EPA is requesting OMB approval to participate in an innovative reporting pilot in cooperation with OMB and state SRF program managers. Because of the ARRA deadlines that apply to water infrastructure projects, we request your approval by July 2 so that we can move forward with this pilot as soon as possible.
Please see attached statement for further explanation.
EPA is requesting an emergency clearance to enable it to fulfill the requirements and implementation schedules of the Act and Implementing Guidance. For example, the Implementing Guidance requires that, starting immediately, agencies must ensure all award documents and related communications include the clauses and provisions necessary to ensure award recipients are legally obligated and prepared to meet their reporting requirements under the Act. Without an emergency clearance, EPA would be unable to fulfill this requirement for immediate implementation.
EPA is requesting OMB approval to partcipate in a pilot reporting project for ARRA receipient reporting under section 1512 in accordance with the "Implementing Guidance for the Reports on the Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009" M-09-21.
This pilot should have a deminimus change in burden from the orginial EPA ARRA emergency ICR. For this reporting pilot ARRA receipients (states) funded through the EPA State Revolving Loan Programs would need to enter ARRA section 1512 data elements (covered by existing ICRs) using existing EPA systems (Clean Water SRF Benefits Reporting system and Drinking Water SRF Benefits Reporting system). The burden would be the time required for each receipient to download their section 1512 data from these systems and then submit the file to Federal Reporting.gov. No additional data beyond the existing ICR's will be collected. Any burden change is a result of changing the data entry and sumbision process.
Total time is likely to be less than 3 minutes additional per state program per fiscal quarter for the duration of ARRA reporting. The additional burden will provide EPA and OMB access to section 1512 data sooner than the Federal Reporting System. This information is critical to measuring program results and is necessary to measure progress against the ARRA statutory deadline of February 17, 2010 when all SRF ARRA funds must be under contract or construction. Through the pilot OMB, the Recovery Board and EPA will gain a better understanding of ARRA receipient reporting needs and concerns prior to the National launch of Federal Reporting.gov.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
2009 07 01 SRF Change Justification V2.doc
Change for SRF Programs