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 Information Collection Request for the 

 Clean Water Act State Revolving Fund Program

 Section 606 of the Clean Water Act

 EPA ICR Number 1391.10

 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, 7th Floor

 Washington, DC 20460
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 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 Number 2040-0118, EPA ICR Number 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 implement 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 individual 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 revolving 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, Disadvantaged 

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 Protection Agency (EPA) to 

execute their responsibilities under the Act. 
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b. Annual Report

The Annual Report 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, and is needed for input into the Clean Water State 

Revolving Fund (CWSRF) National Information Management System. 

The Report also describes the extent to which the existing CWSRF 

financial operating policies, alone or in combination with other State 

financial 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 CWSRF, a report on the internal controls, and 

whether the CWSRF 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 CWSRF Financing Assistance

Local communities have the responsibility for preparing and submitting 

applications for CWSRF assistance to their respective State Agency 

which manages the CWSRF program. The State has sole responsibility 

for reviewing the applications, entering into loan and other financing 

arrangements with applicants, and otherwise managing operations of 

the CWSRF.
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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 CWSRF 

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 administering 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 agreement (Capitalization Grant Agreement) with the 

EPA. State responsibilities include: 

a. contributing 20 percent matching funds; 

b. committing funds expeditiously; 

c. jointly establishing a payment schedule with the federal 

government; 

d. ensuring that enforceable requirements are fulfilled before the 

assistance is provided to recipients for other purposes; and 

e. monitoring assistance recipient compliance with program 

requirements and other federal cross-cutting authorities during 

the period of the assistance agreement. 
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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 adhere 

to appropriate accounting and auditing procedures.

The information to be provided to EPA by the States includes:

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 CWSRF program. Once the CWSRF is 

operational, the State will receive and review applications for CWSRF 

financing assistance submitted by local communities. The State will review 

the applications for conformance with the CWSRF 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 CWSRF Initial Guidance and 

other CWSRF program materials. The specific procedures for preparation 

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 CWSRF programs as 

part of its Annual Review process, the Agency does not have any 

responsibility for reviewing or approving individual applications for CWSRF 

financial assistance.
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3. THE RESPONDENTS AND THE INFORMATION REQUESTED

3(a) RESPONDENTS/SIC CODES

State and local governments; 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 

CWSRF programs 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 CWSRF Management Manual includes a model IUP which should 

improve program efficiency and reduce the burden on States and EPA 

Regions.

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 IUP 
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and grant agreement. The 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 CWSRF 

financial operating policies, alone or in combination with other State 

financial 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 States, EPA developed a model annual 

report, patterned after the model IUP. 

This model is included in the CWSRF Management Manual.

c. State Annual Audit

Most States have agreed to conduct or to have conducted an 

independent financial audit of its CWSRF 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 CWSRF Financing Assistance 

Local communities and other eligible entities have to prepare and 

submit applications for CWSRF assistance to their respective State 

Agency which manages the CWSRF program. Title VI outlines 

eligibilities under the CWSRF program in terms of potential 

recipients, types of projects and activities which may receive CWSRF 

assistance, and the types of financial assistance which an CWSRF may 

provide. The Clean Water Act provides significant flexibility to the 

States regarding the development of specific procedures for 

reviewing and approving applications for CWSRF assistance and for 

managing the CWSRF program.

Specific reporting requirements which are statutorily based relate 
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only to the relationship between the State as recipient of the Federal 

capitalization grant and the Agency as grantor. Similarly, the CWSRF 

Initial Guidance, the Interim Final Rule, CWSRF Management Manual, 

and other CWSRF program 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 CWSRF assistance.

Generally, the applications for CWSRF assistance require local 

communities to 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 Identification 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) Respondent Activities

The respondents (State and local governments) prepare and submit 

the Capitalization Grant Agreement and Application / Intended Use 

Plan when applying for Federal financial assistance
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4. THE INFORMATION COLLECTED--AGENCY ACTIVITIES, 

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 MANAGEMENT

The CWSRF 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 prepare a plan identifying the intended 

uses of the funds in the CWSRF and describing how these uses support the 

goals of the CWSRF. The Intended Use Plan (IUP) must be submitted 

annually, after the State has provided an opportunity for public comment 

and review. The primary purpose of the IUP is the identification of 

proposed annual intended uses of the amounts available to the CWSRF. The 

secondary purpose of the IUP is the facilitation of the negotiation process 

for the capitalization grant agreement and schedule of grant payments 

(Section 606(b)).

