0938ss18 Revised 6.18.14

SUPPORTING STATEMENT FOR INFORMATION COLLECTION

REQUEST NUMBER 0938.18 (2030-0020)

1. Identification of the Information Collection

1(a). Title of the Information Collection. “GENERAL ADMINISTRATIVE REQUIREMENTS FOR ASSISTANCE PROGRAMS”

1(b). Short Characterization/Abstract. This is a request for a renewal of an existing Information Collection Request (ICR). This ICR authorizes the collection of information under EPA’s General Regulation for Assistance Programs that establishes the minimum management requirements for all recipients of EPA grants or cooperative agreements (assistance agreements). 40 CFR Part 30, “Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations,” establishes the management requirements for institutions of higher education, hospitals, and other non-profit organizations, as well as procurement requirements for non-governmental recipients. 40 CFR Part 31, “Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments,” includes the management requirements for States, local governments, and Indian Tribal governments. These regulations include only those provisions mandated by statute, required by Office of Management and Budget (OMB) Circulars, or added by EPA to ensure sound and effective financial assistance management.

In addition, under Executive Orders 11625, 12138, and 12432, EPA is required to promote and report on programs to assist minority and women-owned enterprises. Under P.L. 101-507 and P.L. 102-389, EPA is required to set aside funds for socially and disadvantaged individuals/firms under the Small Business Act, 15 U.S.C. 537(a) (5) and (6). This ICR combines all of these requirements under OMB Control Number 2030-0020. EPA award officials will use the information required by these regulations to make assistance awards, to make assistance payments, and to verify that the recipient is using Federal funds appropriately to comply with Federal requirements.

This request renews the “General Administrative Requirements for Assistance Programs” ICR by consolidating and updating the information contained in the following ICRs previously approved by OMB:

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.11 (base ICR) - requested approval for collection of information under EPA’s assistance programs.

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.12 (amendment ICR) - requested approval of EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.13 (amendment ICR) - adjusted burden hours under the ICR.

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.14 (amendment ICR) - requested approval of nonsubstantive modifications to existing EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.15 (amendment ICR) - requested approval of nonsubstantive modifications to existing EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.16 (amendment ICR) – eliminated NCER Form 3212, “Itemized Budget for EPA STAR Grant Applications” and requested approval of EPA Form 6600-06, “Certification Regarding Lobbying.”

• “General Administrative Requirements for Assistance Programs” ICR Number 0938.17 (amendment ICR) – increased burden estimates by incorporating the following program areas under which grants were funded for the ARRA (previously approved under Emergency ICR Number 2351.01):

• Diesel Emissions Reduction Act

• Superfund Cooperative Agreement

• Leaking Underground Storage Tank Enforcement and Cleanup Program

• Other assistance programs involving ARRA funds, including the Wastewater Treatment Construction Program, Water Quality Management Planning (Sections 205(j)(1) & 604(b)), and Clean Water Tribal Set-Aside Program

In approving the “General Administrative Requirements for Assistance Programs” ICR Number 0938.17, OMB issued terms of clearance. The terms are provided below in bold, followed by EPA’s response explaining how they were addressed.

This change transfers 20,066 hours of burden from Emergency ICR 2030-0046, which expires on Sept 30, 2009, to this ICR, and approves EPA’s collection of 4 additional data items required by EPA to meet the requirements of ARRA that were not previously approved under this ICR. These are: Site Assessments Initiated; Site Assessments Completed; Cleanups Initiated, and Cleanups Completed. Additionally, EPA’s requirement for information for each LUST site (latitude/longitude), and reporting is also approved. The additional burden primarily reflects the increase in grant applicants and awards expected as a result of ARRA, as well as accounting for the new reporting requirements. OMB approves this collection for six (6) months. If EPA decides to continue use of the collection past the six month approval time period, it must resubmit to OMB under the normal PRA clearance process, and include the two requests for public comment. New recordkeeping or requirements, like those listed above, will be incorporated into the supporting statement for the ICR. Additionally, EPA will include these specific items in the two requests for public comment that precede the submission of the ICR to OMB. OMB recognizes EPAs review of the forms covered by this request and encourages EPA to be as rigorous in the review of each form prior to resubmission of this ICR in future years.

EPA response: In 2009, EPA submitted a request for emergency clearance to collect information under the American Recovery and Reinvestment Act (ARRA) of 2009 (ICR Number 2351.01). The purposes of the ARRA are to preserve and create jobs and promote economic recovery, assist those most impacted by the recession, provide investments needed to increase economic efficiency as specified, invest in transportation, environmental protection, and other infrastructure that will provide long-term economic benefits, and stabilize State and local government budgets, in order to minimize and avoid reductions in essential services and counterproductive State and local tax increases. All funds under the ARRA have been appropriated, and there are no additional reporting or audit requirements associated with the ARRA.

2. Need For and Use of the Collection

2(a). Need/Authority for the Collection. This ICR is necessary because of the information collection and reporting requirements included in EPA regulations at 40 CFR Parts 30 and 31. These regulations implement OMB Circulars A-21, A-87, A-102, A-110, A-122, and A-133. These regulations set forth the pre-award, post-award, and after-the-grant requirements. This information is needed by EPA project officers, grant specialists, and finance officials to manage/oversee recipient programmatic and financial performance under all EPA assistance agreements.

Without the data compiled by the use of the forms, it would be impossible for EPA to manage any of its Federal assistance programs. Rational, fair grant awards would be extremely difficult to make, and financial and technical managerial information would not be available to judge the status of grant efforts. Lessening the frequency of data collection would have similar negative impacts.

2(b). Practical Utility/Users of the Data. The pre-award information is used to qualify and select grant/cooperative agreement applicants for funding. The post-award information is used to meet the statutory and regulatory requirements and monitor recipient performance. The after-the-grant information is used to meet reporting and recordkeeping requirements and to close out awards. The information is necessary to ensure minimum fiscal control and accountability for EPA funds and to deter waste, fraud, and abuse.

