## ICR SUPPORTING STATEMENT OUTLINE
Part A 1. Identification of the Information Collection 1(a) Title of the Information Collection Confidential Financial Disclosure Form 3110.48 for Special Government Employ ees (SGE) Serving on Federal Advisory Committees at the Environmental Protection Agency 1(b) Short Characterization/Abstract The purpose of this information collection request is to assist the United States Environmental Pro tection Agency (EPA or the Agency) in selecting Federal advisory committee members who will be appointed as Special Government Employ ees (SGEs), mostly to EPA’s scientific and technical committees. To select SGE members as efficientl y and cost effectivel y as possible, the Agency

needs to evaluate potential conflicts of interest before a candidate is hired as an SGE and appointed as a member to a committee by EPA’s Administrator or Deput y Administrator. Agency officials developed the “Confidential Financial Disclosure Form for Special Government Emplo yees Serving on Federal Advisory Committees at the U.S. Environmental Protection Agency ,” also referred to as Form 3110

- 48, for a greater inclusion of information to discover an y potential conflicts of inte rest as recommended by the Government Accountability Office. 2. Need for and use of the Collection 2(a) Need/Authority for the Collection In June 2001, the Government Accountability Office (GAO) issued a report entitled “EPA’s Science Advisory Board Panels

– Improved Policies and Procedures Needed to Ensure Independence and Balance.” GAO recommended that EPA develop policies and procedures that better identify

and mitigate potential conflicts of interest and support the development of balanced panels. Recommendations included gathering the required conflict of interest information before a member is selected, specifically :

 Determine whether each panel will be reviewing a “particular matter” before selecting the panel in order to identify the financial conflict

- of

- interest requirements, if an y, to which the panelists will be subject.

 Obtain and evaluate relevant background information on peer review panel candidates before appointing panel members. The evaluation should include explicitly discussing w ith potential panelists : (1) items not adequatel y reported on the confidential financial disclosure form as w ell as items reported that could present conflicts of interest; (2) other information relevant to assessing impartiality , such as research conducte d and previous public statements or positions on the matter being reviewed, interest of the employer or clients in the matter, participation in legal proceedings, work for chemical companies or other affected industries, and prior or current research grant s that could be affected bythe matter; and (3) whether they have an y potential conflicts of interest related to the specific panel being established. Further, pertinent information obtained from discussions with panelists should be documented.” As part of that effort to respond to GAO’s recommendations, EPA developed a new and improved form for all of its scientific and technical committee ’ s S pecial G overnment E mployees. EPA’s Designated Federal Officers (DFOs) who manage EPA Federal Advisory Committees (FACs) experienced great difficulty trying to use the OGE Form 450 to identify actual or potential conflicts of interest of potential candidates for Federal Advisory Committee membership. The OGE Form 450 was confusing for the proposed members and they did not identify all financial interests of possible concern. In response to the GAO’s recommendations, EPA developed the Form 3110

- 48 to ensure that all relevant financial interests are identified and considered during the member selection process. It is important for EPA to have this information collection in place because we continuously need to appoint new SGE members as new advisory

committees are created or as members’ terms of appointment expire. The Form 3110

- 48 is completed by candidates for membership as SGEs on EPA federal advisory committees. The form is completed as part of the member selection process and before they are invited to serve as a member of a FAC at EPA. The Form 3110

- 48 is reviewed b y the Committee’s Designated Federal Officer, and the Program Office Deput y Ethics Official (DEO) to determine whether there is a financial conflict of interest between the proposed member’s public responsibilities and private interests/activities and whether there is any appearance of a lac k of impartiality . In some cases, the Alternate Designated Agency Ethics Official also reviews the form. As GAO recommended, it is important to collect this information before the potential member is appointed to the advisory committee, because if a conf lict of interest is identified after the person is appointed, the Agency may have to terminate the person’s membership and identify another person to serve on the committee. This is potentially embarrassing to both the Agency and the appointed member. It is also important to know upfront that a candidate could serve if appointed, as the appointment process is time consuming and, as required b y the Federal Advisory Committee Act, the Agency must ensure that the advisory committee is balanced in the points o f view represented. If a conflict is identified after a person is appointed to an advisory committee as an SGE, additional time is needed to select a replacement and the Agency loses valuable time and expertise in receiving the advice it needs. Also imp ortant is the fact that finding replacement members creates a burden of a dditional cost and staff hours. Using the Form 3110

