

SUPPORTING STATEMENT

INFORMATION COLLECTION FOR THE 

GREAT LAKES ACCOUNTABILITY SYSTEM

U.S. ENVIRONMENTAL PROTECTION AGENCY

GREAT LAKES NATIONAL PROGRAM OFFICE

March 2010TABLE OF CONTENTS

    Page                                                                
                                                                   

pART a of the supporting
statement………………………………………………..1  TOC
\o "1-4" \h \z \u  

  HYPERLINK \l "_Toc257649551"  1.	Identification of the Information
Collection	  PAGEREF _Toc257649551 \h  1  

  HYPERLINK \l "_Toc257649552"  1(a)	Title of the Information Collection
  PAGEREF _Toc257649552 \h  1  

  HYPERLINK \l "_Toc257649553"  1(b)	Short Characterization/Abstract	 
PAGEREF _Toc257649553 \h  1  

  HYPERLINK \l "_Toc257649554"  2.	Need for and use of the Collection	 
PAGEREF _Toc257649554 \h  2  

  HYPERLINK \l "_Toc257649555"  2(a)	Need/Authority for the Collection	 
PAGEREF _Toc257649555 \h  2  

2(b)	Practical Utility/Users of the
Data…………………………………………………………
…………………2

3.     NON DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA…2

  HYPERLINK \l "_Toc257649556"  3(a)	Non duplication	  PAGEREF
_Toc257649556 \h  2  

  HYPERLINK \l "_Toc257649557"  3(b)	Public Notice Required Prior to ICR
submission to OMB	  PAGEREF _Toc257649557 \h  3  

  HYPERLINK \l "_Toc257649558"  3(c)	Consultations	  PAGEREF
_Toc257649558 \h  3  

  HYPERLINK \l "_Toc257649559"  3(d)	Effects of Less Frequent Collection
  PAGEREF _Toc257649559 \h  4  

  HYPERLINK \l "_Toc257649560"  3(e)	General Guidelines	  PAGEREF
_Toc257649560 \h  4  

  HYPERLINK \l "_Toc257649561"  3(f)	Confidentiality	  PAGEREF
_Toc257649561 \h  4  

  HYPERLINK \l "_Toc257649562"  3(g)	Sensitive Questions	  PAGEREF
_Toc257649562 \h  4  

  HYPERLINK \l "_Toc257649563"  4.	The Respondents and the Information
Requested	  PAGEREF _Toc257649563 \h  4  

  HYPERLINK \l "_Toc257649564"  4(a)	Respondents/NAICS Codes	  PAGEREF
_Toc257649564 \h  4  

  HYPERLINK \l "_Toc257649565"  4(b)	Information Requested	  PAGEREF
_Toc257649565 \h  4  

  HYPERLINK \l "_Toc257649566"  (i)	Data items, including record keeping
requirements	  PAGEREF _Toc257649566 \h  5  

(ii)       HYPERLINK \l "_Toc257649567"  Respondent Activities	  PAGEREF
_Toc257649567 \h  6  

  HYPERLINK \l "_Toc257649568"  5.	The Information Collected–Agency
Activities, Collection Methodology, and Information Management	  PAGEREF
_Toc257649568 \h  6  

  HYPERLINK \l "_Toc257649569"  5(a)	Agency Activities	  PAGEREF
_Toc257649569 \h  6  

  HYPERLINK \l "_Toc257649570"  5(b)	Collection Methodology and
Management	  PAGEREF _Toc257649570 \h  7  

  HYPERLINK \l "_Toc257649571"  5(c)	Collection Schedule	  PAGEREF
_Toc257649571 \h  7  

                                                                        
                                                                        
  Page

  HYPERLINK \l "_Toc257649572"  6.	Estimating the Burden and Cost of the
Collection	  PAGEREF _Toc257649572 \h  7  

  HYPERLINK \l "_Toc257649573"  6(a)	Estimating Respondent Burden	 
PAGEREF _Toc257649573 \h  7  

  HYPERLINK \l "_Toc257649574"  6(b)	Estimating Respondent Costs	 
PAGEREF _Toc257649574 \h  8  

  HYPERLINK \l "_Toc257649575"  (i)	    Estimating Labor Costs	  PAGEREF
_Toc257649575 \h  8  

  HYPERLINK \l "_Toc257649576"  (ii)	Estimating Capital and Operations
and Maintenance Costs	  PAGEREF _Toc257649576 \h  10  

