1

SECTION I: PART A OF THE SUPPORTING STATEMENT

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1 (a) TITLE OF THE INFORMATION COLLECTION

“Drinking Water State Revolving Fund Program”

1 (b) SHORT CHARACTERIZATION (ABSTRACT)

The Drinking Water State Revolving Fund Program information collection activities will occur 

primarily at the program level through the State “Capitalization Grant Agreement / Intended Use 

Plan,” “Biennial Report,” the “Drinking Water National Information Management System 

(DWNIMS)” and the “Project & Benefits Reporting (PBR) System.” The information on the 

Intended Use Plan (IUP) is needed annually to describe how the State intends to use available 

Drinking Water State Revolving Fund (DWSRF) funds for the year to meet the objectives of the 

Safe Drinking Water Act (SDWA) and to further the goal of protecting public health. The 

Biennial Report is needed to provide detailed information on how the State met its goals and 

objectives of the previous two fiscal years as stated in the IUP and grant agreement. The SDWA 

requires this information to ensure the national accountability, adequate public review and 

comment, fiscal integrity, and consistent management needed to achieve public health and 

SDWA compliance objectives. To ensure expeditious and timely use of the Fund, financial data 

must be collected annually through DWNIMS. Project level data will be collected on a quarterly 

basis using the PBR System to ensure SDWA eligibility and assess public health results from 

DWSRF projects.

The individual information collections are described as follows:

a. Capitalization Grant Agreement / IUP

The Capitalization Grant Agreement is the principal instrument by which the State 

commits to manage its revolving fund program in conformity with the requirements of 

the SDWA. The grant agreement contains or incorporates by reference the IUP, 

application materials, payment schedule, required certifications, Operating Agreement (if 

used), and other documentation required by the Regional Administrator. Information on 

set-asides and disadvantaged community assistance, public health indicators, core 

measurements, and work plans can be found in the IUP and is needed for input into the 

DWSRF National Information Management System or the Project & Benefits Reporting 

System. The agreement is a general instrument to legally commit the State and the 

Environmental Protection Agency (EPA) to execute their responsibilities under the 

SDWA.

b. Biennial Report

The Biennial Report indicates how the State has met its goals and objectives of the 

previous two fiscal years as stated in the grant agreement and, more specifically, in the 

IUP. The Report provides information on loan recipients, loan amounts, loan terms, 

project categories of eligible costs, and similar data on other forms of assistance. The 

Report also describes the extent to which the existing DWSRF financial operating 

policies, alone or in combination with other State financial assistance programs, will 
2

provide for the long-term fiscal health of the Fund and carry out other provisions as 

specified in a State’s drinking water strategy. Financial information from the Biennial 

Report may be entered into the DWSRF National Information Management System or the 

Project & Benefits Reporting System.

c. State Audit

A State must comply with the provisions of the Single Audit Act Amendments of 1996. 

Best management practices suggest and the EPA recommends that a State conduct an 

annual independent audit of its DWSRF program (including set-asides). The Audit must 

contain an opinion on the financial condition of the DWSRF program, a report on its 

internal controls, and a report on compliance with applicable laws and the SDWA. 

Therefore, a State may voluntarily agree to conduct annual independent audits. 

d. State Reviews of DWSRF Financing Assistance Applications 

The State has the sole responsibility for reviewing the applications, entering into loan and 

other financing arrangements with applicants, and otherwise managing the operations of 

the DWSRF program.

e. Financial and Project Data

To meet the SDWA objective of “promot[ing] the efficient use of fund resources,” states 

must enter financial data, including project and set-aside commitments and 

disbursements, into DWNIMS on an annual basis. These data, also available to the

public, are used by the EPA to assess compliance with the Program’s mandate to use all 

funds in an “expeditious and timely” manner and achieve maximum public health 

protection from the Fund. Project level data is collected on a quarterly basis using the 

PBR System to ensure SDWA eligibility and assess public health results from DWSRF 

projects. To reduce burden on state respondents, the EPA connected these two online 

systems eliminate duplicative data entry.

2. NEED FOR AND USE OF THE COLLECTION

2 (a) NEED / AUTHORITY FOR THE COLLECTION

The SDWA Amendments of 1996 (Pub. L. 104-182) authorize a DWSRF program to assist 

public water systems to finance the costs of infrastructure needed to achieve or maintain 

compliance with SDWA requirements and to protect public health. Section 1452(a)(1) authorizes 

the Administrator of the EPA to award capitalization grants to States, which in turn can provide 

low cost loans and other types of assistance to eligible systems. The information collection 

activities are addressed in the DWSRF Interim Final Rule found in 40 CFR Part 35, Subpart L 

(August 2000). 

The 1996 Amendments declare that the DWSRF program shall be administered by an 

instrumentality of the State and is subject to the requirements of the Act. This means that each 

State is responsible for administering its revolving fund and must make certain assurances 

regarding its plans to carry out its administrative duties.
3

In general, the information collections are required to ensure compliance with Section 1452 of 

the SDWA and to ensure that self-sufficient DWSRF programs are established. These data also

provide the accountability needed to detect and remedy situations of waste, fraud, and abuse of 

federal funds.

