  SEQ CHAPTER \h \r 1 SUPPORTING STATEMENT

1.  Identification of the Information Collection 		

	Title:  Brownfields Program – Revitalization Grantee Reporting (OMB
Control Number 2050-0192; EPA ICR No. 2104.03).  

	This is a request to renew an existing 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 and expand the collection to those eligible entities that
receive grants from EPA under the authority of subtitle C 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 and subtitle C
authorizes a noncompetitive $50 million grant program to establish and
enhance state and tribal response programs. With this ICR, EPA’s
Office of Brownfields and Land Revitalization (OBLR) seeks authorization
to collect information from grant recipients 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 grant recipients 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.  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 subtitle C of the Brownfields Amendments, States and tribes can
receive grants to:

	(1) establish or enhance a State response program that meets the four
elements;

	(2) establish or enhance a public record;

	(3) develop legislation, regulations, procedures, or guidance that
would establish or enhance the legal structure of the State program;

	(4) capitalize a revolving loan fund;

	(5) purchase environmental insurance; and

	(6) carry out site-specific environmental assessment and cleanup
activities.

In 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 hazardous substance, pollutant,
or contaminant.  For grant funding purposes, EPA uses the term
“brownfields property(ies)” synonymously with the term
“brownfields site(s).”  

	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), OBLR needs
additional information from grant recipients 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, OBLR has used and will
continue to use the information collected from grant recipients 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 OBLR’s accomplishments.  The information collection
activities covered by this renewed ICR are intended to:  (1) continue to
improve the alignment of reporting requirements with programmatic
performance measures; and (2) simplify and standardize reporting
requirements to reduce uncertainty and burden imposed on grant
recipients.  Without the information collection, OBLR would have limited
access to information needed to effectively assess the relationship
between those activities funded by EPA’s 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 Federally-recognized 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 subtitles A and C of the Brownfields Amendments.

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(b).  Public Notice Required Prior to ICR Submission to OMB.  The
first notification of the Agency’s request for the renewal of this ICR
was published in the Federal Register on February 6, 2009 (74 FR 6286).
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 ten years of experience
managing a Brownfields grant programs that awarded more than 1,800
cooperative agreements to State, local, and tribal governments to
address brownfields properties.  For these Brownfields grants, EPA staff
have worked closely with the grant recipients to help them participate
in the program and address their brownfields properties.  As such, EPA
has a detailed understanding of the activities that grant recipients
undertake and the burden they incur for voluntarily participating in
EPA’s grant programs.  In addition, during the preparation of the
initial ICR in 2003 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.  Grant recipient responses form the basis of
EPA’s calculations of the burden hours and costs. 

For the first renewal of this ICR in 2006 the ICR was expanded to
include reporting from subtitle C grant recipients. To do so, EPA
consulted with several State and Tribal representatives when working on
modifications to the Property Profile Form. State personnel involved
included:  Barbara Coler, State of California; Andrew Shivas, State of
Tennessee; Mark Walker, State of Colorado; Amy Yersavich, Ohio; and
Catherine Sharp, State of Oklahoma.  Tribal personnel included Susan
Morang, Cherokee Nation.

For this second renewal of the ICR, EPA has added additional fields to
the Property Profile Form. EPA contacted eight Brownfields Grant
recipients to ask them specific questions about the burden associated
with completing the draft new fields for the Property Profile Form
included in this renewal ICR.

	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 OBLR’s ability to report up-to-date and accurate information on
program activities and accomplishments.  In consideration of the burden
imposed on grant recipients, EPA has adopted less frequent reporting for
the Property Profile Form in which grant recipients are required to
update and submit the form as notable activities or changes occur at a
particular property.  EPA anticipates that recipients of subtitle A
assessment, cleanup, and revolving loan fund grants will submit an
updated Property Profile Form to EPA, two times on average a year but
not more than four times a year (i.e. quarterly). For subtitle C State
and tribal response program grants, EPA anticipates that recipients will
submit a Property Profile Form to EPA twice a year in line with the
bi-annual reporting guidelines. 

	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.

