Supporting Statement for an
Information Collection Request (ICR)
Under the Paperwork
Reduction Act (PRA)
Title: |
School Integrated Pest Management Awards Program |
EPA ICR No.: |
2531.03 |
OMB Control No.: |
2070-0200 |
Docket ID No.: |
EPA-HQ-OPP-2023-0335 |
The EPA’s vision is that all students in the U.S. will experience the benefits provided by an IPM program in their school districts. The Agency’s IPM implementation efforts are based on an approach aimed at students in kindergarten through 12th grade in public and Tribal schools. The Agency intends to use the information collected through this ICR to encourage school districts to implement IPM programs and to recognize those that have attained a notable level of success. Since IPM implementation occurs along a continuum, the School IPM (SIPM) Awards program will recognize each milestone step that a school district must take to initiate grow and sustain an IPM program.
This program has five award categories - Great Start, Leadership, Excellence, Model of Sustained Excellence, and Connector. The first four categories are stepwise levels that are reflective of the effort, experience, and, ultimately, success that results from implementing EPA-recommended IPM practices that protect human health and the environment. The fifth category is the Connector award which is open to non-school entities and individuals. The Connector Award is designed to give national recognition to individuals and organizations whose actions and initiatives support improved school environmental health in their community, region, state, or even nationally.
Schools with pest infestations are not only exposed to potential harm to health and property, but also to stigmatization. The School IPM recognition program will give districts across the U.S. the opportunity to receive positive reinforcement through public recognition of their efforts implementing IPM practices such as pest prevention and management strategies.
After this information collection request was initially sought in 2016, the School IPM awards program was not launched due to a change in focus for IPM efforts to include agriculture, vector management, and additional structural areas. However, with this renewal, the Agency is working to implement the School IPM Awards Program. The program follows the model of the Agency’s Indoor Air Quality Tools for Schools program that recognized schools for achievements in improving indoor air quality. The highly successful Tools for Schools program have been active for more ten years and uses the same tiered approach as the SIPM awards program. The SIPM awards program will connect the Agency with school districts to encourage IPM and foster models for other districts to utilize when implementing a sustainable IPM program.
The awards program provides incentives for sustainable IPM practices in school districts, as well as recognizing individuals and non-school entities for their support of initiating and sustaining successful IPM programs in schools. School districts and other participating entities seeking recognition for their IPM programs need to maintain detailed records on a variety of activities and send completed applications to EPA for each award to which they aspire. As part of their activities, participants develop an IPM policy and update their IPM plans annually. Applicants provide information describing how they have met the criteria for the award category to which they are applying. There are four progressive award levels for school districts (i.e., Great Start, Leadership, Excellence, and Model of Sustained Excellence); the Connector award is open to non-school entities and individuals.
EPA’s vision is that all of the nation’s students attend schools with verifiable and ongoing IPM programs which will reduce pests, pesticide use and save money. A relatively small percentage of U.S. K-12 schools currently have verifiable IPM programs. The information collected will substantiate the implementation of the actions required along the IPM continuum from program initiation to robust, sustained implementation.
The SIPM awards program will initially place more focus on school districts rather than individual schools. This is primarily due to the resource requirements to process applications from individual schools on a national scale.
Information Collection |
Number of Respondents |
Annual Number of Responses |
Responses per Respondent |
Annual Time Burden (Hours) |
Annual Cost Burden (Dollars) |
Connector Award |
5 |
5 |
1 |
72 |
$10,767 |
Excellence Award |
9 |
9 |
1 |
248 |
$42,503 |
Great Start Award |
25 |
25 |
1 |
95 |
$24,859 |
Leadership Award |
10 |
10 |
1 |
375 |
$12,068 |
Model of Sustained Excellence Award |
4 |
4 |
1 |
124 |
$8,161 |
Total Agency |
|
|
|
184 |
$18,132 |
Section 13101(b) of the Pollution Prevention Act of 1990, 42 U.S.C. sets forth “the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible.” Section 13102(4) defines source reduction as any practice that “reduces the amount of any hazardous substance … released into the environment” and “reduces the hazards to public health and the environment associated with the release of such substances.” To implement this policy, Section 13103(b)(5) of the Act directs the Administrator of EPA to, among other things; “facilitate the adoption of source reduction techniques by business” (Attachment A).
Section 3 of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), 7 U.S.C. 136a, requires EPA to regulate pesticides to prevent “unreasonable adverse effects” on human health and the environment (Attachment B). IPM strategies, such as removing sources of food, water, and shelter for pests, reduce pest problems and the unnecessary use of pesticides.
