1 **ICR SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **(EPA) 1.**  **Identification of the Information Collection 1(a)**  **Title of Information Collection** State Small Business Stationary Source Technical and Environmental Compliance Assistance Programs (SBTCP) Annual Reporting Form (Renewal) , EPA ICR Number 1748.10, OMB Control Number 2060
- 0337 **1(b) Short Characterization (Abstract)**  This IC R is an annual collection of State Small Business Environmental Assistance Program s (SBEAP) gathered b y the EPA Asbestos Small Business Ombudsman (ASBO) team. Information is collected to measure activities and accomplishments from the preceding calendar ye ar . Th e collection of data is used by

the EPA A SBO to evaluate the progress of state implem entation of Section 507 of the 1990 Clean Air Act Amendments. The reports the EPA ASBO generates based off of the data collection under this ICR may be used by

Congress ; by

states, both externally

and internally

to manage and highlight their programs; by n ational small business trade associations, and by other f ederal agencies, primarily

the Small Business Administration, in evaluating the effectiveness of this ty pe of assistance effort. The information that is collected is evaluated, summarized, and deve loped into a report, which is made available to the Congress , as required under Section 507 of the Clean Air Act’s (CAA) Amendments of 1990. The information collected will reveal trends in program advancement, budget changes, and numbers of small businesses assisted . The outcome questions provide a foundation for reporting on the effectiveness of the 507 program efforts
. This information is valuable to Congress , federal stakeholders , as well as the small business community because it highlights state program accomplis hments, as well as progress toward improved environmental performance
. A total of 53 respondents will complete the survey . Specificall y, information collected will include the following: program contacts; program resources (budget and staffing), programmatic structure (which can vary greatl y from state to state), assistance activities, outreach efforts with the small business community, ty pes and numbers of such activities , technical assistance that their program provides to small businesses, as well approximate figures for the number of businesses that they have assisted each year. The data collected is stored in a spreadsheet that is made available to programs upon request. The EPA A SBO does not mandate any requirement on file storage and retention. Each state may set its own requirements on the length of time and the manner in which they store and retain their files. The Asbestos Small Business Ombudsman Team will evaluate, review, summarize, and compile the inf ormation for preparation of the Status of State Small Business Compliance Assistance Programs report.2

**2. NEED AND USE OF THE COLLECTION**  **2(a) Need/Authority for the Collection**  This collection of information is in response to the direction for EPA’s Small Business Ombudsman to monitor the program under Section 507, Small Business Stationary Source Technical and Environmental Compliance Assistance Program (SBTCP) (d) of the Clean Air Act as amended in 1990, Publi c L aw 101
- 549, November 15, 1990. This Act directs EPA to monitor the 507 programs and to provide a periodic report to Congress
. **2(b) Practical Utility/Users of the Data**  The EPA A SBO will compile the results of this collection into a report, including an objective summary of conclusions and recommendations relative to funding or other environmental legislative consideration. This information will be made available online for Congressional staff and committees interested in environmental matters and small business assistance activities at the state and local levels. In addition, this information will be made available to small business trade associations for their use in promoting the utility

and viability

of assistance programs, to EPA Headquarters and Regional Offices, to other f ederal agencies such as the Small Business Administration, to all state small business ombudsmen and small business environmental assistance program directors, to state g overnors , and other interested parties
. Both state and f

ederal officials are able to use the information generated in the report to evaluate how well the programs are functioning, and to plan how to render m ore effective and less costly assistance. The constantly evolving nature of these programs means that thi s information provides key details to policy makers at the f

ederal, state, and local levels. The Agency

has shared this information within its periodic reports with all the stakeholders listed above. The State 507 programs have found this process to be a valuable tool for learning about other program' s strengths and innovations. It promotes a continual process of sharing ideas across programs. The EPA A SBO is also a resource for stakeholders and provides relevant data and narratives to policy makers at the f

ederal and state levels upon request. The A SBO relies on th e information collected to support recommendations made to other offices within the EPA on how to effectivel y assist small business efforts to improve their environmental compliance
. **3. NON**  **- DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA**  **3(a) Non**  **- duplication**  In formation is being requested from and about programs mandated under Section 507 of the CAA of 1990; therefore, this information is unique to this collection. **3(b) P**  **ublic Notice Required Prior to ICR Submission to OMB** Public notice on the renewal of this I CR was published in the Federal Register on December 11, 2014 under 79 FR 73576
. This notice indicates that the ICR is up for renewal and that public3