	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 grant programs
and receive grant funding from EPA under the authority of subtitle A
and/or C of the Brownfields Amendments.  Specifically, respondents to
this information collection include:   general purpose units of local
government (NAICS Code: 92411); 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 (NAICS Code: 92411); government entities created by State
legislature (NAICS Code: 92411); regional councils or groups of general
purpose units of local government (NAICS Code: 92411); redevelopment
agencies that are chartered or otherwise sanctioned by the State (NAICS
Code: 92411); States (NAICS Code: 92411); Indian Tribes other than in
Alaska (NAICS Code: 92115); Alaska Native Regional Corporations, Alaska
Native Village Corporations, and Metlakatla Indian Communities (NAICS
Code:92115); and non-profit organizations (NAICS Code: 81331).

	4(b).  Information Requested – The information requested by EPA under
this ICR includes information from grant recipients 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 grant recipients are required to complete on a quarterly basis
the Brownfields Job Training Reporting Form.  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 grant recipients 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, revolving loan fund grants, and
property-specific activities of the State Response Program Grants, EPA
requires subtitle A and C grant recipients  to prepare an initial
Brownfields Property Profile Form for each property the grant intends to
address. The Property Profile Form complements the information collected
as part of the progress 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 grant recipients to update the Property
Profile Form as notable activities or changes occur on the property, but
no more frequently than quarterly for subtitle A grant recipients and no
more than twice a year for subtitle C grant recipients.  For example, as
an assessment of the property is completed, grant recipients are
required to 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 grant recipients in meeting
the goals of EPA’s Brownfields Cleanup and Redevelopment Program, and
to share the successes, lessons learned, and best practices among
Brownfields grant recipients.   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 Assessment, Cleanup, and Redevelopment
Exchange System (ACRES), formerly known as the Brownfields Management
System (BMS).  EPA uses ACRES to maintain information on all of its
Brownfields grants’ property specific activities, 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 developed
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 released the electronic reporting process in
January 2007 and all Brownfields grant recipients starting from FY 2003
have been given access.  EPA has modified its reporting guidance and
provides training on the electronic reporting process.  EPA has achieved
early positive returns in user acceptance of the electronic reporting
process since its release and continues to anticipate that the
electronic reporting process may reduce the burden placed on grant
recipients during the next three years of this ICR. Preliminary
estimates based on conversations with current and former Brownfields
grant 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 grant
recipients 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 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 for subtitle A assessment, cleanup, and revolving loan fund
grant recipients shall not occur more frequently than quarterly and no
more than twice a year for subtitle C property specific activities. 
Brownfields Job Training grant recipients must complete and/or update
their Brownfields Job Training Performance Form every quarter.  For
subtitle A assessment, cleanup, revolving loan fund grants, and subtitle
C property specific activities, grant recipients will be required to
prepare an initial Property Profile Form for each property at which the
grant  starts to address, and to update the Property Profile forms for
only those properties in which notable activities or changes have
occurred during the last reporting period. 

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; and

Periodic updating of the Brownfields Property Profile Form to report
progress on specific properties undergoing assessment, cleanup, or
redevelopment.

The estimated burden for respondents receiving grants from the EPA
Brownfields appropriation is presented in Exhibit 2 and the estimated
burden for respondents receiving grants through funding authorized by
the American Recovery and Reinvestment Act of 2009 is presented in
Exhibit 3. 

	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 the original information collection
activity, EPA relied on its extensive experience working closely with
Brownfields grant recipients, as well as in-depth interviews with eight
current or former 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. 

For the expansion and renewal of this information collection request in
2006, EPA carried forward the same assumptions that were made for the
original request. EPA has expanded the information collection request to
include subtitle C grant recipients and uses the original estimates of
time and labor to estimate the increased unit burden.

For this renewal, EPA has added three new fields to the Property Profile
Form, otherwise the forms and data collection remains unchanged. To
estimate the unit burden (hours) and hourly rate for the renewed
information collection activity, EPA conducted in-depth interviews with
eight current grant recipients specific to this ICR.  Those interviewed
were shown draft copies of the new fields 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 for Grantees Receiving
Grants from the EPA Brownfields Appropriation

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)*

Job Training Reporting Form	5	$95.74 	$478.70 	93	465	$44,519 

Initial Completion of Property Profile Form (Subtitle A)	1	$95.74 
$95.74 	1,225	1225	$117,282 

Initial Completion of Property Profile Form (Subtitle C)	1	$95.74 
$95.74 	637	637	$60,986 

Update of Property Profile Form (Subtitle A)	1.5	$95.74 	$143.61 	3,752
5627.5	$538,777 

Update of Property Profile Form (Subtitle C)	1.5	$95.74 	$143.61 	2248
3,372	$322,792 

TOTAL	7,954	11,326	$1,084,356 

AVERAGE TOTAL COST PER BURDEN HOUR	$95.74 

* Unit Labor Cost in Dollars reflects a “loaded” rate for benefits
and overhead.

