TABLE A-1. AVERAGE ANNUAL COST TO THE FEDERAL GOVERNMENT | ||||
Activity | Average Annual Burden Hours (from Table A-3) | Hourly Cost | Average Annual Cost | |
Technical Review of revised application & reapplication | 2,560 | $93.37 | a | $239,027 |
Evaluate revised applications/reapplications for compliance with 301(h) criteria/prepare 301(h) decisions | 2,080 | $44.66 | b | $92,893 |
Evaluate monitoring and toxic control program adequacy | 1,860 | $44.66 | b | $83,068 |
Review State determinations and State certifications and coordinate with State | 140 | $44.66 | b | $6,252 |
TOTAL | 6,640 | $421,240 | ||
a It is assumed that the majority of reapplications and additional information submissions are reviewed by a contractor. It is further assumed that the salary level of a contractor working on the 301(h) program is 15 percent higher than that of a GS-9, Step 10, $84,441 or $97,107/year. Thus, based on 2,080 working hours/year, the average salary of a contractor is $46.69/hour. Assuming 100 percent overhead costs for the private sector, the labor cost for contractors is $93.37. (Hourly rate based on 2023 DC-B salary rate table.) | ||||
b It is assumed that the salary level of a typical government employee working on the 301(h) program is $84,441/year. Based on 2,080 working hours/year, the average hourly salary of a Federal employee is $40.60/hour. Assuming 10 percent overhead costs, the labor cost for Federal employees is $44.66/hour. (Hourly rate based on 2023 DC-B salary rate table.) | ||||
NOTE: Numbers may not add due to rounding. |
TABLE A-2. COST TO POTW AND STATE RESPONDENTS | ||||
Activity | Average Annual Burden Hours | Hourly Cost | Average Annual Cost | |
COST TO POTW RESPONDENTS | ||||
Application Revision | 1,791 | $93.37 | a | $167,226 |
Reapplication | 2,386 | $93.37 | a | $222,781 |
Monitoring Program | 21,088 | $24.94 | b | $525,935 |
Toxics Control Program | 18,560 | $24.94 | b | $462,886 |
TOTAL | 43,825 | $1,378,828 | ||
COST TO STATE RESPONDENTS | ||||
Determination | 870 | 34.35 | c | $29,885 |
Certification | 290 | 34.35 | c | $9,962 |
TOTAL | 1,160 | $39,847 | ||
TOTAL POTW AND STATE RESPONDENTS | 44,985 | $1,418,675 | ||
aIt is assumed that much of the reapplication and additional information is prepared by a contractor with specialized expertise and equipment. It is further assumed that the salary level of a contractor working on the 301(h) program is 15 percent higher than that of a GS-9, Step 10, $84,441, or $97,107/year. Thus, based on 2,080 working hours/year, the average hourly salary of a contractor is $46.69/hour. Assuming 100 percent overhead costs for the private sector, the labor cost for contractors is $93.37/hour. (Hourly rate based on 2023 DC-B salary rate table.) | ||||
bIt is assumed that the salary level of a typical local government employee working on the 301(h) program is a GS-5, Step 4, or $47,158. Based on 2,080 working hours/year, the average hourly salary of a local employee is $22.67/hour. Assuming 10 percent overhead costs, the labor cost for local government employees is $24.94/hour. (Hourly rate based on 2023 DC-B salary rate table.) | ||||
cIt is assumed that the salary level of a typical State government employee working on the 301(h) program is a GS-9, Step 1, or $64,957/year. Based on 2,080 working hours/year, the average hourly salary of a State government employee is $31.23/hour. Assuming 10 percent overhead costs, the labor cost for State government employees is $34.35/hour. (Hourly rate based on 2023 DC-B salary rate table.) | ||||
