## Information Collection Request

For the

State Water Quality Program Ma nagement Resource Analysis

December 20, 2011State Water Quality Program Management Resource Analysis ICR December 20, 2011



### Contents

1 IDENTIFICATION OF THE IN FORMATION COLLECTION ................................................ 1 1(a) Title and Number of th e Information Collection ......................................................... 1 1(b) Short Characterization ................................................................................................. 1

2 NEED FOR AND USE OF THE COLLECTION ....................................................................... 3 2(a) Authority and Need for the Collection ........................................................................ 3 2(b) Practical Utility/Users of the Data .............................................................................. 3
3 NON-DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA ........ 4 3(a) Non-duplication .......................................................................................................... . 4 3(b) Public Notice Required Prio r to ICR Submission to OMB ......................................... 4 3(c) Consultations ............................................................................................................ ... 4 3(d) Effects of Less Frequent Collection ............................................................................ 5 3(e) General Guidelines ...................................................................................................... 5 3(f) Confidentiality .......................................................................................................... ... 6 3(g) Sensitive Questions ..................................................................................................... 6

4 RESPONDENTS AND THE IN FORMATION REQUESTED .................................................. 7 4(a) Respondents and NAICS/SIC Codes........................................................................... 7 4(b) Information Requested ................................................................................................ 7 4(b)(i) Data Items ............................................................................................................ ........ 7 4(b)(ii) Respondent Activities................................................................................................. 8

5 INFORMATION COLLECTED: AGE NCY ACTIVITIES, COLLECTION

METHODOLOGY AND INFORMATION MANAGEMENT ......................................... 9 5(a) Agency Activities ........................................................................................................ 9 5(b) Collection Methodology and Management ................................................................. 9 5(c) Small Entity Flexibility ............................................................................................. 11 5(d) Collection Schedule ................................................................................................... 11

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION ................................... 12 6(a) Respondent Burden ................................................................................................... 12 6(b) Respondent Costs ...................................................................................................... 13 6(c) Agency Burden and Costs ......................................................................................... 14 6(d) Estimating the Respondent Univer se and Total Burden and Costs ........................... 17 6(e) Bottom Line Burden Hours and Costs....................................................................... 17 6(f) Reasons For Change In Burden ................................................................................. 18 6(g) Burden Statement ...................................................................................................... 18State Water Quality Program Management Resource Analysis ICR December 20, 2011



### APPENDICES

APPENDIX A: Burden and Cost Tables fo r State Water Quality Program Management Resource Analysis

APPENDIX B: State Water Quality Program Ma nagement Resource Analysis Activity-Based

Workload Model



### LIST OF EXHIBITS

Exhibit 1 Average Annual State Burden and Costs ...............................................................14

Exhibit 2 Average Annual Agency Burden a nd Costs (Excluding Contractor Activities) ....16

Exhibit 3 Average Annual Burden and Costs of Contractor Activities .................................17

Exhibit 4 Bottom Line Average Annual Burden and Costs ..................................................18State Water Quality Program Management Resource Analysis ICR December 20, 2011



### ACRONYMS

BLS Bureau of Labor Statistics CFR Code of Federal Regulations

CWA Clean Water Act EPA Environmental Protection Agency

FOIA Freedom of Information Act FTE Full Time Equivalent ICR Information Collection Request

NAICS North American I ndustry Classification System OWM Office Wastewater Management OMB Office of Management and Budget PRA Paperwork Reduction Act

SBA Small Business Administration SBREFA Small Business Regulatory Enforcement Fairness Act

SIC Standard Industrial ClassificationState Water Quality Program Management Resource Analysis ICR December 20, 2011

1 

## 1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title: Information Collection Request for the State Water Quality Program Management Resource Analysis

OMB Control Number: 2040-NEW

EPA Tracking Number: 2433.01



### 1(b) Short Characterization

The Environmental Protection Agency (EPA), in partnership with states, is conducting the State Water Quality Management Resource Analysis to enumerate current and future expenditures and resources for the administra tion and management of state water quality programs, and to quantify the resource needs fo r the administration and management of state water quality programs to implement the Clean Water Act (CWA). This effort builds on a

resource and resource needs data collecti on effort conducted by EPA in 1998 and 2000. The proposed Resource Analysis represents a more e fficient, streamlined data collection effort designed to capture programmatic and regulatory changes that have significantly impacted

resources and resource needs since 2000.