Exhibit 3 - Annual Respondent Burden and Cost for Grantees Receiving
Grants Through Funding Authorized by the American Recovery and
Reinvestment Act of 2009

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)*

Job Training Reporting Form	5	$95.74 	$478.70 	93	465	$44,519 

Initial Completion of Property Profile Form (Subtitle A)	1	$95.74 
$95.74 	417	417	$39,892 

Update of Property Profile Form (Subtitle A)	1.5	$95.74 	$143.61 	2,895
4342	$415,712 

TOTAL	3,404	5,224	$500,123 

AVERAGE TOTAL COST PER BURDEN HOUR	$95.74 

* Unit Labor Cost in Dollars reflects a “loaded” rate for benefits
and overhead.

	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 percent
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 2008 for a weighted hourly rate of $45.59 and an
estimated fully loaded rate of $95.74.  

					

	Job training grant recipients will be required to report progress on a
quarterly basis using EPA’s “Brownfields Job Training Reporting
Form.”  Grant recipients will be required to report progress on a
quarterly basis, with each update requiring approximately 5 hours for a
unit burden of $478.70.  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.

	Subtitle A cleanup, assessment, and revolving loan fund grant
recipients will be required to report progress with the “Brownfields
Property Profile Form.”  EPA anticipates that the initial completion
of this form will require approximately 1 hour.  Grant recipients 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 $143.61.  It
is estimated that each form will be updated an average of twice per
year. 

	Cleanup and assessment grants awarded under subtitle A of the
Brownfields Amendments cover a period of performance of two years, and
revolving loan fund grants cover a period of performance up to 5 years.
Based on the Agency’s experience under its grants program, EPA
estimates that at the end of two years, approximately 75 percent of
grants will receive a no-cost extension, approximately 20 percent of
grant recipients will receive supplemental awards, and 5 percent of
grants will close out.  Grant recipients 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. In
addition, grants that have closed out may undergo a five-year review
conducted five years after close out. The five year review gathers data
on the current status of properties that benefited from EPA funding
while the grant was active 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.

	Subtitle C grant recipients that conduct property specific activities
will be required to report progress with the “Brownfields Property
Profile Form.”  EPA anticipates that the initial completion of this
form will require approximately 1 hour.  Grant recipients will be
required to update this form as grant milestones are achieved, though
not more frequently than twice a year.  It is estimated that each update
will require approximately 1.5 hours for a unit burden of $143.61.  It
is estimated that each form will be updated an average of twice per
year. 

	All grants awarded under subtitle C of the Brownfields Amendments have
at least a one year period of performance or can be a multi-year grant
depending on the State’s financial need for continued funding. Based
on the Agency’s understanding of State response programs, EPA
estimates that one-half of the State grant recipients have sophisticated
response programs and can complete property specific activities with in
one year, therefore submitting a total of two responses. EPA further
estimates that the remaining State, tribal, and US territories that
receive grant funding take two years to complete property specific
activities therefore submitting a total of four responses.	

	Start-up costs to meet the Brownfields grants reporting requirements
are minimal and are a part of the customary and usual expenses incurred
by grant recipients.  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:

	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.

The estimated burden associated with EPA activities for respondents with
a grant from the EPA Brownfields appropriation is presented in Exhibit 4
and the estimated burden associated with EPA activities for respondents
with a grant funded by the American Recovery and Reinvestment Act of
2009 is presented in Exhibit 5. 

.  Exhibit 4 - Annual Agency Burden and Cost for Grants from the EPA
Brownfields Appropriation

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

Review and Process Job Training Reporting Form	1.5	$49.46 	$74.19 	93
140	$6,900 

Review and Process Initial Property Profile Form (Subtitle A)	2.5	$49.46
	$123.65 	1,225	3,063	$151,471 

 Review and Process Initial Property Profile Form (Subtitle C)	2.5
$49.46 	$123.65 	637	1,593	$78,765 

Review and Process Updates of Property Profile Form (Subtitle A)	2
$49.46 	$98.92 	3,752	7,503	$371,115 

Review and Process Updates of Property Profile Form (Subtitle C)	2
$49.46 	$98.92 	2248	4,495	$222,342 

TOTAL	7,954	16,793	$830,593 

AVERAGE TOTAL COST PER BURDEN HOUR	$49.46 



* Unit Labor Cost in Dollars reflects a “loaded” rate for benefits
and overhead.