NOTE: Numbers may not add due to rounding. |
TABLE A-3. FEDERAL GOVERNMENT BURDEN | ||||||||||||
Burden Hours/Activity | Number of Permits to be Processed Annuallya | Federal Burden Hours/Activity for 3 Years of ICR | ||||||||||
FY 2024 | FY 2025 | FY 2026 | Average Annual Burdenb | |||||||||
Activity | S | L | S | L | S | L | S | L | S | L | TOTAL | |
Technical review of revised application and reapplication | 360 | 1650 | 1 | 2 | 1 | 1 | 1 | 1 | 1,080 | 6,600 | 7,680 | 2,560 |
Evaluate revised applications and reapplications for compliance with 301(h) criteria | 208 | 1040 | 3 | 2 | 3 | 1 | 4 | 1 | 2,080 | 4,160 | 6,240 | 2,080 |
Evaluate monitoring and toxic control program adequacy | 60 | 100 | 16 | 9 | 16 | 9 | 16 | 9 | 2,880 | 2,700 | 5,580 | 1,860 |
Review State determinations and State certifications and coordinate with the State | 20 | 20 | 4 | 4 | 4 | 2 | 5 | 2 | 260 | 160 | 420 | 140 |
TOTAL | 6,300 | 13,620 | 19,920 | 6,640 | ||||||||
NOTE: S = small, L = large | ||||||||||||
aIncorporates EPA's estimate of how many permittees are expected to revise applications and apply for reissuance. These numbers are consistent with those used on Tables A-6, A-7, A-8, and A-10. | ||||||||||||
bCalculated by dividing total by 3. |
TABLE A-4. ANNUAL, TOTAL AND AVERAGE BURDENS FOR EACH OF THE SIX INFORMATION ACTIVITIES | ||||||||||||
FY 2024 | FY 2025 | FY 2026 | TOTAL | Average | ||||||||
Activity/Unit Burden | Burden Hours | Number Affected | Burden All | Number Affected | Burden All | Number Affected | Burden All | Number Affected | Burden All | Number Affected | Burden All | |
Application Revision (POTW) | ||||||||||||
Sm Facility Hr. | 255 | 1 | 255 | 1 | 255 | 1 | 255 | 3 | 765 | 1 | 255 | |
Lg. Facility Hr. | 1,152 | 2 | 2,304 | 1 | 1,152 | 1 | 1,152 | 4 | 4,608 | 1 | 1,536 | |
SUBTOTAL | 3 | 2,559 | 2 | 1,407 | 2 | 1,407 | 7 | 5,373 | 2 | 1,791 | ||
Reapplication (POTW) | ||||||||||||
Sm Facility Hr. | 255 | 3 | 765 | 3 | 765 | 4 | 1,020 | 10 | 2,550 | 3 | 850 | |
Lg. Facility Hr. | 1,152 | 2 | 2,304 | 1 | 1,152 | 1 | 1,152 | 4 | 4,608 | 2 | 2,304 | |
SUBTOTAL | 5 | 3,069 | 4 | 1,917 | 5 | 2,172 | 14 | 7,158 | 5 | 2,386 | ||
Monitoring (POTW) | ||||||||||||
Sm Facility Hr. | 328 | 16 | 5,248 | 16 | 5,248 | 16 | 5,248 | 48 | 15,744 | 16 | 5,248 | |
Lg. Facility Hr. | 1,760 | 9 | 15,840 | 9 | 15,840 | 9 | 15,840 | 27 | 47,520 | 9 | 15,840 | |
SUBTOTAL | 25 | 21,088 | 25 | 21,088 | 25 | 21,088 | 75 | 63,264 | 25 | 21,088 | ||
Toxics Control | ||||||||||||
Sm Facility Hr. | 80 | 16 | 1,280 | 16 | 1,280 | 16 | 1,280 | 48 | 3,840 | 16 | 1,280 | |
Lg. Facility Hr. | 1,920 | 9 | 17,280 | 9 | 17,280 | 9 | 17,280 | 27 | 51,840 | 9 | 17,280 | |
SUBTOTAL | 25 | 18,560 | 25 | 18,560 | 25 | 18,560 | 75 | 55,680 | 25 | 18,560 | ||
TOTAL (POTWs) | ||||||||||||
Sm Facility Hr. | 16 | 7,548 | 16 | 7,548 | 16 | 7,803 | 48 | 22,899 | 16 | 7,633 | ||
Lg Facility Hr. | 9 | 37,728 | 9 | 35,424 | 9 | 35,424 | 27 | 108,576 | 9 | 36,960 | ||
TOTAL (All POTWs)a | 25 | 45,276 | 25 | 42,972 | 25 | 43,227 | 75 | 131,475 | 25 | 43,825 | ||
Determination (States) | ||||||||||||
Sm Facility Hr. | 90 | 4 | 360 | 4 | 360 | 5 | 450 | 13 | 1,170 | 4 | 390 | |