3. Non Duplication, Consultations, and Other Collection Criteria

3(a). Non Duplication. There is no other source for this information.

3(b). Public Notice Required Prior to ICR Submission to OMB. A notice was published on page 64942 of the October 19, 2011, Federal Register, announcing that EPA was beginning to prepare this ICR. One comment was received in response to the notice, but it was not substantive and therefore did not require a formal response.

3(c). Consultations. We have received continuous feedback from recipients on this information collection. Administering EPA grants requires constant recipient contact (e.g. written, telephone, face to face, etc.). The EPA Office of Grants and Debarment (OGD) is both sensitive and responsive to recipient concerns involving burden, duplication, availability of data, clarity of instructions, etc., and revises EPA grant forms and collection methods in an effort to address recipient concerns and streamline their activities.

Frequent applicant and recipient feedback and informal consultations have been a significant part of EPA grant forms evaluation. These contacts have been particularly useful in developing burden estimates. However, the bulk of recipient burden involves completing Federal Standard Forms (e.g., SF 424). All of the basic information requirements under these regulations have already been subject to considerable comment by recipients through OMB’s revisions to Circular A-102.

This ICR is requesting clearance for a number of EPA grant forms. They are used by respondents on a regular basis and made publicly available in several different locations (e.g., various web sites) in both electronic and hardcopy format.

3(d). Effects of Less Frequent Collection. No less frequent collection is possible in accordance with OMB requirements.

3(e). General Guidelines. In 1996, the regulations of Part 30 were revised to reflect “plain English.” EPA has continued to use plain English since then. As a result, EPA’s grant regulations and other documents are easier to understand by all organizations, large and small. The information collection is consistent with 5 CFR 1320.5(d)(2).

3(f). Confidentiality. No pledge of confidentiality is given for applicant responses.

3(g). Sensitive Questions. No sensitive information is collected under this ICR.

4. The Respondents and the Information Requested

4(a). Respondents/SIC Codes. The primary recipients of EPA grants are State and local governments, Indian Tribes, educational institutions, and not-for-profit institutions. The information requested is used to make awards, pay recipients, and collect information on how Federal funds are being spent.

Standard Industrial Classification Codes for respondents include 8211, 8221, 8399, and 919. The corresponding North American Industry Classification System (NAICS) Codes for respondents include 61111, 61131, 813212, 813219, 813311, 813312, 813319 and 92119.

4(b)(i). Information Requested - Data Items, Including Record Keeping Requirements.

The following identifies the application forms and non-form reporting requirements contained in this regulation. A detailed justification for each reporting requirement immediately follows. Burden estimates are summarized in Exhibit A.

EPA Forms, Reporting and Record Keeping Requirements

(1) SECTIONS 30.50, 30.52, and 31.42 require recipients to establish an official record file for each assistance award to track how the recipient uses the project funds, to account for property purchased under the award or used as part of any in-kind contributions, to maintain time records, and to document compliance with applicable statutes and regulations (40 CFR Part 7). We estimate that this requirement imposes 5 burden hours on the recipient and 1 burden hour on EPA.

(2) SECTIONS 30.50, 30.52, and 31.42 require EPA project officers to perform reviews that pertain to programmatic components of assistance agreements. This type of evaluation focuses on reviewing information that can help assess recipients’ activities and progress toward meeting the goals and objectives outlined in the assistance agreements. Programmatic reviews also ensure that the work to be performed under the agreement is on schedule, within budget, and consistent with the agreements’ relevant programmatic regulation and/or programmatic terms and conditions. During the reviews, EPA project officers may request that recipients provide required information that is missing or incomplete. For those who do complete these reviews, we estimate 1 burden hour on the recipient and 1 burden hour on EPA.

The extent of the information gathered and reviewed through this type of instrument will vary according to the size and scope of each agreement. Complex agreements that involve large financial grants and entail extensive staffing and complex tasks will require a greater degree of review and evaluation. Regardless of the size or complexity of the assistance agreement, the review instrument creates a framework that allows EPA to ensure the sound and effective management of assistance agreements.

(3) SECTIONS 30.51 and 31.40 require recipients to submit interim and final progress reports, if required. EPA uses the interim progress reports to determine progress in relation to the approved schedule and project milestones during the project. The final progress report summarizes all of the work on the project and the extent to which the recipient has met the project’s objectives. We estimate that this requirement imposes a total of 6.5 burden hours on the recipient and 4 burden hours on EPA.

(4) SECTION 31.10(b)(3) requires States and territories to submit work plans for Continuing Environmental Program (CEP) grants. Work plans identify environmental goals and objectives and output and outcome measures that are needed for management purposes. We estimate that this requirement imposes a total of 4 burden hours on the recipient and 4 burden hours on EPA.

(5) EPA Form 190-F-04-001, “EPA Payment Request,” is used to request payment from EPA for Assistance Agreements or grants. We estimate that this form will impose 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(6) EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form,” is completed by fellowship recipients to enable the Treasury Department to transmit payment data, by electronic means, to vendor's financial institution. We estimate that this form will impose 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(7) EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance,” is used to collect information that enables EPA to determine whether applicants are developing projects, programs, and activities on a non-discriminatory basis. We estimate that this form will impose 0.5 burden hours on the applicant and 0 burden hours on EPA.

(8) EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants and Cooperative Agreements,” is completed by recipients of Federal grants, cooperative agreements, or other Federal financial assistance which involve procurement of supplies, equipment, construction or services to accomplish Federal assistance programs. We estimate that this form will impose 1.5 burden hours on the recipient and 1.5 burden hours on EPA.

(9) EPA Form 5700-53, “Lobbying and Litigation Certification for Grants and Cooperative Agreements,” is completed at project completion to certify that funds have not been used to engage in the lobbying of the Federal Government or in litigation against the United States. We estimate that this form will impose 5 minutes of burden on the recipient and 5 minutes of burden on EPA.

