SUPPORTING STATEMENT

INFORMATION COLLECTION FOR THE 

GREAT LAKES ACCOUNTABILITY SYSTEM

U.S. ENVIRONMENTAL PROTECTION AGENCY

GREAT LAKES NATIONAL PROGRAM OFFICE

March 2010
TABLE OF CONTENTS

 Page 

PART A OF THE SUPPORTING STATEMENT........................................................1

1. IDENTIFICATION OF THE INFORMATION COLLECTION........................................... 1

1(a) Title of the Information Collection..................................................................................................................1

1(b) Short Characterization/Abstract ......................................................................................................................1

2. NEED FOR AND USE OF THE COLLECTION.................................................................. 2

2(a) Need/Authority for the Collection...................................................................................................................2

2(b) Practical Utility/Users of the Data.......................................................................................2

3. NON DUPLICATION, CONSULTATIONS AND OTHER COLLECTION CRITERIA...2

3(a) Non duplication ...............................................................................................................................................2

3(b) Public Notice Required Prior to ICR submission to OMB..............................................................................3

3(c) Consultations...................................................................................................................................................3

3(d) Effects of Less Frequent Collection ................................................................................................................4

3(e) General Guidelines..........................................................................................................................................4

3(f) Confidentiality.................................................................................................................................................4

3(g) Sensitive Questions.........................................................................................................................................4

4. THE RESPONDENTS AND THE INFORMATION REQUESTED.................................... 4

4(a) Respondents/NAICS Codes ............................................................................................................................4

4(b) Information Requested ....................................................................................................................................4

(i) Data items, including record keeping requirements........................................................................................5

(ii) Respondent Activities.....................................................................................................................................6

5. THE INFORMATION COLLECTED–AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT.................................................... 6

5(a) Agency Activities............................................................................................................................................6

5(b) Collection Methodology and Management .....................................................................................................7

5(c) Collection Schedule.........................................................................................................................................7
 Page

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION................................ 7

6(a) Estimating Respondent Burden .......................................................................................................................7

6(b) Estimating Respondent Costs..........................................................................................................................8

(i) Estimating Labor Costs ..............................................................................................................................8

(ii) Estimating Capital and Operations and Maintenance Costs.....................................................................10

6(c) Estimating Agency Burden and Cost ............................................................................................................10

6(d) Estimating the Respondent Universe and Total Burden and Costs...............................................................11

6(e) Bottom Line Burden Hours and Cost Tables.................................................................................................11

(iii) Variations in the Annual Bottom Line......................................................................................................12

6(g) Burden Statement ..........................................................................................................................................12

APPENDIX A: COMMENTS ON THE PUBLIC NOTICE FOR THE PROPOSED INFORMATION 

COLLECTION FOR THE GREAT LAKES ACCOUNTABILITY SYSTEM AND EPA’S RESPONSE

APPENDIX B: COMPLETED QUESTIONNAIRES FOR THE INFORMATION COLLECTION FOR 

THE GREAT LAKES ACCOUNTABILITY SYSTEM

- Racine, Wisconsin

- New York State Department of Environmental Conservation

- Michigan Department of Environmental Quality

- Alliance for the Great Lakes 

- Pennsylvania Sea Grant

- Keweenaw Bay Indian Community

APPENDIX C: SUMMARY TABLES – RESPONDENT COST AND BURDEN CALCULATIONS

APPENDIX D: JANUARY 5, 2010 FEDERAL REGISTER NOTICE ANNOUNCING 60 DAY 

PUBLIC COMMENT PERIOD ON THE GREAT LAKES ACCOUNTABILITY SYSTEM
LIST OF TABLES

 Page

Table 1. Consultation Participants by Type of Organization......................................................3

Table 2. Federal Consultation Participants...........................................................................3

Table 3. List of Respondent Activities................................................................................6

Table 4. Collection Schedule..........................................................................................7

Table 5. Annual Burden Estimate Per Project....................................................................7

Table 6. Annual Burden/Cost Estimate Per Project for State, Local and Tribal Government Agencies...8

Table 7. Annual Burden/Cost Estimate Per Project for Non-governmental Organizations..................9

Table 8. Annual Burden/Cost Estimate Per Project for Federal Agencies....................................9

