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This Information Collection Request (ICR) calculates the burden and costs associated with the recognition application for the Environmental Protection Agency's (EPA) Sustainable Water Leadership Program, formerly the National Clean Water Act Recognition Awards Program and prior to that, the National Wastewater Management Excellence Awards Program.

This voluntary program has been updated to reflect new industry practices consistent with EPA’s sustainable infrastructure initiatives and is now called the Sustainable Water Leadership Program. It is authorized by Section 501(e) of the Clean Water Act (CWA). The Sustainable Water Leadership Program maintains elements from the previous Clean Water Act Recognition Awards Program, namely, excellence in operations and maintenance, biosolids, combined sewer overflows, pretreatment, and stormwater management, and also expands eligibility to community drinking water utilities and systems, as well as managed decentralized treatment systems (public or private). The development of the Sustainable Water Leadership Program is the latest evolution in EPA’s commitment to recognize and award outstanding and innovative utility management practices.

In 1985, EPA established the Operations and Maintenance (O&M) awards program to provide a positive incentive for compliance with the National Pollutant Discharge Elimination System (NPDES). Because of the successes of the O&M Awards program, in 1988, EPA amended the program to include the Beneficial Biosolids Use awards (formerly Sludge awards). In 1989, the Pretreatment awards were added. Pretreatment Program activities are covered under a separate ICR (OMB Control No. 2040-0009, EPA ICR No. 0002.14). In 1990, EPA established the Combined Sewer Overflow (CSO) and Stormwater Management awards programs and added these programs to the Clean Water Act Recognition Awards Program.

The Sustainable Water Leadership Program consists of two components: 1) a recognition program that acknowledges applicants that are moving toward sustainable operations and meet specified criteria identified in the application, and 2) a competitive awards program to showcase the “best of the best” in a specific topic area selected in advance by EPA. This ICR addresses the application burden for the recognition component; the awards component is still under development. An update to this ICR will be provided following finalization of the awards component. The recognition component requires that an applicant meet criteria under specific categories. One category Effective Utility Management, is mandatory for all applicants, and is based on the Attributes of Effectively Managed Systems that EPA and members of the water sector have endorsed. In addition, applicants are asked to describe activities in other areas of their choice including: biosolids, pretreatment, decentralized systems, energy management, water efficiency, climate change adaptation and or mitigation, and watershed approaches, including source water protection and stormwater.

The updated application provides the mechanism for the applicants to demonstrate how they meet the required criteria. Organizations applying for recognition will be evaluated on the basis of the criteria described in the application but will not compete directly with other applicants for recognition.

The regulation which establishes the framework to implement the recognition program is at 40 CFR Part 105. A copy is attached in Appendix A.

The respondent will read the instructions for completing the application. It is anticipated that respondents will use existing files, planning and progress reports, and institutional knowledge to complete the application. Based on the instructions provided with the application, the respondent will compile the requested information and write up to a 10-page narrative on how the facility meets the specified criteria in the application.

The information collection will be used by EPA’s Office of Water, led by the Office of Wastewater Management, to evaluate and determine if the required criteria are met for recognition. Based on the collection, national panels will evaluate the nominee's efforts and recommend finalists.

Utilities that are recognized will receive a letter and certificate signed by the EPA Administrator or Assistant Administrator for Water, their utility name will be posted on EPA and outside organization web sites, and announced at national conferences. EPA regions may also opt to hold Regional ceremonies. Additional recognition will be made through a Federal Register notice, and other national publications.

During the 3 years covered by this ICR, the information collection for the Sustainable Water Leadership Program would involve responses from an estimated total of 2,036 respondents and cost approximately $1.8 million (all labor cost), with annual averages of 679 respondents, 13,574 burden hours, and costs of $614,919 per year (for additional detail, see Section 6). EPA estimates assume that water systems in multiple size-categories will have different response rates to Program outreach. The cost to the Agency is estimated to be approximately $56,575 per year, with no anticipated capital or operation and maintenance (O&M) costs.

2. Need For and Use of the Collection

2(a) Need/Authority for the Collection

Section 501(e) of the CWA (copy attached in Appendix B) authorizes a program to recognize political subdivisions of states and industrial organizations that demonstrate outstanding technological achievements, innovative processes, devices or other outstanding methods in their waste treatment and pollution abatement programs. Recognition is given through EPA's voluntary Sustainable Water Leadership Program. EPA will recognize applicants that are moving toward sustainable operations and meet specific criteria identified in the application. Applicants will be asked to describe activities in the area of Effective Utility Management and in other areas of their choice related to Resource Protection and Efficiency. A narrative description of how the utility meets the criteria is needed to complete the application and determine whether to recognize the utility.

