## Information Collection Request for Final National Pollutant

Discharge Elimination System (NPDES) Small Vessel General

Permit for Disch arges Incidental to the Normal Operation of

Vessels Less than 79 Feet (sVGP)

OMB Control No. 2040

- NEW , EPA ICR No. 2504.01

August 25, 201 4

United States Environmental Protection Agency Office of Wastewater Management 1200 Pennsylvania Avenue, NW Washington, DC 20460ii



## Content s

1. Identification of the Information Collection

................................ ................................ ............... 1 1(a) Title of the Information Collection

................................ ................................ ...................... 1 1(b) Short Characterization/Abstract

................................ ................................ .......................... 1

2. Need For and Use of the Collection

................................ ................................ ............................ 3 2(a) Need/Authority for the Collection

................................ ................................ ....................... 3 2(b) Practical Utility/Users of the Data

................................ ................................ ...................... 3

3. Non

- duplication, Consultations, and Other Collection Criteria

................................ .................. 5 3(a) Non

- duplication

................................ ................................ ................................ ................... 5 3(b) Public Notice Required Prior to ICR Submissions to OMB

................................ ............... 5 3(c) Consultations

................................ ................................ ................................ ....................... 5 3(d) Effects of Less Frequent Collection

................................ ................................ .................... 5 3(e) General Guidelines

................................ ................................ ................................ .............. 6 3(f) Confidentiality

................................ ................................ ................................ ..................... 6 3(g) Sen sitive Questions

................................ ................................ ................................ ............. 7 4. The Respondents and the Information Requested

................................ ................................ ...... 8 4(a) Respondents/Standard Industrial Classification (SIC) Codes

................................ ............. 8 4(b) Information Requested

................................ ................................ ................................ ........ 9

5. The Information Collected

— Agency Activities, Collection Methodology, and Information

Management

................................ ................................ ................................ ................... 9 5(a) Agency Activities

................................ ................................ ................................ ................ 9 5(b) Collection Methodology and Management

................................ ................................ ....... 10 5(c) Small Entity Flexibility

................................ ................................ ................................ ..... 10 5(d) Collection Schedule

................................ ................................ ................................ ........... 11 6. Estimating the Burden and Cost of the Collection

................................ ................................ .... 12 6(a) Estimating Respondent Burden

................................ ................................ ......................... 12 6(b) Estimating Respondent Costs

................................ ................................ ............................ 13 6(b)(i) Estimating Labor Costs

................................ ................................ ............................. 13 6(b)(ii) Operating and Maintenance (O&M) Costs

................................ .............................. 13 6(b)(iii) Capital/Start

- up Costs

................................ ................................ ............................. 13 6(c) Estimating Agency Burden and Cost

................................ ................................ ................ 13 6(d) Estimating the Respondent Universe and Total Burden and Costs

................................ ... 14 6(e) Bottom Line Burden Hours and Cost Tables

................................ ................................ .... 15 6(e)(i) Respondent Tally

................................ ................................ ................................ ....... 15 6(e)(ii) The Agency Tally

................................ ................................ ................................ ..... 15 6(f) Reasons for Change in Burden

................................ ................................ .......................... 15 6(g) Burden Statement

................................ ................................ ................................ .............. 15



### Tables
Table 6.1 Respondent Tally

................................ ................................ ................................ .......... 15 Table 6.2 Agency Tally

................................ ................................ ................................ ................. 151. Identification of the Information Collection

1



## 1. Identification of the Information Collection

1(a) Title of the Information Collection

Title : Small Vessel General Permit (sVGP) ( New )

OMB Control Number: 204 0

- New

EPA ICR Number: 2504.01



## 1(b) Short Characterization/Abstract

This new Information Collection Request (ICR) is for the Small Vessel General Permit (sVGP)

.

The objective of the Clean Water Act (CWA) is to restore and maintain the chemical, physical, and biological integrity of the nation ’ s waters (CWA section 101). The NPDES program, established under CWA section 402, is an important tool for controlling pollutant discharges.