(10) EPA Form 5700-54, “Key Contacts Form,” and EPA Form 5700-55, “Key Contacts Form for Multiple Principal Investigators.” These forms are used to collect contact information for individuals responsible for various aspects of the proposed work, including authorized representative, payee, administrative contact, and investigators. A recipient must complete either form as applicable. We estimate that a form imposes 0.5 burden hours on the applicant and 0 burden hours on EPA.

(11) EPA Form 5770-2, “Fellowship Application,” is the basic application form for individuals seeking fellowships and requires information on the applicant’s educational and work experience background. We estimate that this form imposes 3 burden hours on the applicant and 3 burden hours on EPA.

(12) EPA Form 5770-3, “Fellowship Facilities and Commitment Statement,” requires information about the institution that will sponsor the fellowship applicant, the sponsor’s summarized plans for the applicant’s training, and the institution’s commitment to provide that training. We estimate that this form imposes 1 burden hour on the applicant and 1 burden hour on EPA.

(13) EPA Form 5770-5, “Agency Fellowship Certification,” is used by applicants who are current or prospective employees of a regional, State, or local environmental pollution control or regulatory agency. The form asks the agency director or designee for the kind of help (financial, leave of absence, etc.) the agency will be providing the applicant if the receives an EPA fellowship. We estimate that this form imposes 0.5 burden hours on the applicant and 0.5 burden hours on EPA.

(14) EPA Form 5770-7, “EPA Fellowship Activation Notice,” is used by EPA to inform EPA’s Regional Services Staff to begin payment on the fellowship award. We estimate that this form imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(15) EPA Form 5770-8, “Fellowship Agreement,” contains the terms of the fellowship agreement, and is used by the applicant to formally accept an EPA fellowship. We estimate that this form imposes 1 burden hour on the recipient and 1 burden hour on EPA.

(16) EPA Form 5770-9, “Completion of Studies Notice,” is used to officially terminate the fellowship. The form requires the recipient to provide EPA with two reprints of any publication work done under the fellowship, when available, and asks for constructive criticism from the recipient or his sponsor on EPA’s fellowship program. We estimate that this form imposes 1 burden hour on the recipient and 1 burden hour on EPA.

(17) EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire,” requests information about an organization’s administrative and financial policies, procedures, accounting and management of EPA assistance agreements. EPA uses the information to determine if recipients are in compliance with government-wide and EPA-specific rules, regulations and guidelines promulgated in the various OMB Circulars, Code of Federal Regulations, and Agency directives. Additionally, it is reviewed to determine if recipients have good business practices, such as consistently applied policies and procedures that safeguard the management and use of Federal funds. The form provides the Agency with information needed to conduct and complete its statistical analyses and evaluation of recipients. The information is collected on a statistically determined and random basis spread over the various types of organizations receiving funds from EPA. We estimate that the form imposes 30 burden hours on the recipient and 40 burden hours on EPA.

(18) EPA Form 6600-06, “Certification Regarding Lobbying,” is completed by grant applicants and contains certifications about the use of Federal appropriated funds in connection with lobbying, as specified. The form is used by EPA to confirm that no funds have been used for lobbying activities and, if applicable, to direct the recipient to complete Standard Form-LLL, Disclosure Form to Report Lobbying.” We estimate that this form imposes 0.25 burden hours on the recipient and 0.03 burden hours on EPA.

(19) EPA Form 6600-08, “Lobbying Cost Certificate for Indirect Costs/Certificate of Indirect Costs for State and Local Governments.” The “Lobbying Cost Certificate for Indirect Costs” portion is completed by non-profit grant recipients and contains the certification required by OMB Circular A-122. The form is used by EPA to ensure compliance with the requirements and standards on lobbying costs in OMB Circular A-122. The “Certificate of Indirect Costs for State and Local Governments” portion is completed by state, local, and tribal grant recipients and contains the certification required by OMB Circular A-87. The form is used by EPA to ensure compliance with the requirements and standards on lobbying costs in OMB Circular A-87. We estimate that this form will impose 0.25 burden hours on the recipient and 10 minutes of burden on EPA.

(20) EPA Form 6600-09, “EPA Administrative Capability Questionnaire,” is completed by non‑profit organizations seeking EPA grant awards of more than $200,000 and under certain special conditions (e.g., high‑risk recipients and to other applicants below these thresholds in special circumstances). Based on the information provided, EPA assesses the adequacy of an applicant’s administrative and financial management systems (i.e., administrative capability) and determines whether to award the grant. Applicants that provide information that demonstrates that they are administratively and financially capable are “certified” for the next four years. The questionnaire is necessary because it assists organizations identify potential system weaknesses and compliance problems and correct them before grant award. We estimate that the form will impose 4 burden hours on the applicant and 3 burden hours on EPA.

(21) NCER Form 5, “Current and Pending Support,” is used by EPA’s National Center for Environmental Research to determine whether the principal investigator has available capability to handle the additional workload proposed by EPA under the grant. We estimate that this form will impose 0.5 burden hours on the applicant and 0.25 burden hours on EPA.

Standard Form Requirements

(1) SF 428, “Tangible Personal Property,” is used by recipients to report on tangible personal property (equipment and supplies) when required by a Federal financial assistance award. We estimate that this form will impose 2.75 burden hours on the recipient and 2.75 burden hours on EPA.

(2) SF 429, “Real Property Status Report,” is used by recipients of Federal financial assistance to report real property status or to request agency instructions on real property that was/will be provided as Government Furnished Property (GFP) or acquired (i.e. purchased or constructed) in whole or in part under a Federal financial assistance award. We estimate that this form will impose 4 burden hours on the recipient and 4 burden hours on EPA.

