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## Information Collection Request **(ICR) Supporting Statement for Clean Water State Revolving Fund Program**  **OMB NO. 2040**  **- 0118**  **, EPA ICR NO.**  **1391.10**
**Terms of Clearance for Current ICR**  **: This information collection is approved for one year. In its subsequent**  **renewal submission, EPA shall submit an updated supporting statement that includes (a) an updated**  **description of the program and the information needed from respondents; (b) updated burden and cost estimates associated with the information; (c) a descripti**  **on of the method by which the information should be submitted to EPA; (d) a new FR citation soliciting**  **comments and a summary of public comments received in response to the citation; and (e) a summary of consultation with representatives outside of EPA to**  **obtain views on availability of data, frequency of collection, clarity of instructions, and recordkeeping,**  **disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. In addition, EPA shall, to the extent poss**  **ible, include in its request all forms and instructions related to the information covered by the supporting statement.**  The supporting statement has been updated to reflect the Terms of Clearance. 

### A. **Justification 1.1 Short Characterization/Abstract**  The Clean Water State Re volving Funds (CWSRF) were established b y the 1987 amendments to the Clean Wat er Act (CWA) as a financial assistance program for a wide range of wastewater infrastructure and other water quality projects . The 1987 amendments added Title VI to the CWA, enabling EPA to provi de grants to all 50 states and Puerto Rico to capitalize CWSRFs
. The CWSRFs can provide loans and other forms of assistance for a wide array of projects , including construction of wastewater treatments facilities, green infrastructure projects, agricultural best management practices , and activities that improve water quality . Eligible borrowers of CWSRF funding range from municipalities to nonprofit organizations and other private entities. Recentl y, Title VIof the CWA was amended in 2014 by the Water Resources Reform and Development Act . Additional information about the CWSRF s is available at http://www.epa.gov/cwsrf/learn

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. This IC R renews the Office of Management and Budget (OMB) Number 2040
- 0118 CWSRF ICR and provides updat ed estimates of the reporting burden associ ated with the inf ormation collection activities. The updated estimates are based on EPA’s most recent public consultation and capture the estimated impact of the WRRDA amendments. The individ

ual information collections covered under this I CR are briefl y described as follows:2

Capi talization Grant Agreement/ Intended Use Plan The Capitalization Grant Agreement is the p rincipal instrument by which a CWSRF commits to manage its revolving fund program in conformity with the requirements of the Clean Water Act . The grant agreement contains or incorporates by reference the intended use plan , applicati on materials, required certification s , and other documentation required b y EPA
. The intended use plan describe s how a CWSRF program intends to use its funds for the upcoming ye ar to meet the objectives of the Clean Water Act (CWA)
. Annual Report The annual report indicates how the CWSRF has met its goals and objectives of the previous state fiscal ye ar as stated in the grant agreement and, more specifically , in the intended use plan . The report provides information on loan recipients, loan amounts, loan terms, project categories of eligible costs, and similar data on other forms of assistance
. Annual Audit The CWA requires a C WSRF to undergo an annual audit. Though an audit conducted under the Single Audit Act meet s this requirement, EPA still recommends that a CWSRF also undergo a separate independent audit as a best management practice . The audit must contain an opinion on th e financial condition of the CWSRF program, a report on its internal controls, and a report on compliance with applicable laws and the CWA. C lean Water N ational Information M anagement S ys tem (CWNIMS) and CWSRF B enefits Reporting (CBR) To meet the CWA obj ective of “promoting the efficient use of fund resources,” states must enter financial data, including project disbursements, into the CWNIMS database on an annual basis. This publicly available information is used by the EPA to assess compliance with the CWSRF s ’ mandate to use all funds in an “expeditious and timely” m anner and achieve the objectives of the CWA . Project level data is collected on a quarterl y basis using the CBR Sy stem to record projected environmental results from CWSRF projects. Public Awareness Policy Per EPA Grants Policy

I ssuance (GPI) 14

- 02: Enhancing Public Awareness of EPA Assistance Agreements, CWSRF borrowers must publicize the EPA’s involvement in project funding onl y up to the funding amount in each ye ar’s capitalization grant. The CWSRFs have various options to meet this requirement. With the exception of the public awareness policy , the respondents for the information collection activities are the state environmental departments, and/or finance agencies responsible for operating the CWSRFs. The public awareness policy directl y impacts CWSRFs borrowers that are designated as recipients of federal funds. The burden associated with the public awareness policy may have an impact on small entities. However, this impact is mitigated b y the fact that the CWSRFs have flexibility in determining which borrowers must comply with this requirement.3

This renew al adds two information collections activities not included in the previous version of the I CR. Sp ecificall y, the renewal includes the additional burden associated with the EPA requirement that the CWSRF s submit data into the C WNIM S and CBR databases on a recurring basis . The renewal also reflects the additional burden related to the recently released public awareness poli cy , directing CWSRF borrowers that receive federal funds to publicize EPA’s role in funding the project s . Though these information collection activities add additional burden, the total estimated reporting burden under this renewal is significantly lower co mpared to the previously approved ICR
. The estimate of the annual burden has been decreased b y 748 ,471 hours while the total annual cost burden has been d ecreased b y $17,744,006