Under Section 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 

CWSRF construction assistance. This IUP list includes: the community 

name; the permit number or other applicable enforceable requirement; the 

type of financial assistance; and the projected amount of eligible assistance. 
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Under Section 606(c)(2), the State must describe long and short term goals 

and objectives of its water pollution control revolving fund. 

Under Section 606(c)(3), the IUP must include information on the types of 

activities to be supported by the CWSRF. 

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 CWSRF 

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, 

leveraging). The second part describes the process the State will use to 

select Section 212 POTW construction projects from the project priority 

list, and projects or programs to be funded as eligible activities for nonpoint source (NPS) and estuary protection 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.
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Except for the NPS and estuarine management programs under Sections 319 

and 320, 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 also 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 Section 212 projects in accordance with 

the approved environmental review procedures (Section 602(a));

- Deposited its matching funds on or before the date on which each 

EPA quarterly grant payment was made (Section 602(b)(2));

- Made binding commitments to provide assistance equal to 120 

percent of the amount of each grant payment within one year after 

receiving the grant payment (Section 602(b)(4));

- Expended all monies in the fund in an expeditious and timely manner 

(Section 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 (Section 602(b)(5)); and

- Complied with the Title II requirements applicable to those eligible 
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treatment works funded in whole or in part before fiscal year 1995 

with an amount equivalent to the capitalization grant (Section 

602(b)(6)); crosscutters still apply

Under Section 606(b), at least once a year the Administrator (through the 

Office of the Inspector General) expects the State to independently 

conduct or to have conducted a financial and compliance audit of its CWSRF 

and operations. The State may designate an independent auditor to carry 

out the audit or may contractually procure the service. If the State fails to 

conduct 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 CWSRFs, which should reduce the burden on 

States that wish to conduct their own audits and improve the efficiency of 

EPA reviews.

Title VI outlines eligibilities under the CWSRF program in terms of potential 

recipients, types of projects and activities which may receive CWSRF 

assistance, and the types of financial assistance which an CWSRF may 

provide. The CWA provides significant flexibility to the States regarding 

the development of specific procedures for reviewing and approving 

applications for CWSRF assistance and for managing the CWSRF program.

Specific reporting requirements which are statutorily based relate only to 

the relationship between the State as recipient of the Federal capitalization 

grant and the Agency as grantor. Similarly, the CWSRF Initial Guidance, 

Interim Final Rule, CWSRF Management Manual, and other CWSRF program 

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 CWSRF 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 CWSRF programs, within the 

bounds of the Act.
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Because the CWSRF 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 primarily 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 / municipalities desiring financial 

assistance from the CWSRF, they will have a smaller reporting burden 

requirement (loan applications). For those small or local organizations

requiring assistance (non-point source projects), they will also prepare loan 

applications 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 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.
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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 information in the Intended Use 

Plan, Annual Report, and State Audit is unique to each State participating in 

the CWSRF program. Therefore, duplication of effort is not expected. The 

information collection activities herein are based upon program specific 

State 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 Administrators 

(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 applicants. 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 dollars 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 from the Agency’s 

data collection budget for the SRF program. 
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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, 

although 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 

information 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 CWSRF 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 are 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.
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5 (f) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

 The first Federal Register Notice soliciting public comment on this ICR was 

published July ____, 2011. A copy of the Notice is attached to the 

supporting statement.

6. ESTIMATING THE BURDEN 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 the preparation and review of local 

community applications for CWSRF 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 Intended 

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 benefits, 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 2012: 51 States X 400 hrs = 20,400 burden hours

FY 2013: 51 States X 400 hrs = 20,400 burden hours

FY 2014: 51 States X 400 hrs = 20,400 burden hours

Total 1,200 hrs 61,200 hrs
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b. Annual Report

EPA estimates that over the three year period covered by this ICR 

the States will spend an average of 275 hours to put together their 

Annual Report on the CWSRF program. The annual report will include 

information on hardship grants, DBE, environmental benefits, core 

measurements, funding framework, and input for the CWSRF National 

Information Management System. 

