1
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
Title:
Brownfields
Program
 
Revitalization
Grantee
Reporting,
EPA
ICR
No.
2104.01.

This
is
a
request
for
a
new
Information
Collection
Request
(
ICR).
This
ICR
covers
the
collection
of
information
from
those
organizations
that
receive
grants
from
EPA
under
the
authority
of
subtitle
A
of
the
"
Small
Business
Liability
Relief
and
Brownfields
Revitalization
Act"
(
Public
Law
107­
118,
January
2002).
Subtitle
A
of
the
Act
amends
the
Comprehensive
Environmental
Response,
Compensation,
and
Liability
Act
(
CERCLA),
as
amended,
and
authorizes
EPA
to
award
grants
to
states,
tribes,
local
governments,
and
other
eligible
entities
to
support
the
assessment
and
cleanup
of
brownfields
properties.
With
this
ICR,
EPA's
Office
of
Brownfields
Cleanup
and
Revitalization
(
OBCR)
seeks
authorization
to
collect
information
from
grantees
using
several
standard
forms
that
will
streamline
the
data
collection
effort
and
improve
the
quality
of
information
collected.
The
information
collected
under
this
ICR
supplements
the
minimum
reporting
and
record
keeping
requirements
that
grantees
are
subject
to
under
40
CFR
Part
30,
"
Grants
and
Agreements
with
Institutions
of
Higher
Education,
Hospitals,
and
Other
Non­
profit
Organizations"
and
40
CFR
Part
31,
"
Uniform
Administrative
Requirements
for
Grants
and
Cooperative
Agreements
to
State
and
Local
Governments."
EPA
estimates
that
all
respondents
who
voluntarily
respond
to
this
information
collection
by
electing
to
participate
in
the
Brownfields
grants
program
have
determined
that
the
expected
benefits
of
participation
outweigh
any
burden
associated
with
preparing
the
response.

2.
Need
for/
Use
of
the
Collection
On
January
11,
2002,
the
President
signed
into
law
the
Small
Business
Liability
Relief
and
Brownfields
Revitalization
Act
(
the
"
Brownfields
Amendments"),
which
authorizes
EPA
to
award
several
types
of
grants
to
eligible
entities
on
a
competitive
basis.
Under
subtitle
A
of
the
Brownfields
Amendments,
States,
tribes,
local
governments,
and
other
eligible
entities
can
receive
grants
to:

(
1)
inventory,
characterize,
assess,
and
conduct
planning
and
community
involvement
related
to
brownfields
sites;

(
2)
carry
out
cleanup
activities
at
brownfields
sites;

(
3)
capitalize
revolving
loan
funds
and
provide
sub­
grants
for
cleanup
activities;
and
(
4)
support
the
creation
and
implementation
of
environmental
job
training
and
placement
programs.

Under
the
Brownfields
Amendments,
a
brownfields
site
means
real
property,
the
expansion,
redevelopment,
or
reuse
of
which
may
be
complicated
by
the
presence
or
potential
presence
of
a
2
hazardous
substance,
pollutant,
or
contaminant.
For
grant
funding
purposes,
EPA
uses
the
term
"
brownfields
property(
ies)"
synonymously
with
the
term
"
brownfields
sites."

While
the
Agency
collects
basic
grant
information
as
part
of
its
Federal
stewardship
responsibilities
to
manage
and
oversee
recipient
activities
and
expenditures
(
see
40
CFR
Parts
30
and
31),
OBCR
needs
additional
information
from
grantees
to
be
reported
in
a
consistent
manner
in
order
to
evaluate
the
effectiveness
of
the
program
and
to
report
on
program
activities
and
accomplishments
to
Congress
and
other
program
stakeholders.
Specifically,
OBCR
will
use
the
information
collected
from
grantees
to
oversee
the
activities
carried
out
using
grant
funds,
to
evaluate
program
implementation
and
effectiveness,
and
to
meet
the
Agency's
responsibilities
under
the
Government
Performance
and
Results
Act
to
report
on
OBCR's
accomplishments.
The
information
collection
activities
covered
by
this
ICR
are
intended
to:
(
1)
improve
the
alignment
of
reporting
requirements
with
programmatic
performance
measures;
and
(
2)
simplify
and
standardize
reporting
requirements
to
reduce
uncertainty
and
burden
imposed
on
grantees.
Without
the
information
collection,
OBCR
would
have
limited
access
to
information
needed
to
effectively
assess
the
relationship
between
those
activities
funded
by
EPA's
subtitle
A
Brownfields
grants
and
the
intent
of
Congress
with
the
passage
of
the
Brownfields
Amendments.
3.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a).
Non­
duplication
 
