1 

### Information Collection Request for the Clean Water Act State Revolving Fund Program Section 606 of the C lean Water Act

EPA ICR Number 13 91. 10 OMB Control Number 2040

- 0118

U. S. Environmental Protection Agency Office of Wastewater Management State Revolving Fund Branch 1200 Pennsylvania Avenue (4204

- M) EPA East Building, 7 th 

### Floor Washington, DC 204602



### SECTION I: PART A OF THE SUPPORTING STATEMENT 1. IDENTIFICATION OF THE INFORMATION COLLECTION 1(a) TITLE OF THE INFORMATION COLLECTION "CLEAN WATER ACT STATE REVOLVING FUND PROGRAM" (OMB Control N umber 2040

- 0118, EPA ICR N umber 1391.10 ) 1(b) SHORT CHARACTERIZATION (ABSTRACT) The information collection activities will occur primarily at the program level through the State "Intended Use Plan" and "Annual Report". The information is needed annually to im plement Section 606 of the Clean Water Act (CWA). The Act requires the information to ensure national accountability, adequate public comment and review, fiscal integrity, and consistent management directed to achieve environmental objectives.
The indivi dual information collections are described as follows:

a . Capitalization Grant Agreement and Application/State Intended Use Plan The capitalization grant agreement and application is the principal instrument by which the State commits to manage its revol ving fund program in conformity with the requirements of the CWA. The grant agreement contains or incorporates by reference the Intended Use Plan IUP, application materials, payment schedule, and required certifications. Information on hardship grants, D isadvantaged Business Enterprise (DBE), environmental indicators, environmental benefits, core measurements, and funding framework can be found in the IUP. The grant agreement is a general instrument to legally commit the State and the Environmental Prote ction Agency ( EPA ) to execute their responsibilities under the Act.3

b. Annual Report
The A nnual R eport indicates how the State has met the goals and objectives of the previous fiscal year as stated in the IUP and grant agreement. The Report provides information on loan recipients, loan amounts, loan terms, hardship grants, DBE, environmental indicators, environmental benefits, core measurements, funding framework, project categories of eligible costs, and similar data on other forms of assistance, an d is needed for input into the Clean Water State Revolving Fund (CW SRF ) National Information Management System. The Report also describes the extent to which the existing CW SRF financial operating policies, alone or in combination with other State financi al assistance programs, will provide for the long

- term fiscal health of the Fund

.

c. State Annual Audit The State annual audit report will contain opinions on the financial statements of the CW SRF , a report on the internal controls, and whether the CW SRF program compliance requirements have been met. Separate financial audits may be done in conjunction with the guidelines of the Single Audit Act of 1996. d. Applications for CW SRF Financing Assistance Local communities have the responsibility for prepar ing and submitting applications for CW SRF assistance to their respective State A gency which manages the CW SRF program. The State has sole responsibility for reviewing the applications, entering into loan and other financing arrangements with applicants, a nd otherwise managing operations of the CW SRF.4

2



### . NEED FOR AND USE OF THE COLLECTION 2(a) NEED/AUTHORITY FOR THE COLLECTION The Clean Water Act, as amended by "The Water Quality Act of 1987" (33 U.S.C. 1381

- 1387 et. seq.), created a Title VI which authorizes grants to States for the establishment of State Water Pollution Control Revolving Funds. The information activities are pursuant to Section 606 of the Act, EPA Initial Guidance for State Revolving Funds (January 1988), and CW SRF Interim Final Rule (March 1990). The 1987 Act declares that water pollution control revolving loan funds shall be administered by an instrumentality of the State subject to the requirements of the Act. This means that each State has a general responsibility for admin istering its revolving fund, and must take on certain specific responsibilities in carrying out its administrative duties. 2(b) USE/USERS OF THE DATA In order for a State to receive a capitalization grant for its revolving fund, it must enter into an a greement (Capitalization Grant Agreement) with the EPA. State responsibilities include: a. c ontributing 20 p ercent m atching f unds; b. c ommitting f unds e xpeditiously; c. j ointly e stablishing a p ayment s chedule w ith the f ederal g overnment; d. e nsu ring t hat e nforceable r equirements are f ulfilled b efore the a ssistance is p rovided to r ecipients for o ther p urposes; and e. m onitoring a ssistance r ecipient c ompliance w ith p rogram r equirements and o ther f ederal c ross - cutting a uthorities d uring the p eriod of the a ssistance a greement.5

