1

SUPPORTING STATEMENT

1. Identification of the Information Collection 

Title: Brownfields Program – Accomplishment Reporting (OMB Control Number 2050-

0192; EPA ICR No. 2104.06). 

This is a request to renew an existing Information Collection Request (ICR). This ICR 

covers the collection of information from those organizations that receive cooperative agreements 

from EPA under the authority of subtitle A and subtitle C of the “Small Business Liability Relief 

and Brownfields Revitalization Act” (Public Law 107-118, January 2002). Subtitle A of the Act 

amends the Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA), as amended, and authorizes EPA to award grants or cooperative agreements to states, 

tribes, local governments, and other eligible entities to support the assessment and cleanup of 

brownfields properties and subtitle C authorizes a noncompetitive $50 million program to 

establish and enhance state and tribal response programs. The authority for these financial 

assistance programs is codified at CERCLA 104(k) and CERCLA 128(a) respectively. Congress 

appropriates specific amounts of funding for both programs in EPA’s State and Tribal Assistance 

Grant account.

With this ICR, EPA’s Office of Brownfields and Land Revitalization (OBLR) seeks 

authorization to collect information from cooperative agreement recipients (recipients) using 

several standard forms that will streamline the data collection effort and improve the quality of 

information collected. The information collected under this ICR supplements the minimum 

reporting and record keeping requirements that recipients are subject to under 2 CFR Part 200 and 

2 CFR Part 1500. EPA estimates that all respondents who voluntarily respond to this information 

collection by electing to participate in the Brownfields program have determined that the expected 

benefits of participation outweigh any burden associated with preparing the response. 

2. Need for/Use of the Collection

Under CERCLA 104(k) states, tribes, local governments, and other eligible entities may 

receive cooperative agreements to: 

(1) inventory, characterize, assess, and conduct planning and community involvement 

related to brownfields sites; 

(2) carry out cleanup activities at brownfields sites; 

(3) capitalize revolving loan funds and provide subawards for cleanup activities; and

(4) support the research, technical assistance and training including the creation and 

implementation of environmental job training and placement programs. 

Under CERCLA 128(a) States and tribes may receive cooperative agreements to:
2

(1) establish or enhance a response program that includes elements such as:

a. Surveys and inventories of brownfield sites.

b. Oversight and enforcement authorities including legislation, regulations, 

procedures, or guidance that would establish or enhance the legal structure of the 

program.

c. Opportunities for public participation in the process of developing a public 

record for cleanup decisions and other site activities.

d. Site-specific assessment and cleanup activities.

e. Approval of cleanup plans and verifications that response actions are complete.

(2) capitalize a revolving loan fund for brownfields remediation under CERCLA 

104(k)(3); and

(3) purchase environmental insurance, develop a risk sharing or indemnity pool, or other 

insurance mechanisms for the response program.

Under CERCLA 101(39), a brownfields site means real property, the expansion, 

redevelopment, or reuse of which may be complicated by the presence or potential presence of a 

hazardous substance, pollutant, or contaminant. Brownfields sites may also include property 

contaminated with petroleum. For funding purposes, EPA uses the term “brownfields 

property(ies)” synonymously with the term “brownfields site(s).” 

While the Agency collects basic cooperative agreement information as part of its Federal 

stewardship responsibilities to manage and oversee recipient activities and expenditures under 2 

CFR Part 200, OBLR needs additional information from recipients to be reported in a consistent 

manner in order to evaluate the effectiveness of the program and to report on program activities 

and accomplishments to Congress and other program stakeholders. Specifically, OBLR has used 

and will continue to use the information collected from recipients to oversee the activities carried 

out using cooperative agreement funds, to evaluate program implementation and effectiveness, 

and to meet the Agency’s responsibilities under the Government Performance and Results Act to 

report on OBLR’s accomplishments. The information collection activities covered by this 

renewed ICR are intended to: (1) continue to improve the alignment of reporting requirements 

with programmatic performance measures; and (2) simplify and standardize reporting 

requirements to reduce uncertainty and burden imposed on recipients. Without the information 

collection, OBLR would have limited access to information needed to effectively assess the 

relationship between those activities funded by EPA’s Brownfields cooperative agreements and 

the intent of Congress with the passage of the Brownfields Amendments. 

