ICR Supporting Statement

Information Collection Request for EPA Application Materials for the
Water Infrastructure Finance and Innovation Act

OMB Control No. 2040-NEW, EPA ICR No. 2549.01

A.  Justification.

Explain the circumstances that make the collection of information
necessary.  Identify any legal or administrative requirements that
necessitate the collection. 

The collection of information is necessary in order to receive
applications for credit assistance pursuant to section 5024 of the Water
Infrastructure Finance and Innovation Act (WIFIA) of 2014, 33 USC 3903.
The purpose of the WIFIA program is to provide Federal credit assistance
in the form of direct loans and loan guarantees to eligible clean water
and drinking water projects.  

WIFIA requires that an eligible entity shall submit to the Administrator
an application at such time, in such manner, and containing such
information, as the Secretary or the Administrator may require to
receive assistance under WIFIA. In order to satisfy these requirements,
EPA must collect a letter of interest and an application from entities
seeking funding. The relevant section of WIFIA is attached hereto as
Exhibit A. EPA is publishing this notice to give entities an opportunity
to submit applications upon authorization of funding. This collection is
necessary to determine whether each proposed project meets
creditworthiness and other Federal requirements to receive WIFIA credit
assistance.

 2.	Indicate how, by whom, and for what purpose the information is to be
used.  Except for a new collection, indicate the actual use the agency
has made of the information received from the current collection.

The letter of interest and the application (attached as Exhibits B and
C) collected from loan applicants through this solicitation will be used
to evaluate applications for credit assistance under the WIFIA
eligibility requirements and selection criteria. 

3.	Describe whether, and to what extent, the collection of information
involves the use of automated, electronic, mechanical, or other
technological collection techniques or other forms of information
technology, e.g. permitting electronic submission of responses, and the
basis for the decision for adopting this means of collection. Also
describe any consideration of using information technology to reduce
burden.  

	The letter of interest form is available electronically. The letter of
interest and supporting narrative are submitted entirely via e-mail
only. The application is available electronically. It is submitted in
part electronically and in part via conventional mail, due to the size
of the application package. To reduce burden and to minimize the number
of copies required from the applicant, electronic versions of the
application are required via CD.  

 4.	Describe efforts to identify duplication. Show specifically why any
similar information already available cannot be used or modified for use
for the purpose(s) described in item 2 above.

The letters of interest and applications will generally be project
specific and the information is not available elsewhere.  

 5.	If the collection of information impacts small businesses or other
small entities (item 5 of the OMB form 83-1), describe the methods used
to minimize burden.

Eligible applicants under WIFIA include corporations, partnerships,
joint ventures, trusts, Federal, State, or local governmental entities,
agencies, or instrumentalities, tribal governments or consortium of
tribal governments, and state infrastructure financing authorities,
which could include small entities. Letters of interest and applications
are voluntary. EPA cannot minimize the burden to small entities, because
WRRDA requires all eligible entities to submit an application in order
to receive credit assistance. The relevant section of WRRDA is attached
hereto as Exhibit A.

 6.	Describe the consequence to federal program or policy activities if
the collection is not conducted or is conducted less frequently, as well
as any technical or legal obstacles to reducing burden.

If the collection is not conducted, EPA will be unable to satisfy the
statutory mandate to require the submission of applications. Therefore,
WIFIA credit assistance will not be available. In order to provide
credit assistance to eligible projects, which is the purpose of the
program, EPA must collect letters of interest and applications that
respond to the eligibility requirements and selection criteria.

 7.	Explain any special circumstances that would cause an information
collection to be conducted in a manner inconsistent with 5 CFR 1320.6:  

There are no special circumstances. The collection of information is
conducted in a manner consistent with the guidelines in 5 CFR 1320.6.   


8.	Efforts to consult with persons outside the agency to obtain their
views

On DATE OF PUBLICATION (Month, day, and year), Vol. No. _____, pages
__________ to __________, the Agency published the notice of information
collection and request for comments in the Federal Register. The
solicitation is attached as Exhibit D. ________ comments were received.

EPA will consult with persons outside the Agency to obtain their views
on the availability of data, frequency of recordkeeping, disclosure, or
reporting format, and on the data elements to be recorded, disclosed, or
reported. 

 9.	Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.  

 No payments or gifts are provided to respondents.

10.	Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.

EPA cannot offer an assurance of confidentiality to any applicant. The
applicant is directed to state if any information submitted in its
letter of interest, application, or any supplementary material may not
be released by the Agency upon request from a member of the public or
otherwise made publicly available. The applicant must identify the
confidential business information and provide reasons why such
information is confidential business information and should not be
released, including particulars as to any competitive harm which would
potentially result from the release of such information. The Agency will
handle requests from the public for release of information under its
standard Freedom of Information Act procedures. 

11.	Provide additional justification for any questions of a sensitive
nature.

Questions of a sensitive nature are not found in this information
collection.

