SUPPORTING STATEMENT FOR APPROVAL OF

STATE COASTAL NONPOINT POLLUTION CONTROL PROGRAMS

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE OF THE INFORMATION COLLECTION

Approval of State Coastal Nonpoint Pollution Control Programs 

OMB Control Number 2040-0153; EPA ICR Number 1569.08

1(b) SHORT CHARACTERIZATION

This ICR renewal explains reporting requirements that coastal States and 

Territories (referred to as States) must fulfill in order to obtain final approval of their 

Coastal Nonpoint Pollution Control Programs (referred to hereafter as “Coastal Nonpoint 

Programs”) under Section 6217 (Protecting Coastal Waters) of the Coastal Zone Act 

Reauthorization Amendments of 1990 (CZARA). This ICR renewal also assesses 

whether State program requirements for management measure implementation will

impose any reporting of record-keeping requirements on affected entities.

Section 6217 requires coastal States and Territories with Federally-approved 

coastal zone management programs (CZMPs) to develop Coastal Nonpoint Programs. 

The Program Development and Approval Guidance for Section 6217 Coastal Nonpoint 

Pollution Control Programs was prepared by the U.S. Environmental Protection Agency 

(EPA) and the National Oceanic and Atmospheric Administration (NOAA). The 

document implements Section 6217, providing guidance to States on the development 

and content of their Coastal Nonpoint Programs.

Section 6217 addresses persistent coastal pollution problems by improving 

coordination of Federal and State CZMPs and water quality programs. In the past, there 

was limited integration of State Nonpoint Source Management Programs approved by

EPA under Section 319 of the Clean Water Act (CWA) and State CZMPs approved by

NOAA under Section 306 of the Coastal Zone Management Act (CZMA). Section 6217 

formalizes coordination of the Section 319 and Section 306 programs by requiring EPA 

and NOAA to oversee preparation and review of the State Coastal Nonpoint Programs.

The program guidance describes the contents that each coastal State must include 

in the Coastal Nonpoint Program documentation and the criteria for program approval. 

Rather than create an independent program, the Section 6217 program guidance 

encourages States to implement their Coastal Nonpoint Programs through changes to 

existing Section 319 and Section 306 programs. States failing to submit satisfactory

Coastal Nonpoint Programs face reductions in Federal grants issued under CWA Section 

319 and under Section 306 of the CZMA.
2

Section 6217 requires States with approved coastal management programs to 

submit Coastal Nonpoint Programs within 30 months of the publication of the final 

program guidance (January 1993). Twenty-nine States and five Territories have 

submitted their Coastal Nonpoint Programs to the Nonpoint Source Control Branch, 

Assessment and Watershed Protection Division, Office of Wetlands, Oceans, and 

Watersheds (OWOW), Office of Water, within EPA, and to the Office of Ocean and 

Coastal Resource Management within NOAA. Another State is developing its program 

for submittal to EPA and NOAA in early 2014. The two agencies have jointly reviewed 

the State Coastal Nonpoint Programs as required by Section 6217.

EPA and NOAA have approved programs from 17 States and five Territories, and 

conditionally approved programs from 11 States. One State with a conditionally approved 

program withdrew from NOAA’s CZMP in 2011, which brought an end to its 

participation in the Coastal Nonpoint Program under CZARA. The conditional approvals

require States and Territories to submit additional information in order to obtain final 

program approval. CZARA Section 6217 requires States and Territories to obtain final 

approval of their Coastal Nonpoint Pollution Control Programs in order to retain their full 

share of funding available to them under CWA Section 319 and under Section 306 of the 

CZMA.

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED/AUTHORITY FOR THE COLLECTION

Section 6217(g)(1) of CZARA required EPA to issue guidance for coastal 

nonpoint source pollution control:

“The Administrator [of EPA], in consultation with the Secretary [of Commerce, 

overseeing NOAA] and the Director of the United States Fish and Wildlife 

Service and other Federal agencies, shall publish (and periodically revise 

thereafter) guidance for specifying management measures for sources of nonpoint 

pollution in coastal waters.”

