2021 SUPPORTING STATEMENT
0572-0157
Technical Assistance and Training and Training for Innovative Regional Wastewater Treatment Solutions (TAT/RWTS) Pilot Grant Program
A. Justification
1. Explain the circumstances that make the collection of information necessary.
On December 20, 2019, Congress passed the Further Consolidated Appropriations Act, 2019, which established a pilot program, the Technical Assistance and Training and Training for Innovative Regional Wastewater Treatment Solutions (TAT/RWTS) Pilot Grant Program, to assist communities with wastewater systems. One of the essential goals of the TAT/RWTS Pilot Grant Program is to allow rural communities to seek innovative regional solutions to wastewater treatment systems that have been hindered by uncompromising soil conditions. Congress appropriated $5 million in grant funding for the TAT/RWTS Pilot Grant Program in the Further Consolidated Appropriations Act, 2019 for fiscal year 2020, to remain available until expended.
Wastewater systems are basic and vital to both health and economic development. With environmentally sound waste disposal, rural communities can attract families and businesses that will invest in the community and improve the quality of life for all residents. Without safe and clean wastewater facilities, communities cannot sustain economic development or ensure the mitigation of health risks that can arise from poor sanitation.
Qualified regional consortiums will receive TAT/RWTS grant funds to identify and evaluate economically feasible innovative regional solutions to wastewater treatment concerns for historically impoverished communities in areas which have had difficulty installing traditional wastewater treatment systems due to soil conditions. Grants are for wastewater-related technical assistance, including such services as feasibility studies, preliminary design assistance and supervision, oversight, or training for the development of an application for financial assistance.
Grantees will be expected to provide the Agency with a detailed report to include the area to be served, the issues with the present method of wastewater discharge, the alternatives and innovative solutions to the wastewater issue, the long-term cost and effect of the solution, affordability including possible funding sources, potential treatment staff training needs, and lifecycle cost analysis.
This collection is a revision of a currently approved package. The collection of information from the public is necessary for the Rural Utilities Service (RUS) to identify projects eligible for the TAT/RWTS Pilot Program grants.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the Agency has made of the information received from the current collection.
Eligible Regional consortiums located in the United States and its territories may apply for this program. Eligible entities would include consortiums of regional institutions of higher education, academic health and research institutes, or economic development entities located in the region identified to be served that have experience in addressing these issues in the region. An applicant is eligible to apply for the TAT/RWTS grant if it:
(1) Is a consortium (as defined in the definitions section of this notice);
(2) Is legally established and located within one of the following:
(a) A state within the United States;
(b) The District of Columbia;
(c) The Commonwealth of Puerto Rico; or
(d) A United States territory;
(3) Has the legal capacity and authority to carry out the grant purpose;
(4) Has no delinquent debt to the federal government or no outstanding judgments to repay a Federal debt;
(5) Demonstrates that it possesses the financial, technical, and managerial capability to comply with Federal and state laws and requirements; and,
(6) Is not a corporation that has been convicted of a felony (or had an officer or agent acting on behalf of the corporation convicted of a felony) within the past 24 months. Any Corporation that has any unpaid Federal tax liability that has been assessed for which all judicial and administrative remedies have been exhausted or have lapsed, and that is not being paid in a timely manner pursuant to an agreement with the authority responsible for collecting the tax liability is not eligible.
Applicants must include all proposed activity under a single application. Failure to collect proper information could result in improper determinations of eligibility, improper use of funds, or hindrances in making awards authorized by the TAT/RWTS Grant Program. Applications must be submitted electronically using www.grants.gov. No other form of application will be accepted.
The following information is collected and accounted for under this collection package:
Narrative - Project Proposal. Applicants will provide a narrative of experience in providing services similar to those proposed. A brief description of successfully completed projects including the need that was identified, and objectives accomplished.
Additionally, as part of the Narrative, a project summary of the needs assessment/project goals and objectives, should be included to document the ability to administer Technical Assistance and Training, financial resources available to pay operational costs and provide financial assistance to projects and demonstrate secured commitments of financial support from other sources, if applicable.
The Narrative/Project Proposal should also include:
Documentation of Assistance Provided to Rural Development Employees. Applicants must identify and report any known relationship or association with a RUS employee such as close personal association, immediate family, close relatives, or business associates. This includes any assistance provided to employees.
