February 17, 2016

Page 1 of 22 **SU P**  **P O**  **R TING**  **S TA**  **T E**  **M E**  **N T**  **F OR**  **AN IN F**  **OR M**  **ATI O**  **N COLLECTI**  **O N R** **E QU**  **E ST (ICR)**  **1. IDENTI**  **F IC**  **A TION**  **O F T**  **H E IN**  **F OR** **M ATI**  **O N**  **COLLECTI O**  **N 1**  **( a)**  **School Integrated Pest Management Awards Program** EPA ICR No.: 2531.01 OMB Control No.: 207 0
- NEW **1 (**  **b )**  **Sh o**  **r t**  **C h**  **a r**  **a c**  **te r**  **iza t**  **ion** This is new info r

mation co l le c t i on request ( ICR) which enables the U.S. Environmental Protection Agency to encourage the use of Integrated Pest Management (IPM) as the preferred approach to pest control in the nation’s schools. IPM is a smart, sensible, and sustainable approach to pest control that emphasizes the remediation of pest conducive conditions. IP M combin es a variety

of pest management practices to provide effective, economical pest control with the least possible hazard to people, property, and the environment. These practices involve exclusion of pest s , maintenance of sanitation, and the judicious use of pesticides
. The EPA ’s vision is that all students in the U.S. will experience the benefits provided by an IPM program in their school district. The Agency ’s IPM implementation effort s are based on a wholesale approach aimed at kindergarten through 12 th grade public and Tribal schools
. The Agency intends to use the information collected through this ICR to encourage school districts to implement IPM programs and to recognize those that have attained a notable level of success
. Because IPM implementation occurs along a continuum, the School IPM (SIP M) incentive program will recognize each milestone step a school district must take to begin, grow, and sustain an IPM program . This program has five awards categories
- Great Start, Leadership, Excellence, Sustained Excellence, and Connector
. The first four categories are stepwise levels that are reflective of the effort, experience, and , ultimately , success that result s from implementing EPA
- recommended IPM tactics that protect human health and the environment. Schools with pest infestations are not only exposed to potential harm to health and property , but also to stigmatization. The School IPM recognition program will give districts across the nation the opportunity to receive positive reinforcement through public recognition of their efforts in implement ing pest prevention and management strategies. The S chool IPM award s program follows the model of the Agency ’s Tools for Schools program that recognized schools for achievements in improving indoor air quality
. Th e highly successful Tools for Schools program was active for ten ye ars and employed the same tiered approach as the School IPM awards program
. T he awards program will connect the Agency with school districts to encourage reciprocal learning around IPM
. The awards program, as a whole, provides incentives for sustainable IP M practices in schools at the individual for districts as well as individuals, including non
- school entities. School d istricts and other participating entities seeking recognition for th eir IPM programs w ill need to maintain detailed records on a variet y of activities and send completed applications to EPA for each award to which they aspire
. As part of their activities, participants will need to develop anFebruary 17, 2016

Page 2 of 2 2 IPM policy

and update their IPM plans annuall y. Applicants will provide information describing how they have met the requirements for the award category to which they

are appl yi ng . T here are four progressive levels of award for school districts ( i.e., Great Start, Leadership, Excellence, and Sustained Excellence) ; the Connector award is open to non - school entities and individuals
. Comprehensive school IPM programs create safer and healthier learning environment s by helping to effectively manage pests, reduce children’s unnecess ary exposure to pests and pesticides, and reduce pest complaints. A relatively small percentage of U.S. K
- 12 schools currentl y have verifiable IPM programs. The information collected will substantiate the implementation of the actions required along the IPM continuum from p rogram initiation to robust, sustained implementation. The S chool IP M awards program will initially place more focus on school districts rather than individual schools. This is primarily due to the resource requirements to process appl ications from individual schools on a national scale.

**2. NE**  **E D**  **F OR A**  **N D**  **U S**  **E OF THE**  **COLLECTI O**  **N 2**  **( a)**  **N ee**  **d /A**  **u thori**  **t y**  **f or**  **t h**  **e Colle**  **c tion**  S ec t i on 13101(b) of the P ol lut i on P r ev e nt i on A c t of 1 9 90, 42 U.S.C. sets forth “the national policy

of the United States that pollut ion should be pr ev e nted o r r e du ce d at the sour c e wh e n e v e r f

e a sib l e .” Se c t i on 1 3 102 (4) d e fin e s sour c e r e du c t i on a s an y p r ac t ic e that “ r e du ce s th e amount of a

n y h az ardous substan c e ... r e le a s e d int o the e nv i ro nment” and “ r e du c e s the h az ards to publ i c h ea l th an d the e nvironme nt asso c iat e d with the re le a s e of su c h s ubst an ce s.” T o i mp l e m e nt this pol ic y, Se c t i on 13103(b)(5) of the Ac t d i r e c ts the Admin i str ator of EPA to, among other th i n g s; “ f

ac i l i t at e the a dopt i on of sour c e r e du c t i on te c hniques b y busin e ss” ( see Attachment A ). Section 3 of the Fe d e r a l Inse c t i c i d e , F un g icid e , and Rod e nt i c i de A c t ( F IF RA) , 7 U.S.C. 136a, r e quires EPA to r e g u l ate p e st i c ides to pr e v e nt “unr e a sona b l e a dv e rse e f

f e c t s” on human h ea l th and the e nvironme nt (Attachment B ). IP M strategies , such as re mov ing sources of food, water, and shelter for pests, r e du c e pest problems and the unnecessary use of pesticides
. The F ood Q u a l i t y P rot e c t i on A c t (FQPA) of 1996 ( 7 USC 136r

– 1) r e quires the U.S. D ep artme nt of A gri c ul tur e and E P A to i mplem e nt programs in r e s earch, d e monstr at i on, and e du c at i on t o suppo rt the adoption of I P M, m ake info r

mation on I

P M wid e l y av a i l a

ble to p e st i c ide us e rs, use I

P M t ec hniques in car

ry i n g out pest m an a g e ment ac t i vi t ies, as well as p r o mo t e IP M thr o u gh pr o c ure m e nt, r e g u l ato r y pol i c ies and other a c t i vi t ies ( Atta c hment C ). The S chool IP M award s p rogram is a non - re gulato ry approach es to me e t th e g o a ls of the P ol lut i on P r ev e nt i on A c t, FIFRA and FQPA to reduce p e st i c ide risks in non - a gri c ul tura l sett i n g s. The collection of information that documents and measures applicant accomplishments enables EPA to f

airl y and a cc ur a

te l y a ssess p ro gr a

m e f f ec t i v e n e ss and benefits of awards
. Completed applications, including contact information, are preliminary to EPA’s formal recognition. The application s will allow E P A to und e rst and and promote e ac h school district ’ sFebruary 17, 2016