- 48 benefits EPA by increasing efficiency

and saving time and money

. Currently nine of EPA’s 2 2 Federal Advisory Committees (FA Cs) appoint members as SGEs and have need to use the Form 3110

- 48. This number may increase as new committees are added, or decrease as committees are terminated. EPA anticipates averaging approximately 257 SGEs during the next 3 years. Again, it is imp erative that Form 3110

- 48 be approved to satisfy the GAO recommendations that EPA gather the required Conflict of Interest information before a member is selected to improve the EPA’s policies and procedures to better identify and mitigate potential confli cts of interest and support the development of balanced membership. EPA must have thisinformation collection in place so that the EPA doesn’t lose continuity in appointing new Special Government (SGE) members, as new advisory committees are created, or a s members’ terms of appointment expire. I f a conflict is identified after an SGE is appointed to an advisory committee, the SGE and the EPA face embarrassment and additional time is needed to select a replacement while EPA loses valuable time and expertis e. Using the Form 3110

- 48 before member appointments are made benefits EPA by increasing efficiency , thus saving time and money
. Confidentiality of Information provided on the Form 3110
- 48 : Title Iof the Ethics in Government Act of 1978 (the Act), 5 USC App., Executive Order 12674, and 5 CFR Part 2634, Subpart I , of the Office of Government Ethics regulations require the reporting of financial information that is relevant to the administration and application of the criminal financial conflict of interest laws, administrative standards of conduct, and agency

specific statutory

and program

- related restrictions. The primary use of the information collected on this form is to allow EPA to conduct the conflicts reviews in accordance with applicable Fede ral laws and regulations. The information reported on the Form 3110

- 48 is “confidential” and required to be withheld from the public pursuant to Section 107(a) of the Act. Agency personnel shall not publicly release the reports on the information contain ed therein except that disclosures may

be pursuant to (1) a Federal, State or local law enforcement agency if the disclosing agency

becomes aware of a violation or potential violation of law or regulation; (2) a court or part y in a court or Federal adminis trative proceeding if the Government is a part y or in order to compl y with a judge

- issued subpoena; (3) a source when necessary to obtain information relevant to a conflict of interest investigation or decision; (4) the National Archives and Records Admini stration or the General Services Administration in records management inspections; (5) the Office of Management and Budget during legislative coordination on private relief legislation; and (6) in response to a request for discovery or for the appearance o f a witness in a judicial or administrative proceeding, if the information is relevant to the subject matter. The confidential report will not be disclosed to any requesting person unless authorized by law. EPA requires SGEs who are new to a federal advis ory committee to complete parts 2

- 9 of Form 3110

- 48 before participating in a Committee activity . Subsequentl y, SGEs must file reports annuall y to report on the previous calendar y ear. For these annual reports, the SGEs must complete parts 2

- 8. In addit ion, they must complete Part 1 (“Statement regarding an y change since annual submission of the form”) and Part 9 (“Identification of an y other information related to conflicts of interest or appearance of a lack of impartiality”) before participating in an y new advisory activity . Filers must provide sufficient information about outside interests and activities so that EPA DFOs and ethics officials can make an informed judgment regarding any conflict of interest or appearance of lack of impartiality . EPA st aff may contact proposed SGEs to obtain additional information if necessary to determine whether there is a conflict between an SGE’s public responsibilities and his /her or his/her spouse's private interests and activities. EPA seeks to collect the infor mation in “Attachment A,” which is the Confidential Financial Disclosure for Special Government Employ ees Serving on Federal Advisory Committees at the U.S. Environmental Protection Agency (Form 3110

- 48). This information collection request will be needed on a continual basis. Again, it is imperative that Form 3110