  HYPERLINK \l "_Toc257649577"  6(c)	Estimating Agency Burden and Cost	 
PAGEREF _Toc257649577 \h  10  

  HYPERLINK \l "_Toc257649578"  6(d)	Estimating the Respondent Universe
and Total Burden and Costs	  PAGEREF _Toc257649578 \h  11  

  HYPERLINK \l "_Toc257649579"  6(e)	Bottom Line Burden Hours and Cost
Tables	  PAGEREF _Toc257649579 \h  11  

  HYPERLINK \l "_Toc257649580"  (iii)	Variations in the Annual Bottom
Line	  PAGEREF _Toc257649580 \h  12  

  HYPERLINK \l "_Toc257649581"  6(g)	Burden Statement	  PAGEREF
_Toc257649581 \h  12  

 

Appendix A:   Comments on the public notice for the proposed information
collection for the Great Lakes Accountability System and EPA’s
response

APPENDIX b: completed QUESTIONNAIREs FOR THE INFORMATION COLLECTION FOR
THE GREAT LAKES ACCOUNTABILITY SYSTEM

Racine, Wisconsin

New York State Department of Environmental Conservation

Michigan Department of Environmental Quality

Alliance for the Great Lakes 

Pennsylvania Sea Grant

Keweenaw Bay Indian Community

APPENDIX C: Summary tables – Respondent cost and burden calculations

Appendix d: january 5, 2010 federal register notice announcing 60 day
public comment period on the great lakes accountability system 

list of tables

                                                                        
                                                                        
           Page

Table 1.  Consultation Participants by Type of
Organization………………………………………………3

Table 2.  Federal Consultation
Participants……………………………………………………
…………...3

Table 3.  List of Respondent
Activities……………………………………………………
…………….....6

Table 4.  Collection
Schedule………………………………………………………
………………………7

Table 5.  Annual Burden Estimate Per
Project………………………………………………………
…..7

Table 6. Annual Burden/Cost Estimate Per Project for State, Local and
Tribal Government Agencies...8

Table 7. Annual Burden/Cost Estimate Per Project for Non-governmental
Organizations……………...9

Table 8. Annual Burden/Cost Estimate Per Project for Federal
Agencies………………………………9

Table 9.  Total Annual Federal Administrative Burden/Cost
Estimate…………………………………10

Table 10. Annual Burden
Estimate………………………………………………………
……………….10

Table 11.  Bottom Line Burden Hours and Cost
Tables…………………………………………………..11

PART A OF THE SUPPORTING STATEMENT

1.	Identification of the Information Collection

1(a)	Title of the Information Collection

Great Lakes Accountability System (EPA ICR Number 2379.01, OMB Control
Number 2005 NEW)

1(b)	Short Characterization/Abstract

This new request for an information collection is needed to assist with
the administration of the Great Lakes Restoration Initiative (GLRI). 
The GLRI is a new $475 million multi-year program to restore the Great
Lakes that was included in the Department of the  Interior, Environment,
and Related Agencies Appropriations Act, 2010 (Public Law 111-88).  It
will be guided by a 5 year action plan that sets goals, criteria for
measuring progress and clear standards of accountability.  GLRI funding
will be distributed by the Environmental Protection Agency (EPA) through
both its own programs and those of other federal agencies.  A
substantial portion of the funding will be administered to non-federal
partners through grants, cooperative agreements and contracts.

The Conference Report accompanying Public Law 111-88, House Report
111-316 (H. R. 111-316), directed EPA to develop a process that,
“Ensures monitoring and reporting on the progress of the Great Lakes
Restoration Initiative….”  EPA's Great Lakes National Program Office
(GLNPO) developed the Great Lakes Accountability System (GLAS) as the
primary mechanism for collecting information to monitor and report on
GLRI progress.  

The GLAS is a web-based reporting system that is available at  
HYPERLINK "https://restore.glnpo.net:8080/login.htm" 
https://restore.glnpo.net:8080/login.htm .  GLRI funding recipients will
be required to enter information into GLAS on the nature of the
activity, responsible organization, organizational point-of-contact,
resource levels, geographic location and major milestones of progress
toward GLRI goals.  The information will be organized around focus areas
to align activities with the GLRI Action Plan goals and measures.  The
information contained in the GLAS will be available to the public after
undergoing EPA review to verify its accuracy .   

