U.S. Environmental Protection Agency
Information Collection Request
Title: Climate Pollution Reduction Grants (CPRG) Program Implementation Grants ICR
OMB Control Number: 2060-NEW
EPA ICR Number: 2806.01
Abstract: The Climate Pollution Reduction Grants (CPRG) program was established under section 60114 of the Inflation Reduction Act (IRA) signed on August 16, 2022. Through a competitive process, EPA anticipates awarding approximately $4.6B in CPRG implementation grants to states, municipalities, Tribes, territories, and air quality management districts in 2024 to “facilitate the reduction of greenhouse gas air pollution” (H.R. 5376 — 117th Congress: Inflation Reduction Act of 2022). This ICR focuses on the data collection needed as part of the one-year reports for General Competition grantees and final reports for all CPRG implementation grant recipients. Standardizing the specific types and forms of how this information is reported across CPRG implementation grant recipients will allow the Agency to check the accuracy of calculations submitted by grantees and will make it possible for the Agency to consistently apply information collected from CPRG implementation grant recipients to meet other program deliverables and reporting obligations (e.g., Justice401, statutory requirements, etc.).
Supporting Statement A
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
Under section 60114 of the Inflation Reduction Act, the EPA is charged with distributing and overseeing nearly $5B in grants to state and local governments, Tribes, and territories to develop and implement plans to reduce GHG emissions. Under the first phase of the program (i.e., the Planning Phase), $250M in formula-based direct awards were distributed to over 220 grantees in the form of CPRG planning grants during the summer/fall of 2023. An additional $4.6B is to be distributed through a competitive grants process (i.e., the Implementation Phase) to take place during spring-summer 2024. The IRA statutory language (H.R. 5376 — 117th Congress: Inflation Reduction Act of 2022) stipulates that in their applications, prospective grantees are to “include information regarding the degree to which greenhouse gas air pollution is projected to be reduced in total and with respect to low-income and disadvantaged communities.” In keeping with the statute, EPA has structured the CPRG program to award grants, in part, based on the magnitude of GHG reductions that the proposed measures will achieve and the benefits they will confer to low-income and disadvantaged communities. The IRA statutory language also stipulates that EPA “model the effects of plans” funded through the CPRG program. To model the effects of CPRG plans, EPA must have specific knowledge of the information, datasets, models, tools, and approaches used by grantees to project and quantify the magnitude of the GHG reductions achieved and the benefits to low-income and disadvantaged communities from individual projects funded through CPRG implementation grants. In addition, it is expected that the CPRG program, along with other IRA programs, will be required to demonstrate effective execution of the statutory responsibilities charged to EPA, and comply with any additional reporting requirements (e.g., Evidence Act, Justice40). These responsibilities necessitate standardized data collection from CPRG implementation grantees for the purposes of: 1) determining the accuracy of calculations and analyses submitted by grantees, 2) assessing the compliance of grantees in performing tasks agreed to under the Terms and Conditions of CPRG implementation grants, and 3) applying information collected from CPRG implementation grantees for analytical use.
The Notice of Funding Opportunity (NOFO) for the CPRG Implementation Grants General Competition specifies that all grantees are required to submit semi-annual progress reports, including a one-year report with additional information, and a final report within 120 days of the completion of the period of performance. These semi-annual reports must summarize technical progress, accomplishments, and milestones achieved including a description of outputs and outcomes, planned activities for the next six months, and a summary of expenditures to date are required over the course of the grant period, which is anticipated to be 5 years. Grant recipients will also be expected to report on their community engagement, and, as applicable, their strategy for mitigating environmental risks and progress on job quality. The information collected for these semi-annual reports is already covered by the General Administrative Requirements for Assistance Programs ICR, OMB Control Number 2030-0020.
The additional data for the second semi-annual report (i.e., the one-year report) includes information that “quantifies benefits to low-income and disadvantaged communities, including changes in co-pollutant emissions,” and the final report requires a “summary of the GHG reduction measures implemented, outputs and outcomes achieved, and costs of the measures.” The NOFO for the CPRG Implementation Grants Tribes and Territories Competition does not require the additional data for the second semi-annual report (i.e., the one-year report) but does require a final report. This ICR focuses on the additional data associated with the second semi-annual report (i.e., the one-year report) for General Competition grantees and with the final reports for all CPRG implementation grant recipients.