The Food Quality Protection Act (FQPA) of 1996 (7 USC 136r–1) requires the U.S. Department of Agriculture and EPA to implement programs in research, demonstration, and education to support the adoption of IPM, make information on IPM widely available to pesticide users, use IPM techniques in carrying out pest management activities, as well as promote IPM through procurement, regulatory policies and other activities (Attachment C). The SIPM awards program is a non-regulatory approach to meet the goals of the Pollution Prevention Act, FIFRA and FQPA to reduce pesticide risks in non-agricultural settings.
The collection of information that documents and measures applicant accomplishments enables EPA to assess program effectiveness and benefits of awards fairly and accurately. Completed applications, including contact information, are preliminary to EPA’s formal recognition. The applications will allow EPA to understand and promote each school district’s efforts. In addition, this program will measure individual and collective program progress in School IPM implementation.
The information collected by the SIPM awards program is not designed or intended to support EPA regulatory decision-making. EPA intends to use the information collected through award program applications to determine applicant eligibility for award recognition, identify school districts’ commitment to promoting and implementing IPM practices, define the existing landscape and implementation status of IPM practices in school districts nationally, and measure environmental outcomes.
The Agency will use this data to develop case studies that demonstrate the importance of IPM implementation in school districts, encourage replication of best practices for adopting, implementing, and sustaining comprehensive school IPM programs. EPA will also share information on IPM practices that school districts can incorporate into other environmental health initiatives (for example, indoor air quality management, asthma management, etc.) The information will result in a better understanding of how schools can effectively manage environmental issues when faced with budgetary and personnel challenges.
In addition, EPA will analyze the information, to the extent possible, to look for environmental trends and highlight program successes by posting information on the Agency’s IPM website.1
EPA will not publish business information reported by award program applicants. Data will only be shared publicly in aggregate form unless otherwise specified and agreed to by the affected school district or awardee.
Prospective applicants can obtain the SIPM award application forms upon request from the Agency (email: [email protected]). The Agency is currently designing a website where the SIPM award application forms will be available online (Attachment F). The application forms were designed to have a minimum burden on the user.
Once complete, the form is submitted online through email to EPA. Application processing can take up to 60 days because of compliance screening. EPA will review each applicant’s environmental compliance history. To receive recognition, school districts must pass the compliance screening and criteria set forth by the award level. 2
In collecting and analyzing the information associated with this ICR, the EPA will use a telephone system, email and available software.
The information to be collected by EPA’s SIPM awards program is unique and is not duplicative of other collections. For example, data submitted through the award applications are specific to the tasks required to implement an IPM programs in schools. Applicants will not be asked to provide information that has been, or is currently being collected by EPA, other federal or state agencies, or proprietary sources. While some state and local government agencies may require pesticide users to maintain records of pesticide use and IPM, they may not require it to be reported. As detailed below, in those instances when a government or private entity collects pesticide use and IPM data, it is not of the scope or detail needed to operate the SIPM awards program. The EPA consulted with trade associations, nonprofit groups, school districts, and other potential participants to confirm that the information being collected by the SIPM awards program does not exist elsewhere.
While developing the IPM measures, the Agency consulted with the Pesticide Program Dialogue Committee (PPDC), a Federal Advisory Committee Act advisory board to the Agency’s Office of Pesticide Programs. The PPDC is a cross-section of entities with interest in pesticide-related matters, including IPM, with representatives from the private sector, nongovernmental entities, and the federal government. Within the PPDC, there was a workgroup focused on IPM. While EPA did not provide the PPDC with details on the information being requested from award program applicants, the committee provided advice on long-term program goals. (See link on bottom of page 4)
The level of detailed information required for the SIPM awards program is not available through other organizations. Some states collect pesticide use information. Of these, California’s data collection is one of the most comprehensive. Even so, its scope is too limited for the purpose of this award program because: 1) the reporting is not focused on school IPM; and 2) the reporting only applies to California while the Agency’s award program is a nationwide program.
State governments’ pest management reports may also not be consistently available due to changes in reporting requirements or states’ priorities. An example of a state government pesticide data collection program with such limitations is Oregon.3 In 2009, Oregon canceled its pesticide use reporting requirements because budgetary constraints limited the state’s ability to use the data to develop and publish reports.
Some states currently have school IPM requirements based on legislation. These laws vary in breadth and rigor but all deal with some element of pesticide application in or around schools, for example pesticide use notification requirements. Some states have regulations on restricted spray zones that impact schools. Some states require IPM training for those applying pesticides in schools, others define the type of pesticide products that can be used in schools, while others require detailed IPM programs for all schools. The variety of School IPM-related requirements and pesticide data collection mechanisms across all states make it difficult for the EPA to access and use these data. Furthermore, the EPA SIPM awards applications are designed to assess only those activities required to implement an IPM program in a school district. No governmental entity is collecting the data the Agency needs to assess IPM implementation in school districts across the nation. Thus, the EPA believes that the information requested through the ICR is not duplicative.