Table 9. Total Annual Federal Administrative Burden/Cost Estimate.......................................10

Table 10. Annual Burden Estimate..................................................................................10

Table 11. Bottom Line Burden Hours and Cost Tables...........................................................11
GLAS ICR Supporting Statement Part A Page 1 of 13 March 29, 2010

PART A OF THE SUPPORTING STATEMENT

1. Identification of the Information Collection

1(a) Title of the Information Collection

Great Lakes Accountability System (EPA ICR Number 2379.01, OMB Control Number 2005 

NEW)

1(b) Short Characterization/Abstract

This new request for an information collection is needed to assist with the administration of 

the Great Lakes Restoration Initiative (GLRI). The GLRI is a new $475 million multi-year 

program to restore the Great Lakes that was included in the Department of the Interior, 

Environment, and Related Agencies Appropriations Act, 2010 (Public Law 111-88). It will 

be guided by a 5 year action plan that sets goals, criteria for measuring progress and clear 

standards of accountability. GLRI funding will be distributed by the Environmental 

Protection Agency (EPA) through both its own programs and those of other federal agencies. 

A substantial portion of the funding will be administered to non-federal partners through 

grants, cooperative agreements and contracts.

The Conference Report accompanying Public Law 111-88, House Report 111-316 (H. R. 

111-316), directed EPA to develop a process that, “Ensures monitoring and reporting on the 

progress of the Great Lakes Restoration Initiative....” EPA's Great Lakes National Program 

Office (GLNPO) developed the Great Lakes Accountability System (GLAS) as the primary 

mechanism for collecting information to monitor and report on GLRI progress. 

The GLAS is a web-based reporting system that is available at 

https://restore.glnpo.net:8080/login.htm. GLRI funding recipients will be required to enter 

information into GLAS on the nature of the activity, responsible organization, organizational 

point-of-contact, resource levels, geographic location and major milestones of progress

toward GLRI goals. The information will be organized around focus areas to align activities 

with the GLRI Action Plan goals and measures. The information contained in the GLAS will 

be available to the public after undergoing EPA review to verify its accuracy . 

The GLAS will provide transparency on GLRI activities and funds and form the basis for 

reports to the President and Congress on the GLRI. The information in GLAS will be 

updated quarterly. Timely and accurate reporting will be critical.

 

GLNPO estimates the total annual respondent cost and burden to be $1,274,150.40 (as of 

March 29, 2010). The annual federal cost to administer this information collection is 

estimated to be $36,181.25 (as of March 29, 2010), which results in a total annual cost of 

$1,310,331.65. An overview of the cost and burden hours is provided below:

Respondents/Affected Entities: Great Lakes Restoration Initiative Funding Recipients

Estimated total number of potential non-federal respondents: 594 (463 state, 

local and tribal governments, 131 non-government organizations).

Estimated number of projects per non-federal respondent: 1

Number of federal respondents: 15

 Estimated number of projects per federal respondent: 3.3 (50 projects spread 

across 15 federal agencies)
GLAS ICR Supporting Statement Part A Page 2 of 13 March 29, 2010

 Frequency of response per project: Quarterly

Estimated total annual burden hours: 21,613 hours (33 hours per project for state, local, 

and tribal governments, 41.1 hours per project for non-government organizations and 19 hours 

per project for federal agencies). 

2. Need for and use of the Collection

2(a) Need/Authority for the Collection

Collecting information from more than 10 non-federal partners is needed to effectively 

provide transparency and accountability for the GLRI. H.R.111-316 calls for EPA to, 

“Ensure monitoring and reporting on the progress of the Great Lakes Restoration Initiative, 

using scientific research to revise restoration priorities as needed, and adapt and modify 

activities beginning in fiscal year 2011.”

Consistent with this direction, GLRI funding recipients will be required to submit information 

about activities and report progress against measures in the GLRI Action Plan. The GLAS is 

the primary mechanism for collecting information on GLRI activities. 

2(b) Practical Utility/Users of the Data

The primary users of the data are EPA, other government agencies, non-profit 

organizations, universities and the public. The information in GLAS will be used to 

catalog the resources and actions that are implemented under the GLRI and to track 

progress. It will serve as the basis for reports to the President and Congress. The 

public will be able to view activities across the basin, with details such as how much 

funding the activity has received and which organizations are involved. The GLAS is 

a key component of the GLRI.