The CWA authorizes the Agency to issue permits for the discharge of pollutants to waters of the

United States. The Agency regulates point source discharges of pollutants to waters of the United States under its NPDES program. CWA section 402(b) allows states (defined to include Indian tribes and U.S. territories) to acquire authority for the NPDES program. This authori ty enables them to issue and administer NPDES permits. At present, 46 NPDES

- authorized states and the U.S. Virgin Islands have NPDES permit program authority

. In states that do not have authority for these programs, the Agency issues and administers NPDES permits. However, discharges formerly excluded under 40 CFR 122.3 are not “subject to” authorized state programs. The vessel discharges that will be covered by the sVGP are discharges formerly excluded from NPDES permitting programs under 40 CFR 122.3. T herefore the discharges at issue are not considered a part of any currently authorized state NPDES program. See 40 CFR 123.1(i)(2) (where state programs have a greater scope of coverage than “required” under the federal program, that additional coverage is not part of the authorized program) and 40 CFR 123.1(g)(1) (authorized state programs are not required to prohibit point source discharges exempted under 40 CFR122.3). S ince the sVGP is administered at the federal level, this ICR does not include burden and costs for state permitting activities

.

The information collection provisions associated with the sVGP include the following:

 Activities directly related to obtaining coverage under t he general permit: Permit Authorization and Record of Inspection (PARI)

,

 Inspections,

 Reporting,

 Recordkeeping

, and

 Activities resulting from compliance assessments or enforcem ent actions

.

The primary users of this information will be E PA and the permitt ees . It is anticipated that other government agencies, both at the s tate and f ederal level, as well as public interest groups, private companies, and individuals will also use the data.1. Identification of the Information Collection

2

In summary, this ICR estimates a burden of 138,597 hours annually for 137,739 respondents (permittees) at a cost of $ 5

. 064 million ($ 5

. 064 million in labor cost and $ 0 in capital and O&M costs). Agency burden is 472 hours annually at a cost of $ 0.02 million.2. Need F or and U se of the Collection

3



## 2. Need F or and U se of the Collection

2(a) Need/Authority for the Collection

On March 30, 2005, the U.S. District Court for the Northern District of California ( in Northwest

Environmental Ad

vocates et al. v. EPA ) ruled that the EPA regulation excluding discharges incidental to the normal operation of a vessel from NPDES permitting exceeded the Agency’s authority under the Clean Water Act (CWA). EPA appealed the District Court's decision, and on July 23, 2008, the Ninth Circuit upheld the decision. In response , EPA developed permitting requirements for discharges incidental to the normal operation of a vessel into certain inland

waters or the territorial sea of the United States under the NPDES program. The Vessel General Permit (VGP) , issued in 2008 and reissued in 2013, covers discharges incidental to the normal operation from non

- military, non

- recreational commercial vessels greater than 79 feet in length. Information collection requirements for the VGP , as well as for all NPDES individual permits, and many other general permits, are included in EPA’s National Pollutant Discharge Elimination System (NPDES) Program ICR (EPA ICR No. 229.20, OMB Control No. 2040

- 0004, approved

12/27/12 and effect ive through 12/31/15).

In July 2008, the president signed into law Public Law (P.L.) 110

- 299 which imposed a two

- year moratorium during which time neither EPA nor states may require NPDES permits for discharges incidental to the normal operation of commercial fishing vessels and other non

recreational vessels less than 79 feet , unless they have ballast water . Consistent with P.L. 110

- 299, the VGP and associated ICR do not cover vessels less than 79 feet or commercial fishing vessels, unless they hav e ballast water discharges.