3. Non-duplication, Consultations, and Other Collection Criteria
3

3(a). Non-duplication – There is no other known source for the information that EPA 

seeks under this ICR. Moreover, this ICR supplements, and does not duplicate, the information 

that EPA collects as part of its reporting and record keeping provisions under the Agency’s 

general assistance regulations at UGG 2 CFR Part 200 which became effective December 26, 

2014. Exhibit 1 identifies the tasks and burdens of recipients that are covered under other OMBapproved ICRs. This ICR addresses the burden imposed on recipients and EPA associated with 

the reporting requirements that are unique to cooperative agreements awarded by EPA under 

authority of CERCLA 104k and CERCLA 128(a).

Exhibit 1: Grant Burdens Covered Under Other Agency ICRs

Task/Burden Authority Agency Approved ICR

Preliminary Grant Proposal 2 CFR Part 200 OMB 2030-0020

Final Grant Proposal 2 CFR Part 200 OMB 2030-0020

Budget Sheets 2 CFR Part 200 OMB 2030-0020

Quarterly Progress Reports 2 CFR Part 200 OMB 2030-0020

Notification of Significant 

Developments

2 CFR Part 200 OMB 2030-0020

Procurement Reports 2 CFR Part 200 OMB 2030-0020

Financial Reports 2 CFR Part 200 OMB 2030-0020

Project Records 2 CFR Part 200 OMB 2030-0020

3(b). Public Notice Required Prior to ICR Submission to OMB. The first notification of 

the Agency’s request for the renewal of this ICR was published in the Federal Register at 81 FR 

10859 on March 2, 2016. It did not receive any comments. 

3(c). Consultations – EPA has more than 20 years of experience managing Brownfields 

cooperative agreement programs that awarded more than 3,700 cooperative agreements to state, 

local, and tribal governments to address brownfields properties. For these Brownfields 

cooperative agreements, EPA staff has worked closely with the recipients to help them participate 

in the program and address their brownfields properties. As such, EPA has a detailed 

understanding of the activities that recipients undertake and the burden they incur for voluntarily 

participating in EPA’s cooperative agreement programs. In addition, during the preparation of the 

initial ICR in 2003 and the reporting forms that are included, EPA contacted eight Brownfields 

recipients to ask them specific questions about the burden associated with completing the draft 

forms included in this ICR. Recipient responses form the basis of EPA’s initial calculations of 

the burden hours and costs. 

Since the initial ICR, there have been several revisions to help improve the original 

Property Profile and Job Training Reporting Forms to ensure they are as efficient as possible for 

cooperative agreement recipients. For the first renewal in 2006, the ICR was expanded to include 
4

reporting from CERCLA 128(a) recipients. To do so, EPA consulted with several State and Tribal 

representatives when working on modifications to the Property Profile Form. For the second 

renewal in 2009, EPA added additional fields to the Property Profile Form. EPA contacted eight 

Brownfields recipients to ask them specific questions about the burden associated with 

completing the draft new fields for the Property Profile Form included in the renewal. In 2012, 

EPA made no changes to the Property Profile Form and Job Training Reporting Form. 

For this renewal of the ICR, EPA made changes to streamline some questions on the 

Property Profile Form, including making it easier to identify the correct geographical location of a 

property, and avoid duplicate property records in ACRES. Additionally, EPA created a new form 

for the Area-Wide Planning recipients to make it easier for them to report their accomplishments 

to EPA. Moving forward, Area-Wide Planning recipients will only be required to use this new 

form, and no longer need to use the Property Profile Form. Individuals contacted for this revision 

included the following:

1. Harris Byers

Brownfields Project Manager

Stantec

12075 Corporate Parkway Suite 200 Mequon WI 53092-2649

Phone: (262) 643-9174; Cell: (414) 581-6476; Fax: (262) 241-4901

Harris.Byers@stantec.com

2. Michele Oertel

Federal Funding & Community Relations Coordinator

Indiana Brownfields Program

100 N. Senate Avenue, Room 1275 

Indianapolis, Indiana 46204 

Phone: 317-234-0235; or 800-451-6027, Ext. 4¬0235; Fax: 317-234-1338 

Email: moertel@ifa.IN.gov

www.brownfields.IN.gov

3. Marc Gerdeman

Brownfield Redevelopment Officer

City of Toledo, Division of Env. Services

348 S. Erie St. Toledo, OH 43604

Phone: 419-936-3771 (office); 419-936-3959 (fax)

Marc.Gerdeman@toledo.oh.gov

.

3(d). Effects of Less Frequent Collection – The information collection schedule is 

consistent with the Agency’s reporting schedule for general assistance agreements. Less frequent 

collection may not enable EPA to oversee and manage Brownfields cooperative agreements 

effectively and would lessen OBLR’s ability to report up-to-date and accurate information on 

program activities and accomplishments. In consideration of the burden imposed on recipients, 

EPA has adopted less frequent reporting for the Property Profile Form in which recipients are 
5

required to update and submit the form as notable activities or changes occur at a particular 

property. EPA anticipates that recipients of CERCLA 104(k) assessment, cleanup, and revolving 

loan fund cooperative agreements will submit an updated Property Profile Form to EPA at least

twice but not more than four times over the life of the cooperative agreement. For CERCLA 

128(a) state and tribal response program cooperative agreements, EPA anticipates that recipients 

will submit a Property Profile Form to EPA twice a year in line with the bi-annual reporting 

guidelines. 

3(e). General Guidelines – The information collection is consistent with the guidelines set 

forth in 5 CFR 1320.6 of the Paperwork Reduction Act Guidelines.

3(f). Confidentiality – No confidentiality is provided and no sensitive information is 

collected under this ICR.

3(g). Sensitive Questions – Sensitive questions are not associated with the information 

collection activities performed under Public Law 107-118.

4. Respondents and Information Requested

4(a). Respondents – Respondents under this ICR are those entities who voluntarily elect 

to participate in the Brownfields cooperative agreement programs and receive funding from EPA 

under the authority of CERCLA 104(k) and CERCLA 128(a). Specifically, respondents to this 

information collection include: general purpose units of local government (NAICS Code: 92411); 

land clearance authorities or other quasi-governmental entities that operate under the supervision 

and control of, or as an agent of, a general purpose unit of local government (NAICS Code: 

92411); government entities created by State legislature (NAICS Code: 92411); regional councils 

or groups of general purpose units of local government (NAICS Code: 92411); redevelopment 

agencies that are chartered or otherwise sanctioned by the State (NAICS Code: 92411); States

(NAICS Code: 92411); Indian Tribes other than in Alaska (NAICS Code: 92115); Alaska Native 

Regional Corporations, Alaska Native Village Corporations, and Metlakatla Indian Communities

(NAICS Code:92115); and non-profit organizations1(NAICS Code: 813312).

4(b). Information Requested – The information requested by EPA under this ICR includes 

information from recipients specific to the activities undertaken and the accomplishments that 

result using Brownfields funds. The information to be collected by EPA will vary by the type of 

cooperative agreement awarded to the respondent. 

For Brownfields assessment, cleanup, revolving loan fund cooperative agreements, and 

site-specific activities of the State and Tribal Response Program Cooperative Agreements, EPA 

requires CERCLA 104(k) and CERCLA 128(a) recipients to prepare an initial Brownfields 

Property Profile Form for each property the cooperative agreement intends to address. The 

Property Profile Form compliments the information collected as part of the progress reports 

 

1 For the purposes of the Brownfields grant program, EPA uses the definition of non-profit organization contained in 

Section 4(6) of the Federal Financial Assistance Management Improvement Act of 1999, Public Law 106-107. 