The reporting and record requirements burden estimates of Sections 30.25 through 31.36(h) (below) are not listed in Exhibit A due to low frequency of applicability and /or minimal response burden to applicants and recipients of EPA grants.

(1) SECTIONS 30.25 and 31.32 require recipients to obtain the award officials approval before purchasing property or equipment with a unit acquisition cost of $5,000 or more.

We estimate that this requirement applies to about 20% of the non-construction assistance recipients, and that this requirement imposes 3 burden hours on those recipients and 2 burden hours on EPA.

(2) SECTIONS 30.30-37 and 31.32 require recipients to comply with specific property management standards. The recipient is required to keep accurate records and carry out a physical inventory of property and reconcile the results, at least every two years. We estimate that this requirement imposes 3 burden hours on the recipient and 2 burden hours on EPA.

(3) SECTION 30.36 requires recipients to submit invention reports after completion of each project.

(4) SECTIONS 30.4 and 31.6 contain the requirements recipients must follow to request a deviation from an EPA regulation. Only 5% of all recipients request deviations. We estimate that a deviation imposes 8 burden hours on the recipient and 8 burden hours on EPA.

(5) SECTIONS 30.63 and 40 CFR 31 Subpart F contain the procedures the recipient must follow to appeal an assistance agreement dispute between the recipient and the award official. We estimate that this requirement imposes 16 burden hours on the recipient and 16 burden hours on EPA. Less than 1% of EPA grant awards result in disputes.

(6) SECTIONS 30.40-48 and 31.36 contain the procurement requirements recipients must follow. We estimate that this requirement imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA.

(7) SECTION 31.11 requires recipients to follow 40 CFR Part 29, which implements Executive Order 12372, “Intergovernmental Review of Federal Programs,” revokes OMB Circular A-95, and establishes new procedures for intergovernmental reviews. OMB has determined that the new requirements are not subject to the reporting burden clearance process.

(8) SECTION 31.36(h) contains the bonding and reporting requirements recipients must follow. We estimate that this requirement imposes 0.5 burden hours on the recipient and 1 burden hour on EPA.

Common Forms (burden is not included in this ICR)

(1) SF 3881, “ACH Vendor/Miscellaneous Payment Enrollment Form,” is completed by grant recipients to enable the U.S. Treasury Department to transmit payment data, by electronic means, to vendor's financial institution. We estimate that this form will impose 0.25 burden hours on the recipient and 1 burden hour on EPA.

(2) SF 424, “Application for Federal Assistance,” is used by States, local governments, and Federally recognized Indian Tribal governments to apply for Federal financial assistance. SF-424 requires basic information about the applicant (name, address, telephone number, type of applicant, etc.), including a list of sources of proposed funding and a description of the proposed project. Supplemental information is provided in SF-424A, “Budget Information ‑ Non‑Construction Programs,” SF-424B, “Assurances ‑ Non‑Construction Programs,” SF-424C, “Budget Information ‑ Construction Programs,” and/or SF-424D, “Assurances ‑ Construction Programs,” as applicable. We estimate that this form will impose 4 burden hours on the recipient and 5 burden hours on EPA.

(3) SF 425, “Federal Financial Report,” is used by applicants to submit reports on their grant’s financial progress. We estimate that this form will impose 1.5 burden hours on the recipient and 1.5 burden hours on EPA.

(4) SF 425A, “Federal Financial Report Attachment,” is used by applicants for reporting on cash management activity for multiple grants. We estimate that this form will impose 0.5 burden hour on the recipient and 0.5 burden hours on EPA.

Standard Forms to be Converted to Common Forms (burden is not included in this ICR)

(1) SF 270, “Request for Advance or Reimbursement.” This is the standard form prescribed by OMB Circular A-102 for recipients to use to request advances or reimbursement on all non-construction programs when the advance payment or reimbursement methods are used. We estimate that this form will impose 1 burden hour on the recipient and 1.5 burden hours on EPA.

(2) SF 271, “Outlay Report and Request for Reimbursement for Construction Programs.” This is the standard form prescribed by OMB Circular A-102 for recipients of a construction grant to request reimbursements. We estimate that this form imposes 1 burden hour on recipients and 0.5 burden hours on EPA.

(3) The SF LLL, “Disclosure of Lobbying Activities,” is used by applicants to disclose lobbying activities that have been secured to influence the outcome of a Federal action (e.g., contract, grant, cooperative agreement, etc.). We estimate that this form will impose 10 minutes of burden on the recipient and 0 burden hours on EPA.

(4) SF SAC, “Data Collection Form for Single Audits,” requires non-federal entities that expend $500,000 or more in a year in federal awards to conduct an audit in accordance with OMB Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations.” We estimate that this form will impose 59 hours of burden for large auditees (i.e., auditees most likely to administer a large number of Federal awards), 17 hours for all other auditees, and 21.2 burden hours on EPA.

4(b)(ii). Information Requested – Respondent Activities.

Grants.gov, originally called the E‑Grants Initiative, was a mandate of the President’s Fiscal Year 2002 Management Agenda, which directed agencies to “…allow applicants for Federal Grants to apply for and ultimately manage grant funds online through a common Web site, simplifying grants management and eliminating redundancies.”

Grants.gov implements the requirement in the Federal Financial Assistance Management Improvement Act, Public Law 106‑107, to develop a simple, unified source to electronically find, apply, and manage grant opportunities. Grants.gov is the central Federal electronic portal created in response to the Act.

Grants.gov Apply allows an applicant to download a proposal/application package from Grants.gov and complete the package offline based on agency instructions. The proposal/application package of forms generally includes a standard set of core data elements based on the updated version of the SF‑424. After an applicant completes the required proposal/application package of forms, they can be submitted electronically to Grants.gov, which transmits the proposal/application to the funding agency.

The Office of Grants and Debarment has constructed a Grants.gov Application Database (EAPPLY) that receives the proposal/application data and stores them for program retrieval or review. As proposals/applications are selected for funding, the data will migrate to the associated Integrated Grants Management System (IGMS) database for eventual award.

