1

SUPPORTING STATEMENT FOR THE NATIONAL ESTUARY PROGRAM

A. JUSTIFICATION

1. Identification of the Information Collection

1(a) Title - National Estuary Program (Renewal)

1(b) Characterization/Abstract

 Section 320 of the Clean Water Act (CWA) amendments of 1987 established the National 

Estuary Program (NEP) to promote long-term planning and management in nationally significant 

estuaries threatened by pollution, development, or overuse. The NEP’s objectives are to protect, 

preserve, and restore estuaries. The strategy of the Program is to focus on estuaries that are 

nationally significant in recreational and commercial value and are of great importance for fish 

and wildlife resources. Another facet of national significance is whether lessons learned in 

working with the estuary can be applied to other coastal areas. Further, the NEP strategy

emphasizes estuaries that are facing increasing environmental stressors and where there is a 

greater likelihood that NEP efforts will result in improvements in water and sediment quality, as 

well as in the abundance and variety of living resources.

Nationally significant estuaries are identified in one of two ways: 1) the estuary is 

nominated by the State in which it lies; or 2) the Administrator identifies an estuary and decides 

to convene a Management Conference (the local managing entity of an NEP). When the 

Governor of the State in which the estuary is located nominates the estuary for acceptance into 

the NEP, EPA then evaluates the Governor’s nomination. If EPA approves the addition of an 

estuary to the NEP, a Management Conference is convened which involves community

stakeholders including Federal, State, local, and interstate agencies with jurisdiction over the 

estuary, and other interested groups.

Estuaries have come into the NEP in five groups. The first two groups included 12 

estuaries which Congress recommended for priority consideration. In 1987, Albemarle-Pamlico 

Sounds in North Carolina; Buzzards Bay in Massachusetts; Long Island Sound in New York and 

Connecticut; Narragansett Bay in Rhode Island; Puget Sound in Washington; and San Francisco 

Bay in California entered in to the NEP. In 1989, Delaware Inland Bays in Delaware; Delaware 

Bay in Delaware, New Jersey, and Pennsylvania; Galveston Bay in Texas; New York-New Jersey

Harbor in New York and New Jersey; Santa Monica Bay in California; and Sarasota Bay in 

Florida entered in to the NEP. The nominations were evaluated using EPA Nomination 

Guidance. In 1991, the third group of estuaries was designated based on Governors’

nominations. These estuaries were Indian River Lagoon in Florida; Tampa Bay in Florida; 

Barataria-Terrebonne Estuarine Complex in Louisiana; Casco Bay in Maine; and Massachusetts 

Bays in Massachusetts. 

The first 17 estuaries were established on the basis of completing a Comprehensive 
2

Conservation and Management Plan (CCMP) within five years. In an effort to maximize 

successes of these, the Administrator opened a fourth group of nominations in 1991 which called 

for the completion of the planning process in four years. In 1992, four estuaries were designated 

under this streamlined approach: Peconic Bay in New York; San Juan Bay in Puerto Rico; 

Corpus Christi Bays in Texas; and Tillamook Bay in Oregon. Continuing the theme of 

streamlining, the Administrator designated seven new estuaries in 1995 which were to complete 

their CCMPs in three years: Great Bay in New Hampshire; Barnegat Bay in New Jersey; 

Maryland Coastal Bays in Maryland, Charlotte Harbor in Florida; Mobile Bay in Alabama; 

Morro Bay in California; and Lower Columbia River in Washington and Oregon.

Once an estuary is designated by the Administrator, an agreement of intent between the 

EPA and the State or States, called a Conference Agreement, establishes the governing entity for 

the project which is called a Management Conference. The Management Conference performs 

an objective, technical assessment of the condition of the estuary. Based on this assessment, the 

Conference summarizes the estuary’s environmental challenges and indicates which challenges 

will be addressed by the Conference. After the estuary’s priorities are identified, the 

Management Conference establishes goals and objectives for the estuary. Specific actions and 

commitments to protect and restore the estuary are developed and the costs and benefits of 

options are evaluated. This information is used by the Management Conference to develop a 

CCMP for the estuary. Once the CCMP is approved by the Administrator, the NEP is 

responsible for oversight, coordination, and facilitation of CCMP implementation activities.

