June 3, 2015

Page 1 of 13



## Suppor ting Statement f

or a Request for OMB Review under the Paperwork Reduction Act 1. Identification of the Information Collection 1(a). Title of the Information Collection . Title: Reporting in the FIFRA Cooperative Agreement Work Plan and Report Template EPA ICR No.: 25 11 .01 OMB Control No: 2070 -NEW Docket ID No.: EPA - HQ - OPP - 2014 - 0479 

### 1(b). Short Characterization/Abstract . This is a request for a new Information Collection Request (ICR). This ICR describes the burden activities for the electronic collection of information for the pre - award burden activity for creating a work plan and the post - award and after - the - grant award activities related to reporting accompl ishments to implement EPA’s Federal Insecticide Fungicide and Rodenticide Act State and Tribal Assistance Grant (STAG) program (7 U . S . C . 136u) see Attachment A. This ICR augments the ICR entitled “EPA’s General Regulation for Assistance Programs ICR ” (OMB Control No. 2030 - 0020; EPA IC R No. 0938.18) which accounts for the current PRA burden for the minimum management requirements for all recipients of EPA grants or cooperative agreements (assistance agreements). This new ICR provides OMB the burden assessment for collecting the same information in the current IC R (OMB Control N o. 2030 - 0020 ; EPA ICR No. 0938.18 ), and provides a burden breakout for FIFRA program specific activities while using a standardized electronic format for only the STAG program reporting . 1 This ICR is also requesting approval for the FIFRA Grant Reporting Template that was developed in conjunction with the States and EPA Regions. 

## 2. Need For and Use of the Collection 2(a). Need/Authority for the Collection . This ICR documents the PRA burden for STAG grantees to use a standardized electronic template to comply with work plan and reporting requirements which grantees complete and submit to the Agency via email. Under the STAG program (7 U . S . C . 136u) and in EPA regulations at 40 CFR Parts 30 and 31 , grantees are required to provide reports on grant activities to the Office of Pesticide Programs. These regulations implement OMB Circulars A - 21, A - 87, A - 102, A - 110, A - 122, and A - 133. Specificall y, the PRA burden related activities set forth for the pre - award, post - award and after - the - grant requirements associated with submitting a work plan , biannual reporting and reporting enforcement violations of program specific activities (e.g., endangered spe cies, worker protection and container containment) and general record keeping and grant closing requirements. Currently , grantees provide this information to EPA via paper cop y . The burden is accounted for in the EPA’s General Regulati on for Assistance Programs ICR ( OMB Control No. 2030 - 0020; EPA IC R No. 0938.18) see Attachment B.

1 Covering the Catalog of Federal D omestic A ssistance programs in the Office of Chemical Safety and Pollution Prevention, 66.605 - Performance Partnership Grants; and Office of Enforce ment and Compliance Assurance, 66.700 - Consolidated Pesticide Enfo rcement Cooperative Agreements.June 3, 2015

Page 2 of 13

This information is utilized by EPA project officers, grant specialists, and finance officials to manage/oversee recipient programmatic and financial performance under all EPA assistance agreements. Without the collection information, rational, fair grant awards would be extremely difficult to make, and financial and technical managerial information would not be available to judge the status of grant efforts. 

### 2(b). Practical Utility/Users of the Data . The pre - award information (work plan) is used to negotiate with and ensure that the applicants are proposing work activities that align with both national and regional guidance documents and priorities. The post - award information ( interim reporting on work activities and updates to work plan) is used to meet the statutory

and regulatory

requirements concerning monitoring recipient performance. The afterthe - grant information is used to meet reporting and recordkeeping requirements and to close out awards. The information is necessary to ensure accountability of EPA funds and to deter wa ste, fraud, and abuse. 

## 3. Non Duplication, Consultations, and Other Collection Criteria 3(a). Non Duplication. There is no other source for this information . Pursuant to the individual Cooperative A greements, grantees must fulfill the work plan and reporting requirements by utilizing the template . Thus, grantees do not need to submit reports via paper cop y . 

### 3 (b). Public Notice Required Prior to ICR Submission to OMB. Pursuant to 5 CFR 1320.8(d) EPA publish ed a Federal Register notice (80 FR 40, January 2, 2015; Correction notice 80 FR 1029, January 8, 2015) providing a 60 day public comment on this proposed In formation Collection activity . EPA did not receive any public comment on this action. 