2 (b) USE / USERS OF THE DATA

In order for a State to receive a capitalization grant, it must enter into an agreement 

(Capitalization Grant Agreement) with the EPA. State responsibilities include:

a. Contributing 20 percent matching funds;

b. Committing and disbursing funds expeditiously;

c. Jointly establishing a payment schedule with the federal government;

d. Ensuring that enforceable requirements are fulfilled before assistance is provided to 

recipients for other purposes;

e. Monitoring assistance recipient compliance with program requirements and other federal 

cross-cutting authorities during the period of the assistance agreement; and

f. Supplying work plans detailing how set-aside funds will be expended. 

The EPA recommends that States have their DWSRF funds audited on an annual basis in 

accordance with generally accepted government auditing standards (GAGAS).

The information to be provided to the EPA by the States includes:

a. IUP / Capitalization Grant Agreement and Application;

b. Biennial Report; 

c. Most recent Audit; and

d. Financial and Project Data.

Upon approval of the Capitalization Grant Application, each State may begin awarding project 

funds and using set-aside funds after work plans are approved. The State will receive and review 

applications for DWSRF financing assistance. The State will review the applications for 

conformance with the IUP, public health impacts, and financial capabilities of the applicant. For 

those projects and activities funded with monies in an amount equal to the federal capitalization 

grant (including set-asides), the State will also review the proposed projects and activities for 

consistency with federal cross-cutting authorities as described in the DWSRF Interim Final Rule. 

The specific procedures for preparation and review of assistance application materials will be 

developed by each State. If an application is acceptable and the project ranks highly enough on 

the Project Priority List, the State will prepare the appropriate loan agreement documents.

Although the EPA oversees the general operations of the DWSRF program as part of its Annual 

Review process, the Agency does not have any responsibility for reviewing or approving 

individual applications for DWSRF financial assistance.

3. THE RESPONDENTS AND THE INFORMATION REQUESTED
4

3 (a) RESPONDENTS / SIC CODES

The respondents for this request are state and local governments (SIC Code #99). Community 

and nonprofit non-community public water systems are eligible for assistance from the State. 

These water systems may be publicly owned (such as a community or a county) or privately 

owned (such as an investor-owned utility or non-profit homeowner association).

3 (b) INFORMATION REQUESTED

(i) Data Items

The following information elements provide the accountability needed to detect and remedy 

situations of waste, fraud, and abuse of federal funds.

a. IUP / Capitalization Grant Agreement

The Capitalization Grant Application is made on EPA Standard Form (SF) No. 424 

(OMB No. 2020-0020). The DWSRF Management Manual includes a model IUP and SF 

424. This should improve program efficiency and reduce the burden on the States and the 

EPA Regions.

b. Biennial Report

Section 1452(g)(4) of the SDWA requires each State to submit a Biennial Report at the 

end of every other fiscal year that identifies the accomplishments of the previous two 

years under the IUP. The Biennial Report provides the dates, amounts, recipients, and 

terms of loans and other types of financial assistance from Respondent Activities. To 

reduce the burden on the States, the EPA has developed a model Biennial Report that is 

included in the DWSRF Management Manual.

c. State Audit

A State must comply with the provisions of the Single Audit Act Amendments of 1996. 

The EPA recommends that States conduct voluntary annual independent audits that 

contain an opinion on the financial condition of the DWSRF program, a report on its 

internal controls, and a report on compliance with both applicable laws and SDWA 

requirements.

d. State Reviews of DWSRF Financing Assistance Applications 

Section 1452(a) of the SDWA and the DWSRF Final Guidelines outline the eligibilities 

under the DWSRF program in terms of potential recipients, types of projects and 

activities that may receive DWSRF assistance, and the types of financial assistance which 

may be provided. The SDWA provides significant flexibility to the States regarding the 

development of specific procedures for reviewing and approving applications for 

DWSRF assistance and for managing the DWSRF program. 

Specific reporting requirements, which are statutorily based, relate only to the 

relationship between the State as recipient of the federal capitalization grant and the 

Agency as the grantor. The DWSRF Management Manual and other DWSRF program 

materials provide limited guidance or direction to the States regarding the development of 
5

application materials or specific procedures for the processing and disposition of 

applications for DWSRF assistance.

 

f. Financial and Project Data

To ensure expeditious and timely use of the Fund, financial data will be collected 

annually through DWNIMS. Project level data will be collected on a quarterly basis using 

the PBR System to ensure SDWA eligibility and assess public health results from 

DWSRF projects. To reduce burden on state respondents, the EPA connected these two 

online systems eliminate duplicative data entry and provides training on systems’ use.

(ii) Respondent Activities

As a condition of receiving federal funds, State respondents must prepare and submit the 

following documents to apply for federal financial assistance:

 IUP / Capitalization Grant Agreement;

 Biennial Report; and

 Most recent Audit.

Per EPA Grants Policy Issuance (GPI) 14-02: Enhancing Public Awareness of EPA Assistance 

Agreements, local respondents must publicize the EPA’s involvement in project funding only up 

to the funding amount in each year’s capitalization grant. States have various options to meet this 

requirement. 

4. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, 

COLLECTION, METHODOLOGY, AND INFORMATION MANAGEMENT

4 (a) AGENCY ACTIVITIES

The Agency reviews the submissions from the State and analyzes the data provided on the 

Capitalization Grant Agreement / IUP in order to support the State’s management of the 

program. The Agency also reviews Biennial Reports and State Audits from each State to ensure 

that the intended financial and programmatic objectives of the national program are being met.

4 (b) COLLECTION METHODOLOGY AND MANAGEMENT

The DWSRF Management Manual includes a model grant agreement that draws from the Clean 

Water State Revolving Fund (CWSRF) Grant Agreement. Using this example should reduce the 

information burden on States and EPA Regions.

Section 1452(b) of the SDWA requires States to prepare a plan identifying the intended uses of 

funds in the DWSRF program to meet the objectives of the SDWA and further the goal of 

protecting public health. The State must prepare the IUP, after providing for public review and 

comment, and submit it to the Regional Administrator as part of its Capitalization Grant 

Application. In the IUP, the State must include specific details on how it will use all funds 

available, including both funds allocated to the Fund and those that will be allocated to the setaside programs. In addition to uses for the Fund, specified percentages of the Capitalization 
6

Grant funds can be used as set-asides to: (1) administer the DWSRF program and provide 

technical assistance to public water systems (max 4 percent); (2) supplement State drinking 

water management programs (max 10 percent); (3) provide technical assistance to small systems 

(max 2 percent); and (4) provide assistance for source water protection and capacity 

development activities (max 15 percent). A State has the option to develop the IUP in a two-part 

process with one part identifying the distribution and uses of the funds among the various setasides and the other part dealing with project assistance from the Fund. The two-part process 

allows States the flexibility to submit a Capitalization Grant Application for a portion of the 

funds before it completes all of its specific funding decisions. In this situation, a State would 

have to conduct two rounds of public review and comment. One round addresses the use of setaside funding, and the other deals with assistance for projects on the project priority list. 

Under Section 1452(b), the IUP must contain a list of projects, description of the projects, 

expected terms of financial assistance, size of the community served, criteria and methods 

established for the distribution of the funds, and a description of the financial status of the Fund 

and the short-term and long-term goals of the Fund. The IUP should provide to the maximum 

extent practicable: (1) priority for the use of the funds to be given to projects that address the 

most serious risk to human health; (2) priority for projects that are necessary to ensure 

compliance with the requirements of the SDWA; and (3) priority for projects that assist drinking 

water systems most in need, on a per household basis, according to State affordability criteria.

Under Section 1452, States are required to provide assurances in the Capitalization Grant 

Agreement / IUP on how it will comply with requirements. Some of the fifteen assurances that 

follow require the State to simply agree or certify in the grant application that it will comply with 

them. Some of the fifteen assurances require the State to furnish documentation on the 

procedures by which the State plans to ensure compliance with them. The State must include this 

documentation with its Capitalization Grant Application, except when noted. The following 

fifteen assurances are necessary to establish a loan fund that complies with federal requirements:

1. Section 1452(a)(1)(B) – State certification that the state has the authority to establish a 

DWSRF program and that it may legally bind itself to the terms of the Capitalization 

Grant Agreement.

2. Section 1452(a)(1)(G) – Assurance that the State is eligible to receive full allotment of 

funds by complying with the requirements of capacity development and operator 

certification provisions.

3. Section 1452(g)(3) – Assurance that the State will comply with State statutes and 

regulations.

4. Section 1452(a)(1) – Assurance that the State has the technical capability to operate the 

DWSRF program.

5. Section 1452(g)(3) – Assurance that the State will accept capitalization grant funds in 

accordance with a payment schedule and the State will receive federal funds in 
7

accordance with the provisions of the EPA Automated Clearing House or Automated 

Standard Application for Payments.

6. Section 1452(a)(1)(B) – Assurance that the State will deposit all capitalization grant 

funds in the Fund, including repayment of principal and interest and any other funds, 

except for those portions of the grant that the State intends to use for set-aside purposes 

authorized under the SDWA.

7. Section 1452(e) – Assurance the State will deposit an amount at least equal to 20 percent 

of the capitalization grant (State match) in the Fund and deposit any required match for 

set-aside activities in a non-project account.

8. Section 1452(g)(2) – Assurance that the State will provide a dollar for dollar match up to 

10 percent of the funds the State uses for the State program management set-aside.

9. Section 1452(g)(3) – Assurance that the State will use generally accepted accounting 

principles. The State must agree to establish fiscal controls and accounting principles, as 

promulgated by the Governmental Accounting Standards Board, that are sufficient to 

account for and report DWSRF program activities.

10. Section 1452(f)(1)(C) – Assurance that the State will adopt policies and procedures to 

assure that borrowers have a dedicated source of revenue (or in the case of privately 

owned systems, assure that there is adequate security) of all loans to be repaid.

11. Section 1452(g)(3)(A) – Assurance that the State will disburse loans as efficiently as 

possible and in an expeditious and timely manner.