Page 3 of 22 e f f o rts. Inaddition, this program will m e a sure in d iv i du a l and collective program pro gr e ss i n Schoo l IP M implementation
. **2 (**  **b )**  **P r**  **a c**  **ti c**  **al U**  **tility/Us er**  **s o**  **f t**  **h e**  **Da t**  **a** The info r mation colle c t e d b y the S chool IPM award s p rogram is not desi gn e d or inten de d to supp o rt EPA re g

ulato r y d ec is i o n - maki n g . EPA intends to use the info r m at i on c ol l ec ted through award program a

pplications to:

 Determine applicant el ig ib i l ity f or aw ard r e c o gni t ion  Id entify school districts’ c omm i tment to promoting and i mplem e nt i ng IP M p r ac t ice s  Verify participation i n pr om ot i ng and i mplem e nt i ng IPM p rac t ice s  Define the existing landscape and implementation status of IPM practices in school districts nationally  Measure environment a l outc omes T h e A g e n c y will use th i s data to :
 D e v e lop c a se stud i e s that d e monstr ate the importance of IP M i mplem e nt ation in school districts  Encourage replication of best practices for adopting, implementing and sustaining comprehensive school IP M programs  Share information on IP M practices that school districts can incorporate into other environmental health initiatives ( for example , indoor air qualit y management, asthma management , etc. ) Provide a better understand ing of how schools can effectively manage environmental issues when faced with budget ary and personnel challenges
. I n a ddi t ion, EPA wi l l an a l y z e the d ata , t o the e x tent poss i bl e , to look for e nvironme ntal tr e nds and hi ghl i ght pr o gr am suc ce sses b y posti n g info r mation on the Agency ’s S chool IPM w ebsite
. 1 As wi ll be discussed in Section 3(f ) of this I CR, the EPA will not publish business info r mation r ep o rt e d b y award program applicants
. D ata will on l y be share d publ i c l y in a g gre g ate fo r m un l e ss o th e r

wise spe c ified and a gree d to b y the a f f ec ted s chool d istrict or awardee
.
**3. NO**  **N -**  **D U**  **P LIC**  **A TION,**  **CON S**  **UL T**  **ATI O**  **NS, A** **ND O**  **T H**  **E R**  **C O**  **L LE**  **C TION**  **C R** **I T**  **ERIA 3**  **( a)**  **Non -**  **Du p**  **l i**  **c a**  **t ion**  T he info r mat i on to be c ol l ec ted b y EPA ’s School IPM award s program is unique and is not dup l ic at i ve of other collections
. For example, data submitted through the award applications are specific to the task s required to implement an IPM program s in schools
. Applicants will not be a sked to provide info r

m at i on that h a s be en , or is c ur re nt l y b e i n g c ol l ec ted b y EPA, oth e r

1 htt p: / /www2
. e p a . g ov/managing
- pests - schools (accessed February 12, 2016)February 17, 2016

Page 4 of 22 f e d e r al o r st ate a g e n c ie s , or pro p ri e t ar y sour c e s. While s ome s tate and l ocal g overnment a gencies may require pesticide users to maintain records of pesticide use and IPM , they may not require it to be report ed
. As detailed below , in those instances when a government or private entity collects pesticide use and IPM data , it is not of the scope or detail needed to operate the S chool IP M awards program. The EPA c onsulted with tr ade a ssoci at i ons, nonprofit groups, school districts, and other potential p articipants to c o n f irm th at the info r

mation being c ol l ec ted b y the S chool IPM program do e s not e x i st else wher e . While developing the IPM measures , the Agency consulted with the Pesticide Program Dialogue Committee (PPDC) , a Federal Advisory Committee Act advisory board to the Agency ’ s Office of Pesticide Programs
. The PPDC is a cross
- section of entities with interest in pesticide
- related matters , including IPM , with representatives from the private sector, nongovernmental entities, and the federal government. Within the PPDC , there is a workgroup focus ed on IPM. While EPA did not provide the PPDC with details on the information being request ed from award program applicants, the committee provided advice on long
- term program goal s . The level of detailed information required for the S chool IP M award program is not available through other organizations. S ome s tate s collect pesticide use information
. Of these, California’s data collection is one of the most comprehensive. Even so, its scope is too limited for the purpose of this award program because : 1) the reporting is not focused on School IP M ; and 2) the reporting onl y appl ies to California while the Agency ’s award p rogram is a nationwide program . State governments’ pest management reports may also not be consistently available due to changes in reporting requirements or s tates’ priorities. An example of a s tate government pesticide data collection program with such limitations is Oregon. 2 In2009, Oregon canceled its pesticide use reporting requirements because budget ary constraints limited the state’s ability to use the data to develop and publish reports. S ome s tate s currentl y have s chool IP M requirements based on legislation. The se laws vary in breadth and rigor but all deal with some element of pesticide application in or around schools , for example pesticide use notification requirements. Alabama, Louisiana, North Carolina, and Texas have regulations on restricted spray zones that impact schools
. Some s tate s require IPM training for those appl yi ng pesticides in schools , others define the ty pe of pesticide products that can be used in schools , while others require detailed IPM programs for all schools
. T he variet y of School IPM
- related requirements and pesticide data collection mechanisms across all states make it difficult for the EPA to access and use th ese data. Furthermore, the EPA S chool IPM award applications are designed to assess only those activi ties required to implement an IPM program in a school district. No government al entity is collecting the data the Agency needs to assess IP M implementation in school districts across the nation
. Thus, the EPA believes that the information requested through the IC R is not duplicative. **3 (**  **b )**  **P ub**  **l i**  **c No**  **t ice**  **R e**  **qu ir**  **e d**  **P r**  **i o**  **r t**  **o ICR Sub**  **m is**  **s i**  **o n**  **t o OMB**  P ur suant to 5 C F R 1320.8 ( d) , the EPA will publis h a Fe d e r al Re g is t e r N oti c e a nnoun c i n g

2 Pesticide Use Reporting System (PURS **)**February 17, 2016

Page 5 of 22 th i s propos e d info r

mation c ol l ec t i on ac t i vi t y and p ro viding a 60
- d a y publ i c c omm e nt pe riod. The comments received and any additional public comment for this action will be posted in the docket
. **3 (c**  **) Cons**  **u lta**  **t io**  **n s**  During th e d e v e lop m e nt of th i s ICR, the EPA solicited stakeholder input from four kindergarten
- 12 th grade school districts , with varied student populations and diverse geographic locations , and one non
- profit organization. The EPA solicited input on the amount of burden hours to complete the application for each award. Participating school districts were selected on the basis o f their current IPM program s . School d istricts were provided detailed instructions on how to obtain and document the requested information ( **Attachment D**  )
. The input provided by these entities was used in estimating the respondents’ paperwork burden in Section 6 of this I CR. In addition to the initial survey for SIPM , following the publication of the first Federal Register Notice for this new ICR, EPA staff will contact appropriate stakeholders and ask them for their assessment of the regulatory burden estimates expressed by the Agency

in this I CR. A summary of these consultations will be provided in the supporting statement during the second comment period (**Attachment E**  ). **3 (**  **d )**  **Ef**

