1 SUPPORTING STATEMENT

1. Identification of the Information Collection

Title: Brownfields Program

– Accomplishment Reporting (OMB Control Number 2050

- 0192 ; EPA ICR No. 2104.0 6 ).

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 agreement s from EPA under the authority of subtitle A and subtitle C of the “Sm all 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 s tates, 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 s tate 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
Gran t account.

With this ICR, EPA’s Office of Brownfields and Land Revitalization (OB LR ) 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) s tates, 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 t raining and placement programs.

Under CERCLA 128(a) S tates 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 stru cture 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 verificati ons 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 r e sponse 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 informa tion as part of its Federal stewardship responsibilities to manage and oversee recipient activities and expendit ures under 2
CFR Part 200

, OBLR needs additional information from recipients to be reported in a consistent
manner in order to evaluate the effe ctiveness 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

o ut 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 activiti es 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 rec ipients. 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 passag e of the Brownfields Amendments.

3. Non

- duplication, Consultations, and Other Collection Criteria3

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 assistan ce regulations at UGG 2 CFR Part 200 which became effective December 26,
2014

. Exhibit 1 identifies the tasks and burde ns of recipients that are covered under other OMB

approved 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 Regi ster 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 pro grams that awarded more than 3,700 cooperative agreements to s tate, local, and tribal governments to address brownfields properties. For these Brownfields cooperative agreements , EPA staff ha s worked closely with the recipients to help them participate in the program and address their brownfields properties. As suc h, 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 reporti ng 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. R ecipient 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 fir st renewal in 2006, the ICR was expanded to include4

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, E PA 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 2 012, EPA made no changes to the Property Profile Form and Job Training R eporting F orm.

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 Plan ning 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 Suit e 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 Pro gram 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 o f the burden imposed on recipients, EPA has adopted less frequent repo rting for the Property Profile F orm in which recipients are5

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 subm it an updated Property Profile F orm to EPA at least
twice but not more than four times over the life of the cooperative agreement. For CERCLA 128(a) s tate and tribal response program cooperative agreements , EPA anticipates that recipients will submit a Property Profile F orm to EPA twice a year in line with the bi

- annual reporting guidelines.

3(e). General Guidelines

– The information collection is c onsistent 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 participat e 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 Cod e: 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 S tate legislatur e (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 organizations 1 (NAICS Code: 81331 2 )

.

4(b). Information Request ed

– 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

co operative 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 Brownf ields Property Profile Form for each property the cooperative agreement intends to address. The Property Profile Form compl i ments 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

. 2 NAICS Codes as of 2002. Source: http://www.census.gov/epcd/naics02/naicod02.htm6

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 Profil e 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 Workf

orce 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 e fficiently 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
col lect 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 r ecipient 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 Planni ng 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 develop ed an electronic reporting process that will allow recipients to report their data electronically. This electronic reporting p rocess is integrated with EPA’s Enterprise Architecture to further streamline the Agency’s data management and reporting responsibilities. EPA released the electronic reporting7

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

access . EPA has modif

ied its reporting guidance and provide s 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 repor ting process reduce s the burden placed on recipients

. Through continued improvements to ACRES and greater recipient experience, it is estimated that
the re porting 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
incon sistent 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 r equirement; 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 Sc hedule

– 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 F orm 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 m ust complete and/or update their Job Training R e porting 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 Co llection

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) prohib its 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 c ompletion 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 Propert y 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

P roperty Profile Form (CERCLA 104(k) : non

profits) 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) : non

profits) 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 Area

Wide Planning Form (non

profits) 2 $110.48 $220.96 3 6 $663

Initial Completion of Area

Wide Planning Form (government) 2 $110.48 $220.96 15 30 $3,3149

Review and Process of

Area

- Wide planning Reporting Form (non

profits) 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 wi th eight current or former Brownfields recipients submitti ng the Property Profile Form, nine Area

- Wide Planning recipients specific to this ICR , and six Environmental Workforce Development Job Training recipients

. T hose 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 fo rward the same assumptions that were made for the original request. The type of data collected remains unchanged, with only structural change s being made by separating the Area

- Wide Planning questions from the original Property Profile Form into its own re porting form to ensure the lowest
burden on c ooperative a greement r ecipients. For all form types

, t he 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. Bure au of Labor Statistics (BLS).

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

average recipient will incur 15 percent of its burden with executive/managerial staff labor, 6 percent with professional specialty st aff labor, 56 percent with technical labor, 11 percent with administrative support or clerical labor

, and 1 2 percent with program participants and partners

. This labor mix was applied to BLS, National Compensation Survey (NCS) data issued in10

December 201 5 3 for a weighted hourly rate of $ 51.11 and a n 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 Sur vey (NCS) data issued in December 2015 3 for a weighted hourly rate of $ 52.61 and an estimated fully loaded rate of $ 110.48

.

Lastly, on the Job Training Reporting F orm, consultations indicate that the average recipient will incur 4 percent of its burden w ith 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 2015 3 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. R ecipients wi ll 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 “ Brow n fields Area

- wide Planning Reporting Form.” EPA anticipates that the initial completion of this f

orm will require approximately 2 hour s

. R ecipients 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 non

profits 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 qua rterly 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 $358.9 0 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 compens ation 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 P lanning, a ssessment

, c le anup 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 aw ards, and 5 percent of cooperative agreement s will close out. R ecipients 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, coo perative 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 u sing 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 o f performance or
can be a multi

- year award depending on the S tate’s financial need for continued funding. Based on the Agency’s understanding of S tate response programs, EPA estimates that one

- half of the
S tate recipients have sophisticated response progra ms and can complete property specific activities within one year, therefore submitting a total of two responses. EPA further estimates that the remaining S tate, tribal, and US territories that receive funding take two years to complete property specific ac tivities 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
Brownfie lds 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 in formation 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 Co st12

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 P lanning reporting form ( CERCLA 104(k)(6) ) 1.5 $52.68 79.02 18 27 $1422

Review and Process Update

to Area

- Wide P lanning

From ( CERCLA 104(k)(6) ) .5 $52.68 26.34 9 5 $263

Initial Completion of Job Training Reporting F orm 1 $51.71 $51.71 29 29 $1,500

TOTAL 46 36 51 94 $273,579

AVERAGE TOTAL COST PER BURDEN HOUR $52.6 7

* 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 es timates 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 perfo rmed 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 act ivity.

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% $ 12.1013

GS 11, Step 1 10% $2 4. 83

GS 13, Step 1 75% $3 5.38

GS 14, Step 1 5% $ 4 1.81

Weighted Rate $3 2.93

*Rates for 20 1 6 General Schedule ( https://www.opm.gov/policy

- data

- oversight/pay

- leave/salaries

- wages/salary

tables/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

to tal 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 submitt al

. This is due to the overall increase in wages and the overall increase in the number of respondents submitting the Property Profi le Form. Even with this slight increase,

r espondents 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 Rep orting 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 tak e 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 h ours per response for CERCLA 104(k) assessment, cleanup, and re volving loan fund and CERCLA 128(a) recipients , 1.83 hours per response for a rea

- w ide p lanning reporting (CERCLA 104(k)(6)) and 4 hours per response for job14

t raining 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,
ins tall, 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 applica ble 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 t he 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 ind ex 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

- 019 2 in any correspondence.