comments on the previous burden estimates and any proposed changes are being sought by the EPA Office of Small Business Program, which the ASBO is located under
. There were no comments received. **3(c) Consultations**  In preparing this ICR and in revising the Reporting Form, the EPA A SBO worked with a group of staff that were willing to discuss the data collection forms and possible ways to improve its efficiency
. The subcommittee consist ed of representatives from the 507 programs. The following were contac ted: Tony Pendola , North Carolina, Small Business Ombudsman 919
- 707
- 8112, tony .pendola@ncdenr.gov Sara Johnson, New Hampshire Small Business Ombudsman/Small Business Environmental Assistance Provider 603
- 271
- 1379, sara.johnson@des.nh.gov
Donavan Grimwood , Tennessee Small Business Environmental Assistance Provider 615
- 532
- 4966, Donavan.Grimwood@tn.gov Christine Hoefler, Colorado Small Business Environmental Assistance Provider 303
- 692
- 3148, christine.hoefler@state.co.us
Those listed above were provided the opportunity to comment on the burden associated with the standard
. The general consensus was that the current collection form adequatel y captures the program metrics for the majority of assistance efforts. **3(d) Effects of Less Frequent**  **Collection** The submission of this information on less than an annual basis will make it difficult for EPA to monitor and adequately report on the effectiveness of the program which is outlined under Section 507 of the CAA. Annual reporting assures uniformity and consistency
. Many

of the states also use their annual data collected from the EPA SBO report form to organize and communicate their effectiveness and program success to their management and overall promotion within the ir own state. **3(e) Ge**  **neral Guidelines** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, Section 1320.5. **3(f) Confidentiality** **/Sensitive Questions** In formation in the Annual Report is aggregated and i s not of confidential nature. None of the information collected b y this action results in or requests sensitive information of any nature
.4

**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents/SIC Codes**  These departments/agencies ty picall y are responsible for the conduct of the State 507 Programs. Respondents will be one of the following state offices
. **Respondents/SIC Codes** Environmental Agency SI C 9511 Commerce or Economic Development Department SI C 9611 Governor’s Office SI C 9111 Ombudsman’s Office SI C 9511 **4(b) Information Requested**  A cop y of the reporting form is attached as Attachment A
. **(i )**  **Data Items** States will report on the data items shown in the following table. Each item is designated as a record keeping or reporting item; activities that are customary and usual business practices (CBP) also are indicated, as required in the foll owing section. The EPA SBO imposes no record keeping requirements on any respondent. Each state may have its own requirement for retention of records. There have been no changes to the data items since the last clearance.

**DATA ITEM RECORD KEEPING**  **REPORTING CBP**  **Program Information** Name of State, Territory, or Local Agency X X Reporting Form Contact X X Combined SBO/SBAP/CAP Budget X X Budgetary Funding Sources X X **Staffing** X X SBO/SBAP FTEs X X Status of CAP X X **Outreach and Technical Assistance** Air
- only or Multimedia Assistance X X Data on Offered Services/Activities X X Data on Promotional Activities X X Data on Website Activities X Significant Accomplishments, Awards, Highlights X X Outcome Measures X X5 **(ii) Respondent Activities (see**  **draft survey**  **below)** The respondents will engage in the following activities to assemble, submit, and store the data items l isted in the previous section. These activities reflect the items of burden mandated b y the 1995 Paperwork Reduction Act. Review Instructions

– The instructions are straight forward , include several examples , and makes note that the Form will remain the same f o r the next three years . Acquire, Install, and Utilize Technology and Systems
-- Information requested in this I CR is ty pical of information gathered as part of good business practices and anticipates future data needs . No special technology

or systems are required for this collection . H owever programs will be encouraged to share methods they

have developed to make the data collection easier
. Adjust the Existing W

ays to Comply with Any Previously Applicable Instructions and Requirements
-- The Reporting Form will remain the same from year to year. Respondents have consistentl y found the basic structure and breadth of questions to remain the same as the previous ly approved versions
. Search Data Sources
-- Gathering and updating information is an annual task and states have been reporting on the activities of their programs since 1995. Most data items requested are in the current Form and all data are collected as a customary business practice
. Complete and Review the Collection of Information
-- Programs will provide data and one narrative to complete their submissions. Most of the information should be readil y available. For their narrative submission, s tates are encouraged to select examples that be st demonstrate the operations and accomplishments of their programs
. Recording and reviewing the required information should be s traightforward and procedural. Completion and review of the Reporting Form is anticipated to be a cooperative effort among the key program staff. Transmit or Otherwise Disclose the Information
-- The Reporting Form will be given to the respondents via email . Each respondent will then complete the information and return it to the A SBO using the same method
. This approach will ena ble the A SBO to efficientl y compile the information from the individual p rograms and prepare a periodic report. Store, File, and Maintain
-- The EPA A SB O does not mandate any requirement on file storage and retention. Each state may set its own requirements on the length of time and the manner in which they store and retain their files. **5. THE INFORMATION COLLECTED**  **-- AGENCY ACTIVITIES, COLLECTION**  **METHODOLOGY, AND INFORMATION MANAGEMENT 5(a)**  **Agency Activities** The electronic Reporting Form wil l be available to states and territories near the be ginning of each calendar ye ar. Respondents will have at least 60
- 90 days to respond to the request for6