- 48 be approved to satisfy the GAO recommendations that EPA gather the required Conflict of Interest information before a memberis selected to improve the EPA’s policies and procedures to better identify and mitigate potential conflicts of interest and support the development of balanced membership. EPA must have this information collection in place so that the EPA doesn’t lose continuity in appointing new Special Government (SGE) members, as n ew advisory committees are created, or as members’ terms of appointment expire. I f a conflict is identified after an SGE is appointed to an advisory committee, the SGE and the EPA face embarrassment and additional time is needed to select a replacement wh ile EPA loses valuable time and expertise. Using the Form 3110

- 48 before member appointments benefits EPA by increasing efficiency , thus saving time and money

. 2(b) Practical Utility/Users of the Data In formation gathered from Form 3110

- 48 will conti nuously help EPA to evaluate relevant background information on Special Government Employ ee candidates before a ppointing members. By

using the form, EPA DFOs are allowed to expedite the process of selecting viable candidates for membership on EPA’s federa l advisory committees. 3. Non duplication, Consultations, and Other Collection Criteria 3(a) Non duplication Almost all information request from respondents under this I CR is personal in nature and, in most cases, is not available from other sources. 3(b) Public Notice Required Prior to ICR submission to OMB On November 2 4 , 20 10 (7 5 FR 71687) EPA sought comments on this I CR pursuant to 5 CFR 1320.8(d). EPA received no comments

. A second comment will be opened for 30

- day s once this I CR is submitted to OMB. 3(c) Consultations In accordance with OMB’s Terms of Clearance on the previous approval of this I CR, EPA has reviewed the actual number of SGE confidential disclosure forms received over the last three ye ars and consulted with various agency st aff to determine trends in expected committee membership over the next three years. While committee membership can vary year to year, EPA anticipates that the number of SGEs completing the form during the period of this I CR will not vary significantl y from the previous three

- ye ar average, which was 257 per year. 3(d) Effects of Less Frequent Collection The form is required to be updated once a ye ar. The form allows Government officials to determine whether there is a statutory conflict between Special Go vernment Employees public responsibilities and private interests and activities, or the appearance of a lack of impartiality , as defined b y federal regulation. 18 U.S.C. 208: “An employee is prohibited from participating personall y and substantially in an official capacit y in an y particular matter in which, to his knowledge, he or any person whose interests are imputed to him under this statute has a financial interest, if the particular matter will have a direct and predictable effect on that interest.” 5 C.F.R. 2635.502: Appearance of lack of impartiality : “Where an employee knows that a particular matter involving specific parties is likely to have a direct and predictable effect on thefinancial interest of a member of his household, or knows that a p erson with whom he has a

covered relationship is or represents a party to such matter, and where the person determines that the circumstances would cause a reasonable person with knowledge of the relevant facts to question his impartiality in the matter, the employee should not participate in the matter unless he has informed the agency designee of the appearance of a problem and received authorization from the agency designee". 3(e) General Guidelines This I CR complies with OMB’s general guidelines for the collection of information. 3(f) Confidentiality Confidentiality

of Information provided on the Form 3110

- 48 : Title Iof the Ethics in Government Act of 1978 (the Act), 5 USC App., Executive Order 12674, and 5 CFR Part 2634, Subpart I , of the Office of Government Ethics regulations require the reporting of financial information that is relevant to the administration and application of the criminal financial conflict of interest laws, administrative standards of conduct, and agency

specific statutory

and program

- related restrictions. The primary use of the information collected on this form is to allow EPA to conduct the conflicts reviews in accordance with applicable Federal laws and regulations. The information reported on the Form 3110

- 48 is “confi dential” and required to be withheld from the public pursuant to Section 107(a) of the Act. Agency personnel shall not publicly release the reports on the information contained therein except that disclosures may

be pursuant to (1) a Federal, State or loc al law enforcement agency if the disclosing agency

becomes aware of a violation or potential violation of law or regulation; (2) a court or part y in a court or Federal administrative proceeding if the Government is a party or in order to compl y with a judg e - issued subpoena; (3) a source when necessary to obtain information relevant to a conflict of interest investigation or decision; (4) the National Archives and Records Administration or the General Services Administration in records management inspections ; (5) the Office of Management and Budget during legislative coordination on private relief legislation; and (6) in response to a request for discovery or for the appearance of a witness in a judicial or administrative proceeding, if the information is rel evant to the subject matter. The confidential report will not be disclosed to an y requesting person unless authorized by law. EPA requires SGEs who are new to a federal advisory committee to complete parts 2