There
is
no
other
known
sources
for
the
information
that
EPA
seeks
under
this
ICR.
Moreover,
this
ICR
supplements,
and
does
not
duplicate,
the
information
that
EPA
collects
as
part
of
its
reporting
and
record
keeping
provisions
under
the
Agency's
general
assistance
regulations
at
40
CFR
Part
30,
"
Grants
and
Agreements
with
Institutions
of
Higher
Education,
Hospitals,
and
Other
Non­
profit
Organizations,"
and
40
CFR
Part
31,
"
Uniform
Administrative
Requirements
for
Grants
and
Cooperative
Agreements
to
State
and
Local
Governments."
EPA's
regulations
at
40
CFR
Part
31,
which
implements
the
requirements
of
OMB
Circular
A­
102,
became
effective
for
awards
made
on
or
after
October
1,
1988.
The
Part
31
rule
(
common
rule)
established
uniformity
among
Federal
agencies
that
award
Federal
grants
and
cooperative
agreements
to
States,
political
subdivisions
thereof,
and
Federallyrecognized
Indian
Tribal
Governments.
Exhibit
1
identifies
the
tasks
and
burdens
of
grant
recipients
that
are
covered
under
other
OMB­
approved
ICRs.
This
ICR
addresses
the
burden
imposed
on
grant
recipients
and
EPA
associated
with
the
reporting
requirements
that
are
unique
to
grants
awarded
by
EPA
under
authority
of
subtitle
A
of
the
Brownfields
Amendments.

3(
b).
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.
The
first
notification
of
the
Agency's
request
for
this
new
ICR
was
published
in
the
Federal
Register
(
68
FR
16508)
on
April
4,
2003
(
see
Attachment
A
for
a
copy
of
the
Federal
Register
notice).
EPA
received
two
comments
from
one
local
government
official
during
the
sixty­
day
public
comment
period.
One
comment
addressed
reporting
provisions
under
the
Agency's
general
assistance
regulations
at
40
CFR
Parts
30
and
31,
and
does
not
pertain
to
the
reporting
requirements
under
this
ICR.
The
second
comment
recommended
that
EPA
allow
electronic
reporting
to
minimize
grantee
burden.
EPA
agrees
with
this
comment
and,
as
discussed
in
section
5(
b)
of
this
supporting
statement,
is
currently
developing
an
electronic
reporting
process
that
will
allow
grant
recipients
to
report
their
3
data
electronically.
Concurrent
with
the
submission
of
this
ICR
to
OMB,
EPA
is
publishing
a
second
Federal
Register
notice
seeking
public
comments
on
this
ICR.

3(
c).
Consultations
 
EPA
has
more
than
eight
years
of
experience
managing
a
Brownfields
pilot
program
that
awarded
more
than
670
cooperative
agreements
to
State,
local,
and
Tribal
governments
to
address
brownfields
properties.
For
these
Brownfields
pilot
grants,
EPA
staff
have
worked
closely
with
the
pilot
recipients
to
help
them
participate
in
the
program
and
address
their
brownfields
properties.
As
such,
EPA
has
a
detailed
understanding
of
the
activities
that
grantees
undertake
and
the
burden
they
incur
for
voluntarily
participating
in
EPA's
grants
programs.
In
addition,
during
the
preparation
of
this
ICR
and
the
reporting
forms
that
are
included,
EPA
contacted
eight
Brownfields
pilot
recipients
to
ask
them
specific
questions
about
the
burden
associated
with
completing
the
draft
forms
included
in
this
ICR.
Pilot
recipient
responses
form
the
basis
of
EPA's
calculations
of
the
burden
hours
and
costs.