A State, as a federal grant recipient, must also agree to follow generally accepted accounting principles . A State is expected to have an annual financial audit conducted and must assure that assistance recipients adher e to appropriate accounting and auditing procedures. The information to be provided to EPA by the States i nclude s : a. Capitalization Grant Agreement and Application/Intended Use Plan; b. Annual Report; and c. State Annual Audit. Upon approval of the capitalization grant application, each State has the responsibility to establish its CW SRF program. Once the CW SRF is operational, the State will receive and review applications for CW SRF financing assistance submitted by local communities. The State will review the applications for conformance with the CW SRF Intended Use Plan, environmental impact and benefits , and financial capability of the applicant. For those projects funded with monies directly made available by the Federal capitalization grant , the State will also review the proposed project for consistency with applicable Title II requirements and other Federal cross - cutting authorities as described in the CW SRF Initial Guidance and other CW SRF program materials. The specific procedures for p reparation and review of application materials will be developed by each State. If an application is acceptable, the State prepares the appropriate loan agreement documents. Although EPA oversees the general operations of the CW SRF programs as part of i ts Annual Review process, the Agency does not have any responsibility for reviewing or approving individual applications for CW SRF financial assistance.6



### 3. THE RESPONDENTS AND THE INFORMATION REQUESTED 3(a) RESPONDENTS/SIC CODES State and local go vernments; local communities and tribes (SIC Code #99) 3(b) INFORMATION REQUESTED (i) Data Items In general, the information collections are required to ensure compliance with Title VI of the Clean Water Act and to ensure that self

- sufficient CW SRF p rograms are established in perpetuity. These information elements also provide the accountability needed to detect shall remedy situations of waste, fraud, and abuse of Federal funds. The individual information collections are described as follows:

a. Capitalization Grant Agreement and Application/State Intended Use Plan The capitalization grant application is made on EPA short form No. 5700

- 33 (OMB No. 2030

- 0020). The minimal increase in State burden associated with use of this form is being handled separately by the Grants Administration Division in their information collection budget request.
The CW SRF Management Manual includes a model IUP which should improve program efficiency and reduce the burden on States and EPA Re gions. b. Annual Report Section 606 (d) requires the States to submit an annual report at the end of each fiscal year that identifies how the State has met the goals and objectives of the previous fiscal year as stated in the IUP7 and grant agreement. Th e annual report provides information on loan recipients, loan amounts, loan terms, environmental benefits, DBE, project categories, and similar data on other forms of assistance. The annual report describes the extent to which the existing CW SRF financia l operating policies, alone or in combination with other State f inancial assistance programs, will provide for the long term fiscal health of the Fund and carry out other provisions specified in the grant operation agreement. To reduce the burden on the S tates, EPA developed a model annual report, patterned after the model IUP. This model is included in the CW SRF Management Manual.

c. State Annual Audit Most States have agreed to conduct or to have conducted a n independent financial audit of its CW SRF which will provide opinions on the financial statements, and a report on the internal controls and compliance with program requirements. The remaining States will be covered by audits conducted under the requirements of the Single Audit Act or by the EPA Office of Inspector General. d. Applications for CW SRF Financing Assistance Local communities and other eligible entities have to prepare and submit applications for CW SRF assistance to their respective State Agency which manages the CW SRF program. T itle VI outlines eligibilities under the CW SRF program in terms of potential recipients, types of projects and activities which may receive CW SRF assistance, and the types of financial assistance which an CW SRF may provide. The Clean Water Act provides si gnificant flexibility to the States regarding the development of specific procedures for reviewing and approving applications for CW SRF assistance and for managing the CW SRF program. Specific reporting requirements which are statutorily based relate8 only to the relationship between the State as recipient of the Federal capitalization grant and the Agency as grantor. Similarly, the CW SRF Initial Guidance, the Interim Final Rule, CW SRF Management Manual, and other CW SRF program materials do not provide guid ance or direction to the States regarding the development of application materials or specific procedures for the processing and disposition of applications for CW SRF assistance. Generally, the applications for CW SRF assistance require local communities t o provide the following information: o Project description; o Project cost estimate; o Estimated construction schedule; o Projected disbursement schedule; o Description of environmental impacts and benefits; o Estimation of cost impacts on users; o Identif ication of repayment source; o Description of community financial capability; and o For certain projects, certifications and demonstrations regarding compliance with applicable Title II requirements and other Federal cross