The “Affected Public” are the grantees receiving funding through the CPRG implementation grant competitions, including state and local governments, Tribes, and territories. The exact number of total grantees has yet to be determined and will depend on the number and funded amount for selected applications, but it is anticipated to range between ~32-115 implementation grants under the General Competition and between ~27-103 implementation grants for the Tribes and Territories Competition (see “Table 1: CPRG General Competition Grants Ranges and Funding by Tier” from the CPRG General Competition Notice of Funding Opportunity2 and “Table 2: CPRG Tribes and Territories Competition Grants Ranges and Funding by Tier” from the CPRG Tribes and Territories Competition Notice of Funding Opportunity3). The “burden” to the “Affected Public” may be found in “Table 3: Preliminary Estimates of Burden Hours and Costs – Respondents.”
The Agency is planning to develop specific reporting templates for emissions, costs, and overall project progress. The reporting template will be made available to grant recipients through an electronic data interface to be specified by EPA.
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
The focus of this data collection is on two required reporting deliverables for CPRG awardees: the one-year progress reports and final reports. In addition to the information required for all CPRG semi-annual reports (i.e., technical progress, accomplishments, and milestones achieved including a description of outputs and outcomes, planned activities for the next 6 months, and a summary of expenditures to date), the one-year reports require that grantees under the General Competition quantify anticipated “benefits to low-income and disadvantaged communities, including changes in co-pollutant emissions.” Grantees are also required to provide estimates of total anticipated benefits including for LIDAC and non-LIDAC areas. The final report, required of all implementation grant recipients, will require a “summary of the GHG reduction measures implemented, outputs and outcomes achieved, and costs of the measures.” The EPA will need this information submitted in a standardized format from all CPRG implementation grant recipients to ensure the Agency can check the accuracy of calculations submitted by grantees and apply the information to meet other program deliverables and reporting obligations (e.g., Justice40, statutory requirements).
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
The Agency has developed a reporting template that will be available to the awardees through an electronic data interface developed by the Agency. Project-specific information (e.g., project ID, Agency contact information) will be added to the forms and data related to costs and overall project progress will be included in this interface. Emissions-specific information will be entered into a spreadsheet template that will be available within the electronic data interface. Awardees will download this file, enter in their emissions information, and reupload this file through the electronic data interface prior to submission.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
This ICR requests authorization for the collection of information that is not currently collected and otherwise would not be collected in a standardized format. There is currently no mechanism for systematic post-award reporting and public outreach information collections for the CPRG implementation grants with respect to the set of instruments and methodologies outlined in this ICR and the uses outlined in this ICR. EPA has determined that this information is not currently held by EPA or any other federal agency.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
The information collection for CPRG implementation grants should not impact small businesses or other small entities since these types of entities are not eligible for direct CPRG funding.
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
As specified in the Reporting Requirements in the Notices of Funding Opportunity (NOFO) for the CPRG implementation grants general competition and Tribes and territories competition, grantees will be required to report specific types of information through a series of progress reports, including a one-year and final report. CPRG implementation grantees will be bound by the Terms and Conditions of their grants to adhere to the Reporting Requirements specified in the respective NOFO. This collection request is intended to provide clarity to grantees regarding the CPRG implementation grant Reporting Requirements, as well as to help standardize the reporting process and thereby facilitate compliance with the specified Reporting Requirements laid out in the NOFO and Terms and Conditions, for the one-year progress reports and final reports. Any grantee who does not report the information specified in the Reporting Requirements will be in violation of the Terms and Conditions of the grant.
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
The information collection is consistent with the guidelines set forth in 5 CFR 1320(d)(2) of the Paperwork Reduction Act guidelines.
If applicable, provide a copy and identify the date and page number of publications 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 by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
The first Federal Register Notice for this ICR was published February 8, 2024 (89 FR 8679). No comments were received within the comment period.
8b. Consultations
Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
Three consultations were performed with entities who are participating in the Planning Grant phase of the CPRG program and have thus met prior reporting requirements for this program. These entities were two States and one Metropolitan Planning Organization (MSA), each with varying degrees of climate planning experience. As such, these entities represented the variety of participants who may be awarded Implementation Grants. All consultations were performed through online meetings and occurred in April 2024.
The first meeting occurred on April 17th, included EPA staff in OAQPS, OAP, and Region 1, and involved a northeastern MSA. The second meeting occurred on April 17th, included EPA staff in OAQPS and Region 5, and involved a midwestern State. The third meeting occurred on April 23rd, included EPA staff in OAQPS and Region 5, and involved a midwestern State. These consultations and the suggestions arising from them helped guide subsequent efforts in developing this ICR. Suggestions and comments included ensuring standardized forms are developed early, ensuring the electronic data interface can be printed into a PDF for internal review, and broad support for an electronic data interface for reporting.
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No additional payments or gifts will be provided by EPA to CPRG implementation grantees.