12. Section 1452(g)(3)(A) – Assurance that the State will commit and expend all DWSRF 

Fund monies as efficiently as possible and will enter into binding commitments with 

recipients of Fund assistance equal to the combined amount of each quarterly grant 

payment and match within one year of the grant payment.

13. Section 1452(b) – Assurance that funds will be used in accordance with the IUP. The 

State must agree to expend DWSRF program funds in accordance with an IUP that has 

undergone public review and comment.

14. Section 1452(g)(4) – Assurance that the State will provide the EPA with a Biennial 

Report, which includes the most recent Audit of the Fund and the entire State allotment.

15. Section 1452(g)(3) – Assurance that the State will comply with all federal crosscutting 

authorities.

States must also assure that, as a condition of receiving federal financial assistance, they will 

comply with the provisions of the Single Audit Act of 1996.
8

Section 1452 requires the State to prepare a Capitalization Grant Agreement, which is the 

principal instrument by which the State commits to manage its revolving fund program and to 

ensure that it conforms to the requirements of the SDWA Amendments of 1996. The 

Capitalization Grant Agreement contains, or incorporates by reference, the following parts of the 

agreement: the IUP; the application materials; the payment schedule; required certifications; the 

Operating Agreement, if used; and other documentation required by the Regional Administrator. 

In addition to these requirements, the Capitalization Grant Agreement will define the types of 

oversight responsibilities that are required to determine compliance with Section 1452. 

In order to lessen the burden of the annual Capitalization Grant Application process, the State 

and the EPA may develop an Operating Agreement that covers parts of the DWSRF program 

that are not expected to change from year to year. 

Section 1452(g)(4) requires the State to submit a Biennial Report to the Regional Administrator 

reporting on its program activities, including the findings of the most recent Audit of the Fund 

and the entire State allotment. The report should be submitted according to the schedule 

established in the grant agreement. The report will contain detailed information on progress 

toward meeting the goals and objectives of the previous two fiscal years as stated in the IUP and 

grant agreement. The report will provide information on actual assistance provided, including: 

loan recipients; loan amounts; loan terms; project categories of eligible cost; and similar details 

on other forms of assistance. The information is provided in a format and a manner that is 

consistent with the needs of the EPA Regional Office. The report will describe the extent to 

which the existing DWSRF financial operating policies, alone or in combination with other State 

financial assistance programs, will provide for the long-term fiscal health of the Fund, attain and 

maintain compliance with the SDWA, and carry out other provisions specified in the legislation.

The State must submit detailed financial statements as part of the Biennial Report. At a 

minimum, this should include the financial statements and footnotes required under generally 

accepted accounting principles (GAAP) to present fairly the financial condition and results of 

operation. These financial statements will measure and demonstrate the DWSRF program’s 

ability to maintain its contributed capital. The financial report will follow generally accepted 

accounting principles and will follow enterprise fund reporting standards. Financial information 

from financial reports may be used in the DWSRF National Information Management System or 

the Project & Benefits Reporting System.

In addition, the State must address in its Biennial Report that it has:

 Reviewed all DWSRF program-funded projects and activities in accordance with the 

approved State Environmental Review Procedures;

 Deposited its match on or before the date when each grant payment was made; 

 Made binding commitments in an amount equal to the amount of each grant payment and 

accompanying State match that is deposited into the Fund within one year after receiving 

the grant payment;

 Managed the Fund in a fiscally prudent manner and adopted policies and processes which 

promote the long-term financial health of the Fund;
9

 Complied with Agency grant regulations (40 CFR Part 31) and specific conditions of the 

grant;

 Complied with federal cross-cutting authorities that apply to the State as a federal grantee 

and those that flow through to assistance recipients;

 Provided assistance only to eligible water systems and for eligible purposes under Section 

1452; and

 Funded only the highest priority projects listed on the IUP, according to their priority and 

readiness to proceed, and complied with any procedures for bypassing priority projects 

outlined in the IUP.

States are encouraged to conduct an annual financial and compliance audit of the DWSRF 

program and its operations. The State may designate an independent auditor of the State to carry 

out its audit or may contractually procure the service. Under Section 1452(g)(4), the 

Administrator shall periodically audit all State loan funds established by, and other amounts 

allotted to, the States pursuant to Section 1452 in accordance with procedures established by the 

Comptroller General. If needed, a financial and compliance audit of the DWSRF program for a 

State will be conducted by the Office of the Inspector General (OIG). The OIG has developed an 

audit guide for SRFs, which should reduce the burden on States and improve the efficiency of 

EPA reviews.

Sections 1452(a)(2) and 1452(f) of SDWA outline the eligibilities under the DWSRF program in 

terms of potential recipients and the types of financial assistance that the DWSRF may provide. 

The DWSRF Interim Final Rule identifies types of projects and activities that may receive 

DWSRF assistance. The SDWA provides significant flexibility to the States regarding the 

development of specific procedures for reviewing and approving applications for DWSRF 

assistance and for managing the DWSRF program.