The GLAS will provide transparency on GLRI activities and funds and form
the basis for reports to the President and Congress on the GLRI.  The
information in GLAS will be updated quarterly. Timely and accurate
reporting will be critical.

  

GLNPO estimates the total annual respondent cost and burden to be
$1,274,150.40 (as of  March 29, 2010).  The annual federal cost to
administer this information collection is estimated to be $36,181.25 (as
of March 29, 2010), which results in a total annual cost of
$1,310,331.65.  An overview of the cost and burden hours is provided
below:

Respondents/Affected Entities: Great Lakes Restoration Initiative
Funding Recipients 

Estimated total number of potential non-federal respondents: 594 (463
state, local and tribal governments, 131 non-government organizations).

Estimated number of projects per non-federal respondent: 1

Number of federal respondents: 15

Estimated number of projects per federal respondent: 3.3  (50 projects
spread across 15 federal agencies)

Frequency of response per project:  Quarterly

 

	Estimated total annual burden hours: 21,613 hours (33 hours per project
for state, local, and tribal governments, 41.1 hours per project for
non-government organizations and 19 hours per project for federal
agencies). 

2.	Need for and use of the Collection

2(a)	Need/Authority for the Collection

Collecting information from more than 10 non-federal partners is needed
to effectively provide transparency and accountability for the GLRI. 
H.R.111-316 calls for EPA to, 

“Ensure monitoring and reporting on the progress of the Great Lakes
Restoration Initiative, using scientific research to revise restoration
priorities as needed, and adapt and modify activities beginning in
fiscal year 2011.”

Consistent with this direction, GLRI funding recipients will be required
to submit information about activities and report progress against
measures in the GLRI Action Plan.  The GLAS is the primary mechanism for
collecting information on GLRI activities.    

2(b) Practical Utility/Users of the Data

The primary users of the data are EPA, other government agencies,
non-profit organizations, universities and the public.  The information
in GLAS will be used to catalog the resources and actions that are
implemented under the GLRI and to track progress.  It will serve as the
basis for reports to the President and Congress.  The public will be
able to view activities across the basin, with details such as how much
funding the activity has received and which organizations are involved.
The GLAS is a key component of the GLRI.

3.  Non duplication, Consultations, and Other Collection Criteria

3(a)	Non duplication

GLNPO conducted research into other EPA programs and other federal
agency programs, and state agency/department or non-governmental
organizations to determine whether any organization had information
pertinent to the GLRI Action Plan.  Within EPA, it was confirmed that
only the GLNPO had the pertinent information.  No information similar to
that requested for the GLAS was identified in the state, local and
tribal government agencies and non-governmental organizations.

Pursuant to this research, GLNPO concluded that activity and funding
information required in the GLAS is specific and unique to the GLRI’s
goals of protection and habitat restoration.  The GLAS is the only
reporting system used to quarterly collect comprehensive information
about activities and funding levels.   

Several federal agencies have their own restoration project databases
into which some GLRI project information will be entered.   To minimize
burden and avoid duplication, efforts are underway to develop a
mechanism for importing relevant data fields from these systems into
GLAS.  

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

GLNPO solicited public comments on this ICR in the Federal Register
(Volume 75, page 362, published January 5, 2010).  As of the close of
the comment period, on March 9, 2010, EPA received one set of public
comments on this ICR.  The comments and GLNPO’s responses are
contained in Appendix A.  

3(c)	Consultations

GLNPO invited seven non-federal organizations to participate in
consultations to estimate their annual cost and burden for using the
GLAS.  The consultations are in keeping with ICR guidance to consult
with no-more than nine non-federal organizations.  GLNPO provided the 

participating organizations with accountability system demonstrations.
GLNPO prepared and  distributed a questionnaire for respondents to
complete with burden estimates for labor costs associated with reporting
activities, capital/startup costs, and operations and maintenance costs.
 GLNPO also conducted phone consultations to review responses and
clarify as needed. Table 1 provides a list of organizations asked to
participate in consultations.  Not all chose to participate.  