Exhibit 5 - Annual Agency Burden and Cost for Grants from the American
Recovery and Reinvestment Act of 2009

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

Review and Process Job Training Reporting Form	1.5	$49.46 	$74.19 	93
140	$6,900 

Review and Process Initial Property Profile Form (Subtitle A)	2.5	$49.46
	$123.65 	417	1,042	$51,521 

Review and Process Updates of Property Profile Form (Subtitle A)	2
$49.46 	$98.92 	2,895	5,789	$286,347 

TOTAL	3,404	6,971	$344,767 

AVERAGE TOTAL COST PER BURDEN HOUR	$49.46 

* Unit Labor Cost in Dollars reflects a “loaded” rate for benefits
and overhead.

	The burden imposed upon EPA was initially 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.  

	

	For the renewal and expansion of this information collection request,
EPA is using the same estimates that were used to initially calculate
the federal burden. 

	

	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%	$11.57

GS 11, Step 1	10%	$23.74

GS 13, Step 1	75%	$33.84

GS 14, Step 1	5%	$39.98

Weighted Rate  	$30.91

*Rates for 2009 General Schedule
(http://www.opm.gov/oca/09tables/html/gs_h.asp)

	6(d).  Estimated Respondent Universe and Total Burden and Costs – The
estimated annual average number of respondents per year for this
information collection is 544 respondents (294 respondents receiving
grants from the EPA Brownfields appropriation and 250 respondents
receiving grants through the American Recovery and Reinvestment Act of
2009), with the average total number of responses per year estimated at
11,358 (7,954 responses from respondents receiving grants from the EPA
Brownfields appropriation and 3,404 responses respondents receiving
grants through the American Recovery and Reinvestment Act of 2009).  As
presented in Exhibits 2 & 3, the total average annual burden to
respondents is 16,550 hours per year at a cost of $1,584,479.

	6(e).  Bottom-line burden hours and costs – Exhibits 2 - 5 provide
the bottom-line burden hours and costs for respondents and EPA, and are
summarized below. 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.

Bottom-Line Annual Respondent Burden and Costs

Annual Responses	11,358

Annual Hour Burden	16,550

Annual Costs	$1,584,479



Bottom-Line Annual EPA Burden and Costs

Annual Responses	11,358

Annual Hour Burden	23,764

Annual Costs	$1,175,360



	6(f).  Reasons for Change in Burden – There are two reasons for the
increase in burden. The first reason is that the EPA Brownfields Program
was the beneficiary of $100 million in funding from the American
Recovery and Reinvestment Act of 2009, the majority of which is going
towards awarding approximately 200 additional grants in the first year
of the ICR. EPA had to include these stimulus grantees into its ICR in
order to collect Property Profile Form data or JT Form data to measure
environmental accomplishments. The second reason is that the EPA
Brownfields Program has increased its fully-loaded rates to account for
increases in the cost of benefits and overhead incurred by grant
recipients and EPA staff impacted by this data collection. This is the
first benefits and overhead rate adjustment since the Brownfields ICR
was first approved in 2003.

	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 subtitle A assessment, cleanup, and revolving
loan fund and subtitle C 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.
EPA-HQ-SFUND-2009-0078, which is available for public viewing at the
Superfund Docket in the EPA Docket Center (EPA/DC),  EPA West, Room
3334, 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 Superfund
Docket is (202) 566-0276. An electronic version of the public docket is
available at www.regulations.gov.  This site can be used 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 EPA.  Please include the EPA Docket ID No.
EPA-HQ-SFUND-2009-0078 and OMB Control Number 2050-0192 in any
correspondence.

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

NAICS Codes as of 2002. Source:   HYPERLINK
"http://www.census.gov/epcd/naics02/naicod02.htm" 
http://www.census.gov/epcd/naics02/naicod02.htm   

	4See 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,
March 2005
http://stats.bls.gov/news.release/ecec.t0⸴瑨⍭潣瑮湥⹴†–䑁
䅖䍎⁅摜ㄠᔲ഍ഃЍ഍ഃЍ഍഍഍഍഍഍഍഍ഀ

഍഍഍഍ഀ

഍഍഍഍ഀ

഍഍഍഍ഀ

6