Specific reporting requirements that are statutorily based relate only to the relationship between 

the State as recipient of the federal capitalization grant and the Agency as grantor. Similarly, the 

DWSRF Interim Final Rule, Management Manual, and other DWSRF program materials do not 

provide guidance or direction to the States regarding the development of application materials or 

specific procedures for the processing and disposition of applications for DWSRF assistance to 

eligible recipients.

Generally, State programs require that applications for DWSRF assistance provide the following 

information:

 Project description;

 Project cost estimate;

 Estimated construction schedule;

 Projected disbursement schedule;

 Description of public health impacts;

 Estimation of cost impacts on users;

 Identification of repayment source;

 Description of community;

 Financial, technical, and managerial capability; and,
10

 Certain projects, certifications, and demonstrations regarding compliance with federal 

cross-cutting authorities.

The EPA undertakes many activities to support the Regions and the States with implementation. 

The EPA provides training on the program and prepared model documents relating to IUPs, 

Capitalization Grant Agreements, and Biennial Reports. EPA Regional personnel are regularly in 

contact with their State counterparts and are currently working to determine efficient ways to 

communicate needed information and reduce the burden on respondents.

4 (c) SMALL ENTITY FLEXIBILITY

Respondents are the States, usually within the State Department of Health, Environmental 

Department, and/or Finance Agency. Although information collection activities do not directly 

affect small businesses or organizations as defined in the Regulatory Flexibility Act, 5 U.S.C. 

Sections 601 (3) and (4), States might have activities that require information from small 

businesses or organizations. 

4 (d) COLLECTION SCHEDULE

The information collection activities will occur primarily at the program level through the State 

IUP and the Biennial Report. The information is needed annually to implement Section 1452 of 

the SDWA. The Act requires this information to ensure national accountability, adequate public 

comment and review, fiscal integrity, and consistent management directed to achieve public 

health objectives.

5. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

5 (a) NON-DUPLICATION

The information collection elements are specific to Section 1452, established under the SDWA 

Amendments of 1996. The information in the IUP, Biennial Report, the State Audit and 

DWNIMS/PBR is unique to each State participating in the DWSRF program. Therefore, there is 

no duplication of the effort. The information collection activities herein are based on programspecific State sources that are not duplicated anywhere else.

5 (b) CONSULTATIONS

The information requirements were subjected to the same reviews as the other requirements and 

procedures contained in the DWSRF Interim Final Rule. The DWSRF Interim Final Rule was 

commented on by State officials, representatives of local government, private concerns involved 

with municipal finance, EPA Regional and Headquarters offices, and the Office of Management 

and Budget (OMB).

5 (c) EFFECTS OF LESS FREQUENT COLLECTION
11

The SDWA requires information to be provided annually. The EPA is not requesting the 

information more frequently than the Act requires, although a State may submit information 

more frequently. 

5 (d) GENERAL GUIDELINES

The data collections covered by this ICR are in compliance with the OMB General Guidelines 

for information collections.

5 (e) CONFIDENTIALITY AND SENSITIVE QUESTIONS

(i) Confidentiality: No confidential data is collected.

(ii) Sensitive Questions: Financial information, such as income tax records and financial 

statements, may be required from private water systems for assessing financial capability during 

the loan application process.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6 (a) ESTIMATING RESPONDENT BURDEN

The respondent burden estimates are based on the incremental effort associated with the 

information collection activity. 

The respondents may use DWSRF administrative monies to pay the costs of the annual State 

Audit. Section 1452(g)(2) of the SDWA allows each State to set-aside up to 4 percent of the 

funds allotted to it to cover the reasonable costs of administering the DWSRF program. The 

estimation of the State respondents’ burden for the four information collections is shown below.

a. IUP/Capitalization Grant Agreement

The EPA estimates that each State will spend an average of 400 hours per year to prepare 

the IUP and Capitalization Grant Agreement for submission. Information on set-asides, 

disadvantaged community assistance, public health indicators, core measurements, and 

work plans can be found in the IUP. Table 1 represents the total national burden from the 

IUP/Capitalization Grant Agreement for 50 states and Puerto Rico.

Table 1: IUP/Capitalization Grant Agreement National Burden Hours

Year Number of States Preparation Hours Burden Hours

(A) (B) (A x B)

2016 51 400 20,400

2017 51 400 20,400

2018 51 400 20,400

b. Biennial Report
12

The EPA estimates that, over the 3-year period covered by this ICR, each State will 

spend an average of 275 hours per year in years during which a report is due to compile 

each Biennial Report. The Report is required every two years. This ICR assumes that 

approximately half of the States will submit a Report in 2016 (having last submitted a 

Report in 2014) and 2018 while the other half will submit a Report in 2017 (having last 

submitted a Report in 2015). Table 2 shows the total national burden from the Biennial 

Report.

Table 2: Biennial Report National Burden Hours

Year

Number of States Preparation Hours Burden Hours

(A) (B) (A x B)

2016 26 275 7,150

2017 25 275 6,875

2018 26 275 7,150

c. State Audit

The estimated average burden for each State Audit is 80 hours per year. States are 

required to comply with the provisions of the Single Audit Act. States may build on audit 

work done under the Single Audit Act to complete the separate audit required for this 

program. Table 3 shows the total national burden from the State Audit.

