Information Collection Request 

For the 

State Water Quality Program Management Resource Analysis 

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

Contents

1 IDENTIFICATION OF THE INFORMATION COLLECTION ................................................ 1

1(a) Title and Number of the 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 Prior 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 INFORMATION 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: AGENCY 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 Universe 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 ...................................................................................................... 18
State Water Quality Program Management Resource Analysis ICR December 20, 2011

APPENDICES

APPENDIX A: Burden and Cost Tables for State Water Quality Program Management 

Resource Analysis 

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

Workload Model 

LIST OF EXHIBITS

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

Exhibit 2 Average Annual Agency Burden and 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 ..................................................18 
State 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 Industry 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 Classification 
State 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 administration and management of state water quality 

programs, and to quantify the resource needs for 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 collection effort conducted by EPA in 1998 and 2000. The 

proposed Resource Analysis represents a more efficient, 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 EPA’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 needs for individual states and to 

develop strategies that promote sustainable and efficient management 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, progress tracking, and information gathering tool for the states to 

use 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 direction from EPA, for a previous 2000 data 

collection effort.

The total number of respondents for this ICR is estimated at twenty; these respondents 

are all state agencies. The total number of responses 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 description of the unit 

burden and costs for this collection. 

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

to states and EPA associated with the Resource Analysis. This ICR estimates burden and costs 

for calendar years 2011, 2012, and 2013. For the three-year ICR period, the average annual 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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national burden and cost, including 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 hours and $49,740. The estimated average annual EPA 

burden for this ICR (including contractor support) is 479 hours, at an estimated annual cost of 

$36,776. No capital costs or operation and maintenance costs are associated with this ICR. 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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2 NEED FOR AND USE OF THE COLLECTION

2(a) Authority and Need for the Collection

EPA requires this information to estimate resource expenditures and needs for the 

management and administration of the water quality programs under 33 U.S.C. Section 1251 et. 

seq. This effort, supported by EPA and the states, is necessary to develop strategies for better 

managing state water quality programs implementing the CWA, thus ensuring the long-term 

sustainability, efficiency, and effectiveness of these 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 expenditures and to develop a workload-based national 

estimate of the resources needed to achieve the objectives of the CWA. The estimates will 

improve the Agency’s and states’ abilities to administer 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 for supporting long-term programmatic 

sustainability. 

• States and EPA may use the model to establish program priorities; track and measure 

program progress, efficiency, and success in advancing EPA’s strategic goals; and 

identify opportunities for work sharing. 

• States and EPA may use the data to develop a framework for prioritization 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 Administrators, and state governments. 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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3 NON­DUPLICATION, CONSULTATIONS AND OTHER

COLLECTION CRITERIA

3(a) Non­duplication

The information will be created by the respondents; it does not duplicate information 

otherwise reasonably accessible to EPA. To the best of the Agency’s knowledge, data requested 

under this ICR are not available 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 public comment period for this additional notice is 

30 days. 

3(c) Consultations

EPA has consulted with state water quality management personnel 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 carefully considered in the development of 

this document. There are no anticipated capital, start-up, or operation and maintenance costs, or 

any change in record keeping practices associated 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 that the final model covers all the activities in 

state water quality management programs; and reviewing, commenting 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 Resources 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 Quality 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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Associations

Environmental Council of States 

Association of State and Interstate Water 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 with the October 2009 version of the ICR 

Handbook prepared by EPA’s Office of Environmental Information, Office of Information 

Collection, Collection Strategies Division. The ICR Handbook provides the most current 

instructions for ICR preparation 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 activities. Specifically, the respondents 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 universe 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 pledge, or which unnecessarily impedes sharing of data with 

other agencies for compatible confidential use. 

• Submit proprietary, trade secret, or other 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

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3(f) Confidentiality

This information collection does not require respondents to disclose confidential 

information. Respondents are not obliged to respond 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

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4 RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS/SIC Codes

The respondents to this information collection include personnel from state water quality 

management programs. The Standard Industrial Classification (SIC) code for the state agencies 

that include the water quality management programs are classified under either 9511 (Air and 

Water Resources and Solid Waste Management) or 9431 (Administration of Public Health 

Programs). State licensing/certification 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 Management Programs) or 923120 (Administration of 

Public Health Programs). State licensing/certification agencies are classified as NAICS 92615 

(Regulation, Licensing, and Inspection of Miscellaneous 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 will 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, enforcement and septage), nonpoint source control, 

total maximum daily load development, wetlands, coastal and marine areas, water quality 

monitoring, water quality standards, reporting and planning, 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 various program areas can be combined into a total 

estimate across all program areas. 