Exhibit
1:
Grant
Burdens
Covered
Under
Other
Agency
ICRs
Task/
Burden
Authority
Agency
Approved
ICR
Preliminary
Grant
Proposal
40
CFR
Parts
30
and
31
OMB
2030­
0020
Final
Grant
Proposal
40
CFR
Parts
30
and
31
OMB
2030­
0020
Budget
Sheets
40
CFR
Parts
30
and
31
OMB
2030­
0020
Quarterly
Progress
Reports
40
CFR
Parts
30
and
31
OMB
2030­
0020
Notification
of
Significant
Developments
40
CFR
Parts
30
and
31
OMB
2030­
0020
Procurement
Reports
40
CFR
Parts
30
and
31
OMB
2030­
0020
Financial
Reports
40
CFR
Parts
30
and
31
OMB
2030­
0020
Project
Records
40
CFR
Parts
30
and
31
OMB
2030­
0020
3(
d).
Effects
of
Less
Frequent
Collection
 
The
information
collection
schedule
is
consistent
with
the
Agency's
reporting
schedule
for
general
assistance
grants.
Less
frequent
collection
may
not
enable
EPA
to
oversee
and
manage
Brownfields
grants
effectively
and
would
lessen
OBCR's
ability
to
report
up­
to­
date
and
accurate
information
on
program
activities
and
accomplishments.
In
consideration
of
the
burden
imposed
on
grantees,
EPA
has
adopted
less
frequent
reporting
for
the
Property
Profile
form
in
which
grantees
are
required
to
update
and
submit
the
form
as
notable
activities
or
changes
occur
at
a
particular
property.
EPA
anticipates
that
recipients
of
assessment,
cleanup,
and
revolving
loan
fund
grants
will
submit
an
updated
Property
Profile
form
to
EPA,
on
average,
two
times
a
year
but
not
more
than
quarterly.

3(
e).
General
Guidelines
 
The
information
collection
is
consistent
with
the
guidelines
set
forth
in
5
CFR
1320.6
of
the
Paperwork
Reduction
Act
Guidelines.
1For
the
purposes
of
the
Brownfields
grant
program,
EPA
defines
general
purpose
unit
of
local
government
as
a
"
local
government"
as
that
term
is
defined
under
40
CFR
Part
31.

2For
the
purposes
of
the
Brownfields
grant
program,
EPA
uses
the
definition
of
nonprofit
organization
contained
in
Section
4(
6)
of
the
Federal
Financial
Assistance
Management
Improvement
Act
of
1999,
Public
Law
106­
107.

4
3(
f).
Confidentiality
 
No
confidentiality
is
provided
and
no
sensitive
information
is
collected
under
this
ICR.

3(
g).
Sensitive
Questions
 
Sensitive
questions
are
not
associated
with
the
information
collection
activities
performed
under
Public
Law
107­
118.

4.
Respondents
and
Information
Requested
4(
a).
Respondents
 
Respondents
under
this
ICR
are
those
entities
who
voluntarily
elect
to
participate
in
the
Brownfields
grants
program
and
receive
grant
funding
from
EPA
under
the
authority
of
subtitle
A
of
the
Brownfields
Amendments.
Specifically,
respondents
to
this
information
collection
include:
general
purpose
units
of
local
government;;
land
clearance
authorities
or
other
quasi­
governmental
entities
that
operate
under
the
supervision
and
control
of,
or
as
an
agent
of,
a
general
purpose
unit
of
local
government;
government
entities
created
by
state
legislature;
regional
councils
or
groups
of
general
purpose
units
of
local
government;
redevelopment
agencies
that
are
chartered
or
otherwise
sanctioned
by
the
State;
States;
Indian
Tribes
other
than
in
Alaska;
Alaska
Native
Regional
Corporations,
Alaska
Native
Village
Corporations,
and
Metlakatla
Indian
Communities;
or
non­
profit
organizations..