The EPA expects to receive applications to the SIPM program from a variety of school districts and organizations. Award applications are designed to minimize respondent burden while obtaining enough and accurate information. The Agency will review members’ applications, making allowances on a case-by-case basis for the inapplicability of certain elements and the applicants’ abilities to provide the information.
Since membership in the SIPM awards program is voluntary, applicants may also elect to withdraw from the program, at any time, if they do not wish to submit applications needed to maintain their award status. The EPA requires that all awardees submit applications every two years to maintain recognition status.
The EPA requests that School IPM awardees submit applications at least every two years to maintain their award status level. Because of the intended high visibility of the program, less frequent resubmission could compromise program integrity. It will also take time for a school district to implement their IPM program and report on its results. The Agency believes that the two-year timeframe gives schools the flexibility needed to complete a School IPM award application and, subsequently begin or further develop their IPM program.
a) requiring respondents to report information to the agency more often than quarterly;
b) requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
c) requiring respondents to submit more than an original and two copies of any document;
d) requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
e) in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
f) requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
g) that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
h) requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
The information collection activities discussed in this ICR comply with all regulatory guidelines under 5 CFR 1320.5(d)(2). School IPM award program applicants will not need to retain records for this program for more than one year with the exception of the applications that are committed to maintain awardee status or to move to the next award in the program. SIPM awards program participants may resubmit applications every two years to maintain awardee status or to move to the next level in the program. 8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken in response to the comments. Specifically address comments received on cost and hour burden.
Pursuant to 5 CFR 1320.8(d), EPA published a notice in the Federal Register on August 14, 2023 (88 FR 55039; FRL-10664-01-OCSPP), announcing the planned renewal of this information collection activity, soliciting public comment on specific aspects of the ICR and providing a 60-day public comment period.
The EPA also consulted 3 stakeholders via telephone, specifically asking them for their assessment of the regulatory burden estimates expressed by the Agency in this ICR. The stakeholders consulted were:
Howard County Public Schools
University of Arizona – College of Agriculture
Texas A&M – AgriLife Research & Extension Center
Of those consulted, EPA received comments from the University of Arizona and Texas A&M. Overall the respondents commented that they do not see any current change with the estimated burden provided by the Agency. The Agency thanks all commenters for their comments.
No payments or gifts are provided to respondents
EPA has implemented procedures to protect any confidential, trade secret or proprietary information from disclosure that provide strict instructions regarding access to and contact with documents confidential business information (CBI). These procedures comply with EPA’s CBI regulations at 40 CFR Part 2, Subpart B. The reporting method and system prevents access to , and distribution of business information reported by School IPM awardees. Data will only be shared publicly in aggregate form unless otherwise specified and agreed to by the affected awardee.
No information of a sensitive or private nature is requested in conjunction with these information collection activities, and these information collection activities comply with the provisions of the Privacy Act of 1974 and OMB Circular A-108, as amended, “Responsibilities for the Maintenance of Records about Individuals by Federal Agencies.”
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included under ‘Annual Cost to Federal Government’
The School IPM information collection instrument assumes that a number of different employees or contractors can complete the data collection task for the school district. These could include the IPM coordinator, health and safety coordinator, quality assurance specialist, pest management professional, campus facility supervisor, custodian, groundskeeper, and food service personnel. Each award has a different information collection demand.
The EPA assumes that all the paperwork burden incurred by individual schools as well as by their districts to maintain records and to report (apply) for the incentive program are included in the burden estimates provided in the survey responses submitted by the school districts. This assumption is reasonable since many schools are already positioned for such school-to-district reporting either because of existing pesticide, IPM, or school environmental health reporting requirements. In such cases, information reported by individual schools are already compiled and maintained at the district level.
The School IPM awards allow for rolling applications, i.e., applications can be submitted at any time during the year. EPA will process each application within 60 days of submission. EPA will make award presentations to awardees monthly as applications are approved.
The standard threshold for the four-tiered awards that recognize school districts increases as an applicant seeks higher levels of recognition. The exception is for the Connector award which recognizes an organization or individual for “connecting” school districts to help implement an IPM program. This award program recognizes the incremental steps it takes to implement IPM in a school district.
School districts seeking recognition in the EPA SIPM awards program have the opportunity to participate in one or more of five award programs (Attachment E).