The moratorium on permitting of non

- recreational vessels l ess than 79 feet and commercial fishing vessels has been extended two additional times (P.L. 111

- 215 and P.L. 112

- 213) and is currently in place through December 18, 2014 . However, t o ensure that permit coverage is

available for the non

- recreational vessels less than 79 feet upon expiration of the moratorium,

EPA developed the s mall V essel G eneral P ermit (sVGP)

. 1 Specifically, the sVGP cover s discharges incidental to the normal operation of all non

- recreational, non

- military commercial vessels less than 79 feet in length. Small commercial vessels are substantially different in operation from larger commercial vessels, and the sVGP contains simpler provisions than the

VGP. Primarily, the sVGP require s technology

- based effluent limits expressed as best management practices (BMPs).



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

This ICR includes information used primarily by EPA and permittees

. The vast majority of these

data must be maintained on

- board the vessel by the permittee. T his information can be categorized into two sets: identification information and information related to the vessel ’s

1 Commercial fishing vessels greater than 79 feet are not eligible for coverage u nder the sVGP but can do so under the VGP. Burden and cost for commercial fishing vessel activities are included in EPA’s National Pollutant Discharge Elimination System (NPDES) Program ICR (EPA ICR No. 229.20, OMB Control No. 2040

- 0004, approved 12/27/12 and effective through 12/31/15).2. Need F or and U se of the Collection

4

discharges or practices. I nformation such as the name, location, an d description of vessels can be

used to uniquely identify each vessel and identify a contact person and highlight the fact that the

vessel is covered under the sVGP

. Information related to vessel discharges and practices can be used to assess compliance wi th permit requirements and to demonstrate that adequate r esponse is taken to address any identified problems that may lead to excess discharges of pollutants to waters covered by the sVGP.3. Non

- duplication, Consultations, and Other Collection Criteria

5 

## 3. Non

- duplication, Consultations, and Other
Collection Criteria

3(a) Non

- duplication

Almost all information requested from respondents under this ICR is required by statute or regulation and, in most cases, is not available from other sources. EPA has examined all other reporting and record

- keeping requirements contained in the CWA and 40 CFR Parts 122, 123, 124, 125, 403, 501, and 503. EPA also has consulted the following sources of information to

determine if similar or du plicate information is available elsewhere:

 The EPA Inventory of ICRs;

 S imilar requirements by the U.S. Coast Guard. For example, the “Phase I discharge standard”, which follow the International Maritime Organization (IMO) “Regulation D

- 2” and CFR 162 (MAR POL Annex I implementing regulations).



## 3(b) Public Notice Required P rior to ICR S ubmissions to OMB

Announcement of t his ICR is published in the Federal Register

. The notice include s a request for comments on the content and impact of these information coll ection requirements on the regulated community

. 

## 3(c) Consultations

Before the sVGP was finalized

, the public had 83 days to comment on the draft permit which was published in the Federal Register along with the draft VGP on December 8, 2011 (76 FR 76716)

. At that time, EPA sought the views of the interested public o n requirements contained in both permits (and the accompanying fact sheets and economic analyses), and any changes or

additions recommended for the final permits . EPA also hosted at least two pub lic meetings and one webcast to present the proposed requirements of the permits , to receive public comment, and to answer questions concerning the proposed permit s

. EPA h eadquarters staff responsible for oversight in the vessels program area were contacte d to provide revised information, data, and

review for this ICR.



## 3(d) Effects of Less Frequent Collection

EPA recognizes the importance of balancing the need for data collection efforts against respondent burden and costs. From the inception of the NPDES program, cost has been one of the major factors considered in establishing application requirements, monito ring conditions, and report contents and frequencies. In the past several years, the executive and legislative branches of the U.S. government have stressed the need to evaluate the costs and benefits of regulation and the financial impact on the regulated community, state, and local government. EPA regularly seeks new opportunities to reduce burden on the regulated community.

T he information needed to meet permitting, monitoring, reporting

, and information collection requirements related to the sVGP is co llected one time, at a regular frequenc y, or as needed. EPA

need s current information about permittees, discharge characteristics, enforcement actions, and3. Non

- duplication, Consultations, and Other Collection Criteria

6 program performance to fulfill oversight responsibilities. The NPDES burden described in this

ICR id entifies the burden that EPA has determined as necessary

. For example, less frequent reporting would not provide enough data for EPA to effectively provide guidance, to review or comment on actions, or to intervene in compliance or enforcement cases

, as ne cessary.