This is a one-time collection effort by EP A’s Office Wastewater Management (OWM), and responses to this information collection request (ICR) are voluntary. The collection is necessary to develop an estimate of expenditures and resource need s for individual states and to develop strategies that promot e sustainable and efficient mana gement and administration of water quality programs under 33 U.S.C. Section 1251 et . seq. The data collection model will also serve as a long-term budgeting, progre ss tracking, and information gathering tool for the states touse in the future. Data will be collected, managed, and stored by EPA using commercial, off-theshelf software, such as Microsoft Excel. The data collection model will be an updated version of the model developed by a contractor, under dir ection from EPA, for a previous 2000 data

collection effort.

The total number of respondents for this I CR is estimated at twenty; these respondents are all state agencies. The total number of res ponses for each respondent is one, which averages to 0.33 responses per respondent annually. This effort will require an average annual $2,517 and 63 hours per respondent for each respondent that chooses to submit information. Section 6, Estimating the Burden and Cost of the Collection , provides a detailed de scription of the unit

burden and costs for this collection.

As explained in Section 2(a), this ICR estim ates information collection burden and costs

to states and EPA associated with the Resour ce Analysis. This ICR es timates burden and costs for calendar years 2011, 2012, and 2013. For the th ree-year ICR period, the average annualState Water Quality Program Management Resource Analysis ICR December 20, 2011

2 national burden and cost, includ ing all participating states and EPA (including contractor support), is estimated at 1,731 hours and $86,518. The total average annual burden and cost to participating states is estimated at 1,252 hour s and $49,740. The estimated average annual EPA burden for this ICR (including co ntractor support) is 479 hours, at an estimated annual cost of $36,776. No capital costs or operation and maintenan ce costs are associated with this ICR.State Water Quality Program Management Resource Analysis ICR December 20, 2011

3 

## 2 NEED FOR AND USE OF THE COLLECTION

2(a) Authority and Need for the Collection

EPA requires this information to estimat e resource expenditure s and needs for the management and administration of the water qua lity programs under 33 U.S.C. Section 1251 et. seq. This effort, supported by EPA and the states, is necessary to devel op strategies for better managing state water quality programs implemen ting the CWA, thus en suring the long-term sustainability, efficiency, and effectiveness of thes e programs. This effort also helps states and EPA to effectively target resources to meet EPA’s FY 2011-2015 strategic goals of protecting America’s waters and enforcing environmental laws.



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

The information will be collected by EPA and made available to the states and to the public in accordance with the requirements of the Freedom of Information Act (FOIA). EPA will use the collected data to estimate current expendi tures and to develop a workload-based national

estimate of the resources needed to achieve th e objectives of the CWA. The estimates will improve the Agency’s and states’ abilities to ad minister and manage effective and sustainable water quality management programs.

The information that will be collected from each respondent will have several secondary uses, both inside and outside of EPA. For example:

• States may use the workload-based model for workload planning and budgeting for new and existing programs, and fo r supporting long-term programmatic sustainability.

• States and EPA may use the model to estab lish program priorities; track and measure program progress, efficiency, and success in advancing EPA’s st rategic goals; and identify opportunities for work sharing.

• States and EPA may use the data to devel op a framework for prio ritization by linking staffing and resource needs to watersheds, which will enable states to estimate specific environmental or economic benefits that might be achieved by meeting these staffing and resource needs.

Primary users of the information collected under this ICR include the EPA Office of Water, EPA Regional Administrato rs, and state governments.State Water Quality Program Management Resource Analysis ICR December 20, 2011

4 

## 3 NON

­ DUPLICATION, CONSULTATIONS AND OTHER

COLLECTION CRITERIA

3(a) Non

­ duplication

The information will be created by the re spondents; it does not duplicate information otherwise reasonably accessible to EPA. To the be st of the Agency’s knowledge, data requested

under this ICR are not availa ble from any other source.



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

On July 27, 2011 (76 FR 44904), EPA sought comments on this ICR pursuant to 5 CFR 1320.8(d). EPA received no comments. An additional Federal Register notice will be published prior to submission of this ICR to OMB. The pub lic comment period for this additional notice is 30 days.



### 3(c) Consultations

EPA has consulted with state water quality management pe rsonnel on the burden and cost estimates provided in this ICR including:

Kansas Department of Health and Environment North Carolina Department of Environment and Natural Resources

Their comments and suggestions have been ca refully considered in the development of this document. There are no anticipated capital, st art-up, or operation and maintenance costs, or any change in record keeping practices associat ed with the activities detailed in this ICR.

The following is a list of regions, states and other interested stakeholders that EPA is consulting to update the workload model that will be used in this collection. These stakeholders are assisting EPA with determining the activities for each of the program areas; the development of the necessary linkages between the modules so th at the final model covers all the activities in state water quality management programs; and reviewing, commenti ng on, and testing the accuracy, utility, and usability of the model. All states will have the opportunity to review and

comment on the model before it is used in this data collection.