### 3(c). Consultations . The FIFRA Cooperative Agreement Work Plan and Report Template ( a.k.a. “template”) is the result of a collaborative effort that began in the fall of 2011 at th e request of the State FIFRA Issues, Research and Evaluation Group (SFIREG) to EPA to help reduce the administrative burden of the cooperative agreement process, and to increase consistency in work plans and reports throughout the country . The t emplate wi ll also facilitate national compilation of data. W orkgroup participants included representatives from Office of Pesticide Programs , the Office of Compliance, 8 EPA regional offices, and one SFIREG representative. In the spring of 2012 s everal FIFRA state lead agencies volunteered to test the t emplate either by testing it in - house or by

using it as a work plan or year - end report. Periodic meetings were held via adobe connect to receive feedback and suggestions for improvement until the fall of 2013 - see Attachment C for copies of the survey data and consultation questions. The following states participated in the pilot phase:

 Arizona Department of Agriculture

– Jack Peterson, Associate Director, 602 - 542 - 3575  California Department of Pesticide Regulation - Scott Benson, 916 322 - 7269  Office of the Indiana State Chemist

– Dave Scott, Pesticide Administrator, 765 - 494 - 1593  New Jersey

Department of Environmental Protection

– Roy Meyer, Bureau Chief for Pesticide Compliance, 609 - 984 - 6982  New York State Department of Environmental Conservation

– Anthony L amanno, Section Chief, 518 - 402 - 8727June 3, 2015

Page 3 of 13

 New Mexico Department of Agriculture

– Bonnie Rabe, Director, Division of Agricultural and Environmental Services, 575 - 646 - 2134  North Dakota Department of Agriculture

– Jim Gray , Division Director, 701 - 328 - 1505  Virginia Department of Agriculture and Consumer Services

– Li za Fleeson, Program Manager, 804 - 371 - 6559  Wisconsin Department of Agriculture, Trade and Consumer Protection

– Lori Bowman, Director, Bureau of Agrichemical Manag ement, 608 - 224 - 4550 EPA received positive feedback from States for developing the template as a reporting mechanism. For most states the template provided increase efficiency for completing the work plan and reporting requirements and for some grantees a way to reduce the paperwork burden. This ICR is requesting approval for the EPA template that was developed in conjunction with the States and EPA Regions. 

### 3(d). Effects of Less Frequent Collection . No less frequent collection is possible in accordance with OMB requirements. 

### 3(e). General Guidelines . Recipients keep their records for three ( 3 ) ye ars after the date they submit the final SF 269, “Financial Status Report” unless otherwise directed b y EPA. Therefore the recordkeeping activities briefly described herein are in compliance with OMB’s guideline that agencies not require that records be retained for more than 3 years (5 CFR 1320.5(d)(2)(iv)). 3(e ) ( 1). Forms . Respondent s ( grantees ) fill out the “FIFRA Cooperative Agreement Work Plan and Report,” a template that is available via the internet and available to the States, territories and Tribes who have FIFRA cooperative agreements with EPA. 

### 3(f). Confidentiality. No pledge of confidentiality is given for applicant responses. 

### 3(g). Sensitive Questions . No sensitive information is collected under this ICR. 

## 4. The Respondents and the Information Requested 4(a). Respondents/SIC Codes. The primary

recipients of EPA grants are State and local governments and Indian tribes. The information requested is used to make awards, pay recipients, and collect information on how Federal funds are being spent. The corresponding North American Industry Classification System (NAICS) Co des for respondents include: **9241** - Administration of Environmental Quality Programs; **9211 50**  American Indians and Alaska Native Tribal Governments. 