EPA and states also have made extensive use of general permits, which tend to have less burdensome monitoring and reporting requirements than individual permits. In fact, the majority of stormwater permittees, which comp o se more than three quarte rs of all NPDES permittees

, are covered under general permits.

The CWA prohibits NPDES permits from having terms longer than 5 years. Thus, permitted facilities must obtain coverage under the new or re

- issued NPDES permits at least once every 5 years. Thi s 5

- year time frame provides a mechanism for EPA and permittees to take advantage of technological advancements and for permittees to read the new/re

- issued permit and take any actions necessary to ensure that their discharge practices are consistent with permit requirements (which typically change to some extent every five years as permits are re

- issued). Permits must contain conditions that reflect, for example, the following criteria:

 New industrial processes and waste treatment technologies;

 New kinds of discharges (such as toxic chemicals);

 New analytical detection methods; and

 Changes in the quality of receiving waters.

Some of the information in this ICR that is required to be collected is only after the permittee violates a permit condition or afte r a certain condition occurs. For example, noncompliance reports are submitted annually if the vessel identifies some type of noncompliant event during the year

. 

## 3(e) General Guidelines

This information collection is consistent with OMB guidelines contain ed in 5 CFR 1320.5(d)(2)

. Requests for supplemental information for the purposes of emergency response or enforcement activities are exempt from the Paperwork Reduction Act requirements.



## 3(f) Confidentiality

Certain respondent reports can contain confidential business information. If this is the case, the respondent may request that such information be treated as confidential. All confidential data will be handled in accordance with 40 CFR 122.7, 40 CFR Part 2, and EPA’s Security Manual

Par t III, Chapter 9, dated August 9, 1976. Any claim of confidentiality must be asserted at the time of submission. However, CWA section 308(b) specifically states that effluent data may not

be treated as confidential.3. Non

- duplication, Consultations, and Other Collection Criteria

7 

## 3(g) Sensitive Questions

Sensitive questions are defined in EPA ’ s ICR Handbook, Guide to Writing Information Collection Requests Under the Paperwork Reduction Act of 1995 as “questions concerning sexual behavior or attitudes, religious beliefs, or other matter s usually considered private.” The requirements addressed in this ICR do not include sensitive questions.4. The Respondents and the Information Requested

8



## 4. The Respondents and the Information Requested

4(a) Respondents/

Standard Industrial Classification ( SIC )
Codes

Industries potentially covered by the sVGP include the water transportation industry (NAICS

codes 483

—

Water Transportation; 4872

— Scenic and Sightseeing Transportation, Water; and

4883

— Support Activities for Water Transportation; SIC code 44

— Water Transportation) and the fishing industry (NAICS cod e 11411

— Fishing; SIC code 0912 Fishing, hunting, and trapping, Finfish). An overview of the basis of EPA’s estimates of the total number of domestic and foreign vessels covered by the sVGP are as follows:

Domestic Vessels

Size Commercial
Fishing Other Non

Recreational Unspecified

Vessel Type TOTAL b

Less than 79 ft 54,176 32, 799 15,01 1

114,996
137,583 Zero or Null a 13,537 9,6 96 12,36 4
Total (lower bound estimate) c 67,178 32,806 15,012

Total (upper bound estimate) d 67,713 42,495 27,375

Source: U.S. EPA, 2010, as determined from data compiled by the U. S. Coast Guard, MISLE database, 2009

a MISLE indicates a length of zero or the vessel length field is blank.

b Range indicates number of vessels when excluding (lower bound) vs. including (higher bound) vessels with
zero or unknown length. Note that the estimates may include some vessels that are used in non

- recreational service (e.g., commercial fishing or law enforcement) but that were manufactured as pleasure vessels.

c Includes a fraction of ve ssels with length reported as zero or null in the MISLE database, based on the share of vessels in the overall vessel population for each vessel type that are reported to be less than 79 feet (96%
of commercial fishing vessels, 0.1% of other non

- recreation al vessels, and 0.0% of vessels of unspecified

ty pe).

d Assumes all vessels with length reported as zero or null in the MISLE database are less than 79 ft.