In response to Section 6217(g)(1), EPA convened a work group to prepare a 

technical document specifying management measures for controlling nonpoint source 

pollution in coastal waters. The draft technical guidance document was issued in June 

1991; the final technical guidance document was issued in January 1993. EPA and 

NOAA proposed program guidance in October 1992 for preparing the State Coastal 

Nonpoint Programs, which document State efforts to implement the management 

measures described in the technical guidance. This document was issued in final form in 

January 1993.

EPA and NOAA issued the program guidance to explain how States should
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prepare their Coastal Nonpoint Programs in order to comply with CZARA Section 

6217(a):

“Not later than 30 months after the date of the publication of final 

guidance under subsection (g), each State for which a management program has 

been approved pursuant to Section 306 of the Coastal Zone Management Act of 

1972 shall prepare and submit to the Secretary and the Administrator a Coastal 

Nonpoint Pollution Control Program for approval pursuant to this section. The 

purpose of the program shall be to develop and implement management measures 

for nonpoint source pollution to restore and protect coastal waters, working in 

close conjunction with other State and local authorities.”

Section 6217(b) of CZARA specifies the contents of the Coastal Nonpoint 

Programs, which are incorporated into the program guidance requirements. Table 1 

presents a summary of the program contents required by Section 6217(b). Additional 

justification for each reporting item is provided in section 3(b) of this supporting 

statement.

In addition, Section 306(d)(16) of CZARA requires State Coastal Nonpoint 

Pollution Control Programs to include enforceable policies and mechanisms to implement 

the applicable requirements of Section 6217.

Subsequent to the publication of the program and technical guidance, EPA and NOAA 

provided further program clarification in the Final Administrative Changes to the Coastal 

Nonpoint Pollution Control Program Guidance for Section 6217 of the Coastal Zone Act 

Reauthorization Amendments of 1990, which the agencies issued in October 1998. This updated 

guidance calls for each state to communicate program priorities by submitting a 15-year program 

strategy to EPA and NOAA that briefly describes the State’s overall approach and schedule to ensure 

implementation of the 6217(g) management measures and improve water quality within 15 years of 

the date of conditional approval.

At this time, EPA and NOAA have approved programs from 17 States and five

Territories, and conditionally approved programs from 11 other States. One State with a 

conditionally approved program withdrew from NOAA’s CZMP in 2011, which brought 

an end to its participation in the Coastal Nonpoint Program under CZARA. In order for 

conditionally approved programs to gain final approval, certain conditions must be met. 

Such conditions could include the completion of a particular program element or the 

development of additional authority to ensure implementation of certain management 

measures. This ICR renewal is needed so that the remaining States may complete 

development and obtain final approval of their programs. The ICR is also needed to allow 

states that have recently and voluntarily joined NOAA’s CZMP to develop and submit 

new Coastal Nonpoint Programs under CZARA to EPA and NOAA. Illinois is the most 

recent State to join the CZMP, and is required to submit its Coastal Nonpoint Program to 

EPA and NOAA in 2014.
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2(b) PRACTICAL UTILITY/USERS OF THE DATA

EPA and NOAA will use the Coastal Nonpoint Program submittals to determine 

whether to grant final approval of the State Coastal Nonpoint Programs. States not 

receiving final approval may lose a portion of both their CWA Section 319 and CZMA 

Section 306 funds under the withholding provisions of CZARA. The requested 

information will ensure the efficient distribution of Federal funds to States with 

comprehensive plans for controlling coastal water pollution. EPA and NOAA will also 

use the requested information to ensure that State recipients of Federal funds provide 

adequate opportunities for public participation during program development. States will 

use the information requested as part of management measure implementation in 

conformity with EPA’s technical guidance.

Table 1. Statutory Requirements in CZARA §6217

CZARA Citation Statutory Requirements for Coastal Nonpoint Programs 

§6217(b) Specify general management measures to protect coastal 

waters.

§6217(b)(1) Identify land uses which contribute significantly to the 

degradation of coastal waters.