4(
b).
Information
Requested
 
The
information
requested
by
EPA
under
this
ICR
includes
information
from
grantees
specific
to
the
activities
undertaken
and
the
accomplishments
that
result
using
Brownfields
grant
funds.
The
information
to
be
collected
by
EPA
will
vary
by
the
type
of
grant
awarded
to
the
respondent.
Brownfields
job
training
grantees
are
required
to
complete
on
a
quarterly
basis
the
Brownfields
Job
Training
Reporting
Form
(
see
Attachment
B).
The
Job
Training
Reporting
Form
seeks
basic
information
on
how
grant
funds
were
used
to
support
job
training
programs
and
the
accomplishments
stemming
from
those
programs.
For
example,
job
training
grantees
will
report
the
number
of
participants
who
have
completed
the
training,
whether
participants
obtained
employment,
and
the
average
hourly
wages
of
participants
who
obtained
employment.

For
Brownfields
assessment,
cleanup,
and
revolving
loan
fund
grants,
EPA
requires
grantees
to
prepare
an
initial
Property
Profile
Form
(
see
Attachment
C)
for
each
property
at
which
grant
funds
are
expended.
The
Property
Profile
Form
complements
the
information
collected
as
part
of
the
quarterly
reports
required
by
the
general
assistance
regulations,
and
requests
basic
information
about
each
brownfields
property
covered
by
the
grant,
such
as
property
name,
location,
parcel
number,
and
size.
EPA
requires
grantees
to
update
the
Property
Profile
Form
as
notable
activities
or
changes
occur
on
the
property,
but
no
more
frequently
than
quarterly.
For
example,
as
an
assessment
of
the
property
is
completed,
grantees
are
required
to
5
complete
the
portion
of
the
Property
Profile
Form
that
applies
to
assessments,
and
provide
basic
information
to
EPA
on
the
type
of
assessment,
date
of
completion,
and
results
or
findings
of
the
assessment.
Other
sections
of
the
Property
Profile
Form
collect
basic
information
on
cleanups
and
any
redevelopment
activities
that
occur
on
the
property,
including
estimates
of
the
number
of
jobs
that
result.

5.
The
Information
Collected
 
Agency
Activities,
Collection,
Methodology
and
Information
Management
5(
a).
Agency
Activities
 
EPA
is
responsible
to
Congress
and
other
stakeholders
to
ensure
that
its
resources
are
being
used
efficiently
and
effectively,
to
evaluate
the
progress
of
the
grantees
in
meeting
the
goals
of
EPA's
Brownfields
Cleanup
and
Revitalization
Program,
and
to
share
the
successes,
lessons
learned,
and
best
practices
among
Brownfields
grantees.
EPA
will
collect
the
information
using
standardized
forms
that
minimize
the
burden
on
respondents
while
ensuring
consistent
information
that
can
be
easily
aggregated
and
accurately
reported.
EPA
program
staff
will
review
the
information
collected
to
keep
current
on
grant
activities,
and
will
enter
the
information
into
the
Agency's
Brownfields
Management
System
(
BMS).
EPA
uses
BMS
to
maintain
information
on
all
of
its
Brownfields
grants,
develop
reports
to
support
management
and
program
evaluation
activities,
and
to
report
accomplishments
achieved
as
part
of
the
Agency's
responsibilities
under
GPRA.

5(
b).
Collection
Methodology
and
Management
 
EPA
will
collect
data
under
this
ICR
using
a
standard
set
of
forms,
instructions,
and
guidance
that
are
designed
to
simplify
and
facilitate
the
reporting
requirements
for
grant
recipients.
In
fulfilling
the
requirements
under
the
Government
Paperwork
Elimination
Act
(
Public
Law
105­
277),
EPA
is
currently
developing
an
electronic
reporting
process
that
will
allow
grant
recipients
to
report
their
data
electronically.
This
electronic
reporting
process
will
be
integrated
with
EPA's
Enterprise
Architecture
to
further
streamline
the
Agency's
data
management
and
reporting
responsibilities.
EPA
expects
that
this
electronic
reporting
process
will
be
available
to
grantees
beginning
in
the
first
quarter
of
FY2004.
EPA
will
modify
its
reporting
guidance
and
provide
training
when
the
electronic
reporting
process
is
in
place.
EPA
anticipates
that
the
electronic
reporting
process
may
reduce
the
burden
placed
on
grant
recipients;
preliminary
estimates
based
on
conversations
with
current
and
former
Brownfields
pilot
recipients
suggest
that
such
a
process
will
reduce
the
reporting
burden
by
an
estimated
20
to
50
percent.