To obtain funding to administer Management Conferences, to characterize and define 

environmental challenges of the estuary, and to develop the CCMP, States and other eligible 

applicants may apply for federal funds using a standard General Federal Assistance application. 

To ensure efficient use of allotted resources, an annual work plan for each estuary program must 

be developed by the Management Conference before individual awards can be approved. The 

approved work plan then becomes a part of the grant agreement between EPA and the recipient.

In addition, NEPs must also undergo a program evaluation every five years. The purpose 

of the program evaluation is to document progress made in implementing the CCMP; to highlight

successes, strengths, and environmental results; and identify areas for improvement. This 

information is used by EPA to make decisions regarding funding to NEPs who are implementing 

their management plans, to transfer lessons learned in the NEPs to other coastal watersheds and 

EPA programs, and to provide guidance and programmatic support to NEPs based on needs 

identified in the program evaluation.

 Individual NEPs must also develop Government Performance Results Act (GPRA) reports 

that provide information about environmental results and progress implementing their CCMPs. 

These are submitted annually with the information being presented to the Office of Management 

and Budget (OMB) with other EPA GPRA measures.

2. Need for and use of the Collection
3

2(a) Need/Authority for the Collection

 Statutory authority for the NEP is provided by Section 320 of the Clean Water Act, as 

amended. The terms and conditions of grants under the NEP are provided in 40 CFR Section 

35.9040 and Section 35.9045, including the requirement for the 50 percent matching funds from 

non-Federal sources and applications that are consistent with the annual work plan prepared by

each Management Conference.

For each NEP, other than standard application data, EPA needs: 1) the Governor’s 

voluntary nomination to determine whether an estuary should be included in the NEP; 2) the 

annual work plan to determine how the Federal and non-Federal matching funds will be spent; 

3) program evaluation package documenting CCMP implementation progress to justify

continued EPA funding under Section 320; and 4) annual GPRA reports to show environmental 

results. 

The State’s participation in the NEP is voluntary. A Governor nominates an estuary for 

the NEP on his or her own initiative using Guidance which EPA has established. The 

information from the Governor includes already available knowledge about the estuary and its 

importance. The nomination also contains the Governor’s views concerning the significance of 

the estuary, the need for designation, and the State’s goals and objectives for the estuary with it’s 

a strategy for meeting them. To select an estuary for designation, EPA uses the nomination and 

other existing public information on the national significance of the estuary, considers the 

importance of the estuary on a regional scale, and analyzes the environmental challenges facing 

the estuary.

To obtain funding under the NEP, the General Federal Assistance Grant application must 

be filed and an annual work plan must be prepared. The burden of the actual grant application is 

covered under the ICR for General Federal Assistance applications (ICR No. 0938.11; OMB No. 

2030-0020). The only burdens covered under this ICR are the burdens of preparing the annual 

work plan, the program evaluation package, and GPRA reports which are specific to the NEP. 

General Federal Assistance Grant application burdens are not unique to the NEP and are not 

covered by this document. 

The annual work plan identifies and discusses major projects with goals and milestones 

that will be pursued in the upcoming year. The goals are comprehensive and broad and are based 

on the individual NEP’s goals established by the Management Conference. In addition, the work 

plan must document the sources, amounts, and kinds of funds for the upcoming year’s activities, 

including a demonstration of how the required matching funds will be provided from non-Federal

sources.

NEPs must report every five years to EPA on their progress in implementing the CCMP 

and achieving environmental results through the program evaluation. 

 

NEPs must also annually prepare a GPRA report estimating: 1) the number of acres of 

habitat being restored within their study areas, and 2) the number of CCMP priority actions being 
4

initiated. 

2(b) Practical Utility/Users of the Data

The EPA Administrator uses the information collected under this ICR to evaluate Governors’

voluntary nominations of estuaries for the NEP and whether grant applications under the NEP 

should be approved. The following paragraphs describe information required by the NEP: 

 Respondents

 Process and techniques used to obtain this information

 How and by whom the information is used

 Flow of information and where it is submitted, filed, etc. 

(A) Governor’s Nomination

A Governor’s nomination is submitted on a one-time basis only by States that wish to 

participate in the NEP, and nominations are accepted only when the Administrator determines 

that additional programs are needed and that sufficient resources are available to support them. 

