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The Environmental Protection Agency’s (EPA) Office of Mission Support – Environmental Information (OMS-EI) provides funding via grants to EPA’s Exchange Network partners (states, territories, and federally recognized Indian tribes) to support the development of the National Environmental Information Exchange Network (Exchange Network or EN). The Exchange Network is a communication, data, and services platform for sharing environmental information to foster informed decision-making. It is managed under the collaborative leadership of EPA, States, Territories, and Tribes. The EN is currently used by its partners to share electronic data related to environmental issues including, but not limited to, ambient air quality, air emissions inventories, inland water quality, coastal water quality, drinking water violations and National Pollutant Discharge Elimination System (NPDES) reports.

As a stipulation of the grant program, recipients are required to submit the following reports: i) Quality Assurance Reporting Form (EPA Form 5300-27) within 90 days of the award, ii) Semi-Annual Reports (EPA Form 5300-26), and iii) a Final Progress Report (EPA Form 5300-26) within 90 calendar days after the period of performance end date. The information gathered from these reports helps EPA ensure projects are on schedule to meet their goals and produce high quality environmental outputs.

2. NEED FOR AND USE OF THE COLLECTION

AUTHORITY/NEED FOR THE COLLECTION

The authority to gather progress performance for assistance programs is derived from 2 CFR Part 200, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.”

Section 200.328 “Monitoring and reporting program performance,” paragraphs (b)(1) and (b)(2) state:

“(1) The Non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example, where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Annual reports must be due 90 calendar days after the reporting period; quarterly or semiannual reports must be due 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report will be due 90 calendar days after the period of performance end date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any performance report.

(2) The Non-Federal entity must submit performance reports using OMB-approved government-wide standard information collections when providing performance information. As appropriate in accordance with above mentioned information collections, these reports will contain, for each Federal award, brief information on the following unless other collections are approved by OMB:

(i) A comparison of actual accomplishments to the objectives of the Federal award established for the period. Where the accomplishments of the Federal award can be quantified, a computation of the cost (for example, related to units of accomplishment) may be required if that information will be useful. Where performance trend data and analysis would be informative to the Federal awarding agency program, the Federal awarding agency should include this as a performance reporting requirement.

(ii) The reasons why established goals were not met, if appropriate.

(iii) Additional pertinent information including, when appropriate, analysis and explanation of cost over runs or high unit costs.”

The recipient shall submit the semi-annual performance reports for EPA review by submitting the Semi-Annual reports (EPA Form 5300-26) each year the grants are active.

In addition, the recipient shall submit a Final Performance/close-out report within 90 calendar days after the period of performance end date, highlighting performance elements as specified in Section 200.328.

The authority to gather quality assurance information for assistance programs is derived from 2 CFR Part 1500, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.”

Section 1500.11 “Quality Assurance,” paragraphs (a) through (d), state:

“(a) Quality assurance applies to all assistance agreements that involve environmentally related data operations, including environmental data collection, production or use.

(b) Recipients shall develop a written quality assurance system commensurate with the degree of confidence needed for the environmentally related data operations.

(c) If the recipient complies with EPA's quality policy, the system will be presumed to be in compliance with the quality assurance system requirements and meet unique quality assurance needs for the Exchange Network Program. The recipient may also comply with the quality assurance system requirement by complying with American National Standard ANSI/ASQ E4:2014: Quality management systems for environmental information and technology programs.

(d) Within 90 days of the award, the recipient shall submit a quality assurance report to EPA for their review by submitting a Quality Assurance Reporting Form (EPA Form 5300-27). Upon EPA's written approval, the recipient shall implement the EPA-approved quality assurance system.”

OMS requires these reports to ensure that grants are making progress consistent with their work plans and that grantees have the policies, procedures, specifications, standards, and documentation to produce data of sufficient quality to meet project objectives.

(b) PRACTICAL UTILITY/USERS OF THE DATA

The information provided on Semi-Annual Progress Report Forms will be used by the Regional Exchange Network Coordinators (RENCs) to monitor grant project development and performance. RENCs will upload these reports to the applicable grantee’s file in the New Generation Grants System (NGGS). The same reporting form will also be used for the Final Progress Report and will be used to rate performance for future grant awards.

The Quality Assurance Reporting Form will be used to ensure grantees will use quality assurance measures outlined in the grant’s administrative terms and conditions.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

(a) NONDUPLICATION

The information a grantee provides in their semi-annual progress report is unique to each project. Information concerning the status of goals and outputs for each project is not available from any other source.