FY 2012: 51 States X 275 hrs = 14,025 burden hours

FY 2013: 51 States X 275 hrs = 14,025 burden hours

FY 2014: 51 States X 275 hrs = 14,025 burden hours

Total 825 hrs 42,075 hrs

c. State Annual Audit

The estimated 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 controls 

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 conducted on their program.

FY 2012: 51 States X 80 hrs = 4,080 burden hours

FY 2013: 51 States X 80 hrs = 4,080 burden hours

FY 2014: 51 States X 80 hrs = 4,080 burden hours

Total 240 hrs 12,240 hrs

It is important to note that respondents may use CWSRF 

administrative monies to pay for costs resulting from the State 

Annual Audit. Section 603(d)(7) of the Act allows money in the 

CWSRF to be used for the reasonable costs of administering the 

Fund, provided that the amount does not exceed four percent of the 

Federal grant awards received by the State CWSRF. If the effort 
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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. CWSRF Assistance Application Preparation and Review

States have total responsibility for reviewing and approving local 

applications for assistance from the CWSRF program. We estimate 

that States will spend an average of 40 hours in reviewing and 

approving each assistance application. The following chart represents 

the total national State burden in processing CWSRF assistance 

applications.

FY 2012: 51 States X 74 Comm. appl. X 40 hrs = 150,960 hours

FY 2013: 51 States X 79 Comm. appl. X 40 hrs = 161,160 hours

FY 2014: 51 States X 84 Comm. appl. X 40 hrs = 171,360 hours

Total 237 Comm. appl. 483,480 hours

States develop specific procedures and reporting and application 

materials for CWSRF assistance applicants. We estimate that local 

communities and tribes will spend an average of 60 hours in collecting 

information and preparing their CWSRF assistance applications. The 

following chart represents the total national local community burden 

in preparing CWSRF assistance applications.

FY 2012: 3,774 Comm. X 60 hrs = 226,440 burden hours

FY 2013: 4,029 Comm. X 60 hrs = 241,740 burden hours

FY 2014: 4,284 Comm. X 60 hrs = 257,040 burden hours

 Total 12,087 Comm. 725,220 hrs
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Average Annual State Burden Hours (FY 2012-2014):

 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 Audit 240 12,240

Application Review 9,480 483,480

 ___________________ 

Total State Burden Hrs. 

(FY 2012-2014) 11,745 598,995

Average Annual State Burden 

Hours (FY 2012-2014) 3,915 199,665

 

 

Total Local Community Burden Hours (FY 2012-2014):

Hours Hours

ICR per Comm. all Comm.

Application Preparation 60 725,220

Average Annual Local Community Burden Hours (FY 2012-2014):

Hours Hours

ICR per Comm. all Comm.

Application Preparation 60 241,740

 
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Total Local Community Respondents

(FY 2012 – 2014) 12,087

Average Local Community Respondents

(FY 2012 – 2014) 4,029

6(b) ESTIMATING RESPONDENT COSTS

a. Costs To State Respondents

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 CWSRF grant eligible, 

and therefore, are indirect Federal costs paid out of the CWSRF. Under 

section 603(d)(7), money in the CWSRF 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 CWSRF. CWSRF 

administrative monies may be used for all reasonable costs that 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 CWSRF and for projects receiving financial assistance 

from the . (If actual State expenditures for administrative costs of 

managing the CWSRF 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 costs 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 CWSRF program and by the States' reported FTE (full-time 

employee) direct labor costs.

 
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FY 2012

 ICR # States Hours $/Hour $ Cost

Capitalization Grant Agreement and Application/Intended Use Plan

 

- Initial Plan 51 300 32.00** 489,600

 - Revised Plan 51 100 32.00** 163,200

Annual Report 51 175 32.00** 285,600

State Audit 51 80 32.00** 130,560

Appl. Review 3,774 60 32.00** 7,246,080

Total FY 2012 State Cost $8,315,040

 

** State salary cost is figured at $27.00 per hour to cover technically trained 

personnel plus an additional ADP cost of $5.00 per hour = $32.00 total per 

hour.