12.		Provide estimates of the hour burden of the collection of
information.  

The Agency does not have any directly relevant prior experience on which
to base these estimates of the hour burden of the collection and the
annualized cost to respondents. Nevertheless, based on the number and
type of interested stakeholders that have contacted the Agency about
this program, the funding levels for the WIFIA program, and the EPA’s
application procedures, the EPA estimates that the burden will be as
follows, exclusive of the hours required for project development:

Letter of Interest:

Letter of Interest Burden per Application

Function	Legal	Manager	Technical	Clerical

Read application guidelines

1	1	1

Gather Information	 	 	10	5

Complete application form	 	 	 	1

Complete narrative	 	 	19	 

Review Application	5	5	 	 

Compile Application	 	 	 	2

TOTAL	5	6	30	9

Total number of unduplicated respondents: 20

Frequency of response: one per respondent

Annual hour burden per application: 50

Total annual burden hours: 1,000

	Application:

Application Burden per Application

 	Legal	Manager	Technical	Clerical

Read application guidelines

1	1	1

Gather Information	 	 	26	15

Complete application form	 	 	 	1

Complete narrative	 	 	30	 

Review Application	10	10	 	 

Compile Application	 	 	 	5

TOTAL	10	11	57	22



Total number of unduplicated respondents:  5

Frequency of response: one per respondent

Annual hour burden per application: 100

Total annual burden hours: 500

13.		Provide an estimate of the total annual cost burden to respondents
or recordkeepers resulting from the collection of information.  

EPA estimates that the total annual cost burden to respondents will be
$1,489,594. This estimate includes the following:

For the letter of interest, EPA estimates 1,000 annual burden hours and
the annualized cost of those hours is $40,107. 

For the application, EPA estimates 500 annual burden hours and the
annualized cost of those hours is $19,487.

In addition, applicants will be charged two fees:

An application fee will be due upon submission of the application. For
applications for projects serving small communities (population of not
more than 25,000 people), this application fee will be $25,000. For all
other applicants, this application fee will be $100,000. EPA assumes
that one applicant will be a small community. The annual application fee
will be $425,000.

A credit processing fee will be due upon loan closing, to reimburse
costs incurred by the EPA due to legal, financial, and other expert
contractor help. Due to the nature of this fee, the amount is expected
to vary between applicants. However, EPA estimates these costs as
approximately $200,000 per applicant, a portion of which may be waived
at the discretion of the EPA. The total credit processing fee for five
applicants will be approximately $1,000,000.

The cost of general expenses for submitting an application, such as
supplies, delivery charges, mailing, copying, and telecommunications,
will be $1,000. The total general expenses will be $5,000.

Note: EPA used the following median hourly wages from the May 2015
National Occupational Employment and Wage Estimates United States ( 
HYPERLINK "http://www.bls.gov/oes/current/oes_nat.htm" 
http://www.bls.gov/oes/current/oes_nat.htm ) from the U.S. Bureau of
Labor Statistics to calculate the cost of the estimated burden hours:

Lawyers= $55.69

Management= $47.38

Engineers= $43.30

Office and Administrative Support= $15.96

14.	Provide estimates of annualized cost to the federal government.  

	The estimated cost to the Federal government of this request for
letters of interest and applications is $325,150. This cost reflects
three components:

EPA will establish an evaluation process to review each of letter of
interest and application and to determine which projects will receive
WIFIA funding. This process includes technical, financial, and
management review of the letters of interest. Then, additional
technical, financial, and management review of the applications. EPA
estimates that this process will require the equivalent of five FTE per
year. 

The estimated average annual cost for EPA personnel is $95,704 based on
the General Schedule (GS) 13, Step 05 level from the 2016 GS salary
table. The annual cost was then multiplied by the standard government
benefits multiplication factor of 1.6 to calculate an estimated annual
pay including benefits per FTE of $153,126. Therefore, the estimated
annualized cost for the evaluation team is $765,632. EPA plans to use
the application fees to offset these costs. Assuming one application
from a small community and four other applications per year, the total
fees collected will be $425,000. Consequently, the net estimated
annualized cost to the Federal Government for the evaluation team is
$340,632.

EPA will hire legal, financial, and other expert contractor support for
credit processing. These costs are estimated to be $200,000 per
application and are expected to be reimbursed in full by the applicants.
The net estimated annualized cost to the Federal Government for credit
processing is $0.

EPA will print application materials. EPA does not expect to need any
special equipment or support, other than printing. As noted above in
item 12, EPA expects 20 letters of interest and 5 applications. If each
letter of interest is 25 pages and each application is 50 pages, as
requested in the solicitation, EPA may need to print as many as 750
pages for staff involved in the evaluation process. EPA estimates up to
10 staff may need materials which adds up to a total of 7500 pages of
printing. EPA’s printing costs are approximately 2 cents per page,
which adds up to a total printing cost of $150.  

	 

Explain the reason for any program changes or adjustments reported in
items 13 or 14 of the OMB form 83-1.  

This is a new information collection at EPA. 

For collections of information whose results will be published, outline
plans for tabulation, and publication.  

The letters of interest and applications collected for the WIFIA program
will not be published. EPA will maintain a publicly available list of
projects that have submitted letters of interest and applications to the
WIFIA program.

17.	If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that display
would be inappropriate.  

The Agency plans to display the expiration date for OMB approval of the
information collection on all instruments.

  

18.	Explain each exception to the certification statement identified in
item 19, "certification for paperwork reduction act submissions," of OMB
form 83-1. 

The Agency is able to certify compliance with all provisions under Item
19 of OMB Form 83-I.”

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