Table 1.  Consultation Participants by Type of Organization

Name	Phone Number	Affiliation

State, Local, and Tribal Government Agencies

Julie Kinzelman	(262) 636-9501	City of Racine, Wisconsin, Health
Department

Rick Hobrla	(517) 335-4173	Michigan Department of Natural Resources and
Environment

Chris O’Connor	(518) 402-9140	New York Department of Environmental
Conservation

Mark Kwitowski	(814) 870-1593	City of Erie, Pennsylvania

Todd Warner	(906) 524-5757 ext. 13	Keweenaw Bay Indian Community

Private / Non-Governmental Organizations

Michelle Liebetreu	(857) 399-6219	Alliance for the Great Lakes

Dave Skellie	(814) 217-9014	Pennsylvania Sea Grant

GLNPO has received completed questionnaires from six respondents.  

In addition, GLNPO conducted a demonstration of the GLAS for Wisconsin
Department of Natural Resources staff on March 4, 2010 and for
representatives of the organizations listed below at a Great Lakes
Habitat/Species Workgroup on March 17, 2010:

U.S. Fish and Wildlife Service

U.S. Army Corps of Engineers

National Oceanic and Atmospheric Administration

Natural Resources Conservation Service

Great Lakes Fishery Commission

Great Lakes Commission

Wisconsin Department of Natural Resources

Ducks Unlimited

Council of Great Lakes Governors

Wisconsin Wetlands Association

Environmental Consulting and Technology, Inc.

GLNPO based the federal burden estimate on EPA’s experience because it
is the agency most familiar with the system.  

Table 2.  Federal Consultation Participants

Name	Phone Number	Affiliation

Rita Cestaric	(312) 886-6815	U.S. Environmental Protection Agency, GLNPO

Ken Klewin	(312) 886-4794	U.S. Environmental Protection Agency, GLNPO

3(d)	Effects of Less Frequent Collection

If the information is not collected, it will be impossible to provide
accountability on the expenditure of Federal funds under the GLRI or to
evaluate progress.  Quarterly submissions of information are required to
provide timely information to ensure Federal monies are properly used
and report progress.  

3(e)	General Guidelines

This information collection is consistent with all of OMB’s general
guidelines.

Respondents are asked to report quarterly.

Respondents are provided more than 30 days to respond to the data call.

Respondents are not required to submit more than one copy of original
documents.

This information collection does not use a statistical survey.

Respondents do not receive a pledge of confidentiality in regard to the
information collection.  No information is confidential or personal; all
is considered public.

Respondents are not asked to submit proprietary or confidential
information.

3(f)	Confidentiality

Information in the GLAS is not of a confidential nature.  

3(g)	Sensitive Questions

None of the requested information is considered to be of a sensitive
nature.

4.	The Respondents and the Information Requested

4(a)	Respondents/NAICS Codes

The respondents for this ICR are the recipients of GLRI funding, which
includes federal, state, and local agencies (NAICS 924110 and 924120),
non-governmental organizations (e.g., environment, conservation, and
wildlife organizations in NAICS 813312), and other program partners.  

4(b)	Information Requested

Information from GLRI funding recipients will be collected through the
web-based GLAS.  

(i)	Data items, including record keeping requirements

GLRI funding recipients provide information about the activities they
undertake to restore and protect the Great Lakes.  Once logged in to the
GLAS, the funding recipients enter data about their activities, which
are grouped by focus and program areas.  GLNPO does not impose
additional recordkeeping requirements on any respondent.  States and
other entities may impose their own recordkeeping requirement that is
separate from the GLAS.  Specific data items entered into the GLAS
include:

Project reporting elements

Focus area – A broad programmatic area in the Action Plan to organize
restoration activities.  The focus areas are predefined in GLAS. 
Mandatory field.    

Program area – Specific thematic program areas organized as a subset
of the focus areas.  Program areas are predefined in GLAS.  Mandatory
field.

Project type -  A function such as monitoring or restoration that
supports a program area. Project types are predefined in GLAS. 
Mandatory field.

	- 

	       Project and funding reporting elements

Project title – Mandatory field

Project description – Mandatory field.

Quality Assurance Plan required and date of approval– Check yes or no.
If yes, provide date of approval.  Mandatory field.

Lead organization/contact information – Basic details necessary to
identify and contact project managers.  The lead organizations are
predefined in GLAS.  Mandatory field.

Collaborating organizations – A list of other organizations providing
resources for the project.  The lead organizations are predefined in
GLAS.  Optional field.

GLRI funding amount/funding year -   Specifies total GLRI dollars and
the fiscal year in which the funding was provided.  The funding year is
predefined in GLAS.  Mandatory field.