2(b) Practical Utility/Users of the Data

Information collected will be used for the Sustainable Water Leadership Program by EPA’s Office of Water. The information collected will be used by EPA to evaluate and determine if the required criteria are met for recognition. Based on the collection, national panels will evaluate the nominee's efforts and recommend finalists who have demonstrated that they are moving toward sustainable operations and are implementing practices identified in the application.

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

3(a) Non-duplication

The design, operating, and environmental information needed to complete the application is not immediately available in databases or files of a State or Federal office. If such data is available, it may exist in an outdated report or database which cannot be timely or readily cross-referenced to the requested data. Demonstrations of program accomplishments required by the Sustainable Water Leadership Program must be provided from the water and wastewater management facilities and programs as it is not available from any other source.

3(b) Public Notice Required Prior to ICR Submission to OMB

In compliance with the 1995 Paperwork Reduction Act (PRA), any agency developing a non-rule-related ICR must solicit public comments before submitting the ICR to OMB. These comments, which are used partly to determine realistic burden estimates for respondents, must be considered when completing the Supporting Statement that is submitted to OMB.

This ICR was published in the Federal Register on Feb. 19, 2010 (75 FR 7476). The notice included a request for comments on the content and impact of these information collection requirements on the regulated community. No comments were received.

3(c) Consultations

EPA has spent over two years consulting with other water and wastewater professionals on the development of this new program. EPA headquarters convened an EPA Regional Workgroup that assisted in the program development including the criteria and content of the new recognition application. In addition, EPA had several meetings with outside stakeholders and trade associations that represent the potential respondents for this application. Feedback from these consultation groups was considered and is reflected in the new application being used for information collection.

EPA strives to minimize the burden on all respondents, especially small communities/businesses. In previous years, EPA asked the Regional and State personnel to assist the respondents where necessary in completing the application. For the new program, EPA will continue to request that the Regions assist the respondents where necessary. In addition, EPA tentatively plans to conduct at least one webcast on completing the application and will be available for specific questions from potential respondents. Guidance on completing the application will also be provided on EPA’s web site.

For the previous program, EPA managers solicited feedback on its application from non-Federal panelists and from past municipal winners in a very informal manner. EPA managers also received indirect comments from Regional EPA employees, who were also in contact with municipal and industrial entities and State officials. Positive and negative feedback were both evaluated. Feedback from the State’s facility operators stated that the old application form for awards was too complex and was a significant burden for the plant staff. Based on these comments and feedback from Regions, EPA has attempted to make the new application form for the Sustainable Water Leadership Program more streamlined.

3(d) Effects of Less Frequent Collection

Recognition will be determined every other year, with recognition lasting a total of three years. The EPA recognition program manager sends out the application and instructions in May/June of each recognition-year. The completed application is received by EPA headquarters in September/October, and an EPA panel reviews the applications in November/December. Recognition letters and certificates are sent in January/February [final schedule to be determined]. Since the program is designed to recognize the current state of treatment facilities, less frequent collection of information would impact the goals of the program to recognize and incentivize innovative and effective practices for water treatment.

3(e) General Guidelines

This information collection request is consistent with guidelines contained in 5 CFR 1320.5(d)(2).

3(f) Confidentiality

Respondents are not being asked to submit any confidential information in the recognition application. As a result, no confidential information is involved for this collection activity. However, any claim of confidentiality must be asserted at the time of submission. If any confidential information is submitted, all confidential data will be handled in accordance with 40 CFR 122.7, 40 CFR Part 2.

3(g) Sensitive Questions

Sensitive questions are defined in EPA’s ICR Handbook, Guide to Writing Information Collection Requests Under the Paperwork Reduction Act of 1995 as “questions concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private.” The requirements addressed in this ICR do not include sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC and NAICS Codes

The Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS) codes for the respondents affected by this information collection activity are as follows:

SIC: 4952; NAICS: 22131 - Water Supply and Irrigation Systems
SIC: 4952; NAICS: 22132 - Sewage Treatment Facilities
SIC: 8711; NAICS: 54133 - Engineering Services
SIC: 4953; NAICS: 56292, 562211-262213, 562219 - Refuse Systems
SIC: 8221; NAICS: 61131 - Colleges, Universities, Professional Schools
SIC: 9511; NAICS: 92411 - Air and Water Resource and Solid Waste Management (Administration of Environmental Quality)

4(b) Information Requested

This section presents the data items, including recordkeeping requirements, and required respondent activities involved in preparing and submitting those data items.