2NAICS Codes as of 2002. Source: http://www.census.gov/epcd/naics02/naicod02.htm 
6

required by the general assistance regulations, and requests basic information about each 

brownfields property covered by the cooperative agreement, such as property name, location, 

parcel number, and size. EPA requires recipients to update the Property Profile Form as notable 

activities or changes occur on the property, but no more frequently than quarterly for CERCLA 

104(k) recipients and no more than twice a year for CERCLA 128(a) recipients. For example, as 

an assessment of the property is completed, recipients are required to complete the portion of the 

Property Profile Form that applies to assessments, and provide basic information to EPA on the 

type of assessment, date of completion, and results or findings of the assessment. Other sections 

of the Property Profile Form collect basic information on cleanups and any redevelopment 

activities that occur on the property, including estimates of the number of jobs that result. 

Brownfields Area-Wide Planning recipients are required to complete an initial Area-Wide 

Planning Reporting Form. Recipients are then required to provide form updates as notable events 

occur pertaining to revitalizing the BF AWP project area is available. 

Environmental Workforce Development Job Training recipients are required to complete 

on a quarterly basis the Job Training Reporting Form. The form asks for information about the 

number of training participants, their success in obtaining employment after the training, and the 

leveraged funds from the job training program. 

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

Management

5(a). Agency Activities – EPA is responsible to Congress and other stakeholders to ensure 

that its resources are being used efficiently and effectively, to evaluate the progress of the 

recipients in meeting the goals of EPA’s Office of Brownfields and Land Revitalization, and to 

share the successes, lessons learned, and best practices among Brownfields recipients. EPA will 

collect the information using standardized forms that minimize the burden on respondents while 

ensuring consistent information that can be easily aggregated and accurately reported. EPA 

program staff will review the information collected to keep current on recipient activities, and will 

enter the information into the Agency’s Assessment, Cleanup, and Redevelopment Exchange 

System (ACRES). EPA uses ACRES to maintain information on all of its Environmental 

Workforce Development Job Training and Area-Wide Planning cooperative agreements and all of 

its Brownfields cooperative agreements’ property specific activities. Acres is also used to, 

develop reports to support management and program evaluation activities, and to report 

accomplishments achieved as part of the Agency’s responsibilities under GPRA. 

5(b). Collection Methodology and Management – EPA will collect data under this ICR 

using a standard set of forms, instructions, and guidance that are designed to simplify and 

facilitate the reporting requirements for recipients. In fulfilling the requirements under the 

Government Paperwork Elimination Act (Public Law 105-277), EPA developed an electronic 

reporting process that will allow recipients to report their data electronically. This electronic 

reporting process is integrated with EPA’s Enterprise Architecture to further streamline the 

Agency’s data management and reporting responsibilities. EPA released the electronic reporting 
7

process in January 2007 and all Brownfields recipients starting from FY 2003 have been given 

access. EPA has modified its reporting guidance and provides training on the electronic reporting 

process. EPA has achieved positive returns in user acceptance of the electronic reporting process 

since its release and the electronic reporting process reduces the burden placed on recipients.

Through continued improvements to ACRES and greater recipient experience, it is estimated that 

the reporting burden will decrease. 

5(c). Small Entity Flexibility – This information collection request is expected to affect 

small governmental jurisdictions, which are defined as governments of cities, counties, towns, 

townships, villages, school districts, or special districts with populations of less than 50,000. This 

definition may also include Indian Tribes, in keeping with the President’s Federal Indian Policy. 

EPA has considered whether to establish different reporting requirements for small entities and 

has determined that: (1) different reporting requirements among recipients will result in 

inconsistent data that may lessen the Agency’s ability to oversee and report on program activities 

and accomplishments; (2) the burden imposed by this information collection is relatively small 

and small entities should not be unduly burdened by the reporting requirement; and (3) the 

Brownfields program is voluntary and respondents who elect to participate in this program have 

determined that the expected benefits of participation outweigh any burden associated with 

preparing the response.

5(d). Collection Schedule – The information to be collected under this ICR for CERCLA 

104(k) assessment, cleanup, and revolving loan fund recipients shall not occur more frequently 

than quarterly, and no more than twice a year for CERCLA 128(a) property specific activities. 