3. Non duplication, Consultations, and Other Collection Criteria

3(a) Non duplication

GLNPO conducted research into other EPA programs and other federal agency programs, and 

state agency/department or non-governmental organizations to determine whether any 

organization had information pertinent to the GLRI Action Plan. Within EPA, it was 

confirmed that only the GLNPO had the pertinent information. No information similar to that 

requested for the GLAS was identified in the state, local and tribal government agencies and 

non-governmental organizations.

Pursuant to this research, GLNPO concluded that activity and funding information required 

in the GLAS is specific and unique to the GLRI’s goals of protection and habitat restoration. 

The GLAS is the only reporting system used to quarterly collect comprehensive information 

about activities and funding levels. 

Several federal agencies have their own restoration project databases into which some GLRI 

project information will be entered. To minimize burden and avoid duplication, efforts are 

underway to develop a mechanism for importing relevant data fields from these systems into 

GLAS. 
GLAS ICR Supporting Statement Part A Page 3 of 13 March 29, 2010

3(b) Public Notice Required Prior to ICR submission to OMB

GLNPO solicited public comments on this ICR in the Federal Register (Volume 75, page 

362, published January 5, 2010). As of the close of the comment period, on March 9, 2010, 

EPA received one set of public comments on this ICR. The comments and GLNPO’s 

responses are contained in Appendix A. 

3(c) Consultations

GLNPO invited seven non-federal organizations to participate in consultations to estimate 

their annual cost and burden for using the GLAS. The consultations are in keeping with ICR 

guidance to consult with no-more than nine non-federal organizations. GLNPO provided the 

participating organizations with accountability system demonstrations. GLNPO prepared and 

distributed a questionnaire for respondents to complete with burden estimates for labor costs 

associated with reporting activities, capital/startup costs, and operations and maintenance 

costs. GLNPO also conducted phone consultations to review responses and clarify as needed. 

Table 1 provides a list of organizations asked to participate in consultations. Not all chose to 

participate. 

Table 1. Consultation Participants by Type of Organization

Name Phone Number Affiliation

State, Local, and Tribal Government Agencies

Julie Kinzelman (262) 636-9501 City of Racine, Wisconsin, Health Department

Rick Hobrla (517) 335-4173 Michigan Department of Natural Resources and 

Environment

Chris O’Connor (518) 402-9140 New York Department of Environmental 

Conservation

Mark Kwitowski (814) 870-1593 City of Erie, Pennsylvania

Todd Warner (906) 524-5757 ext. 13 Keweenaw Bay Indian Community

Private / Non-Governmental Organizations

Michelle Liebetreu (857) 399-6219 Alliance for the Great Lakes

Dave Skellie (814) 217-9014 Pennsylvania Sea Grant

GLNPO has received completed questionnaires from six respondents. 

In addition, GLNPO conducted a demonstration of the GLAS for Wisconsin Department of 

Natural Resources staff on March 4, 2010 and for representatives of the organizations listed 

below at a Great Lakes Habitat/Species Workgroup on March 17, 2010:

U.S. Fish and Wildlife Service

U.S. Army Corps of Engineers

National Oceanic and Atmospheric Administration

Natural Resources Conservation Service

Great Lakes Fishery Commission

Great Lakes Commission

Wisconsin Department of Natural Resources

Ducks Unlimited

Council of Great Lakes Governors

Wisconsin Wetlands Association

Environmental Consulting and Technology, Inc.
GLAS ICR Supporting Statement Part A Page 4 of 13 March 29, 2010

GLNPO based the federal burden estimate on EPA’s experience because it is the agency most 

familiar with the system. 

Table 2. Federal Consultation Participants

Name Phone Number Affiliation

Rita Cestaric (312) 886-6815 U.S. Environmental Protection Agency, GLNPO

Ken Klewin (312) 886-4794 U.S. Environmental Protection Agency, GLNPO

3(d) Effects of Less Frequent Collection

If the information is not collected, it will be impossible to provide accountability on the 

expenditure of Federal funds under the GLRI or to evaluate progress. Quarterly submissions 

of information are required to provide timely information to ensure Federal monies are 

properly used and report progress. 