Foreign Vessels

Vessel Type Total Foreign Vessels a

Count Percentage of Total

Utility Vessel 85 54
Commercial Fishing Vessel 38 24
Freight Ship 18 12
Tank Ship 6 4
Freight Barge 6 4
Passenger vessel 2 1

Other 1 1

Total 156 100

Based on data from FTVEC data for 2008, 2009, and 2010.

a Includes only vessels less than 150 gross registered tons in weight.

For calculating burden and costs, EPA uses the combined upper bound domestic and foreign

vessel estimates of the universe ( 137,583 + 156 = 137,739).4. The Respondents and the Information Requested

9



## 4(b) Information Requested

This section presents the data items, including record

- kee ping requirements, and required respondent activities involved in preparing and submitting those data items

.

Small Vessel General Permit Activities

– Permit Authorization and Record of Inspection Recordkeeping and routine visual inspections are already required or performed as a matter of regular business for non

- recreational vessels. However, additional time for these tasks may be required to comply with certain requirements specific to the sVGP. For example, for recordkeeping, the sVGP introduces additional paperwork in the form of the Permit Authorization and Record of Inspection (PARI) Form

. For the vessels covered under the s VGP, the only recordkeeping requirement is to sign, date, and certify to completion of quarterly inspections on the PARI Form and maintain a copy of th at form onboard the vessel.

Standard Condition

- Permittee Report of Anticipated Noncompliance

The requirement to submit a Permittee Report of Antici pated Noncompliance in 40 CFR 122.41(l)(2) applies to a change in the permitted activities that may result in noncomplia nce with existing permit requirements.

Standard Condition

– Twenty

- Four Hour Reporting Requirements in 40 CFR 122.41(l) (6 ) specif y tha t a permittee must report any noncompliance which may endanger health or the environment (with oral notification required within 24 hours

and a written follow

- up submission due within 5 days).

Standard Condition

– Other Noncompliance Requirements in 40 CFR 122.41(l) ( 7) specif y that a permittee must report all instances of noncompliance not otherwise reported at the time monitoring reports are provided. Since the sVGP does not require monitoring reports, the permit specifies that these noncompliance repo rts must be provided annually, as necessary , consistent with 40 CFR 122.44(i)(5)

.

Standard Condition

– Other Reports Additional standard conditions in 40 CFR 122.41 apply to permittees covered under the sVGP; however, EPA does not expect any vessels will meet requirements to submit those reports. Th is

includes permittee report of planned facility changes, permittee report of inaccurate previous information, facility and permit transfer report, unanticipated bypass/upset reports, and other

reports. Estim ates of the burden associated with these other reports are included in EPA’s National Pollutant Discharge Elimination System (NPDES) Program ICR (EPA ICR No. 229.20,

OMB Control No. 2040

- 0004, approved 12/27/12 and effective through 12/31/15).



## 5 . The Information Collected

— Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA ’ s activities as the NPDES permitting authority in charge of administering the sVGP are:5. The Information Collected

— Agency Activities, Collection Methodology, and Information Management

10  Process reports rel ated to standard permit conditions (Permittee Report of Planned Facility Changes, Permittee Report of Anticipated Noncompliance, and Permittee Report of Inaccurate Previous Information)

Information for permittees covered under general permits might be entered into a database

. EPA uses these data to manage the NPDES program, for example, to develop statistical summaries on such things as permit compliance rates, permit issuance rates , to evaluate problems resulting from citizen complaints, focus inspecti on efforts, conduct spot check reviews, and determine appropriate enforcement action

. 