### 4(b )( i). Information Requested

- Data Items, Including Record Keeping Requirements . The following describes the Respondent burden activities when using the t emplate to submit the status of the work plan and other reporting activities . Under 40 CFR part 35.107 grantees are required to submit a work plan. The FIFRA Work Plan and Report Template contains a work plan tab for the grantee to insert the exact activities the grantee will be completing based upon the priorities as specified in the National FIFRA Cooperative Agreement Guidance that is revised on a three (3) ye ar cycle, and asJune 3, 2015

Page 4 of 13

negotiated between the regions and grantees. These priorities fall broadl y under the categories of programmatic work, compliance and enforcement, and certifi cation and training of pesticide applicators. Under 40 CFR part 35.115 grantees are required to submit an end of year report. The Template contains specific reporting tabs for enforcement outputs, as well as space within the work plan tab to discuss accomp lishments as measured against work plan commitments. An ex ample of a completed template is shown in Attachment E . Since the cooperative agreement priorities among the s tates, tribes and territories are not the same and the national priorities change depending on the Agency budget , the template provides a flexible format to accommodate the variety of activities and program changes over time. Generally , the template is sectioned into a series of “tabs” or categories, including: **Tab Description**  Start Respondents provide responses to eight (8) basic questions: Name; Grantee; Agreement

Type; Number of Years the Agreement Covers; Project Period; Which Budget Period the Work plan/Report Corresponds to; Work plan/Report Status and Date. Narrative Respondents have the option to submit additional narratives that do not fit anywhere

else in the template, such as: authority to accept the cooperative agreement, legislative changes, QAPPs, neutral administrative inspection schemes, case review results, etc. Budget Grantees can either enter budget information directly into the spaces provided in the

template or embed a separate document (Word, PPT, PDF files) into this tab. Work plan The required activities areas included in the national guidance from which the grantee

must select priority work. Outcomes This chart includes all the program areas listed in the national FY15 - 17 cooperative

agreement guidance, and links them to potential outcomes from work done in each program area, and to the appropriate goal in EPA’s Strategic Plan. The grantee adjusts the outcomes as necessary to match work contained in the grantee’s Work Plan. Enforcement (5700 Group reports) This section of the template allows the grantee to complete three 5700 forms related to

projections and accomplishments related to inspections for enforcement, worker protection and container/containment concerns. Endangered Species Grantees complete projections and accomplishments sections related to inspections for

Endangered Species Inspections. Performance Measures Grantees collect information to help determine the effectiveness of the program; provide

data for management decisions and inform Congress and the public on the value of the program. 

### 4(b ) ( ii). Information Collection Baseline

- STAG Grant Program . The following selected sections of 40 CFR parts 30 and 31 (see Attachment D) are summarized here to highlight the burden hours that are covered b y the template activities and are considered the baseline burden for the STAG Grant Program. The se activities are already addressed in an ICR that accounts for the current PRA burden for the minimum m anagement requirements for all recipients of EPA grants or cooperative agreements (assistance agreements) and that is currentl y approved under OMB Control No. 2030 - 0020 (EPA ICR No. 0938.18). A summary of the baseline activities and related burdens is also presented in Table 1 . ( A ) . Application for Federal Assistance . The p re - award SF - 424 form , Application for Federal Assistance is us ed by States, local governments and federall y recognized Indian Tribal governments to apply for Federal financial assistance. SF - 424 requires basic information about the applicant, including a list of sources of proposed funding and a description for the proposed project. Supplemental information is provided in SF - 424A, BudgetJune 3, 2015

Page 5 of 13

Information

– Non Construction Programs, and SF - 424B, Assurances - Non Construction

– Programs , as applicable. The regulatory authority for using the SF - 424 is in 40 CFR part 31, Subpart B as supplemented by

40 CFR 35.104 which governs applications for the continuing environmental program grants and refers back to part 31 and incorporates the work plan regulation in 35.107. We estimate, collectively

these forms will impose 4 burden hours on the recipient and 5 hours on EPA. (b) . Official Record Files (40 CFR 30.50, 30.52, and 31.42) . Recipients must establish an official record file for each assistance award to track how the recipient uses the project funds, to account for property purchased under the award or used as part of any in - kind contributions, to maintain time records, and to document compliance with applica ble statutes and regulations (40 CFR Part 7 ) . We estimate that this requirement imposes 5 burden hours on the recipient and 1 burden hour on EPA. EPA project officers may use an evaluation instrument to perform reviews that pertain to programmatic components of assistance agreements. This ty pe of evaluation focuses on reviewing information that can help assess recipients’ activities and progress toward meeting the goals and objectives outlined in the assistance agreements. Programmatic reviews also ensure that the work to be performed under the agreement is on schedule, within budget, and consistent with the agreements’ relevant programmatic regulation and/or programmatic terms and conditions. For those who do complete these reviews, we estimate 1 burden hour on the recipient and 1 burden hour on EPA . The extent of the information gathered and reviewed through this type of instrument will vary according to the size and scope of each agreement. Complex agreements that involve large financial grants and entail extensive staffing and complex tasks will require a greater degree of review and evaluation. Regardless of the size or complexity