The Great Start award is presented to school districts that are in the initial stages of implementing an effective IPM program. Applicants must have selected an IPM coordinator for the district and created a written IPM policy to receive this award.
The Great Start application is required for the Great Start award. This award recognizes districts that are starting an IPM program. EPA estimates 25 school districts will complete this application and the estimated time to complete the application is 95 hours.
The Leadership award is presented to school districts with a senior-level commitment to establish and maintain an IPM program as well as to relate their IPM strategies to the framework for effective school IPM programs (i.e., Organize, Assess, Plan, Act, Evaluate, and Communicate).
The Leadership award application is required for the Leadership award. This award requires a school district to demonstrate how its IPM program was implemented to include staff education and the definition of roles and responsibilities. EPA estimates 10 school districts will complete this application and the estimated time to complete the application is 375 hours.
To merit an Excellence award, applicants need to tell the story of their IPM program in a way that demonstrates the program is comprehensive, effective, and moving towards being institutionalized as part of a comprehensive environmental health program in the district. Specifically, the EPA will look for evidence that:
The critical components of the framework for effective school IPM programs (i.e., Organize, Assess, Plan, Act, Evaluate, and Communicate) are embodied in the school environmental health management program;
An established system exists to ensure consistent and sustained action to identify, address and prevent pest problems; and
Evidence that the program is achieving results.
The Excellence award application is required for the Excellence award. This is the middle tier of the award program. For this award, applicants must show how employees have received IPM education, how IPM-related maintenance is performed, and pest monitoring is being tracked. EPA estimates 9 school districts will complete this application and the estimated time to complete the application is 248 hours.
To merit a Mode of Sustained Excellence award, applicants must meet the requirements of the previous levels of award criteria for at least two years after receiving Excellence award recognition. Applicants must demonstrate that its IPM program is sustainable by providing documentation for pest reduction, health improvements, and financial benefits. Lastly, Model of Sustained Excellence award applicants must show how the school district communicates about its IPM program, both to its internal community (students, parents, employees) and to the external community (other districts, surrounding neighborhood, and community leaders).
The Model of Sustained Excellence award application is required for the Model of Sustained Excellence award. This level builds on the Excellence award by requiring school districts to provide documentation of pest proofing or pest prevention by design. This is in addition to documenting how employees are educated on IPM, how pest proofing repairs are made, and that pest monitoring is being conducted and tracked. EPA estimates 4 school districts will complete this application and the estimated time to complete the application is 124 hours.
The Connector award is designed to give national recognition to individuals and organizations whose actions and initiatives support improved school environmental health in their community, region, state, or even nationally, with a special focus on actions and initiatives that reflect the spirit of the award. Examples include the following:
Development of innovative initiatives, approaches, tools, or resources that have contributed to improved school IPM and indoor environments;
Outstanding individuals and groups who have played a coordinating function to bring people or IPM programs together to provide mutual assistance and support in school IPM implementation;
Leadership/mentorship of school or school district’s IPM program;
Technical assistance in IPM program implementation;
Increasing student involvement in IPM, such as integration of science clubs; and
Other actions and initiatives that foster interconnectedness and mutual support and demonstrate results as part of these efforts.
The Connector award application is required for the Connector award. This award is reserved for the individual or organization that can demonstrate playing a key role in implementing an IPM program in a school district. EPAA estimates 5 school districts will complete this application and the estimated time to complete the application is 72 hours.
Award Program |
Respondents |
Hourly Burden |
Wage Costs |
Great Start Award |
25 |
95 |
$10,767 |
Leadership Award |
10 |
375 |
$42,503 |
Excellence Award |
9 |
248 |
$24,859 |
Model of Sustained Excellence Award |
4 |
124 |
$12,068 |
Connector Award |
5 |
72 |
$8,161 |
Total |
53 |
914 |
$98,357 |
To estimate average annual paperwork burden on respondents, estimated cost per respondent is multiplied by the total number of respondents, which are projected based on past data. Since this is still a fairly new program, as proxy for the School IPM awards program, the Agency used the data on the number of applicants from its Indoor Air Quality (IAQ) project to develop projections
Burden estimates were prepared for the average time necessary to perform each activity in preparation, submission, and recordkeeping of an application for each award type. Burden estimates are based on interviews conducted with representative respondents. Each of the three school districts consulted and the non-profit organization were provided detailed instructions on how to obtain each requested burden estimate through both phone conversations and written correspondence. Respondents were allowed 30 days to acquire the requested information and provide comments and/or suggestions on program improvement when interacting with potential school districts.
