U.S. Environmental Protection Agency
Information Collection Request
Title: Environmental and Climate Justice Community Change Grants Program: Post-Award Reporting
OMB Control Number: 2035-NEW
EPA ICR Number: 7781.01
Abstract
The
U.S. Environmental Protection Agency (EPA) makes competitive
financial assistance awards to support projects that tackle
environmental, public health, and energy challenges across the
country. Historically, these investments have not reached communities
and groups who are overburdened by the effects of pollution,
environmental hazards, and climate change. To help get resources and
funding to underserved and overburdened communities, the
Inflation Reduction Act (IRA) created the Environmental and Climate
Justice Block Grant Program (ECJP)—the largest investment in
environmental and climate justice in U.S. history—when it was
signed into law by President Biden on August 16, 2022. The
Community Change Grants (CCG) are the final and most comprehensive
piece of EPA’s implementation of ECJP IRA funding. The CCG
program will provide funding to communities and their partners to
design, develop, and implement multi-faceted, community-driven
projects to protect public health and the environment. With
this Information Collection Request (ICR), EPA seeks approval to
collect performance information from CCG grantees via progress
reports and final reports. Collection of this information enables EPA
to assess and manage the CCG program, which ensures responsible
stewardship of public funds; rigorous evidence-based learning and
improvement; and transparent accountability to the American public.
Total (3-Year) Respondent Burden & Costs |
||||
Respondents |
Burden Hours |
Labor Costs |
Non-Labor Costs |
Total Costs |
105 |
27,300 |
$1,564,017 |
$0 |
$1,564,017 |
Supporting Statement A
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.
Overview
The U.S. Environmental Protection Agency (EPA) makes competitive financial assistance awards to support projects that tackle environmental, public health, and energy challenges across the country. Historically, these investments have not reached communities and groups who are overburdened by the effects of pollution, environmental hazards, and climate change. While these communities often have the vision and plans to overcome their local challenges, they can face systemic barriers that limit their access to resources that are needed to implement and deliver these solutions.
The Inflation Reduction Act (IRA)1 created the Environmental and Climate Justice Block Grant Program (ECJP)—the largest investment in environmental and climate justice in U.S. history—when it was signed into law by President Biden on August 16, 2022. The ECJP is now contained in Section 138 of the Clean Air Act2, 42 U.S.C. § 7438. Under this program, EPA was provided $2.8 billion to award grants to help disadvantaged communities address a wide range of environmental and climate justice issues, and $200 million for technical assistance related to these grants. This historic investment advances Executive Order 139853 (Advancing Racial Equity and Support for Underserved Communities Through the Federal Government) that established a whole-of-government approach to advancing equity and opportunity, and Executive Order 140084 (Tackling the Climate Crisis at Home and Abroad) which created the government-wide Justice 40 Initiative establishing the goal that 40 percent of the overall benefits of certain federal investments flow to disadvantaged communities. Awards under the ECJP also support core goals of Executive Order 140915 (Further Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, and Executive Order 140966 (Revitalizing Our Nation’s Commitment to Environmental Justice for All).
The Environmental and Climate Justice Community Change Grants Program (Community Change Grants) are the final and most comprehensive piece of EPA’s implementation of ECJP IRA funding. The Community Change Grants will complement grant programs that EPA launched in 2022 and 2023, including the Collaborative Problem-Solving Program, Government-to-Government Program, and Thriving Communities Grantmaking Program. Collectively, these programs will empower communities and their partners to design, develop, and implement multi-faceted, community-driven projects. These programs will address the diverse and unique needs of disadvantaged communities by, among other things:
Monitoring, preventing, and remediating pollution across all environmental media;
Building resilience to climate change and mitigating current and future climate risks;
Enhancing meaningful involvement in government processes related to environmental and climate justice;
Expanding access to high-quality jobs and economic opportunity through workforce development in occupations that help reduce greenhouse gas emissions and other air pollutants and;
Bolstering community strength by ensuring that local residents receive the benefits of investments in low- and zero-emissions technologies and related infrastructure and have the opportunity to build on them for current and future generations.
Track I projects will make intensive place-based investments with strong collaborations to build climate resilience and reduce pollution in disadvantaged neighborhoods. These projects will address specific, community-driven environmental justice challenges and will center meaningful community engagement in order to build immediate and longer-term community strength and economic prosperity.