Table 3: State Audit National Burden Hours

Year Number of States Preparation Hours Burden Hours

(A) (B) (A x B)

2016 51 80 4,080

2017 51 80 4,080

2018 51 80 4,080

d. Assistance for Application Preparation and Review

States have responsibility for reviewing and approving local applications for assistance

from the DWSRF program. The EPA estimates that the States will spend an average of 

40 hours reviewing and approving each assistance application in each of the three years. 

Based on historical data, the EPA estimates that, on average, a state will receive 27 

applications for review each year. Table 4 represents the total national State burden from

processing DWSRF assistance applications.

Table 4: Application Review National Burden Hours

Year

Number of States Apps Prep Hours Burden Hours

(A) (B) (C) (A x B x C)

2016 51 27 40 55,080

2017 51 27 40 55,080

2018 51 27 40 55,080
13

e. Financial and Project Data

States have the responsibility to report financial and program data into DWNIMS and 

PBR. The EPA estimates that States will spend an average of 24 hours preparing and 

entering financial data into DWNIMS on annual basis. The EPA estimates that States will 

spend an average of 7.5 hours preparing and entering project data into PBR over a year. 

Table 5 represents the total national State respondent burden.

Table 5: Financial and Project Data Burden Hours

Year

Number of States Preparation Hours Burden Hours

(A) (B) (A x B)

2016 51 31.5 1,606.5

2017 51 31.5 1,606.5

2018 51 31.5 1,606.5

f. Public Awareness Requirements

Per EPA Grants Policy Issuance (GPI) 14-02: Enhancing Public Awareness of EPA 

Assistance Agreements, local respondents (excluding Indian Tribes and Alaska Native 

Villages) receiving DWSRF funds must publicize the EPA’s involvement in project 

funding. The EPA issued guidance to assist states and local communities in meeting this 

requirement. 

This policy only applies to funding up to the amount of each year’s capitalization grant 

and states may choose the systems to which this requirement applies. It is at the 

discretion of the state SRF program to select projects most able to efficiently and 

effectively comply in a way that meets the intention to enhance public awareness without 

significant financial hardship to the state or its borrowers.

Local respondents have various options to meet this requirement and are encouraged to 

choose the method most cost-effective and accessible to a broad audience. After 

consulting with EPA and state staff throughout the country, the following compliance 

options were developed:

i. Standard signage

ii. Posters or wall signage in a public building or location

iii. Newspaper or periodical advertisement for project construction, groundbreaking 

ceremony, or operation of the new or improved facility

iv. Online signage placed on community website or social media outlet

v. Press release

The following information must be included:

• Name of facility, project and community

• State SRF administering the program

• Project is wholly or partially funded with EPA funding

• Brief description of project

• Brief description of the water quality benefits the project will achieve
14

The EPA estimates that 328 local respondents will be affected by this policy each year. 

Table 6 represents the total national local respondent burden.

Table 6: Public Awareness Local Respondent Burden Hours

Year Number of Local Respondents Prep Hours Burden Hours

(A) (B) (A x B)

2016 328 2 656

2017 328 2 656

2018 328 2 656

SUMMARY OF RESPONDENT BURDEN HOURS

Table 7 summarizes the State burden hours for the five individual information collection 

activities. Average burden hours per State and total hours for all States for the three years 

covered by this ICR are provided for each activity.

Table 7: Summary of State Burden Hours (FY 2016 - FY 2018)

ICR Hours Per State Hours for All States

IUP / Cap Grant Agreement 1,200 61,200

Biennial Report 825 21,175

State Audit 240 12,240

Application Review 3,240 165,240

Financial & Program Data 94.5 4,819.5

Program Total Burden 

Hours (FY 2016 - FY 2018) 5,599.5 264,674.5

Table 8 illustrates burden hours for local respondents from public awareness responses. 

The EPA estimates that a total of 328 local respondents will spend 2 hours during each of 

the three years.

Table 8: Summary of Local Respondent Burden Hours (FY 2016 - FY 2018)

ICR Number of Local 

Respondents

Hours 

per Local Respondent

Hours for 

All Local 

Respondents

Public Awareness 984 2 1,968

6 (b) ESTIMATING RESPONDENT COSTS

a. Costs to State Respondents 

The average annual State costs for the 3-year period is estimated to be $4,860,306.07.
15

Since these State costs are grant eligible, they can be paid for out of the DWSRF 

program. Under Section 1452(g)(2), monies can be set aside and used for any reasonable 

costs related to administering the Fund, provided the amount does not exceed 4 percent of 

the State’s allotment. Reasonable costs under this section can include reasonable costs 

expended to establish a State loan fund and to provide technical assistance to public water 

systems within the State.

Under Section 1443(a), an additional 10 percent of the State’s allotment may be used, in 

part, for: (1) supervising public water system programs; (2) administering or providing 

technical assistance through source water protection programs; (3) developing and 

implementing a capacity development strategy under Section 1420(c); and (4) developing 

an operator certification program for purposes of meeting the requirements of Section 

1419. 