- 9 of Form 3110

- 48 before participating in a Committee activity . Subsequentl y, SGEs must file reports annuall y to report on the previous calendar y ear. For these annual reports, the SGEs must complete parts 2

- 8. In addition, they must complete Part 1 (“Statement regarding an y change since annual subm ission of the form”) and Part 9 (“Identification of an y other information related to conflicts of interest or appearance of a lack of impartiality”) before participating in an y new advisory activity . Filers must provide sufficient information about outsid e interests and activities so that EPA DFOs and ethics officials can make an informed judgment regarding any conflict of interest or appearance of lack of impartiality . EPA staff may contact proposed SGEs to obtain additional information if necessary to de termine whether there is a conflict between an SGE’s public responsibilities and his /her or his/her spouse's private interests and activities. EPA seeks to collect the information in “Attachment A,” which is the Confidential Financial Disclosure for Spec ial Government Employees Serving on Federal AdvisoryCommittees at the U.S. Environmental Protection Agency (Form 3110

- 48). This information collection request will be needed on a continual basis. Again, it is imperative that Form 3110

- 48 be approved to satisfy the GAO recommendations that EPA gather the required Conflict of Interest information before a member is selected to improve the EPA’s policies and procedures to better identify and mitigate potential conflicts of interest and support the developme nt of balanced membership. EPA must have this information collection in place so that the EPA doesn’t lose continuity in appointing new Special Government (SGE) members, as new advisory committees are created, or as members’ terms of appointment expire. If a conflict is identified after an SGE is appointed to an advisory committee, the SGE and the EPA face embarrassment and additional time is needed to select a replacement while EPA loses valuable time and expertise. Using the Form3110

- 48 before member a ppointments benefits EPA by increasing efficiency , thus saving time and money

. 3(g) Sensitive Questions Title Iof the Ethics in Government Act of 1978 (the Act), 5 USC App., Executive Order 12674, and 5 CFR Part 2634, Subpart I , of the Office of Gover nment Ethics regulations require the reporting of financial information that is relevant to the administration and application of the criminal financial conflict of interest laws, administrative standards of conduct, and agency

specific statutory

and progr am - related restrictions. The primary use of the information collected on this form is to allow EPA to conduct the conflicts reviews in accordance with applicable Federal laws and regulations. The information reported on the Form 3110

- 48 is “confidential” and required to be withheld from the public pursuant to Section 107(a) of the Act. Agency personnel shall not publicly release the reports on the information contained therein except that disclosures may

be pursuant to (1) a Federal, State or local law e nforcement agency if the disclosing agency

becomes aware of a violation or potential violation of law or regulation; (2) a court or part y in a court or Federal administrative proceeding if the Government is a party or in order to compl y with a judge

- issued subpoena; (3) a source when necessary to obtain information relevant to a conflict of interest investigation or decision; (4) the National Archives and Records Administration or the General Services Administration in records management inspections; (5) th e Office of Management and Budget during legislative coordination on private relief legislation; and (6) in response to a request for discovery or for the appearance of a witness in a judicial or administrative proceeding, if the information is relevant to the subject matter. The confidential report will not be disclosed to an y requesting person unless authorized by law.