Other funding amount/funding source – Non-GLRI dollars allocated for
the project and the source of the funds.  Optional field.  

FTEs – The total number of full time equivalents per quarter that are
funded with GLRI funds.  Mandatory field.

Project status/date-  An identifier such as current or completed that
identifies the status of the project as of a specific date.  The project
status and date are predefined fields in GLAS.  Mandatory field.

Pertinent GLRI performance measures  -  A quantitative summary metric
for evaluating progress.  Performance measures are predefined in GLAS. 
Mandatory field.

Location

Street address, city state and zip code for the funding recipient-
Mandatory field.

Congressional district of funding recipient – This field is predefined
in GLAS.  Mandatory field.

Watershed or 8-digit hydrologic unit code for the project – This field
is predefined in GLAS.  Mandatory field.

Area of Concern (AOC) – This field in predefined in GLAS.  Mandatory
field if the project is located in an AOC.  

State, latitude/longitude, Congressional district – Project location
information.  Optional field.

Links to the GLRI Action Plan

GLRI long term goal, interim measure and measure of progress –
Relevant GLRI Action Plan goals and measures for the project. At a
minimum, information must be entered into one of these fields for each
project.  These fields are predefined in GLAS.  

Milestones

Schedule, description and status – A short description, schedule and
status for key project events.  Mandatory field. 

(ii)	Respondent Activities

GLRI grant recipients conduct the following activities to assemble,
submit, and store the data items identified above (Table 3).  These
activities reflect the items of burden mandated by the 1995 Paperwork
Reduction Act.  

Table 3.  List of Respondent Activities 

Activity	Record Keeping	Reporting	GLNPO1

Preparing to Use the System.  EPA provides detailed instructions for
entering data online and through training workshops.  Gathering and
reviewing the data to be entered, and organizing it by GLRIAP goal is a
typical activity as part of common business practices.  

X	X

Obtaining Access.  No special technology or systems are required for
this collection as the GLAS is Web-based.  Internet access is a standard
business tool.  EPA establishes user IDs and passwords for each
reporting organization.

X	X

Entering Records.  GLRI grant recipients will review pre-populated
system elements, and review data entered by their project partners to
ensure no duplicative data.  Records about new activities will be
entered as appropriate. 

X

	Reviewing and Verifying Records.  Reviewing and verifying the accuracy
of the data entered into the system is typical of standard business
practice.   

X	X

Feedback and Evaluation.  Users of the GLAS are encouraged to provide
feedback on the system.  

X

	1. Common Business Practice

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

5(a)	Agency Activities   

Activities undertaken by GLNPO on a quarterly basis for this information
collection include:

Update reporting guidance and system instructions

Notify system users of data call

Conduct training

Update Web site

Solicit and compile feedback from users

Respond to user comments and questions.

5(b)	Collection Methodology and Management

GLNPO will use the Web-based GLAS available at   HYPERLINK
"http://restore.glnpo.net:8080/glas.login.htm" 
http://restore.glnpo.net:8080/glas.login.htm  to collect data from the
GLRI grant recipients.  Each reporting organization will be assigned a
user ID and password.  EPA has established security measures to protect
data that have been entered, including maintaining the data on a secure
server on a secure network, confirming the data with each reporting
organization, and making only summarized information available to the
public.

In preparation for the quarterly data call, EPA/GLNPO will provide
detailed guidance about the database to the GLRI fund recipients (e.g.,
organize training/workshops, facilitate hands-on demonstrations as
necessary).  GLNPO will also verify the accuracy of the data entered
into the system during and after the data call.  Quarterly updating by
the GLRI fund recipients will be streamlined in light of the automated
nature of compiling the information.  To improve the efficiency of
entering data, a cloning button is available during data entry that
allows users to make a copy of the data for the next fiscal year (i.e.,
clone the 2010 data to create and modify a record for 2011).

5(c)	Collection Schedule

The information collection is based on a quarterly collection of data on
the activities of the GLRI grant recipients.  Table 4 shows a typical
quarterly or 3-month collection schedule.

Table 4.  Collection Schedule 

DATE 	ACTIVITY 

Month 1	Outreach to GLRI fund recipients

Conduct workshops / feedback sessions 

Month 1	Data call sent to GLRI funding recipients 

Month 2	Data entry complete  

Month 3 	Accuracy check by GLNPO

6.	Estimating the Burden and Cost of the Collection 

The consultations to determine the annual cost and burden estimates for
using the GLAS are complete.  The final estimates are detailed in the
subsections that follow.