States Delaware Department of Natural Re sources and Environmental Control Kansas Department of Health and Environment Nebraska Department of Environmental Quality Oklahoma Department of Environmental Quality South Carolina Department of Health and Environmental Control Utah Department of Environmental QualityState Water Quality Program Management Resource Analysis ICR December 20, 2011

5 Associations

Environmental Counc il of States

Association of State and Interstate Wa ter Pollution Control Administrators

EPA Regions Region 6



### 3(d) Effects of Less Frequent Collection

This is a voluntary, one-time collection of information from the respondents with no record keeping requirements.



### 3(e) General Guidelines

This ICR was developed in accordance w ith the October 2009 version of the ICR Handbook prepared by EPA’s Office of Environm ental Information, Office of Information Collection, Collection Strategies Division. The ICR Handbook provides the most current instructions for ICR preparat ion to ensure compliance with the 1995 PRA amendments and OMB’s implementing guidelines. This collection does not violate any of the OMB guidelines for

information collection activi ties. Specifically, the res pondents are not required to:

• Report information to EPA more than quarterly.

• Prepare a written response to a collection of information in fewer than 30 days after receipt of a request.

• Submit more than an original and two copies of any document.

• Retain records, other than health, medical , government contract, grant-in-aid or tax records, for more than three years.

• Participate in a statistical survey that is not designed to produce data that can be generalized to the un iverse of the study.

• Use a statistical data classification that has not been reviewed and approved by OMB.

• Receive a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the ple dge, or which unnecessarily impe des sharing of data with other agencies for compatible confidential use.

• Submit proprietary, trade secret, or othe r confidential information unless EPA can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.State Water Quality Program Management Resource Analysis ICR December 20, 2011

6 

### 3(f) Confidentiality

This information collection does not requi re respondents to disclose confidential information. Respondents are not obliged to resp ond to this strictly voluntary information

collection.



### 3(g) Sensitive Questions

No questions of a sensitive nature (e.g., questions pertaining to sexuality, religious beliefs, or other private matters) are included in any of the information collection requirements

outlined in this ICR.State Water Quality Program Management Resource Analysis ICR December 20, 2011

7 

## 4 RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS/SIC Codes

The respondents to this information collecti on include personnel from state water quality management programs. The Standard Industrial Cl assification (SIC) code for the state agencies that include the water quality management pr ograms are classified under either 9511 (Air and Water Resources and Solid Waste Management) or 9431 (Administration of Public Health Programs). State licensing/certific ation agencies are classified under 9651. The North American Industry Classification System (NAICS) code for state agencies is 924110 (Administration of Air and Water Resources and Solid Waste Manageme nt Programs) or 923120 (Administration of Public Health Programs). State licensing/certification agencies are classified as NAICS 92615 (Regulation, Licensing, and Inspection of Miscellane ous Commercial Sectors).



### 4(b) Information Requested

EPA will be asking states to provide estimates of current spending and resource needs for water quality management program activities. EPA w ill provide the states with integrated, userfriendly modules (the Resource Analysis model) designed to capture expenditures and needs to perform all activities associated with the development, planning, coordination, management, and implementation of state water quality management programs. Program areas covered include: point source control (permitting, compliance, enfo rcement and septage), nonpoint source control, total maximum daily load development, wetlan ds, coastal and marine areas, water quality monitoring, water quality sta ndards, reporting and planni ng, and data management.

Each module will contain lists of activities in each of the program areas. The modules will be integrated so that estimates for variou s program areas can be combined into a total estimate across all program areas.

There are no recordkeeping requirements asso ciated with this information collection.



### 4(b)(i) Data Items

For each activity listed in the sub-modules, each state will be asked to provide an estimate of the following:

• The unit of analysis (e.g., annual, one-time, gr ants issued, permits issued, sample events, special studies, FTEs, square miles, etc.).

• Units per year.

• Current effort and costs (FTE hours/unit).

• Required effort (FTE hours/unit).State Water Quality Program Management Resource Analysis ICR December 20, 2011

8 • Other current costs (dollars/unit).

• Other necessary costs (dollars/unit).

Based on the information provided by each state, the Resource Analysis model will automatically calculate the total annual effort expended and required (F TEs/year), total other costs expended and required (dollars/year), and the total annual costs expended and required for each line item (dollars/year).



### 4(b)(ii) Respondent Activities

In order to provide the data items liste d above, each respondent may complete the following activities:

• Review the workload modules, instru ctions, and accompanying materials.