For CERCLA 104(k) assessment, cleanup, revolving loan fund cooperative agreements, and 

CERCLA 128(a) property specific activities, recipients will be required to prepare an initial 

Property Profile Form for each property at which the cooperative agreement starts to address, and 

to update the Property Profile forms for only those properties in which notable activities or 

changes have occurred during the last reporting period. Environmental Workforce Development 

Job Training recipients must complete and/or update their Job Training Reporting Form every 

quarter. Brownfields Area-Wide Planning recipients must complete and/or update their 

Brownfields Area-Wide Planning Reporting Form bi-annually.

6. Estimating the Burden and Cost of the Collection

6(a). Estimating respondent burden - A “unit” burden is the burden incurred by a 

respondent for performing a specific activity that is not covered by another ICR (such as 2 CFR 

Part 200). It should be noted that although CERCLA 104(k) prohibits the use of EPA funds for 

administrative costs, EPA interprets this provision to make the direct cost of complying with 

reporting requirements allowable. The estimated burden is incurred by the following activities:

 Completion of the Job Training Reporting Form;

 Initial completion of the Brownfields Area-Wide Planning Reporting Form;
8

 Periodic updating of the Area-Wide Planning Reporting Form as new activities, 

accomplishments, resources, changes, and other information pertaining to revitalizing the 

BF AWP project area is available. 

 Initial completion of the Brownfields Property Profile Form; and

 Periodic updating of the Brownfields Property Profile Form to report progress on specific

properties undergoing assessment, cleanup, or redevelopment.

The estimated burden for respondents is presented in Exhibit 2. 

If any burdens were found to be imposed in the ICR by a rule that supersedes the 

Brownfields Amendments, those burdens, or a percentage of those burdens, were removed from 

the overall burden calculation in this ICR (see Exhibit 1). 

Exhibit 2 - Annual Respondent Burden and Cost

Activity Unit 

Burden 

(Hours)

Unit 

Labor 

Cost 

(Dollars)*

Total 

Unit Cost 

(Dollars)*

Average 

Number of 

Responses/ 

Year**

Total Burden 

Hours/Year**

Total 

Cost/Year 

(Dollars)**

Initial Completion of 

Property Profile Form 

(CERCLA 104(k): nonprofits)

1 $107.32 $107.32 87 87 $9,337 

Initial Completion of 

Property Profile Form 

(CERCLA 104(k): 

government)

1 $107.32 $107.32 1488 1488 $159,692 

Initial Completion of 

Property Profile Form 

(CERCLA 128(a))

1 $107.32 $107.32 1268 1268 $136,084 

Update of Property Profile 

Form (CERCLA 104(k): nonprofits)

0.5 $53.66 $53.66 60 30 $3,220 

Update of Property Profile 

Form (CERCLA 104(k): 

government)

0.5 $53.66 $53.66 1043 521 $55,967 

Update of Property Profile 

Form (CERLA128 (a))

0.5 $53.66 $53.66 634 317 $34,021 

Initial Completion of AreaWide Planning Form (nonprofits)2 $110.48 $220.96 3 6 $663 

Initial Completion of AreaWide Planning Form

(government)

2 $110.48 $220.96 15 30 $3,314 
9

Review and Process of 

Area-Wide planning 

Reporting Form (nonprofits)

1.5 $110.48 $165.72 2 3 $331 

Review and Process of 

Area-Wide planning 

Reporting Form 

(government)

1.5 $110.48 $165.72 7 10.5 $1,160 

Initial Completion of Job 

Training Reporting Form 

(non-profits)

4 $89.72 $358.90 18 72 $6,460 

Initial Completion of Job 

Training Reporting Form 

(government)

4 $89.72 $358.90 11 44 $3,948 

TOTAL 4,636 3,877 $414,197 

AVERAGE TOTAL COST PER BURDEN HOUR $ 106.85 

* Unit Labor Cost in Dollars reflects a “loaded” rate for benefits and overhead.