Lg Facility Hr. | 180 | 4 | 720 | 2 | 360 | 2 | 360 | 8 | 1,440 | 3 | 480 | |
SUBTOTAL | 8 | 1,080 | 6 | 720 | 7 | 810 | 21 | 2,610 | 7 | 870 | ||
Certification (States) | ||||||||||||
Sm Facility Hr. | 30 | 4 | 120 | 4 | 120 | 5 | 150 | 13 | 390 | 4 | 130 | |
Lg Facility Hr. | 60 | 4 | 240 | 2 | 120 | 2 | 120 | 8 | 480 | 3 | 160 | |
SUBTOTAL | 8 | 360 | 6 | 240 | 7 | 270 | 21 | 870 | 7 | 290 | ||
Total (States)b | 5 | 1,440 | 5 | 960 | 5 | 1,080 | 5 | 3,480 | 5 | 1,160 | ||
GRAND TOTAL(States + POTWs) | 30 | 46,716 | 30 | 43,932 | 30 | 44,307 | 30 | 134,955 | 30 | 44,985 | , | |
aThere are 25 POTWs in the 301(h) universe. | ||||||||||||
bThere are 5 States in the 301(h) universe. |
TABLE A-5. APPLICATION REVISION AND REAPPLICATION ACTIVITIES AND BURDEN HOURS FOR POTWS | ||
Burden Hours | ||
Activities | Small | Large |
Read Instructions | 8 | 16 |
Plan Activities | 8 | 16 |
Create Information | 80 | 320 |
Gather Information | 135 | 320 |
Complete Information | 24 | 480 |
TOTAL | 255 | 1,152 |
TABLE A-6. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF APPLICATION REVISION | |||||||||
FY 2024 | FY 2025 | FY 2026 | TOTAL | Average Annuala | |||||
S | L | S | L | S | L | S | L | ||
Number of Respondents | 1 | 2 | 1 | 1 | 1 | 1 | 3 | 4 | 2 |
Burden (burden from Table A-5 x number of respondents) | 255 | 2,304 | 255 | 1,152 | 255 | 1,152 | 765 | 4,608 | 1,791 |
Note: S = small, L = large | |||||||||
aCalculated by dividing the total small and large POTWs for 3 years by 3. |
TABLE A-7. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF REAPPLICATION | |||||||||
FY 2024 | FY 2025 | FY 2026 | TOTAL | Average Annuala | |||||
S | L | S | L | S | L | S | L | ||
Number of Respondents | 3 | 2 | 3 | 1 | 4 | 1 | 10 | 4 | 5 |
Burden (burden from Table A-5 x number of respondents) | 765 | 2,304 | 765 | 1,152 | 1,020 | 1,152 | 2,550 | 4,608 | 2,386 |
Note: S = small, L = large | |||||||||
aCalculated by dividing the total small plus large POTWs for 3 years by 3. |
TABLE A-9. BURDEN FOR STATE DETERMINATIONS AND 401(A)(1) CERTIFICATIONS | |||||
Burden (Hours/Activity) | |||||
State Determination | 401 Certification | ||||
Activity | Smalla | Largea | Small | Large | |
Identify Applicable Requirements | 8 | 8 | 4 | 4 | |
Analyze Material | 69 | 155 | 17 | 43 | |
Review Accuracy | 8 | 10 | 4 | 6 | |
Report Information | 5 | 7 | 5 | 7 | |
TOTAL | 90 | 180 | 30 | 60 | |
aBurden for application revisions and reapplications. |
TABLE A-8. ANNUAL POTW RESPONDENTS AND TOTAL ANNUAL BURDEN OF MONITORING AND TOXICS CONTROL PROGRAM | ||||||||||||||
Average Annual Burdena | ||||||||||||||
Number of Respondents | Average Annual Number of Respondents | Burden Hours/Permittee | Annual Burden | |||||||||||
FY 2024 | FY 2025 | FY 2026 | ||||||||||||
S | L | S | L | S | L | S | L | FY 2024 | FY 2025 | FY 2026 | TOTAL | |||
Monitoring Program | 16 | 9 | 16 | 9 | 16 | 9 | 25 | 328 | 1,760 | 21,088 | 21,088 | 21,088 | 63,264 | 21,088 |
Toxics Control Program | 16 | 9 | 16 | 9 | 16 | 9 | 25 | 80 | 1,920 | 18,560 | 18,560 | 18,560 | 55,680 | 18,560 |
Note: S = small, L = large | ||||||||||||||
aCalculated by dividing the total annual burden of small plus large POTWs for 3 years by 3. |
TABLE A-10. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE DETERMINATIONS | ||||||||
FY 2024a | FY 2025 | FY 2026 | Total | Average Annuala | ||||