EPA encourages use of Grants.gov for all competitive grants.

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

5(a). Agency Activities. These data collection forms are reviewed periodically to identify and eliminate duplication in reporting requirements. Similar information is simply not available elsewhere.

These reports are reviewed in accordance with the requirements of 40 CFR Parts 30 and 31. The Agency also conducts periodic on-site reviews to ensure recipient compliance with applicable requirements.

5(b). Collection Methodology and Management. Most of the information will be collected using standardized reports and appropriate recordkeeping. This information is entered into IGMS, the Agency’s database for tracking the status of grant/cooperative actions.

5(c). Small Entity Flexibility. EPA believes the reporting requirements discussed in this ICR do not place an unreasonable burden on small entities; the estimated burdens cannot be further reduced for small entities. EPA needs the information requested to make award decisions, properly manage assistance agreements, maintain records, and monitor performance. This requested information may, in some cases, be dependent on the type of entity (e.g., state agency, non-profit organization, individual, etc.) but is not dependent on an entity’s relative size. EPA takes active steps to minimize the burden on small entities in the form of guidance materials and electronic forms. In most cases, the requirements do not impose a large burden on small entities because the information required is simple and straightforward.

5(d). Collection Schedule. Specific schedules for the collection of the data forms are outlined in grant solicitation notices for pre-award application forms and in the grant terms and conditions for post-award forms.

6. Estimating the Burden and Cost of the Collection

6(a). Estimating Respondent Burden. An estimation of the burden hours per requirement is included in Exhibit A.

Type of Information		Number of Respondents
Competed Grants	Unsuccessful Applications	3,758
	Awards	1,359
Not Competed Grant Awards		1,634
Fellowship Awards		1,575
TOTAL		8,326

6(b)(i). Estimating Respondent Costs – Estimating Labor Costs.

EPA estimates that 80% of burden hours for respondents will be used by the applicant and the remaining 20% will be used by secretarial/clerical staff.

Therefore: Applicant Wage Rate:¹ $45.96 x 1.43 = $65.72.

Secretarial/Clerical Wage Rate:² $17.98 x 1.43 = $25.71.

6(b)(ii). Estimating Respondent Costs – Estimating Capital and Operations and Maintenance Costs. Start-up costs for EPA grant applications and associated forms are minimal and are part of customary and usual recipient business expenses. There are no capital costs related to EPA grant applications and related reporting requirements.

6(b)(iii). Estimating Respondent Costs – Capital/Start-up Operating and Maintenance Costs. There are no capital costs related to EPA grant applications and related reporting requirements. Therefore, total start-up and capital costs are zero (0). There are no O&M costs required.

6(b)(iv). Estimating Respondent Costs – Annualizing Capital Costs. Not applicable.

6(c). Estimating Agency Burden and Cost. The total annual burden hours for EPA is estimated to be 106,560. 106,560 hours divided by 8,326 respondents = 13 hours per respondent for EPA.

Thus: 8,326 respondents x 13 hours x $49.33³ = $5,339,381 (labor costs).

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

The total annual burden hours for recipients is estimated to be 155,006. 155,006 hours divided by 8,326 respondents = 19 hours per respondent.

EPA estimates that 80% of these 19 hours will be used by the applicant (15 hours) and the remaining 20% by secretarial/clerical staff (4 hours).

Thus: 8,326 respondents x 15 hours x $65.72 = $8,207,771 and

8,326 respondents x 4 hours x $25.71 = $856,246.

Total: $9,064,017 (labor costs).



6(e). Bottom Line Burden Hours and Cost Tables.

	Burden Hours	Cost
Respondents	155,006	$9,064,017
EPA	106,560	$5,339,381

6(f) Reasons for Change in Burden. The overall respondent burden has increased from the previous ICR by 40,475 hours (i.e., from 114,531 hours to 155,006 hours). This change occurred for several reasons. Initially, EPA carefully reviewed the set of grant and fellowship forms covered in this ICR. Based on this review, EPA deleted nine existing forms and added seven new forms. In addition, EPA removed burden associated with four forms that have been converted to common forms. These program changes are outlined in the table below.

The details and justification for the forms that were added is included in Section 4 of this ICR.

Program Changes	Total Respondent Hours
Deleted Forms
Completion of desk review protocol	-190
Completion of onsite protocol	-680
40 CFR 30.22 and 31.21 Establish separate bank account - ACH Payment System (the requirements of this form are covered under SF 3881, “ACH Vendor/Miscellaneous Payment Enrollment Form;” EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form;” and EPA Form 190-F-04-001, “US EPA Payment Request”)	-802
40 CFR 30.33 and 31.32 Report on Federally-owned property (the requirements of this form are included under the new SF 429, “Real Property Status Report”)	-684
40 CFR 30.21 and 31.20 Maintain financial management system (these requirements are covered under existing financial reporting elements)	-6,834
Meet OMB Circular A-133 Audit Requirements (these requirements are included under SF SAC, “Data Collection Form for Single Audits”)	-950
EPA Form 5770-4, “Fellowship Applicant Qualifications Inquiry” (this form is no longer used by the Environmental Education Division’s National Network for Environmental Management Studies Fellowship Program)	-2,967
SF 269, “Financial Status Report” (the requirements are replaced by SF 425, “Federal Financial Report”)	-3,417
SF 272, “Federal Cash Transactions Report” (ACH Payment System) - Family of Forms (the requirements of this form are included under SF 425, “Federal Financial Report”)	-840
Subtotal: Deleted Forms	-17,364
Common Form Burden Removed from ICR
SF-424, “Application for Federal Assistance” (including SF-424A, SF-424B, SF-424C, and SF-424D)	-15,264
SF-LLL, “Disclosure of Lobbying Activities”	-162
SF-270, “Request for Advance or Reimbursement”	-1,900
SF-271, “Outlay Report and Request for Reimbursement for Construction Programs”	-760
Subtotal: Common Forms	-18,086
Added Forms
40 CFR 31.10(b)(3) Grant work plans	3,584
EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form”	50
EPA Form 190-F-04-001, “US EPA Payment Request”	17,958
EPA Form 5700-53, “Lobbying and Litigation Certificate”	249
EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants”	9,000
SF 428 “Tangible Personal Property”	8,231
SF 429 “Real Property Status Report”	120
Subtotal: Added Forms	39,192
Subtotal: Program Changes	3,742