The EPA estimates that, on average, a total of 53 entities per year would participate in the SIPM during a three-year period. Since the past data from the EPA’s IAQ project (2000-2010) show high variability without an increasing or decreasing trend, and the data for 2010 is not complete, the three-year average data over 2007-2009 are used as the projected annual number of applicants for the three-year ICR period. For respondents, the EPA estimates an average of 914 hours for all award categories combined, at a total cost of approximately $98,357 annually (see Table 1).
Consistent with recent ICR submissions, the EPA is using labor cost estimates from Agency economists with respect to wages, benefits and overhead for all labor categories for affected industries, local government, and EPA employees. This approach uses a transparent and consistent methodology and current publicly available data to provide more accurate estimates and allow easy replication of the estimates.
Methodology: The calculation of the wage rate uses base wage data for each sector and labor type for an Unloaded wage rate (hourly wage rate) and calculates the Loaded wage rate (unloaded wage rate + benefits) and the Fully loaded wage rate (loaded wage rate + overhead) based on that data. Fully loaded wage rates are used to calculate respondent costs. Cost estimates are based on 2022 wage data.
Unloaded Wage Rate: Wages are estimated for labor types (management, technical, and clerical) within applicable sectors. The Agency uses average wage data for the relevant sectors available in the National Industry-Specific Occupational Employment and Wage Estimates from the Bureau of Labor Statistics (BLS) at http://www.bls.gov/oes/current/oessrci.htm.
Sectors: The specific NAICS code and website for each sector is included in that sector’s wage rate table in Attachment G. Within each sector, the wage data are provided by Standard Occupational Classification (SOC). The SOC system is used by Federal statistical agencies to classify workers into occupational categories for the purpose of collecting, calculating, or disseminating data (see http://www.bls.gov/oes/current/oes_stru.htm).
The managerial labor rate is based on the SOC for management occupations, and the clerical labor rate is based on the SOC for office and administrative support occupations. The technical labor rate is based on the SOC for life, physical and social science occupations. For school IPM, the technical rate is based on first-line supervisors/managers of landscaping, lawn service, and grounds keeping workers.
Loaded Wage Rate: Benefits represent approximately 44.9% of unloaded wage rates, based on total benefits for all civilian non-farm workers from http://www.bls.gov/news.release/ecec.t01.htm
Fully Loaded Wage Rate: The loaded wage rate is multiplied by 50% (EPA guidelines 20-70%) to get overhead costs.
A copy of the formula work sheets used to estimate the labor rates based on 2022 wage data and to derive the fully loaded rates and overhead costs for this new ICR are provided in Attachment G.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$113.34 |
$77.86 |
$50.87 |
|||
per hour |
per hour |
per hour |
|||
Average time to read instructions |
0.2 |
0.0 |
0.0 |
0.2 |
$23 |
Average time to plan activities |
0.5 |
0.0 |
0.0 |
0.5 |
$57 |
Average time to gather information |
1.0 |
0.0 |
0.0 |
1.0 |
$113 |
Average time to compile and review |
1.0 |
0.0 |
0.0 |
1.0 |
$113 |
Average time to complete and submit paperwork |
0.8 |
0.0 |
0.0 |
0.8 |
$91 |
Average time to store/maintain data |
0.3 |
0.0 |
0.0 |
0.3 |
$34 |
Total per applicant |
3.8 |
0.0 |
0.0 |
3.8 |
$431 |
Total annual cost |
|
|
|
|
$10,767 |
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300 – Local Government. May 2022 data. Average number of applicants per year and total burden hours are rounded.
In Table 2, the cost to apply for the Great Start award is estimated to be $431 per applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality (IAQ) project, 25 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 95 hours and total cost is $10,767.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$113.34 |
$77.86 |
$50.87 |
|||
per hour |
per hour |
per hour |
|||
Average time to read instructions |
1.0 |
0.0 |
0.0 |
1.0 |
$113 |
Average time to plan activities |
1.5 |
0.0 |
0.0 |
1.5 |
$170 |
Average time to gather information |
5.0 |
0.0 |
0.0 |
5.0 |
$567 |
Average time to compile and review |
14.0 |
0.0 |
0.0 |
14.0 |
$1,587 |
Average time to complete and submit paperwork |
14.0 |
0.0 |
0.0 |
14.0 |
$1,587 |
Average time to store/maintain data |
2.0 |
0.0 |
0.0 |
2.0 |
$227 |
Total per applicant |
37.5 |
0.0 |
0.0 |
37.5 |
$4,250 |
Total annual cost |
|
|
|
|
$42,503 |
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300 – Local Government. May 2022 data.
Average number of applicants per year and total burden hours are rounded.