5(
c).
Small
Entity
Flexibility
 
This
information
collection
request
is
expected
to
affect
small
governmental
jurisdictions,
which
are
defined
as
governments
of
cities,
counties,
towns,
townships,
villages,
school
districts,
or
special
districts
with
populations
of
less
than
50,000.
This
definition
may
also
include
Indian
Tribes,
in
keeping
with
the
President's
Federal
Indian
Policy.
EPA
has
considered
whether
to
establish
different
reporting
requirements
for
small
entities
and
has
determined
that:
(
1)
different
reporting
requirements
among
grantees
will
result
in
inconsistent
data
that
may
lessen
the
Agency's
ability
to
oversee
and
report
on
program
activities
and
accomplishments;
(
2)
the
burden
imposed
by
this
information
collection
is
relatively
small
and
small
entities
should
not
be
unduly
burdened
by
the
reporting
requirement;
and
(
3)
the
6
Brownfields
grants
program
is
voluntary
and
respondents
who
elect
to
participate
in
this
program
have
determined
that
the
expected
benefits
of
participation
outweigh
any
burden
associated
with
preparing
the
response.

5(
d).
Collection
Schedule
 
The
information
to
be
collected
under
this
ICR
shall
not
occur
more
frequently
than
quarterly.
Brownfields
Job
Training
grant
recipients
must
complete
and/
or
update
their
Brownfields
Job
Training
Performance
Form
every
quarter.
For
assessment,
cleanup,
and
revolving
loan
fund
grants,
grantees
will
be
required
to
prepare
an
initial
Property
Profile
form
for
each
property
at
which
grant
funds
are
expended,
and
to
update
the
Property
Profile
forms
quarterly
for
only
those
properties
in
which
notable
activities
or
changes
have
occurred.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a).
Estimating
respondent
burden
­
A
"
unit"
burden
is
the
burden
incurred
by
a
respondent
for
performing
a
specific
activity
that
is
not
covered
by
another
ICR
(
such
as
40
CFR
Parts
30
and
31).
The
estimated
burden
is
incurred
by
the
following
activities:

°
Completion
of
the
Brownfields
Job
Training
Reporting
Form;

°
Initial
completion
of
the
Brownfields
Property
Profile
Form;

°
Periodic
updating
of
the
Brownfields
Property
Profile
Form
to
report
progress
on
specific
properties
undergoing
assessment,
cleanup,
or
redevelopment;
and
The
estimated
burden
for
respondents
is
presented
in
Exhibit
2.

If
any
burdens
were
found
to
be
imposed
in
the
ICR
by
a
rule
that
supercedes
the
Brownfields
Amendments,
those
burdens,
or
a
percentage
of
those
burdens,
were
removed
from
the
overall
burden
calculation
in
this
ICR
(
see
Exhibit
1).

6(
b).
Estimating
respondent
costs
­
To
estimate
the
unit
burden
(
hours)
and
hourly
rate
for
each
information
collection
activity,
EPA
relied
on
its
extensive
experience
working
closely
with
Brownfields
pilot
grant
recipients,
as
well
as
in­
depth
interviews
with
eight
current
or
former
pilot
grant
recipients
specific
to
this
ICR.
Those
interviewed
were
shown
draft
copies
of
all
forms
and
accompanying
instructions
and
guidance
that
would
be
used
for
reporting
and
asked
to
estimate:
(
1)
the
number
of
hours
that
would
be
required
to
perform
each
task;
and
(
2)
the
labor
mix
required
to
perform
each
task
(
e.
g.,
percentage
of
management,
technical,
clerical).
The
data
gathered
from
these
interviews
were
then
analyzed
to
estimate
the
unit
burden
and
labor
mix.
Exhibit
2
­
Annual
Respondent
Burden
and
Cost
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
Number
of
Responses/
Year*
Total
Burden/
Year
(
Hours)*
Total
Cost/
Year
(
Dollars)*
7
Job
Training
Performance
Form
5
$
29.57
$
147.85
93
467
$
13,750
Initial
Completion
of
Property
Profile
Form
1
$
29.57
$
29.57
1,225
1,225
$
36,223
Update
of
Property
Profile
Form
1.5
$
29.57
$
44.36
3,752
5,628
$
166,420
TOTAL
5,070
7,320
$
216,393
AVERAGE
TOTAL
COST
PER
BURDEN
HOUR
$
29.57
*
Figures
may
not
sum
due
to
rounding.
3See
Bureau
of
Labor
Statistics
publication
entitled
"
Employer
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation:
state
and
local
government,
by
occupational
group,
December
2002."
http://
stats.
bls.
gov/
news.
release/
ecec.
t04.
htm#
content.