. This significant revision is due to the removal of the burden associated with CWSRF applications and ongoing ARRA reporting. 1 **1.2 Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.**  Title VIof the CWA provides the statutory basis for having a CWSRF prepare and submit a c apitalization grant a greement, intended use plan, annual report, and annual a udit
. EPA also requires that the CWSRFs periodicall y enter program and project level information into CWNIMS and CBR databases. These datab ases provide EPA with the information needed to effectivel y evaluate the performance of the CWSRFs and to ensure compliance with statutory and other federal requirements. Prior to awarding a capitalization grant, EPA must h ave su fficient assurances that a CWSRF will be manage d in compliance with the CWA. To ensure that EPA receives these assurances , the CWA provides specific instructions to the state for developing and submitting the capitalization grant agreement . The contents of the capitalization grant agreement are governed b y Section 6 02, which lists the assurances and certifications a CWSRF must provide to EPA . As part of the capitalizatio n grant agreement, a state must submit an intended use plan that is developed in accordance with Section 606(c). In addition to mandating the minimum level of information that must be included in the intended use plan , S ection 606(c) also require s that a CWSRF provide an op portunity

for public comment before the plan can be submitt ed to EPA for review. The intended us e plan must also reflect how a CWSRF will comply with other federal requirements. These federal requirements are usuall y included in annual appropriation acts. Two major requirements that have accompanied recent annual appropriations involve the use of additional subsidization and the funding of the p rojects that promote such activities as green infrastructure and water and energy

efficiency improvements
. 2 To help ensure that the re is sufficient oversight of the CWSRFs , the CWA also re quires that a CWSRF annually submit a report to EP A and undergo an audit . Under s ection 606 (d) , a CWSRF is required to develop and submit an annual report describing how it has met the goals and obj ectives included in the previous ye ar ’s intended use plan. The annual report must also include

1 Section 15 of the supporting statement provides additional information for why CWSRF applications and ARRA reporting are no longer included as part of the reporting burden calculation. 2 Additional subsidization is assistance provided in the form of prin cipal forgiveness, grants, or negative interest loans.4

detailed information on the financial assistance provided through the CWSRF program over the past year, including identification of the loan recipients, assistance amounts and terms, and other related information. Section 606 (b) requires each CWSRF to have an annual audit that is conducted in accordance with the auditing procedures of the General Accounting Office to ensure the proper usage of all CWSRF funds
. In addition to these statutory requirements, EPA will continue to direct the CWSRFs to submit program and project level information through the CWNIMS and CBR databases on a periodic basis. The information collected through these databases is critical to E PA’s oversight responsibilities in ensuring the timel y and expeditious use of CWSRF funds and the long

- term financial sus tainability

of the CWSRF s. The information collected through CBR database also serves another important role by establishing a stronger link between CWSRF financed projects and the projected environmental benefits as required by EPA Order 5700.7, Environmental Results Under Assistance Agreements. The CWSRFs are asked to submit program level financial data annuall y through CWNIMS, including loan amounts, disbursements, repay ments, and other critical information. The data collected supports section 606(e) of the CWA, requiring EPA to conduct annual oversight reviews of the CWSRFs. The CWNIMS database complements the annual report and audit by providing a current snapshot of financial activity and the extent of which the CWSRFs funds have been committed and disbursed for projects. The CWNIMS database also provides an overview of the ty

pes of projects and the recipients receiving CWSRF funding. This comprehensive overview on program activity allows EPA to discuss the future direction of the CWSRFs and head off potential concerns before they become major problems. The CWNIMS database is also instrumental in allowing EPA to document the progres s of the CWSRFs in addressing the nation’s water quality needs to the public and Congress. Information provided b y this database is an essential part of EPA ’s testimony before the Congressional appropriations and authorizing committees that oversee environmental infrastructure programs. The data collected b y this sy stem is made available to the public and greatly supports outreach efforts b y EPA and several key state and trade organizations (e.g., Council of Infrastructure Financing Authorities, Associatio n of Clean Water Administrators, National Utility Contractors Association, and Water and Wastewater Equipment Manufacturers Association). The CBR database was originall y developed to assist states in complying with EPA Order 5700.7, Environmental Results Under Assistance Agreement s , which became effective on January 1 2005. The Order aimed at addressing environmental results under EPA assistance agreements, including grants and cooperative agreements, and to establish a stronger linkage between EPA financ ed projects and the goals of the Agency ’s Strategic Plan. The CWSRFs had the option of meeting the EPA Order b y entering project level data into CBR and producing report - outs that could then be include d in their annual report. The CWSRFs that chose not to use CBR were required to work with EPA to show appropriate output s and outcomes that can be tied back to the Strategic Plan. 3

3 The Strategic Plan includes five goals to better serve the mission of the Agency, which is to protect human health and the environment. The goal that applies to the CWSRF is Goal 2: Protecting America’s Waters. The key elements for the CWSRF are found under Goal 2, Objective 2.2: Protect and Restore Watersheds and Aquatic Ecosystems.5

Since 2010, Congress has included several major provision s in the annual appropriations that affected the CWSRFs . O ne of the p rovisions included the Green Project Reserve requirement that directed a portion of the federal funding be used to fund projects that addressed green infrastructure, water efficiency improvements, energy

efficiency

improvements, or environmentally

innovati ve activities. Another provision directed that a portion of federal funding be used to provide additional subsidization in the form of principal forgiveness, negative interest loans, or direct grants . Accompanyi ng these provisions was conference language that directed EPA to not only

track how additional subsidies are used, but also by what ty pes of communities. These provisions have been carried over into subsequent appropriations. The CBR database was determined to be the best option for collecting and tracking this information. As a result, data entry into CBR database stopped being optional in 2010. The CWSRFs are required to enter project level infor mation into the CBR database on a quarterl y basis. This frequency

of collection is to ensure that EPA can p rovide a timely response to congressional in quiries with the most up