§6217(b)(2) Identify critical coastal areas adjacent to impaired or 

threatened coastal waters, where the general management 

measures will be insufficient to maintain water quality

standards and/or designated uses.

§6217(b)(3) Identify additional management measures needed to attain or 

maintain water quality standards under CWA §303 and 

designated uses in the critical coastal areas identified in 

§6217(b)(2).

§6217(b)(4) Provide technical assistance to local governments and the 

public for implementing the additional management

measures identified in §6217(b)(3).

§6217(b)(5) Designate opportunities for public participation in all aspects 

of the coastal nonpoint program.

§6217(b)(6) Establish mechanisms for coordinating State and local 

agency implementation of the coastal nonpoint programs.

§6217(b)(7) Propose modified coastal zone boundary, as the State deems 
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necessary, so that the State has adequate geographic 

jurisdiction to implement the management measures (NOAA 

reviewed the adequacy of existing boundaries for each

coastal management program and recommended changes 

where necessary).

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) NONDUPLICATION

Under the original ICR, the EPA Assessment and Watershed Protection Division 

consulted with OPPE Desk Officer Harold Woodley and Masi Okasaki of NOAA to 

ensure that the information requested in the Section 6217 program guidance could not be 

acquired from other sources. EPA reviewed existing ICRs prepared by EPA’s Office of 

Water and NOAA’s Office of Ocean and Coastal Resource Management to identify

possible duplications of reporting requirements. EPA recently (October 2013) found that 

NOAA has included information on this information collection as part of a larger set of 

programs authorized under the CZMP under OMB Control No. 0648-0119. In the future, 

EPA and NOAA will work to merge these estimates and submit it as a single information 

collection request since the collection consists of the same set of respondents 

simultaneously submitting the same information to both federal agencies.

EPA recognizes similarities between the reporting requirements for the biennial 

State Section 305(b) reports (under ICR Number 1560.1) and those in the Section 6217 

program guidance. The Section 305(b) program guidance requires States and Territories 

to summarize total impaired estuarine and ocean waters and the sources of impairment in 

their 305(b) reports. States are aware that they are able to conduct monitoring activities 

associated with the Section 6217 program guidance at least partially through their 

existing Section 305(b) processes.

3(b) PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

EPA will publish a notice in the Federal Register soliciting comments on this 

draft ICR before it is submitted to OMB for approval.

3(c) CONSULTATIONS

Under the original ICR, NOAA and EPA held regional meetings to acquire 

respondent input during the initial development of the Section 6217 program guidance. 

The regional meetings were attended by representatives of State coastal management 

programs, State water quality control programs, the Coastal States Organization (CSO), 
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and the Association of State and Interstate Water Pollution Control Administrators 

(ASIWPCA). EPA and NOAA also distributed options papers and requested comments 

from each of the approved State coastal management programs.

NOAA and EPA issued proposed program guidance in October 1992 and 

provided a 60 day public comment period. The agencies held a series of focus group 

meetings with representatives from State coastal management and water quality agencies 

and began a second series of regional meetings with States and EPA regional offices 

during the summer of 1992. The State respondents expressed concern about flexibility to 

tailor their Coastal Nonpoint Programs to specific water quality problems in their coastal 

zones. EPA and NOAA have provided flexibility by allowing respondents to propose 

alternative management measures to those included in the technical guidance. The 

respondents must document that the alternative management measures are as effective as 

the pre-approved management measures in the technical guidance prepared by EPA.

The final program guidance was published in January 1993. In response to State 

concerns about potential burden requirements, EPA and NOAA made every effort to 

integrate components of existing CWA Section 319 and CZMA Section 306 programs 

into the Coastal Nonpoint Program requirements. In order to minimize respondent 

burden, States may satisfy some reporting requirements contained in Section 6217 by

identifying existing program activities that already meet Coastal Nonpoint Program 

objectives.