8
The
unit
labor
cost
(
dollars)
for
this
burden
estimate
is
a
weighted
hourly
rate
based
upon
the
estimated
labor
mix
and
wage
rates
gathered
from
the
U.
S.
Bureau
of
Labor
Statistics
(
BLS).
Across
all
tasks,
data
from
consultations
indicate
that
the
average
grantee
will
incur
15
percent
of
its
burden
with
executive/
managerial
staff
labor,
5%
with
professional
specialty
staff
labor,
70
percent
with
technical
labor,
and
10
percent
with
administrative
support
or
clerical
labor.
This
labor
mix
was
applied
to
BLS,
National
Compensation
Survey
(
NCS)
data
issued
in
December
20022
for
a
weighted
hourly
rate
of
$
29.57.

Job
training
grant
recipients
will
be
required
to
report
progress
on
a
quarterly
basis
using
EPA's
"
Job
Training
Reporting
Form
­­
Brownfields"
(
see
Attachment
B).
Grantees
will
be
required
to
report
progress
on
a
quarterly
basis,
with
each
update
requiring
approximately
5
hours
for
a
unit
burden
of
$
147.85.
The
majority
of
this
burden
stems
from
the
collection
of
salary
or
wage
information
from
job
training
program
participants
who
are
able
to
find
employment.

Cleanup,
assessment,
and
revolving
loan
fund
grant
recipients
will
be
required
to
report
progress
with
the
"
Property
Profile
Form
 
Brownfields"
(
see
Attachment
C).
EPA
anticipates
that
the
initial
completion
of
this
form
will
require
approximately
1
hour.
Grantees
will
be
required
to
update
this
form
as
grant
milestones
are
achieved,
though
not
more
frequently
than
quarterly.
It
is
estimated
that
each
update
will
require
approximately
1.5
hours
for
a
unit
burden
of
$
44.36.
It
is
estimated
that
each
form
will
be
updated
an
average
of
twice
per
year.

All
grants
awarded
under
subtitle
A
of
the
Brownfields
Amendments
cover
a
period
of
performance
of
two
years.
Based
on
the
Agency's
experience
under
its
pilot
grants
program,
EPA
estimates
that
at
the
end
of
two
years,
approximately
75
percent
of
grants
will
receive
a
nocost
extension,
approximately
20
percent
of
grantees
will
receive
supplemental
awards,
and
5
percent
of
grants
will
close
out.
Grantees
that
receive
either
a
no­
cost
extension
or
a
supplemental
award
will
be
required
to
continue
to
report
on
their
grant
activities
using
the
forms
authorized
under
this
ICR.
This
burden
is
included
in
the
estimated
number
of
responses
per
year
and,
therefore,
the
overall
burden
calculation
estimated
for
this
ICR.

Start­
up
costs
to
meet
the
Brownfields
grants
reporting
requirements
are
minimal
and
are
a
part
of
the
customary
and
usual
expenses
incurred
by
grantees.
There
are
no
capital
costs
related
to
Brownfields
reporting
requirements.
Therefore,
total
start­
up
and
capital
costs
are
zero.
There
are
no
operation
and
maintenance
costs
required.

6(
c).
Agency
burden
and
costs
­
EPA
incurs
a
burden
in
the
process
of
requesting,
reviewing
and
processing
the
information
covered
by
this
ICR.
This
burden
includes:

°
The
development
of
grant
profiles
with
information
collected
from
grantees;
°
Reviewing
and
processing
Brownfields
Job
Training
Reporting
Forms;
°
Reviewing
and
processing
initial
Brownfields
Property
Profile
Forms;
and
°
Reviewing
and
processing
updates
of
Brownfields
Property
Profile
Forms.
9
10
The
estimated
burden
associated
with
EPA
activities
is
presented
in
Exhibit
3.