- cutting authorities. (ii) Respon dent Activities The respondents (State and local governments) prepare and submit the Capitalization Grant Agreement an d Application / Intended Use Plan when apply ing f or Federal financial assistance9



### 4. THE INFORMATION COLLECTED
-- AGENCY ACTIVITIE S, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT 4(a) AGENCY ACTIVITIES The Agency reviews the submissions from the State and local governments and analyzes the data provided on the Capitalization Grant Agreement and Application/Intended Use Plan in order to base its decisions for approval. The Agency reviews the annual reports and the annual audits from each state to ensure that the intended financial and programmatic objectives of the program are being met. 4(b) COLLECTION METHODOLOGY AND MANAG EMENT
The CW SRF Management Manual includes a model agreement which draws from the existing Construction Grant Agreement. Use of this example is likely to reduce the information burden on States and EPA Regions. Section 606(c) requires the State to prepa re a plan identifying the intended uses of the funds in the CW SRF and describing how th e se uses support the goals of the CW SRF. Th e Intended Use Plan (IUP) must be submitted annually, after the State has provided an opportunity for public comment and revi ew. The primary purpose of the IUP is the identification of proposed annual intended uses of the amounts available to the CW SRF. The secondary purpose of the IUP is the facilitation of the negotiation process for the capitalization grant agreement and sc hedule of grant payments (Section 606(b)).
Under S ection 606(c) ( l), the IUP must contain a list of publicly

- owned treatment works projects on the State's priority list that are eligible for CW SRF construction assistance. This IUP list includes: the co mmunity name; the permit number or other applicable enforceable requirement; the type of financial assistance; and the projected amount of eligible assistance.10

Under S ection 606(c)(2), the State must describe long and short term goals and objectives of its water pollution control revolving fund.
Under S ection 606(c)(3), the IUP must include information on the types of act ivities to be supported by the CWS RF. Section 606(c)(4) requires that assurances and specific proposals be contained in the IUP to describe how the State intends to meet the following requirements:

- Section 602(a)

-- State certification that it will conduct environmental reviews on treatment works projects and submit the specific procedures it will use.

- Section 602(b)(3)

-- State certification that it will enter into binding commitments. The estimated schedule for the binding commitments is a part of the IUP.

- Section 602(b)(4)

- State certification that all funds in the CW SRF will be expended in an expeditious and timely manner

.

- Section 602(b)(5)

-- State identification of all projects expected to be funded with "first use" funds to meet the enforceable requirements of the Act. All States have certified compliance with this requirement. Section 606(c)(5) requires that the IUP describe the criteria and methods established for the distribution of the CWSRF funds. The first part describes the distribution of the various types of assistance offered by the State (e.g., loans, guarantees, insurance, refinancing of existing debt, le veraging). The second part describes the process the State will use to select S ection 212 POTW construction projects from the project priority list, and projects or programs to be funded as eligible activities for non

point source (NPS) and estuary protec tion management programs. This section also includes how the State will provide opportunity for public comment and review of the IUP before submitting it in final form to EPA.11

Except for the NPS and estuarine management programs under Sections 319 and 3 20, the procedures for selecting projects from the State priority list and for providing for public participation have already been established under the existing Construction Grant Program. Therefore, the burden connected with this part of the IUP will a lso be minimal. Payment Schedule

-- Based on its projection of binding commitments in its Intended Use Plan, the State must propose a draft payment schedule. The payment schedule and the specific criteria establishing the conditions under which the State may draw cash from ASAP (Automated Standard Application for Payments system) must be jointly established by EPA and the State. A schedule of estimated disbursements is also required to allow a forecast of the amount of funds to be drawn from ASAP during the upcoming Federal fiscal year. This forecast is necessary to plan the outlay of Federal funds from the Treasury due to the Title VI program. In its Annual Report, the State verifies that it has:

- Reviewed all CWSRF funded S ection 212 projects in acc ordance with the approved environmental review procedures ( S ection 602(a));