**f ec**  **ts of L**  **e ss**  **F re**  **qu e**  **n t**  **C ol**  **l ec**  **tion** The EPA request s that S chool IP M awardee s submit applications at least every two years to maintain their award status level
. Because of the intended high visibility of the program, less frequent re submission c ould compr om ise program integrit y. It will also take time for a school district to implement their IP M program and report on its results. The Agency believes that the two - ye ar timeframe gives schools the flexibility needed to complete a School IPM award application and , subsequently begin o r further develop their IP M program. **3 (e**  **) G**  **e ne**  **r al**  **G u**  **i d**  **e l**  **in e**  **s** The info r mation colle c ti o n ac tivities discuss e d in this ICR c omp l y with all r e g u l ato r y g uidelines und e r 5 C F R 1320.5 ( d) (2). S chool IP M award program applicants w ill n ot need to r e tain re c o rds for this pr o gr am f o r more than one year . S chool IPM award program participants may re submit applications every two years to maintain awardee status or to move to the next level in the program. **3 (**  **f) Con**  **f**

**id e**  **nti a**  **lity** EPA has implemented procedures to protect an y confidential, trade secret or proprietary information from disclosure that provide strict instructions regarding access to and contact with documents confidential business information (CBI). These procedures comply with EPA’s CBI regulations at 40 CFR Part 2, Subpart B. T he reporting method and s ys tem p r ev e nts a c ce ss to and di s tribution of business info r mation r ep o rt e d b y S chool IP M awardees
. D ata will on l y be share d publ i c l y in a g gre g ate fo r m un l e ss o th e r

wise spe c ified and a gree d to b y the a f f ec ted awardee. **3 (**  **g) S**  **e n**  **sitive Q u**  **e stio**  **n s**  This information collection activity complies with the provisions of the Privacy Act ofFebruary 17, 2016

Page 6 of 22 1974 and OMB Circular A
- 108 , as amended, “Responsibilities for the Maintenance of Records about Individuals by

Federal Agencies.” No information of a sensitive or private nature is requested in conjunction with this information collection activity
. EPA aggregates data before sharing it with an y part y outside of the Agency
. S chool IP M data sharing activities protect an organization’s data b y presenting them in a general and unidentifiable manner un l e ss o th e r wise spe c ified and a gree d to b y the a f f ec ted awardee.
**4. THE**  **RE S**  **P ONDENTS**  **A N**  **D THE IN**  **F O**  **R M** **A TION RE**  **Q UE**  **S T**  **ED 4**  **( a)**  **R e**  **s p**  **o nd**  **e n**  **ts and N**  **A I**  **C S**  **c o**  **d e**  **s** S chool districts , or entities that represent them, are the target applicant pool for the S chool IPM award program . B e low is a l i st of No rth Am e ri can I ndustr y Classifi cat i on S ystem (NA I C S ) c od e s and a ss o c iat e d industries th at may be a f

f ec ted b y info r

m at i on c ol l ec t i on r e qui r e ments c ov e r e d und e r this I CR. This l i st is i ntend e d to be il lustr at i v e ; enti t ies f rom other i n dustri e s m ay e le c t t o a p p l y f o r r e c o gni t ion thr ou gh the S chool IP M award program . Ho we v e r, E P A e x p ec ts th at m ost appli cat i ons will come f rom public kindergarten through 12 th grade schools.

**NAICS Code Affected Industry**  6111 Elementary

and Secondary

Schools 6244 Chi l d D ay C ar e S e rvi c e s 56172 J ani t o rial S e rvi ce s 56173 L and s ca

pi n g S e rvi c e s 56171 E x te r

m i n at i ng and P e st C ontrol S e rvi ce s 5617 S e rvi ce s to B ui l di n g s an d D we l l in g s **4 (**  **b )**  **I nf** 

**o r**  **m a**  **t ion**  **R e**  **qu e**  **st e**  **d** School districts seeking recognition in the EPA S chool IP M award program must fill out one or more of five application forms (attachment F )
. These forms are:

 The Great Start a

pplication f

orm is required for the Great Start award. This award recognizes districts that are starting an IPM program.

 The Leadershi

p award a pplication f

orm is required for the Leadership award. This award re quires a school district to demonstrate how its IP M program was implemented to i nclude staff education and the definition of roles and responsibilities.

 The Excellence award a pplication f

orm is required for the Excellence award. Th is is the middle tier of the award program. For this award, applicants must show how employee s have receive d IP M education, how IP M
- related maintenance is performed , and pest monitoring is being tracked.February 17, 2016

Page 7 of 22  The Sustained Excellence award a pplication f

orm is required for the Sustained Excellence award. This level builds on the Excellence award b y requiring school districts to provide documentation of pest proofing or pest prevention by design. This is in addition to documenting how employees are educated on IPM , how pest proofing repairs are made , and that pest monitoring is being conducted and tracked.

 The Connector award a pplication is required for the Connector award. Thi s award is reserved for the individual or organization that can demonstrate playing a key role in implementing an IPM program in a school district
. The time and effort to complete the application form for each type of data collection varies
. For example , the Great Start award onl y requires applicants to complete a narrative for an IP M plan and commit to appointing an IPM c oordinator
. Itdoes not require the specific measures and progress tracking elements present i n the Excellence award . Consequently , completing the application for the Great Start award is less burdensome than completing the application for the Excellence award. The S chool IP M information collection instrument assumes that a number of different employees or contractor s can complete the data collection task for the school district
. These could include the IPM coordinator, health and safety coordinator, qualit y assurance specialis t, pest management professional, campus facility supervisor, custodian, groundskeeper, and food service personnel. Each award has a different information collection demand. The EPA assumes that all of the paperwork burden incurred by individual schools as well as by their districts to maintain records and to report (appl y) for the incentive program are included in the burden estimates provided in the survey responses submitted by

the school districts. This assumption is based on the fact that many schools are already positioned for such school
- to - district reporting either because of existing pesticide, IP M, or school environmental health reporting requirements. Insuch cases, information report ed b y individual schools are already compiled and maintained at the district level
. The S chool IP M awards allow for rolling applications , i.e., applications can be submitted at any

time during the y ear. EPA will process each application within 60 day s of submission. EPA will make award presentations to awardees on a monthly basis as applications are approved. The standard threshold for the four tiered awards that recognize school districts increases as an applicant seek s higher levels of recognition. The exception is for the C onnector award which recognizes an organization or individual for “connecting” school districts to help implement an IPM program. This award program recognizes the incremental steps it takes to implement IPM in a school district. Each award category and its requirem ents are explained in section 4 (c). **4 (c) Incentive program conditions and criteria** The School IPM Awards c onditions and criteria , which are summarized below, are detailed in **Attachment G** 
.February 17, 2016

Page 8 of 22 **Great Start Award**  The **Great Start** award is presented to school districts that are in the initial stages of implementing an effective IPM program. Applicants must have selected an IPM c oordinator for the district and created a written IPM p olicy to receive this award. **Leadership Award**  The Leadership award is presented to school districts with a senior
- level commitment to establish and maintain an IP M program as well as to relate their IPM strategies to the framework for effective school IPM programs (i.e., Organize, Assess, Plan, Act, Evaluate, and Communicate). **Excelle nce**  **Award** To merit an Excellence award, applicants need to tell the story of their IPM program in a way that demonstrates the program is comprehensive, effective, and moving towards being institutionalized as part of a comprehensive environmental health program in the district. Specificall y, the EPA will look for evidence that:

 The critical components of the framework for effective school IPM programs (i.e., Organize, Assess, Plan, Act, Evaluate, and Communicate) are embodied in the school environmental health management program;  An established s ys tem exists to ensure consistent and sustained action to identify , address and prevent pest problems; and  Evidence that the program is achieving results. **Sustained Excellence Award**  To merit a Sustained Excellence award, applicants must meet the requirements of the previous levels of award criteria for at least two years after receiving Excellence award recognition
. Applicants must demonstrate that its IPM program is sustainable by providing documentat ion for pest reduction, health impro vements, and financial benefits. Lastl y, Sustained Excellence award applicants must show how the school district communicates about its IPM program, both to its internal community (students, parents, employees) and to the external community (other district s, surrounding neighborhood, and community leaders). **Connector Award**  The Connector award is designed to give national recognition to individuals and organizations whose actions and initiatives support improved school environmental health in their community, region, state, or even nationally , with a special focus on actions and initiatives that reflect the spirit of the award . Examples include the following:

 Development of innovative initiatives, approaches, tools, or resources that have contributed to improved school IP M and indoor environments;February 17, 2016

Page 9 of 22  Outstanding individuals and groups who hav e played a coordinating function to bring people or IPM programs together to provide mutual assistance and support in school IPM implementation;  Leadership/mentorship of school or school district’s IP M program;  Technical assistance in IPM program impleme ntation;  In creasing student involvement in IPM, such as integration of science clubs; and  Other actions and initiatives that foster interconnectedness and mutual support and demonstrate results as part of these efforts.
**5. THE**  **IN F**  **OR M** **ATI O**  **N COLLECT**  **E D** 

**– A**  **G EN**  **C Y**  **A CTIVI**  **T I**  **ES , COLLECTI**  **O N**  **M ETH**  **O DOLO**  **G Y,**  **A ND**  **IN F**  **O R**  **M ATI**  **O N**  **M A** **N A**  **G E**  **M ENT**  **5 (**  **a) Ag**  **e n**  **c y A**  **c tiviti**  **e s**  Und e r the SIPM Award program, the EPA e ng a g e s in the f ol l owi n g ac t i vi t ies: **Award A**  **pp l**  **ication Processing**

 Organize applications b y region as they are submitted. Track applicants in detailed tracking spreadsheet
 Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets.
 Determine who will be participating on the review panel. Preferabl y an odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application.
 Provide regional staff PDF file version s of applications for their review and weigh
- in as personnel that may

have worked with the districts specificall y.
 In two weeks , assimilate all score and hold a half day consensus meeting to determine what schools districts are worthy of awards. During this meeting each ap plicant is discussed and the strength s and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year’s appli cation , if they wer e not chosen
.  Provide a list of selected applicant recommendation s to the EPA region al office and to headquarters’ senior management for approval.
 Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the ap plicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application.
 If there is an event designated for highlighting the award winning school districts and invitational travel involved, convey logistics to selected applicants.February 17, 2016

Page 10 of 22  Using award winning applications , create communications materials to showcase these award winning programs. Initiate comprehensive outreach communications plan (develop press release, secure Sr. level quote, FB, Twitter postings). If necessary , assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories. In addition to the above listed activities , the Agency also performs an environmental and criminal compliance screening to ensure that all members are good actors. The EPA perform s this task by checking Agency data bases both at headquarters and the regions. **5 (**  **b )**  **Colle c**  **tion M e**  **tho d**  **ology a n**  **d M**  **a n**  **ag e**  **m e**  **n t**  P rosp ec t i ve applicants can obtain the SIPM award application online. I n c ol l ec t i ng and an a l y z i n g the info r

mation asso c iat e d w i th th i s ICR, the EPA will use a tel ephone s ystem, p e rso n a l compute r s, email, and a ppl i c a ble PDF s o ftw ar e . All fo r ms w e re d e s i gn e d to have a m i ni mum burd e n on the us e r . The SIPM award applications will be listed on the EPA SIPM website. On c e c omp l e t e , the f o r m i s sub m i tted onl i n e through email to EPA
. Application processing can take up to 60 day s because of compliance screening. The EPA will review each applicant’s environmental compliance history
. To receive recognition, school district s must pass the compliance screening and the crit eri a set forth by the award level. **5 (c**  **) S**  **m all**  **E n**  **ti t** **y F**  **lexi b**  **i l**  **ity** The EPA e x p ec ts t o receive applications to the SIPM program from a variety of school district s and organization s . Award application s are designed to m in i m i z e re spond e nt burd e n while obt a i ning suf

f i c ient and a cc ur ate i n fo r

mation. The Agency will r e view memb e rs’ applications , making a l l o w an c es on a ca s e - b y- ca s e b a sis for th e inapplic a bi l i t y of ce rt a in el e ments and the applicants ’ a

bi l i t ies to provide the in f

o r mation. S ince memb e rship in the SI PM award program i s voluntary, applicants m a y a lso e l e c t t o withdr aw f

rom the p r o gr am , at an y t i me, if th e y d o not wish to submit applications needed to maintain their award status. The EPA requires that all awardees submit applications every two ye ars to maintain recognition status. **5 (**  **d )**  **Colle c**  **tion S**  **c h**  **e du**  **le** O r g ani z at i ons m ay sub m it a ppl i cat i on f

o r ms at any t i me. The SIPM program is a rolling admission program. The EPA will approve or reject all applications within 60 day s of submission. School districts may

submit the Great Start, Leadership, Excellence , Sustained Excellence, and Connector Award at an y time of the year. The EPA will seek to hold an annual recognition ceremony for awardees at a conference that attracts school district s and key stakeholders’ leadership.February 17, 2016

Page 11 of 22 **6. E**  **S TI**  **M ATING**  **THE B**  **U R** **DEN A** **ND CO**  **S T OF**  **THE COLLECTI**  **O N**  **6 (**  **a) Est**  **i m**  **a t**  **i n**  **g R**  **e s**  **p o**  **nd e**  **n t B**  **u r**  **d e**  **n** R e spond e nt pap e r

wo r k b urd e n of p articip at i ng in t he SIPM recognition program c onsists prim ari l y of the a dm i nis tr a t i ve burde n a s s o c iat e d with applying for the different t ype s of awards. This involves preparation, submission, and recordkeeping of an application form. To estimate average annual paperwork burden on respondents, estimated cost per respondent is multiplied by the total number of respondents, which are projected based on past data. However, since this is a new program there are no past data on the number of applicants to develop such projections. Therefore, as a pro xy for the S chool IP M awards program , the Agency used the data on the number of applicants from its Indoor A ir Q uality (IAQ) project
. As discussed in previous s ection s of this I CR, the Agency modelled the School IPM program after the IAQ Tools for Schools program, and believes the initial level of participation may be similar. **Annual Respondent Numbers (Data from EPA’s IAQ Tools for Schools**  **Awards Program) Year**  **Great**