The following tables (Table 9.1 - 9.3) contain estimates of burden costs for the five

individual activities involving information collections. The State salary cost of $55.09 per 

hour is based on State wage rate information, inflated to year 2015 dollars using the 

Employment Cost Index.

Table 9.1: FY 2016 State Burden Costs

Fiscal Year 2016

ICR

# of 

States Hours Cost Per Hour Cost

(A) (B) (C ) (A x B x C)

IUP / CGA

– Initial Plan 51 332 $55.09 $932,783.88

– Revised Plan 51 68 $55.09 $191,052.12

Biennial Report 26 275 $55.09 $393,893.50

State Audit 51 80 $55.09 $224,767.20

Application Review 51 1,080 $55.09 $3,034,357.20

Financial & Project Data 51 31.5 $55.09 $88,502.09

Program Total Fiscal Year 2016 State Cost $4,865,355.99

Table 9.2: FY 2017 State Burden Costs

Fiscal Year 2017

ICR

# of 

States Hours Cost Per Hour Cost

(A) (B) (C ) (A x B x C)

IUP / CGA
16

– Initial Plan 51 332 $55.09 $932,783.88

– Revised Plan 51 68 $55.09 $191,052.12

Biennial Report 25 275 $55.09 $378,743.75

State Audit 51 80 $55.09 $224,767.20

Application Review 51 1,080 $55.09 $3,034,357.20

Financial & Project Data 51 31.5 $55.09 $88,502.09

Program Total Fiscal Year 2017 State Cost $4,850,206.24

Table 9.3: FY 2018 State Burden Costs

Fiscal Year 2018

ICR

# of 

States Hours Cost Per Hour Cost

(A) (B) (C ) (A x B x C)

IUP / CGA

– Initial Plan 51 332 $55.09 $932,783.88

– Revised Plan 51 68 $55.09 $191,052.12

Biennial Report 26 275 $55.09 $393,893.50

State Audit 51 80 $55.09 $224,767.20

Application Review 51 1,080 $55.09 $3,034,357.20

Financial & Project Data 51 31.5 $55.09 $88,502.09

Program Total Fiscal Year 2018 State Cost $4,865,355.99

SUMMARY OF STATE COSTS

Total State Costs (FY 2016 - FY 2018): $14,580,918.22

Average Annual State cost over 3-Year Period: $4,860,306.07

b. Costs to Local Respondents

Table 10 illustrates the burden costs of application preparation for local respondents. The 

hourly rate of $37.02 for water system operators and professional personnel is based on 

wage rate information, inflated to year 2015 dollars using the Employment Cost Index.

Only local respondents that receive DWSRF assistance in the amount equivalent to the 

state’s capitalization grant must meet this provision and states are encouraged to select 

projects most able to efficiently and effectively comply in a way that meets the intention 

to enhance public awareness without significant financial hardship to the state or its 
17

borrowers. Therefore, this information collection will pertain only to a limited number of 

local respondents. The Agency estimates that, on average, 328 local respondents will 

spend approximately 2 hours meeting this provision each year.

Table 10: Local Respondents Burden Costs (FY 2016 - FY 2018)

ICR – Public Awareness

Year # of Local Respondents Hours Cost Per Hour Cost

(A) (B) (C ) (A x B x C)

2016 328 2 $37.02 $24,285.12

2017 328 2 $37.02 $24,285.12

2018 328 2 $37.02 $24,285.12

Program Total Local Respondent Costs (FY 2016- FY 2018) $72,855.36

Average Annual Cost Over 3-Year Period $24,285.12

6 (c) Estimating Agency Burden and Cost

Estimation of the direct cost to EPA to implement the DWSRF program covers negotiation and 

analysis of the IUP, Capitalization Grant Agreement, Grant Application, and State performance 

and compliance through the Biennial Report, State Audit and DWNIMS/PBR data. 

The estimates in Tables 11.1 - 11.3 reflect Agency workload over the 3-year period covered by 

this information collection. The estimate of EPA costs is based on average hourly expenditures, 

including Regional and Headquarters personnel compensation and benefits. The estimates were 

based on participation by all States in the DWSRF program.

The estimated average hourly cost of $53.60 for EPA Headquarters and Regional personnel is 

based on the General Schedule (GS) 12, Step 05 level. The hourly estimates were calculated by 

dividing the annual compensation of $69,686 from the 2015 GS pay schedule, by 2,080 hours in 

the federal work year. The hourly rates were then multiplied by the standard government benefits 

multiplication factor of 1.6.