of the assistance agreement, the review instrument creates a framework that allows EPA to ensure the sound and effective management of assistance agreements. (c) . Interim and Final Progress Reports (40 CFR 30.51 and 31.40) . Recipients must submit interim and final progress reports, if required. EPA uses the interim progress reports to determine progress in relation to the approved schedule and project milestones during the project. The final progress report summarizes all of the work on the project and the extent to which the recipient has met the project’s objectives. We estimate that this requirement imposes a total of 6.5 burden hours on the recipient and 4 burden hours on EPA. ( d ) . Obtaining Approval for Certain Purchases (40 CFR 30.25 and 31.32 ) . Recipients must obtain the award officials approval before purchasing property or equipment with a unit acquisition cost of $5,000 or more. We estimate that this req uirement applies to about 20% of the non construction assistance recipients, and that this requirement imposes 3 burden hours on those recipients and 2 burden hours on EPA. ( e ) . Property Management Standards (40 CFR 30.30

- 37 and 31.32 ) . Recipients must co mply

with specific property management standards. The recipient is required to keep accurate records and carry out a phys ical inventory of property and reconcile the results, at least every two years. We estimate that this requirement imposes 3 burden hours on the recipient and 2 burden hours on EPA.June 3, 2015

Page 6 of 13

( f ) . Management of Federally

- owned Property (40 CFR 30.33 and 31.32 ) . Recipients must comply

with requirements for Federall y- owned property management . We estimate that this requirement affects only 1% of the projects, and imposes 2 burden hours on those recipients and 2 burden hours on EPA. ( g ) . Invention Reports (40 CFR 30.36 ) . If applicable, recipients must submit invention reports after completion of each project. ( h ) . Requests for deviations from EPA regulations (40 CFR 30.4 and 31.6 ) . If applicable, recipients must comply with procedural requirements for requesting a deviation from an EPA regulation. Only

5% of all recipients request deviations. We estimate that a deviation imposes 8 burden hours on the recipient and 8 burden hours on EPA. ( j ) . Assistance Agreement Dispute Appeals (40 CFR 30.63 and 40 CFR 31 Subpart F ) . If applicable, recipients must comply with procedural requirements for appeal ing an assistance agreement dispute between the recipient and the award official. We estimate that this requirement imposes 16 burden hours on the recipient and 16 burden hours on EPA. Less than 1% of EPA grant awards result in disputes. ( k ) . Procedural Requirements (40 CFR 30.40

- 48 and 31.36 ) . Recipients must comply

with procedural requirements . We estimate that this requirement imposes 0.5 burden hours on the recipient and 0.5 burden hours on EPA. ( l ) . Intergovernmental Review of Federal Programs (40 CFR 31.11 ) . Recipients must comply 40 CFR Part 29, which implements Executive Order 12372, “Intergovernmental Review of Federal Programs,” revokes OMB Circular A - 95, and establishes new procedures for intergovernmental reviews. OMB has determined that the new requirements are not subject to the reporting burden clearance process. ( m ) . Bonding and Reporting Requirements (40 CFR 31.36(h) ) . Recipients must comply bonding and reporting requirements. We estimate that this requirement imposes 0.5 burden hours on the recipient and 1 burden hour on EPA. 