4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes A Special Government Employee ( SGE ) is a person who is retai ned, designated, appointed, or emplo yed to perform, with or without compensation, for a period not to exceed 130 day s during any

period of 365 consecutive day s, temporary duties for the Federal Government either on a full

- time or intermittent basis. SGEs who provide advice to EPA are required to file the Form 3110

- 48 in lieu of the Office of Government Ethics F orm 450 to disclose confidential financial information . Form 3110

- 48 has already been reviewed and approved for use b y the Office of Government Eth ics. 4(b) Information Requested(i) Data items, including record keeping requirements

The Agency

will maintain records of the Form 3110

- 48. Designated Federal Officers from Offices sponsoring federal advisory committees will retain files of the completed form. The Agency does not anticipate any

record keeping activities on the part of the respondents under this ICR. (ii) Respondent Activities After being nominated by an outside party or themselves, respondents will be asked to Complete the Fo rm 3110

- 48 . Forms may be mailed or e

- mailed to candidates. Although candidates may

t ype their information on the form on

- line, they must then print the form and sign it. They

may return the form by

mail, but may

not return the form by

e - mail as an origi nal signature is required. Each form will involve reading instructions and completing the form. The form will require one hour to complete. Subsequent forms filed annually should take less time to complete as respondents gain familiarity with its info rmation requirements and may onl y need to make slight changes to information filed previously

.

5. The Information Collected

–Agency Activities, Collection Methodology,

and Information Management 5(a) Agency Activities To respond to this I CR, we estimat ed that Designated Federal Officers (DFOs) spend one hour reviewing each Form 3110

- 48 (sometimes calling and asking for further clarification or to address areas not filled out completely). EPA currently pay s an estimated labor cost of GS 14 Step 10, whic h in 2011 was $ 65.53 per hour, rounded to $ 66 per hour according to the Office of Personnel Management ( http://www.opm.gov/oca/11tables/html/dcb_h.asp )

. Due to the 2011 federal emplo yee pay fre eze for the next 2 ye ars and possibly beyond , w e anticipate no cost increase for the next 3 ye ars of this I CR (2011, 2012, 2013) the 3 year average estimated cost for the DFO is $ 16,962

. The EPA Deput y Ethics Official (DEO) labor cost is estimated to b e a GS

- 15 Step 7, which in EPA’s Emergency I CR (20 10 ) was $ 71.16 , rounded to $ 71 per hour at one hour per form. Due to the 2011 federal employee pay freeze for the next 2 years and possibly beyond, we anticipate no cost increase for the next 3 y ears of th is I CR (2011, 2012, 2013) the 3 y ear average estimated cost for the DEO is $ 18,247

. Both DFO and DEO total labor rates below include a factor of 1.6 (60%) for overhead costs. DFO Cost EPA estimates that approximately 257 advisory

committee members will serve on EPA’s Federal Advisory

Committees (FACs) as SGEs over the next 3 y ears. Multiplying the number of SGE members ( 257 ) by the 3 year average dollar amount paid to EPA’s DFOs ($ 6 6 ), and multiplying the subtotal cost of $ 16,962 by 1.6 (60% overhead) to allow for employee overhead costs, we estimate the subtotal to be $ 27,139

. Year 1 @ $6 6 for 1 hour x 257 = $ 16,962 x 1.6 = $ 27,139Year 2 @ $6 6 for 1 hour x 257 = $ 16,962 x 1.6 = $ 27,139

Y ear 3 @ $6 6 for 1 hour x 257 = $ 16,962 x 1.6 = $ 27,139 DEO Cost Multiplying the number of SGE members ( 257 ) by the dollar amount paid to EPA’s DEO with a 3 year average cost ($ 71 ), and multiplyi ng the cost of $ 18,247 by 1.6 (60% overhead) to allow for emplo ye e overhead costs, we estimate the subtotal to be $ 29,19 5

. Year 1 @ $ 71 for 1 hour x 257 = $ 18,247 x 1.6 = $ 29,195 Year 2 @ $71 for 1 hour x 257 = $ 18,247 x 1.6 = $ 29,195 Year 3 @ $71 for 1 hour x 257 = $ 18,247 x 1.6 = $ 29,195 Total DFO and DEO Cost Using 3 Year Average The total 3 year average dollar burd en estimate for this I CR (for both DFOs and DEO ) is approximately $ 56,334 each ye ar. DFO 3 ye ar average $ 27,139 + DEO 3 year average $ 29,195 = $ 56 , 334 Agency (EPA) activities associated with the collection of information include:
 Designated Federal Offic ers (DFOs) for each committee with Special Government Employees (SGEs), Deputy Ethics Official, Assistant Deputy Ethics Official
 First internal EPA review and approval of Form 3110