## 5(b) Collection Methodology and Management

EPA maintains some application data in databases such as PCS, ICIS

- NPDES, and the NOI

database

. These systems provide EPA with a nationwide inventory of permit holders

. EPA

h eadquarters uses this information to assess permit compliance

. This technology also reduces the burden to EPA and the states for gathering and analyzing national permit and water quality data.

In collecting a nd analyzing the information associated with sVGP permit coverage, EPA may use PCS, ICIS

- NPDES, and electronic NOI (eNOI) systems; paper

- based forms; personal computers; and databases to ultimately store the information

. EPA will ensure accuracy and comple teness of the information by reviewing each submittal upon receipt and is responsible for ensuring that applicable data are entered into PCS or ICIS

- NPDES

. Any form that is considered inaccurate or incomplete will not be accepted and will be returned to th e sender with a letter requesting

correction or the missing information.

Upon request to EPA, the public may access certain information via PCS, ICIS

- NPDES , Online Tracking Information System (OTIS), or Enforcement and Compliance History Online (ECHO)

. So me of the information is available to the public through W eb

- based interfaces of these

databases or other EPA W eb

- based tools such as Envirofacts.



## 5(c) Small Entity Flexibility

For many reasons, EPA believes the reporting requirements discussed in this ICR do not place an

unreasonable burden on small business

. For one, EPA developed two separate General Permit schemes with significantly different requirements for commercial vessels greater than 79 feet in length (VGP) and vessels smaller than 79 feet in len gth (sVG P ) with the burden on small businesses from the sVGP being significantly less than that for the same type of entities operating under the VGP. EPA developed two different permits, with different requirements to

tailor the information collection de mands considering, among other factors, the size and complexity of the vessels

. Generally, as the size of a vess el increases, the amount of required information increases correspondingly.

EPA has regularly looked for ways to reduce reporting burdens on businesses of all sizes

. That is why EPA developed general permit procedures to reduce burdens associated with the application

process for vessels.5. The Information Collected

— Agency Activities, Collection Methodology, and Information Management

11 

## 5(d) Collection Schedule

The CWA prohibits NPDES permits from having terms longer than 5 years. Thus, permitted facilities must obtain coverage under the new or re

- issued NPDES permits at least once every 5 years. This 5

- year time frame provides a mechanism for EPA and permittees to take advantage of technological advancements and for permittees to read th e new/re

- issued permit and take any actions necessary to ensure that their discharge practices are consistent with permit requirements (which typically change to some extent every five years as permits are re

- issued). The sVGP does not require permittees to submit any type of document to obtain permit coverage; rather, permittees are required to complete the PARI and retain a copy of that document on

- board the vessel. Other reports required under the sVGP are required only on an as needed basis and for

wh ich there is no set required schedule

.6. Estimating the Burden and Cost of the Collection

12



## 6. Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden

This sect ion presents the estimated respondent burden for each information request.

Small Vessel General Permit Activities

– Permit Authorization and Record of Inspection Based on the relative simplicity of the Permit Authorization and Record of Inspection (PARI ),

EPA assumes that 1.0 hour (0.25 hours per quarterly inspection) will be required to comply with the sVGP paperwork burden per year. To calculate EPA assumes that all of the approximately

13 7

, 739 vessels (higher end estimate) will incur this 1.0 hour burden per year of compliance costs, regardless of their type, and that all vessels must perform these tasks each.

Standard Condition

- Permittee Report of Anticipated Noncompliance EPA estimates the annual number of NPDES respondents reporting ant icipated noncompliance

to be 0. 0 1 percent of vessels covered by the general permit for a total of 14 annual respondents.

The estimated ti me to complete the report is 5 hours. This burden is divided as follows: 1 hour

to read and understand the re quirement , 1 hour of planning, 1 hour of collecting information, and 2 hours for writing and submitting the report.