- to - date data . In response to constant inquiries regarding the status of meeting the annual GPR requirements , EPA also use s the CBR database to track funding under the GPR requirement . The CWSRFs are also still expected to complete the data fields established in 2005, tracking general project information and projected environmental results
. The recentl y released EPA Grants Policy Issuance (GPI) 14

- 02: Enhancing Public Awareness of EPA Assistance Agreements requires CWSRF bo rrowers designated as recipients of federal funds to publicize the EPA’s involvement in the funding of the project. The purpose of this policy is to enhance public awareness of EPA assistance agreements nationwide an d communicate the positive impact and benefits of EPA funding around the country . This requirement went into effect in FY 2015 and applies to all future federal capitaliz ation grant awards
. **2. Indicate**  **how , by whom, and for what purpose**  **the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received**  **from the collection.** The inform ation collection activities serve several important functions. Foremost, they are the mean s by which EPA can assess whether the CWSRFs are being properl y managed. They factor heavily in EPA’s determination of whether a CWSRF should be awarded a capitalization grant
. The capitalization grant a greement/intended use p lan not only provides det ailed information on how a CWSRF will operate its program in the up coming year, it is instrument al in legally binding a CWSRF to fulfilling its responsibilities under the CWA. Working in concert with the capitalization grant agreement/intended use p lan are the annual rep ort and audit, which provide EPA with documentation that a CWSRF is actually operating in compliance with the CWA and thus sufficiently

meeting the assurances provided through the capitalization grant agreement/intended use plan
. While the C WNIMS and CBR databases support program oversight , they also have an important role when it comes to public outreach and responding to stakeholder inquiries in a prompt and effective manner
. The purpose of the new public awareness policy is to better inform the public of the role EPA has in supporting CWSRF funded projects6

that yi eld numerous economic and environmental benefits. With the exception of the public awareness policy , the respondent s for the information collection activities are the state environmental department s , and/or finance a gencies responsible for operating the CWSRFs
. The public awareness policy directl y impacts CWSRFs borrowers that are designated as recipients of federal funds. The burden a ssociated with the public awarenes s policy may

have an impact on small entities . However, this impact is mitigated b y the fact that the CWSRFs have flexibility in determining which recipients must comply with this requirement. Capitalization Grant Agreement / Intended Use Plan The c apit alization grant a greement is the pri ncipal instrument by which a CWSRF comm its to manage its program in conformance with the requirement s of the CWA as a prerequisite of receiving a capitalization grant award . The capitalization grant a greement contains, o r incorporates b y reference, the following : the grant application form (EPA Standard Form (SF) No. 424/ OMB N o. 2020
- 0020), intended use plan, attorney general certification , and other documentation requir ed by EPA . This material is submitted to EPA through the www.grants.gov website. A critical component of the capitalization grant agre ement is the intended use p lan. This document not onl y covers what a CWSRF plan s to accomplish for the upcoming year, it also provide s EP A with detaile d information on how a CWSRF will meet the assurances included as part of the capitalization grant agreement
. At a minimum, the IUP must include the following:

 S hort

- term and long

- term goals
.  “ S ources and U ses ” table that documents the amount of funding that is expected to be available in the upcoming ye ar from capitalization grant awards, state contributions, loan repay ments, earnings, and other non

- federal sources. 4 This table also shows how this funding will be used for eligible projects and administrative expenses. The maximum amount that can be used to cover administration is set by section 603(d)(7).  D ocum entation for how the CWSRF plans to provide the required 20% state match
.  D ocumentation on whether fees will be charged, the basis for the fees, and the planned uses of fee revenue.  A schedule/estimate for when it will enter into binding commitments on projects to ensure that it me ets the requirement that a CWSRF enters into binding commitments equal to the federal grant pay

ment and accompanying 20% state match within one year of receipt of a grant pay ment
. 5 The intended use plan must also document the procedure by which grant funds will be drawn from the fe deral treasury into the CWSRF
.  A summary

of the CWSRF ’s financial plan, including loan interest rate(s); information on how the interest rate, loan term and additional subsidies are established for the ty pes of

4 This mainly includes leveraging, where a CWSRF raises additional funding by selling municipal bonds. 5 For some CWSRFs the binding commitment represents a preliminary commitment to provide funding for a project. The binding commitment is eventually finalized as an executed loan agreement. For other CWSRFs there is no distinction between the binding commitment and e xecuted loan. Regardless, the binding commitment is considered sufficient for meeting this requirement.7

assistance the state will offer; and how it will maintain the long term health of th e Fund. T o the extent kn own, it should also include the state’s plans on leveraging and the level of bond issuance.  D ocumentation on the state’s compliance with the following requirements : o The CWSRF will conduct enviro nmental reviews according to its own establishe d State Environmental Revi ew Process. o The CWSRF wi ll expend all funds in a timely and expeditious manner. o The new capitalization grant agreement requirements added by WRRDA involving cost and effectiveness analy sis and procurement of archite ctural and engineering services. This also includes fiscal su stainability planning by

CWSRF assistance recipients required under section 603(d)(1)(e) of the CWA.  D ocumentation for how the state will ensure compliance with the Single Audit Act, the Federal Funding Accountability and Transparency