- 48 (completed 2003)
 Second internal EPA review and approval of Form 3110

- 48 (completed 2007)
 Taking actions to review the form, ascertain improvements, and revise periodically (approximately

3 year intervals or more if needed) Designated Federal Officers (DFOs) for each committee with Special Government Employees (SGEs) :  Provid ing copies of the mandatory form
 Answering an y respondent questions, follow

- up  Gathering respondents completed forms
 Reviewing and anal yz ing data
 Recordkeeping/storing completed form
 Forwarding form to EPA’s Ethics staff for review and anal yz ing Deputy E thics Official :  First review and approval of Form 3110

- 48 (completed 2003)
 Second review and approval of Form 3110

- 48 (completed 2007) 5(b) Collection Methodology and Management In collecting and anal yz ing the information associated with this I CR, EPA wi ll use a telephone s ys tem, personal computers, e - mail and websites from which the respondents can obtain blank forms, as well as using the mail and committee meetings for distribution of the form. Although candidates (respondents) may t yp e their informatio n on the form on

- line, they must then print the form and sign it. They may return the form by

mail, but may

not return the form by e - mail as an original signature is required.Although EPA uses internet websites and e

- mail to distribute the blank f orms, this form is not a survey

instrument, and no database is necessary to aggregate results

. This information is not available to the public. 5(c) Small Entity Flexibility Not applicable 5(d) Collection Schedule
 After being nominated by an outside par ty or themselves, respondents are asked to Complete the Form 3110

- 48 (No schedule

– dates are variable)

.

 After the initial completion of the Form 3110

- 48, respondents are asked to update the form annuall y (generally during January of each year). Respon dent ’ s confidential financial information is not made public.

6. Estimating t he Burden and Cost of the Collection 6(a) Estimating Respondent Burden and Costs (i) Estimating Burden and Labor Costs The respondents for this information collection request are candidates who are willing to serve on EPA Federal Advisory Committees as Special Government Employees (SGE). An SGE is a person who is retained, designated, appointed, or employed to perform, with or without compensation, for a period not to exce ed 130 day s during an y period of 365 consecutive day s, temporary

duties for the Federal Government either on a full

- time or intermittent basis. SGEs who are currently

members of EPA advisory committees must file the Form 3110

- 48 once a ye ar. In addition as new candidates who wish to be considered for such service must file before they are formall y appointed by the EPA Administrator or Deput y Administrator. To respond to this I CR, we estimated that each responding SGE candidate will take one hour to complete the Form 3110

- 48. We anticipate that EPA will pay an estimated labor cost of $ 6 6 , which including the standard overhead factor of 1.6 produces a loaded wage rate of $105.60. We estimate that approximately 257 members of Advisory Committees will have to respond to this request each y ear . Multipl yi ng the estimated number of SGE members ( 257 ) b y the dollar amounts to be paid to EPA’s SGEs each successive ye ar, and multiplying the subtotal costs of each successive year by 1.6 to allow for respondent ov erhead costs, we estimate that the total dollar burden estimate for this ICR to be approximately $ 27,139 for year 1, $ 27,139 for ye ar 2 and $ 27,139 for year 3. The grand total for all 3 years is estimated at $ 81,417 . The annual average cost to all respon dent’s cost over the three ye ars is $ 27,139 , as indicated in the following annual r espondent b urden and c ost table

.