information. The EPA’s SBO will answer questions from the respondents regarding the Reporting Form. The EPA A SBO will collect , assemble, anal yz e, and store the information provided b y the 507 programs. The ASBO will use this information to prepare the periodic report made available to the Congress
. The periodic r eport, which will contain summary information developed from the data collection forms from the states , a perspective on the materials provided, selected highlights, conclusions, and recommendations on the overall effectiveness of the 507 program
. The EPA A SBO will maintain copies of state submittals and the Annual Report electronically
. **5(b) Collection Methodology and Management**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. 1. Respondents receive electronic Reporting Form and instructions via email 2. Data quality will be checked upon receipt of each state’s Reporting Form during anal ys is and the f

inal Review 3. Data is processed using spreadsheet software and input manually 4. Data is made publicl y accessible through Period Report made available to Congress and is accessible on
- line **5(c) Small Entity Flexibility**  The completion of the Reporting Form does not require any input or action by any small entity
. **5(d) Collection Schedule**  This is an annual (calendar year) collection of information on the states’ activities, accomplishments, and data outputs under Section 507 of the CAA. A typical reporting schedule would look as follows:

 Electronic Reporting Form is made available to states: January
- March  States complete Reporting Form: March
- June  State agency

submits reporting form to EPA SBO: M ay 31 with option for extension if needed, provided on a case by case basis.  EPA A SBO Transfers Data to Spread sheet and conducts Anal ys is: June/July  Data is made available to state programs: July or as requested  EPA ASBO prepares a periodic report (per the 1990 CAA Amendment requirements) and obtains final EPA approvals: Ty pically on a bi
- annual basis  EPA A SBO makes the report available to congress : Fall of the Reporting Year, which is posted online with a memo to the Congress, notifying them of the report and how to access it
.7

**6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION**  **6(a) Estimating Respondent Burden**  **Hours** There are a total of 53 respondents with a total of 40 burden hours in responding to this data collection request. On average, the requested information can be compiled readily and maintained by the state within 40 hours (assuming the state organization continuously maintains their records in a reasonabl y efficient manner) using experienced professional or technical staff. The 40
- hour forecast includes 36 hours for record keeping and 4 hours for reporting the required information. Burden hour estimates are based on the results of a pretest of the original survey information and report preparation cycle , and experience with similar past surveys . The revised 2012 Reporting Form (which continues to be used to collect data) was discussed in great detail prior to the 2012 I CR renew al package with state program staff, included state ombudsmen and/or small business assistance program managers from ten of the 53 Section 507 reporting state programs (i.e., comprising the 50 states, the District of Columbia, the Virgin Is lands, and Puerto Rico). They formulated a general consensus of how long it would take to complete the reporting form and who would likely be responsible from each state to complete the task. The information requested was confirmed to be normal program activity informati on the 507 program s collect on an ongoing basis. Where a few state environmental agencies have delegated or contracted management of their technical assistance program, this information is part of the project management responsibi lities. This requested rep orting information typically would be compiled b y experienced professional or technical staff. **6(b) Estimating the Respondent Burden**  **Costs** The burden costs were derived from the labor hours, which remain consistent from the current ICR collection of 53 respondents, but have slightly increased due to inflation and the increase in salary costs for respondents. Labor rates were derived from the Bureau of Labor Statistics, Employ ment Cost Trends, Table 4: State and Local Government by Occupational and Industry Group (http://data.bls.gov/cgi
- bin/print.pl/news.release/ecec.t04.htm). Please refer to Worksheet 1. **6(c) Estimating Agency Burden and Cost**  Agency rates are b ased on the US Office of Personnel Management 2015 General Sche d ule Locality Pay Tables
. EPA estimates an average hourly regional labor cost of $ 68.56 for GS
- 15, $ 49.32 for GS
- 13 ; and $ 41.69 for GS
- 12 (all hourl y rates are for step 5)
. Refer to Worksheet 2 **6(d) Estimating the Respondent Universe and Total Burden and Costs**  The Respondent Burden hours have remained consistent and have not change d since the last approved ICR. The burden hours continue to total 40 hours per each respondent. The total cost of these burden hours has slightly increased due to inflation. The total respondent cost is estimated to be8