**Start Applicants**  **Leadership**

**Applicants Excellence** 

**Applicants Model of** 

**Sustained Applicants**  **Special**

**Achievement Applicants** * **Total**

**Applications Received**  2009 18 12 13 3 5 51 2008 14 12 6 4 3 39 2007 42 6 8 6 8 70 **Annual Average**  **25 10**  **9 4**  **5 53**  * IA Q Connector Award started in 2009
B urd e n e st i mat e s w e re p r ep ar e d f o r the av e ra g e t i me n e ce ss ar y to p e r f o r m e a c h a c t i vi t y in prep aration, submission, and record keeping of an application for each award ty pe . B urd e n e st i mat e s ar e b a s e d on int e rvi e ws c ondu c t e d with representative respondent s. Each of the three school district s surveyed and the non
- profit organization were provided detailed instruction s on how to obtain each requested burden estimate through both phone conversations and written correspondence. Respondents were allowed 30 day s to acquire the requested information and prov ide comment s and

/ or suggestions on program improvement when interacting with potential school districts. A s shown in Section 6(b), Tables 1

– 5, the total annual burden ho urs associated with applying for an award are 90, 375, 198, 134, and 72 f or Great Start Award, L eadership Award, Excellence Award, Sustained Excellence Award, and Connector Award, respectively
. The EPA e st i mat e s that , on av e ra g e , a total o f 53 ent i t i e s per year w ould p articip ate in the SI PM during a thr e e - ye ar p e riod. Since the past data from the EPA’s IAQ project (2000
- 2010) show high variability

without an increasing or decreasing trend, and the data for 2010 is not complete, the three year average data over 2007
- 2009 are used as the projected annual number ofFebruary 17, 2016

Page 12 of 22 applicants for the thr ee - year ICR period. For respondents, the EPA estimates an average of 870 hours for all award categories combined , at a total cost of approximately $ 72 ,000 annually
. **6 (**  **b ) Esti**  **m a**  **ting R**  **e s**  **p o**  **nd e**  **n t**  **C osts**  Consistent with r e ce nt IC R submission s , O P P is u s ing l a bor c ost est i mat e s f

r o m A g e n c y e c onom i sts with r e spe c t t o w a g e s, b e n e fits and ov e r h ea d f o r al l l a bor c at e g o ri e s for a f

fe c ted industri e s, s t ate g ov e rnm e nt, and E P A e mp l o yee s. This a p p roa c h us e s a transp ar ent and c onsistent m e thodo l o g y and c urr ent publ i c l y av a i l a ble d ata to p rovide mo r e a cc urate e st i mat e s and a l l ow ea s y repl ic at i on of the e st i mat e s. Me thodo log

y : The calculation of the wage rate u se s base wage data for eac h se c t o r and l a bor ty pe for an Unloade d wage rate (hourl y w a ge rat e ) and ca lcul ates the L oad e d wage rate (unlo a d e d wa ge rate + b e n e fits ) and the F ully loade d wage rate ( l o a d e d w a ge rat e + ov e r hea d) based on that data. F ul l y loa de d w a ge r ate s ar e used to ca lcul at e r e spond e nt costs. C ost estimates are based on 2014 wage data. Unload e d W age Rate : W a g e s are e st i mat e d for labor ty pes (m an a g e me nt, t ec hnic a l, and c le ric a l ) w i thin applic a

b l e se c tors. T h e A g e n c y u s e s av e ra g e w a g e d ata f or the re lev ant se c tors av a i l a ble in the N at i on a l Industr y- S p ec ific O c c up at i on a l E mp l o y m e nt and Wa g e E s t i mat e s f r om the B ur ea u of L a b o r St at i st i c s (B L S ) a

t htt p: //www .bls. g ov/oes/ c urr ent/ o e ssrci.htm . S ec tor s : The s p ec ific NA I CS c ode and w ebsi t e for eac h s e c tor is i n c luded i n that s ec tor ’ s w a g e r a te t a ble in Attachment H
. W i thin e ac h s ec tor, the w a g e d at a ar e p rovid e d b y S tand ard O c c up at i on a l C lassifi cat i on (SOC). The S OC s ystem is u s e d b y Fe d e r al s t at i st i ca l a g e n c ies to c lassi f y wo r k e rs into o c c up at i on a l cat e g o ries for the pur po s e of c ol l ec t i n g , c a lcul at i n g , or d is s e m i n at i n g d ata ( s e e htt p: //www .bls. g ov/oes/ c ur

r ent/ o e s_s tru.htm )
. The man a g e ri a l l a b o r rate is bas e d on the SOC f

or man a g e ment o c c up at i on s , and the c le ric a l l a bor r ate is b a s e d on the SOC f or of f i c e an d a dm i nis tr a

t i ve support o c c up at i ons. The te c hnic a l l a bor r a te i s bas e d on the SOC f

or l i f e , p h ysic a l and so c ial s c ie n c e o c c up at i ons . For school IP M, the technical rate is based on first
line supervisors/managers of landscaping, lawn service, and grounds keeping workers. L oad e d W age Rate : B e n e fits r ep re s e nt approximately 4 5 % of un l o a d e d w a ge rat e s, bas e d on total b e n e fits for a ll c iv i l i an no n - f arm w o rk e r s f

rom htt p: //www .bls.gov/ne w s.r e l e a s e/e c ec .t01
. htm Fully Load

e d W ag e Rate : The load e d w a g e r ate is mu l t i pl i e d b y 50% ( E P A g uidelines 2 0
- 7 0 % ) to g e t ov e rh e a d c ost s . A c o p y of the f

o rmula w o r

k sh ee ts u s e d to estim ate the labor r ates b a s e d o n 2014 wage d ata and to d e rive the f

ul l y loa d e d rates and ov e rh ea d c osts f o r this n e w ICR are provided in Attachment H
. T a bles 1
- 5 b e low p r ovide average annual respondent burd e n and c ost est i mat e s b y award ty pe .February 17, 2016

Page 13 of 22 **Table 1. Average Annual Respondent Burden and Cost Estimates -**  **Great Start Award**

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $86.43 $65.36 $40.14 per hour per hour per hour **Average tim e to read instructions**  0.2 0.0 0.0 0.2 $14 **Average tim e to plan activities**  0.5 0.0 0.0 0.5 $43 **Average tim e to gather information**  1.0 0.0 0.0 1.0 $86 **Average tim e to compile and review**  1.0 0.0 0.0 1.0 $86 **Average tim e to complete and submit paperwork**  0.8 0.0 0.0 0.8 $65 **Average tim e to store/m**  **aintain data** 0.3 0.0 0.0 0.3 $22 Total per applicant 4 0.0 0.0 4 **$317** # of applicants/year (3
- yr avg . over 2007
- 2009) 25 90 Total annual cost **$7,817** Burden hours are from representative school districts that applied for this award in the past. Wages rates are from BLS for NAICS 999300