## Annual Cost for SGE Respondents SGE Respondent Activities to Complete Form 3110
- 48 Burden Hours/ Respondent Burden for SGE

Candidate Number of

Respondents per Year Total

Cost per Year( $ 6 6 per labor hour multiplied by 1.6 for overhead equals $1 05.6 ) Total per Year 60 minutes (1 hour/100%) $1 05.6 257 $ 27,139
Read Instructions 10 minutes ( ~ 0.17%) (0.17 x $ 105.6 =)

$ 17. 60 ($ 1 7 .9 5 x 257 =) $ 4, 523.20 Fill Out Form 48 minutes ( ~ 0.80% (0.80 x $1 05.6 =)

$ 84.48 ($ 84.48 x 257 =) $ 21,711 .36 Prepare Envelope to Mail 2 minutes ( ~ 0.03%) (0.03 x $ 105.6 =)

$ 3. 5 ($ 3. 1 7 x 257 =) $ 904.64 TOTAL 60 minutes $1 05.60 257 $27,139.20 (ii) Estimating Capital and Operations and Maintenance Costs Not applicable. (iii) Capital/Start

- up Operating and Maintenance (O&M) Costs Not applicable. (iv) Annualizing Capital Costs Not Applicable

6( b ) Estimating Agency Burden and Cost



## Annual Agency Burden and Cost Agency Hours Number

of Hours Per Year Labor Cost

Per Year Overhead

Cost Per Year Subtotal

Labor & Overhead Cost Total

Cost/ Year (rounded) Form 3110

- 48 DFO Activities For 257 Respondents $ 6 6 per hour

Distribute form to SGE Nominees (respondents) and answer their questions 5 minutes

(0.0833) 257 $1,413.50 $848.10 $2,261.60

Review and anal yz e data of 45 minutes

(0.75) 257 $12,721.50 $7,632 .90 $20,354.40completed form,

and ask follow

up questions Recordkeeping/ storing form 5 minutes

(0.0833) 257 $1,413.50 $848.10 $2,261.60 Forward form to EPA Ethics Staff 5 minutes

(0.0833 257 $1,413.50 $848.10 $2,261.60

DFO Subtotal 60 min./1 hour

(1.00) 257 $16,962.00 $10,177.20 $27, 139.20 $27,139

DEO Activities For 257 Respondents $ 71 per hour
Review, anal yz e, follow

up, and approve or disapprove 60 min./1 hour

(1.00) 257 $18,247.00 $10,948.20 $29,195.20

DEO Subtotal 60 min./1 hour

(1.00) 257 $ 18,247 $ 10 ,948 $ 29,195 $ 29,195 EPA Grand Total (DFO & DEO ) 120 min./ 2

hours 2.00 514 $35,209.00 $21,125.40 $56,334.40 $56,334

6( c ) Bottom L ine Burden Hours and Cost Tables (i) Respondent Tall y 

## Bottom
- Line Annual Burden and Cost for SGE Respondents SGE Resp ondent Activities to Complete Form 3110
- 48 Burden Hours/ Respondent Burden for SGE

Candidate ($66 per labor hour multiplied by 1.6 for overhead equals $105.6) Number of

Respondents per Year Total

Cost per Year

Total per Year 60 minutes (1 hour/1 00%) $ 105.6 257 $ 27,139
(ii) The Agency

Tall y 

## Bottom
- Line Annual Agency Burden and Cost Agency Hours For Each Number

of Hours Labor

Cost Per Overhead

Cost Per Total

AgencyReview Per Year Year Year Cost per Year Agency Total (DFO & DEO ) For 300 Res pondents 120 min./ 2

hours 2.00 514 $ 35,209 $21, 125 $5 6,334

6(f) Reasons for Change in Burden There is a decrease of 43 hours in from the currently approved burden due to more precise estimates of the number of SGEs filling out Form 3110

- 48, based on the average number of forms received in the last 3 years. 6(g) Burden Statement Burden Statement : The annual public reporting and recordkeeping burden for this collection of information is estimated to average one hour per response. Burden means the t otal time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize techno logy and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously applicable instructions and req uirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency 's need fo r this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OA

- 2010

- 0757 , which is available for online viewing at www.regulations.gov , or in person viewing at the Office of Environmental Information Docket in the EPA Docket Cent er (EPA/DC), EPA West, Room 3334 , 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone numbe r for the Office of Environmental Information Docket is (202) 566

- 9744. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of th e public docket, and to access those documents in the public docket that are available electronically . When in the sy stem, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Re gulatory

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

HQ

- OA

- 2010

- 0757 and OMB Control No. 2090

- 0029 in any correspondence.