In Table 3, the cost to apply for the Leadership award is estimated to be $4,250 per applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality (IAQ) project, 10 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 375 hours and total cost is $42,503.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$113.34 |
$77.86 |
$50.87 |
|||
per hour |
per hour |
per hour |
|||
Average time to read instructions |
0.5 |
0 |
0 |
0.5 |
$57 |
Average time to plan activities |
2.0 |
2.0 |
0 |
4.0 |
$382 |
Average time to gather information |
8.0 |
8.0 |
0 |
16.0 |
$1,530 |
Average time to compile and review |
3.0 |
0 |
0 |
3.0 |
$340 |
Average time to complete and submit paperwork |
3.0 |
0 |
0 |
3.0 |
$340 |
Average time to store/maintain data |
1.0 |
0 |
0 |
1.0 |
$113 |
Total per applicant |
17.5 |
10 |
0 |
27.5 |
$2,762 |
Total annual cost |
|
|
|
|
$24,859 |
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300 – Local Government. May 2022 data.
Average number of applicants per year and total burden hours are rounded.
In Table 4, the cost to apply for the Excellence award is estimated to be $2,762 per applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality (IAQ) project, 9 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 247.5 hours and total cost is $24,859.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$113.34 |
$77.86 |
$50.87 |
|||
per hour |
per hour |
per hour |
|||
Average time to read instructions |
2.0 |
0.0 |
0.0 |
2.0 |
$227 |
Average time to plan activities |
4.0 |
4.0 |
0.0 |
8.0 |
$765 |
Average time to gather information |
4.0 |
4.0 |
0.0 |
8.0 |
$765 |
Average time to compile and review |
4.0 |
4.0 |
0.0 |
8.0 |
$765 |
Average time to complete and submit paperwork |
2.0 |
2.0 |
0.0 |
4.0 |
$382 |
Average time to store/maintain data |
1.0 |
0.0 |
0.0 |
1.0 |
$113 |
Total per applicant |
17 |
14 |
0 |
31 |
$3,017 |
Total annual cost |
|
|
|
|
$12,068 |
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300 – Local Government. May 2022 data.
Average number of applicants per year and total burden hours are rounded.
In Table 5, the cost to apply for the Model of Sustained Excellence award is estimated to be $3,017 per applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality (IAQ) project, 4 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 124 hours and total cost is $12,068.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$113.34 |
$77.86 |
$50.87 |
|||
per hour |
per hour |
per hour |
|||
Average time to read instructions |
0.5 |
|
|
0.5 |
$57 |
Average time to plan activities |
0.5 |
|
|
0.5 |
$57 |
Average time to gather information |
2.0 |
|
|
2.0 |
$227 |
Average time to compile and review |
6.5 |
|
|
6.5 |
$737 |
Average time to complete and submit paperwork |
4.5 |
|
|
4.5 |
$510 |
Average time to store/maintain data |
0.4 |
|
|
0.4 |
$45 |
Total per applicant |
14.4 |
0 |
0 |
14.4 |
$1,632 |
Total annual cost |
|
|
|
|
$8,161 |
Burden hours are from representative school districts that applied for this award in the past.
Wages rates are from BLS for NAICS 999300 – Local Government. May 2022 data.
Average number of applicants per year and total burden hours are rounded.
In Table 6, the cost to apply for the Sustained Excellence award is estimated to be $1,632 per applicant. Based on the data on the number of applicants from the Agency’s Indoor Air Quality (IAQ) project, 5 entities are estimated to apply for this award annually for the three-year ICR period. The estimated total burden hours are 72 hours and total cost is $8,161. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
There are no operational and/or maintenance costs.
As in the case of respondents, the burden hour data from the EPA’s Indoor Air Quality program is used to estimate the Agency burden and cost. To determine Agency costs, the EPA used the Bureau of Labor Statistics estimates of labor rates for 2022 for the NAICS code for the Federal Executive Branch (NAICS 999100). The managerial labor rate is based on the Standard Occupational Classification (SOC) for management occupations; the technical labor rate is based on the SOC for life, physical and social science occupations; and the clerical labor rate is based on the SOC for office and administrative support occupations. The labor rates are fully loaded and include benefits and overhead. Detailed labor costs for agency labor is included in Attachment G.