Act , and federal cross cutters.  Documentation on whether funds will be transferred between the CWSRF and DWSRF in accordance with section 302 of the Safe Drinking Water Act and/or that the state reserves the right t o transfer fund s in the future.  A list of projects the CWSRF plans to fund. This list should include the following o Documentation that any project meeting the definition of a publicly owned treatment work was ranked based on the state’s project priority se tting s ys tem. o Project description sufficiently detailed to determine project eligibility
. o Ty pe and amount of financial assistance. o NPDES permit number (if applicable).  A description of how the CWSRF plans to meet the Green Project Reserve requirement inclu ded in recent annual appropriations. To the extent possible, this description should include a list of the projects that will be used to meet this target.  A description of how the CWSRF plans to provide additional subsidization. To the extent possible, this description should include a list of the projects that will be used to meet the minimum required amount set by recent annual appropriations and under what conditions it is eligible under the CWA. 6 A CWSRF is required by the CWA to make the intended use plan available for public comment and review
. EPA is also provided an electronic copy for review. Once a CWSRF makes any necessary revisions based on these comments , the CWSRF submit s the final intended use plan through grants.gov as part of the capitalization grant agreement package. Recently , EPA provided the CWSRFs w ith an example intended use plan to provide additional guidance on what should be included in this document
. The purpose of the example inten ded use plan was to reduce the reporting burden b y limiting the amount of interactions between a CWSRF and EPA. 7

6 WRRDA amended the CWA to provide the CWSRFs with the ability to provide additional subsidization under certain conditions. These conditions restrict the use of this type of assistance to addressing affordability issues or to promoting projects that include sustainability, water or energy efficiency, or stormwater components. 7 This example intended use plan is currently being revised to reflect the WRRD A amendments to the CWA.8

Annual Report : As required b y the CWA, an annual report must be submitted to EPA covering program activities for the past ye ar. A cop y of the report is provided in an electronic format (e.g., MS Word or Adobe) to the EPA regional office within 90 day s of the end of the CWSRF ’s fiscal ye ar . The report must illustrate the progress a CWSRF has made toward s meeting the goal s and objectives of the previous fiscal year ’s IUP and capitalization grant agreement. Similarly , the report must document a CWSRF ’ s compliance with the assurances included as part of the intended use plan
. The report must also provide detailed informati on on actual assistance provided, including: loan recipients; loan amounts; loan terms; project categories of eligible cost; and similar details on other forms of assistance. This information must note whether a project is being counted towards the Green Project Reserve requirement . Addition ally , a CWSRF must include whether a project received additional subsidization and supporting rationale for why it was eligible to receive such assistance. A CWSRF must also submit det ailed financial stat ements as part of the annual report that provide a sna

pshot of its financial stability . If an annual audit has not yet been completed, the annual report should include draft financial s tatements and footnotes that are in accordance with generall y accepted accounting principles (GAAP) to present fairl y the financial condition and results of operation. Preferabl y, a CWSRF would include the financial statements resulting from the annual audit. The report is one of the principal instruments by which a CWSRF demonstrates to EPA that it has abided b y the assurances and terms set forth in the capitalization grant agreement. Any major discrepancies between the annual report and capitalization grant/intended use plan must be addressed to the satisfaction of EPA. The regional annual rev iew of a CWSRF is usually where such concerns are identified and raise d , though EPA may contact a CWSRF prior to the annual review if such action is deemed warranted. Annual Audit : Section 606 (b) requires that a CWSRF undergo an independent annual audit consistent with the auditing procedures of the General Accounting Office, including chapter 75 of title 31, United States Code. Though an audit conducted under the Single Audit Act meet s this requi rement, it is strongl y encouraged that a CWSRF s till proceed with an independent annual audit. The rational e being that an indep endent audit looking only at a CWSRF provides a much m o re detailed and effective review as opposed to the Single Audit that grou ps a CWSRF with many other programs disbursing federal funds. A CWSRF usually

relies on the services of a professional auditing firm to conduct the i ndependent audit. The audit include s te sting of accounting records and other procedures the auditor consi ders necessary to express an opinion that the financial statements are fairly presented, in all material respects. Audits also include tests of documentary evidence supporting the transactions recorded in the accounts. The product of an a udit generall y inc ludes issuing the9

following reports:

 Financial statements with an opinion (or disclaimer of opinion) as to whether the CW SRF financial statements are presented fairl y in accordance with GAAP. As a minimum, financial statements should include a statement of net position or balance sheet, statement of revenues and expenses an d changes in net position , a statement of cash flows, and notes to the financial statements.  A report on internal controls related to the CW SRF financial statements. The report should describe the scope of testing of internal control s and the results of the test s.  A report on compliance that includes an opinion as to whether the state has complied in all material respects with laws, regulations, and the provisions of the CW SRF capitali zation grants. On c e completed, an electronic cop y of the annual audit is provided to EPA. Of critical importance is whether the audit includes any finding s or recommendations that either relay concerns that the financial statements may not accuratel y reflect the financial c ondition of the fund or that a CWSRF is not in compliance with one or more federal or state requirements. Working with EPA, a CWSRF must take steps to address the se recommendations
. Clean Water National Information Management Sy stem (CWNIMS) and CWSRF Benefits Reporting (CBR) The CWNIMS and CBR databases are designed to support EPA oversight responsibilities and public outreach efforts. Both databases are hosted on EPA servers located at the National Computer Center and can be accessed at the following web address: https: //owsrf.epa.gov/
. The CWSRFs use this website to establish an account and submit data in the NIMS and CBR databases. The NIMS database provides an annual snapshot of program level activity . By contrast, the CBR database collects project level and projected environmental benefits information quarterl y. During the summer of each year, the CWSRFs complete the CWNIMS data entry for the reporting period of July