• Coordinate with program area managers to determine the appropriate personnel for providing estimates.

• Distribute the modules to the a ppropriate program area staff.

• Contact EPA to obtain assistance in responding to this data request.

• Develop estimates of current expenditures a nd resource needs by sear ching data sources (e.g., water quality program management budgets ) and consulting personnel familiar with

the activities listed in each sub-module.

• Enter the estimates into the model or provi de estimates in hard copy or through other

electronic means.

• Review estimates, make any necessary re visions, and submit the modules to EPA.

• Respond to questions from EPA about the estimates and provide additional information, if necessary.State Water Quality Program Management Resource Analysis ICR December 20, 2011

9 

## 5 INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION

METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities

Many of the EPA activities described below will be conducted by contractors with EPA oversight/technical direction. For example, EPA will oversee contractor update of the data collection modules and data analysis and extr apolation. For purposes of describing Agency activities, contractor effort is not distinguished from EPA effort. Separate information on

estimates for contractor burden and cost is provided in Section 6(c).

The following EPA activities are associated with this information collection for the State Water Quality Program Resource Analysis:

• Creating a letter requesting info rmation from state agencies.

• Updating the modules listing activ ities to send to the states.

• Responding to questions from states about the information collection.

• Reviewing information submitted by states.

• Auditing information to assess quality.

• Compiling and storing the data.

• Requesting, if necessary, additi onal information from states.

• Analyzing and extrapolating the data.



### 5(b) Collection Methodology and Management

This section describes the steps EPA is taking to ensure that the collected information is accurate, reliable, and retrievable. The steps have been developed based on comments and advice from EPA staff, state staff, and other interested stakeholders.

Updating the Resource Analysis Model

The updated Resource Analysis model will be based largely on the model developed for a 2000 data collection effort. Duri ng the initial development of the original model, EPA worked with focus groups that c onsisted of state and EPA representatives. Because of the size and complexity of stat e water quality management programs, EPA held four focus group sessions, each a ddressing particular program areas.State Water Quality Program Management Resource Analysis ICR December 20, 2011

10 The groups determined the activities to include in each module and then reviewed, commented on, and tested the accur acy, utility, and usability of each module. The focus groups also developed the necessa ry linkages between modules so that the final model incorporated all applicable state water quality management activities.

The outcome of this process was the development of a model that includes

consensus-based definitions of activities in each program area. The revised model will use the existing model as its foundation, a nd will be modified and updated based on

recommendations and consensus from a collaborative Resource Analysis Workgroup, consisting of state, EPA, and stat e association representatives.

Data Quality

Data quality will be assured by implementing the following mechanisms throughout the collection and processing pha ses of the information collection:

Detailed Instructions. EPA will develop detailed instructions and supplemental materials explaining the information requested from the states. The materials include explanations of the assumptions for model development and a frequently asked questions document that further explains how each module works, the scope of each module, how the module relates to the other modules, and the general assumptions underlying each module. The detailed instructions and supplemental materials will be updated to address the expenditures portion of the model.

EPA and state personnel will be available to answer any questions that arise once the model and supplemental materi als are sent to the states.

Data Entry. All information will be reviewed for completeness and internal consistency.

States will be contacted for additional or clarifying information, if necessary.

Data Systems. EPA will use commercial, off-the-shelf software, such as Microsoft Excel, to manage the information.

Public Access to Data

The Agency will make the collected in formation available to the public in

accordance with the FOIA and EP A policies and procedures.State Water Quality Program Management Resource Analysis ICR December 20, 2011

11 

### 5(c) Small Entity Flexibility

In developing this ICR for the requirements of the Act, EPA considered the requirement of the Small Business Regulatory Enforcement Fairness Act (SBREFA) to minimize the burden

of information collections on small entities. Small entities include small businesses, small organizations, and small government jurisd ictions. These terms are defined below. 1

• A small business is any business that is indepe ndently owned and operated and not dominant in its field, as defined by the Small Busi ness Administration (SBA) regulations under Section 3 of the Small Business Act.

• A small organization is any non-profit enterprise th at is independently owned and operated and not dominant in its field.

• A small governmental jurisdiction is the government of a city, county, town, township, village, school district or special district that has a population of fewer than 50,000. This definition may also include Indian tribes.

The major requirement under SBREFA is a regulato ry flexibility analysis of all rules that have a significant economic impact on a substan tial number of small entities. Since EPA is not promulgating a rule, this ICR is not subject to SBREFA.

Since OWM is only requesting information fr om state governments, small entities will not be significantly impacted. Since no burden w ill be placed on small entities by this ICR, EPA has met the requirements of SBREFA to minimi ze the burden of the information collection on

small entities.