EPA issued proposed management measures guidance in June 1991 and provided 

a six-month comment period on the management measures guidance. EPA convened 

technical workgroups composed of Federal and State experts in preparing both the 

proposed and the final management measures guidance. In addition, EPA held focus 

group meetings with various industry groups (agriculture, forestry, and marinas, in 

particular). The final technical guidance was published in January 1993.

In 1993 and 1994, EPA and NOAA worked closely with States to assist them in 

developing their programs. This assistance included highly detailed reviews of draft State 

Coastal Nonpoint Programs, as well as extensive meetings with individual States. 

Subsequently, on January 6, 1995, EPA and NOAA wrote letters to the State 

organizations that represent State nonpoint source and coastal zone management agencies 

to provide increased flexibility to the States with respect to criteria for program approval 

and schedules for implementation.

In April 1997, NOAA, EPA, the States, and other interested parties began 

discussions regarding the progress made to date in developing and implementing State 

Coastal Nonpoint Programs and the significant impediments to further progress. Both the 

States and Federal agencies recognized that while the goals of CZARA remain valid, the 

program and schedules originally conceived by NOAA and EPA were extremely 

ambitious, and additional flexibility would be needed to enable the States to successfully 
7

implement their programs. Based on this understanding, the parties proceeded to discuss 

in detail the specific aspects of the program that would require modification while 

maintaining the overall objective that States implement management measures needed to 

protect coastal waters.

Based on these discussions, EPA and NOAA drafted a set of proposed 

administrative changes the agencies would use to guide future implementation of the 

CZARA program and made them available for a 60 day public comment period 

beginning March 11, 1998. After reviewing and responding to public comments on the 

proposed changes, NOAA and EPA issued final administrative changes to the program 

guidance, reflecting the comments received. In some cases, the administrative changes 

impacted previous findings and conditions on State Coastal Nonpoint Programs. In such 

cases, EPA and NOAA reviewed those findings and conditions and made adjustments 

(including, where appropriate, elimination of conditions).

On October 25, 2002 (67 FR 65563), EPA sought comments on a previous 

renewal of this ICR pursuant to 5 CFR 1320.8(d). On November 20, 2002 (67 FR 70070), 

EPA extended the comment period 30 days. EPA received one comment from NOAA, 

providing recommendations for increasing the Federal government burden hours to more 

accurately reflect the assessment of hours incurred by the agencies’ review of State 

programs. EPA incorporated NOAA’s recommendations to adjust the estimate 

accordingly (see Table 4).

NOAA and EPA have continued to consult with States and public interest groups 

throughout the process of formulating strategies for final approval and criteria for 

fulfilling conditions. Much of this work has been coordinated through the Coastal States 

Organization (CSO), which has continued from 2011 through 2013 by way of an ongoing 

CSO-led joint state-federal work group.

3(d) EFFECTS OF LESS FREQUENT COLLECTION

The development and approval of State Coastal Nonpoint Programs is a one-time 

collection activity. To date, twenty-two coastal States and Territories have completed 

development and obtained conditional approval of their Coastal Nonpoint Programs, and 

now need only to remove the remaining conditions to obtain final approval. In any given 

year, a subset of States has made progress to reduce the number of remaining conditions.

3(e) GENERAL GUIDELINES

The guidance does not include any information collection activities that exceed 

the PRA-imposed guidelines contained in 5 CFR 1320.6.

3(f) CONFIDENTIALITY
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The information collected under Section 6217 and this ICR renewal will not 

require States and Territories to collect any confidential information.

3(g) SENSITIVE QUESTIONS

Information to be reported is not of a sensitive nature.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS/SIC CODES

The respondent community consists of the 12 coastal States with approved 

CZMPs that have not yet submitted fully approvable Coastal Nonpoint Programs under 

CZARA. The SIC Code for State respondents is 9511 (Administration of Environmental 

Quality Programs: Air and Water Resources and Solid Waste Management).

4(b) INFORMATION REQUESTED

(i) Data Items, including Record Keeping Requirements

The respondents have reported on the following items in their Coastal Nonpoint 

Program submittals under Section 6217. (The CZARA section requiring each item is 

listed in brackets.) No record keeping requirements are imposed on the respondents.