PUBLIC NOTICE

On February 23, 2021, the EPA published a Federal Register notice to solicit public comment with the intention to submit this information collection to the Office of Management and Budget (see 86 FR 10952). A sixty (60) day comment period was provided. The comment period closed on April 26, 2021. We encouraged all interested parties to review and provide feedback on this proposed information request. We did not receive any comments or feedback on this information collection during the comment period. Once the ICR is submitted to OMB, there will be an additional thirty (30) day comment period announced in the Federal Register.

CONSULTATIONS

In preparation for the renewal of this ICR, EPA contacted a total of 9 respondents, i.e., Grantees - 6 States, 2 Tribes, and 1Territory to ask for their opinions on the burden requirements associated with this ICR. The respondents indicated that the burden estimates were appropriate and did not provide any suggestions on how to further reduce the burden.

EFFECTS OF LESS FREQUENT COLLECTION

EN grants are usually awarded for three-year project periods. The Quality Assurance Reporting Form is completed only once, no more than 90 days after the award is made. As a stipulation of the EN grant award, a Semi-Annual Progress report is completed every six months and a Final Progress Report is submitted no later than 90 days after the period of performance end date. Semi-annual progress reports and final progress reports requests the same information but are noted separately because they provide project updates and accomplishments for different project periods. Less frequent reporting could result in project mismanagement. For some Project Officers with many grants to manage, the semi-annual progress report is the best opportunity to ensure the project is on schedule to meet its goals.

GENERAL GUIDELINES

This ICR does not exceed any of the guidelines found under 5 CFR 1320.5(d)(2).

CONFIDENTIALITY

No pledge of confidentiality is given for grantee responses in either the Semi-Annual Progress Report Form or the Quality Assurance Reporting Form.

SENSITIVE QUESTIONS

No sensitive questions are asked on either the Semi-Annual Progress Report Form or Quality Assurance Reporting Form.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

RESPONDENTS/NAICS CODES

Our respondents are employees of state, tribal, or territorial environmental government offices. For instance, the current grants awarded to the state of Maryland are managed by an employee of the Maryland Department of the Environment.

According to the 2002 NAICS codes available at www.naics.com, our respondents would fall into one of three categories:

921150 American Indian and Alaska Native Tribal Governments
921190 Other General Government Support
924120 Administration of Conservation Programs

INFORMATION REQUESTED

Please see attached instruments Semi-Annual and Final Progress Report Form (EPA Form 5300-26) (Attachment 1) and Quality Assurance Reporting Form (EPA Form 5300-27) (Attachment 2) for specific data elements. Additional information can be found in Appendix 1: FY 2021Exchange Network Solicitation Notice, Section VI which provides grantees with guidance for submitting quality assurance plans (inserted below)

As previously stated, grantees are already required to report progress semi-annually on their projects. EN grantees have been submitting semi-annual progress reports and final progress reports to EPA Regional Offices since the National Environmental Information Exchange Network grant program began in 2002. EPA implemented the requirement to submit the Quality Assurance Reporting Form for new EN grants beginning in 2006, but the measures for quality assurance in grantees’ projects have been explained in the EN Solicitation Notice since 2002.

According to the 1995 Paperwork Reduction Act (PRA) definition of burden §3502, the only time and effort that the forms required from grantees are:

(A) Reviewing instructions;

(E) Completing and reviewing the collection of information; and

(F) Transmitting through email.

5. INFORMATION COLLECTED

AGENCY ACTIVITIES

The Grantees electronically submits the Quality Assurance reports, Semi-annual reports, and the Final Progress Reports via the Central Data Exchange to EPA’s RENCs. These reports are then uploaded to NGGS by the RENCs. The Headquarters Exchange Network staff and management may review these reports to track and report grant status.

COLLECTION METHODOLOGY

Beginning with grants awarded in FY 2008, EPA has required, through the administrative terms and conditions, that recipients submit semi-annual and final progress reports online via EPA’s Central Data Exchange (CDX) system, which replaced the former paper reports. These progress reports must be submitted within one month of the end of each reporting period. The first reporting period is from the award issuance date to March 31, of the following year, and the first report will be due to the RENCs a month after on April 30. Subsequent reports will be due every six months thereafter, until the project is completed, and the reporting periods will be as follows: April 1 through September 30 (report due October 31) and October 1 through March 31 (report due April 30). The final progress report will be due to the RENC within 90-days after the grant project termination/expiration date. These forms are then uploaded to the NGGS database that has been used by the EPA since 2000.

To reduce burden, EPA asks that grantees not rewrite their entire semi-annual progress report, but simply add their recent outcomes, outputs, and modified dates into their semi-annual progress report from the previous six months.