### 5(d) Collection Schedule

Upon receipt of approval for this collection from OMB, EPA will finalize the Resource Analysis model. The model will be reviewed by the Resource Analysis Workgroup to ensure that the functionality minimizes the burden on states . Once the model is complete, EPA will send the request for information (model and detailed inst ructions) to state water quality management personnel. EPA will request that the states submit their values within 45 days of receiving the information request.

1 These definitions are taken from section 601 of the Regulatory Flexibility Act.State Water Quality Program Management Resource Analysis ICR December 20, 2011

12 

## 6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION

This section describes the annual burden and cost for the information collection activities of the State Water Quality Program Manageme nt Resource Analysis. The burden and cost

estimates for the states are shown in Sections 6(a) and 6(b) and the Ag ency’s burden and cost estimates are shown in Section 6(c). No other entities incur respondent burden under this ICR.

The per-respondent estimates re present the average burden a nd cost over the three-year period covered by this ICR (2011 through 2013). Detail ed burden and cost estimates for states and EPA are provided in Exhibits 1, 2, 3, and 4 as well as in Appendix A.



### 6(a) Respondent Burden

State agencies are the only respondents to this informa tion collection request. The average annual respondent burden for states is summarized in Exhibit 1. EPA estimates a total average annual respondent burden of 63 hours for complying with this vol untary data collection.

This estimate includes burden hours associat ed with reviewing th e information request; coordinating personnel; researching data sour ces; examining the Resource Analysis model; entering estimates into the model; reviewing and submitting the final product; and responding to EPA’s questions. No recordkeeping burden is asso ciated with this ICR. The derivation of each

estimate is described below.

Upon receiving the modules and additional materials from EPA, a state water quality senior manager will review the information and decide whether to respond. EPA will distribute the model to 50 states. EPA’s estimates assume that 20 states will provide estimates of current expenditures and resource needs.

The senior manager receiving the materials will need to coordinate with program managers (i.e., personnel responsib le for non-point source activities, coastal zone activities, etc.), explain the request, and distribut e the various component s of the model to appropriate staff.

These activities are estimated to take eight hours in the first y ear, and two hours in each of the subsequent years.

The various program managers will develop estimates of resource needs by examining the activities, researching data sources, such as past budgets and performance summaries, and meeting with staff. These activities are estimate d to take 64 hours in the first year, and 15 hours in each of the subsequent years.

Each program manager will then enter the current estimates or resource needs into the model. The estimated time to complete these acti vities is 2.5 hours in the first year, and one hour in each of the subsequent years.

Once the model is complete, EPA assumes that each state will review the estimates, revise the information, if necessary, and subm it the final product to EPA. Reviewing and revising the estimates may involve coordinating with various progr am managers to ensure thatState Water Quality Program Management Resource Analysis ICR December 20, 2011

13 the estimates are accurate. These activities are estimated to take 15 hours in the first year and 30 hours in each of the subsequent years.

Once the model has been submitted by the par ticipating states, EPA estimates that ten states will need to be contacted for additional information concerning their submissions. Responding to EPA’s request for additional information is estimated to take 2.5 hours in the first year and one hour in each of the subsequent years.



### 6(b) Respondent Costs

State agencies are the only respondents to this information collection request. No capital or operation and maintenance costs are associated with this ICR. Exhi bit 1 shows the average

annual costs for states over the three-year ICR period.

State labor costs are estimated by applying an hourly labor rate to the burden hour estimates (as explained in 6(a) above). For purposes of calculating state labor costs, EPA assumed a single average hourly wage rate of $39.74 pe r hour for all state activ ities. This rate is based on the average hourly wage for state employ ees (all workers), as determined by the U.S. Department of Labor, and includes benefits. It is derived from the U.S. Department of Labor,

Bureau of Labor Statistics information f ound at http://stats.bls .gov, specifically the Employer Costs for Employee Compensation, Table 3- Em ployer costs per hour worked for employee compensation and costs as a percent of total compensation: State and local government, by major occupational and industry group, June 2010 . EPA assumed that program managers will provide the requested information due to th eir comprehensive knowledge of water quality management programs and their detailed understanding of each program area.State Water Quality Program Management Resource Analysis ICR December 20, 2011