### 4(b )( i i i) . Information Requested – Respondent Activities for FIFRA Cooperative Agreement s . Whereas the information collection activities approved under OMB Control No. 2030 - 0020 (EPA ICR No. 0938.18) generall y apply to grantees across multiple program areas, this new ICR addresses additional information collection activities that are undertaken b y FIFRA grantees. Grantees complete a work plan at the beginning of the project period as part of the cooperative agreement application package. Respondent/grantees fill out the “FIFRA Cooperative Agreement Work Plan and Report,” template that is available via the internet and available to all grantees, s tates, t erritories and tribes , participating in the STAG program . The template can be downloaded free of charge for use. The minimum requirement for use of the template is Excel © software which most s tates, territories and tribes currentl y use for business purposes. Biannually, s tates will fill out the template information and send an electronic cop y of the completed template to the Agency via email. In accordance with 5 CFR 1320.5(b )( 1), once OMB approves the template a valid OMB control number will be displayed on the template. To assist the s tates , tribes, and territories template guidance isJune 3, 2015

Page 7 of 13

provided to the grantees , see http://www2.epa.gov/compliance/fiscal - ye ar - 2015 - 2017 - fifra - cooperative agreement - guidance . As necessary , the Agency may also provide webinar training to assist states and tribes using the template . 

## 5. The Information Collected

– Agency Activities, Collection Methodology, and Information Management 5(a). Agency Activities . The data collected on the template is reviewed perio dically to identify

and eliminate duplication in reporting requirements . The Agency also conducts periodic on - site reviews to ensure recipient compliance with applicable requirements. Th e template is reviewed in accordance with the requirements of 40 CFR Parts 30 and 31. A summary of the Agency

burden hours and costs are summarized in Table 3. 

### 5(b). Collection Methodology and Management . The information will be collected using the standardized template. 

### 5(c). Small Entity Flexibility. EPA believes the reporting requirements discussed in this ICR do not place an unreasonable burden on small entities; the estimated burdens cannot be further reduced for small entities. EPA needs the information requested to make award decisions, properly m anage assistance agreements, maintain records, and monitor performance. This requested information may, in some cases, be dependent on the ty pe of entity

(e.g., state agency , territory , or tribe.) but is not dependent on an entity ’s relative size. EPA take s active steps to minimize the burden on small entities in the form of guidance materials and electronic forms. In most cases, the requirements do not impose a large burden on small entities because the information required is simple and straightforward. 

### 5(d). Collection Schedule. Specific schedules for the collection of the t emplate are outlined in the Cooperative Agreement Guidance. Biannual reporting is the average reporting period. 

## 6. Estimating the Burden and Cost of the Collection 6(a). Estimati ng Respondent Burden . Since the burden activities associated with the work plan and reporting are already covered under the existing EPA’s General Regulation for Assistance Programs ICR ” (OMB Control No. 2030 - 0020; EPA ICR No. 0938.18) , a summary of the baseline burden hours associated with only the STAG grantees was developed for comparison and is used as the burden baseline in Table 1 . Currently , 81 states, tribes and territories are active FIFRA grantee s under the current STAG program. To establish the burden hour estimate and costs for FIFRA grantees ( s tates , tribes and territories , hereafter referenced as “ grantees ”) to use the template, EPA solicited burden data from 9 states (Indiana, Oregon, New York, Massachusetts, New Mexico, Pennsylvania, Virginia, Wisconsin, and Vermont) . FIFRA grantees responded to EPA’s consultation by providing the total estimated burden for completing all grant reporting using the reporting template . EPA identified the FIFRA program specific activities required to be repo rted under the grant. Table 4 displays the annual incremental burden and cost of the FIFRA program specific grant reporting activities as compared to the burden for the general grant reporting requirements in the existing ICR.June 3, 2015

Page 8 of 13

There are no capital costs related to completing EPA grant applications and the related reporting requirements and there are no operating and maintenance costs associated with these activities. 

### 6(b). Estimating Labor Costs . OPP is using labor cost estimates generated by Agency economists with respect to wages, benefits and overhead for all labor categories for affected industries, state government, and EPA employees. This approach uses a transparent and consistent methodology employing publicly- available data to provi de more accurate estimates and allow eas y replication of the calculations. Methodolog

y. The methodology

uses publicly

available wage data for each sector and labor ty pe for an Unloaded wage rate (hourly wage rate) and calculates the Loaded wage rate (unlo aded wage rate + benefits) and the Fully loaded wage rate (loaded wage rate + overhead). Fully loaded wage rates are used to calculate the Agency ’s staffing costs. Costs use 2012 base data. Unloaded Wage Rate. Wages are estimated for l abor ty pes (management, technical, and clerical) within applicable sectors. The Agency uses average wage data for the relevant sectors available in the National Industry- Specific Occupational Employ ment and Wage Estimates from the Bureau of Labor Statistics (BLS). ( See http://www.bls.gov/oes/current/oes_nat.htm). Sectors. The specific North American Industry Classification System (NAICS) code and website for each sector is included in that sector’s wage rate table . Within each sector, the wage data are provided by Standard Occupational Classification (SOC). The SOC system is used by Federal statistical agencies to classify