Standard Condition

– Twenty

- Four Hour Reporting When a permittee violates a permit condition which may endanger health or the environment,

oral noti fication is due within 24 hours and a written follow

- up submission is due within 5 days. EPA estimates that 0.01 percent (14) of the 137,739 vessels covered by the general permit will have an incident requiring verbal notification and written follow

- up. The estimated time to complete the verbal notification is 5 hours and the time to co mplete the written report is 2 hours

for a total of 7 hours per response

.

Standard Condition

– Other Noncompliance When a permittee violates a permit condition, it must submit a noncompliance report to the permitting authority

. EPA estimates that 0.1 percent ( 138 ) of the 13 7

, 739 vessels covered by the general permit will have such a noncompliant event annually, thereby requiring written

notification to EPA

. The estimated time to complete the written report is 5 hours.

Standard Condition

– Other Reports EPA determined that vessels covered under the sVGP likely will not have to submit other types of reports as specified in 40 CFR 122.41 and as such, the Agency did not calcu late the burden associated with other types of reports. This includes permittee report of planned facility changes, permittee report of inaccurate previous information, facility and permit transfer report, unanticipated bypass/upset reports, and other rep orts. Estimates of the burden associated with these other reports are included in EPA’s National Pollutant Discharge Elimination System (NPDES) Program ICR (EPA ICR No. 229.20, OMB Control No. 2040

- 0004, approved 12/27/12 and effective through 12/31/15)

.6. Estimating the Burden and Cost of the Collection

13



## 6(b) Estimating Respondent Costs

With burden hour estimates in place from Section 6(a), the next step is to estimate the labor cost per respondent and the capital costs required to complete each activity

. The total cost for each respondent activity is com p o sed of the following :

 Labor Cost;

 Operating and Maintenance (O&M) Cost; and

 Capital/Start

- up Cost.



### 6(b)(i) Estimating Labor Costs

Based on the information presented in the Economic Analyses, EPA used a vessels labor rate of $36

. 54 in 2014 dollars when estimating the costs of incremental labor hours. This rate is based on the average 20 07 labor rate used in the 2008 VGP analysis, which reflects the average across industry sectors based on input from industry representatives. Labor rate was escalate d from

2007 to 201 4 dol lars using the Bureau of Labor Statistics Employment Cost Index (ECI) of

1. 156

. At 138,597 hours per year, this equates to $ 5,064,298 annually in labor costs associated with respondent burden.



### 6(b)(ii) Operating and Maintenance (O&M ) Costs

C alculations in th is ICR account for labor costs only

. No O&M costs are anticipated for this

action

. 

### 6(b)(iii) Capital/Start

- up Costs

All calculations in this ICR account for labor costs only. No capital costs are expected for the

ICR.



## 6(c) Estim ating Agency Burden and Cost

This section presents the estimated agency burden for each information request and the associated agency cost

. A summary of the burden and cost is provided at the end of this section.

S tandard Condition

- Permittee Report of Anticipated Noncompliance As the permit authority, EPA will handle and review Permittee Reports of Anticipated Noncompliance. EPA estimates it will spend 10 hours for each report received.

Standard Condition

– Twenty

- Four Hour Reporting As the permit a uthority, EPA will handle and review twenty four hour reports and follow

- up reports. EPA estimates it will spend 2 hours for verbal notification and 2 hours for written notification for a total of 4 hours for each incident reported.

Standard Condition

– Other Noncompliance As the permit authority, EPA will handle and review other noncompliance reports. EPA

estimates it will spend 2 hours for each report.6. Estimating the Burden and Cost of the Collection

14

EPA determined the hourly employment cost of federal employees using methodology

established in previous ICRs. According to the U.S. Office of Personnel Management, 2014 General Schedule (2014

- GS), the average annual salary of a government employee at the GS

- 9, Step 10 level is $54,570. At 2,080 hours per year, the hourly wage is $26.24. Assuming ove rhead costs of 60 percent, or $15.74 per hour, the fully loaded cost of employment for a federal employee is $41.98.