14 Exhibit 1 Average Annual State Burden and Costs

Activity Number of

State Respondents Labor Cost per

Hour FY 2011 FY 2012 FY 2013 Total – All States,

All Years

Burden per State (Hours) 1 Labor Cost per

State Burden per State (Hours) 1 Labor Cost per

State Burden per State (Hours) 1 Labor Cost per

State Hours Cost

Review workload model, coordinate distribution, and

distribute 20 $39.74 8 $317.92 2 $79.48 2 $79.48 240 $9,538

Develop estimates

of resource needs 20 $39.74 64 $2,543.36 15 $596.10 15 $596.10 1880 $74,711

Enter estimates of

resource needs 20 $39.74 2.5 $99.35 1 $39.74 1 $39.74 90 $3,577

Review estimates,

revise if necessary, and

submit workload

model to EPA 20 $39.74 15 $596.10 30 $1,192.20 30 $1,192.20 1500 $59,610

Respond to EPA requests for

additional

information 10 $39.74 2.5 $99.35 1 $39.74 1 $39.74 45 $1,788

TOTAL 92 $3,656 49 $1,947 49 $1,947 3755 $149,224

Annual Average Over the Three-Year ICR Period For Each State Respondent 63 $2,517

Annual Average Over the Three-Year ICR Period For All State Respondents 1252 $49,740

Note: Detail may not add exactly to total due to independent rounding.



### 6(c) Agency Burden and Costs

To collect the data requested by this ICR, EP A will incur burden and costs. EPA will also

incur the costs of contractor activities. Cost and burden estimates for EPA and contractor

activities associated with these activities ar e detailed in Exhibit 2 and Appendix A.

EPA Headquarters

For the three-year ICR period, EPA estimated that the average a nnual burden to the Agency (excluding contractor act ivities) will be 146 hours. This estimate includes burden incurred by EPA staff for the ac tivities outlined in Section 5(a) above. The derivation of these

burden hours follows.

Due to the complexity of water quality management programs, certain activities associated with the development of the Resource An alysis will fall to managerial level personnel. These activities require a comprehensive knowledge of program activities, how these activities relate, and the resources necessary to manage and implement state water quality programs. OtherState Water Quality Program Management Resource Analysis ICR December 20, 2011

15 tasks, such as entering data into a database, do not require specialized kno wledge and, therefore, will be completed by technical level staff.

EPA will develop an updated Resource Analysis model, based on that developed for the

2000 data collection effort. EPA will revise the model to reflect recent regulatory and policy requirements that may have impacted the assumpti ons and pricing of activities included in the draft modules, integrate the modules, make final ca librations to the model, and test the calibrated model for accuracy and reliability. EPA will expand the model to collect current state expenditures. EPA will also prepare a User’s Guide and other documentation to provide to the

states with the final model. These activities ar e estimated to take 33.3 hour s of managerial level time in the first year and two hours in each of the subsequent years.

Based on past experience in developing th e national estimate of state water quality management program needs, EPA estimates that 10 states will have quest ions about the modules and the Resource Analysis project. EPA estimates that it will take 10 minutes of an Agency program manager’s time, per state, to respond to questions and provide additional information.

EPA assumes that 20 states will respond to th e request for information. An EPA technical

level FTE will review and audit the submitted information, compile the responses, and store the submitted data in a database. Reviewing and aud iting the information is estimated to take 20 minutes per response and compiling and storing the submitted data is estimated to take an additional 10 minutes per response.

After reviewing the responses, EPA assumes th at additional informa tion or clarification will be necessary from 10 of the states that have submitted information. These activities are

estimated to take a technical level FTE five minutes per state to complete.

To complete the Resource Analysis, EPA will analyze the state data and an extrapolation

to a national estimate. EPA will coordinate with water quality management program personnel to ensure accuracy of the analysis . These activities are estimated to take 100 hours of managerial level time in each of the first two ye ars and 120 hours in the final year.

For the 146 burden hours, EPA will incur annua l labor costs of $9,110 to complete this data collection. The following assumptions were used to develop a cost estimate for EPA

activities associated with the data collection:

• The average salary and benefits for EPA staff is at the GS 13, Step 5 level of $129,968. 2

• There are 2,080 hours per person-year.

• The average hourly rate is $62.48.

2 According to the Office of Personnel Management 2010 GS Pay Schedule, the GS-13 Step 5 salary is $81,230. By adding the standard government benefits factor of 1.6, the average salary plus benefits is $129,968.State Water Quality Program Management Resource Analysis ICR December 20, 2011

16 EPA Contractor(s)

• Over the 3-year period, the EPA contractor will spend a total of 1,000 hours of direct labor; an average annual 333 hours. The c ontractor will suppor t all EPA activities

described above.

• The EPA contractor will provide this professional labor at a total hou rly rate, including all applicable indi rect costs, of $83.00.

Exhibit 3 illustrates the total estimated burde n and costs for activities associated with developing an estimate of the resource needs fo r state water quality management programs.