workers into occupational categories for the purpose of collecting, calculating, or disseminating data (see http://www.bls.gov/oes/current/oes_stru.htm). Loaded W

age Rate. Unless stated otherwise, all benefits represent 43% of unloaded wage rates, based on benefits for all civilian non - farm workers, from http://www.bls.gov/news.release/ecec.t01.htm . However, if o ther sectors are listed for which 43% is not applicable, the applicable percentage will be stated. Fully Loaded W

age Rate. The fully

loaded wages include benefits and overhead costs. The loaded wage rate is multiplied by

50% (EPA guidelines 20 - 70%) to get overhead costs. Using these data and methodology , the full y loaded wage rates used to calculate the respondent costs for this renewal are $ 43.67 , $ 31.80 , and $ 18.37 per hour for managerial, technical, and clerical labor hour costs, respectivel y.June 3, 2015

9

**Table 1 -**  **FI FRA baseline biannual workplan**  **plan ,**  **reporting and record keeping burdens hours f**  **r om**  **OMB Control No.**  **2030 -**  **0020 Manager**  **Technical Average**  **Per Response**  **Number of**

**Respondents Responses /** 

**Respondent Annual Totals**  Hrs. $43.67/hr. Hrs. $31.80/hr. Hrs Costs ($) Burden (hrs) Costs

($) *P re - award SF - 424 2.14 $93.45 1.86 $59.15 4.0 $152.60 81 .333 108 $4,116.07 40 CFR Sections 30.50, 52, and 31.42 2.67 $116.59 2.33 $74.09 5.0 $190.68 81 2 810 $30,890.16 40 CFR Se ctions 30.51 and 31.40 3.47 $151.53 3.03 $96.35 6.5 $247.88 81 2 1053 $40,156.56 40 CFR Section 30.25 (low frequency) N/A N/A 40 CFR Sections 30.25 and 31.32 1.6 $69.87 1.4 $44.52 3.0 $114.39 81 2 486 $18,531.18 30.30 - 37 and 31.32 1.6 $69.87 1.4 $44.52 3.0 $114.39 81 2 486 $18,531.18 40 CFR Sections 30.33 and 31.32 (low frequency %1 of all Agency projects) 1.07 $46.72 .93 $29.57 2.0 $76.29 81 2 324 $12,358.98 40 CFR Section 30.36 (invention reports) NA NA 40 CFR Sections 30.4 and 31.6 4.28 $186.90 3.72 $118.29 8.0 $305.19 81 2 1296 $49,440.78 40 CFR Sections 30.63 and 31 subpart F (low frequency less than %1 of all Agency projects) 8.56 $373.81 7.44 $236.59 16.0 $610.40 81 2 2592 $98,884.80 40 CFR Section 30.40 - 48 and 31.36 .267 $11.65 .233 $7.40 0.5 $19.05 81 2 81 $3,086.10 40 CFR Section 31.11 (Ex. order 12372) NA NA 40 CFR Section 31.36(h) .267 $11.65 .233 $7.40 0.5 $19.05 81 2 81 $3,086.10 **Total 25.92**  **$1,132.04 22.58**  **$717.88 48.5**  **$1,849.92 --**  **-- 7317**  **$279,081.91** Numbers may not add due to rounding. Wage rates reflect the average hourly wage rate estimate provide by the Bureau of Labo r Statistics for the North American Industry Classification System (NAICS) code for all levels of government (NAIC code 999000). 20 12 base data is used. Under the current ICR, OMB Control No. 2030 - 0020 (EPA ICR No. 0938.18) , the average for one reporting event is 48 .5 hours, most grantees report biannually o r an estimated 89 hours annually. The current ICR does not provide a labor category break- out, so for this comparison we redistributed the total burden between the managerial (approximately 53% of the burden) and technical wage rate categories. The clerical category was not used because the consultation with the grantees indicates this labor category is rarely used. *P re - award SF - 424 form burden hours and cost are amortized over the three year cycle because the pre - award application including the development of the work plan and assurances is only conducted o nce during the lifecycle of the grant.June 3, 2015