At this time, the EPA does not anticipate soliciting nominations in the information collection 

period of 2010-2012. A Governor’s nomination is submitted by a State in which the target 

estuary lies. If the estuary is located in more than one State, a single nomination may be 

submitted for the estuary which combines the information from all the participating States.

The National Estuary Program Final Guidance on the Contents of the Governor’s 

Nomination states that three general topics should be addressed in the nomination: 1) national 

significance of the estuary, 2) need for a Management Conference, and 3) likelihood of success.

Much of the information included in a Governor’s nomination is based on previous 

accomplishments by States, EPA Regions, and local organizations. Information is also available 

in EPA’s 305(b) reports; NOAA’s National Estuarine Inventory; NOAA’s Coastal Zone 

Management, Estuarine Research, and Marine Sanctuary Programs; and university studies. In the 

Guidance, States are urged to use existing and readily available information in the nominations. 

New research and studies are not required. For example, data attained from the State economic 

development agency or a community business group can be used to evaluate recreational and/or 

commercial value of the estuary. The uses of the specific information recommended for 

inclusion in the nomination are described below:

Describe estuary’s boundaries

-To determine if estuary meets CWA definition.

Describe estuary’s value

-To determine if estuary is nationally significant.

Demonstrate how problems will yield transferable results

-To determine how an estuary will enhance results that can be applied to other estuarine 

or coastal watersheds.

Data on economic and living resources

-To determine if estuary has significant local or regional value.
5

Data on problems

-To determine if problems reduce value of estuarine resources.

Discussion of cause and effect

-To determine if the problem is sufficiently understood so as to be addressed effectively.

Assess existing laws, regulations, control programs, enforcement, and coordination

-To determine if the proposed estuary program entails studies and control efforts beyond 

these programs.

List overall goals for the estuary and provide examples of specific objectives and action plans

-To demonstrate whether the State has an understanding of the work which must be done 

to mitigate problems.

List structure and membership of proposed Management Conference

-To demonstrate broad stakeholder support for the program.

Document existence of and/or potential for generating public support

- To determine whether there is or will be sufficient public support for successful 

implementation of the program.

Discuss interests and agencies already working in the estuary

-To determine these public entities’ interest in and commitment to protecting or restoring 

estuarine water quality.

Discuss ability to fund the coordination of the Management Conference and action plans

-To determine if the non-Federal cost share requirement of the statute can be met and if 

sufficient funding exists to implement the program.

After an estuary is accepted into the NEP, the information in the Governor’s nomination 

is used to initiate consensus among Management Conference members on priorities to be 

addressed by the program and to set goals and objectives.

(B) Annual Work Plan

In order to receive funds, grantees must submit an annual work plan to EPA. The 

contents of annual work plans are specified in 40 CFR Section 35.9045. Work plans should 

include: 1) a listing and discussion of completed projects and projects planned for the upcoming 

year, and 2) describe the types of funding and amounts to be supplied by each funding source. 

The work plan is reviewed by EPA and also serves as the scope of work for the grant agreement. 

Annual work plans must be approved by EPA after they are approved by the Management 

Conference so that assistance funding can be awarded. The EPA also uses these work plans to 

track performance of the 28 programs currently in the NEP. 

Information presented in the work plan is based on the EPA/State Conference Agreement 

developed for the Management Conference, but may further define the goals and milestones in 

the overall plan and modify them based on the success or failure of activities completed in the 

previous years. The information is available from the Conference Agreement. The EPA uses the 

work plan to determine whether the monies requested in the grant application serve the seven 

statutory purposes of the Management Conference, whether they fund activities consistent with 

the individual program goals, and whether their expenditure is an efficient use of resources. The 
6

budget information is also used to determine whether 50 percent of the funding is provided by

non-Federal sources as required by 40 CFR 35.9040.

(C) Program Evaluation

Each NEP must submit a program evaluation (PE) package documenting the CCMP 

implementation progress. The purpose of the PE is to document progress made in implementing 

the CCMP; to highlight successes, strengths, and environmental results; and identify areas for 

improvement. EPA issued a PE Guidance in 2011 in which the PE cycle was changed from a 

three year cycle to a five year cycle (four consecutive years with the fifth year to be spent 

producing a findings report). Also the NEPs where distributed in four groups of seven Programs 

each. The NEPs must submit a PE package to EPA every five years. 