In Tables 7 to 11, the total Agency cost for each award category is estimated by multiplying the per-applicant cost by the average annual total number of applicants. The per-applicant Agency cost is obtained by summing the products of wage rates (managerial, technical, and clerical) and the per-applicant burden hours for each labor type. Note that the total number of applications reviewed by the Agency includes those applications that are not chosen for award as well.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$143.95 |
$95.49 |
$53.00 |
|||
per hour |
per hour |
per hour |
|||
Average time to read application and determine if applicant met requirements. |
0.00 |
0.13 |
0.00 |
0.13 |
$12 |
Average time to accept/deny, create a form letter and print paper certificate. Division Director signature. |
0.05 |
0.08 |
0.00 |
0.13 |
$15 |
Average time to create mailing label, track applicant in the awards tracking spreadsheet, mail certificate and letter to applicant. |
0.00 |
0.03 |
0.00 |
0.03 |
$3 |
Total per applicant |
0.05 |
0.24 |
0.00 |
0.29 |
$30 |
Total annual cost |
|
|
|
|
$753 |
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100 – Federal Government. May 2022 data.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$143.95 |
$95.49 |
$53.00 |
|||
per hour |
per hour |
per hour |
|||
Average time to read application and determine if applicant met requirements. |
0.0 |
0.17 |
0.0 |
0.17 |
$16 |
Average time to accept/deny, create a form letter and print paper certificate. Division Director signature. |
0.05 |
0.08 |
0.0 |
0.13 |
$15 |
Average time to create mailing label, track applicant in the awards tracking spreadsheet, mail certificate and letter to applicant. |
0.0 |
0.03 |
0.0 |
0.03 |
$3 |
Total per applicant |
0.05 |
0.28 |
0.00 |
0.33 |
$34 |
Total annual cost |
|
|
|
|
$339 |
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100 – Federal Government. May 2022 data.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$143.95 |
$95.49 |
$53.00 |
|||
per hour |
per hour |
per hour |
|||
Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application. |
0.25 |
0.25 |
0.00 |
0.50 |
$60 |
Provide regional staff PDFs of their applicants for their review and weigh-in as personnel that may have worked with districts specifically. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
In two weeks assimilate all score and hold half day consensus meeting to determine what school districts are awards. During this meeting each applicant is discussed, and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year’s application if they were not chosen this year. |
0.00 |
5.00 |
0.00 |
5.00 |
$477 |
Provide a list of selected applicants to recognize; submit to EPA regions and senior management for approval. |
0.50 |
0.50 |
0.00 |
1.00 |
$120 |
Conduct compliance scans on school districts and reconcile any issues that may arise. |
0.00 |
0.50 |
0.00 |
0.50 |
$48 |
Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application. |
0.00 |
0.50 |
0.00 |
0.50 |
$48 |
If there is an event designated for highlighting the award-winning school districts and invitational travel involved, convey logistics to selected applicants. |
0.00 |
0.17 |
0.00 |
0.17 |
$16 |
Using award winning applications create communications materials to showcase these award-winning programs. Initiate comprehensive outreach communications plan. If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories. |
0.50 |
1.00 |
0.00 |
1.50 |
$167 |
Total per applicant |
1.25 |
8.17 |
0.00 |
9.42 |
$960 |
Total annual cost |
|
|
|
|
$8,641 |
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100 – Federal Government. May 2022 data.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$143.95 |
$95.49 |
$53.00 |
|||
per hour |
per hour |
per hour |
|||
Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application. |
0.25 |
0.25 |
0.00 |
0.50 |
$60 |
Provide regional staff PDFs of their applicants for their review and weigh-in as personnel that may have worked with a district specifically. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
In two weeks assimilate all score and hold half day consensus meeting to determine what school districts are awards. During this meeting each applicant is discussed, and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year’s application if they were not chosen this year. |
0.00 |
5.00 |
0.00 |
5.00 |
$477 |
Provide a list of selected applicants to recognize; submit to EPA regions and senior management for approval. |
0.50 |
0.50 |
0.00 |
1.00 |
$120 |
Conduct compliance scans on school districts and reconcile any issues that may arise. |
0.00 |
0.50 |
0.00 |
0.50 |
$48 |
Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application. |
0.00 |
0.50 |
0.00 |
0.50 |
$48 |
If there is an event for highlighting the award-winning school districts and invitational travel involved, convey logistics to selected applicants. |
0.00 |
0.17 |
0.00 |
0.17 |
$16 |
Using award winning applications create communications materials to showcase these award-winning programs. Initiate comprehensive outreach communications plan). If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories. |
0.50 |
1.00 |
0.00 |
1.50 |
$167 |
Total per applicant |
1.25 |
8.16 |
0.00 |
9.41 |
$959 |
Total annual cost |
|
|
|
|
$3,837 |
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100 – Federal Government. May 2022 data.