10

**Tab le**  **2 Total**  **Estimated Annual**  **Incremental FI**  **FRA Grantee Burden**  **Manager Technical**  **Avg. Burden Per Response**  **# of**

**Respondents Annual**  **Responses per**

**Respondent Annual Totals**  Hrs. $43.67/hr. Hrs. $31.80/hr. Burden (hrs) Costs

($) Burden (hrs) Costs ($) 5700 Main 4.5 $198 9.8 $312 14.3 $510 81 2 2,316.6 $41,318 5700 WPS 1.6 $70 2.8 $88 4.4 $157 81 2 712.8 $12,723 5700 Container Containment (CC) 1.2 $52 6.2 $199 7.4 $251 81 2 1,198.8 $20,310 Endangered Species 9.6 $417 3.3 $105 12.9 $522 81 2 2,089.8 $42,278 **Total** 16.9 $ 737 22.1 $704 39.0 $ 1440 81 2 6 , 318.0 $ 233,280 Numbers may not add due to rounding . Wage rates reflect the average hourly wage rate estimate provide by the Bureau of Labor Statistics for the North American Ind ustry Classification System (NAICS) code for all levels of government (NAIC code 999000). Similar to the current ICR, 2012 base data is used. The labor wage category is only distributed between the managerial (approximately 53% of the burden) and technical wage rate categories. The clerical category was not used because consultation with the grantees indicates this labor category is rarely used for these burden activities. The average incremental burden for one reporting event is 39 hours, most grantees repo rt biannually or an estimated 78 hours per grantee annually. 

### 6(b). Estimating Agency Burden and Costs . To calculate the Agency

burden, in 2014 EPA surveyed its Regional offices. The estimated average annual Agency burden hours per region is 498.3 to assist and process all the annual paperwork for STAG grantees (not just the incremental burden activities) . 10 regions implement the program and oversee one or more STAG grants within the region. Numbers may not add due to rounding. Wage rates reflect the average hourly wage rate estimate provide by the Bureau of Labor Statistics for the North American Industry Classification S ys tem (NAICS) code for the federal government (NAIC code 999100). Similar to the current IC R , 2012 base data is used. **Table 3**  **- Total Estimated**  **Annual Agency Burden and Cost**  **Manager Technical**  **Clerical Average**  **Totals x 10**  **regions** Hrs. 55.66/hr Hrs. $36.11/hr Hrs. $20.59/hr Burden (hrs) Costs

($) Burden

(hrs) Costs ($) Consult with Grantee and respond to questions about template completion 2.0 $111 102.0 $3,683 - $0 104.0 $3,795 936 $3 4 , 155June 3, 2015

11

Developing mid - year and year end reports (columns P - R) 27.0 $1,503 212.0 $ 7 , 655 2.5 $51 241.5 $ 9,158 2 173.5 $ 82,422 Submit template to regional management and HQ 0.7 $39 20.1 $ 725 - $0 20.8 $ 764 187.2 $ 6 876 Working with the regional grants office (Region 1) - $0 12.0 $ 433 - $0 12.0 $ 433 10 8 .0 $ 3897 Region 6 * 9.5 $529 110.5 $3, 990 $0 120.0 $4, 519 120.0 $ 4519 Totals (due to rounding, totals may not add to 100%) 39.2 $2,182 456.6 $ 16,487 2.5 $51 **498.3 $**  **18,670 3**  **, 524**  **. 7**  **$ 1**  **31 ,**  **869** Region 6 did not provide a burden breakdow n of activities so only a summary of the annual activities estimates are provided. For the nine remaining regions the average burden and cost was multiplied by a factor of nine.June 3, 2015

12



### 6(d). Estimating the Respondent Universe and Total Burden and Costs . Table 1 , p resents a summary of the current reporting and recordkeeping burden from the current IC R entitled “EPA’s General Regulation for Assistance Programs ICR ” (OMB Control No. 2030 - 0020; EPA ICR No. 0938.18) , which was used to determine a baseline for the adjustment in the burden hours. For the FIFRA program specific ICR burden hour projections, the estimates and cost projected assume that all the grantees , 8 1 states, territories and tribes , will use the template for their work plan and reporting requirements. The burden also assumes that all grantees would report to EPA biannually , and will conduct all the activities. This is a conservative estimate, since not all 81 FIFRA grantees will participate in all of the FIFRA grant program activities. 