$ 112,10 5.60 per year, which is a $7,441.6 increase from the 2012 estimate of $104,664, due to inflation and wage rate increases. Refer to Worksheet 1. The Agency

Burden has increased both in burden hours and in direct labor costs. Due to diminish financial resources EPA’s Ombudsman office is compiling the data forms and reports without contractor support that was once avail able to assist in this effort. The previous 2012 I CR package included the contract support rates but that has been omitted from this package. EPA staff hours have increased to fill in this gap of support. Activities include Review/update survey instrument (not including the cost of renewing the IC R every three years), maintaining a master informational data base, answering respondent questions, review of submissions for accuracy and completeness, preparing a report from the data, Agency review and approval process, and distributing the report. Refer to Worksheet 2. The Respondent Universe Burden and Costs is lower in both hourl y burden and cost. The hours were less overall due to moving the data collection, review and reporting in
- house, rather than having both agency

and contractor hours and costs included as in previous years. The total cost is roughl y $383,000 for the full three ye ars of the IC R , which is significantl y lower than the previous 2012 I CR package of $418,776. Refer to Worksheet 3.

**6(e) Bottom Line Burden Hours and Cost Tables**  Fifty
- three states and territories will complete the Reporting form annuall y during the period covered by

this ICR. No significant variation (more than 25 percent) in the annual reporting/record keeping burden over the life of this I CR is expected for the agency or the respondents. Please see Worksheets 1, 2 and 3
. The cost over the entire period covered by the ICR is in Table 3. **6(f) Reasons for Change in Burden**  There is no change in the total estimated respondent burden compared with the ICR currentl y approved b y OMB.

**6(g) Burden Statement**  The annual public reporting and recordkeeping burden for this collection is estimated to average 40 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide informati on to or for a federal agency
. This inc ludes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purpose of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing informati on; adjusting the existing ways to comply with any previous applicable instructions and requirements; train personnel to respond to the collection of information; and transmit or other wise 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 number for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15. To comment on the Agency's need f or this information, the accuracy of the provided burden estimates,9

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 EP A
- HQ
- OA
- 2007
- 0706 , which is available for online viewing at www.regulations.gov , or in person viewing at the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday

through Friday , excluding legal holidays. The telephone number for the Reading Room is (202) 566
- 1744, and the telephone number for the OEI Docket is (202) 566
- 1744 . An electro nic 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 availa ble electronically
. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA
- HQ
- OA
- 2007
- 0706 and OMB Control Number 2060
- 0337 in any correspondence.10

**WORKSHEET 1: ANNUAL RESPONDENT BURDEN/COST ESTIMATE**

* Based on Prof/Tech rate of $ 52.88 per hour, a $3.51 an hour increase from the 2012 rate of $ 49.37 per hour

**WORKSHEET 2: ANNUAL AGENCY BURDEN/COST ESTIMATE GS Level**  **Agency Burden**

**Hours Federal pay** 

**rate (step 5) Annual** 

**C ost**  **Capital**

**Costs O & M** 

**Costs Total Costs**  GS15 75 $ 68.56 /hr $ 5,142 0 0 $ 5,142 GS1 3 130 $ 49.32 /hr $ 6,411.60 0 0 $ 6,411.60 GS12 100 $ 41.69 /hr $ 4,169 0 0 $ 4,169 Total 305 $ 15,722.60 0 0 $ 15,722.60

**WORKSHEET 3: COSTS OVER THE ENTIRE PERIOD COVERED BY THE ICR**  **Total Annual Costs Costs over 3 years**  Agency $ 15,722.60 $ 47,167.80 All respondents $ 112,105.60 $ 336,316.80 TO TAL $ 383,484.60 **Collection Activity**  **Burden**

**Hours Total Labor** 

**Costs Per Year** * **Capital**

**Costs O & M** 

**Costs Respondent** 

**Universe Total Hours** 

**Per Year -**  **all respondents**  **Total Cost**

**Per Year****** **all respondent**  **s** Annual Recordkeeping burden 36 $ 1,903.68 0 0 53 1 , 908 $ 100,895.04 Annual Reporting Burden 4 $ 211.52 0 0 53 212 $11,210.56 TO TALS 40 $ 2,115.20 0 0 53 2,120 $ 112,105.60