4(b)(i) Data Items, Including Record Keeping Requirements

The requested information should be readily available from facility operating records. Respondents may include flow, permit, operating, and environmental compliance data with the required narrative description of the facility’s activities.

4(b)(ii) Respondent Activities

To be considered for recognition, the respondent will read the instructions for completing the application. The respondent will use existing files when possible, planning and progress reports, and institutional knowledge to complete the application. The respondent will prepare a written narrative description on how the facility meets the criteria stated in the application. A copy of the current application is attached in Appendix C.

5. The Information Collected—Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

The completed application is sent directly to EPA headquarters by the specified application deadline. EPA is strongly requesting that applications be sent electronically to the specified email address on the application. The review of electronic applications will reduce the burden on the agency. EPA will still accept hand-written applications.

Each application is first reviewed by EPA for completeness. The completed applications will then be sent to EPA’s Office of Enforcement and Compliance Assurance for a criminal compliance check. In addition to criminal compliance, information for each application will also be entered into EPA’s Online Tracking Information System (OTIS) for an administrative compliance check. It is assumed that 20 percent of the completed applications will not be in compliance with applicable water quality requirements for the past year and will not have a satisfactory record with respect to environmental quality. The remaining 80 percent of the applications will then move forward in the review process.

The applications that are deemed complete and without compliance violations will be provided to the respective review panels consisting of representatives from EPA's headquarters and Regions and also potentially non-EPA technical professionals. The panels will review each application to determine if it meets the specified criteria. The panels will make recommendations to EPA management on which facilities to recognize.

The facilities that are recognized will receive a letter and certificate signed by the EPA Administrator or Assistant Administrator for Water, their utility name will be posted on EPA and outside organization web sites, and announced at national conferences. EPA regions may also opt to hold Regional ceremonies. Additional recognition will be made through a Federal Register notice, and other national publications.

5(b) Collection Methodology and Management

All nominees are screened for environmental compliance by EPA. Data quality information will be retrieved from the Agency's Permit Compliance System (PCS), OTIS, Safe Drinking Water Information System (SDWIS), the new Integrated Compliance Information System (ICIS-NPDES) database, other environmental reports, and professional knowledge of the facility or program.

5(c) Small Entity Flexibility

This information collection activity does not concern a rulemaking. A framework to implement the awards recognition program is at 40 CFR Part 105. EPA strives to minimize the burden on all respondents, especially small communities/businesses. The recognition application for the Sustainable Water Leadership Program includes reduced requirements for small entities. EPA headquarters and some EPA Regions will be available to assist respondents to answer the application.

5(d) Collection Schedule

The information collection schedule is contained in the respondents' application. The EPA recognition program manager sends out the application and instructions in May/June of each year. The completed application is received by EPA headquarters in September/October, and the panel reviews the applications in November/December. Recognition letters and certificates are sent in January/February [schedule to be determined by EPA].

6. Estimating the Burden and Cost of the Collection

The following sections present the rationale, assumptions made, and results of EPA’s estimation of burden and costs for the Sustainable Water Leadership Program. See Appendix D for specific assumptions made to estimate the burden and cost of the Program.

6(a) Estimating Respondent Burden

This section describes the burden estimates for facilities to complete the application, as well as the methods used and assumptions made to derive them. Respondent activities are separated into those activities that will occur in year 1 of the program and those activities that will occur in year 3 of the program. The reason for this is that applications for recognition are submitted every 2 years. The Respondent Activity Exhibits E.1-E.6 in Appendix E presents all calculations and results discussed in this subsection. EPA estimates that the total annual burden to applicant respondents is approximately 13,600 hours.

To calculate the total annual applicant respondent burden, EPA first calculated the burden for each type of applicant respondent in years 1 and 3 of the program^¹. The Agency then added these together. Then, the sum of the burdens for each respondent expected over the next three years was divided by three to obtain the estimated total annual burden.