6(a)	Estimating Respondent Burden

Burden hour estimates are based on the responses to the consultation
questionnaires and follow-up discussions where needed with respondents. 
Respondents provided annual burden estimates on a per project basis. 
Each project will require the initial entry and quarterly updates.  The
respondents include state, local and  tribal governments and
non-governmental organizations identified in Section 3(c). 
Additionally, federal burden is included based on EPA estimates, as
identified in Section 3(c).  Annual estimates for each type of
respondent are provided in Table 5.  For the Fiscal Year (FY) 2010, EPA
estimates 458 projects conducted by non-federal entities to be awarded
GLRI funding in FY2010. Assuming continued project funding under the
GLRI, EPA estimates that 288 new awards will be made to non-federal
entities in years two and three. Using these assumptions and assuming
that one project is entered or updated by a single respondent, EPA
estimates that 458 projects will need quarterly updates during year one,
746 projects will need updating during year two and 576 projects will
need to be updated during year three (assumes 458 projects completed
will be completed and not require updates in year three). Annualizing
over three years (458, 458 + 288, 288 + 288), there will be 594
non-federal respondents and quarterly updates per year.

For FY 2010, GLNPO estimates that  14 federal agencies will be awarded
GLRI funding for between 40 - 50 new projects.  Assuming continued
project funding under the GLRI, EPA estimates that between 20 – 25 new
awards will be made to federal entities in years two and three.   Using
these assumptions, GLNPO estimates that 50 federal projects will need
quarterly updates during years one, two and three (assumes 50 projects
will be completed and not require updates in year three).  Annualizing
over three years (50, 25 + 25, 25 + 25), there will be 14 federal
respondents and 50 quarterly updates per year.  

Table 5. Estimated Annual Burden  Per Project

Respondent Type 	Annual Burden Per Project

State, Local, and Tribal Government Agencies 	33 hours

Non-Governmental Organizations	41.1 hours

Federal Agencies	19 hours

6(b)	Estimating Respondent Costs

 (i)	Estimating Labor Costs

Table 6 presents the annual respondent burden/cost estimate for state,
local, and tribal government respondents.  Labor rates were derived from
information published by the Bureau of Labor and Statistics (BLS) for
May 2008 (the most recent available data) and include a benefits
multiplier of 1.5.  BLS labor rates used in the calculations have the
following Standard Occupational Categories: 11-0000 (Management
Occupations), 19-0000 (Life, Physical, and Social Science Occupations),
and, 43-0000 (Office and Administrative Support Occupations).  GLNPO
escalated wages and benefits from May 2008 values to December 2009
values using the Employment Cost Index for total compensation of state
and local government employees.  The index value for the second quarter
of 2008 is 109.9 and the index value for the fourth quarter of 2009 is
114.1.  The resulting escalation factor is 1.038.  Labor rates were also
increased by 17 percent to account for overhead.  For each labor
category, the labor rate is the average of a calculated rate for state
employees and a calculated rate for local government agency staff.  

Table 6.  Estimated Annual Burden/Cost Per Project for State, Local, and
Tribal Government Agencies 

Information Collect Activity	Annual Hours Per Project	Annual

Labor Cost Per Project	Annual Capital or Startup Costs Per Project
Annual O&M Cost Per Project	Total

	Managerial ($65.37/

hour)	Technical ($48.27/

hour)	Clerical ($30.83/

hour)