– Local Government. May 2014 data. In Table 1, the cost to apply for the Great Start Award is estimated to be $317 per applicant. Based on the data on the number of applicants from the Agency ’s In door Air Qualit y (IAQ) project , 25 entit ies are estimated to apply for this award annually for the three
- ye ar IC R period
. The estimated total burden hours are 90 hours and total cost is $7,817. **Table 2. Average Annual Respondent Burden and Cost Estimates -**  **Leadership Award**

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $86.43 $65.36 $40.14 per hour per hour per hour **Average tim e to read instructions**  1.0 0.0 0.0 1.0 $86 **Average tim e to plan activities**  1.5 0.0 0.0 1.5 $130 **Average tim e to gather information**  5.0 0.0 0.0 5.0 $432 **Average tim e to compile and review**  14.0 0.0 0.0 14.0 $1,210 **Average tim e to complete and submit paperwork**  14.0 0.0 0.0 14.0 $1,210 **Average tim e to store/m**  **aintain data** 2.0 0.0 0.0 2.0 $173 Total per applicant 38 0.0 0.0 38 **$3,241** # of applicants/year (3
- yr avg . over 2007
- 2009) 10 375 Total annual cost **$32,410** Burden hours are from representative school districts that applied for this award in the past. Wages rates are from BLS for NAICS 999300

– Local Government. May 2014 data. In Table 2, the cost to apply for the Leadership Award is estimated to be $3,241 per applicant. Based on the data on the number of applicants from the Agency ’s Indoor Air Qualit y (IAQ) project , 10 e ntities are estimated to apply for this award annually for the three
- ye ar IC R period
. The estimated total burden hours are 375 hours and total cost is $32,410.February 17, 2016

Page 14 of 22 **Table 3. Average Annual Respondent Burden and Cost Estimates -**  **Excellence Award**

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $86.43 $65.36 $40.14 per hour per hour per hour **Average tim e to read instructions**  0.5 0.5 $43 **Average tim e to plan activities**  2.0 2.0 4.0 $304 **Average tim e to gather information**  8.0 8.0 16.0 $1,214 **Average tim e to compile and review**  0.5 0.5 $43 **Average tim e to complete and submit paperwork**  0.5 0.5 $43 **Average tim e to store/m**  **aintain data**  0.5 0.5 $43 Total per applicant 12 10 0 22 **$1,691** # of applicants/year (3
- yr avg . over 2007
- 2009) 9 198 Total annual cost **$15,216** Burden hours are from representative school districts that applied for this award in the past. Wages rates are from BLS for NAICS 999300

– Local Government. May 2014 data. In Table 3, the cost to apply for the Excellence Award is estimated to be $1,691 per applicant. Based on the data on the number of applicants from the Agency ’s Indoor Air Qualit y (IAQ) project, 9 entities are estimated to apply for this award annually

for the three
- year ICR period. The estimated total burden hours are 198 hours and total cost is $15,216.
**Table 4. Average Annual Respondent Burden and C ost Estimates**  **- Sustained Excellence**  **Award**
**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $86.43 $65.36 $40.14 per hour per hour per hour **Average tim e to read instructions**  2.0 0.0 0.0 2.0 $173 **Average tim**  **e to plan activities** 4.0 4.0 0.0 8.0 $607 **Average tim e to gather information**  4.0 4.0 0.0 8.0 $607 **Average tim e to compile and review**  4.0 4.0 0.0 8.0 $607 **Average tim e to complete and submit paperwork**  2.0 2.0 0.0 4.0 $304 **Average tim e to**  **store/m aintain data**  1.0 0.0 0.0 1.0 $86 Total per applicant 17 14 0 31 **$2,384** # of applicants/year (3
- yr avg . over 2007
- 2009) 4 134 Total annual cost **$10,332** Burden hours are from representative school districts that applied for this award in the past. Wages rates are from BLS for NAICS 999300

– Local Government. May 2014 data. In Table 4, the cost to apply for the Sustained Excellence Award is estimated to be $2,384 per applicant. Based on the data on the number of applicants from th e Agency ’s Indoor Air Quality

(IAQ) project , 4 entities are estimated to apply for this award annually for the three
ye ar ICR period
. The estimated total burden hours are 134 hours and total cost is $10,332.February 17, 2016

Page 15 of 22 **Table 5. Average Annual Respondent Burden and Cost Estimates**  **- Connector Award** 

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $86.43 $65.36 $40.14 per hour per hour per hour **Average tim e to read instructions**  0.5 0.5 $43 **Average tim e to**  **plan activities** 0.5 0.5 $43 **Average tim e to gather information**  2.0 2.0 $173 **Average tim e to compile and review**  6.5 6.5 $562 **Average tim e to complete and submit paperwork**  4.5 4.5 $389 **Average tim**  **e to store/m aintain data**  0.4 0.4 $35 Total per applicant 14 0 0 14 **$1,245** # of applicants/year (3
- yr avg . over 2007
- 2009) 5.0 72 Total annual cost **$6,223** Burden hours are from representative school districts that applied for this award in the past. Wages rates are from BLS for NAICS 999300

– Local Government. May 2014 data. In Table 5, the cost to apply for the Sustained Excellence Award is estimated to be $1,245 per applicant. Based on the data on the number of applicants from the Agency ’s Indoor Air Quality

(IAQ) project , 5 entities are estimated to apply for this award annually for the three
ye ar ICR period
. The estimated total burden hours are 72 hours and total cost is $6,223. **6 (c**  **) Est i**  **m a**  **t i**  **n g Ag**  **e n**  **c y**  **B u**  **r d**  **e n**  **a n**  **d Cost**  As in th e case of respondents , the burden hour d ata f rom the EPA’s Indoor Air Quality program is used to estimate the Agency burden and cost
. To d e te r m i ne A g e n c y c o st s , the EPA used the B ure a u of L a bor St at i st i c s esti m ates of labor r a tes for 2014 f

or th e N A I CS c ode f

or the Fed e r a l E x ec ut i ve B r an c h (N A I CS 9991 0 0 )
. The man a g e ri a l l a

b o r rate is bas e d on the SOC (Standard Occupational C lassifi cat i on) f or man a g e ment o c c up at i on s ; the te c hnic a l l a bor r a te i s bas e d on the SOC f

or l i f e , p h ysic a l and so c ial s c ie n c e o c c up at i ons; and the c le ric a l l a bor r ate is b a s e d on the SOC f or of f i c e an d a dm i nis tr a

t i ve support o c c up at i ons. The labor r a t e s ar e f ul l y load e d and include benefits and overhead. Detailed labor costs for agency labor is included in Attachment H
. Tables 6 to 10 summarize the Agency ’s burden hours and costs for the different award categories
. **Table 6. Average Annual Agency Burden and Cost Estimates -**  **Great Start Award**

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $84.81 $55.73 $31.73 per hour per hour per hour Average time to read application and determine if applicant met requirements. 0.00 0.13 0.00 0.13 $7February 17, 2016