1. Categories and subcategories of nonpoint sources that generally impair or 

threaten coastal water quality within the respondent’s jurisdiction 

[CZARA §6217(b)].

2. Management measures selected from the CZARA §6217(g) technical 

guidance to address each significant nonpoint source category and 

subcategory identified above [CZARA §6217(b)].

3. Alternative management measures and technical documentation. (This 

optional item is included to allow the States additional flexibility in 

designing their Coastal Nonpoint Programs.)

4. Coastal waters not maintaining water quality standards and coastal waters 

threatened by increased pollution from new or expanding uses 

[§6217(b)(1)].

5. Land uses that are sources of nonpoint pollution entering impaired or 

threatened coastal waters [§6217(b)(1)].

6. Critical coastal areas adjacent to waters not maintaining water quality 
9

standards [CZARA §6217(b)(3)].

7. Additional management measures developed by the State or Territory to 

address threats or impairments identified in #5 above and for application 

in critical coastal areas [§6217(b)(3)].

8. Plans for revising additional management measures [CZARA 

§6217(b)(3)].

9. Plans for providing technical assistance for implementing additional 

management measures to local governments and the public [CZARA 

§6217(b)(4) and §6217(b)(5)].

10. The organization, structure, authority, and resources of lead agencies 

selected to implement management measures. (This information is needed 

to ensure that implementation of the Coastal Nonpoint Program is 

delegated to agencies with adequate authority and resources.)

11. Schedules for implementation of management measures. (This information 

is needed to evaluate State progress towards implementing their Coastal 

Nonpoint Programs.)

12. Legislative and administrative authorities for implementing management 

measures. (This information is needed to ensure that the State has the 

authority to implement the Coastal Nonpoint Program.)

13. Mechanisms for coordinating State agency and local government 

participation in the Coastal Nonpoint Programs [CZARA §6217(b)(6)].

14. Procedures to ensure implementation of management measures including 

operation and maintenance, inspection, and monitoring activities. (This 

information is needed to ensure that the State can implement selected 

management measures in the Coastal Nonpoint Program.)

15. Plans to modify coastal zone boundaries [CZARA §6217(b)(6)].

16. Mechanisms for coordinating Coastal Nonpoint Programs with CWA 

programs under Sections 208, 303, 319, and 320 [CZARA §6217(a)(2) 

and §6217(b)(6)].

17. Provisions for public participation [CZARA §6217(b)(5)].

(ii) Respondent Activities
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Section 6217 required each respondent to prepare a one-time document describing 

its Coastal Nonpoint Program. Eleven of the 12 respondents have already performed the 

following activities and submitted their coastal Nonpoint Programs to NOAA and EPA in 

compliance with the program and technical guidances:

 Reviewed the program and technical guidance documents describing the contents 

required in the Coastal Nonpoint Programs and the management measures for 

controlling nonpoint sources of water quality degradation in coastal areas.

 Planned activities (i.e., delegate collection tasks, plan interagency meetings, 

establish reviewers, and delegate writing activities) to complete development of 

the Coastal Nonpoint Program.

 Collected information relevant to the data items listed above (e.g., lists of 

impaired coastal waters, lists of management measures to be adopted, legal and 

geographical jurisdiction of agencies implementing management measures). The 

States acquired all of the information from existing sources.

 Analyzed the information and constructed the Coastal Nonpoint Program, 

including revising coastal zone boundaries and planning new or modified State 

and local regulations to implement the Coastal Nonpoint Program.

 Wrote draft and final Coastal Nonpoint Programs, provided notice and 

opportunity for public comment on their programs, and submitted the programs to 

EPA and NOAA for approval.

Under this ICR renewal, States that have received conditional approval for their 

Coastal Nonpoint Programs will be required to submit additional information to obtain 

final program approval.