** Figures may not sum due to rounding. 

6(b). Estimating respondent costs - To estimate the unit burden (hours) and hourly rate for 

the original information collection activity, EPA relied on its extensive experience working 

closely with Brownfields recipients, as well as in-depth interviews with eight current or former 

Brownfields recipients submitting the Property Profile Form, nine Area-Wide Planning recipients 

specific to this ICR, and six Environmental Workforce Development Job Training recipients.

Those interviewed were shown draft copies of all forms and accompanying instructions and 

guidance that would be used for reporting and asked to estimate: (1) the number of hours that 

would be required to perform each task; and (2) the labor mix required to perform each task (e.g., 

percentage of management, technical, clerical). The data gathered from these interviews were 

then analyzed to estimate the unit burden and labor mix. 

For the renewal of this information collection request in 2016, EPA carried forward the 

same assumptions that were made for the original request. The type of data collected remains 

unchanged, with only structural changes being made by separating the Area-Wide Planning 

questions from the original Property Profile Form into its own reporting form to ensure the lowest 

burden on cooperative agreement recipients. For all form types, the unit labor cost (dollars) for 

this burden estimate is a weighted hourly rate based upon the estimated labor mix and wage rates 

gathered from the U.S. Bureau of Labor Statistics (BLS). 

Data from consultations on the Property Profile Form, across all tasks, indicate that the 

average recipient will incur 15 percent of its burden with executive/managerial staff labor, 6

percent with professional specialty staff labor, 56 percent with technical labor, 11 percent with 

administrative support or clerical labor, and 12 percent with program participants and partners. 

This labor mix was applied to BLS, National Compensation Survey (NCS) data issued in 
10

December 2015

3

for a weighted hourly rate of $51.11 and an estimated fully loaded rate of 

$107.32.

On the Area-Wide Planning Reporting Form, consultations indicate that the average 

recipient will incur 10 percent of its burden with executive/managerial staff labor, 5 percent with 

professional specialty staff labor, 28 percent with technical labor, 5 percent with administrative 

support or clerical labor, and 53 percent with program participants and partners. This labor mix 

was applied to BLS, National Compensation Survey (NCS) data issued in December 20153for a 

weighted hourly rate of $52.61 and an estimated fully loaded rate of $110.48.

Lastly, on the Job Training Reporting Form, consultations indicate that the average 

recipient will incur 4 percent of its burden with executive/managerial staff labor, 54 percent with 

professional specialty staff labor, 13 percent with finance labor, 4 percent with administrative 

support or clerical labor, and 25 percent with program participants and partners. This labor mix 

was applied to BLS, National Compensation Survey (NCS) data issued in December 20153 for a 

weighted hourly rate of $42.73 and an estimated fully loaded rate of $89.72

CERCLA 104(k) cleanup, and revolving loan fund recipients, and CERCLA 128(a)

recipients that conduct property specific activities will be required to report progress with the 

“Brownfields Property Profile Form.” EPA anticipates that the initial completion of this form 

will require approximately 1 hour. Recipients will be required to update this form as milestones 

are achieved, though not more frequently than quarterly. It is estimated that each update will 

require approximately .5 hours for a unit burden of $53.66 for both non-profits and governmental 

entities. It is estimated that each form will be updated an average of twice per year.

CERCLA 104(k)(6) area wide planning recipients will be required to report progress with 

the “Brownfields Area-wide Planning Reporting Form.” EPA anticipates that the initial 

completion of this form will require approximately 2 hours. Recipients will be required to update 

this form as milestones are achieved, though not more frequently than quarterly. It is estimated 

that each update will require approximately 1.5 hours for a unit burden of $165.72 for both nonprofits and governmental entities. It is estimated that each form will be updated an average of 

twice per year.

Environmental Workforce Development Job Training recipients will be required to report 

progress on a quarterly basis using EPA’s “Job Training Reporting Form.” Recipients will be 

required to report progress on a quarterly basis, with each update requiring approximately 4 hours 

for a unit burden of $358.90 for both non-profits and governmental entities. The majority of this 

burden stems from the activities associated with the collection of salary or wage information from 

Environmental Workforce Development Job Training program participants who are able to find 

employment.