Annual Hours Per  Project 	Annual Costs Per Project

Preparing to Use the System	8.6	7.5	0	$924.19 	$0.00 	$0.00 	16.1
$924.19 

Obtaining Access	0.4	0.8	0	$64.76 	$0.00 	$0.00 	1.2	$64.76 

Entering Records	5.9	4.60	0	$607.71 	$0.00 	$0.00 	10.50	$607.71 

Reviewing and Verifying Records	1	2.80	0	$200.52 	$0.00 	$0.00 	3.80
$200.52 

Feedback and Evaluation	0.9	0.50	0	$82.97 	$0.00 	$0.00 	1.40	$82.97 

Total	16.8	16.2	0	$1,880.14	$0.00 	$0.00 	33	$1,880.14

Sources:	Hour burden estimates are averages across consultees. Wage
rates are based on BLS mean wages for State agencies (  HYPERLINK
"http://www.bls.gov/oes/2008/may/naics4_999200.htm"
http://www.bls.gov/oes/2008/may/naics4_999200.htm ), Local government
agencies, (  HYPERLINK
"http://www.bls.gov/oes/2008/may/naics4_999300.htm"
http://www.bls.gov/oes/2008/may/naics4_999300.htm ), and. BLS 2010
Employment Cost Index, Series ID CIS30100000000001 (state and local
government) (customized tables at:   HYPERLINK
"http://www.bls.gov/ncs/ect/" \l "data" http://www.bls.gov/ncs/ect/#data
; accessed 3/3/2010).

Note: numbers may not add up across all rows and columns due to
rounding.

Table 7 presents the annual respondent burden/cost estimate for
non-governmental organizations.  State/local/tribal government labor
rates used in Table 6 are used for non-governmental labor rates in this
table.  Since non government wage rates tend to be slightly lower than
state/local/tribal government wage rates, the use of the
state/local/tribal government wage rates in these calculations provides
conservative estimates. 

Table 7. Estimated Annual Burden/Cost Per Project  for Non-governmental
Organizations 

Information Collect Activity	Annual Hours Per Project	Annual Labor Cost
Per Project	Annual Capital or Startup Cost Per Project	Annual O&M Cost
Per Project	Total

	Managerial ($65.37/

hour)	Technical ($48.27/

hour)	Clerical ($30.83/

hour)



Annual Hours Per Project	Annual Cost Per Project

Preparing to Use the System	25	3	0	$1,779.08 	$0.00 	$0.00 	28	$1,779.08


Obtaining Access	0.5	0.3	0	$47.17 	$0.00 	$0.00 	0.8	$47.17 

Entering Records	6.5	1.3	0	$487.66 	$0.00 	$0.00 	7.8	$487.66 

Reviewing and Verifying Records	4	0	0	$261.49 	$0.00 	$0.00 	4	$261.49 

Feedback and Evaluation	0.5	0	0	$32.69 	$0.00 	$0.00 	0.5	$32.69 

Total	36.5	4.6	0	$2,608.08 	$0.00 	$0.00 	41.1 	$2,608.08 

Sources:	Hour burden estimates are averages across consultees. Wage
rates are based on BLS mean wages for State agencies (  HYPERLINK
"http://www.bls.gov/oes/2008/may/naics4_999200.htm"
http://www.bls.gov/oes/2008/may/naics4_999200.htm ), Local government
agencies, (  HYPERLINK
"http://www.bls.gov/oes/2008/may/naics4_999300.htm"
http://www.bls.gov/oes/2008/may/naics4_999300.htm ), and. BLS 2010
Employment Cost Index, Series ID CIS30100000000001 (state and local
government) (customized tables at:   HYPERLINK
"http://www.bls.gov/ncs/ect/" \l "data" http://www.bls.gov/ncs/ect/#data
; accessed 3/3/2010).

Note: numbers may not add up across all rows and columns due to
rounding.

Table 8 presents the annual respondent burden/cost estimate for federal
respondents.  The federal labor rates were derived from information
published by the U.S. Office of Personal Management and include a
benefits multiplier of 1.6.  

Table 8.  Estimated Annual Burden/Cost Per Project for Federal Agencies 

Information Collect Activity	Annual Hours Per Project	Annual Labor Cost
Per Project	Annual Capital or Startup Costs Per Project	Annual O&M Cost
Per Project	Total

	GS14	GS13



Annual Hours Per Project 	Annual Costs Per Project

	($73.58/ hour)	($62.27/

hour)





	Preparing to Use the System	1.00	1.00	$135.86	$0.00 	$0.00 	2	$135.86

Obtaining Access	0.5	0.5	$67.93	$0.00 	$0.00 	1	$67.93

Entering Records	1.00	8.00	$571.76	$0.00 	$0.00 	9	$571.76

Reviewing and Verifying Records	2.00	4.00	$396.26	$0.00 	$0.00 	6
$396.26

Feedback and Evaluation	0.5	0.5	$67.93	$0.00 	$0.00 	1	$67.93

Total	5.00	14.00	$1239.73	$0.00 	$0.00 	19	$1239.73

Source:  http://www.opm.gov/oca/10tables/html/gs_h.asp (step 5); rates
include a benefits multiplier of 1.6

(ii)	Estimating Capital and Operations and Maintenance Costs

Respondents will not incur capital or operations and maintenance costs
for this information collection.