Page 16 of 22 Average time to accept/deny, create a form letter and print paper certificate. Division Director signature. 0.05 0.08 0.00 0.13 $9 Average time to create mailing label, track applicant in the awards tracking spreadsheet, mail certificate and letter to applicant. 0.00 0.03 0.00 0.03 $2 Total per applicant 0.05 0.25 0.00 0.30 **$18** # of applicants/year (3
- yr average over 2007
- 2009) 25 7 Total annual cost **$448** Burden hours are from the EPA OAR's Indoor Air Quality program. Wages rates are from BLS for NAICS 999100

– Federal Government. May 2014 data. In Table 6, the Agency

cost per applicant ($18) is estimated first, and multiplied by the average annual total number of applicants (25) to obtain an estimate ($448) of the total Agency cost for the Great Start award. The per
- applicant Agency cost is obtai ned by

summing the products of wage rates (managerial, technical, and clerical) and the per
- applicant burden hours for each labor t ype (0.05 hours of managerial labor, 0.25 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed b y the Agency includes those applications that are not chosen for award as well
. **Table 7. Average Annual Agency Burden and Cost Estimates -**  **Leadership Award.**

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $84.81 $55.73 $31.73 per hour per hour per hour Average time to read application and determine if applicant met requirements. 0.0 0.17 0.0 0.17 $9 Average time to accept/deny, create a form letter and print paper certificate. Division Director signature. 0.05 0.08 0.0 0.13 $9 Average time to create mailing label, track applicant in the awards tracking spreadsheet, mail certificate and letter to applicant. 0.0 0.03 0.0 0.03 $2 Total per applicant 0.05 0.28 0.00 0.33 **$20** # of applicants/year (3
- yr average over 2007
- 2009) **10** 3 Total annual cost **$200** Burden hours are from the EPA OAR's Indoor Air Quality program. Wages rates are from BLS for NAICS 999100

– Federal Government. May 2014 data. In Table 7, the Agency

cost per applicant ($20) is estimated first, and multiplied by the average annual total number of applicants (10) to obtain an estimate ($200) of the total Agency cost for the Leadership award. The per
- applicant Agency cost is obtained by

summing the products of wage rates (managerial, technical, and clerical) and the per
- applicant burden hours for each labor t ype (0.05 hours of managerial labor, 0.28 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed b y the Agency includes those applications that are not chosen for award as well
.February 17, 2016

Page 17 of 22 **Table 8. Average Annual Agency Burden and Cost Estimates -**  **Excellence Award**

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $84.81 $55.73 $31.73 per hour per hour per hour Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet. 0.00 0.08 0.00 0.08 $5 Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets. 0.00 0.08 0.00 0.08 $5 Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application. 0.25 0.25 0.00 0.50 $35 Provide regional staff PDFs of their applicants for their review and weigh
- in as personnel that may have worked with districts specifically. 0.00 0.08 0.00 0.08 $5 In two weeks assimilate all score and hold half day consensus meeting to determine what schools districts are awards. During this meeting each applicant is discussed and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year’s application if they were not chosen this year. 0.00 5.00 0.00 5.00 $279

Provide a list of selected applicants to recognize ; submit to EPA regions and senior management for approval. 0.50 0.50 0.00 1.00 $70 Conduct compliance scans on school districts and reconcile any issues that may arise. 0.00 0.50 0.00 0.50 $28 Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of im provement of the application. 0.00 0.50 0.00 0.50 $28
If there is an event designated for highlighting the award winning school districts and invitational travel involved, convey logistics to selected applicants. 0.00 0.17 0.00 0.17 $9 Using award winning applications create communications materials to showcase these award winning programs. Initiate comprehensive outreach communications plan
. If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories. 0.50 1.00 0.00 1.50 $98
Total per applicant 1.25 8.17 0.00 9.42 **$561** # of applicants/year (3
- yr average over 2007
- 2009) **9** 85 Total annual cost **$5,050** Burden hours are from the EPA OAR's Indoor Air Quality program. Wages rates are from BLS for NAICS 999100

– Federal Government. May 2014 data.February 17, 2016

Page 18 of 22 In Table 8, the Agency

cost per applicant ($561) is estimated first, and multiplied by the average annual total number of applicants (9) to obtain an estim ate ($5,050) of the total Agency cost for the Excellence award. The per
- applicant Agency cost is obtained by

summing the products of wage rates (managerial, technical, and clerical) and the per
- applicant burden hours for each labor t ype (1.25 hours of mana gerial labor, 8.17 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed b y the Agency includes those applications that are not chosen for award as well
. **Table 9. Average Annual Agency Burden and Cost Estimates**  **- Sustained Excellence Award** 

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $84.81 $55.73 $31.73 per hour per hour per hour Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet. 0.00 0.08 0.00 0.08 $5 Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets. 0.00 0.08 0.00 0.08 $5 Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application. 0.25 0.25 0.00 0.50 $35 Provide regional staff PDFs of their applicants for their review and weigh
- in as personnel that may have worked with a districts specifically. 0.00 0.08 0.00 0.08 $5 In two weeks assimilate all score and hold half day consensus meeting to determine what schools districts are awards. During this meeting each applicant is discussed and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year’s application if they were not chosen this year. 0.00 5.00 0.00 5.00 $279

Provide a list of selected applicants to recognize; submit to EPA regions and senior management for approval. 0.50 0.50 0.00 1.00 $70 Conduct compliance scans on school districts and reconcile any issues that may arise. 0.00 0.50 0.00 0.50 $28 Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of im provement of the application. 0.00 0.50 0.00 0.50 $28
If there is an event for highlighting the award winning school districts and invitational travel involved, convey logistics to selected applicants. 0.00 0.17 0.00 0.17 $9February 17, 2016

Page 19 of 22 Using award winning applications create communications materials to showcase these award winning programs. Initiate comprehensive outreach communications plan). If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories. 0.50 1.00 0.00 1.50 $98 Total per applicant 1.25 8.17 0.00 9.42 **$561** # of applicants/year (3
- yr average over 2007
- 2009) 4 41 Total annual cost **$2,431** Burden hours are from the EPA OAR's Indoor Air Quality program. Wages rates are from BLS for NAICS 999100

– Federal Government. May 2014 data. In Table 9, the Agency

cost per applicant ($561) is estimated first, and multiplied by the average annual total number of applicants (4) to obtain an estimate ($2,431) of the total Agency cost for the Sustained Excellence award. The per
- applicant Agency cost is obtained by

summing the products of wage rates (managerial, technical, and clerical) and the per
- applicant burden hours for each labor ty

pe (1.25 hours of managerial labor, 8.17 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed by the Agen cy includes those applications that are not chosen for award as well
. **Table 10. Average Annual Agency Burden and Cost Estimates -**  **Connector Award**