There are no recordkeeping requirements associated 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, grants 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

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• 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 (FTEs/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 listed above, each respondent may complete the 

following activities: 

• Review the workload modules, instructions, and accompanying materials. 

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

providing estimates. 

• Distribute the modules to the appropriate program area staff. 

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

• Develop estimates of current expenditures and resource needs by searching 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 provide estimates in hard copy or through other 

electronic means. 

• Review estimates, make any necessary revisions, 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

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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 extrapolation. 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 information from state agencies. 

• Updating the modules listing activities 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, additional 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. During the initial development of the original 

model, EPA worked with focus groups that consisted of state and EPA representatives. 

Because of the size and complexity of state water quality management programs, EPA 

held four focus group sessions, each addressing particular program areas. 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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The groups determined the activities to include in each module and then 

reviewed, commented on, and tested the accuracy, utility, and usability of each module. 

The focus groups also developed the necessary 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, and will be modified and updated based on 

recommendations and consensus from a collaborative Resource Analysis Workgroup, 

consisting of state, EPA, and state association representatives. 

Data Quality

Data quality will be assured by implementing the following mechanisms 

throughout the collection and processing phases 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 materials 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 information available to the public in 

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

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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 jurisdictions. These terms are defined below.1

• A small business is any business that is independently owned and operated and not 

dominant in its field, as defined by the Small Business Administration (SBA) 

regulations under Section 3 of the Small Business Act. 

• A small organization is any non-profit enterprise that 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 regulatory flexibility analysis of all rules that 

have a significant economic impact on a substantial number of small entities. Since EPA is not 

promulgating a rule, this ICR is not subject to SBREFA. 

Since OWM is only requesting information from state governments, small entities will 

not be significantly impacted. Since no burden will be placed on small entities by this ICR, EPA 

has met the requirements of SBREFA to minimize 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 instructions) 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

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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 Management Resource Analysis. The burden and cost 

estimates for the states are shown in Sections 6(a) and 6(b) and the Agency’s burden and cost 

estimates are shown in Section 6(c). No other entities incur respondent burden under this ICR. 

The per-respondent estimates represent the average burden and cost over the three-year 

period covered by this ICR (2011 through 2013). Detailed 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 information 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 voluntary data collection. 

This estimate includes burden hours associated with 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 burden is associated 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 responsible for non-point source activities, coastal zone activities, etc.), 

explain the request, and distribute the various components of the model to appropriate staff. 

These activities are estimated to take eight hours in the first year, 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 estimated 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 activities 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 submit the final product to EPA. Reviewing and 

revising the estimates may involve coordinating with various program managers to ensure that 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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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 participating 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. Exhibit 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 per hour for all state activities. This rate is 

based on the average hourly wage for state employees (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 found at http://stats.bls.gov, specifically the Employer 

Costs for Employee Compensation, Table 3- Employer 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 their 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

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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, EPA 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 are detailed in Exhibit 2 and Appendix A. 

EPA Headquarters 

 For the three-year ICR period, EPA estimated that the average annual burden to the 

Agency (excluding contractor activities) will be 146 hours. This estimate includes burden 

incurred by EPA staff for the activities 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 Analysis 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. Other 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

15 

tasks, such as entering data into a database, do not require specialized knowledge 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 assumptions and pricing of activities included in the 

draft modules, integrate the modules, make final calibrations 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 are estimated to take 33.3 hours of managerial level 

time in the first year and two hours in each of the subsequent years. 

Based on past experience in developing the national estimate of state water quality 

management program needs, EPA estimates that 10 states will have questions 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 the 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 auditing 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 that additional information 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 years and 120 hours in the final year. 

For the 146 burden hours, EPA will incur annual 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

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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 contractor will support all EPA activities 

described above. 

• The EPA contractor will provide this professional labor at a total hourly rate, including 

all applicable indirect costs, of $83.00. 

Exhibit 3 illustrates the total estimated burden and costs for activities associated with 

developing an estimate of the resource needs for state water quality management programs. 