Track II projects work to break down
systemic barriers that limit community participation in government
processes around environmental and climate justice. Projects will
create engagement and feedback mechanisms between community members
and government decision-makers. These projects focus on ways to
provide disadvantaged communities with information about issues that
directly impact them, while simultaneously creating mechanisms to
ensure that community needs inform government decision-making.
Grantees in this track will strive to enable communities to play a
meaningful role in making and implementing decisions.
The information requested under this ICR will be collected via post-award reports submitted by Grantees that document their planned and actual milestones, activities, target audiences, outputs, outcomes, timelines, and locations of activities or benefits. The two instruments include Progress Reports and Final Reports.
Legal and Administrative Requirements
The collection of information to assess and manage financial assistance programs fulfills various legal and administrative requirements:
EPA’s general regulation for financial assistance programs establishes the minimum management requirements for recipients of EPA’s financial assistance programs. The reports submitted by the grantees under this ICR fulfill the information collection and reporting requirements included in EPA regulations 2 CFR Parts 2007 and 1500.8
The Government Performance and Results Modernization Act of 2010 (GPRA-Mod9) requires agencies to set goals, measure performance against those goals and report publicly on progress. As a mechanism to achieve this goal, agencies must build and publish an Annual Performance Report (APR), which includes measurable goals, targets, and actuals from the prior fiscal year for all EPA programs. EPA publishes the APR each year alongside the Congressional Justification submitted to the Office of Management and Budget (OMB). Information collected for the Community Change Grants via post-award reports will be included in the APR.
The Digital Accountability and
Transparency Act of 2014 (DATA
Act10)
requires the federal government to transform its spending
information into open data, and link federal contract, loan, and
grant spending information to federal programs to enable more
transparent public examination
of federal
spending. To
enable public
scrutiny of
federal investments,
EPA will
need to collect information from the grantees about the
location of each funded activity and its associated place of
performance.
Justice4011 is a whole-of-government initiative launched by the Biden-Harris Administration in 2021, which represents a commitment to direct 40% of the overall benefits of certain Federal investments to disadvantaged communities that are marginalized, underserved, and overburdened by pollution. As per OMB Guidance M-21-2812, EPA programs that are covered by this initiative are required to report: (1) investments that go to disadvantaged communities; (2) program outcomes and benefits for disadvantaged communities; and (3) community engagement and stakeholder consultation with disadvantaged communities and their partners. To fulfill the reporting requirements regarding the location of investments and benefits, EPA must collect information from each grantee about the location of each funded activity and its area of impact, at the appropriate and feasible level of specificity.
The Foundations for Evidence-Based Policymaking Act of 2018 (Evidence Act13) provides a federal framework for agencies to work with stakeholders to promote a culture of continuous learning, and decision-making using the best available evidence. This legislation asks agencies to (1) produce measures and indicators; (2) use data to improve day-to-day operations; (3) advance the rigorous use of evidence as a routine part of planning and budget development; and (4) incorporate evidence in decision-making and reporting. Information collected for the Community Change Grants via post-award reports will help develop an evidence base to address the effectiveness, efficiency, and equity of the program’s activities. This evidence base, in turn, will address needs related to organizational learning, ongoing program management, performance management, strategic management, interagency and private sector coordination, internal and external oversight, and accountability.
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.
EPA will collect information from each grantee across two post-award instruments: (1) progress reports and (2) final reports. EPA will use this information to verify that recipients are using Federal funds appropriately to comply with Federal requirements; assess the status of grant efforts; and track outcomes required for Federal reporting.
EPA will collect quarterly progress reports from each Grantee for the duration of the funding period. This timeline was chosen based on the schedule along which progress on project activities can be documented and reported.