**Collection Activities Burden Hours**  **Total** Management Technical Clerical Hours Costs $84.81 $55.73 $31.73 per hour per hour per hour Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet. 0.00 0.08 0.00 0.08 $5 Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets. 0.00 0.08 0.00 0.08 $5 Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application. 0.25 0.25 0.00 0.50 $35 Provide regional staff PDFs of their applicants for their review and weigh
- in as personnel that may have worked with a districts specifically. 0.00 0.08 0.00 0.08 $5 In two weeks assimilate all score and hold half day consensus meeting to determine what schools districts are awards. During this meeting each applicant is discussed and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year’s application if they were not chosen this year. 0.00 4.50 0.00 4.50 $251

Provide list of selected applicants to recognize to regions and senior management for approval. 0.50 0.50 0.00 1.00 $70 Conduct compliance scans on school districts and reconcile any issues that may arise. 0.00 0.50 0.00 0.50 $28February 17, 2016

Page 20 of 22 Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of im provement of the application. 0.00 0.50 0.00 0.50 $28
If there is an event for highlighting the award winning school districts and invitational travel involved, convey logistics to selected applicants. 0.00 0.17 0.00 0.17 $9 Using award winning applications create communications materials to showcase these award winning programs. Initiate comprehensive outreach communications plan
. If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories. 0.50 1.00 0.00 1.50 $98
Total per applicant 1.25 7.67 0.00 8.92 **$533** # of applicants/year (3
- yr average over 2007
- 2009) **5** 45 Total annual cost **$2,666** Burden hours are from the EPA OAR's Indoor Air Quality program. Wages rates are from BLS for NAICS 999100

– Federal Government. May 2014 data. In Table 10, the Agency

cost per applicant ($533) is estimated first, and multiplied by the average annual total number of applicants (5) to obtain an estimate ($2,666) of the total Agency cost for the Connector award. The per
- applicant Agency cost is obtained by summing the products of wage rates (managerial, technical, and clerical) and the per
- applicant burden hours for each labor t ype (1.25 hours of managerial labor, 7.67 hours of technical labor, and zero hours of clerical labor). Note that the total number of applications reviewed b y the Agency includes those applications that are not chosen for award as well
. **6 (**  **d ) Bo**  **t t**  **o m**  **Li n**  **e Burden**  **Ho u**  **r s a**  **n d**  **Cos t**  **s** In this section, the total respondent and Agency burden hours and costs over all award ty pes are summarized (Table 11).
**Table 11: Total Annual Burden and Cost Summary**  Total burden hours Total cost **Respondents 870**  **$ 71,998**  Great Start Award 90 $ 7,817 Leadership Award 375 $ 32,410 Excellence Award 198 $ 15,216 Sustained Excellence Award 134 $ 10,332 Connector Award 72 $ 6,223 **Agency 181**  **$ 10,796**  Great Start Award 7 $ 448 Leadership Award 3 $ 200 Excellence Award 85 $ 5,050February 17, 2016

Page 21 of 22 Sustained Excellence Award 41 $ 2,431 Connector Award 45 $ 2,666 Source: Tables 1
- 10 in this document. For the respondents across all categories of awards, the total annual cost of applying for the School IPM recognition program is estimated at 870 burden hours and $71,998. These costs consist of preparing, submitting, and recordkeeping of applications. For the EPA, the total cost of administering this recognition program is estimated at 181 hours and $10,796 annually , most of which is the cost of reviewing the applications for awards (Table 11). **6 (e**  **) R e**  **aso n**  **s F**  **o r Cha**  **n g**  **e s in**  **B u**  **r d**  **e n**  This I CR is being submitted for approval for the first time. **6 (**  **f )**  **B u**  **r d**  **e n**  **S ta**  **teme n**  **t** The annu a l r e spond e nt b urd e n for th i s I CR is est i mat e d to av e ra g e 870 hours. This i n c ludes average times to carry out activities in Tables 1

– 5 in the section 6 (b) above. The A g e n c y h a s est a

bl i s h e d a publ i c do c k e t for this I CR und e r D o c k e t ID No. EPA
- HQ
OPP
- 2016
- 0047 , whi c h is av a i lable f or onl i ne vie w i n g at htt

p: //www . re g

u l at i ons. g o v , or in person viewing at the EPA Docket Center Public Reading Room, EPA West Building, Room 3334, 1301 Constitution Avenue, NW, Washington, DC 20004. The EPA Docket Center is open from 8:30 a.m. to 4 p.m., Monday through Friday , excluding federal holiday s. The docket telephone number is (202) 566
- 1744. You may submit comments regarding the Agency 's need f or this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden, including the use of automated collection techniques. Comm e nts may be submi tted to EPA e le c troni ca l l y thro u gh htt p: //www . r e gulations. g ov or b y mail addre ssed to Di r ec t o r , Co l le c t i on S tr ate g ies Division, U. S . Environm e ntal P rot ec t i on A g e n c y (282 2 T ) , 1200 P e nn s y l v ania Av e ., N W , W a shin gt on, D.C. 20460. You c an a lso s e nd c omm e nts t o the O f

fi c e o f In f o rm at i on an d Re g

ulato r y A f

f a irs, of the Office of M an a g e ment and B u d g e t, 725 17 th S tr ee t, N W , W a shin gton, DC 20503, Attention: D e sk O f fi c e f or EPA. I n c lude d o c k e t ID No. EPA
- HQ
- OPP
- 2016
- 0047 and OMB c ontrol number 207 0
- NEW in an y c o r r e spon d e n ce .February 17, 2016

Page 22 of 22 **LIST OF ATTACHMENTS** All of the att ac hments lis t e d b e low can b e f ound i n the do c k e t for th i s I CR or a h y p e rlink is provid e d for the sourc e d o c ument at i o n. The do c k e t f o r the a c t i on is acce ss i ble e l ec tron i ca l l y thro u gh htt

p: //www . re g

ulations
. gov using the do c k e t i d e nt i fi e r EPA
- HQ
- OPP
- 2016
- 0047
. ATTACHMENT A: 42 UCS 133 P ol lut i o n P r ev e nt i on A c t of 199 0 , av a i l a ble at htt p: //www . g

po . g ov/fd s y s/pkg

/U S CO D E
- 200 9
- t i t l e 42/pdf/USCO D E
- 2009
- t i t l e 4 2
- c h a p133.pd f ATTACHMENT B: 7 USC 136a, Registration of Pesticides, available at

http://www.gpo.gov/fds ys/pkg/USCODE
- 2010
- title7/pdf/USCODE
2010
- title7
- chap6
- subchapII
- sec136a.pdf ATTACHMENT C : 7 USC 136r

– 1, Integrated Pest Management, av a i l a ble at htt p: //www . g

po . g ov/fd s y s/pkg

/U S CO D E
- 201 0
- t i t l e 7/pdf/US C O D E
2010
- t i t l e 7
- c h a

p 6
- subc h a

p I I
- s ec 13 6r
- 1.pd f

. ATTACHMENT D: Stakeholder Survey L etter and Responses

– Respondent Burden Estimates ATTACHMENT E : Reserved ATTACHMENT F: SIPM Award Program Application Guide and Forms ATTACHMENT G: SIPM Award Program Conditions and Criteria ATTACHMENT H: Wage Rates Worksheet