6(c)	Estimating Agency Burden and Cost

As shown in Table 9, the estimated annual cost to the federal government
for administering this collection of information is $36,181.25.

Table 9.  Estimated Annual Federal Administrative Burden/Cost 

Information Collect Activity	Hours / Year	Labor Cost/

Year	O&M Cost/

Year	Total Hours and Costs

	GS14	GS13	GS12

	Total Hours/

Year	Total Costs/

Year

	$73.58/

hour	$62.27/

hour	$52.37/

hour





Update Reporting Guidance and System Instructions	24	0	0	$1,766.02	$0.00
24	$1,766.02

Notify System Users of Data Call	24	0	0	$1,766.02	$0.00	24	$1,766.02

Conduct Training	40	0	0	$2,943.36	$0.00	40	$2,943.36

Update Web Site	0	12	16	$1,585.15	$0.00	28	$1,585.15

Solicit and Compile Feedback from Users	16	0	0	$1,177.34	$0.00	16
$1,177.34

Respond to User Comments and Questions	40	0	0	$2,943.36	$0.00	40
$2,943.36

Contractor support



	$24,000.00

$24,000.00

Total Administrative Burden	144	12	16	$12,181.25	$24,000.00	172
$36,181.25

Source:  http://www.opm.gov/oca/10tables/html/gs_h.asp (step 5); rates
include a benefits multiplier of 1.6

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

GLNPO estimates that 463 state, local, and tribal government agencies,
131 non-governmental organizations, and 15 federal agencies are likely
to report to the GLAS annually.  The total burden and costs are
summarized in Table 10.

Table 10.  Estimated Annual Burden Cost* 

Respondent Type	Annual Total Hours Per Project 

	Annual Total Cost Per Project 	Average Number of Projects/ Year	Total
Annual Hours 	Total Annual Cost

State, Local, and Tribal Government Agencies 	33	$1880.14	463	15,279
$870,506.01

Non-governmental Organizations	41.1	$2608.08	131	5,384	$341,657.99

Federal Agencies	19	$1239.73	50	950	$61,986.40

Total	Varies	Varies	644

	21,613	$1,274,150.40



Note:  Respondents will not incur capital or operations and maintenance
costs for this information collection

6(e)	Bottom Line Burden Hours and Cost Tables

As of March 9, 2010, the total annual cost for this information
collection is estimated to be $1,310,331.65.  The bottom line burden
hours and costs for each respondent group, federal administrative hours,
and operations and maintenance costs are listed in Table 11.

Table 11.  Bottom Line Burden Hours and Costs

Line Item	Annual Hours	Annual Cost  

	Average Number of Projects Per Year	Total Burden Hours Per Year	Total
Cost Per Year

State, Local, and Tribal Government Agency Responses	33	$1880.14	463
15,279	$870,506.01

Non-governmental Organization Responses	41.1	$2608.08	131	5,384
$341,657.99

Federal Agency Responses	19	$1239.73	50	950	$61,986.40

Total Respondent Cost	Varies	Varies	644	21,613	  =SUM(ABOVE) 
$1,274,148.50 

Total Respondent Burden hours





	Federal Administrative Hours	0.271	$18.911

	$12,181.25

Federal Operations and Maintenance (Contractor Support)



	$24,000

Total 

	644

$1,310,331.65

1. Average labor hours and labor cost in Table 8 Per Project.





(iii)	Variations in the Annual Bottom Line

GLNPO does not anticipate significant variations in the annual bottom
line.

6(g)	Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 33 hours per project for state,
local, and tribal government agencies, 41.1 hours per project for
non-governmental organizations, and 19 hours per project for federal
agencies.  Burden is defined as 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 estimate
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 Number
EPA-R05-OW-2009-0932, which is available for online viewing at
www.regulations.gov, or in person viewing at the Environmental
Protection Agency, Great Lakes National Program Office, 77 W. Jackson
St., Chicago, Illinois 60604.  Materials are available for viewing from
8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays;
telephone number (312) 886-6815.  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, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-R05-OW-2009-0932 and OMB Control Number
2005-NEW in any correspondence.

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GLAS ICR Supporting Statement Part A	Page   PAGE  6  of 13	March 29,
2010						March 29, 2010