1 to June 30. Once the CWSRFs have completed the data entry, EPA, with the assistance of a contractor, conducts a quality review . During the quality review , there is follow

- up with the CWSRFs to address any questions or concerns regarding the most recent entries. Though a cop y of the glossary that defines each data fi eld is included with the supporting statement, a summary

of what must be reported into CWNIMS is provided below:

 Federal and state contributions  Total assistance provided  Assistance b y p opulation s erved  Assistance b y needs category  Leveraging activity

(making additional funding available fo r projects by issuing bonds)  Loan repay

ments  Investment earnings The data collected through the CWNIMS database is used to generate a variety of state and10

national reports that cover various aspects of the CWSRF activity . These reports contain detailed information on CWSRF activity as it relates to funding levels and th e ty pes of projects being funded. These reports also provide detailed information on CWSRF financial performance, including metrics that track the rate of which loans are made and funds are being disbursed for projects. They

also track the extent of which the funds are growing as a result of loan and investment earnings. These reports are reviewed by EPA to identify

possible issues that are brought to the attention of a CWSRF. This is usually included as part of the annual review; however, an issue may

be raised sooner if the situation warrants it.. The CWNIMS reports are publicly available and can be accessed at http://www.epa.gov/cwsrf/clean

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. The CWS RFs are required to enter project level information into the CBR database no less than on a quarterly

basis. Unlike the CWNIMS data, the information captured by the CBR database focus es on loan project level details. More importantly , the CBR database also captures the project ed environmental benefits associated with the CWSRF funded projects. This d atabase also collects data associated with F ederal F unding A ccountability and T ransparency A ct (FFATA)
. The FFATA data fields are optional . Once these data fields are completed, a CWSRF can produce an e xcel

- based report that can then be upload ed into fsrs.gov website. Though a cop y of the help file that defines each d ata field is included with this I CR , a summary of what must be reported into the CBR database is provided below. **Loan Information :**   Borrower  Assistance Ty

pe  Agreement History o Additional Subsidy o Population Served o Green Project Reserve o Needs Categories  % Funded b y CWSRF  CWSRF Total from all Projects $  Interest Rate  Repay ment Period  Tracking #  Other #  In cremental Funding  Loan funds one or more NPS Projects  Assign Assistance to Federal Grant(s): (Additional Subsidization, Green Project Reserve, and FFATA). **Project Information:**  CW Needs Survey

Number  Project Description  Wastewater Volume  Discharge Affected11

 Permit Information  Affected Waterbodies  Project L ocation  Project Improvement/Maintenance of Water Quality  Contribution to Protection or Restoration of the Waterbody and Other Uses The CBR and CWNIMS data is also crucial to EPA’s ability to respond to inquiries from C ongress, OMB, GAO, and other stakeholders. Data from the CBR database has been used to provide C ongress wi th periodic updates on the use of additional subsidization and other trends such as assistance to small communities and the degree b y which the CWSRFs are complying with the GPR requirement. For example, CBR data was one of the primary sources of data used to p repare the following report to C ongress: Utilization of Additional Subsidization Authority in the Clean W

ater and Drinking W

ater State Revolving Fund Programs
. 8 In formation from CBR and CWNIMS is also used in pulling together material needed for the p resident’s budget, including the congressional justification, program factsheets, congressional testimony, and other budget related material. Finally , information from CWNIMS and CBR is pivotal in EPA’s ability to produce information al material that highli ghts the national trends in CWSRF environmental and financial performance . This material includes the environmental benef its reports, national financial reports , and assorted array of factsheets. These document s are made publicly available through EPA ’s website at http://www.epa.gov/cwsrf/clean

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. Publi c Awareness Policy Per EPA Grants Policy

I ssuance (GPI) 14

- 02: Enhancing Public Awareness of EPA Assistance Agree ments, borrowers receiving C WSRF funds must publicize EPA’s invo lvement in project funding. EPA has issued guidance to assist the CWSRFs and borrowers in meeting this requirement. 9 This policy

onl y applies to funding up to the amount of each ye ar’s capitalization grant and states may choose the s ys tems to which this requirement applies. It is at the discretion of the state SRF program to select projects most able to efficientl y and effectivel y compl y i n a way that m eets the intention to enhance public awareness without significant financial hardship to the state or its borrowers. Local respondents have various options to meet this requirement and are encouraged to choose the method most cost

- effective and accessible to a broad audience. Aft er consulting with EPA and CWSRF staff throughout the country, the following compliance options were developed: i. Standard signage ii. Posters or wall signage in a public building or location iii. Newspaper or periodical advertisement for project construction, groundbreaking ceremony , or operation of the new or improved facility iv. Online signage placed on community website or social media outlet