For the years covered in the PE cycle, the NEP must submit as part of the PE package: 1) the 

program management core elements response (standardized measures), 2) a work plan narrative 

summary, and 3) a budget summary. The whole PE process entails: 1) PE package submission, 

2) conference calls, 3) on site visit, and 4) findings letter.

Annual work plans are submitted as a component of the PE and cannot serve in place of 

the PE because annual work plans are limited to the activities of the grant recipient. The PE 

encompasses the progress made by the overall estuary program which is a collaboration of many

stakeholders each contributing to the implementation of the CCMP and the restoration and 

protection of the estuary. Only the NEP can collect this information from stakeholders because, 

according to purpose (6) of Section 320 of the CWA, the NEP is responsible for monitoring the 

effectiveness of actions taken to implement the CCMP. In addition, Section 320(h) of the CWA 

requires grant recipients to report on the progress made under Section 320. The standard 

recordkeeping requirement for EPA grants is three years after the date the recipient submits the 

final Financial Status Report (FSR).

(D) Government Performance Results Act (GPRA) Reporting

 The Government Performance and Results Act (GPRA) require that each agency report 

annually to Congress on the results of its activities in each fiscal year. This Annual Performance 

Report forms the bridge between the goals and objectives presented in the EPA Strategic Plan

and budgeted activities. The Annual Performance Report tracks the progress made toward 

implementing goals and objectives in any single fiscal year. To assist in fulfilling this 

requirement, the NEPs are asked to report on two items: 1) number of acres of habitat that have 

been restored within individual study areas including type of restoration and type of habitat; and 

2) priority action items within the CCMP that have been initiated, are ongoing, or have been 

completed. NEP reporting on these items helps to measure EPA’s overall goal of clean and safe 

water.

Use of Improved Information Technology
7

States can access numerous computerized databases to obtain information necessary for 

the Governor’s nomination. These databases are particularly useful in assessing water quality. 

The EPA databases available are: Surf Your Watershed, Index of Watershed Indicators (IWI), 

Reach File, Water Quality File, Industrial Facilities Discharge File, Permit Compliance System, 

BIOS, Complex Effluent Toxicity Information System, Water Body File, Federal Reporting Data 

System, Needs Survey File, and Grants Information Control System. The EPA encourages the 

use of internet resources to the maximum extent in all NEP transactions. 

3. Non Duplication, Consultations, and Other Collection Criteria

3(a) Non Duplication

 The NEP is administered by the Office of Wetlands, Oceans, and Watersheds (OWOW). 

The Governor’s nomination, the annual work plan, the program evaluation, and GPRA reporting 

are unique documents addressing particular NEP requirements. No other EPA office or any other 

Federal, State, or local agency requests these same data organized in this particular manner.

Although there are no duplicative reporting requirements, some data required for the 

Governor’s nomination may be available from other EPA programs and from other Federal, State 

and local agencies. However, no one source contains all the data required for the Governor’s 

nomination. Therefore, the data must be compiled from other sources and organized in a manner 

detailed in the NEP Nomination Guidance and it must reflect the Governor’s priorities and 

recommendations. The Nomination Guidance also affords the States considerable flexibility in 

style and interpretation. Some of the Federal agencies that compile information relevant to the 

Governor’s nomination are the Department of Interior, National Oceanic and Atmospheric 

Administration, and the Natural Resources Conservation Service. In addition, public interest 

groups, such as the Nature Conservancy, may possess appropriate information. For example, 

data on declining fish catches to assess the estuary’s commercial and recreational value can be 

obtained from the National Oceanic and Atmospheric Administration. For annual work plans, 

program evaluations, and GPRA reporting, the NEP Management Conferences are the only

source of information.

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

 EPA Published a Federal Register notice on July 31, 2013 (78 FR 46332) to announce the 

renewal of this ICR. No comments were received.

3(c) Consultations

 The EPA convenes one NEP national meeting each year for the purpose of achieving the 

mission of the Oceans and Coastal Protection Division. The NEP national meeting is held in 

Washington, DC and brings together EPA HQ staff, EPA Regional staff, and NEP Directors and 

staff to discuss policy, budget, and implementation issues on coastal watershed protection. The 

meeting is an annual opportunity to strengthen partnerships with EPA and the NEP community.

EPA also has regulations that address the grants portion of the NEP. These regulations 
8

require that a Management Conference be convened and that certain program objectives are 

complete before funds are awarded under Section 320(g)(3) of the CWA. In addition, EPA has 

issued the guidance package, “The National Estuary Program: Final Guidance on the Contents of 

a Governor’s Nomination.” 