Scope of Work/Work Plan. RUS uses the information in the scope of work to measure the performance of the grant recipient and the success of the project. The scope of work describes what will happen in a project, when, and what staff will be responsible. It provides details on the activities or tasks to be accomplished, objectives, timetables for task completion, and anticipated results.
Budget Justification. The budget justification demonstrates how the funds will be spent and provides details for proposed expenditures, calculations of costs, and explanations of unusual lines in the budget. It discusses how the budget supports the proposed project activities and explains how each budget item is essential to achieving project objectives. RUS uses this information to evaluate the cost effectiveness of the project and the adequacy of funding to carry out the activities of the project. The information will also be used to evaluate a grant recipient’s request for payments.
Latest Financial Information. The applicant’s latest financial statement is used to help determine if the applicant is financially viable to complete their proposed scope of work.
Evidence of Financial Management System. Applicant must provide evidence that a financial management system is in place or proposed. RUS uses the information to determine if the applicant will be able to adequately account for federal funds expended.
Evidence of Legal Existence and Authority. The applicant must submit certified copies of organization documents and a certified list of directors and officers as evidence of the applicant’s legal existence and authority for the proposed project. The organizational documents can be charters, bylaws, or articles of incorporation. RUS uses the information to determine if the applicant has the proper authority to enter into a binding agreement to use grant funds.
Evidence of Tax-Exempt Status. Private nonprofit organizations eligible for TAT/RWTS grants must have 501(c)(3) or 501(c)(4) tax-exempt status, designated by the Internal Revenue Service. An applicant must submit evidence of its tax-exempt status. RUS uses this information to ensure that the applicant meets the eligibility criteria mandated by law.
Post-Application Requirements Collected under this Package
RUS Bulletin 1775-1, “Grant Agreement.”
The Grant Agreement is the official grant instrument between RUS and the TAT/RWSTS recipient. It outlines the terms and conditions of the grants, including each party’s obligations and remedial authorities available for nonperformance.
Project Performance Report. Grant recipients must submit a narrative progress report quarterly. The project performance report summarizes the project’s progress for the quarter and includes information needed to support expenditures claimed for the quarter. The last quarterly report may serve as the final report and must be submitted within 90 days of the project end date. Those items discussed in 1775.20 (d)(1) through (5) should be addressed. RUS uses this information to monitor performance, ensure schedules are met, projected work is accomplished, and objectives are achieved.
The project performance report meets the requirements of: (1) 7 CFR Part 3016, the USDA Implementation of OMB Circular No. A-102, “Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments;” and (2) 7 CFR Part 3019, the USDA implementation of OMB Circular A-110, “Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations.”
Audit. Grant recipients must comply with the audit requirements of 2 CFR 200 Subpart F. Grant recipients that expend $750,000 or more in a year in Federal awards must have a single or program-specific audit conducted for that year. Those that expend less than $750,000 in Federal awards may be exempt from audit requirements for that year. RUS will review the information and determine if a grant recipient must submit an audit in accordance with the requirements of the Water and Waste Disposal program and 2 CFR 200.
Financial Statements. Grant recipients that expend less than $750,000 in a year in Federal awards may be able to submit their financial statement in lieu of an audit report after project completion. RUS will review the information and determine if a grant recipient must submit an audit in accordance with the requirements of the Water and Waste Disposal program and 2 CFR 200.
Indirect Cost Rate Agreement. The applicant’s indirect cost rate agreement with a cognizant Federal Agency must be submitted if their proposed budget includes indirect costs.
Statement of Compliance. To assure compliance with Title VI of the Civil Rights Act of 1964, the applicant must provide a narrative of how they plan to notify eligible entities of the availability of the service being provided.
Statement Concerning Assistance Under the National Forest Service-Dependent Rural Communities Economic Diversification Act. Applicants must contact the Forest Service and RUS to find out if any geographical or local areas have received grants for technical assistance to a forest-dependent rural community in a five-year period. TAT grant funds cannot be used to duplicate technical assistance provided to a forest-dependent rural community under the National Forest-Dependent Rural Communities Economic Diversification Act of 1990. Applicants must submit documentation that such duplicate assistance has not been given.