 

3

See Bureau of Labor Statistics publication entitled “Employer costs per hour worked for employee compensation and 

costs as a percent of total compensation: State and local government, by occupational group, December 2015 

http://stats.bls.gov/news.release/ecec.t04.htm#content. 
11

Area-wide Planning, assessment, cleanup and job training cooperative agreements 

awarded under CERCLA 104(k) cover a period of performance of up to three years, and revolving 

loan fund cooperative agreements cover a period of performance up to five years. Based on the 

Agency’s experience under its program, EPA estimates that at the end of two years, 

approximately 75 percent of cooperative agreements will receive a no-cost extension, 

approximately 20 percent of recipients will receive supplemental awards, and 5 percent of 

cooperative agreements will close out. Recipients that receive either a no-cost extension or a 

supplemental award will be required to continue to report on their activities using the forms 

authorized under this ICR. In addition, cooperative agreements that have closed out may undergo 

a five-year review conducted five years after close out. The five year review gathers data on the 

current status of properties that benefited from EPA funding while the cooperative agreement was 

active using the forms authorized under this ICR. This burden is included in the estimated 

number of responses per year and, therefore, the overall burden calculation estimated for this ICR.

All awards made under CERCLA 128(a) have at least a one year period of performance or 

can be a multi-year award depending on the State’s financial need for continued funding. Based 

on the Agency’s understanding of State response programs, EPA estimates that one-half of the 

State recipients have sophisticated response programs and can complete property specific 

activities within one year, therefore submitting a total of two responses. EPA further estimates 

that the remaining State, tribal, and US territories that receive funding take two years to complete 

property specific activities therefore submitting a total of four responses.

Start-up costs to meet the Brownfields reporting requirements are minimal and are a part 

of the customary and usual expenses incurred by recipients. There are no capital costs related to 

Brownfields reporting requirements. Therefore, total start-up and capital costs are zero. There 

are no operation and maintenance costs required.

6(c). Agency burden and costs - EPA incurs a burden in the process of requesting, 

reviewing and processing the information covered by this ICR. This burden includes:

 Reviewing and processing initial Brownfields Property Profile Forms;

 Reviewing and processing updates of Brownfields Property Profile Forms; 

 Reviewing and processing initial Brownfields Area-Wide Planning Forms;

 Reviewing and processing updates of Brownfields Area-Wide Planning Forms and

 Reviewing and processing Job Training Reporting Forms

The estimated burden associated with EPA activities is presented in Exhibit 3. 

Exhibit 3 - Annual Agency Burden and Cost
12

Activity Unit 

Burden 

(Hours)

Unit 

Labor 

Cost 

(Dollars)*

Total 

Unit Cost 

(Dollars)*

Average 

Number of 

Responses/ 

Year**

Total Burden 

Hours/Year**

Total 

Cost/Year 

(Dollars)**

Review and Process Initial 

Completion of Property 

Profile Form (CERCLA 

104(k))

1.5 $52.68 $79.02 1575 2363 $124,457 

Review and Process Initial 

Completion Property Profile 

Form (CERCLA 128(a))

1.5 $52.68 $79.02 1268 1902 $100,197 

Review and Process Update 

to Property Profile Form 

(CERCLA 104(k))

0.5 $52.68 $26.34 1103 551 $29,040 

Review and Process Update 

to Property Profile Form 

(CERCLA 128(a))

0.5 $52.68 $26.34 634 317 $16,700 

Review and Process Initial 

Area-Wide Planning 

reporting form (CERCLA 

104(k)(6))

1.5 $52.68 79.02 18 27 $1422

Review and Process Update 

to Area-Wide Planning 

From (CERCLA 104(k)(6))

.5 $52.68 26.34 9 5 $263

Initial Completion of Job 

Training Reporting Form

1 $51.71 $51.71 29 29 $1,500 

TOTAL 4636 5194 $273,579

AVERAGE TOTAL COST PER BURDEN HOUR $52.67

* Unit Labor Cost in Dollars reflects a “loaded” rate for benefits and overhead.