- Deposited its matching funds on or before the date on which each EPA quarterly grant payment was made ( S ection 602(b)(2));

- Made binding commitments to provide assistance equa l to 120 percent of the amount of each grant payment within one year after receiving the grant payment ( S ection 602(b)(4));

- Expended all monies in the fund in an expeditious and timely manner ( S ection 602(b)(4));

- First used all monies in the fund as a result of capitalization grants to assure maintenance of progress toward compliance with the enforceable requirements of the Act ( S ection 602(b)(5)); and

- Complied with the Title II requirements applicable to those eligible12 treatment works funded in wh ole or in part before fiscal year 1995 with an amount equivalent to the capitalization grant ( S ection 602(b)(6)); crosscutters still apply
Under S ection 606(b), at least once a year the Administrator (through the Office of the Inspector General) expect s t he State to independently conduct or to have conducted a financial and compliance audit of its CW SRF and operations. The State may designate an independent auditor t o carry out the audit or may contractually procure the service. If the State fails to con duct the audit or if the review is unsatisfactory, the Office of Inspector General (OIG) may arrange for an EPA audit. The OIG is currently developing an audit guide for CW SRFs, which should reduce the burden on States that wish to conduct their own audit s and improve the efficiency of EPA reviews. Title VI outlines eligibilities under the CW SRF program in terms of potential recipients, types of projects and activities which may receive CW SRF assistance, and the types of financial assistance which an CW SR F may provide. The CWA provides significant flexibility to the States regarding the development of specific procedures for reviewing and approving applications for CW SRF assistance and for managing the CW SRF program. Specific reporting requirements which ar e statutorily based relate only to the relationship between the State as recipient of the Federal capitalization grant and the Agency as grantor. Similarly, the CW SRF Initial Guidance, Interim Final Rule, CW SR F Management Manual, and other CWS RF progr am materials do not provide guidance or direction to the States regarding the development of application materials or specific procedures for the processing and disposition of applications for CW SRF assistance. The Initial Guidance and Interim Final Rule on State Revolving Funds impose virtually no requirements on States that go beyond those imposed by the CWA itself. The guidance and rule were designed to promote flexibility for States in establishing and operating their CW SRF programs, within the bounds of the Act.13

Because the CWS RF is a dynamic State

- led program, EPA has undertaken many activities to support the Regions and States with implementation. EPA has prepared model documents relating to intended use plans, capitalization grant agreements, and annual reports. EPA Regional personnel are regularly in contact with their State counterparts and are currently working to determine efficient ways to communicate needed information and reduce the burden. The information collection activities will occur pr imarily at the program level through the State Intended Use Plan and Annual Report. The information is needed annually to implement Section 606 of the CWA. The Act requires the information to ensure national accountability, adequate public comment and review, fiscal integrity, and consistent management directed to achieve environmental objectives. 4(c) SMALL ENTITY FLEXIBILITY A majority of the reporting burden (IUP, annual report, annual audit, falls on the States. For those communities / municipa lities desiring financial assistance from the CW SRF, they will have a smaller reporting burden requirement (loan applications). For those small or local organizations requiring assistance (non

- point source pr ojects ), they will also prepare loan applicatio ns similar to the communities ’ / municipalities ’ requirement for submittal to the State program office. 4(d) COLLECTION SCHEDULE The information collection activities will occur primarily at the program level for use in the State Intended Use Plan and An nual Report. The information is needed annually to implement Section 606 of the CWA. The Act requires the information to ensure national accountability, adequate public comment and review, fiscal integrity, and consistent management directed to achieve e nvironmental objectives.14

5. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 5(a) NONDUPLICATION The information collection elements are specific to Title VI, established under the amendments to the CWA. The infor mation in the Intended Use Plan, Annual Report, and State Audit is unique to each State participating in the CW SRF program. Therefore, duplication of effort is not ex pect ed. The information collection activities herein are based upon program specific Sta te sources which are not duplicated anywhere else. 5(b) CONSULTATIONS The information collection requirements were developed during the initial stages of the program, and were reviewed and commented on by the groups that would be impacted; such as State officials, representatives of local government, private concerns involved with municipal finance, EPA regional and Headquarters’ offices, and the Office of Management and Budget. The Association of State and Interstate Water Pollution Control Administrato rs (ASIWPCA) also reviewed and commented on the requirements. As the program progressed through the years, there were minor changes made to the requirements, mostly due to reporting burden increases resulting from an increase in the number of loan applica nts. These changes were reviewed and commented on by the impacted organizations as a result of the Federal Register postings every 3 years during the renewal process. The burden hours did double for one year in 2009, due to the infusion of $4 billion d ollars into the SRF program from the American Recovery and Reinvestment Act of 2009. However, these burden hours were approved by OMB on a separate ICR developed by the EPA Grants Administration Division; and these hours allowed have since been dropped fr om the Agency’s data collection budget for the SRF program.15

5(c) EFFECTS OF LESS FREQUENT COLLECTION The statute (Clean Water Act) requires the information to be provided at least annually. EPA is not requesting the information more frequently, a lthough a State may submit it more frequently if it wishes (e.g. semi

- annual audit instead of annual audit). The information is indispensable for prudent administration and sound fiscal management of the State Revolving Fund Program. EPA will use the inf ormation to respond to OMB and Congressional requests and requirements for accurate analysis and projection of national budget impacts and needs. It will be relied upon by State managers for key planning decisions and by EPA managers for essential program evaluation and corrective measures. Local communities are not required to apply for CW SRF assistance. Preparation of an application is only necessary if the community wishes to receive financial assistance. In view of the limitation of funds available from the CWSRF and the option of other sources , a limited number of communities will likely receive assistance in a particular year. The impact on communities generally is quite limited. 5(d) GENERAL GUIDELINES The data collections covered by this ICR a re in compliance with the OMB General Guidelines for information collections. 5(e) CONFIDENTIALITY AND SENSITIVE QUESTIONS (i) Confidentiality No confidential data is collected. (ii) Sensitive Questions No such information is required.16

5 (f) PU BLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB The first Federal Register Notice soliciting public c omment on this ICR was published July ____, 2011 . A copy of the Notice is attached to the supporting statement.
6. ESTIMATING THE BU RDEN AND COST OF THE COLLECTION 6(a) ESTIMATING RESPONDENT BURDEN HOURS The respondent burden estimates are based on the incremental effort associated with the information collection activity. As program activity increases at the local and State level t he preparation and review of local community applications for CW SRF assistance will likely increase. The estimation of State respondents' burden for the four information collections are shown below:

a. Capitalization Grant Agreement and Application /State I ntended Use Plan We estimate that States will spend an average of 400 hours each to prepare the Capitalization Grant Agreement and Application / State Intended Use Plan for submission to EPA. The information provided for hardship grants, environmental b enefits, core measurements and funding framework is included in the burden hour estimate. The following chart represents the total national burden from the Capitalization Grant Agreement and Application / State Intended Use Plan.
FY 20 12 : 51 States X 40 0 hrs = 20,400 burden hours FY 20 13 : 51 States X 400 hrs = 20,400 burden hours FY 20 1 4 : 51 States X 400 hrs = 20,400 burden hours Total 1,200 hrs 61,200 hrs17

b. Annual Report EPA estimates that over the three year period covered by this ICR the Sta tes will spend an average of 275 hours to put together their Annual Report on the CW SRF program. The annual report will include information on hardship grants, DBE, environmental benefits, core measurements, funding framework, and input for the CW SRF Nati onal Information Management System.
FY 20 12 : 51 States X 275 hrs = 14,025 burden hours FY 20 13 : 51 States X 275 hrs = 14,025 burden hours FY 20 1 4 : 51 States X 275 hrs = 14,025 burden hours Total 825 hrs 42,075 hrs