In line with Agency strategic goals, program objectives, and submitted workplans, each Grantee will be asked to provide seven categories of information in the progress reports that cover the specified three-month reporting period:
Objectives, milestones, and priorities
Accomplishments: Activities with associated timeframes, locations, target audiences, outputs, and outcomes, as applicable in each area of work
Summary of public outreach information collections (if applicable, and if not reported in Part 2)
Program management updates (e.g., personnel changes, fiscal information)
Schedule of noteworthy activities for next reporting period
Feedback or comments for EPA
Optional: Images of key activities and events
EPA will use these reports to determine progress in relation to the approved schedule and milestones during the project pursuant to EPA Order 5700.7A1: EPA's Policy for Environmental Results under EPA Assistance Agreements.14 Tracking progress at regular intervals will enable EPA to identify and address issues in a timely manner, thus ensuring responsible stewardship of public funds and transparent accountability to the American public. Collection of the information will also facilitate the collection and dissemination of success stories and best practices in real time, thus contributing to learning and improvement across the Grantees within the program.
Final Reports
The final report will summarize
each Grantee’s work on the project during the entire period of
performance, and the extent to which the work has met the project’s
objectives.
In line with Agency strategic goals, program objectives, and submitted workplans, each Grantee will be asked to report on seven categories of information in the final reports:
Objectives, milestones, and priorities
Activities
with associated timeframes, locations, target audiences, outputs,
and outcomes,
as applicable in each area of work pursuant to
section 7 of EPA Order 5700.7A1: EPA's Policy for Environmental
Results under EPA Assistance Agreements:
Summary of public outreach information collections (if applicable, and if not reported in Part 2).
Reflection on medium-term and long-term outcomes
Program management (e.g., personnel changes, fiscal information)
Feedback or comments for EPA
Optional: Images of key activities and events
EPA will use the final reports to assess and report the Grantees’ performance relative to program objectives.
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 adapting this means of collection. Also describe any consideration of using information technology to reduce burden.
With this ICR, EPA is seeking approval to require funding recipients to submit information via specified post-award reporting forms, which will substantially reduce the burden on respondents and EPA staff by collapsing what could be extensive written narratives into concise, specific data fields. This approach will also improve the accuracy of data collected by each grantee and the consistency of data collected across grantees. All forms will be completed and submitted electronically, via systems that are currently in development.
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. There is currently no mechanism for systematic post-award reporting for the Community Change Grants, with respect to the set of instruments and methodologies outlined in this ICR. EPA has determined that this information is not currently held by EPA or any other federal agency.
This ICR includes information collection forms and methodologies (online data collection) that are not currently authorized by EPA’s General Administrative Requirements for Assistance Programs Information Collection Request package (OMB Control Number 2030-0020).
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
EPA has considered whether to establish different reporting requirements for small businesses and other small entities and has determined that:
Different reporting requirements among recipients will result in inconsistent data that may reduce the Agency’s ability to oversee and report on program activities and accomplishments;
The burden imposed by this information collection is relatively small and small entities should not be unduly burdened by the reporting requirement; and
The EJCPS and EJG2G programs are voluntary and grantees who elected to enter into the cooperative agreements with EPA have determined that the expected benefits of participation outweigh any burden associated with preparing the responses.
EPA will assist grantees with compliance against financial and program performance reporting requirements. EPA Project Officers will meet regularly with their designated grantees and will document their questions and concerns; EPA staff will then determine the appropriate resources and support to address each issue.
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.
EPA recognizes the importance of balancing the need for data collection efforts against respondent burden and costs. The quarterly progress reporting schedule set out in this ICR is consistent with the Agency’s reporting schedule for financial assistance programs. As noted in 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, grantees are required to report updates on their respective projects quarterly throughout the project’s period of performance, followed by a final report at the completion of the project.
EPA has determined that the quarterly reporting schedule is necessary to adequately track awardee progress in completing the proposed activities, and to measure project outcomes (e.g., calculate the emissions reductions that are achieved through the grant). Less frequent collection would weaken EPA’s ability to oversee and manage the Community Change Grants and to report up-to-date and accurate information on program activities and accomplishments.
If this information were not collected, EPA would have no mechanism for tracking and assessing the extent to which the Community Change Grants are operating effectively, efficiently, and equitably. This situation would leave EPA unable to fulfill its legal and administrative requirements to ensure responsible stewardship of public funds; rigorous evidence-based learning and improvement; and transparent accountability to the American public.
Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
Information collections for the Community Change Grants will be conducted in accordance with the Paperwork Reduction Act [4 U.S.C. 3501 et seq and Title 5 of the Code of Federal Regulations (CFR) section 1320.5(d)(2)] and will adhere to OMB’s general guidelines for information collections. There are no known special circumstances that would require reporting on an alternative timeline or methodology.