### 6(e). Bottom Line Incremental Burden Hour and Cost Table . T able 4 represents the annual incremental burden and cost of the required grant reporting for the FIFRA program specific activities . This increment is an amount over the baseline burden and cost in the current ICR , OMB Control No. 2030 - 0020 (EPA ICR No. 0938.18 ) . **Table 4 Annual**  **Burden Hours**  **Cost s**  Respondents /Grantees ( 81 States, Tribes, territories - biannual reporting ; incremental cost over the baseline ICR ) 6318 $233,280 Agency processing burden for STAG grants (not just the incremental burden) 4983 $131, 869 

### 6(f ) Reasons for Change in Burden . This is a new ICR. Relative to the baseline annual burden for reporting general management grant reporting requirements approved under OMB Control No. 2030 - 0020 (EPA ICR No. 0938.18 ) , the overall annual burden increase for FIFRA program specific activities is 6 , 318 hours, or 78 hours per respondent annually . This change documents the incremental burden for reporting FIFRA grant program specific activities ( e.g. , 5 , 700 environmental enforcement and endangered species ac tivities) and provides conservative projection for program growth . This is a program adjustment . “Burden” is defined in 5 CFR 1320.3(b). The A gency may not conduct or sponsor, and a person is not required to respond to, a collection of information unles s it displays a currently valid OMB control number. OMB control numbers for certain EPA regulations in title 40, after initial display in the final rule, are listed in 40 CFR part 9 and appear on the information collection instrument as applicable, i.e., form or instructions, and in the Federal Register. The Agency

has established a public docket for this ICR under Docket ID No. EPA - HQ - OPP - 2014 - 0479, which is available for online viewing at www.regulations.gov , or in person viewing at the OPP Docket in the EPA Docket Center, William Jefferson Clinton (WJC) West, Rm. 3334, 1200 Pennsylvania Ave, NW, Washington, DC 20460 - 0001. This docket facility is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday , excluding legal holidays. The docket telephone number is (703) 305 - 5805. You may submit comments regarding the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques. Comments may be submitted to EPA electronically through http://www.regulations.gov or by mail to: EPA Docket Center, Environmental Protection Agency , Mail Code 28221T, 1200 Pennsylvania Av e., NW, Washington, DC 20460. You can also send comments toJune 3, 2015

13

OMB, addressed to “OMB Desk Officer for EPA” and referencing OMB Control No. **2070 -** **NEW** (EPA ICR No. 2511.01) via email to oira_submission@omb.eop.gov . Include docket ID No. EPA - HQ - OPP 2014 - 0479 and OMB control number **2070 -** **NEW** (EPA ICR No. 2511.01) in any correspondence, but do not submit and any

grant related information (e.g., fo rms, reports, etc.) to these addresses. 

## 7. A tt achment s to the Supporting Statement The Attachments listed below can be found in the docket for this ICR, identified as Docket ID Number, **EPA -**  **HQ -**  **OPP -**  **2014 -**  **0479** , which is accessible electronicall y through **http:// www.regulations.gov**  . Direct links are provided for those documents that are also available online elsewhere. **Attachment A** : EPA’s Federal Insecticide Fungicide and Rodenticide Act State and Tribal Assistance

Grant (STAG) program (7 U . S . C . 136 u) is attached in the docket for this action . **Attachment B:** “EPA’s General Regulation for Assistance Programs ICR ” (OMB Control No. 2030 -

0020; EPA IC R No. 0938.18) is attached as part of the docket for this action. **Attachment C**  **:** Consultation Questions and Responses from States is attached in the docket for this

action . **Attachment D**  **:** 40 CFR part 30 : Grant Agreements with Institutions of Higher Education, Hospitals and

other non -profits, and 40 CFR part 31 : Uniform Administrative Requirements for Grants and Cooperative agreements to States and Local Governments , available on line at: http://www.epa.gov/QUALITY/qa_cfrs.html . **Attachment E:** FIFRA Grant Work Plan and Report Template .