Exhibit 2 

Average Annual Agency Burden and Costs (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

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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 that voluntarily respond to EPA’s request for 

information. This ICR estimates the number of state respondents at twenty. The total costs and 

burden for these respondents are summarized in Exhibit 1. Agency costs and burden are detailed 

in Section 6(c) and in Exhibit 2. 

6(e) Bottom Line Burden Hours and Costs

Exhibit 43

 illustrates the total estimated annual burden and labor costs for both the states 

and the Agency for activities associated with developing 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 states, 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 (including contractor activities), is estimated to be 

$86,518 annually. This includes annual labor costs 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

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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 include 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 collections included in this ICR is detailed in Exhibit 3 

above. The annual respondent burden is estimated to average 63 hours per respondent per year, 

which is attributed to states. This estimate includes 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 burden is associated with this ICR. 

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, 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 the information. An agency may not conduct 

or sponsor, and a person is not required to respond to, a collection of information unless it 

displays a currently valid OMB control number. The OMB control numbers for EPA's 

regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

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

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

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

Docket ID Number EPA-HQ-OW-2011-0424, which 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 Constitution Avenue, NW, Washington, D.C. 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-
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 version 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 documents in the public docket that are available 

electronically. When in the system, select the appropriate document type then key in the Docket 

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

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APPENDIX A 

Burden and Cost Tables for State Water Quality Program Management Resource Analysis 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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Water Quality Program Management Resource Analysis: Information Co

State Burden and Cost Estimates

Activity 

Number of 

State 

Respondents 

Frequency 

of 

Response 

Labor 

Cost 

per 

Hour 

FY 2011 FY 2012 

Burden per 

Respondent 

(Hours) 

Cost per 

Respondent 

($) 

Total 

Burden 

(Hours) 

Total 

Cost ($) 

Burden per 

Respondent 

(Hours) 

Cost per 

Respondent 

($) 

Total 

Burde

(Hour

Review workload model, coordinate distribution, distribute 

20 1 $39.74 8 $318 160 $6,358 2 $79 40 

Develop estimates of resource needs 

20 1 $39.74 64 $2,543 1280 $50,867 15 $596 300 

Enter estimates of resource needs 

20 1 $39.74 2.5 $99 50 $1,987 1 $40 20 

Review estimates, revise if necessary, and submit workload model to EPA 

20 1 $39.74 15 $596 300 $11,922 30 $1,192 600 

Responding to EPA requests for additional information 

10 1 $39.74 2.5 $99 25 $994 1 $40 10 

TOTAL 92 $3,656 1815 $72,128 49 $1,947 970 Annual Average Over the Three-Year ICR Period For Each State Respondent Annual Average Over the Three-Year ICR Period For All State Respondents 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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Water Quality Program Management Resource Analysis: Information Collection Reque

Agency Burden and Cost Estimates

Activity Labor Cost per Hour 

FY 2011 FY 2012 FY 2013 Tot

Burd

(Hou

Burden (Hours) Cost ($) Burden (Hours) Cost ($) Burden (Hours) Cost ($) 

Develop and distribute the workload model $62.48 33.3 $2,081 2 $125 2 $125 37.Respond to questions concerning the model $62.48 1.7 $106 1.7 $106 1.7 $106 5.1 Review and audit submitted information $62.48 6.7 $419 6.7 $419 1.7 $106 15.Compile and store submitted data $62.48 3.3 $206 3.3 $206 3.3 $206 9.9 Review and audit information, if requested $62.48 0.8 $50 32.1 $2,006 17.1 $1,068 50 Analyze and extrapolate the data and prepare report 

$62.48 100 $6,248 100 $6,248 120 $7,498 320 

TOTAL 146 $9,110 146 $9,110 146 $9,110 437 Annual Average Over the Three-Year ICR Period 146 
State Water Quality Program Management Resource Analysis ICR December 20, 2011

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APPENDIX B 

State Water Quality Program Management Resource Analysis Activity‐Based Workload 

Model 

NOTE:  The appended State Water Quality Program Management Resource Analysis Model 

was developed in 2000 by a State Task Force as a tool to be used by states as a systematic 

way to quantify resources needed for the administration and management 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 the current information 

collection proposal, the model will be updated to provide a more efficient, streamlined data 

collection effort to capture programmatic and regulatory changes since 2000, based on 

recommendations and consensus from a collaborative Resource Analysis Workgroup, 

consisting of state, EPA, and state association representatives.