Exhibit 2 Average Annual Agency Burden and Cost s (Excluding Contractor Activities)

Activity Labor Cost per

Hour FY 2011 FY 2012 FY 2013 Total –

All Years

Hours Cost Hours Cost Hours Cost Hours Cost

Develop and distribute

the workload model $62.48 33.3 $2,081 2 $125 2 $125 37.3 $2,331

Respond to questions concerning the model $62.48 1.7 $106 1.7 $106 1.7 $106 5.1 $319

Review and audit

submitted information $62.48 6.7 $419 6.7 $419 1.7 $106 15.1 $943

Compile and store

submitted data $62.48 3.3 $206 3.3 $206 3.3 $206 9.9 $619

Review and audit additional information, if requested $62.48 0.8 $50 32.1 $2,006 17.1 $1,068 50 $3,124

Analyze and extrapolate the data and prepare report $62.48 100 $6,248 100 $6,248 120 $7,498 320 $19,994

TOTAL 146 $9,110 146 $9,110 146 $9,110 437 $27,329

Annual Average Over the Three-Year ICR Period 146 $9,110

Note: Detail may not add exactly to total due to independent rounding.State Water Quality Program Management Resource Analysis ICR December 20, 2011

17 Exhibit 3 Average Annual Burden and Costs of Contractor Activities

Activity Labor Cost per

Hour FY 2011 FY 2012 FY 2013 Total --

All Years

Hours Cost Hours Cost Hours Cost Hours Cost

Develop the

workload model $83.00 180 $14,940 10.8 $896 2.7 $224 193.5 $16,061

Review and audit

submitted

information $83.00 24 $1,992 24 $1,992 3.3 $274 51.3 $4,258

Compile and store

submitted data $83.00 24 $1,992 24 $1,992 5 $415 53 $4,399

Review and audit

additional information, if requested $83.00 32 $2,656 201.2 $16,700 25 $2,075 258.2 $21,431

Analyze and extrapolate the data and prepare

report $83.00 140 $11,620 140 $11,620 164 $13,612 444 $36,852

TOTAL 400 $33,200 400 $33,200 200 $16,600 1,000 $83,000

Annual Average Over the Three-Year ICR Period 333 $27,667

Note: Detail may not add exactly to total due to independent rounding.



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

The only respondents for this ICR are states th at voluntarily respond to EPA’s request for

information. This ICR estimates the number of st ate respondents at twen ty. The total costs and burden for these respondents are summarized in E xhibit 1. Agency costs and burden are detailed in Section 6(c) and in Exhibit 2.



### 6(e) Bottom Line Burden Hours and Costs

Exhibit 4 3 illustrates the total estimated annual bur den and labor costs for both the states and the Agency for activities associated with de veloping an estimate of the resource needs for state water quality management programs. EPA will request information from 50 states. Based on the expected responses from twenty stat es, the total average annual respondent burden

associated with this ICR is estimated to be 1,252 burden hours. The corresponding total average annual respondent costs are estimated to be $49,740. The total national burden, including respondent burden and EPA burden, is estimated to be 1,731 hours annually. The total average annual national cost, for respondents and EPA (includi ng contractor activities), is estimated to be $86,518 annually. This includes annual labor cost s only, since no operation and maintenance or capital costs are associated with this ICR.

3 See Appendix A for detailed derivations of these burden and cost estimates.State Water Quality Program Management Resource Analysis ICR December 20, 2011

18 Exhibit 4 Bottom Line Average Annual Burden and Costs

Respondent Total

Annual Respondents Average

Annual

Hours Average

Annual Cost

State 20 1,252 $49,740

Agency 1 479 $36,776

Total 21 1,731 $86,518

Note: Detail may not add exactly to total due to independent rounding. Agency estimates in clude total contractor costs.



### 6(f) Reasons For Change In Burden

This ICR does not renew or modify an existing ICR.



### 6(g) Burden Statement

The public reporting burden for co llections included in this ICR is detailed in Exhibit 3 above. The annual respondent burden is estimate d to average 63 hours per respondent per year,

which is attributed to states. This estimate in cludes time for reviewing the information request, coordinating personnel, researching data sources , examining the Resource Analysis model, entering estimates into the model, reviewing and submitting the final product, and responding to EPA’s questions. No recordkeeping burde n is associated with this ICR.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or di sclose or provide information to or for a Federal agency. This

includes the time needed to revi ew instructions; develop, acquire , install, and utilize technology and systems for the purposes of collecting, valid ating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing ways to comply with any previously applicable instructio ns and requirements; train personnel to be able to respond to a collection of info rmation; search data sources; co mplete and review the collection of information; and transmit or otherwise disc lose the information. An agency may not conduct or sponsor, and a person is not required to re spond 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 CF R part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OW-2011-0424, whic h is available for online viewing at www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitu tion Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is ope n 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-State Water Quality Program Management Resource Analysis ICR December 20, 2011