Recipients of all new grants must submit the Quality Assurance Reporting Form to their RENC via email within 90 days of receiving the award.

SMALL ENTITY FLEXIBILITY

There are no small entities affected because the respondents are states, Tribes, and Territories.

COLLECTION SCHEDULE

The collection schedule for the three forms are reflected in Table 1.

Table 1 – Form Types and Collection Schedule

FORM	SCHEDULE
Quality Assurance Reporting Form (one-time submission)	Due to RENC within 90 days of the grant award
Semi-Annual Progress Report Form for each year the Grant is active	Due to RENC April 30 (Oct. 1- Mar. 31 period) Due to RENC October 31 (Apr. 1 – Sept. 30 period)
Final Progress Report Form	Final due to RENC no longer than 90 days after expiration or termination of the grant project period.

6. BURDEN ESTIMATE AND COST OF COLLECTION

ESTIMATING RESPONDENT BURDEN

The estimated hours for completing each form includes time for reviewing instructions, completing information, and transmitting through email or via CDX. These estimates were developed based on consultations with EPA Regional Exchange Network Coordinators, who helped EPA gather burden information from 9 respondents, i.e., grantees, 6 States, 2 Tribes, and 1Territory, to perform these activities. The average burden per form type are reflected in Table 2.

Table 2 – Form type and Burden per form

Form	Estimated Hours	Frequency per Year	Total Burden Hours per year per Form type
Semi-Annual Progress Report Form	1.2	2	2.4
Quality Assurance Reporting Form	2.6	1	2.6
Final Progress/Close-out Report	1.65	1	1.65

(b) RESPONDENT UNIVERSE AND BURDEN

At the beginning of fiscal year 2021, EPA estimates that each year, 149 grantees will be responding to the Semi-Annual Progress Report Form, 35 new grantees will be submitting the Quality Assurance Reporting Form, and another 36 grantees will be submitting the Final Progress Reports. These numbers are derived from an estimate of the rolling number of “active grants” each year, the number of new grant awardees each year, and the number of grants with grant period expiring each year. The number of active grants fluctuates throughout the year as projects are completed and grants are officially awarded and closed. Starting in FY 2013, every EN grant awarded is for a three-year project period (increased from two years).

The Quality Assurance Reporting Form will be completed once for each new award by award recipient. These respondents will also submit Semi-Annual Progress Report Forms after the first six months of their projects.

EPA’s burden estimate per year is based on the government’s fiscal year. In one fiscal year, a respondent who receives an award in 2021 will complete one quality assurance report and two semi-annual progress reports for that grant. The burden estimates also account for the submission of Final Progress report within 90 days of the grants project period expiration.

Table 3 reflects the total annual burden hours for all respondents.

Table 3 – Respondent Burden

	Respondents	Calculation	Semi-Annual Progress Report Form	Quality Assurance Reporting Form	Final Progress report/ Close out report	Total
a	Estimated Hours per Form		1.2	2.6	1.65
b	Frequency per Year		2	1	1
c	Annual Burden Hours per Form Type	(a) x (b)	2.4	2.6	1.65
d	Respondents per Year		149	35	36	220
e	Responses per Year	(b) x (d)	298	35	36	369
f	Total Annual Burden Hours	(c) x (d)	357.6	91	59.4	508

Respondent costs consist only of labor. There is no capital, operating and maintenance, or annualizing capital costs incurred by this information collection.

Using current Respondent Wage Rate: $63.11^¹, the respondent costs are as follows and reflected in Table 4:

Semi-Annual Progress Report Form: 298 Total Annual Burden Hours x $63.11 = $18,806.78
Quality Assurance Reporting Form: 35 Total Annual Burden Hours x $63.11 = $2,208.85
Final Progress Report Form: 36 Total Annual Burden hours x $63.11 = $2,271.96

Table 4 – Respondent Costs

Respondent Costs	Semi-Annual	Quality Assurance	Final Progress Report	Total
Labor Cost	$ 18,806.78	$ 2,208.85	$2,271.96	$ 23,287.59
Capital/Start-up Cost	$0	$0		$0
Operating and Maintenance	$0	$0		$0
Total Costs	$18,806.78	$2,208.85	$2,271.96	$23,287.59

(d) ESTIMATING AGENCY BURDEN AND COST

To estimate the cost and burden to the RENCs, EPA assumes that each grant recipient will submit two Semi-Annual Progress Report Forms each year the grant is active, and that each new grant recipient will submit one Quality Assurance Reporting Form within 90 days of award. In addition, the grantees will submit the Final Progress Report to RENC no later than 90 days after the grant performance period end date. EPA assumes that there are 149 active grants in any single fiscal year, that 35 new grants are awarded each year, and an estimated 36 grants close out each year. In addition, there is an even distribution for each (active and new grants) across all 10 regions.