The average annual federal cost of $2,404,406.67 over the 3-year period was estimated as 

follows:

Table 11.1: FY 2016 EPA Burden Costs

Fiscal Year 2016

ICR Hours Cost Per 

Hour Agency Cost

EPA HQ Review of IUP and Agreement 

Materials (15 hours per State submission)

765 $53.60 $41,004.00 

EPA Regional Review of IUP and Agreement 

Materials (350 hours per State submission)

17,850 $53.60 $956,760.00 
18

EPA HQ Oversight Review of Audit & 

Biennial Reports (40 hours per State 

submitting Biennial report; 25 hours per 

State only submitting Audit Report)

1,665 $53.60 $89,244.00 

EPA Regional Oversight Review of Audit & 

Biennial Reports (500 hours per State 

submitting Biennial report; 445 hours per 

State only submitting Audit Report)

24,125 $53.60 $1,293,100.00 

EPA HQ Review of DWNIMS and PBR Data 

(1 hour per State submission)

51 $53.60 $2,733.60

EPA Regional Review of DWNIMS and PBR 

Data (2 hours per State submission)

102 $53.60 $5,467.20

Grand Total Fiscal Year 2016 Federal Cost $2,388,308.80

Table 11.2: FY 2017 EPA Burden Costs

Fiscal Year 2017

ICR Hours Cost Per 

Hour Agency Cost

EPA HQ Review of IUP and Agreement 

Materials (15 hours per State submission)

765 $53.60 $41,004.00 

EPA Regional Review of IUP and Agreement 

Materials (350 hours per State submission)

17,850 $53.60 $956,760.00 

EPA HQ Oversight Review of Audit & 

Biennial Reports (40 hours per State 

submitting Biennial report; 25 hours per 

State only submitting Audit Report)

1,650 $53.60 $88,440.00 

EPA Regional Oversight Review of Audit & 

Biennial Reports (500 hours per State 

submitting Biennial report; 445 hours per 

State only submitting Audit Report)

25,500 $53.60 $1,366,800.00 

EPA HQ Review of DWNIMS and PBR Data 

(1 hour per State submission)

51 $53.60 $2,733.60

EPA Regional Review of DWNIMS and PBR 

Data (2 hours per State submission)

102 $53.60 $5,467.20

Grand Total Fiscal Year 2017 Federal Cost $2,461,204.80

Table 11.3: FY 2018 EPA Burden Costs

Fiscal Year 2018

ICR Hours Cost Per 

Hour Agency Cost
19

EPA HQ Review of IUP and Agreement 

Materials (15 hours per State submission)

765 $53.60 $41,004.00 

EPA Regional Review of IUP and Agreement 

Materials (350 hours per State submission)

17,850 $53.60 $956,760.00 

EPA HQ Oversight Review of Audit & 

Biennial Reports (40 hours per State 

submitting Biennial report; 25 hours per 

State only submitting Audit Report)

1,665 $53.60 $89,244.00 

EPA Regional Oversight Review of Audit & 

Biennial Reports (500 hours per State 

submitting Biennial report; 445 hours per 

State only submitting Audit Report)

24,125 $53.60 $1,293,100.00 

EPA HQ Review of DWNIMS and PBR Data 

(1 hour per State submission)

51 $53.60 $2,733.60

EPA Regional Review of DWNIMS and PBR 

Data (2 hours per State submission)

102 $53.60 $5,467.20

Grand Total Fiscal Year 2018 Federal Cost $2,388,308.80

6 (d) BOTTOM LINE BURDEN HOURS AND COSTS / BURDEN TABLES

(i) Respondent Burden (FY 2016 - FY 2018)

Total State Burden Hours: 264,674.50

Total State Costs: $14,580,918.22

Annual State Burden Hours: 88,224.83

Annual State Costs: $4,860,306.07

Total Local Respondent Burden Hours: 1,968

Total Local Respondent Costs: $72,855.36

Annual Local Respondent Burden Hours: 656

Annual Local Respondent Costs: $24,285.12

Total Respondent (State & Local) Burden Hours: 266,642.5

Total Respondent (State & Local) Costs: $14,653,773.58

Annual Respondent (State & Local) Burden Hours: 88,880.83

Annual Respondent (State & Local) Costs: $4,884,591.19

(ii) The Agency Burden (FY 2016 - FY 2018)

Annual Headquarters Burden Hours: 2,425

Annual Headquarters Costs: $132,713.60

Annual Regional Burden Hours: 42,433

Annual Regional Costs: $2,279,893.87
20

(iii) Variations in the Annual Bottom Line

There will be negligible variation in annual burden during the three years of this ICR.

6 (e) REASONS FOR CHANGE IN BURDEN

There is a net decrease in total respondent burden hours from the previous ICR. This is largely 

attributable to the previous ICR’s inclusion of burden hours from the American Recovery and 

Reinvestment Act (ARRA) signed by the President on February 17, 2009. ARRA’s additional $2 

billion in funding for assistance agreements resulted in approximately twice the normal number 

of applications for assistance in 2009. There is also a net decrease in local respondent burden 

hours from the previous ICR; it included application preparation and submission burden hours 

for localities. This is a state need/requirement, not federal, and thus it is excluded from this ICR. 

Some of the decrease is offset by inflation and this ICR’s inclusion of local burden for public 

awareness activities.

6 (f) BURDEN STATEMENT

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

average 1,729 hours per state and 2 hours per local respondent (excluding Indian Tribes and 

Alaska Native Villages) annually. Burden means the total time, effort, or financial resources 

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

agency. This 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 processes 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, the EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OW-2002-0059, which is available for public viewing at the Water 

Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., 

NW, Washington, DC. An electronic version of the public docket is available through 

www.regulations.gov.