In addition to reviewing the set of grant and fellowship forms included under the ICR, EPA reviewed the burden assumptions in the ICR to ensure that they reflect the Agency’s current experiences under its grant programs. Based on this review, EPA made significant adjustments in the number of respondents, the annual submissions per respondent, and the burden hours for completion for all of its grant forms. This renewal request also incorporates reporting and audit requirements associated with assistance programs funded under ARRA. These adjustment changes are outlined in the table below. Additional details about the revised estimates are included in Exhibit A.

Adjustment Changes	Total Respondent Hours	Change from 2009 ICR
40 CFR 30.50 and 52 and 31.42 Keep records	14,965	-2,120
40 CFR 30.50 and 52 and 31.42 Completion of project officer protocol	376	91
40 CFR 30.51 and 31.40 Submit progress reports	77,818	33,384
EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance”	3,376	1,667
EPA Form 5700-54, “Key Contacts Form” and EPA Form 5700-55, “Key Contacts Form for Multiple Principal Investigators”	3,376	1,667
EPA Form 5770-2, “Fellowship Application”	4,725	1,758
EPA Form 5770-3, “Fellowship Facilities and Commitment Statement”	1,575	586
EPA Form 5770-5, “Agency Fellowship Certification”	788	293
EPA Form 5770-7, “EPA Fellowship Activation Notice”	75	-1
EPA Form 5770-8, “Fellowship Agreement”	150	-2
EPA Form 5770-9, “Completion of Studies Notice”	150	-2
EPA Form 6600-06, “Certification Regarding Lobbying”	1,688	734
EPA Form 6600-08, "Lobbying Cost Certificate for Indirect Costs/Certificate of Indirect Costs for State and Local Governments”	108	-517
EPA Form 6600-09, “EPA Administrative Capability Questionnaire”	200	-600
NCER Form 5, “Current and Pending Support”	446	-204
Subtotal: Adjustment Changes		36,734

The net effect of these program changes and adjustments is an increase of 40,475 hours from the previous ICR.

6(g). Burden Statement. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 19 hours per respondent. 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.

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-OARM-2011-0795, which is available for public viewing at the Office of Environmental Information 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 Office of Environmental Information Docket is (202) 566-1752. An electronic version of the public docket is available online at www.regulations.gov. Use www.regulations.gov to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. Once in the system, select “search,” then key in the docket ID number identified above.

EXHIBIT A

ANNUAL ESTIMATE OF EPA ASSISTANCE AGREEMENT AWARDS

Type of Information		Number of Respondents
Competed Grants	Unsuccessful Applications	3,758
	Awards	1,359
Not Competed Grant Awards		1,634
Fellowship Awards		1,575
TOTAL		8,326

The above estimates were used to determine the number of actions per year for each of the following reporting requirements.

BURDEN HOURS PER REPORTING REQUIREMENT

NOTES: Column D = A x B x C

Column F = A x B x E

Burden estimates for analyzing, processing, and maintaining EPA grant forms were derived from EPA employees directly responsible for day-to-day grant operations. Employee estimates were obtained shortly after forms were approved for use and have been modified to reflect our grant processing streamlining efforts.

Reporting and recordkeeping requirement burden estimates for Sections 30.25 through 33.211 of 40 CFR are not listed in Exhibit A due to the low frequency or applicability and/or minimal response burden to applicants and recipients of EPA grants.

Information Collection Requirement	A	B	C	D	E	F
	Actions per Year	Submissions per Agreement	Burden Hours per Action	Total Burden Hours for Recipients	Burden Hours for EPA	Total Burden Hours for EPA
EPA Forms, Reporting and Record Keeping Requirements
40 CFR 30.50 and 52 and 31.42 Keep records	2,993	1	5	14,965	1	2,993
40 CFR 30.50 and 52 and 31.42 Completion of project officer protocol	376	1	1	376	1	376
40 CFR 30.51 and 31.40 Submit progress reports	2,993	4	6.5	77,818	4	47,888
40 CFR 31.10(b)(3) Grant work plans	896	1	4	3,584	4	3,584
EPA Form 190-F-04-001, “US EPA Payment Request”	2,993	12	0.5	17,958	0.5	17,958
EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form”	100	1	0.5	50	0.5	50
EPA Form 4700-4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance”	6,751	1	0.5	3,376	0	0
EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants”	3,600	1.67	1.5	9,000	1.5	9,000
EPA Form 5700-53, “Lobbying and Litigation Certificate”	2,993	1	0.08	249	0.08	249
EPA Form 5700-54, “Key Contacts Form” and EPA Form 5700-55, “Key Contacts Form for Multiple Principal Investigators”	6,751	1	0.5	3,376	0	0
EPA Form 5770-2, “Fellowship Application”	1,575	1	3	4,725	3	4,725
EPA Form 5770-3, “Fellowship Facilities and Commitment Statement”	1,575	1	1	1,575	1	1,575
EPA Form 5770-5, “Agency Fellowship Certification”	1,575	1	0.5	788	0.5	788
EPA Form 5770-7, “EPA Fellowship Activation Notice”	150	1	0.5	75	0.5	75
EPA Form 5770-8, “Fellowship Agreement”	150	1	1	150	1	150
EPA Form 5770-9, “EPA Completion of Studies Notice”	150	1	1	150	1	150
EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire”	200	1	30	6,000	40	8,000
EPA Form 6600-06, “Certification Regarding Lobbying”	6,751	1	0.25	1,688	0.03	203
EPA Form 6600-08, “Lobbying Cost Certificate for Indirect Costs/Certificate of Indirect Costs for State and Local Governments”	430	1	0.25	108	0.17	73
EPA Form 6600-09, “EPA Administrative Capability Questionnaire”	50	1	4	200	3	150
NCER Form 5, “Current and Pending Support”	892	1	0.5	446	0.25	223
Subtotal	43,944			146,655		98,209
Standard Form Requirements
SF 428 “Tangible Personal Property”	2,993	1	2.75	8,231	2.75	8,231
SF 429 “Real Property Status Report”	30	1	4	120	4	120
Subtotal	3,023			8,351		8,351
TOTAL	46,967			155,006		106,560