** Figures may not sum due to rounding. 

The burden imposed upon EPA was initially estimated by: (1) interviewing EPA Regional 

and Headquarters staff to gather individual estimates of the time required to perform each activity 

and the GS level of the staff performing those tasks; (2) averaging the time data to estimate the 

number of hours required for each burden element; (3) averaging the data on the percentage of 

time performed by particular staff GS levels; (4) developing a weighted hourly rate based upon 

percentage of staff labor at different GS levels devoted to each task; and (5) determining the 

product of the weighted hourly rate and the number of hours required per activity. 

The weighted hourly rate utilized in the Federal burden estimate is based upon the 

following composite:

GS Level Percent Hourly Wage Rate*

GS 4, Step 1 10% $12.10
13

GS 11, Step 1 10% $24.83

GS 13, Step 1 75% $35.38

GS 14, Step 1 5% $41.81

Weighted Rate $32.93

*Rates for 2016 General Schedule (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/16Tables/html/GS_h.aspx )

6(d). Estimated Respondent Universe and Total Burden and Costs – The estimated annual 

average number of respondents per year for this information collection is 2,890 respondents, with 

the average total number of responses per year estimated at 4,636. As presented in Exhibit 2, the 

total average annual burden to respondents is 3,877 hours per year at a cost of $414,197.

6(e). Bottom-line burden hours and costs – Exhibits 2 and 3 provide the bottom-line 

burden hours and costs for respondents and EPA, respectively. The hours and costs presented in 

these exhibits represent the average annual burden resulting from this information collection; the 

total burden hours and costs for the three-year period covered under this ICR is estimated to be 

three times the total hours and costs provided in each exhibit.

Respondents Responses Hours

States 2,782 4,466 3,679

Non-Profits 108 170 198

Total 2,890 4,636 3,877

6(f). Reasons for Change in Burden – The overall burden has increased 710 hours since 

the last ICR submittal. This is due to the overall increase in wages and the overall increase in the 

number of respondents submitting the Property Profile Form. Even with this slight increase, 

respondents indicated that improvements in the ACRES reporting system and increased 

familiarity with the program lead to a lower burden per individual entry.

Additionally, Form 6200-14, the Area-Wide Planning Reporting Form, along with the 

form’s instructions (Form 6200-13), are new to this ICR. These new forms will be required for 

Area-Wide Planning recipients instead of using the Property Profile Form. The Area-Wide 

Planning Reporting Form is estimated to take slightly longer to initially fill out and update than 

the Property Profile Form, but it is much better at capturing the impacts and outcomes specific to 

Area-Wide Planning Cooperative Agreements. It was specifically created to allow grantees to 

capture outcomes unique to their cooperative agreement that may not have been captured using 

the Property Profile Form.

6(g). Burden Statement – The annual public reporting and recordkeeping burden for this 

collection of information is estimated to average .8 hours per response for CERCLA 104(k)

assessment, cleanup, and revolving loan fund and CERCLA 128(a) recipients, 1.83 hours per 

response for area-wide planning reporting (CERCLA 104(k)(6)) and 4 hours per response for job 
14

training recipients (CERCLA 104(k)(6)). Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information to 

or for a Federal agency. This includes the time needed to review instructions; develop, acquire, 

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

information, processing and maintaining information, and disclosing and providing information; 

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

train personnel to be able to respond to a collection of information; search data sources; complete 

and review the collection of information; and transmit or otherwise disclose the information. An 

agency may not conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB control numbers 

for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. 

 To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-SFUND-2012-0104, which is available for online viewing at 

www.regulations.gov, or in person viewing at the OSWER Docket in 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 OSWER Docket is (202) 566-0276. An electronic 

version of the public docket is available at www.regulations.gov. This site can be used to submit 

or view public comments, access the index listing of the contents of the public docket, and to 

access those documents in the public docket that are available electronically. When in the system, 

select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-SFUND-2012-0104 and OMB Control Number 

2050-0192 in any correspondence.