8 A electronic copy of this report is available at http://www.epa.gov/sites/production/files/2015

- 04/documents/additional_subsidization_report_to_congress_.pdf 9 A copy of this guidance has been included with the supporting statement.12

v. Press release The following information must be included:
• Name of facility , pro

ject and community
• State SRF administering the program
• Project is wholly

or partially

funded with EPA funding
• Brief description of project
• Brief description of the water quality benefits the project will achieve **3. Describe whether, and to what**  **extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collections techniques or other**  **forms of information technology, e.g. permitting electronic submission of responses, and the basis for the d**  **ecision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.**  The CWNIMS and CBR databases are hosted at EPA’s National Computer Center and can be accessed onli ne. Once a CWSRF successful l y creates an ac count, it has full access to submit and review data via the online interface. The CWSRF capitalization grant application along with accompanyi ng material (e.g., intended use plan, attorney

general c ertification) is submitted online through www. grants.gov
. **4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in item 2**  **above.** Duplication of effort is not e xpected. The information collected through the intended use plan, annual report, and independent audit is specific to the requirements of the CWA. They are derived from CWSRF specific sources that are not duplicated elsewhere and are designed to capture di fferent aspects of CWSRF activity . The intended use plan provides EPA with a detailed roadmap of how a CWSRF plans to proceed for the upcoming ye ar, while the annual report covers a CWSRF ’ s actually activity . The annual audit provides an independent review of the financial status and m anagement of a CWSRF co nducted b y certified auditors
. The information collected through CWNIMS and CBR databases is also derived from CWSRF specific sources that are not duplicated elsewhere. Much of the overlap between the information reported in CBR and the annual report is by design. One of the CBR database’s primary functions is to provide the CWSRF a convenient means to meet EPA Order 5700.7, Environmental Results Under Assistance Agreement

. The CBR database allowed a CW SRF to document its compliance with this order in its latest annual report b y taking the project level information reported and producing summary statements that could be appended to the document. Though the annual report includes information related to additional subsidization and the GPR , the CWSRFs are asked to enter this information into the CBR database quarterl y so that EPA can effectivel y respond to ongoing congressional inquiries with more recent data
. When CBR data entry

became required for all C WSRF assistance in 2010, there was concern of13

overlap with the program level information already being captured through the NIMS database. Specificall y, project information related to the typ e of assistance provided, needs and population categories, and co nstruction start and initiation of operation data. This overlap has been addressed b y developing a feature that allows CWSRFs to automatically populate overlapping CWNIMS data elements with aggregated CBR data. The informatio n made available because of the public awareness policy is project specific and no duplication is expected. **5. If the collection of information impacts small businesses or other small entities, describe the methods used to minimize burden.**  The respondents for almost all the information collection activities are the S tate Department of Health, Environmental D epartment, and/or Finance Agencies responsible for operating the CWSRFs
. The only

information collection activity that could impact small entities is the public awareness policy
. However, this is not expected to occur since it only applies to a portion of the funding provided annually and a CWSRF has full flexibility in determining which borrowers must comply
. Further, the five compliance options allow borrowers to select the leas t burdensome method for complying with the public awareness policy . As a result, many borrowers are expected to choose the online signage option. It is estimated that only borrowers that are already required by state law to provide promotional material suc h as sign s, posters, and newspapers advertisements will choose the other options provided under the policy
. **6. Describe the consequences to federal program or policy activities if the collection is not conducted or is conducted less frequently, as well, a**  **s any technical or legal obstacles to reducing burden.**  The capitalization grant agreement/intended use plan and annual report are required b y the CWA and represent critical components by which EPA awards capitalizations grants to the CWSRFs. The capitalization grant agreement /intended use plan is the principal means by which a CWSRF commits to managing its program in conformance to the requirements of the CWA
. The annual report and audit provides official documentation that a CWSRF has met this co mmitment. The information collected through the CWNIMS and CBR databases is relied upon by the CWSRFs for key

planning decisions and is used by EPA for essential program oversight and corrective measures . This information is also critical for effectivel y responding to ongoing OMB and congressional requests
. Ty picall y the se requests revolve around wanting a status update regarding the performance of the CWSRFs. However, EPA is sometimes requested to go beyond this and produce anal ys es related to national ne eds and budgetary impacts. **7. Explain any special circums tances that would cause**  **an information collection to be conducted in a manner:** 

 **r equiring respondents to report information to the agency more often than quarterly**  **;**  **r equiring respondents to prep**  **are a written response to a collection of information in fewer than 30 days after receipt of it;** 14

 **r equiring respondents to submit more than an original and two copies of any**  **document;**  **r equiring respondents to retain records, other than health, medical, gov**  **ernment contract, grant** **- in**  **- aid, or tax records for more than 3 years;**   **i n connection with a statistical survey, that is not designed to produce valid and reliable**  **results that can be generalized to the universe of study;**  **r equiring the use of a statistical d**  **ata classification that has not b een reviewed and**  **approved by OMB ;**   **that includes a pledge of confidentiality that is not supported by authority established in statue 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; or**  **requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate**  **that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.**  There are no special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6. **8. I f applicable, identify the date and page number of publication in the federal register of**  **the agency's notice, required by 5 CFR**  **1320.8(d), soliciting comments on the information colle**  **ction prior to submission to OMB. S ummarize public comments receive**  **d in response to that notice and describe actions taken by the agency**  **in response to these comments. S**  **pecifically address comments received on cost and hour burden.** “ On DATE OF PUBLICATION (Month, day , and year), Vol. No. _____, pages __________ to