S | L | S | L | S | L | |||
Number of Respondents | 4 | 4 | 4 | 2 | 5 | 2 | 21 | 7 |
Burdenb | 360 | 720 | 360 | 360 | 450 | 360 | 2,610 | 870 |
Note: S = small, L = large | ||||||||
aCalculated by dividing the number of respondents and the total burden for 3 years by 3. There are 5 states in the 301(h) universe. | ||||||||
bCalculated by multiplying burden estimates in Table A-9 by the corresponding number of respondents in each information submission category. |
TABLE A-11. ANNUAL RESPONDENTS AND TOTAL ANNUAL BURDEN OF STATE 401(a)(1) CERTIFICATION | ||||||||
FY 2024 | FY 2025 | FY 2026 | Total | Average Annuala | ||||
S | L | S | L | S | L | |||
Number of Respondentsb | 4 | 4 | 4 | 2 | 5 | 2 | 21 | 7 |
Burdenc | 120 | 240 | 120 | 120 | 150 | 120 | 870 | 290 |
Note: S = small, L = large | ||||||||
aCalculated by dividing total burden hours and number of respondents for the 3 years by 3. There are 5 states in the 301(h) universe. | ||||||||
bNumber derived by assuming 21 permit reapplications and application revisions over 3 years of the ICR; 13 small and 8 large; and will result in the final approval and preparation of a draft permit, thus requiring State certification. It is assumed that the application review process takes approximately one year. | ||||||||
cCalculated by multiplying burden estimates in Table A-9 by number of respondents. |
TABLE A-12. SUMMARY TABLEa | |||
Respondent/Activity | Number of Respondents/Responses | Hours per Responseb | Average Annual Burden |
POTWs | |||
Application Revision | 2 | 896 | 1,791 |
Reapplication | 5 | 477 | 2,386 |
Monitoring Program | 25 | 844 | 21,088 |
Toxics Control Program | 25 | 742 | 18,560 |
TOTAL: POTWs | 25 | 43,825 | |
STATES | |||
Determinations | 7 | 145 | 870 |
Certifications | 7 | 40 | 290 |
TOTAL: STATES | 5 | 1,160 | |
TOTAL: POTWs AND STATES | 30 | 44,985 | |
aAverage of 3 years divided by 3. | |||
b Hours per response were calculated by dividing the average annual burden by the number of respondents. Values have been rounded to the nearest hour. |
TABLE A-13. EXPLANATION OF CHANGE IN BURDEN | |||||
Activity | Burden from Previous ICR | Difference | Reason for Change | ||
Application Revision | 1,791 | 1,791 | 0 | No changea | |
Reapplication | 2,386 | 2,386 | 0 | No changea | |
Monitoring Program | 21,088 | 21,088 | 0 | No changea | |
Toxics Control Program | 18,560 | 18,560 | 0 | No changea | |
State Determination | 870 | 870 | 0 | Fewer respondentsab | |
State Certification | 290 | 290 | 0 | Fewer respondentsab | |
TOTAL | 44,985 | 44,985 | 0 | No changea Fewer respondentsb. Program adjustmentc | |
aThe universe of permittees with Clean Water Act section 301(h) modified permits remains unchanged since the previous ICR. bNumber of states in 301(h) universe has decreased by one since the previous ICR. However, the total annual burden hours for states remains unchanged because the number of actions has not changed. cProgram adjustment. Two large POTWs that discharged out a common outfall and previously counted as one were corrected to count as two section 301(h) modifications, with all associated information collections. This addition offsets the large POTW that was denied and is no longer in the POTW universe. |
End of CWA 301(h) ICR Tables. No data or info. |
End of CWA 301(h) ICR Tables. No data or info. |
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