For those applicants applying for recognition, this ICR only calculates burden and cost for a three year period. At the end of that period, this ICR will be revised with new calculations, as appropriate, for the following three years. Therefore, for the burden and cost calculations for respondents applying for recognition, the estimate of the total number of applicants expected over the next three years is divided by three to obtain the estimated number of applicants per annum. Exhibit E.1 estimates the number of respondents that will provide application information over the next three years.

The total number of applicant respondents is estimated to be 2,037, including 530 applicants in Year 1 and 1,507 in Year 3. The responses are collected once every two years. EPA estimates the total annual number of applicant respondents to be 679.

The respondents reporting burden is estimated to be 20 hours per response: 2 hours for manager to read instructions and search data; 16 hours for staff to gather information and complete the application; and 2 hours for administrative support staff to prepare forms. The average annual burden is estimated to be 13,574 hours. For a more detailed presentation of hourly burdens for applicant respondents see Exhibits E.3-E.9 in Appendix E.

In addition, states will not incur any burden and costs associated with this ICR since EPA will conduct the review of applications. As a result, the burden and cost for reviewing applications will belong to the federal government exclusively.

6(b) Estimating Respondent Costs

This section describes cost estimates for respondents, as well as the methods used to derive them. Because EPA has determined that there are no capital or operation and maintenance costs associated with any of the respondent activities, this ICR only includes labor costs in its estimates.

6(b)(i) Estimating Labor Costs

The costs to applicant respondents associated with the ICR activities can be estimated by multiplying the time spent in each labor category by an appropriately loaded hourly wage rate.

EPA used the following categories and hourly rates to estimate labor costs for activities by applicant respondents. A labor rate of $55.00 hour was used for managers, $46.86 for staff, and $23.12 for administrative support. These rates are based on the mean hourly cost of employment for all occupations, including benefits, and are adjusted with the Employment Cost Index (ECI) for civilian workers to September 2009 dollars. These hourly rates were based on the average hourly wage for civilian workers as determined by the U.S. Department of Labor.^²

6(c) Estimating Agency Burden and Cost

EPA’s estimate of its burden and costs are from the activities described in Section 5(a). When calculating the Agency cost, EPA makes the following assumption:

EPA determined the hourly employment cost of federal employees using methodology established in previous ICRs. According to the U.S. Office of Personnel Management, 2009 General Schedule (2009-GS), the average hourly wage of a federal employee at the GS-13, Step 5 level is $38.35. Assuming overhead costs of 50 percent, or $19.18 per hour, the fully loaded cost of employment for a program management-level federal employee is $57.53. The average hourly wage for a federal employee at the GS-8, Step 5 level is $20.13. Assuming overhead costs of 50 percent, or $10.07 per hour, the fully loaded cost of employment for program support-level federal employee is $30.20.

Completeness Review

EPA estimates that the Agency will spend approximately 0.17 hour (10 minutes) reviewing each application for completeness. In addition, EPA estimates that 10 percent of the applications submitted will be incomplete and will result in 0.5 hour each for additional follow-up. The total annual burden for the completeness review is 147 hours and $8,454. See Exhibits F.1, F.2 and F.9 in Appendix F.

Compliance Review

EPA estimates that the Agency will spend 0.33 hour (20 minutes) reviewing each application for compliance. The total annual burden for the compliance review is 204 hours and $11,717. See Exhibits F.3, F.4, and F.9 in Appendix F.

Substantive Review

EPA estimates that the Agency will spend 0.33 hour (20 minutes) per panel member for the substantive review. EPA assumed a total of three panel members which results in a substantive review of 60 minutes for each application. The total annual burden for the substantive review is 489 hours and $28,111. See Exhibits F.5, F.6 and F.9 in Appendix F.

Post-Review Recognition

The burden and cost for EPA is based on the time required to develop and review the certificate and letter. EPA estimates that 0.33 hour (20 minutes) are required per recipient for certificates and letters. The total annual burden for the post-review recognition is 122 hours and $8,294. See Exhibits F.7, F.8, and F.9 in Appendix F.

6(d) Estimating the Respondents Universe and Total Burden and Cost

Detailed information describing the universe and basis for burden and costs is provided in Section 6(a). Exhibits E.1 and E.2 in Appendix E provides the respondents universe for all respondent categories used throughout this ICR. The total burden and costs for respondents submitting an application are summarized in Exhibit E.9 in Appendix E.