_ _________, the agency

published the notice of information collection and request for comments in the Federal Register. EPA also reach ed o ut to the following four states : California, Illinois, Georgia, and New Mexi co. These states were specifically selected by EPA to help account for the fact that CWSRFs differ in size, sophistication, and geographic location. As part of the consultation, these states were asked to provide feedback on the proposed burden (hours and cost) associated with information c ollection activities. This feedback was used to develop the revised reporting burden estimates. In addition, these stat es were also asked a series of que stions to obtain their views on the availability

of data, frequency

of collection, the clarity

of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be rec orded, disclosed, or reported. The states indicated that information being reques t by EPA was easily

available. For the most part, they also indicated the information being asked for was appropriate for the stated purposes of the information collection activities and that the process for providing the data to EPA was eas y and straightforward . One state did indicate that s ince each project is unique, it i s occasionall y difficult to match up the list of benefits in the CBR database with the category o f project being funded
. Another state noted the overlap between the CBR and CWNIMS databases. EPA has addressed this overlap b y inclu ding a feature that allows CWSRFs to automatically import CBR project level information into the NIMS database . Another state15

expressed its appreciation of this feature
. **9. Explain any decision to provide any payment or gift to respondents, other than**  **remuneration of contractors o r grantees** 
. No pay ment or gifts are provided to respondents. **10. D escribe any assurance of confidentiality provided to respondents and the basis for the**  **assurance in statute, regulation, or agency policy .**  No confidential information is collected. **11. Provide additional justification for any questions of a sensitive nature, such as sexual**  **behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency cons**  **iders the questions necessary, the specific uses to be made of the information, the explanation to be**  **given to persons from whom the information is requested, and any steps to be taken to obtain their consent.**  Questions of a sensitive nature are not found in this information collection. **12. Provide estimates of the hour burden of the collection of information.** As part of the consultation process, EPA r eached out to the following four states: California, Illinois, Georgia, and New Mexico. These states were selected to ensure that EPA received feedback from a cross - section of the various CWSRFs that accounted for differ ence in size, sophistication, and geographic location . These states were asked to provide feedback on the proposed burden (hours and cost) associated with information collection activities. The average of these responses was used to develop the burden estimates for the following information collection activities: capitalization grant agreement/intended use plan, annual report, annual audit, and CBR and CWNIMS database reporting. Except for the annual audit, the respondents are the 51 State Department of Health, Environmental Department, and/or Finance Agencies responsibl e for operating the CWSRFs . O nly 47 CWSRFs elect to undergo an independent audit. Th e remaining four CWSRFs instead rel y onl y on the audit conducted under the Single Audit Act. It is estimated that a

pproximately 393 CWSRF borrowers annuall y will be affec te d by the public awareness policy
. Historical CWNIMS data was used to estimate the approximate number of loans that wi ll be made in subsequent years. The CWNIMS data was also used to determ ine the subset of these loans subject to the public awarenes s policy
. This was accomplished by calculating the percentage of expected federal funding to total project funding and appl yi ng this percentage to the estimated number of loans.16

The CWSRF salary

cost of $55.09 per hour and the hourly rate of $37.02 estimat es were developed b y an EPA contractor and are based on prevailing wage rates for state staff and water sy stem operators respectively
.

**Activity No. of**  **Responses/Year Hours** 

**Per Response Total Hours** 

**Per Year Cost** 

**Per Hour Total Cost** 

**Per Year** Capitalization Grant Agreement/ Intended Use Plan 51 200 10,200 $55.09 $561,918 Annual Report 51 110 5,610 $55.09 $309,055 Annual Audit 47 770 36,190 $55.09 $1,993,707
CBR & NIMS Reporting 51 90 4,590 $55.09 $252,863 Public Awareness Policy 393 2 786 $37.02 $29,098 **Average Annual # of Hours: 57,376**  **Average Annual Cost: $3,146,641**  **Total # of Hours (2016 to 2018): 172,128**  **Total Cost (2016 to 2018): $9,439,922.46**  **13. P**  **rovide an estimate of the total annual cost burden to respondents or record**  **keepers resulting from the**  **collection of information. (do not include the cost of any hour burden**  **shown in items 12 and 14).** The only non - labor O & M costs are those associated with an independent annual audit. The CWSRF usually

contract the s ervices of an auditing firm to conduct these audits, and the estimated average cost is approximately $62,300

. The total average annual cost for the 47 CWSRFs that elect to undergo an independent audit is estimated to be $ 2 , 928 , 100 **14. P**  **rovide estimates of annualized co**  **st to the federal government. A lso, provide a**  **description of the method used to estimate cost, which should include quantification of hours, operation expenses (such as equipment, overhead, printing, and support staff), and**  **any other expen se that would not have been incurred without th**  **is collection of information. A**  **gencies also may aggregate cost estimates from items 12, 13, and 14 in a single table.** Estimation of the direc t cost to EPA ’s oversight of the CWSRFs covers review and anal ys is of the capitalizatio n grant/intended use plan, annual report, audit , and CWNIMS/C BR data. The estimates reflect EPA’s workload over the 3

- ye ar period covered b y this information collection. The estimate of EPA costs is based on average hourly expenditures, includi ng regional and h eadquarters personnel compensation and benefits. The estimated average hourly cost of $53. 60 for EPA Headquarters and Regional personnel is based on the General Schedule (GS) 12, Step 05 level. The hourl y estimates were calculated b y17

dividing the annual compensation of $69,686 from the 2015 GS pay schedule, by 2,080 hours in the f ederal work ye ar. The hourly rates were then multiplied by the standard government benefits multiplication factor of 1.6. In addition to these costs, EPA also expends $180,000 a year for contractor support for the CWNIMS and CBR databases. This support includes assisti ng the CWSRF s with data entry and EPA with data revi ew. The contractor also provides support by addressing any

tec hnical issues that prevent the CWSRFs from effectivel y entering data into these databases
.