INFORMATION COLLECTION APPROVED UNDER OTHER OMB DOCKETS
SF- 424, “Application for Federal Assistance.” (Cleared under 4040-0004).
Applicants use this form as a required cover sheet for applications submitted for TAT grants. The application is an official form required for all Federal grants and requests basic information about the applicant and the proposed project. This form is submitted as part of the pre-application and if the project is selected, as part of the formal application.
SF-424A, “Budget Information--Non-Construction Programs.” (Cleared under 4040-0006)
Applicants project costs and expenses for the grant project. The form also provides information on matching funds. This form is submitted as part of the pre-application and if the project is selected, as part of the formal application.
SF -270, "Request for Advance or Reimbursement.” (Cleared under 4040-0012)
SF -270 "Request for Advance or Reimbursement," will be completed by the grantee and submitted to either the State or National Office upon acceptance of work product.
SF 425, “Federal Financial Report.” (Cleared under 4040-0014)
Grant recipients must report the status of grant funds for TAT/RWTS on the SF-425 on a quarterly basis. The use of this form complies with OMB Circular A-110.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection.
RUS is committed to meeting requirements of the e-Government Act, which requires Government agencies in general to provide the public the option of submitting information or transacting business electronically to the maximum extent possible. RUS accepts electronic applications for TAT Grants through Grants.gov.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
RUS collects information from applicants only who are applying for or who are receiving TAT grants. There will be no duplication in the collection of information required. If applicants are applying for other programs where similar information is required, the Agency would make every effort to use that information which is the same.
5. If the collection of information impacts small businesses or other small entities (item 5 of OMB Form 83-1), describe any methods used to minimize burden.
The information to be collected for the administration of the grant program is the minimum that RUS needs to approve the grants and monitor performance Information to be collected is in a format designed to minimize the paperwork burden for all program applicants. For this grant program, regional consortiums such as regional institutions of higher education, academic health and research institutes, or economic development entities located in the region, would be considered small entities, that may apply for this program. The collection of information from eligible consortiums for this grant program, could impact three (3) small entities.
6. Describe the consequences to Federal program or policy activities if the collection is not conducted or conducted less frequently, as well as any technical or legal obstacles to reducing burden.
The information collected under these programs is the minimum necessary to conform to the requirements of the program regulations established by law. Much of the information is collected when applicants file for grants or when the grants are closed. Information is collected when needed or required by departmental regulations and OMB circulars. Information cannot be collected less frequently and meet the requirements of the programs. Failure to collect proper information could result in improper determinations of eligibility or improper use of funds.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
Requiring respondents to report information more than quarterly. There are no information requirements for reporting more than quarterly
Requiring written responses in less than 30 days. There are no information requirements for written responses in less than 30 days. However, grant recipients must notify RUS immediately of developments that have a significant impact on the grant-supported activities or that might materially impair the ability to meet the objectives of the grant.
Requiring more than an original and two copies. There are no such requirements.
Requiring respondents to retain records for more than 3 years. There are no such requirements unless any litigation, claim, or audit is started before the expiration of the 3-year period and has not been resolved and final action taken.
That is not designed to produce valid and reliable results that can be generalized to the universe of study. There are no such requirements.
Requiring use of statistical sampling which has not been reviewed and approved by OMB. There are no such requirements.
Requiring a pledge of confidentiality. There are no such requirements.
Requiring submission of proprietary trade secrets. There are no such requirements.
8. If applicable, identify the date and page number of Publication in the Federal Register of the agency’s notice soliciting comments on the information collection. Summarize public comments received and describe actions taken by the agency in response to these comments. Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, reporting format (if any), and on data elements to be recorded, disclosed, or reported.
This collection is associated with a Notice of Funds Availability (NOFA). In accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. chapter 35), the 60-day notice for public comment on this information collection was embedded in the NOFA and published in the Federal Register (85-FR-62691); October 5, 2020; Volume 85, No. 193, Page 62691. The public was given until November 4, 2020 to submit comments on this collection. Suggestions and comments are always considered by the Agency, and RD remains committed to pursuing further reductions in both the burdens placed upon our borrowers/customers and the total volume of regulations imposed. The Agency did not receive any comments.