The burden numbers were collected by contacting 8 RENCs, 7 of which provided the burden estimates as follows:

EPA estimates that it should take a RENC 0.5 hours to review a Quality Assurance Reporting Form, 0.35 hours to review a Semi-Annual Progress Report Form, and 0.5 hours to review the Final Progress Report.
EPA estimates that Agency RENCs will review 149 x 2 = 298 Semi-Annual forms, 35 x 1 = 35 Quality Assurance forms, and 36 Final Progress Reports each year.
RENCs will spend 298 x 0.35hrs = 104.3 hours reviewing Semi-Annual forms, 35 x 0.5hrs = 17.5 hours reviewing Quality Assurance forms, and 36 x 0.5hrs= 18 hours reviewing the Final Progress Reports.

The total number of hours spent each year by the RENCs to review the forms is 139.8 hours.

Table 5 reflects the total burden on the Agency.

Table 5 – Agency Burden

	EPA RENCs	Calculation	Semi-Annual Progress Report Form	Quality Assurance Reporting Form	Final Progress Report	Total
a	Estimated Hours per Form (Review/Upload)		0.35	0.5	0.5
b	Frequency per Year		2	1	1
c	Annual Burden Hours per Form Type	(a) x (b)	0.7	0.5	0.5
d	Grants Subject to EPA Review/Upload per Year		149	35	36
e	EPA Reviews/Uploads per Year	(b) x (d)	298	35	36	369
f	Total Annual Burden Hours: EPA	(c) x (d)	104.3	17.5	18	139.8

Assuming a fully burdened hourly rate of $76.50 ² for each RENC, the cost to review:

Semi Annual Progress Report forms is 104.3 hrs. x $76.50 = $7,978.95,
Quality Assurance Reporting Form is 17.5 hrs. x $76.50 = $1,338.75, and
Final Progress Report is 18 hrs. x $76.50 = $1,377, for a total of $10,694.7 each year.

Table 6 reflects the total Agency costs.

Table 6 - Agency Costs.

EPA Costs	Semi-Annual	Quality Assurance	Final Progress Report	Total
Labor Cost	$7,978.95	$1,338.75	$1,377	$10,694.7
Capital/Start-up Cost	$0	$0		$0
Operating and Maintenance	$0	$0		$0
Total Costs	$7,978.95	$1,338.75	$1,377	$10,694.97

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²The 2018 average hourly rate for a General Schedule (GS) 13, Step 1 for U.S. Locality Pay of the metro areas for the RENC’s ($47.815) was used to estimate burden costs for EPA’s RENCs. This rate was also fully burdened (x 60 %), yielding a wage rate of $76.504.

(e) BOTTOM LINE SUMMARY BURDEN HOURS AND COSTS

The total respondent Burden and Costs discussed above are summarized in Table 7.

The total Agency Burden and Costs discussed above are summarized in Table 8.

Table 7 – Summary Respondent Burden Hours and Costs

	Semi-Annual	Quality Assurance	Final Progress Report	Total
Total Annual Responses	298	35	36	369^*
Total Burden Hours for Respondents	357.6 hours	91 hours	59.4	508 hours
Total Respondent Labor Cost	$18,806.78	$2,208.85	$2,271.96	$23,287.59
Total Respondent Non-Labor Cost	$0	$0		$0
Total Respondent Costs	$18,806.78	$2,208.85	$2,271.96	$23,287.59

*Not all respondents complete every activity, every year.

Table 8 – Summary Agency Burden Hours and Costs

	Semi-Annual	Quality Assurance	Final Progress Report	Total
Total Annual Responses	298	35	36	369
Total Burden Hours for EPA	104.3 hours	17.5 hours	18	139.8 hours
Total EPA Labor Cost	$7,978.95	$1,338.75	$1,377	$10,694.7
Total EPA Non-Labor Cost	$0	$0		$0
Total Agency Costs	$7,978.95	$1,338.75	$1,377	$10,694.7

(f) REASONS FOR CHANGE IN BURDEN

There is an increase of 228 (508 hours in 2021 vs 280 hours in 2018) hours in the total estimated respondent burden as compared with the ICR currently approved by OMB. On the other hand, the number of open active grants each year were estimated at 149, about 23 less than those projected for 2018. The increase in burden hours for respondents can be attributed primarily to the fact that the 2021 ICR also accounts for 59.4 hours of burden associated with the submission and review of estimated 36 final progress reports within 90 days of the grant project period expiration. This final progress report and the burden associated with was inadvertently excluded from consideration in the 2018 ICR. In addition, in 2021, the burden hour estimates were provided by a larger number of respondents including 2 Tribes, 1 Territory, and 6 states, as compared to a total of 4 respondents in 2018. Given the increased emphasis to make the reports more comprehensive, the respondents indicated a slight increase of 0.45 hours to prepare and upload a semi-annual progress report, and an increase of 1.6 hours to prepare and upload the quality assurance reporting form.