3(e) General Guidelines

This information collection is consistent with all of OMB’s general guidelines.

 Respondents are asked to report quarterly.

 Respondents are provided more than 30 days to respond to the data call.

 Respondents are not required to submit more than one copy of original documents.

 This information collection does not use a statistical survey.

 Respondents do not receive a pledge of confidentiality in regard to the information 

collection. No information is confidential or personal; all is considered public.

 Respondents are not asked to submit proprietary or confidential information.

3(f) Confidentiality

Information in the GLAS is not of a confidential nature. 

3(g) Sensitive Questions

None of the requested information is considered to be of a sensitive nature.

4. The Respondents and the Information Requested

4(a) Respondents/NAICS Codes

The respondents for this ICR are the recipients of GLRI funding, which includes federal, 

state, and local agencies (NAICS 924110 and 924120), non-governmental organizations (e.g., 

environment, conservation, and wildlife organizations in NAICS 813312), and other program 

partners. 

4(b) Information Requested

1. Information from GLRI funding recipients will be collected through the web-based GLAS. 
GLAS ICR Supporting Statement Part A Page 5 of 13 March 29, 2010

(i) Data items, including record keeping requirements

GLRI funding recipients provide information about the activities they undertake to restore 

and protect the Great Lakes. Once logged in to the GLAS, the funding recipients enter data 

about their activities, which are grouped by focus and program areas. GLNPO does not 

impose additional recordkeeping requirements on any respondent. States and other entities

may impose their own recordkeeping requirement that is separate from the GLAS. Specific 

data items entered into the GLAS include:

Project reporting elements

 Focus area – A broad programmatic area in the Action Plan to organize restoration 

activities. The focus areas are predefined in GLAS. Mandatory field. 

 Program area – Specific thematic program areas organized as a subset of the focus 

areas. Program areas are predefined in GLAS. Mandatory field.

 Project type - A function such as monitoring or restoration that supports a program area. 

Project types are predefined in GLAS. Mandatory field.

-

 Project and funding reporting elements

 Project title – Mandatory field

 Project description – Mandatory field.

 Quality Assurance Plan required and date of approval– Check yes or no. If yes, provide 

date of approval. Mandatory field.

 Lead organization/contact information – Basic details necessary to identify and contact 

project managers. The lead organizations are predefined in GLAS. Mandatory field.

 Collaborating organizations – A list of other organizations providing resources for the 

project. The lead organizations are predefined in GLAS. Optional field.

 GLRI funding amount/funding year - Specifies total GLRI dollars and the fiscal year in 

which the funding was provided. The funding year is predefined in GLAS. Mandatory 

field.

 Other funding amount/funding source – Non-GLRI dollars allocated for the project and 

the source of the funds. Optional field. 

 FTEs – The total number of full time equivalents per quarter that are funded with GLRI 

funds. Mandatory field.

 Project status/date- An identifier such as current or completed that identifies the status of 

the project as of a specific date. The project status and date are predefined fields in

GLAS. Mandatory field.

 Pertinent GLRI performance measures - A quantitative summary metric for evaluating 

progress. Performance measures are predefined in GLAS. Mandatory field.

Location

 Street address, city state and zip code for the funding recipient- Mandatory field.

 Congressional district of funding recipient – This field is predefined in GLAS. 

Mandatory field.

 Watershed or 8-digit hydrologic unit code for the project – This field is predefined in 

GLAS. Mandatory field.

 Area of Concern (AOC) – This field in predefined in GLAS. Mandatory field if the 

project is located in an AOC. 

 State, latitude/longitude, Congressional district – Project location information. Optional 

field.

Links to the GLRI Action Plan
GLAS ICR Supporting Statement Part A Page 6 of 13 March 29, 2010

 GLRI long term goal, interim measure and measure of progress – Relevant GLRI Action 

Plan goals and measures for the project. At a minimum, information must be entered into 

one of these fields for each project. These fields are predefined in GLAS. 

Milestones

 Schedule, description and status – A short description, schedule and status for key project 

events. Mandatory field. 

