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ICR Supporting Statement

Information Collection Request for EPA Application Materials for the Water 

Infrastructure Finance and Innovation Act

OMB Control No. 2040-NEW, EPA ICR No. 2549.01

A. Justification.

1. Explain the circumstances that make the collection of information necessary. 

Identify any legal or administrative requirements that necessitate the collection. 

The collection of information is necessary in order to receive applications for credit 

assistance pursuant to section 5024 of the Water Infrastructure Finance and Innovation 

Act (WIFIA) of 2014, 33 USC 3903. The purpose of the WIFIA program is to provide 

Federal credit assistance in the form of direct loans and loan guarantees to eligible clean 

water and drinking water projects. 

WIFIA requires that an eligible entity shall submit to the Administrator an application at 

such time, in such manner, and containing such information, as the Secretary or the 

Administrator may require to receive assistance under WIFIA. In order to satisfy these 

requirements, EPA must collect a letter of interest and an application from entities seeking 

funding. The relevant section of WIFIA is attached hereto as Exhibit A. EPA is publishing 

this notice to give entities an opportunity to submit applications upon authorization of

funding. This collection is necessary to determine whether each proposed project meets 

creditworthiness and other Federal requirements to receive WIFIA credit assistance.

2. Indicate how, by whom, and for what purpose the information is to be used. Except 

for a new collection, indicate the actual use the agency has made of the information 

received from the current collection.

The letter of interest and the application (attached as Exhibits B and C) collected from 

loan applicants through this solicitation will be used to evaluate applications for credit 

assistance under the WIFIA eligibility requirements and selection criteria. 

3. Describe whether, and to what extent, the collection of information involves the use 

of automated, electronic, mechanical, or other technological collection techniques or 

other forms of information technology, e.g. permitting electronic submission of 

responses, and the basis for the decision for adopting this means of collection. Also 

describe any consideration of using information technology to reduce burden. 

The letter of interest form is available electronically. The letter of interest and supporting 

narrative are submitted entirely via e-mail only. The application is available 

electronically. It is submitted in part electronically and in part via conventional mail, due 

to the size of the application package. To reduce burden and to minimize the number of 
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copies required from the applicant, electronic versions of the application are required via 

CD. 

4. Describe efforts to identify duplication. Show specifically why any similar 

information already available cannot be used or modified for use for the purpose(s) 

described in item 2 above.

The letters of interest and applications will generally be project specific and the 

information is not available elsewhere. 

5. If the collection of information impacts small businesses or other small entities (item 

5 of the OMB form 83-1), describe the methods used to minimize burden.

Eligible applicants under WIFIA include corporations, partnerships, joint ventures, trusts, 

Federal, State, or local governmental entities, agencies, or instrumentalities, tribal 

governments or consortium of tribal governments, and state infrastructure financing 

authorities, which could include small entities. Letters of interest and applications are 

voluntary. EPA cannot minimize the burden to small entities, because WRRDA requires 

all eligible entities to submit an application in order to receive credit assistance. The 

relevant section of WRRDA is attached hereto as Exhibit A.

6. Describe the consequence to federal program or policy activities if the collection is 

not conducted or is conducted less frequently, as well as any technical or legal 

obstacles to reducing burden.

If the collection is not conducted, EPA will be unable to satisfy the statutory mandate to 

require the submission of applications. Therefore, WIFIA credit assistance will not be 

available. In order to provide credit assistance to eligible projects, which is the purpose of 

the program, EPA must collect letters of interest and applications that respond to the 

eligibility requirements and selection criteria.

7. Explain any special circumstances that would cause an information collection to be 

conducted in a manner inconsistent with 5 CFR 1320.6: 

There are no special circumstances. The collection of information is conducted in a 

manner consistent with the guidelines in 5 CFR 1320.6. 

8. Efforts to consult with persons outside the agency to obtain their views

On DATE OF PUBLICATION (Month, day, and year), Vol. No. _____, pages 

__________ to __________, the Agency published the notice of information collection 

and request for comments in the Federal Register. The solicitation is attached as Exhibit 

D. ________ comments were received.
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EPA will consult with persons outside the Agency to obtain their views on the availability 

of data, frequency of recordkeeping, disclosure, or reporting format, and on the data 

elements to be recorded, disclosed, or reported. 

9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees. 

No payments or gifts are provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for 

the assurance in statute, regulation, or agency policy.

EPA cannot offer an assurance of confidentiality to any applicant. The applicant is 

directed to state if any information submitted in its letter of interest, application, or any 

supplementary material may not be released by the Agency upon request from a member 

of the public or otherwise made publicly available. The applicant must identify the 

confidential business information and provide reasons why such information is 

confidential business information and should not be released, including particulars as to 

any competitive harm which would potentially result from the release of such 

information. The Agency will handle requests from the public for release of information 

under its standard Freedom of Information Act procedures. 

11. Provide additional justification for any questions of a sensitive nature.

Questions of a sensitive nature are not found in this information collection.

12. Provide estimates of the hour burden of the collection of information. 

The Agency does not have any directly relevant prior experience on which to base these 

estimates of the hour burden of the collection and the annualized cost to respondents. 

