## 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 SUPPORTI NG STATEMENT

................................................... ..... 1 1. ID ENTIFICATION OF TH E INFORMATION COLLEC TI ON

................................ ........... 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 OM B
................................ ................................ .............. 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, C OLLECTION METHODOLOGY, AND INF ORMATION 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 CO LLECTION

................................ 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 (i ii ) Vari ations in the Annual Bottom Line

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

................................ ................................ ................................ ................................ .......... 12



### APPENDIX A: COMMEN TS ON THE PUBLIC NOT ICE FOR THE PROPOSED INFORMATION COLLECTION FOR THE GREAT LAKES ACCOUNTABILITY SYSTEM AND EPA’S RES PONSE APPENDIX B: COMPLETED QUESTIONNA IRES FOR THE INFORMAT ION 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 REGI STER NOTICE ANNOUNCING 60 DAY PUBLIC COMMENT PERIOD ON THE GREAT LAKES ACCOUNTABILITY SYSTEM

### LIST OF TABLES
Page

Table 1. C onsultation Par ticipants 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 L ine Burden Hours and Cost Tables...........................................................11GLAS ICR Supportin g Statement Part A Page 1 of 13 March 29, 2010



### PART A OF THE SUPPOR TING ST AT EMENT 1. Identification of the Information Collection 1(a) Title of the Information Collection Great Lakes Accountability System (EPA ICR Number 2379.01, OMB Control Numb er 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) . Itwill 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. T he Conference Rep ort 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 N ational 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 $1,274,150.4 0 (as of March 29 , 2010). The annual federal cost to administer this information c olle ction is estimated to be $36,181.25 (as of March 29 , 2010), which results in a total annual cost of $1,310,3 31

. 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 Supportin g Statement Part A Page 2 of 13 March 29, 2010 

###  Frequency

of response per project : Quarterly Estimated total annual burden hours : 21,61 3 hours (33 hours per project for state, local, and tribal gov ernments , 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. T he 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 inf ormation 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 con firmed 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 Supportin g 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, 20 10, 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 operati ons and maintenance costs. GLNPO also conducted phone consultations to review responses and cl arify 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 Nam e 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 Dep artment 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 - Governm ental 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 Commiss ion 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 Supportin g Statement Part A Page 4 of 13 March 29, 2010 

### GLNPO based the federal burden estimate on EPA’ s experience b ecause it is the agency most familiar with the system. Table 2. Federal Consultation Participants Nam e Phone Number Affiliation Rita Cestaric (312) 886

- 6815 U.S. Environmental Protection Agency , GLNPO Ken Klewin (312) 886

- 4794 U.S. Environmental Prote ction 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 recipi ents 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 Supportin g 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 whi ch 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 eq uivalents 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 recipi ent
- Mandatory field.  Congressional district of funding recipient

– This field i s 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 PlanGLAS ICR Supportin g Statement Part A Page 6 of 13 March 29, 2010 

###  GLRI long term goal, interim measure and measure of progress

– Relevant GLRI Action Plan goal s 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 stat us
– 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 GLNPO 1 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 pre

populated 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

Revie wing 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 Informati on 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 Supportin g 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 s erver 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 hands

on 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 colle ction 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 Bur den 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 en try 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 b y 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 b y a single respondent, EPA estimates that 458 projects will need quarterl y updates during ye ar one, 746 projects will need updating during ye ar two and 576 projects will need to be updated during year threeGLAS ICR Supportin g 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 + 2 88), there will be 594 non - federal respondents and quarterly updates per year. For FY 2010, GLNPO estimates that 1 4 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, GL NPO estimates that 50 federal projects will need quarterl y 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 quarterl y update s per ye ar. 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 u sed 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 2 009 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 Supportin g 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

Inform ation Collect Activity Annual Hours Per Project Annual L abor Cost Per Project Annual

Capital or Startup Cost s 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 Revie wing 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 $0.0 0 $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 non

governmental 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 B urden/Cost Per Project for Non - governmental Organization s

Inform ation Collect Activity Annual Hours Per Project Annual Labor Cost Per P roject Annual

Capital or Startup Cost Per P roject Annual

O&M Cost Per P roject 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 Revie wing 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 $32.69GLAS ICR Supportin g Statement Part A Page 10 of 13 March 29, 2010 Inform ation Collect Activity Annual Hours Per Project Annual Labor Cost Per P roject Annual

Capital or Startup Cost Per P roject Annual

O&M Cost Per P roject 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

Inform ation Collect Activity Annual Hours

Per Project Annual

Labor Cost Per Project Annual

Capital or S tartup 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 Revie wing 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. 7 3 $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 Federa l Administrative Burden/Cost

Inform ation 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 $1,766.02GLAS ICR Supportin g Statement Part A Page 11 of 13 March 29, 2010 Inform ation 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 non go vernmental 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 Cos t 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, th e total annual cost for this information co llection 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 Supportin g Statement Part A Page 12 of 13 March 29, 2010 Table 11. Bottom Line Burden Hours and Costs

Line Ite m 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 0.27 1 $ 18.91 1 $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 GLNP O 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

- go vernmental 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 disclo se 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, proce ssing 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

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- 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 pu blic docket that are available electronically. When in the system, select “search,” thenGLAS ICR Supportin g 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 1 7th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- R05

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- 0932 and OMB Control Number 2005

-NEW in any correspondence.