EXHIBIT B

Forms Covered Under this ICR

• EPA Form 190-F-04-001, “EPA Payment Request”

• EPA Form 190-F-05-001, “Fellowship Stipend Payment Enrollment Form”

• EPA Form 4700‑4, “Preaward Compliance Review Report for All Applicants and Recipients Requesting Federal Financial Assistance”

• EPA Form 5700-52A, “MBE/WBE Utilization Under Federal Grants and Cooperative Agreements”

• EPA Form 5700-53, “Lobbying and Litigation Certification for Grants and Cooperative Agreements”

• EPA Form 5700-54, “Key Contacts Form,” and EPA Form 5700-55, “Key Contacts Form for Multiple Principal Investigators”

• EPA Form 5770‑2, “Fellowship Application”

• EPA Form 5770‑3, “Fellowship Facilities and Commitment Statement”

• EPA Form 5770‑5, “Agency Fellowship Certification”

• EPA Form 5770‑7, “EPA Fellowship Activation Notice”

• EPA Form 5770‑8, “Fellowship Agreement”

• EPA Form 5770‑9, “Completion of Studies Notice”

• EPA Form 6600-01, “EPA Administrative and Financial Onsite Review Questionnaire”

• EPA Form 6600-06, “Certification Regarding Lobbying”

• EPA Form 6600-08, “Lobbying Cost Certificate for Indirect Costs/ Certificate of Indirect Costs for State and Local Governments”

• EPA Form 6600-09, “EPA Administrative Capability Questionnaire”

• NCER Form 5, “Current and Pending Support”

• SF 428, “Tangible Personal Property”

• SF 429, “Real Property Status Report”

EXHIBIT C

ENVIRONMENTAL PROTECTION AGENCY

FINANCIAL ASSISTANCE PROGRAMS—CATALOG OF

FEDERAL DOMESTIC ASSISTANCE (CFDA) NUMBER AND TITLE

Office of Administration and Resources Management (OARM)

66.508 Senior Environmental Employment Program

66.518 State Senior Environmental Employment Program

Office of Air Radiation (OAR)

66.001 Air Pollution Control Program Support

66.032 State Indoor Radon Grants

66.033 Ozone Transport Commission

66.034 Surveys, Studies, Research, Investigations, Demonstrations and Special Purpose Activities Relating to the Clean Air Act

66.037 Internships, Training and Workshops for the Office of Air and Radiation

66.038 Training, Investigations, and Special Purpose Activities of Federally-Recognized Indian Tribes Consistent With the Clean Air Act (CAA), Tribal Sovereignty and the Protection and Management of Air Quality

66.039 National Clean Diesel Emissions Reduction Program

66.040 State Clean Diesel Grant Program

66.042 Temporally Integrated Monitoring of Ecosystems (TIME) and Long-Term Monitoring (LTM) Program

66.043 Regional Healthy Indoor Air Projects for Community Outreach and Education, Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act

Office of Chemical Safety and Pollution Prevention (OCSPP)

66.707 TSCA Title IV State Lead Grants Certification of Lead‑Based Paint Professionals

66.708 Pollution Prevention Grant Program

66.714 Regional Agricultural IPM Grants

66.716 Research, Development, Monitoring, Public Education, Training, Demonstrations, and Studies

66.717 Source Reduction Assistance

66.718 National Community-Based Lead Outreach and Training Grant Program

Office of the Chief Financial Officer (OCFO)

66.202 Congressionally Mandated Projects

66.203 Environmental Finance Center Grants

Office of Enforcement and Compliance Assurance (OECA)

66.305 Compliance Assistance Support for Services to the Regulated Community and Other Assistance Providers

66.306 Environmental Justice Collaborative Problem-Solving Cooperative Agreement Program

66.309 Surveys, Studies, Investigations, Training and Special Purpose Activities Relating to Environmental Justice

66.310 Capacity Building Grants and Cooperative Agreements for Compliance Assurance and Enforcement Activities in Indian Country and Other Tribal Areas

66.313 International Compliance and Enforcement Projects

66.604 Environmental Justice Small Grants Program

66.700 Consolidated Pesticide Enforcement Cooperative Agreements

66.701 Toxic Substances Compliance Monitoring Cooperative Agreements

Office of Environmental Information (OEI)

66.608 Environmental Information Exchange Network Grant Program and Related Assistance

66.612 Survey, Studies, Investigations, Training Demonstrations and Educational Outreach Related to Environmental Information and the Release of Toxic Chemicals

Office of International and Tribal Affairs (OITA)

66.473 Direct Implementation Tribal Cooperative Agreements

66.926 Indian Environmental General Assistance Program (GAP)

66.931 International Financial Assistance Projects Sponsored by the Office of International and Tribal Affairs

Office of Research and Development (ORD)