Nevertheless, based on the number and type of interested stakeholders that have contacted 

the Agency about this program, the funding levels for the WIFIA program, and the EPA’s 

application procedures, the EPA estimates that the burden will be as follows, exclusive of 

the hours required for project development:

Letter of Interest:

Letter of Interest Burden per Application

Function Legal Manager Technical Clerical

Read application guidelines 1 1 1

Gather Information 10 5

Complete application form 1

Complete narrative 19
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Review Application 5 5

Compile Application 2

TOTAL 5 6 30 9

 Total number of unduplicated respondents: 20

 Frequency of response: one per respondent

 Annual hour burden per application: 50

 Total annual burden hours: 1,000

Application:

Application Burden per Application

Legal Manager Technical Clerical

Read application guidelines 1 1 1

Gather Information 26 15

Complete application form 1

Complete narrative 30

Review Application 10 10

Compile Application 5

TOTAL 10 11 57 22

 Total number of unduplicated respondents: 5

 Frequency of response: one per respondent

 Annual hour burden per application: 100

 Total annual burden hours: 500

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers

resulting from the collection of information. 

EPA estimates that the total annual cost burden to respondents will be $1,489,594. This 

estimate includes the following:

1. For the letter of interest, EPA estimates 1,000 annual burden hours and the annualized 

cost of those hours is $40,107. 

2. For the application, EPA estimates 500 annual burden hours and the annualized cost of 

those hours is $19,487.

3. In addition, applicants will be charged two fees:

a. An application fee will be due upon submission of the application. For applications 

for projects serving small communities (population of not more than 25,000 people), 

this application fee will be $25,000. For all other applicants, this application fee will 

be $100,000. EPA assumes that one applicant will be a small community. The annual 

application fee will be $425,000.

b. A credit processing fee will be due upon loan closing, to reimburse costs incurred by 
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the EPA due to legal, financial, and other expert contractor help. Due to the nature of 

this fee, the amount is expected to vary between applicants. However, EPA estimates 

these costs as approximately $200,000 per applicant, a portion of which may be 

waived at the discretion of the EPA. The total credit processing fee for five applicants 

will be approximately $1,000,000.

4. The cost of general expenses for submitting an application, such as supplies, delivery 

charges, mailing, copying, and telecommunications, will be $1,000. The total general 

expenses will be $5,000.

Note: EPA used the following median hourly wages from the May 2015 National 

Occupational Employment and Wage Estimates United States

(http://www.bls.gov/oes/current/oes_nat.htm) from the U.S. Bureau of Labor Statistics to 

calculate the cost of the estimated burden hours:

 Lawyers= $55.69

 Management= $47.38

 Engineers= $43.30

 Office and Administrative Support= $15.96

14. Provide estimates of annualized cost to the federal government. 

The estimated cost to the Federal government of this request for letters of interest and 

applications is $325,150. This cost reflects three components:

1. EPA will establish an evaluation process to review each of letter of interest and 

application and to determine which projects will receive WIFIA funding. This process 

includes technical, financial, and management review of the letters of interest. Then, 

additional technical, financial, and management review of the applications. EPA 

estimates that this process will require the equivalent of five FTE per year. 

The estimated average annual cost for EPA personnel is $95,704 based on the General 

Schedule (GS) 13, Step 05 level from the 2016 GS salary table. The annual cost was then 

multiplied by the standard government benefits multiplication factor of 1.6 to calculate an 

estimated annual pay including benefits per FTE of $153,126. Therefore, the estimated 

annualized cost for the evaluation team is $765,632. EPA plans to use the application fees 

to offset these costs. Assuming one application from a small community and four other 

applications per year, the total fees collected will be $425,000. Consequently, the net 

estimated annualized cost to the Federal Government for the evaluation team is $340,632.

2. EPA will hire legal, financial, and other expert contractor support for credit processing. 

These costs are estimated to be $200,000 per application and are expected to be 

reimbursed in full by the applicants. The net estimated annualized cost to the Federal 

Government for credit processing is $0.
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3. EPA will print application materials. EPA does not expect to need any special equipment 

or support, other than printing. As noted above in item 12, EPA expects 20 letters of 

interest and 5 applications. If each letter of interest is 25 pages and each application is 50

pages, as requested in the solicitation, EPA may need to print as many as 750 pages for 

staff involved in the evaluation process. EPA estimates up to 10 staff may need materials 

which adds up to a total of 7500 pages of printing. EPA’s printing costs are 

approximately 2 cents per page, which adds up to a total printing cost of $150. 

15. Explain the reason for any program changes or adjustments reported in items 13 or 

14 of the OMB form 83-1. 

This is a new information collection at EPA.

16. For collections of information whose results will be published, outline plans for 

tabulation, and publication. 

The letters of interest and applications collected for the WIFIA program will not be 

published. EPA will maintain a publicly available list of projects that have submitted 

letters of interest and applications to the WIFIA program.

17. If seeking approval to not display the expiration date for OMB approval of the 

information collection, explain the reasons that display would be inappropriate. 

The Agency plans to display the expiration date for OMB approval of the information

collection on all instruments.

 

18. Explain each exception to the certification statement identified in item 19, 

"certification for paperwork reduction act submissions," of OMB form 83-1. 

The Agency is able to certify compliance with all provisions under Item 19 of OMB Form 

83-I.”