Collection Activities |
Burden Hours |
Total |
|||
Management |
Technical |
Clerical |
Hours |
Costs |
|
$143.95 |
$95.49 |
$53.00 |
|||
per hour |
per hour |
per hour |
|||
Organize applications by region as they are submitted. Track applicants in detailed tracking spreadsheet. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
Print each application with scoring sheet with evaluation criteria. Create large binder for reviewers that contains all the applications and scoring sheets. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
Determine who will be participating on the review panel. Preferably odd number of people. Depending on number of applications, provide lead time of two weeks for reviewers to read and score each application. |
0.25 |
0.25 |
0.00 |
0.50 |
$60 |
Provide regional staff PDFs of their applicants for their review and weigh-in as personnel that may have worked with a district specifically. |
0.00 |
0.08 |
0.00 |
0.08 |
$8 |
In two weeks assimilate all score and hold half day consensus meeting to determine what school districts are awards. During this meeting each applicant is discussed, and strength and weaknesses of the application documented. This information is used in follow up communications (both winners and those not chosen) with the applicants for them to improve their next year’s application if they were not chosen this year. |
0.00 |
4.50 |
0.00 |
4.50 |
$430 |
Provide list of selected applicants to recognize to regions and senior management for approval. |
0.50 |
0.50 |
0.00 |
1.00 |
$120 |
Conduct compliance scans on school districts and reconcile any issues that may arise. |
0.00 |
0.50 |
0.00 |
0.50 |
$48 |
Send an announcement email to internal EPA staff about award winning applicants. Contact via phone all the applicants being recognized and set up phone meetings with those applicants not chosen to share consensus meeting feedback about strengths and areas of improvement of the application. |
0.00 |
0.50 |
0.00 |
0.50 |
$48 |
If there is an event for highlighting the award-winning school districts and invitational travel involved, convey logistics to selected applicants. |
0.00 |
0.17 |
0.00 |
0.17 |
$16 |
Using award winning applications create communications materials to showcase these award-winning programs. Initiate comprehensive outreach communications plan. If necessary, assist applicants with promoting their award using approved EPA messaging about the awards program and showcasing school IPM success stories. |
0.50 |
1.00 |
0.00 |
1.50 |
$167 |
Total per applicant |
1.25 |
7.67 |
0.00 |
8.92 |
$912 |
Total annual cost |
|
|
|
|
$4,562 |
Burden hours are from the EPA OAR's Indoor Air Quality program.
Wages rates are from BLS for NAICS 999100 – Federal Government. May 2022 data.
|
Total burden hours |
Total cost |
Great Start Award |
7 |
$753 |
Leadership Award |
3 |
$339 |
Excellence Award |
85 |
$8,641 |
Model of Sustained Excellence Award |
41 |
$3,837 |
Connector Award |
48 |
$4,562 |
TOTAL |
184 |
There are minor corrections to the burden from the last renewal for the Great Start, Model of Sustained Excellence and the Connector Award which were miscalculated in error but still reflect no change in the actual burden. There were no changes in the number of respondents and the respondent and Agency burden hours over the previous renewal cycle. The only change from the last renewal cycle is that the cost estimates were updated using the May 2022 wage rates. This change is an adjustment.
The Agency does not intend to publish results of this information collection.
The Agency plans to display the expiration date for OMB approval of the information collection on all instruments.
This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.
PRA Burden Statement
This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2070-0200). Responses to this collection of information are voluntary however mandatory to retain benefits. 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 public reporting and recordkeeping burden for this collection of information is estimated to be a range from 3.60 to 37.5 hours per response. Send comments on the Agency’s need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden to the Information Engagement Division Director, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address.
You can also provide comments to the Office of Information and Regulatory Affairs, Office of Management and Budget via http://www.reginfo.gov/public/do/PRAMain. Find this particular information collection by selecting ‘‘Currently under 30-day Review—Open for Public Comments’’ or by using the search function.
All comments received by EPA will be included in the docket without change, including any personal information provided, unless the comment includes profanity, threats, information claimed to be Confidential Business Information (CBI), or other information whose disclosure is restricted by statute. Do not submit electronically any information you consider to be CBI or other information whose disclosure is restricted by statute.
The attachments listed below can be found in the docket for this ICR or by using the hyperlink that is provided in the list below. The docket for this ICR is accessible electronically through https://www.regulations.gov using Docket ID Number: EPA-HQ-OPP-2023-0335.
Attachment |
Description |
A |
|
B |
|
C |
|
D |
Consultation & Stakeholder Response(s) |
E |
SIPM Awards Program Conditions and Criteria |
F |
SIPM Awards Program Application Guide and Forms |
G |
2022 Wage Rates Worksheet |
1 https://www.epa.gov/ipm
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| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |