov to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select "search," then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for the EPA. Please include EPA Docket ID (EPA-HQ-OW-2011-0465) and OMB Control Number (2040-0049) in any correspondence.



Summary Tables
  Table 1:  Total annual burden and cost for states, tribes and dischargers
                                  Collection
                            No. Responses per year
                              Unit Burden (hours)
                          Total Annual burden (hours)
                               Annual Labor Cost
                              Annual O&M Cost
                         State and Tribal Respondents
                                       
(A) WQS Adoption, Review, and Revision (WQS Base Program) 
                                      100
                                     2,500
                                    250,000
                                  $10,927,500
                                     None
(B)(1) Rulemaking
                                      17
                                   500-1,000
                                 8,500-17,000
                               $371,535-$743,070
                                     None
(B)(2) Designated Uses: Identifying the Highest Attainable Use
                                      15
                                    150-300
                                  2,250-4,500
                               $98,348-$196,695
                                     None
(B)(3) Triennial Review: Criteria Explanations
                                      450
                                     10-50
                                 4,500-22,500
                               $196,695-$983,475
                                     None
(B)(4) Antidegradation: Implementation Methods
                                       5
                                    150-300
                                   750-1,500
                                $32,783-$65,565
                                     None
(B)(5) Antidegradation: Tier 2 Waters Designations
                                       8
                                    150-300
                                  1,200-2,400
                               $52,452-$104,904
                                     None
(B)(6) Antidegradation: Alternatives Analyses
                                      461
                                     30-90
                                 13,830-41,490
                              $604,509-$1,813,528
                                     None
(B)(7) Antidegradation: Additional Tier 2 Reviews
                                      258
                                    130-390
                                33,540-100,620
                             $1,466,033-$4,398,100
                                     None
(B)(8) WQS Variances: Submission Requirements
                                      50
                                     31-75
                                  1,550-3,750
                               $67,751-$163,913
                                     None
(B)(9) WQS Variances: Reevaluations
                                    50-150
                                     23-56
                                  1,150-8,400
                               $50,267-$367,164
                                     None
(C)(1) Great Lakes Bioassay Tests
                                      14
                                   Aggregate
                                   estimate
                                     2,714
                                   $118,629
                                     None
(C)(2) Great Lakes Antidegradation Demonstrations
                                      54
                                       8
                                      432
                                    $18,883
                                     None
(C)(3) Great Lakes Regulatory Relief Requests
                                      18
                                      44
                                      792
                                    $34,618
                                     None
(D)(1) Dispute Resolution Requests 
                                       1
                                      80
                                      80
                                    $3,497
                                     None
(D)(2) Tribal Applications for TAS
                                       6
                                     1,607
                                     9,642
                                   $421,452
                                   $263,520
(E) Periodic Requests for WQS Program Information (new in this ICR)
                                     1,000
                                      2-6
                                  2,000-6,000
                               $87,420-$262,260
                                     None
                                          Total for State and Tribal Responses 
                                 2,507- 2,607
                                       
                                332,930-471,820
                            $14,552,372-$20,623,253
                                   $263,520
                      Great Lakes Discharger Respondents
(C)(1) Great Lakes Bioassay Tests
                                      14
                              Aggregate estimate
                                    34,964
                                  $2,339,300
                                     None
(C)(2) Great Lakes Antidegradation Demonstrations
                                      54
                                    various
                                      685
                                    $17,652
                                     None
(C)(3) Great Lakes Regulatory Relief Requests
                                      18
                                    417.65
                                     7,518
                                   $193,739
                                     None
                                     Total for Great Lakes Discharger Responses
                                      86
                                       
                                    43,167
                                  $2,550,692
                                     None
                                  Grand Total
                                                                    GRAND TOTAL
                                 2,593- 2,693
                                       
                                376,097-514,987
                           $17,103,064- $23,173,945
$263,520

  Table 2:  Total agency burden and cost 
                                  Collection
                            No. Responses per year
                              Unit Burden (hours)
                          Total Annual burden (hours)
                               Annual Labor Cost
                              Annual O&M Cost
(A) WQS Adoption, Review, and Revision (WQS Base Program) 
                                      100
                                      168
                                    16,800
                                  $1,396,416
                                     None
(B) Specific WQS Regulation Requirements
                                 1,314 - 1,414
                              Aggregate estimate
                               7,075  -  21,262
                             $588,075 - $1,767,283
                                     None
(C) Great Lakes WQS Requirements
                                     none
                              Aggregate estimate
                                      80
                                    $6,650
                                     $400
(D)(1) Dispute Resolution Requests
                                       1
                                      20
                                      20
                                    $1,662
                                     None
(D)(2) Tribal Applications for TAS
                                       6
                                      205
                                     1,230
                                   $102,238
                                     None
(E) Periodic Requests for WQS Program Information
                                      64
                                      12
                                  256  -  768
                              $21,279  -  63,836
                                     None
                                                                          Total
                                 1,485 - 1,585
                                       
                                25,461 - 40,160
                            $2,116,319- $3,338,085
                                     $400


  Table 3:  Change in Respondent Burden 
      (Negative numbers are in parentheses)
                                  Collection
                             Previous ICRs (hours)
                               This ICR (hours)
                                  Difference
                                    (hours)
                                   Comments
           Previous ICR: WQS Regulation (Renewal), 2015 (2040-0049)
(A) WQS Adoption, Review, and Revision (Base Program)
                                    245,000
                                    250,000
                                     5,000
                 Addition of two tribes with EPA-approved WQS
(C)(1) Great Lakes Bioassay Tests 
                                    37,678
                                    37,678
                                       0
                                       
(C)(2) Great Lakes Antidegradation Demonstrations
                                     1,117
                                     1,117
                                       0
                                       
(C)(3) Great Lakes Regulatory Relief Requests
                                     8,310
                                     8,310
                                       0
                                       
(D)(1) Dispute Resolution Requests
                                      80
                                      80
                                       0
                                       
(D)(2) Tribal Applications for TAS
                                      120
                             Deleted old estimate
                                     (120)
Deletion of old estimate; see new estimate below under previous ICR for Interpretation of Clean Water Act Tribal Provision
(E) Periodic Requests for WQS Program Information
                                Non-quantified
                                     6,000
                                     6,000
            Newly quantified collection, previously non-quantified
                                                       Total for WQS Regulation
                                    292,305
                                    303,185
                                    10,880
                                       
            Previous ICR: WQS Regulation Revision, 2015 (2040-0286)
(B)(1) Rulemaking
                                    32,000
                                    17,000
                                   (15,000)
            Completion of half of one-time rulemakings in 2016-2018
(B)(2) Designated Uses: Identifying the Highest Attainable Use
                                     4,500
                                     4,500
                                       0
                                       
(B)(3) Triennial Review: Criteria Explanations
                                    21,600
                                    22,500
                                      900
                 Addition of two tribes with EPA-approved WQS
(B)(4) Antidegradation: Implementation Methods
                                     1,290
                                     1,500
                                      210
                 Addition of two tribes with EPA-approved WQS
(B)(5) Antidegradation: Tier 2 Waters Designations
                                     4,300
                                     2,400
                                    (1,900)
Completion of half of one-time designations in 2016-2018; rounding of response estimate
(B)(6) Antidegradation: Alternatives Analyses
                                    41,490
                                    41,490
                                       0
                                       
(B)(7) Antidegradation: Additional Tier 2 Reviews
                                    100,620
                                    100,620
                                       0
                                       
(B)(8) WQS Variances: Submission Requirements
                                    72,000
                                     3,750
                                   (68,250)
Downward revision in the number of WQS variances estimated to be submitted annually
(B)(9) WQS Variances: Reevaluations
                                    161,280
                                     8,400
                                   (152,880)
Downward revision in the number of WQS variance reevaluations estimated to be submitted annually
                                             Total for WQS Regulatory Revisions
                                    439,080
                                    202,160
                                   (236,920)
                                       
Previous ICR: Interpretation of Clean Water Act Tribal Provision (Final Interpretive Rule), 2016 (2040-0289
(D)(2) Tribal Applications for TAS
                                     9,642
                                     9,642
                                       0
                                       
                               Total for Interpretation of CWA Tribal Provision
                                     9,642
                                     9,642
                                       0
                                       
                                  GRAND TOTAL
                                                                    GRAND TOTAL
                                    741,027
                                    514,987
                                   (226,040)
                                       

Note: This table was derived using the upper burden hour estimates from the previous ICRs and from Table 1 of this ICR. 