 FY 2013

 ICR # States Hours $/Hour $ Cost

Capitalization Grant Agreement and Application/Intended Use Plan

 

- Initial Plan 51 300 32.00** 489,600

 - Revised Plan 51 100 32.00** 163,200

Annual Report 51 200 32.00** 326,400

State Audit 51 80 32.00** 130,560

Appl. Review 4,029 60 32.00** 7,735,680

 

Total FY 2013 State Cost $8,845,440

FY 2014
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 ICR # States Hours $/Hour $ Cost

Capitalization Grant Agreement and Application/Intended Use Plan

 

- Initial Plan 51 300 32.00** 489,600

 - Revised Plan 51 100 32.00** 163,200

Annual Report 51 250 32.00** 408,000

State Audit 51 75 32.00** 122,400

Appl. Review 4,284 60 32.00** 8,225,280

Total FY 2014 State Cost $9,408,480

 

Total State costs (FY 2012-2014) $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 related 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 CWSRF assistance at a State's option. For 

the purpose of this information collection, only the direct costs associated 

with preparation of the application for CWSRF financial assistance are 

reported.

During the period of this information collection activity, the CWSRF 

program will experience growth in the number of communities which receive 

CWSRF 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. The 
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Agency estimates that the number of local communities to receive CWSRF 

assistance during the period of this information collection to be as follows: 

2012 - 74 per State; 2013 - 79 per State; 2014 - 84 per State.

Only communities which desire financial assistance from the CWSRF 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 CWSRF program implementation and management. The 

Agency estimates that on average, communities will spend approximately 60 

hours in completing their CWSRF assistance applications.

 

FY 2012

 ICR # Communities Hours $/Hour $ Cost

Appl. Prep. 3,774 60 27.00 $6,113,880 

FY 2013

 ICR # Communities Hours $/Hour $ Cost

Appl. Prep. 4,029 60 27.00 $6,526,980

 

 FY 2014

 ICR # Communities Hours $/Hour $ Cost

Appl. Prep. 4,284 60 27.00 $6,940,080

 

Total Local costs (FY 2012-2014) $19,580,940

Average annual local cost over 3-year 

period $6,526,980

 
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6(c) ESTIMATING AGENCY BURDEN AND COST

Estimation of the direct costs to EPA to implement the CWSRF 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 Report and State Audit. 

Analysis of documents, information, and data includes receipt, validation, 

verification, and evaluation.

Authorization for the CWSRF 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 matching funds), revised environmental procedures, and alternative 

methods to assure compliance 

The average annual Federal cost of $1,766,640 over the three-year period 

was estimated as follows:

 FY 2012

 ICR Hours $/Hour $ Cost

EPA HQ Review of IUP 765 48.00* 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 48.00* 97,920

of Annual Report/Audit

(40 hours per State 

submission)

EPA Regions' Oversight 20,400 40.00** 816,000

Review of Annual 

Report/Audit (400 hours 

per State submission) 

 

Total FY 2012 Federal 41,055 $1,664,640

* GS 13/5, including PC&B (personnel compensation and benefits). 

** GS 12/5, including PC&B.

 

 

 FY 2013

 ICR Hours $/Hour $ Cost

EPA HQ Review of IUP 765 48.00* 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 48.00* 97,920

of Annual Report/Audit

(40 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 2013 Federal 43,605 $1,766,640

 

FY 2014

ICR Hours S/Hour $ Cost

EPA HQ Review of IUP 765 48.00* 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 48.00* 97,920

of Annual Report/Audit

(40 hours per State 

submission)

EPA Regions' Oversight 25,500 40.00** 1,020,000 

Review of Annual 

Report/Audit (500 hours 

per State submission) 

 

Total FY 2014 Federal 46,155 $1,868,640

Total Federal costs (FY 2012-2014) $5,299,920
27

 Average annual cost over 3-year period $1,766,640

 

Total Federal Burden Hours (FY 2012-2014) 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 2012-2014)

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 $32.00

Total Local Burden Hours 725,220

Average Annual Local

Burden Hours 241,740

Total Local Costs $19,580,940

Average Annual Local Costs $6,526,980

Hourly Local Cost $27.00

Total Average Annual
28

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 108.19

 

(ii) The Agency Tally (FY 2012-2014)

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 $40.51

6(e) REASONS FOR CHANGE IN BURDEN

The change in the State and local respondent burden of 76,500 hours is 

attributed to an increased estimate on the number of respondents 

interested in receiving CWSRF loans (adjustment). The previous ICR 

estimated the number of respondents to be 3,825, while this ICR estimates 

the number of respondents to be 4,080. More entities will be applying for 

CWSRF 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 average annual Federal burden is estimated to be 43,605

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 comments 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 Protection 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.