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

EPA and NOAA activities under this ICR renewal will consist of the review of 

Coastal Nonpoint Program amendments and/or informational updates submitted by States 

to fulfill specified conditional approval requirements necessary to obtain final program 

approvals, as well as review of initial Coastal Nonpoint Program submittals by new State 

program entrants.

5(b) COLLECTION METHODOLOGY AND MANAGEMENT
11

The States will submit amendments to their Coastal Nonpoint Programs when 

such amendments are required to fulfill and therefore remove the conditions set out in the 

conditional approval and obtain final program approval. New State program entrants will 

submit initial Coastal Nonpoint Programs for review by EPA and NOAA.

5(c) SMALL ENTITY FLEXIBILITY

This section is not applicable because respondents are States and Territories, and 

are not small businesses or organizations as defined in the Regulatory Flexibility Act, 5 

U.S.C. Sections 601(3) and (4).

5(d) COLLECTION SCHEDULE

There is no uniform schedule for the submission of State amendments to Coastal 

Nonpoint Programs when such amendments are required to fulfill conditions established 

in conditional approvals. Rather, EPA and NOAA have set forth specific schedules for 

completion of conditions tailored to each State’s program.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN

The burden hour estimates for the original ICR were based upon discussions with 

Regional NOAA and EPA personnel who have direct contact with State respondents and 

past experience with Coastal Nonpoint Program submittal procedures. Burden estimates 

for specific elements were also acquired from a small sample of State respondents 

(Wisconsin, Maine, North Carolina, and Washington). The detailed breakdown of burden 

estimates for each activity is presented in Table 2.

Based on our analyses of State Coastal Nonpoint Programs that have been 

submitted to EPA and NOAA under Section 6217, we have estimated that the collection 

burden under this ICR renewal for the conditionally approved programs will be 

approximately 41 percent of the burden estimated in the original ICR (12 respondents in 

2013 versus 29 original respondents). This estimate is based on States’ successful 

completion of the majority of program elements, the additional work already underway

by many States to complete program elements that require further development, and the 

entrant of a new State Coastal Nonpoint Program in 2014. In addition, while States will 

submit information under this ICR renewal more than once to address different aspects of 

their Coastal Nonpoint Programs that require additional work specified under a 

conditional approval, other States may not submit any information under this ICR 

renewal because the conditions in their conditional approvals may be resolved through 

State rulemaking or legislative processes as a result of other forces at work or as a result 

of investigations conducted for other reasons that support exemptions to existing 

conditions. Therefore, the estimate of the collection burden under this ICR renewal is an 
12

approximate prediction.

6(b) ESTIMATING RESPONDENT COSTS

The associated collection under this ICR renewal will have a moderate financial

impact on the respondents.

(i) Estimating Labor Costs

This respondent labor cost estimate under the original ICR was based upon an average 

hourly rate and benefits comparable to a Federal GS Grade 10, Step 7. The total hourly

rate, including benefits, was estimated in the original ICR to be $33. For this ICR 

renewal, the estimated hourly rate was increased to $37 to account for inflation. Table 2 

presents a detailed breakdown of the labor cost estimates for each activity.