3(d) Effects of Less Frequent Collection 

A Governor’s nomination is submitted on a one-time basis by States that request 

participation in the NEP, and when the Administrator determines that there is an opportunity for 

additional programs with sufficient resources to support these actions. At this time, EPA does 

not anticipate soliciting nominations in the information collection period of 2010-2012. 

Therefore, frequency of collection is not an issue for the reporting requirements contained in this 

ICR. 

Annual work plans are prepared every year and are submitted with the grant application. 

Priorities for Management Conferences can change during a year, and numerous projects are tied 

to the results of projects completed during the year. Therefore, work plans must be developed 

annually to plan and track the progress. 

Program Evaluations (PEs) are conducted every five years. Five years is adequate time 

for significant progress to be made implementing the CCMP. Longer than five years poses the 

risk of not identifying program challenges in time to take corrective action. Waiting longer than 

five years also puts the Agency at risk of funding programs that are not using EPA funds for 

appropriate purposes or achieving expected results. PEs conducted in less than five year 

intervals would be a burden with nominal, if any, increases in useful information.

 GPRA reporting is performed on an annual cycle, typically near the beginning of the new 

fiscal year. Therefore, the NEP GPRA reports need to be provided annually to measure progress 

toward annual targets.

3(e) General Guidelines

This information collection is consistent with OMB guidelines contained in 5 CFR 

1320.6 in that:

 Information is not collected more often than quarterly.

 Responses are not required in less than 30 days.

 Respondents are not required to submit more than an original and two copies of the 

document.

 It does not provide for remuneration of respondents other than contractors or grantees.

 It does not require records to be kept for more than three years.

 It is not in conjunction with a statistical survey.

 Provisions for small businesses and other small entities are appropriate.

 Confidentiality is protected.

 It does not require provision of information in a format other than that which it is 

customarily maintained.
9

3(f) Confidentiality

The Governor’s nomination is considered an application and is confidential until a 

Management Conference is convened. Similarly, applications for 320(g)(3) grants are 

confidential until an offer or award is accepted by the applicant. After acceptance, all documents 

are public.

3(g) Sensitive Questions

No information of a sensitive nature is requested by this ICR.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

 Respondents are mainly State and local government workers. The SIC code applicable to 

the State and local governments is 9511.

4(b) Information Requested

(i) Data items: annual work plans, program evaluation packages, GPRA Reports.

For annual work plans the standard recordkeeping requirement for EPA grants is three years 

after the date the recipient submits the final Financial Status Report (FSR). 

(ii) Respondent Activities: Compiling information on activities for each NEP such as 

restoration projects, outreach material that has been developed, and workshop proceedings. This 

may include reviewing and transmitting information or searching established databases.

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management 

5(a) Agency Activities

 For annual work plans, program evaluation packages, and GPRA reports, the Agency

typically will answer respondent questions, hold conference calls, review and analyze the 

submissions, record the submissions, and store the information.

5(b) Collection Methodologies and Management

 Annual work plans serve as a scope of work for the grant agreement and are submitted in 

hard copy form or electronically as part of the grant application. Program evaluation (PE) 

packages are submitted in hard copy form or electronically. PE submissions may include 

brochures, pictures, and other public outreach tools that have been developed. GPRA reports are 

submitted through an online reporting tool. Quality is checked by follow-up conversations with 

the respondents. For example, with PE, conference calls are set up to go over the PE package 

and discuss overall progress being made implementing the CCMP. The processing technology at 

this time is standard desktop computer with word processing software. Agency staff will enter 

and store some data electronically using these formats. GPRA information is also stored in a 

manner that allows public access through the EPA website. Some information is not electronic 
10

and will be disseminated at conferences and workshops, as appropriate. 

5(c) Small Entity Flexibility

 States and local governments are the most likely respondents to this information request. 

The burden on small organizations is therefore not an issue for the reporting requirements 

contained in this ICR.

5(d) Collection Schedule

 Annual work plans are required each year from the 28 NEPs by June 1st. Program 

evaluations are scheduled as follows: eight NEPs for FY2014 (added one NEP from FY2013 to 

have PE review one year later due to administrative issues), seven NEPs for FY 2015, and zero 

NEPs for FY2016. GPRA reports are submitted annually to correspond with the Agency

reporting process and are requested to be provided by the end of the fiscal year. 