This increase in number of total reports along with increased burden hours, compounded by the slight inflation in labor rates also explains an increase of $7,100.6 (up from $16,186.98 to $23,287.59 in 2021) in total annual respondent costs for 2021.

(g) BURDEN STATEMENT

The reporting burden for States, Tribes, and Territories is estimated to be 1.20 hours for semi-annual progress report, 2.6 hours to submit a quarterly assurance reporting form, and 1.65 hours to submit the final progress report. This includes time for reviewing instructions, completing the form, and submitting it by uploading it electronically through the Central Data Exchange.

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-OEI-2006-0037, which is available for online viewing at www.regulations.gov, or in person viewing at the Office of Environmental Information 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 Office of Mission Support Docket is (202) 566-1752. Please call and make an appointment with the Docket Center before visiting. 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-OEI-2006-0037 and OMB Control Number 2025-0006 in any correspondence.

Appendix – 1

VI-B. Administration and National Policy Requirements

Each assistance agreement will include a set of Administrative Terms and Programmatic Conditions, such as requirements for electronic funding transfers, additional financial status reporting, limitations on payments to consultants and application of indirect cost rates. These terms and conditions form the basis for the final award of Exchange Network grant funding. Failure to concur with the included terms and conditions will invalidate the award.

In accordance with the Exchange Network Interoperability Policy, applicants must commit, in writing, to reuse existing data flows, EN services, and other IT resources such as widgets and RESTful web services. Please see Appendix D in the FY21 Exchange Network Solicitation Notice for further information on reuse and links to helpful resources. Applicants must also commit to register any newly developed resources and the reuse of existing resources. At the time of grant close-out, EN grantees must work with the Regional Exchange Network Coordinator (RENC) in the region that their organization is located to complete this registration. A current list of RENCs can be found here. EPA requires all grant recipients issued under this solicitation notice to meet these terms and conditions.

EPA will include a grant condition in the assistance agreement requiring the recipient to submit the Exchange Network Quality Assurance Reporting Form (QARF) to the EPA Regional Project Officer within 90 days of the award issuance date. The QARF is a tailored Quality Assurance Project Plan (QAPP) tailored specifically to satisfy the unique Quality Assurance needs of the EN Grant Program. The QARF must describe for each goal and output:

the relevant task-specific Quality Assurance (QA) criteria.
how the recipient will ensure adherence with the QA criteria.
how the recipient will confirm and document the project deliverables meet the QA criteria.

The QA criteria information specified above must be documented for each goal and task under the Quality Assurance Measures section of the Exchange Network QARF. The template for the Exchange Network QARF can be found at: https://www.epa.gov/exchangenetwork/exchange-network-grant-program#QARF. Please note that if an EN grantee’s project includes data collection and/or data monitoring, they should work with their RENCs to determine if a QARF is also required.

Semi-Annual Performance Progress Reports and Final Progress Reports:

All grantees, regardless of the funding vehicle, are expected to submit semi-annual progress reports in a timely fashion. Award recipients will submit semi-annual and final progress reports electronically through EPA’s Central Data Exchange (CDX).

VI-C. Reporting

Semi-Annual Performance Progress Reports: Reporting is an important obligation that award recipients agree to undertake when they sign an assistance agreement. Both EPA and recipients are accountable to Congress and to the public for the proper and effective use of Exchange Network assistance funds. All grantees, regardless of the funding vehicle, are expected to submit semi-annual progress reports in a timely fashion. Award recipients will submit semi-annual and final Progress reports electronically through EPA’s Central Data Exchange (CDX) using a web form. In addition, the new award recipient shall submit quality assurance reporting form within 90 days of the grant award electronically through CDX using a web form. EPA will provide successful applicants with detailed instructions for registering with and reporting through CDX at the time of award.

1¹Using the most recent data from Bureau of Labor Statistics, https://www.bls.gov/news.release/pdf/ecec.pdf, page 6, Table 3. Employer Costs for Employee Compensation for state and local government workers by occupational and industry group, identifies an average loaded rate of $63.11 for wages, salaries, and benefits for several occupations for state and local agencies expected to apply for grants or fellowships.

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