TABLE 2. ESTIMATE OF BURDEN TO STATE RESPONDENTS WITH 

CONDITIONALLY APPROVED PROGRAMS, LABOR COSTS

Collection Activity

-A -

Burden 

hours per 

respondent

-BNumber of 

respondents

-CPersonhours

C = A x B

-DCost in 

Dollars

D = C x $37

1. Review documents

a. Program guidance

b. Technical guidance

1

4

12

12

 12

 48

444

 1,776

2. Plan activities 16 12 192 7104
13

3. Collect information

a. Identify general NPS categories 

and identify general management 

measures

b. Technical documentation for 

alternatives

c. Identify impaired coastal waters

d. Identify land uses

e. Identify critical coastal areas

f. Identify supplemental management 

measures

g. Identify lead agencies

h. Schedule

i. Legislative/administrative authority

j. Coordination mechanisms

k. Operation & maint. procedures

l. Inspection procedures

m. Monitoring procedures

n. Coastal zone boundaries

o. Technical assistance options

p. Public participation mechanisms 

70

10

4

24

10

16

4

12

15

15

8

8

26

4

4

4

12

12

12

12

12

12

12

12

12

12

12

12

12

12

12

12

 840

 120

 48

 288

 120

 192

 48

 144

 180

 180

 96

 96

 312

 48

 48

 48

31,080

 4,440

 1,776

10,656

 4,440

7,104

 1,776

5,328

6,660

6,660

3,552

 3,552

11,544

1,776

1,776

1,776

4. Compile, review and analyze 

information

a. Develop State and local regulations

b. Revise coastal zone boundaries

c. Other analysis

60

5

30

12

12

12

 720

 60

 360

26,640

 2,220

13,320

5. Write Coastal Nonpoint Program

a. Draft program report

b. Final program report

10

15

12

12

 120

 180

 4,440

 6,660

6. Recordkeeping requirements Not 

applicable

- - -

TOTAL: ALL BURDEN ITEMS 375 12 4,500 $166,500

(ii) Estimating Capital and Operations and Maintenance Costs

No capital costs or operation and maintenance costs are associated with this ICR

renewal.

(iii) Capital/Start-up Operations and Maintenance Costs

No capital/start-up operation and maintenance costs are associated with this ICR

renewal.
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(iv) Annualizing Capital Costs

As there are no capital costs associated with this ICR renewal, this section is not 

applicable.

6(c) ESTIMATING AGENCY BURDEN AND COST

The agency burden in the original ICR was based on discussions with EPA 

Regional 319 Coordinators and NOAA Regional personnel. The cost was based upon an 

average hourly rate of $33, which included salary and benefits for a Federal employee 

Grade 10, Step 7. The total number of burden hours in the original ICR to the Federal

government was estimated to be 13,240, and the total cost was estimated to be $436,920. 

Based on comments received from NOAA in 2003, these figures were later determined to 

be underestimates.

Under this ICR renewal, the Federal government burden will include the burden 

associated with EPA and NOAA review of amendments submitted by States to fulfill 

conditional approval requirements. Altogether since CZARA passed into law in 1990, 34 

States and Territories have developed and submitted coastal nonpoint programs to EPA 

and NOAA for approval, and that number will increase to 35 by 2014. The Federal 

burden for this ICR accounts for review of the remaining elements of the 12 State coastal 

Nonpoint Programs that remain not yet fully approved. To calculate the Federal

government burden, the estimated hourly rate was increased to $37 to account for 

inflation. Table 3 presents a breakdown of the burden and cost estimates for each agency.

TABLE 3. ESTIMATE OF BURDEN TO FEDERAL GOVERNMENT

Collection Activity -A -

Burden hours

(personhours)

-BPersonnel 

Costs

A x $37.00

-COther direct 

costs

-DTotal Dollars

B + C

1. EPA review of State Coastal 

Nonpoint Program submittals

9,692 $358,604 - $358,604

2. NOAA review of State 

Coastal Nonpoint Program

submittals

12,000 444,000 - 444,600

TOTAL 24,191 $802,604 - $802,604

6(d) ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN 

AND COSTS
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The universe of respondents is precisely known to be comprised of the 11 States 

that remain conditionally approved with regard to their Coastal Nonpoint Programs and 

one (1) new State program entrant in 2014.

The total burden and costs for these 12 respondents are summarized in 6(e)(i), 

with detail provided in Table 2.

6(e) BOTTOM LINE BURDEN HOURS AND COSTS/MASTER TABLES

(i) The Respondent Tally

States

The one-time total burden to the respondents is:

Total hours (375) X Number of Respondents (12) = 4,500 hours

The one-time total cost to the respondents is:

Total cost (4,875 X $37/hour) = $166,500

EPA assumes the respondents will perform the burden items over the three-year 

ICR renewal period. Thus, the average annual burden/cost is equivalent to the total onetime burden/cost divided by three years:

Total burden (4,500 hours)/3 years = 1,500 hours/year

Total cost ($166,500)/3 years = $55,500/year (for all respondents)

Total cost per respondent per year = $55,500/12 respondents = $4,625

The master table for respondent burden and costs is:

Total Burden Total

Hours Costs

Bottom Line 4,500 hours $166,500

(ii) The Agency Tally

The total cost to the Federal government is estimated at 21,692 hours, or 

$802,604. EPA assumes the Federal government will perform the collection activities 

over the three-year period of this ICR renewal.