This is a new pilot program and Grants have not yet been awarded. Thus, other than the initial 60-day notice, no additional contact has been initiated with applicants/awardees regarding the clarity of instruction or data collection requirements. The Agency intends, however, to reach out to stakeholders during the next renewal cycle.
9. Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.
RUS has not made any such decisions or payments.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy.
No assurance of confidentiality is provided. Under the Freedom of Information Act, the public can request most data collected from respondents. The information collected under the provisions of these programs is not considered to be confidential.
11. Provide additional justification for any question of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private.
The information collected does not contain any questions of a sensitive nature that would be considered private.
12. Provide estimates of the hour burden for the collection of information.
Based on the number of awards made and the agency’s experience with the grant program, the agency estimates that the hour burden on respondents associated with this information collection to be 647 hours as summarized below:
Regulation |
Number of Respondents |
Total Annual Responses |
Total Burden Hours |
Total Hourly Wage |
Total Costs |
7 CFR 1775 |
9 |
149 |
647 |
$48.60 |
$ 31,444.20 |
As indicated above, RUS estimates a cost of $31,444.20 for respondents to comply with this regulation. The cost is based on 9 organizations filing an application and 5 of them receiving a grant. The primary individuals submitting a grant application, pre-application, or required reports under this regulation would be a director or a professional financial operations staff member. The wage rate of $37.56 per hour is based on the rate provided for Occupation Code 13-0000 Business and Financial Operations Occupations taken from the Bureau of Labor Statistics (BLS) May 2019 National Industry-Specific Occupational Employment and Wage Estimates for Sector 22-Utilities (NAICS 221000) found at https://www.bls.gov/oes/current/oes130000.htm. The hourly wage was calculated using an hourly rate of $37.56 and then multiplying by 29.40% to account for a fringe benefit cost factor for a total hourly wage of $48.60.
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information for (a) capital and start-up cost and (b) operation, maintenance, and purchase of services components.
There are no capital and start-up costs involved with this collection. There are no requirements for respondents to report information other than what is project specific and associated with specific funding applications. Once a request for financial assistance has been approved, no or minimal information is required of the applicant. Additional information is information the applicant would have available and would not be expected to recreate and, only requested under limited situations where formal mitigations measures have been required.
14. Provide estimates of annualized cost to the Federal Government.
The cost to the Federal Government is calculated based on the hourly wage of $55.75 for a GS13/Step 5 Community Programs Specialist. Cost of benefits is calculated at $20.21 for a total hourly wage of $75.96.1 The cost to the Federal Government to collect and evaluate the information in this collection is summarized in the following calculations:
Application phase analysis – 10 hours X 9 applications X $75.96 = $6,836.40
Award phase analysis – 10 hours X 5 applications X $75.96 = $3,798.00
First Administrative phase – 5 hours X 5 applications X $75.96 = $1,899.00
Second Administrative phase – 3 hours X 5 applications X $75.96 = $1,139.40
Servicing per quarter – 4 quarters X 4 hours X 5 borrowers X $75.96 = $6,076.80
End of grant period – 5 hours X 5 borrowers X $75.96 = $1,899.00
Closeout – 2 hours X 5 borrowers X $75.96 = $ 759.60
Total estimated cost to the Federal Government is: $22,408.2
15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of the OMB Form 83-I.
There was an increase in the number of respondents from 3 in the previous collection to 9 respondents for this collection. The increase in the number of respondents also increased the total annual responses of 53 from the previous collection to 149. There was also an unexpected number of applicants than originally anticipated which resulted in an increased number of applications received. The increased number of applications necessitated additional awards, resulting in the increased number of burden hours in this collection from 242 burden hours from the previous collection to 647 burden hours.
16. For collection of information whose results will be published, outline plans for tabulation and publication.
RUS has no plans to publish the information collected under the provisions of these programs.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
RUS does not control the printing of the forms cleared in the other information collection packages and no forms are cleared under this package. Therefore, no such approval is requested
18. Explain each exception to the certification statement identified in item 19 on OMB 83-1.
There are no exceptions requested.
B. Collection of Information Employing Statistical Methods.
This collection does not employ statistical methods.
1 The cost of benefits for Federal Employees is 36.25% of the hourly wage rate as provided in OMB Memorandum M-08-13.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | CFrancis |
| File Modified | 0000-00-00 |
| File Created | 2021-03-16 |