(ii) Respondent Activities

GLRI grant recipients conduct the following activities to assemble, submit, and store the data 

items identified above (Table 3). These activities reflect the items of burden mandated by the 

1995 Paperwork Reduction Act. 

Table 3. List of Respondent Activities 

Activity

Record 

Keeping Reporting GLNPO1

Preparing to Use the System. EPA provides detailed 

instructions for entering data online and through training 

workshops. Gathering and reviewing the data to be 

entered, and organizing it by GLRIAP goal is a typical 

activity as part of common business practices. 

X X

Obtaining Access. No special technology or systems are 

required for this collection as the GLAS is Web-based. 

Internet access is a standard business tool. EPA establishes 

user IDs and passwords for each reporting organization.

X X

Entering Records. GLRI grant recipients will review prepopulated system elements, and review data entered by 

their project partners to ensure no duplicative data. 

Records about new activities will be entered as appropriate.

X

Reviewing and Verifying Records. Reviewing and verifying 

the accuracy of the data entered into the system is typical of 

standard business practice. 

X X

Feedback and Evaluation. Users of the GLAS are 

encouraged to provide feedback on the system. 

X

1. Common Business Practice

5. The Information Collected–Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities 

Activities undertaken by GLNPO on a quarterly basis for this information collection include:

 Update reporting guidance and system instructions

 Notify system users of data call

 Conduct training

 Update Web site

 Solicit and compile feedback from users

 Respond to user comments and questions.
GLAS ICR Supporting Statement Part A Page 7 of 13 March 29, 2010

5(b) Collection Methodology and Management

GLNPO will use the Web-based GLAS available at 

http://restore.glnpo.net:8080/glas.login.htm to collect data from the GLRI grant recipients. 

Each reporting organization will be assigned a user ID and password. EPA has established 

security measures to protect data that have been entered, including maintaining the data on a 

secure server on a secure network, confirming the data with each reporting organization, and 

making only summarized information available to the public.

In preparation for the quarterly data call, EPA/GLNPO will provide detailed guidance about 

the database to the GLRI fund recipients (e.g., organize training/workshops, facilitate handson demonstrations as necessary). GLNPO will also verify the accuracy of the data entered 

into the system during and after the data call. Quarterly updating by the GLRI fund recipients 

will be streamlined in light of the automated nature of compiling the information. To 

improve the efficiency of entering data, a cloning button is available during data entry that 

allows users to make a copy of the data for the next fiscal year (i.e., clone the 2010 data to 

create and modify a record for 2011).

5(c) Collection Schedule

The information collection is based on a quarterly collection of data on the activities of the 

GLRI grant recipients. Table 4 shows a typical quarterly or 3-month collection schedule.

Table 4. Collection Schedule 

DATE ACTIVITY 

Month 1 Outreach to GLRI fund recipients

Conduct workshops / feedback sessions 

Month 1 Data call sent to GLRI funding recipients 

Month 2 Data entry complete 

Month 3 Accuracy check by GLNPO

6. Estimating the Burden and Cost of the Collection 

The consultations to determine the annual cost and burden estimates for using the GLAS are 

complete. The final estimates are detailed in the subsections that follow.

6(a) Estimating Respondent Burden

Burden hour estimates are based on the responses to the consultation questionnaires and 

follow-up discussions where needed with respondents. Respondents provided annual burden 

estimates on a per project basis. Each project will require the initial entry and quarterly 

updates. The respondents include state, local and tribal governments and non-governmental 

organizations identified in Section 3(c). Additionally, federal burden is included based on 

EPA estimates, as identified in Section 3(c). Annual estimates for each type of respondent 

are provided in Table 5. For the Fiscal Year (FY) 2010, EPA estimates 458 projects 

conducted by non-federal entities to be awarded GLRI funding in FY2010. Assuming 

continued project funding under the GLRI, EPA estimates that 288 new awards will

be made to non-federal entities in years two and three. Using these assumptions and 

assuming that one project is entered or updated by a single respondent, EPA estimates 

that 458 projects will need quarterly updates during year one, 746 projects will need 

updating during year two and 576 projects will need to be updated during year three
GLAS ICR Supporting Statement Part A Page 8 of 13 March 29, 2010

(assumes 458 projects completed will be completed and not require updates in year 

three). Annualizing over three years (458, 458 + 288, 288 + 288), there will be 594 

non-federal respondents and quarterly updates per year.