c. State Annual Audit The estimat ed average burden for each State Annual Audit was 80 hours per year. It should be noted that all States are expected to have an annual financial audit of their program conducted, including opinions on the financial statements, and reports on internal cont rols and compliance with program requirements. This estimate is based on the extra increment of effort caused by the federal requirement. Some States will build on the Single Audit Act audits while others will simply have annual financial audits conducte d on their program.
FY 20 12 : 51 States X 80 hrs = 4,080 burden hours FY 20 13 : 51 States X 80 hrs = 4,080 burden hours FY 20 1 4 : 51 States X 80 hrs = 4,080 burden hours Total 240 hrs 12,240 hrs It is important to note that respondents may use CW SRF administrative monies to pay for costs resulting from the State Annual Audit. Section 603(d)(7) of the Act allows money in the CW SRF to be used for the reasonable costs of administering the Fund, provided that the amount does not exceed four percent of th e Federal grant awards received by the State CW SRF. If the effort18 required under the State Audit exceeds the requirements under the Single Audit Act, the incremental costs associated with the additional effort may be paid from the administrative monies. d. CW SRF Assistance Application Preparation and Review States have total responsibility for reviewing and approving local applications for assistance from the CW SRF program. We estimate that States will spend an average of 40 hours in reviewing and ap proving each assistance application. The following chart represents the total national State burden in processing CW SRF assistance applications.
FY 20 12 : 51 States X 7 4 Comm. appl. X 40 hrs = 150,960 hours FY 20 13 : 51 States X 7 9 Comm. appl. X 40 hrs = 161,160 hours FY 20 1 4 : 51 States X 8 4 Comm. appl. X 40 hrs = 171,360 hours Total 2 3 7 Comm. appl. 483,480 hours States develop specific procedures and reporting and application materials for CW SRF assistance applicants. We estima te that local communities and tribes will spend an average of 60 hours in collecting information and preparing their CW SRF assistance applications. The following chart represents the total national local community burden in preparing CW SRF assistance appl ications. FY 20 12 : 3,774 Comm. X 60 hrs = 226,440 burden hours FY 20 13 : 4,029 Comm. X 60 hrs = 241,740 burden hours FY 20 1 4 : 4,284 Comm. X 60 hrs = 257,040 burden hours Total 12,087 Comm. 725,220 hrs19

A verage Annu al State Burden Hours (FY 20 12
- 20 1 4):
Hours Hours ICR per State all States Capitalization Grant Agreement 1,200 61,200 and Application / State Intended Use Plan Annual Report 825 42,075 State Annual Au dit 240 12,240 Application Review 9,480 483,480

___________________ T otal State Burden Hrs. (FY 20 12

- 201 4 ) 11,745 598,995 Average Annual State Burden Hours (FY 20 12

- 20 1 4 ) 3,915 199,665

Total Local Commun ity Burden Hours (FY 20 12
- 20 1 4 ):
Hours Hours ICR per Comm. all Comm. Application Preparation 60 725,220 Average Annual Local Community Burden Hours (FY 20 12
- 20 1 4 ):
Hours Hours ICR per Comm

. all Comm

. Application Preparation 60 241,74020 Total Local Community Respondents (FY 20 12
– 201 4 ) 12,087 Average Local Community Respondents (FY 20 12
– 201 4 ) 4,029 6(b) ESTIMATING RESPONDENT COSTS

a. Costs To State Res pondents The average annual State Costs for the three

- year period is estimated to be $ 8,725,760 It is important to note that costs to the States are CW SRF gr ant eligible, and therefore, are indirect Federal costs paid out of the CW SRF. Under section 603 (d)(7), money in the CW SRF may be used for the reasonable costs of administering the Fund, provided that the amount does not exceed four percent of all grant awards received by the CW SRF. CW SRF administrative monies may be used for all reasonable costs th at would be eligible under section 205(g) for delegated program and project management, to the extent those types of costs are incurred for management of the CW SRF and for projects receiving financial assistance from the . (If actual State expenditures fo r administrative costs of managing the CW SRF exceed the four percent limit, the excess costs must be paid from other State monies.) A small sample of State respondents were initially selected during program implementation for interviews for assessing cost s and hourly burden. The respondents provided estimates for the costs associated with the information collection activity. The estimates were averaged for the four individual activities involving information collections that have already been described. The averages were multiplied to reflect participation by all States in the CW SRF program and by the States' reported FTE (full

- time employee) direct labor costs.21 FY 20 12 ICR # States Hours $/Hour $ Cost Capitalization Grant Agreement and Application/Intended Use Plan