ASSURANCE OF CONFIDENTIALITY
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
EPA asks grantees to refrain from including any Confidential Business Information (CBI) in their reporting. All confidential data will be handled in accordance with 40 CFR 122.7, 40 CFR Part 2, and EPA’s Security Manual Part III, Chapter 9, dated August 9, 1976. Any claim of confidentiality must be asserted at the time of submission. Any personal information included in a request would be treated in accordance with the Privacy Act, section 14 of TSCA, and the Freedom of Information Act.
Data will be publicly reported in anonymous and aggregated form where necessary to protect CBI and PII. Location identifiers will be used to fulfill federal reporting requirements (e.g., DATA Act, Justice40 Initiative) to document results in different geographic locations. EPA will follow best practices in stating the source of the data (e.g., grant progress reports) and the methodology used to collect the information (e.g., self-report).
Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
Questions about sensitive issues that are normally considered private will not be included in the information collections covered by this ICR.
Provide estimates of the hour burden of the collection of information. The statement should:
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. 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 the 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 as O&M costs under non-labor costs covered under question 13.
Respondents to this ICR will be CPRG Implementation Grant recipients under the General Competition and the Tribes and Territories Competition. Generally, this will include entities that fit within the 9211 - Executive, Legislative, and Other General Government Support NAICS code.
For the period January 1, 2025, to December 31, 2027, EPA expects that all grantees awarded under the CPRG Implementation Grants General Competition will develop and submit one-year reports (due one year after the grant is awarded, or roughly in late 2025/early 2026). EPA is estimating burden based on a conservative assumption that there will be 115 one-year reports submitted. In addition, while the grant period for CPRG implementation grants is anticipated to be 5 years in most cases, EPA is estimating that, for purposes of this Information Collection Request, up to 15 grantees under the General Competition and 15 grantees under the Tribes and Territories Competition may develop and submit a final report to close out their CPRG implementation grants by the end of 2027. Recipients of CPRG implementation grants will incur a burden in the process of preparing, completing, and submitting required performance information via the one-year progress report and final reports. However, it should be noted that these requirements are mandated by the Notice of Funding Opportunity and should be accounted for in the submitted grant applications. This Information Collection Request is simply enabling the compiled data to be submitted in a particular template.
Awardees will report on technical progress, accomplishments, and milestones achieved, including a description of outputs and outcomes, planned activities for the next six months, a summary of expenditures to date, their community engagement, their strategy for mitigating environmental risks, progress on job quality, benefits to low-income and disadvantaged communities, including changes in co-pollutant emissions, and summary of the GHG reduction measures implemented. Most qualitative information will be entered by the awardees into the electronic data interface to be specified by EPA (screenshots of which are available in the “20240626 - CPRG Progress Report Template.pptx”). The quantitative, emissions changes portion of the reporting will be entered into a spreadsheet (see “CPRG_reporting_template_draft_v2_20240626_EMISSIONSonly.xlsx”) downloaded from the electronic data interface to be specified by EPA, filled out by the awardee, and re-uploaded to the electronic data interface to be specified by EPA for final submission.
12d. Respondent Burden Hours and Labor Costs
EPA has used its best professional judgement and feedback obtained through consultations with representatives of those from whom information may be obtained (see Section 8b) to develop estimates of burden hours and costs for each instrument for the period January 1, 2025, to December 31, 2027. Since all respondents will be either state/local/tribal/territorial governments and the reporting “obligation to respond” for all deliverables are mandatory, only one Respondent Burden Table is provided.
Activity |
Respondents (total) |
Responses (in 3-year period covered by ICR) |
Average annual responses |
Burden per Response (Hours) |
Labor Cost per Response ($) |
Non-Labor Costs Per Response ($) |
Average Annual Total Burden (Hours) |
Average Annual Labor Costs ($) |
Average Annual Non-Labor Costs ($) |
Average Annual Total Costs ($) |
One-year Progress Report (General Competition) |
115 |
115 |
38.3 |
960 |
$55,037 |
$0 |
36,480 |
$2,109,751 |
$0 |
$2,109,744 |
Final Report (General Competition) |
115 |
15 |
5 |
960 |
$55,037 |
$0 |
4,800 |
$275,185 |
$0 |
$275,185 |
Final Report (Tribes and Territories Competition) |
103 |
15 |
5 |
960 |
$55,037 |
$0 |
4,800 |
$275,185 |
$0 |
$275,185 |
Total: |
218 |
145 |
48.3 |
|
|
|
46,080 |
$2,660,121 |
$0 |
$2,660,121 |
The wage rates assumed a FY24 GS11-01 hourly rate and increased by 110% to account for benefits ($57.33/hr). |
||||||||||
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
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 consider 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 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.
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.