For FY 2010, GLNPO estimates that 14 federal agencies will be awarded GLRI

funding for between 40 - 50 new projects. Assuming continued project funding under 

the GLRI, EPA estimates that between 20 – 25 new awards will be made to federal 

entities in years two and three. Using these assumptions, GLNPO estimates that 50 

federal projects will need quarterly updates during years one, two and three (assumes 

50 projects will be completed and not require updates in year three). Annualizing 

over three years (50, 25 + 25, 25 + 25), there will be 14 federal respondents and 50 

quarterly updates per year. 

Table 5. Estimated Annual Burden Per Project

Respondent Type Annual Burden Per Project

State, Local, and Tribal Government Agencies 33 hours

Non-Governmental Organizations 41.1 hours

Federal Agencies 19 hours

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

Table 6 presents the annual respondent burden/cost estimate for state, local, and tribal 

government respondents. Labor rates were derived from information published by the 

Bureau of Labor and Statistics (BLS) for May 2008 (the most recent available data) and 

include a benefits multiplier of 1.5. BLS labor rates used in the calculations have the 

following Standard Occupational Categories: 11-0000 (Management Occupations), 19-0000 

(Life, Physical, and Social Science Occupations), and, 43-0000 (Office and Administrative 

Support Occupations). GLNPO escalated wages and benefits from May 2008 values to 

December 2009 values using the Employment Cost Index for total compensation of state and 

local government employees. The index value for the second quarter of 2008 is 109.9 and the 

index value for the fourth quarter of 2009 is 114.1. The resulting escalation factor is 1.038. 

Labor rates were also increased by 17 percent to account for overhead. For each labor 

category, the labor rate is the average of a calculated rate for state employees and a calculated 

rate for local government agency staff. 
GLAS ICR Supporting Statement Part A Page 9 of 13 March 29, 2010

Table 6. Estimated Annual Burden/Cost Per Project for State, Local, and Tribal Government 

Agencies 

Information 

Collect 

Activity

Annual Hours Per Project

Annual

Labor 

Cost Per 

Project

Annual 

Capital 

or 

Startup 

Costs Per 

Project

Annual 

O&M 

Cost Per 

Project

Total

Managerial 

($65.37/

hour)

Technical 

($48.27/

hour)

Clerical 

($30.83/

hour)

Annual

Hours

Per 

Project 

Annual 

Costs Per 

Project

Preparing to 

Use the 

System 8.6 7.5 0 $924.19 $0.00 $0.00 16.1 $924.19 

Obtaining 

Access 0.4 0.8 0 $64.76 $0.00 $0.00 1.2 $64.76 

Entering 

Records 5.9 4.60 0 $607.71 $0.00 $0.00 10.50 $607.71 

Reviewing 

and 

Verifying 

Records 1 2.80 0 $200.52 $0.00 $0.00 3.80 $200.52 

Feedback 

and 

Evaluation 0.9 0.50 0 $82.97 $0.00 $0.00 1.40 $82.97 

Total 16.8 16.2 0 $1,880.14 $0.00 $0.00 33 $1,880.14

Sources: Hour burden estimates are averages across consultees. Wage rates are based on BLS mean wages for 

State agencies (http://www.bls.gov/oes/2008/may/naics4_999200.htm), Local government agencies, 

(http://www.bls.gov/oes/2008/may/naics4_999300.htm), and. BLS 2010 Employment Cost Index, 

Series ID CIS30100000000001 (state and local government) (customized tables at: 

http://www.bls.gov/ncs/ect/#data; accessed 3/3/2010).

Note: numbers may not add up across all rows and columns due to rounding.

Table 7 presents the annual respondent burden/cost estimate for non-governmental 

organizations. State/local/tribal government labor rates used in Table 6 are used for nongovernmental labor rates in this table. Since non government wage rates tend to be slightly 

lower than state/local/tribal government wage rates, the use of the state/local/tribal 

government wage rates in these calculations provides conservative estimates. 