66.509 Science to Achieve Results (STAR) Research Program

66.510 Surveys, Studies, Investigations and Special Purpose Grants within the Office of Research and Development

66.511 Office of Research and Development Consolidated Research/Training/Fellowships

66.513 Greater Research Opportunities (GRO) Fellowships For Undergraduate Environmental Study

66.514 Science to Achieve Results (STAR) Fellowship Program

66.516 P3 Award: National Student Design Competition for Sustainability

66.517 Regional Applied Research Efforts (RARE)

Office of Solid Waste and Emergency Response (OSWER)

66.801 Hazardous Waste Management State Program Support

66.802 Superfund State, Political Subdivision, and Indian Tribe Site-Specific Cooperative Agreements

66.804 Underground Storage Tank Prevention, Detection and Compliance Program

66.805 Leaking Underground Storage Tank Trust Fund Corrective Action Program

66.806 Superfund Technical Assistance Grants (TAG) for Community Groups at National Priority List (NPL) Sites

66.808 Solid Waste Management Assistance Grants

66.809 Superfund State and Indian Tribe Core Program Cooperative Agreements

66.810 Chemical Emergency Preparedness and Prevention (CEPP) Technical Assistance Grants Program

66.812 Hazardous Waste Management Grant Program for Tribes

66.813 Alternative or Innovative Treatment Technology Research, Demonstration, Training and Hazardous Substance Research Grants

66.814 Brownfields Training, Research and Technical Assistance Grants and Cooperative Agreements

66.815 Environmental Workforce Development and Job Training Cooperative Agreements

66.816 Headquarter and Regional Underground Storage Tanks Program

66.817 State and Tribal Response Program Grants

66.818 Brownfields Assessment and Cleanup Cooperative Agreements

66.819 Disaster Relief Appropriations Act (DRAA) Hurricane Sandy Leaking Underground Storage Tank Trust Fund Corrective Action Program

Office of Administration (OA)

66.605 Performance Partnership Grants

66.609 Protection of Children from Environmental Health Risks

66.610 Surveys, Studies, Investigations and Special Purpose Grants within the Office of the Administrator

66.611 Environmental Policy and Innovation Grants

66.950 National Environmental Education Training Program

66.951 Environmental Education Grants

66.952 National Network for Environmental Management Studies Fellowship Program

Office of Water (OW)

66.418 Construction Grants for Wastewater Treatment Works

66.419 Water Pollution Control State, Interstate, and Tribal Program Support

66.424 Surveys, Studies, Investigations, Demonstrations, and Training Grants - Section 1442 of the Safe Drinking Water Act

66.432 State Public Water System Supervision

66.433 State Underground Water Source Protection

66.436 Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative Agreements - Section 104(b)(3) of the Clean Water Act

66.437 Long Island Sound Program

66.439 Targeted Watersheds Grants

66.440 Urban Waters Small Grants

66.441 Healthy Watersheds Consortium Grant Program

66.454 Water Quality Management Planning

66.456 National Estuary Program

66.458 Capitalization Grants for Clean Water State Revolving Funds

66.460 Nonpoint Source Implementation Grants

66.461 Regional Wetland Program Development Grants

66.462 National Wetland Program Development Grants and Five-Star Restoration Training Grant

66.463 Water Quality Cooperative Agreements

66.466 Chesapeake Bay Program

66.467 Wastewater Operator Training Grant Program

66.468 Capitalization Grants for Drinking Water State Revolving Funds

66.469 Great Lakes Program

66.472 Beach Monitoring and Notification Program Implementation Grants

66.474 Water Protection Grants to the States

66.475 Gulf of Mexico Program

66.481 Lake Champlain Basin Program

66.482 Disaster Relief Appropriations Act (DRAA) Hurricane Sandy Capitalization Grants For Clean Water State Revolving Funds

66.483 Disaster Relief Appropriations Act (DRAA) Hurricane Sandy Capitalization Grants for Drinking Water State Revolving Funds

Region 1

66.110 Healthy Communities Grant Program

Region 4

66.128 Southeastern Multi-Media and Geographic Priority Projects

Region 6

66.124 Coastal Wetlands Planning Protection and Restoration Act

66.125 Lake Pontchartrain Basin Restoration Program (PRP)

Region 9

66.126 The San Francisco Bay Water Quality Improvement Fund

66.600 Environmental Protection Consolidated Grants for the Insular Areas - Program Support

Region 10

66.121 Puget Sound Protection and Restoration: Tribal Implementation Assistance Program

66.122 Puget Sound Action Agenda Outreach, Education and Stewardship Support Program

66.123 Puget Sound Action Agenda: Technical Investigations and Implementation Assistance Program

1 $45.96 represents the average wage rate of several occupations expected to apply for grants or fellowships. This information is derived from Bureau of Labor Statistics; Occupational Employment and Wages, May 2013. Cost data available at: http://www.bls.gov/oes/current/oes_stru.htm (accessed 5/21/2014). 1.43 represents a 43% rate for benefits. This figure is derived from the Bureau of Labor Statistics’ “Occupational Employment and Wages: Management Occupations ” available at http://www.bls.gov/oes/current/oes110000.htm.

2 $17.98 represents the average hourly wage rate of two administrative/clerical positions. This information is derived from Bureau of Labor Statistics; Occupational Employment and Wages, May 2013. Cost data available at: http://www.bls.gov/oes/current/oes_stru.htm (accessed 5/21/2014). 1.43 represents a 43% rate for benefits. This figure is derived from the Bureau of Labor Statistics’ “Occupational Employment and Wages: Information and Record Clerks” available at http://www.bls.gov/oes/current/oes434199.htm and “Occupational Employment and Wages: Bookkeeping, Accounting, and Auditing Clerks” available at http://www.bls.gov/oes/current/oes433031.htm.

3 Office of Personnel Management; 2014 General Schedule (GS) Base (Hourly Rate) for GS 11, Step 9 ($30.83). Available at: http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2014/GS_h.pdf. This was fully burdened (x 60%), yielding a wage rate of $49.33.

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