- Initial Plan 51 300 32 .00** 489,6 00

- Revised Plan 51 100 3 2 .00** 163,200 Annual Report 51 175 3 2 .00** 285,600
State Audit 51 80 3 2 .00** 130,560 Appl. Review 3,774 60 3 2 .00** 7,246,080 Total FY 20 12 State Cost $ 8,315,040 ** State salary cost is figure d at $2 7 .00 per hour to cover technically trained personnel plus an additional ADP cost of $5.00 per hour = $3 2 .00 total per hour. FY 20 13 ICR # States Hours $ /Hour $ Cost Capitalization Grant Agreement and Application/Intended Use Plan

- Initial Plan 51 300 3 2 .00** 489,600

- Revised Plan 51 100 3 2 .00** 163,200 Annual Report 51 200 3 2 .00** 326,400
State Audit 51 80 3 2 .00** 130,560 Appl. Revie w 4,029 60 3 2 .00** 7,735,680 Total FY 20 13 State Cost $ 8,845,440
FY 20 1 422 ICR # States Hours $/Hour $ Cost Capitalization Grant Agreement and Application/Intended Use Plan

- Initial Plan 51 300 3 2 .0 0** 489,600

- Revised Plan 51 100 3 2 .00** 163,200 Annual Report 51 250 3 2 .00** 408,000
State Audit 51 75 3 2 .00** 122,400 Appl. Review 4,284 60 32.00** 8,225,280 Total FY 20 1 4 State Cost $ 9,408,480

Total State costs (FY 20 12

- 20 1 4 ) $ 26, 568,960 Average annual State cost over 3

- year period $ 8, 856,320
b. Costs to Local Respondents Local communities may incur costs in identifying and evaluating their water quality problems. Likewise, communities may need to absorb costs re lated to the development and evaluation of alternative planning and engineering approaches for solving the water quality problems. These planning and design costs may be eligible for CW SRF assistance at a State's option. For the purpose of this informati on collection, only the direct costs associated with preparation of the application for CW SRF financial assistance are reported. During the period of this information collection activity, the CW SRF program will experience growth in the number of communiti es which receive CW SRF financial assistance. The number of communities in each State will vary significantly according to the funding available, the types of projects to be assisted, the average cost/size of projects, and other factors. The23

Agency estima tes that the number of local communities to receive CW SRF assistance during the period of this information collection to be as follows: 20 12

- 74 per State; 20 13

- 7 9 per State; 20 1 4

- 84 per State. Only communities which desire financial assistance from the CW SRF will prepare applications. Therefore, this information collection will pertain only to a limited number of communities. The specific requirements and complexity of application materials varies widely among the States which are responsible for C W SRF program implementation and management. The Agency estimates that on average, communities will spend approximately 60 hours in completing their CW SRF assistance applications.
FY 20 12
ICR # C ommunities Hours $/Hour $ Cost Appl. Prep. 3,774 60 2 7 .00 $ 6,113,880
FY 20 13
ICR # Communities Hours $/Hour $ Cost Appl. Prep. 4,029 60 2 7 .00 $ 6,526,980
FY 20 1 4
ICR # Communities Hours $/Hour $ Cost Appl. Prep. 4,284 60 2 7 .00 $ 6,940,080 Total Local costs (FY 20 12

- 20 1 4 ) $ 19,580,940 Average annual local cost over 3

- year period $ 6,526,98024

6(c) ESTIMATING AGENCY BURDEN AND COST E st imation of the direct costs to EPA to implement the CW SRF Program covers negotiation and analysis of the Intended Use Plan (including Capitalization Grant Agreement and Application), and assessment of State performance and compliance through the Annual R eport and State Audit. Analysis of documents, information, and data includes receipt, validation, verification, and evaluation. Authorization for the CW SRF Program expired in FY 1994, however, since future appropriations for the program are anticipated, States will continue to submit applications for capitalization grants. Many States are expected to make modifications to their programs. These changes may include new funding approaches (e.g., leveraging funds, alternative sources for required State matc hing funds), revised environmental pr ocedures, and alternative methods to assure compliance
T he average annual Federal cost of $ 1,766,640 over the three

- year period was estimated as follows:
FY 20 12
ICR Hours $/Hour $ Co st EPA HQ Review of IUP 765 4 8 .00* 36,720 and Agreement Materials ( 15 hrs per State submission) EPA Regions' Review of IUP 17, 850 40 .00 ** 714,000 and Agreement Materials (350 hrs per State submission)25

EPA HQ Oversight Review 2,040 4 8 .00* 97,920 of Annual Report/Audit ( 4 0 hours per State submission) EPA Regions' Oversight 20, 4 00 40 .00 ** 816,000 Review of Annual Report/Audit (400 hours per State submission) Total FY 20 12 Federal 41,055 $ 1,664,640 * GS 13/5, including PC&B (personnel compensation and benefits). ** GS 12/5, including PC&B.