Table 7. Estimated Annual Burden/Cost Per Project for Non-governmental Organizations 

Information 

Collect 

Activity

Annual Hours Per Project

Annual 

Labor 

Cost Per 

Project

Annual 

Capital 

or

Startup 

Cost Per 

Project

Annual 

O&M 

Cost Per 

Project

Total

Managerial 

($65.37/

hour)

Technical 

($48.27/

hour)

Clerical 

($30.83/

hour)

Annual

Hours

Per 

Project

Annual 

Cost Per 

Project

Preparing to 

Use the 

System 25 3 0 $1,779.08 $0.00 $0.00 28 $1,779.08 

Obtaining 

Access 0.5 0.3 0 $47.17 $0.00 $0.00 0.8 $47.17 

Entering 

Records 6.5 1.3 0 $487.66 $0.00 $0.00 7.8 $487.66 

Reviewing 

and 

Verifying 

Records 4 0 0 $261.49 $0.00 $0.00 4 $261.49 

Feedback 

and 0.5 0 0 $32.69 $0.00 $0.00 0.5 $32.69 
GLAS ICR Supporting Statement Part A Page 10 of 13 March 29, 2010

Information 

Collect 

Activity

Annual Hours Per Project

Annual 

Labor 

Cost Per 

Project

Annual 

Capital 

or

Startup 

Cost Per 

Project

Annual 

O&M 

Cost Per 

Project

Total

Managerial 

($65.37/

hour)

Technical 

($48.27/

hour)

Clerical 

($30.83/

hour)

Annual

Hours

Per 

Project

Annual 

Cost Per 

Project

Evaluation

Total 36.5 4.6 0 $2,608.08 $0.00 $0.00 41.1 $2,608.08 

Sources: Hour burden estimates are averages across consultees. Wage rates are based on BLS mean wages for 

State agencies (http://www.bls.gov/oes/2008/may/naics4_999200.htm), Local government agencies, 

(http://www.bls.gov/oes/2008/may/naics4_999300.htm), and. BLS 2010 Employment Cost Index, 

Series ID CIS30100000000001 (state and local government) (customized tables at: 

http://www.bls.gov/ncs/ect/#data; accessed 3/3/2010).

Note: numbers may not add up across all rows and columns due to rounding.

Table 8 presents the annual respondent burden/cost estimate for federal respondents. The 

federal labor rates were derived from information published by the U.S. Office of Personal 

Management and include a benefits multiplier of 1.6. 

Table 8. Estimated Annual Burden/Cost Per Project for Federal Agencies 

Information 

Collect Activity

Annual Hours 

Per Project Annual 

Labor 

Cost Per 

Project

Annual 

Capital or 

Startup 

Costs Per 

Project

Annual 

O&M 

Cost Per 

Project

Total

GS14 GS13 Annual

Hours Per 

Project 

Annual

Costs Per 

Project

($73.58/ 

hour)

($62.27/

hour)

Preparing to Use 

the System 1.00 1.00 $135.86 $0.00 $0.00 2 $135.86

Obtaining Access 0.5 0.5 $67.93 $0.00 $0.00 1 $67.93

Entering Records 1.00 8.00 $571.76 $0.00 $0.00 9 $571.76

Reviewing and 

Verifying Records 2.00 4.00 $396.26 $0.00 $0.00 6 $396.26

Feedback and 

Evaluation 0.5 0.5 $67.93 $0.00 $0.00 1 $67.93

Total 5.00 14.00 $1239.73 $0.00 $0.00 19 $1239.73

Source: http://www.opm.gov/oca/10tables/html/gs_h.asp (step 5); rates include a benefits multiplier of 1.6

(ii) Estimating Capital and Operations and Maintenance Costs

Respondents will not incur capital or operations and maintenance costs for this information 

collection.

6(c) Estimating Agency Burden and Cost

As shown in Table 9, the estimated annual cost to the federal government for administering 

this collection of information is $36,181.25.

Table 9. Estimated Annual Federal Administrative Burden/Cost 

Information Collect 

Activity

Hours / Year

Labor 

Cost/

Year

O&M 

Cost/

Year

Total Hours and Costs

GS14 GS13 GS12 Total 

Hours/

Year

Total 

Costs/

Year

$73.58/

hour

$62.27/

hour

$52.37/

hour

Update Reporting 

Guidance and

System Instructions

24 0 0 $1,766.02 $0.00 24 $1,766.02
GLAS ICR Supporting Statement Part A Page 11 of 13 March 29, 2010

