Information Collection Request for Final National Pollutant 

Discharge Elimination System (NPDES) Small Vessel General 

Permit for Discharges Incidental to the Normal Operation of 

Vessels Less than 79 Feet (sVGP)

OMB Control No. 2040-NEW, EPA ICR No. 2504.01

August 25, 2014

United States Environmental Protection Agency

Office of Wastewater Management

1200 Pennsylvania Avenue, NW

Washington, DC 20460
ii

Contents

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) Sensitive 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................................................................................................................. 15
1. 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: 2040-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 authority 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. Therefore 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). Since 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 the general permit: Permit 

Authorization and Record of Inspection (PARI),

 Inspections,

 Reporting,

 Recordkeeping, and 

 Activities resulting from compliance assessments or enforcement actions.

The primary users of this information will be EPA and the permittees. It is anticipated that other 

government agencies, both at the state and federal 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 For and Use of the Collection

3

2. Need For and Use 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 Advocates 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 effective 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 nonrecreational 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 have ballast water discharges.

The moratorium on permitting of non-recreational vessels less 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, to ensure that permit coverage is 

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

EPA developed the small Vessel General Permit (sVGP).

1 Specifically, the sVGP covers

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 requires 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. This 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 under 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 For and Use of the Collection

4

discharges or practices. Information such as the name, location, and 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 with permit requirements and to demonstrate that adequate response 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 duplicate information is available elsewhere:

 The EPA Inventory of ICRs;

 Similar 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 (MARPOL Annex I implementing regulations).

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

Announcement of this ICR is published in the Federal Register. The notice includes a request for 

comments on the content and impact of these information collection 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 on 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 public meetings and 

one webcast to present the proposed requirements of the permits, to receive public comment, and 

to answer questions concerning the proposed permits. EPA headquarters staff responsible for 

oversight in the vessels program area were contacted 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, monitoring 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.

The information needed to meet permitting, monitoring, reporting, and information collection 

requirements related to the sVGP is collected one time, at a regular frequency, or as needed. EPA 

needs current information about permittees, discharge characteristics, enforcement actions, and 
3. Non-duplication, Consultations, and Other Collection Criteria

6

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

ICR identifies 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 necessary.

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 compose more than three quarters 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. This 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 after 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 contained 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

Part 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 matters 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 code 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 NonRecreationalUnspecified 

Vessel Type 

TOTAL b

Less than 79 ft 54,176 32,799 15,011

114,996

137,583

Zero or Null a 13,537 9,696 12,364

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 vessels 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-recreational vessels, and 0.0% of vessels of unspecified 

type).

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-keeping 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 sVGP, 

the only recordkeeping requirement is to sign, date, and certify to completion of quarterly 

inspections on the PARI Form and maintain a copy of that form onboard the vessel. 

Standard Condition - Permittee Report of Anticipated Noncompliance

The requirement to submit a Permittee Report of Anticipated Noncompliance in 40 CFR 

122.41(l)(2) applies to a change in the permitted activities that may result in noncompliance with 

existing permit requirements.

Standard Condition – Twenty-Four Hour Reporting

Requirements in 40 CFR 122.41(l)(6) specify that 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) specify 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 reports 

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. 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 

reports. 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).

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 related 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 inspection 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 

headquarters 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 and 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 completeness 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 the 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). 

Some of the information is available to the public through Web-based interfaces of these 

databases or other EPA Web-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 length (sVGP) 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 demands considering, among other factors, the size and 

complexity of the vessels. Generally, as the size of a vessel 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 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). 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 

which 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 section 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

137,739 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 anticipated noncompliance 

to be 0.01 percent of vessels covered by the general permit for a total of 14 annual respondents. 

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

to read and understand the requirement, 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 notification 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 complete 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 137,739 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 calculate 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 reports. 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 composed 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 2007 labor rate used in the 2008 VGP analysis, which reflects the average across 

industry sectors based on input from industry representatives. Labor rate was escalated from 

2007 to 2014 dollars 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 

Calculations in this 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) Estimating 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.

Standard 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 authority, 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 overhead 

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 

Section 6(a). Results are presented below.

Respondents Activities

Activity

Hours per 

Response

Respondent 

Type

No. Annual 

Responses

Total Annual

Burden (hrs)

Total Annual Cost

Permit Authorization 

and Record of 

Inspection (PARI)

0.25 All small 

vessels

550,956 137,739 $5,032,983

Permittee Report of 

Anticipated 

Noncompliance

5 Small 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 $5,064,298
6. 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 annual number of respondents, burden hours, 

and costs. 

Table 6.1 Respondent Tally

Permittees States/tribes/territories 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 

collectively incurred for all activities during the period covered by this ICR. Table 6.2 provides a 

summary of the average annual Agency burden hours and costs. 

Table 6.2 Agency Tally

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

This 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-keeping 

burden for this collection of information is estimated to average 1 hour per respondent (0.25 

hours per response).
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 federal agency. This includes the time 

needed to review instructions; develop, acquire, install, and utilize technology and systems for 

the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with 

any previously applicable instructions and requirements; train personnel to be able to respond to 

a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose 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 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 available 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 available 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.