Based on feedback EPA received during the consultation process, EPA does not anticipate any specified capital or start-up costs for recipients to meet EPA’s performance reporting requirements. As noted by participants in the CPRG Planning Grant phase of the program, CPRG reporting to date has only required standard equipment (e.g., computer, relevant software packages) and infrastructure (e.g., workspace, access to internet services), and no additional capital and O&M costs are anticipated.
Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
14a. Agency Activities
EPA incurs a burden in the process of reviewing and processing the information collected from grant recipients and answering respondent questions. For CPRG, EPA is currently working to develop infrastructure to automate some of the necessary collection and processing steps for applications, reports, and other documents required for the CPRG program. The goal is for these new systems to help minimize burden to both grantees and EPA staff when submitting and processing required documents and reports for the program.
14b. Agency Labor Cost
EPA has used its best professional judgement to develop estimates of burden hours and costs for each instrument for the period January 1, 2025, to December 31, 2027.
Activity Description |
Per Activity |
Total Annual Activities |
Total Annual Costs |
||
Hours |
Cost |
||||
Federal Oversight |
|||||
Review One-year Progress Reports (General Competition) |
16 |
$996.32 |
38.3 |
$37,042 |
|
Review Final Reports (General Competition) |
16 |
$996.32 |
5 |
$4,982 |
|
Review Final Reports (Tribes and Territories Competition) |
16 |
$996.32 |
5 |
$4,982 |
|
Total |
$47,006 |
||||
The wage rates assumed a FY24 GS13-01 hourly rate and increased by 60% to account for benefits ($62.27/hr). |
|||||
14c. Agency Non-Labor Costs
Data from this Information Collection Request will be submitted and processed through an electronic data interface as specified by EPA, with support provided by EPA’s Office of Mission Support. To meet the needs of this Information Collection Request, no new modules or functions will need to be developed and on-going costs are anticipated to be minimal.
REASONS FOR CHANGE IN BURDEN
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
Not applicable; there was no change in the burden estimates.
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
Results from this ICR are not published formally. They are used to calculate agency-level accomplishments and site-specific impacts on publicly available EPA websites.
Information collected under this ICR will be used to support Program and Agency activities in two ways:
Internal Decision-Making: Continuous Improvement and Evidence Building
EPA can use the collected information about project outputs and outcomes to track progress against program objectives, thus allowing for assessments of effectiveness, efficiency, and equity. Results will help EPA identify success stories as well as areas for improvement, which will inform internal discussions to develop evidence-based recommendations for best practices and improvement strategies within the program. In line with the 2018 Evidence Act, this evidence base will be used to inform and improve day-to-day operations and decision-making. The Agency’s Office of the Chief Financial Officer provides resources and support to develop staff capacity to use information and data in this way.
Public Reporting: Accountability
To enable more transparent public examination of federally funded activities, the information collected under this ICR will be published in three ways:
EPA will post aggregated summaries of the grantees’ performance (e.g., activities, outputs, outcomes) on its public websites.
EPA will collate program-level information for inclusion in public reports, such as the Annual Performance Report mandated by the Government Performance and Results Act (GPRA) and annual reports on activities supported by supplemental funds (e.g., Bipartisan Infrastructure Law, Inflation Reduction Act).
EPA will use the collected information to respond to requests for data and information from the Executive and Legislative branches.
Information will be reported in anonymous and aggregated form where necessary to protect Confidential Business Information (CBI) and Personally Identifiable Information (PII). Location identifiers will be used to fulfill federal reporting requirements (e.g., DATA Act, Justice40 Initiative) to document results in different communities. EPA will follow best practices in stating the source of the data and the methodology used to collect the information.
18) DISPLAY OF EXPIRATION DATE
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
The agency plans to display the expiration date for OMB approval of the information collection on all instruments.
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
EPA does not seek any exceptions to the topics for the certification statement identified in the “Certification for Paperwork Reduction Act Submissions.”
1 EPA is committed to meeting the objectives of the Justice40 Initiative set forth in Executive Order 14008, which sets the goal that 40 percent of the overall benefits of relevant federal investments flow to disadvantaged communities, which have been or are marginalized, underserved, and overburdened by pollution. Individual applicants do not have to explicitly demonstrate that 40 percent of the benefits of each measure or project will flow to disadvantaged communities. Instead, EPA will conduct an analysis of the GHG emission reduction measures and the benefits to disadvantaged communities resulting from the CPRG program as a whole.
2 https://www.epa.gov/system/files/documents/2024-01/cprg-general-competition-correction.pdf
3 https://www.epa.gov/system/files/documents/2024-01/cprg_tribal_nofo_correction_12-18-23_0.pdf
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 18Q Supporting Statement Instructions_draft |
| Author | Seltzer, Karl |
| File Modified | 0000-00-00 |
| File Created | 2024-07-21 |