F Y 20 13
ICR Hours $ /Hour $ Cost EPA HQ Review of IUP 7 65 4 8 .00* 36,720 and Agreement Materials (15 hours per State submission) EPA Regions' Review of 17, 850 40 .00 ** 714,000 IUP and Agreement Materials (350 hours per State submission) EPA HQ Oversight Review 2,040 4 8 .00* 97,920 of Annual Report/Audit ( 4 0 hours per State submission)26

EPA Regions' Oversight 22, 950 40 .00 ** 918,000 Review of Annual Report/Audit (450 hours per State submission) Total FY 20 13 Federal 43, 605 $ 1, 766,640
FY 20 1 4
ICR Hours S/Hour $ Cost EPA HQ Review of IUP 7 65 4 8 .00* 3 6,720 and Agreement Materials (15 hours per State submission) EPA Regions' Review of 17, 850 40 .00 ** 714,000 IUP and Agreement Materials (350 hours per State submission) EPA HQ Oversight Review 2,0 4 0 4 8 .00* 97,920 of Annual Report/Audit (40 hours per State submission) EPA Regions' Oversight 25, 5 00 40 .00 ** 1,020,000 Review of Annual Report/Audit (500 hours per State submission) Total FY 20 1 4 Federal 46,155 $1, 868,640

Total Federal costs (FY 20 12

- 20 1 4 ) $ 5,299,92027

Average annual cost over 3

- year period $ 1,766,640 Total Federal Burden Hours (FY 20 12

- 201 4 ) 130,815 Average Annual Federal Burden Hours 43,605 Hourly Federal Cost $ 40.51 6(d) BOTTOM LINE BURDEN HOURS AND COSTS / BURDEN TABLES (i) Respondent Burden (FY 20 12
- 20 1 4 ) Total State Burden Hours 598,995 Average Annual State Burden Hours 199,665
Total State Costs $ 26, 568,960 Average Annual State Costs $ 8, 856,320 Hourly State Cost $ 3 2.00 Total Local Burden Hours 725,220 Average Annual Local Burden Hours 241,740 Total Local Costs $ 1 9,580,940 Average Annual Local Costs $ 6,526,980 Hourly Local Cost $2 7 .00 Total Average Annual28 Respondents (State and Local) 4,080 Total Average Annual Respondent (State and local) Burden Hours 441,405 Total Average Annual Respondent ( State and Local) Cost $ 15, 383,300 Total Number of Annual Burden Hours / per respondent 1 08.19 (ii) The Agency Tally (F Y 20 12
- 20 1 4 ) Total Federal Costs $ 5,299,920 Average Annual Federal Costs $ 1,766,640 Total Federal Burden Hours 130,815 Average Annual Federal Burden Hours 43, 605 Federal Cost per hour $ 40. 5 1

6(e) REASONS FOR CHANGE IN B URDEN The change in the State and local respo ndent burden of 76,500 hours is a ttributed to an increased estimate on the number of respondents interested in receiving CW SRF loans (adjustment). The previous ICR estimated the number of respondents to be 3, 8 25 , while this ICR estimates the number of respondents to be 4, 080 . More entities will be applying for CW SRF loans than in previous years.29

6(f) BURDEN STATEMENT Average annual State and local burden for this ICR is estimated to be 441,405 hours; and ave rage annual Federal burden is estimated to be 4 3, 605 hours. This includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send co mments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to Susan Auby, U.S. Environmental Prot ection Agency, Collection Strategies Division (Mail Code 2822), 1200 Pennsylvania Avenue, N.W., Washington, DC 20460; and to the Office of Information and Regulatory Affairs, Office of Management and Budget (OMB), 725 17th St., N.W., Washington, DC 20503, marked "Attention: Desk Officer for EPA." Comments are requested within [Insert date 30 days after publication in the FEDERAL REGISTER]. Include the ICR number in any correspondence.