Exhibit
3
­
Annual
Agency
Burden
and
Cost
Activity
Unit
Burden
(
Hours)
Unit
Labor
Cost
(
Dollars)
Total
Unit
Cost
(
Dollars)
Average
Number
of
Responses
/
Forms
per
Year
(
Full)
Total
Burden
(
Hours)*
Total
Cost
(
Dollars)*

Preparation
of
Grant
Profile
4.5
$
26.81
$
120.65
203
912
$
24,504
Review
and
Process
Job
Training
Performance
Form
1.5
$
26.81
$
40.22
93
140
$
3,753
Review
and
Process
Initial
Property
Profile
Form
2.5
$
26.81
$
67.03
1,225
3,063
$
82,119
Review
and
Process
Updates
of
Property
Profile
Form
2
$
26.81
$
53.62
3,752
7,503
$
201,182
TOTAL*
11,618
$
311,558
AVERAGE
TOTAL
COST
PER
BURDEN
HOUR
$
26.81
*
Figures
may
not
sum
due
to
rounding
The
burden
imposed
upon
EPA
was
estimated
by:
(
1)
interviewing
EPA
Regional
and
Headquarters
staff
to
gather
individual
estimates
of
the
time
required
to
perform
each
activity
and
the
GS
level
of
the
staff
performing
those
tasks;
(
2)
averaging
the
time
data
to
estimate
the
number
of
hours
required
for
each
burden
element;
(
3)
averaging
the
data
on
the
percentage
of
time
performed
by
particular
staff
GS
levels;
(
4)
developing
a
weighted
hourly
rate
based
upon
percentage
of
staff
labor
at
different
GS
levels
devoted
to
each
task;
and
(
5)
determining
the
product
of
the
weighted
hourly
rate
and
the
number
of
hours
required
per
activity.

The
weighted
hourly
rate
utilized
in
the
Federal
burden
estimate
is
based
upon
the
following
composite:

GS
Level
Percent
Hourly
Wage
Rate*

GS
4,
Step
1
10%
$
10.04
GS
11,
Step
1
10%
$
20.59
GS
13,
Step
1
75%
$
29.35
GS
14,
Step
1
5%
$
34.68
Weighted
Rate
$
26.81
*
Rates
for
2003
General
Schedule
11
6(
d).
Estimated
Respondent
Universe
and
Total
Burden
and
Costs
 
The
estimated
annual
average
number
of
respondents
per
year
for
this
information
collection
is
203
respondents,
with
the
average
total
number
of
responses
per
year
estimated
at
5,070.
As
presented
in
Exhibit
2,
the
total
average
annual
burden
to
respondents
is
7,320
hours
per
year
at
a
cost
of
$
216,393.

6(
e).
Bottom­
line
burden
hours
and
costs
 
Exhibits
2
and
3
provide
the
bottom­
line
burden
hours
and
costs
for
respondents
and
EPA,
respectively.
The
hours
and
costs
presented
in
these
exhibits
represent
the
average
annual
burden
resulting
from
this
information
collection;
the
total
burden
hours
and
costs
for
the
three­
year
period
covered
under
this
ICR
is
estimated
to
be
three
times
the
total
hours
and
costs
provided
in
each
exhibit.

6(
f).
Reasons
for
Change
in
Burden
 
This
is
a
new
information
collection
and,
as
such,
there
is
no
change
in
burden.

6(
g).
Burden
Statement
 
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
5
hours
per
response
for
job
training
grant
recipients,
and
1.25
hours
per
response
for
assessment,
cleanup,
and
revolving
loan
fund
grant
recipients.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
SFUND­
2003­
0004,
which
is
available
for
public
viewing
at
the
OSWER
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
OSWER
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
SFUND­
2003­
0004
and
EPA
ICR
No.
2104.01
in
any
correspondence.
Attachment
A:
Federal
Register
Notice
Seeking
Public
Comment
on
the
Agency's
Information
Collection
Request
for
the
Brownfields
Program
 
Revitalization
Grantee
Reporting
1