6(e) Bottom Line Burden Hours and Cost Estimates

6(e)(i) Respondent Tally

The bottom line burden hours and costs for applicant respondents are the average annual hours and costs collectively incurred for all activities during the 3-year period covered by this ICR. Table 1 provides a summary of the average annual number of respondents, burden hours, and costs. See Exhibit E.9 in Appendix E for additional details.

Table 1. Respondent Tally

	Totals
Total Annual Number of Respondents	679
Total Annual Respondent Burden Hours	13,574
Average Burden Hours per Respondent	20.00
Costs (labor)	$614,919
Costs (capital)-annualized	$0
Costs (O&M)	$0
Total Respondent Costs	$614,919

6(e)(ii) The Agency Tally

The bottom line burden hours and costs for the Agency are the total annual hours and costs collectively incurred for all activities during the period covered by this ICR. Table 2 provides a summary for Appendix F of the average annual Agency costs. See Exhibit F.9 in Appendix F for additional details.

Table 2. Summary of Agency Cost for the ICR Approval Period

	Total Annual Costs (2009$)
Agency Totals	$56,575

6(f) Reasons for Change in Burden

This ICR includes programmatic changes to the National Clean Water Act Recognition Awards Program to develop the Sustainable Water Leadership Program which are detailed below.

The current burden approved by OMB for the previous Clean Water Act (CWA) Recognition Awards ICR is 2,030 hours. In addition, the current burden approved by OMB for pretreatment awards (whose burden will be consolidated into this ICR) is 210 hours. This ICR estimates a total burden that is 11,544 hours more than the currently approved burden for the previous ICR. Table 3 presents the change in burden.

Table 3. Burden Change

Respondent	Reported Annual Burden (hours)		Change
Respondent	Previous ICR OMB Inventory	Current ICR	Change
Respondents
Applicant Respondents	1,160	13,574	12,414
Subtotal	1,160	13,574	12,414
NPDES-Authorized States
NPDES-Authorized States	870	0	-870
Subtotal	870	0	-870
Total	2,030	13,574	11,544

Some reasons for the change in burden include the following:

Changes and adjustments in the number and types of applicants eligible for recognition under the Sustainable Water Leadership Program. These three changes are anticipated to increase the average annual number of interested responses from 145 to 678.
- The universe of eligible entities now includes community drinking water utilities and systems, as well as managed decentralized treatment systems (public or private), which were previously not addressed in any ICR for the Clean Water Act Recognition Awards Program.
- Changes in the design of the program are expected to attract more eligible applicants.
- Additionally, it is anticipated that EPA’s active outreach will increase the number of respondents interested in participating in the program.
EPA updated the estimated time spent by respondents to complete the revised Recognition Application for Sustainable Water Leadership Program to 20 hours per respondent based on staff input.
Previously, EPA accounted for 870 hours for NPDES-Authorized States for reviewing applications. EPA has assumed the burden and cost for this activity since States are not expected to have requirements under the Sustainable Water Leadership Program.
This ICR now encompasses burden hours for pretreatment awards. Historically, pretreatment burden hours were covered under a separate ICR for the National Pretreatment Program (OMB Control No. 2040-0009, EPA ICR No. 0002.14). Burden hours for awards applications totaled 210 hours (120 for POTW’s and 90 for state agencies) in the most recent Pretreatment ICR. These hours will be removed from the Pretreatment Program ICR at its next renewal.

6(g) Burden Statement

The public reporting burden for respondents is estimated to average 20 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OW-2003-0064, which is available for online viewing at www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426.

An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OW-2003-0064 and OMB Control Number 2040-0101 in any correspondence.

1 Each type of applicant includes potential respondents from the following types of utilities: publicly or privately owned wastewater treatment plants or systems, community drinking water plants or systems, managed decentralized treatment systems (public or private), and municipally-owned stormwater systems. These respondents encompass the applicant pool from drinking water, wastewater, and pretreatment facilities.

2 From U.S. Department of Labor, Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 2, “Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Civilian workers, by occupational and industry group, June 2009.”: Management, business, and financial: $54.95, Professional and related: $46.61, Office and administrative support: $23.04. (http://stats.bls.gov/news.release/ecec.t02.htm)

File Type	application/msword
Author	Alejandro Escobar
Last Modified By	ctsuser
File Modified	2010-07-06
File Created	2010-07-06