19 1744, and the telephone number for the Information Collection Request for the Water Docket is (202) 566-2426. An electronic vers ion of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documen ts in the public docket that are available electronically. When in the system, select the ap propriate document type then key in the Docket

ID Number identified above.State Water Quality Program Management Resource Analysis ICR December 20, 2011

20 APPENDIX A

Burden and Cost Tables for State Water Quality Program Manageme nt Resource AnalysisState Water Quality Program Management Resource Analysis ICRDecember 20, 201121Water Quality Program Management ResourceAnalysis: Information Collection RequestState Burden and Cost EstimatesActivityNumber ofStateRespondentsFrequencyofResponseLaborCostperHourFY 2011 FY 2012 FY 2013Total –All States, All YearsBurden perRespondent(Hours)Cost perRespondent($)TotalBurden(Hours)TotalCost ($)Burden perRespondent(Hours)Cost perRespondent($)TotalBurden(Hours)TotalCost ($)Burden perRespondent(Hours)Cost perRespondent($)TotalBurden(Hours)TotalCost ($)TotalBurden(Hours)TotalCost ($)Reviewworkloadmodel,coordinatedistribution,distribute20 1 $39.74 8 $318160 $6,3582 $7940 $1,5902 $7940 $1,590 240 $9,538Developestimates ofresource needs20 1 $39.74 64 $2,5431280 $50,86715 $596300 $11,92215 $596300 $11,922 1880 $74,711Enter estimatesof resourceneeds20 1 $39.74 2.5 $9950 $1,9871 $4020 $7951 $4020 $795 90 $3,577Reviewestimates,revise ifnecessary, andsubmitworkloadmodel to EPA20 1 $39.74 15 $596300 $11,92230 $1,192600 $23,84430 $1,192600 $23,844 1500 $59,610Responding toEPA requestsfor additionalinformation10 1 $39.74 2.5 $9925 $9941 $4010 $3971 $4010 $397 45 $1,788TOTAL 92 $3,656 1815 $72,128 49 $1,947 970$38,548 49 $1,947 970 $38,548 3755 $149,224Annual Average Over the Three-Year ICR Period For Each State Respondent63 $2,517Annual Average Over the Three-Year ICR Period For All State Respondents1252 $49,740State Water Quality Program Management Resource Analysis ICRDecember 20, 201122Water Quality Program Management ResourceAnalysis: Information Collection RequestAgency Burden and Cost EstimatesActivityLabor Costper HourFY 2011 FY 2012 FY 2013TotalBurden(Hours)TotalCost ($)Burden(Hours)Cost ($)Burden(Hours)Cost ($)Burden(Hours)Cost ($)Develop and distributethe workload model$62.48 33.3 $2,081 2 $125 2 $12537.3 $2,331Respond to questionsconcerning the model$62.48 1.7 $106 1.7 $106 1.7 $1065.1 $319Review and auditsubmitted information$62.48 6.7 $419 6.7 $419 1.7 $10615.1 $943Compile and storesubmitted data$62.48 3.3 $206 3.3 $206 3.3 $2069.9 $619Review and auditinformation, if requested$62.48 0.8 $50 32.1 $2,006 17.1 $1,06850 $3,124Analyze and extrapolatethe data and preparereport$62.48 100 $6,248 100 $6,248 120 $7,498320 $19,994TOTAL 146 $9,110 146 $9,110 146 $9,110 437 $27,329Annual Average Over the Three-Year ICR Period146 $9,110State Water Quality Program Management Resource Analysis ICR December 20, 2011

23 APPENDIX B

State Water Quality Program Management Resource Analysis Activi ty‐Based Workload

Model

NOTE:  The appended State Water Q uality Program Management Reso urce Analysis Model was developed in 2000 by a State Task Force as a tool to be use d by states as a systematic way to quantify resources needed for the administration and man agement of state water quality programs. The model was independently reviewed in 2002 by the National Academy of Public Administration which found that the model was a useful tool for producing a reasonable estimate of state resource needs. For th e current information collection proposal, the model will be updated to provide a mor e efficient, streamlined data collection effort to capture prog rammatic and regulatory change s since 2000, based on

recommendations and consensus from a collaborative Resource Ana lysis Workgroup, consisting of state, EPA, and sta te association representatives

.