6. Estimating The Burden and Cost of the Collection

6(a) Estimating Respondent Burden

The total number of estuary programs in the NEP is limited by the amount of funds 

appropriated from Congress. Current status and budget projections provide for up to a total of 28 

estuaries in the NEP in FY2010. During the term of this ICR, all 28 are operating in the postCCMP implementation stage which, as discussed in the abstract in section 1(b), concerns 

oversight and implementation of the CCMP. During the post-CCMP phase, the NEPs receive 

significantly less funding and the annual work plan encompasses less effort than those of the preCCMP period. Based on the experience of NEPs to date, we will continue to use the burden hour 

estimates developed for the 2009 ICR calculations for the Agency as well as respondents.

(A) Annual Work Plans: It is estimated that 100 burden hours are required for State personnel to 

prepare and gather information to summarize the previous year’s activities, to plan for the current 

year, and to produce the annual work plan. This is the same value used in the previous review 

cycle. It is expected that Management Conferences will be moving to more improved records 

keeping and tracking, which should result in a lower burden for the following cycle. 

The annual work plan burden to respondent is: 

FY2014: 28 Annual Work Plans

FY2015: 28 Annual Work Plans 

FY2016: 28 Annual Work Plans

28 annual work plans * 100 hours/work plan = 2,800 hours/year

2,800 hours/year * 3 years = 8,400 hours/3 years

(B) Program Evaluations: It is estimated that 280 burden hours per PE review cycle are required 

for respondents to prepare and gather information to summarize the previous period’s activities. 
11

Because it is expected that the NEPs will be continually reviewing and reassessing priorities, 280

hours is considered to be an upper limit on the effort required to prepare a program evaluation 

package. The burden hours for the first two years is a little higher than in the previous ICR 

estimate because in 2011 EPA issued a Program Evaluation Guidance that further align the 

program evaluations with individual NEP priorities and related NEP work plans; therefore more 

effort is required. There will not be any PEs in 2016 so the burden hours in that year will be 0. 

The personnel required to complete this effort is a mix of white collar staff: approximately 55 

percent technical, 5 percent secretarial, and 40 percent administration or managerial level. 

The program evaluation burden to the respondent is:

FY2014: 8 Program Evaluations*

FY2015: 7 Program Evaluations

FY2016: 0 Program Evaluations**

*One NEP PE was shifted from 2013 to 2014.

**EPA will spend this year producing a PE findings report.

15 Program Evaluations 280 hours/report = 4,200 hours/3 years

(C) Government Performance Results Act Reporting: The 2006 ICR value will be used for 

GPRA reporting. The 2006 value was derived based on discussions with respondents. It was 

estimated that an upper limit for burden hours to the NEPs for reporting GPRA information is 60 

hours with a lower limit of ten hours for those NEPs with established information management 

systems in place. The annual average estimate of burden hours for the NEPs to collect and report 

GPRA information is presently 25 hours per report.

The GPRA reporting burden to the respondent is:

FY2014: 28 GPRA Reports 

FY2015: 28 GPRA Reports 

FY2016: 28 GPRA Reports

28 GPRA Reports * 25 hours/report = 700 hours/year

700 hours/year * 3 years = 2,100 hours/3 years

6(b) Estimating Respondent Costs 6(b)(I) Estimating Labor Costs 

(A) Annual Work plans: The post-CCMP annual work plan is estimated to take 100 hours of 

preparation time by State and local government personnel. For estimates on respondent costs, we 

will use the estimates developed for the 2009 ICR from the US Department of Labor’s 

occupational employment statistics employment cost index to calculate the current value of 

dollar. The 2013 mean hourly wage estimate of $28.58 + a benefits/overhead multiplier of 1.6 

will have a current value of $45.30 This amount will be applied for the occupational group of 

life, physical, and social science.
12

The annual work plan cost to the respondent is: 

FY2014: 28 Annual Work Plans 

FY2015: 28 Annual Work Plans 

FY2016: 28 Annual Work Plans 

28 Annual Work Plans * 100 hours/workplan = 2,800 hours/year

2,800 * 3 years = 8,400 hrs/3 years

8,400 hrs/3 years * $45.30hour = $380,520/3 years

(B) Program Evaluations: It is estimated that 280 burden hours are required for respondents to 

prepare and gather information to summarize the previous period’s activities. Because it is 

expected that NEPs will be continually reviewing and reassessing priorities, 280 hours is 

considered to be an upper limit on the effort required to prepare a program evaluation package. 