Information Collect 

Activity

Hours / Year

Labor 

Cost/

Year

O&M 

Cost/

Year

Total Hours and Costs

GS14 GS13 GS12 Total 

Hours/

Year

Total 

Costs/

Year

$73.58/

hour

$62.27/

hour

$52.37/

hour

Notify System Users 

of Data Call 24 0 0 $1,766.02 $0.00 24 $1,766.02

Conduct Training 40 0 0 $2,943.36 $0.00 40 $2,943.36

Update Web Site 0 12 16 $1,585.15 $0.00 28 $1,585.15

Solicit and Compile 

Feedback from 

Users

16 0 0 $1,177.34 $0.00 16 $1,177.34

Respond to User 

Comments and 

Questions

40 0 0 $2,943.36 $0.00 40 $2,943.36

Contractor support $24,000.00 $24,000.00

Total 

Administrative 

Burden

144 12 16 $12,181.25 $24,000.00 172 $36,181.25

Source: http://www.opm.gov/oca/10tables/html/gs_h.asp (step 5); rates include a benefits multiplier of 1.6

6(d) Estimating the Respondent Universe and Total Burden and Costs

GLNPO estimates that 463 state, local, and tribal government agencies, 131 nongovernmental organizations, and 15 federal agencies are likely to report to the GLAS 

annually. The total burden and costs are summarized in Table 10.

Table 10. Estimated Annual Burden Cost* 

Respondent Type

Annual Total 

Hours Per 

Project 

Annual 

Total 

Cost Per 

Project 

Average 

Number of 

Projects/ 

Year

Total 

Annual 

Hours 

Total Annual 

Cost

State, Local, and Tribal

Government Agencies 33 $1880.14 463 15,279 $870,506.01

Non-governmental 

Organizations 41.1 $2608.08 131 5,384 $341,657.99

Federal Agencies 19 $1239.73 50 950 $61,986.40

Total Varies Varies 644 21,613 $1,274,150.40

Note: Respondents will not incur capital or operations and maintenance costs for this information collection

6(e) Bottom Line Burden Hours and Cost Tables

As of March 9, 2010, the total annual cost for this information collection is estimated to be 

$1,310,331.65. The bottom line burden hours and costs for each respondent group, federal 

administrative hours, and operations and maintenance costs are listed in Table 11.
GLAS ICR Supporting Statement Part A Page 12 of 13 March 29, 2010

Table 11. Bottom Line Burden Hours and Costs

Line Item

Annual 

Hours

Annual 

Cost 

Average 

Number of 

Projects Per 

Year

Total 

Burden 

Hours 

Per Year

Total Cost

Per Year

State, Local, and Tribal

Government Agency Responses

33 $1880.14 463 15,279 $870,506.01

Non-governmental Organization 

Responses

41.1 $2608.08 131 5,384 $341,657.99

Federal Agency Responses 19 $1239.73 50 950 $61,986.40

Total Respondent Cost Varies Varies 644 21,613 $1,274,148.50

Total Respondent Burden hours

Federal Administrative Hours 0.271$18.911$12,181.25

Federal Operations and 

Maintenance (Contractor 

Support)

$24,000

Total 644 $1,310,331.65

1. Average labor hours and labor cost in Table 8 Per Project.

(iii)Variations in the Annual Bottom Line

GLNPO does not anticipate significant variations in the annual bottom line.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 33 hours per project for state, local, and tribal government agencies, 

41.1 hours per project for non-governmental organizations, and 19 hours per project for 

federal agencies. Burden is defined as the total time, effort, or financial resources expended 

by persons to generate, maintain, retain, or disclose or provide information to or for a federal 

agency. This estimate includes the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions 

and requirements; 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 displays 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 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, EPA has established a public docket for this ICR under 

Docket ID Number EPA-R05-OW-2009-0932, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Environmental Protection Agency, Great 

Lakes National Program Office, 77 W. Jackson St., Chicago, Illinois 60604. Materials are 

available for viewing from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays; telephone number (312) 886-6815. 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 the public docket, and to access those documents in 

the public docket that are available electronically. When in the system, select “search,” then 
GLAS ICR Supporting Statement Part A Page 13 of 13 March 29, 2010

key in the Docket ID Number identified above. Also, you can send comments to the Office 

of Information and Regulatory 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-R05-OW-2009-0932 and OMB Control Number 2005-NEW in any 

correspondence.