Agency Burden and Cost

Activity Hours per Response No. Annual

Responses Total Annual Agency

Burden (hrs) Total Annual Agency Cost Permittee Report of Anticipated Noncompliance 10 14 140 $5,877

24

- Hour Reporting 4 14 56 $2,351 Other Noncompliance 2 138 276 $11,586 Total Agency 166 472 $19,814



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

Detailed information describing the universe and basis for burden and costs is provided in

S ection 6(a)

. R esults are presented below.

Respondent s Activities

Activity Hours per Response Respondent

Type No. Annual

Responses Total Annual

Burden (hrs) Total Annual Cost

Permit Authorization
and Record of Inspection (PARI) 0. 2 5 All small

vessels 550,956 137,739 $ 5

, 032

, 983

Permittee Report of Anticipated Noncompliance 5 S mall vessels

with anticipated noncompliance 14 70 $2,521

24

- Hour Reporting 7 Small vessels

with certain types of noncompliance 14 98 $3,581

Other Noncompliance 5 Small vessels

with noncompliance 138 690 $25,213

Total Respondent
Activities 551,122 138,597 $ 5,064,2986. Estimating the Burden and Cost of the Collection

15



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

6(e)(i) Respondent Tally

The bottom line burden hours and costs for facilities and authorized states are the average annual hours and costs collectively incurred for all activities during the 3

- year period covered by this

ICR

. Table 6

. 1 provides a summary of the average annu al number of respondents, burden hours,

and costs

.

Table 6. 1 Respondent T ally

Permittees S tates / t ribes/ t erritories Totals

Unique Respondents (number) 137,739 0 137, 739 Responses (number) 551,122 0 551,122 Burden (hours) 138,597 0 138,597

Costs (labor) $5,064,298 $0 $5,064,298
Costs (capital) $0 $0 $0
Costs (O&M) $0 $0 $ 0

Total costs $5,064,298 $0 $5,064,298



### 6(e)(ii) The Agency Tally

The bottom line burden hours and costs for the Agency are the total annual hours and costs

collectiv ely incurred for all activities during the period covered by this ICR

. Table 6

. 2 provides a summary of the average annual A gency burden hours and costs

.

Table 6. 2 Agency T ally Responses (number) 166 Burden (hours) 472 Costs (labor) $ 19,814

Costs (capital) $0
Costs (O&M) $0

Total costs $19,814



## 6(f) Reasons for Change in Burden

Th is is a new ICR. The respondent and Agency tallies identified above represent new burden

hours and costs.



## 6(g) Burden Statement

The calculations made for this ICR cover the burden and costs for EPA and vessel operators

. This ICR estimates a burden of 138,597 hours annually for 137,739 respondents (permittees) at a cost of $ 5

. 064 million ($ 5

. 064 million in labor cost and $ 0 in capital and O&M costs). Agency

burden is 472 hours annually at a cost of $ 0.02 million. The annual reporting and record

- kee ping burden for this collection of information is estimated to average 1 hour per respon dent (0.25

h ours per respon se )

.6. Estimating the Burden and Cost of the Collection

16

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, or disclose or provide information to or for a f ederal agency

. This includes the time needed to review instructions; develop, acquir e, 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 a pplicable 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 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 number s for EPA ’ s regulations are

listed in 40 CFR Part 9 and 48 CFR chapter 15.

To comment on EPA ’ 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, the Agency has established a public docket for this ICR under Docket ID

No. EPA

- HQ

- OW

- 2011

- 0150 (Draft 2013 sVGP) , which is available for public viewing 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 avail able through the Federal Docket Management System (FDMS) at http://www.regulations.gov/

. Use FDMS to submit or view public comments, to access the index listing of the contents of the public docket, and to access documents in the public docket that are ava ilable electronically

. Once in the system, key in the

docket ID number identified above

. You can also send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA

. Please include the EPA Docket ID No. in any correspondence

.