The mean hourly wage estimate of $45.30 will be applied for the occupational group of life, 

physical, and social science (see Annual Work plan cost description above). 

The Program Evaluation cost to the respondent is:

FY2014: 8 Program Evaluations

FY2015: 7 Program Evaluations

FY2016: 0 Program Evaluations

15 Program Evaluations * 280 hours/report = 4,200 hours/3 years

4,200 hours/5 years * $45.30/hour = $190,260/3 years

(C) Government Performance Results Act Reporting: Based on discussions with respondents, it 

is estimated that an upper limit for burden hours to the NEPs for reporting GPRA information is 

60 hours with a lower limit of 10 hours for those programs with established information

management systems in place. As programs begin to establish tracking systems and information 

management systems the burden hours should decrease. Presently, the annual average estimate 

of burden hours for the NEPs collecting and reporting GPRA information is 25 hours per report.

The mean hourly wage estimate of $45.30 will be applied for the occupational group of life, 

physical, and social science (see Annual Work plan cost description above). 

The GPRA annual reporting cost to the respondent is:

FY2014: 28 GPRA Reports 

FY2015: 28 GPRA Reports 

FY2016: 28 GPRA Reports

28 GPRA Reports * 25 hours/report = 700 hours/year

700 hours/year * 3 years = 2,100 hours/3 years

2,100 hours/3 years * $45.30/hour = $95,130/3 years
13

(6)(b)(ii) Estimating Capital and Operations and Maintenance Costs:

As in the last review cycle, no Capital and Operations and Maintenance Costs are expected. 

(6)(b)(iii) Capital/Start-up Operating and Maintenance (O&M) Costs:

As in the last review cycle, no Capital and Operations and Maintenance Costs are expected.

(6)(b)(iv) Annualizing Capital Costs: N/A

6(c) Estimating Agency Burden and Cost

(A) Annual Work plans:

Part of the overall burden and cost to the Federal Government is based on the number of annual 

work plans expected each year as estimated in Item No. 6(a). The burden also is based on the 

2008 ICR cycle. In the 2008 ICR cycle, reviewing the post-CCMP annual work plan required 16 

hours of Federal workers’ time. These estimates were collected from several EPA Regional 

Offices and also from Headquarters staff reviewers. Cost estimates are based on the 2010 

General Schedule (GS) locality pay for a GS-12, Step 1 Federal employee for the Washington, 

DC area (see http://www.opm.gov/oca/10tables/indexGS.asp). With these estimates applied, the 

hourly wage estimate is $35.88 + a benefits/overhead multiplier of 1.6 (total $57.41). The burden 

and cost to the Federal Government for reviewing annual work plans is summarized below.

The Annual Work Plan burden and cost to the Agency is:

FY2014: 28 Annual Work Plans 

FY2015: 28 Annual Work Plans 

FY2016: 28 Annual Work Plans 

28 Work Plans * 16 hours/plan = 448 hours/year

448 hours/year * 3 years = 1,344 hours/ 3 years

1,344 hours/ 3 years * $57.41/hour = $77,159/3 years

(B) Program Evaluations:

Part of the overall burden and cost to the Federal Government is based on the number of program 

evaluations expected each year as estimated in Item No. 6(a). The whole program evaluation 

process (e.g., reviewing the PE packages, attending conference calls, participating in site visit, 

and issuing PE findings letter) required 60 hours of Federal workers’ time. These estimates were 

collected from several EPA Regional Offices and also from HQ staff reviewers. Cost estimates 

are based on the 2010 General Schedule (GS) locality pay for a GS-12, Step 1 Federal employee 

for the Washington, DC area (see http://www.opm.gov/oca/10tables/indexGS.asp). With these 

estimates applied, the hourly wage estimate is $35.88 + a benefits/overhead multiplier of 1.6 

(total $57.41). The burden and cost to the Federal Government conducting the whole program 

evaluation process is summarized below. 