**Average Annual # of Hours: 8,836**  **Average Annual Cost: $653,610**  **Total # of Hours (2016 to 2018): 26,508**  **Total Cost (2016 to 2018): $1,960,828.80**  **15. E xplain the reason for any program changes or adjustments**  **in burden estimates from the previous approved ICR**  **.** The respondent average annual burden decreased by 748,471 hours which represents a 93 % de crease. The total average annual cost burden decreased by $17,744,006 (or 74 % )
. The t able below presents a summary of the adjustments in burden estimates from the p reviously approved ICR. These adjustments are due to several changes:

 The burden previously associated with developing and reviewing CWSRF applications is not included in this renewal and reduces the estimated annual burden by 402,900 hours ( $11,684,100 )
. It was determined that this burden should not be included as part of the burden estimate. The reason is that the CWSRF s have complete flexibility in developing a pplications for CWSRF funding and are solely responsible for determining what information is collected from the borrowers. As a result, a borrower application will vary widely depending on the informational needs an d requirements of a CWSRF. EPA doe s not collect or review these applications. Nor does EPA provide gui dance or direction with respect to application content or submittal process. **Activity*** **Average Annual Labor Hours**  **Cost**

**Per Hou r**  **Average Annual**

**Labor Cost Average Annual** 

**O & M Cost Total Cost** 

**Per Year** Capitalization Grant Agreement/ Intended Use Plan 2,525 $53.60 $135,340 $0.00 $135,340 Annual Report 1,495 $53.60 $80,132 $0.00 $80,132
Annual Audit 940 $53.60 $50,384 $0.00 $50,384
CBR & NIMS Reporting 3,876 $53.60 $207,754 $180,000 $387,754 * The number of respondents is the 51 CWSRFs, with the exception of th e Annual Audit (47 respondents). There is no federal burden associated with the public awareness policy.18

 The estimated burden of 364,442 hours ( $10,902,487 ) previousl y associated with ARRA reporting has also been excluded. All ARRA funds have been fully loaned out and disbursed. N o additional reporting associated with ARRA will occur
.  As a result of the latest consultation, the estimated hour burden for the annual audit was revised upward to more fully capture the activities associated with this information collection activity
. These activities include making the relevant material and documentation available to the auditors while also addressing questions and providing clarification as needed
. The revised cost estimate also reflects the $2,928,100 in O&M costs that were not reflected in the previous version of the ICR.  The supporting statement has been updated to reflect the estimated reporting burden of 4,590 hours ( $252,863 ) associated with CBR and NIMS databases. This burden should have been included in the previous burden estimate.  It is estimated that the recently released public awareness policy will increase the reporting burden on CWSRF borrow er b y 786 hours ($29,098).  The burden estimates for the capitalization grant agreement and intended use plan were revised downward based on responses provided during the consultation pro cess. This consultation took into account the new WRRDA amendments.19

**Activity Reason** * **Previous Burden**  **New**

**Burden) Difference**  Capitalization Grant Agreement/ Intended Use Plan (Hours) A 20,400 10,200 (10,200) Capitalization Grant Agreement/ Intended Use Plan (Cost) A $652,800 $561,918 ($90,882) Annual Report (Hours) A 14,025 5,610 (8,415) Annual Report (Cost) A $448,800 $309,055 ($139,745) Annual Audit (Hours) A 4,080 36,190 32,110 Annual Audit (Cost)** A $130,560 $4,921,807 $4,791,247
CBR & NIMS Reporting (Hours) A 0 4,590 4,590 CBR & NIMS Reporting (Cost) A $0 $252,863 $252,863 Public Awareness Policy (Hours) PC 0 786 786 Public Awareness Policy (Cost) PC $0 $29,098 $29,098 CWSRF Applications (Hours) A 402,900 0 (402,900) CWSRF Applications (Cost) A $11,684,100 $0 ($11,684,100) ARRA Reporting (Hours) A 364,442 0 (364,442) ARRA Reporting (Costs) A $10,902,487 $0 ($10,902,487) **Total (Hours) 805,847**  **57,376** (748,471) **Total (Cost) $23,818,747**  **$6,074,741** ($17,744,006) *A = Adjustment; PC = Program Change ** Includes the average annual O & M cost of $2,928,100 associated with the hiring a firm to conduct the audit **16. F or collections of information whose results will be published, outline plans for**  **tabulation, and publication. A ddress any complex analytical**  **techniques that will be used. P**  **rovide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.**  Annual state and national reports reflecting the latest CWNIMS data are posted in the earl y part of every calendar ye ar on EPA’s website
. Reports showing the loans reported in the CBR database are also posted online on a quarterly basis
. These reports are made publicly available at http://www.epa.gov/cwsrf/clean

- water - state - revolving

- fund

- cwsrf

- results
.20

**17. I f seeking approval to not displ**  **ay the expiration date for OMB approval of the**  **information collection, explain the reasons that display would be inappropriate**  **.** The agency

plans to display

the expiration date for OMB approval of the information collection on all instruments. **18. E xplain each exception to the certification statement identifi**  **ed in item 19, "Certification for Paperwork Reduction Act S**  **ubmissions," in ROCIS**  **.** The agency

is able to certify

compliance with all provisions under Item 19 of OMB Form 83

- I
. 

### B. **Statistical Methods (used for collection of information employing statistical methods)**  Statistical methods are not used with this collection 

### .