EPA burden hours are estimated at approximately 3,231 hours per year over three 

years, resulting in a total burden of 9,692 hours.

NOAA burden hours are estimated at approximately 4,000 hours per year over 

three years, resulting in a total burden of 12,000 hours.
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Total Federal Agency Hours = 9,692 (EPA) + 12,000 (NOAA) = 21,692

The average annual burden/cost is equivalent to the total burden/cost divided by

three years:

Total burden (21,692 hours)/3 years = 7,231 hours/year

Total cost at $37/hour = ($802,604)/3 years = $267,535

The master table for agency burden and costs is:

Total Burden Total

Hours Costs

Bottom Line 21,692 hours $802,604

(iii) Variations in the Annual Bottom Line

For many reasons, variations for State respondents and for Federal agencies are 

problematic to estimate. Some of the factors that affect these variations are described in

section 6(a). In general, activities associated with Federal approvals of State Coastal 

Nonpoint Programs have decreased over time, both for State respondents and for Federal

agencies, as more States have achieved full program approvals. Indeed, during the first 

several years of the Coastal Nonpoint Program development period, there were 

comparatively higher levels of activity among both the Federal partners (who developed 

program guidance and conducted “threshold reviews” of initial State program submittals) 

and the State respondents (who submitted materials for most or all 56 management 

measures specified in statutorily mandated program guidance, as well as information on 

State enforceable policies and mechanisms). Since that initial start-up period, activity has 

declined. However, activity levels for CZARA remain moderate among both State 

respondents and Federal agencies. Two factors seem to account for this:

1) Five States joined the Coastal Nonpoint Program as late entrants: 

Georgia, Minnesota, Ohio, Texas and Indiana, and a sixth state (Illinois) 

will come onboard in 2014. Minnesota’s program was approved in July

2006.

2) Among the 29 original participating States and Territories, the 7 States 

that remain conditionally approved have challenging and unique 

obstacles that account for their continued conditionally approved status, 

and these States, along with the Federal partners (NOAA and EPA), are 

working to overcome the more difficult hurdles that remain. So while 

the number of conditions per State has greatly decreased, the few

conditions that remain are the most challenging to resolve, and thus 

require disproportionately greater efforts that were not originally 

anticipated.

6(f) REASONS FOR CHANGE IN BURDEN
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The respondent burden in the original ICR is is a net reduction under this ICR 

renewal because States have already completed most activities in this one-time CZARA 

Section 6217 requirement and because EPA and NOAA fully approved New Jersey’s 

Coastal Nonpoint Program in late 2009 (since the previous ICR was published).

Additionally, one State that was conditionally approved (Alaska) ceased its participation 

in this program in 2011 by choosing not to participate in the NOAA-admninistered 

CZMP. This reduction was partially offset by the anticipated addition of Illinois as a new 

program entrant in 2014.

6(g) BURDEN STATEMENT

The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 375 hours per response. Burden means the total time, 

effort, or financial resources expended by persons 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 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 No. EPA-HQ-OW-2006-0394, which is 

available for online viewing at www.regulations.gov, or in-person viewing at the Office 

of Water Docket, Environmental Protection Agency, Public Reading Room, Room 3334, 

EPA West Building, 1301 Constitution Ave., NW, Washington, DC 20004. The EPA 

Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday 

through Friday, excluding legal holidays. The telephone number for the Reading Room is 

202-566-1744, and the telephone number for the Water Docket is 202-566-2426. 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. Once in the system, select “search,” then key in the Docket ID Number 

identified above.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
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This section is not applicable because no statistical procedures are employed for 

the data collection.