The Program Evaluation burden and cost to the Agency is:
14

FY2014: 8 Program Evaluations

FY2015: 7 Program Evaluations

FY2016: 0 Program Evaluations

15 Program Evaluations * 60 hours/report = 900 hours/3 years

900 hours/5 years * $57.41/hour = $51,669/3 years

(C) Government Performance Results Act Reporting:

Part of the overall burden and cost to the Federal Government is based on the number of GPRA 

reports expected each year as estimated in Item No. 6(a). Based on Headquarters experience 

approximately 8 hours of Federal workers time is required to review a GPRA report. Cost 

estimates are based on the 2010 General Schedule (GS) locality pay for a GS-12, Step 1 Federal 

employee for the Washington, DC area (see http://www.opm.gov/oca/10tables/indexGS.asp). 

With these estimates applied, the hourly wage estimate is $35.88 + a benefits/overhead multiplier 

of 1.6 (total $57.41). The burden and cost to the Federal Government for reviewing GPRA 

reports is summarized below. 

The GPRA burden and cost to the Agency is:

FY2014: 28 GPRA Reports 

FY2015: 28 GPRA Reports 

FY2016: 28 GPRA Reports

28 GPRA Reports * 8 hours/report = 224 hours/year

224 hours/year * 3 years = 672 hours/3 years

672 hours/3 years * $57.41/hour = $38,580/3 years

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

The total universe of respondents is 28 NEPs for work plans and GPRA reports, as every NEP is 

required to submit annual work plans and GPRA reports over this three year cycle. However, the 

universe of respondents for program evaluations is 22 NEPs over this three year cycle.

Total Burden to Respondent:

Annual Work plans 8,400 hrs/3 years

Program Evaluations 4,200 hrs/3 years

GPRA Reports 2,100 hrs/3 years

TOTAL 14,700 hrs/3 years 

Annualized 4,900 hours/year

Total Cost to Respondent: 

Annual Work plans $380,520/3 years

Program Evaluations $190,260/3 years

GPRA Reports $ 95,130/3 years
15

TOTAL $665,910/3 years

Annualized $221,970/year

Total Burden for Agency: 

Annual Work plans 1,344 hours/3 years 

Program Evaluations 900 hours/3 years

GPRA Reports 672 hours/3 years

TOTAL 2,916 hours/3 years

Annualized 972 hours/year

Total Cost to Agency:

Annual Work plans $77,159/3 years

Program Evaluations $51,669/3 years

GPRA Reports $38,580/3 years

TOTAL $167,408/3 years

Annualized $55,803/year

6(e) Bottom Line Burden Hours and Cost Tables

(I) Respondent Tally Total Burden: 4,900 hours/year Total Cost: $221,970/year

(ii) The Agency Tally Total Burden: 972 hours/year Total Cost: $55,803/year

(iii) Variations in the Annual Bottom Line: It is not anticipated that there will be a significant 

variation (>25%) for the burden or cost to either respondents or Agency over this ICR cycle.

6(f) Reasons for Change in Burden

There is decrease of 933 hours in the total estimated respondent burden compared with 

the ICR currently approved by OMB. This decrease is due to the fact that the respondents are not 

required to submit a program evaluation package in 2016, as a result of modifications made by

EPA to the Program Evaluation Guidance and a redistribution of the number of NEPs to be 

reviewed each evaluation cycle.

6(g) Burden Statement

 The public reporting and recordkeeping burden for this collection of information is 

estimated to average 100 hours per response for Annual Work plans, 250 hours per response for 

program evaluations, and 25 hours per response for GPRA reporting. Burden means the total 

time, effort, or financial resources expended by persons to generate, maintain, retain, 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 
16

or otherwise disclose the information. An agency may not conduct or sponsor, and a person is 

not required to respond to a collection of information unless it displays a currently valid OMB 

control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 

48 CFR Chapter 15. 

 To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OW-2006-0369, which is available for on-line viewing at 

www.regulations.gov or in person at the Water 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 Water Docket is (202) 566-2426). 

An electronic version of the public docket is available at www.regulations.gov. Use 

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. Also, you can send comments to the Office of Information and Regulatory Affairs, Office 

of Management and Budget at oira_submission@omb.eop.gov. Please include the EPA Docket 

ID No. (EPA-HQ-OW-2006-0369) and OMB control number 2040-0138 in any correspondence. 

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This section is not applicable because no statistical procedures are employed for the data 

collection.