The Grantees will not be required to report information to EPA more often than quarterly and will be provided the relevant forms and instructions at least 30 days in advance. The Grantees will not be required to submit more than an original and two copies of any document.
In conjunction with OMB’s general guidelines at 2 CFR 200.334, grant recipients must retain all financial records, supporting documents, accounting books and other evidence of program activities for three years after submission of the final report. If any litigation, claim, or audit is started before the expiration of the three-year period, the recipient must maintain all appropriate records until these actions are completed and all issues resolved.
The Grantees will not be required to submit Confidential Business Information (CBI). If a participant feels that any information requested would be CBI, the participant may request that such information be treated as confidential. 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.
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 by the Agency in response to these comments. Specifically address comments received on cost and hour burden.
EPA published a notice in the Federal Register (FRL-12020-01-OEJECR) announcing the Agency’s intention to request an OMB review of this information collection activity. This notice was published on August 6, 2024 in Volume 89, Number 151, Pages 63940-63941, and provided a 60-day period for public comment (Docket ID EPA-HQ-OEJECR-2024-0235). EPA received one public comment that emphasized the importance of providing sufficient time after award of funds for preparation and submission of the first progress report. The program will ensure that all grantees have three months before the first progress report is due to be submitted.
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.
Consultation with seven selectees were undertaken so that EPA could understand the burden associated with completing the data collection covered in this ICR. These consultations included discussions concerning potential response problems, clarity of questions and instructions, and other aspects of respondent burden.
Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
Per OMB guidance, incentives are generally not appropriate for recipients of assistance agreements because they already have a preexisting relationship with the Agency. Incentives will not be provided for post-award reports submitted by Grantees.
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 survey would be treated in accordance with the Privacy Act, section 14 of TSCA, and the Freedom of Information Act.
Progress reports and final reports submitted by grantees will be stored in an EPA IT system that meets the Agency’s current policies and guidelines regarding security and privacy. A Privacy Threshold Analysis was conducted on this system, and a Privacy Impact Assessment Form was completed as part of the SORN process to safeguard sensitive information such as personally identifiable information (see https://www.govinfo.gov/content/pkg/FR-2022-09-06.pdf/2022-19183.pdf). Personal identifiers will not be used to retrieve specific information in this system.
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.
The information collection activities covered by this ICR will not include questions about sensitive issues (e.g., religious beliefs, sexual attitudes and behavior).
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.
Total Number of Respondents = 105
Total Annual Hour Burden (across all instruments and respondents) = 9,100 hours
Total Annual Cost (across all instruments and respondents) = $521,339
12a. Respondents/NAICS Codes
Respondents will include entities who are eligible to receive awards, who are covered by the following NAICS code: 813410 (Civic and Social Organizations).
12b. Information Requested
12c.
Respondent Activities
12d. Respondent Burden Hours and Labor
Costs
Information Requested: The
information requested under this ICR will be collected via post-award
reports submitted by Grantees that document their planned and actual
milestones, activities, target audiences, outputs, outcomes,
timelines, and locations of activities or benefits.
Respondent activities: The Grantees incur a burden in the process of preparing, completing, and submitting the progress reports and final reports.
Methodology: The burden for respondents was estimated using a seven-step process for each information collection instrument:
Calculate the number of hours to prepare, complete, and submit each response, across all staff roles at relevant levels of seniority: management, technical, clerical/support (based on consultations with Grantees).
Calculate the weighted labor cost to prepare, complete, and submit each response, across all staff roles involved (based on salaries identified in the Bureau of Labor Statistics).
Determine the number of responses for the three years (based on signed Terms and Conditions agreements with each Grantees).
Calculate the total burden hours per instrument (number of hours per response x number of responses).
Calculate the total cost per instrument (labor cost per response x number of responses).
Calculate the total burden hours and costs across all instruments for the three years.
Calculate the annualized burden hours and costs across all instruments for each year.
Table 1 (below) includes the information calculated in each step of the methodology, with the total burden hours and costs and annualized burden hours and costs presented in the bottom two rows. Appendix 1 includes the calculations and reference sources for Steps 1 and 2 of the methodology.
Table 1: Estimated burdens and costs – Respondents |
|||||
Activity |
1. Burden per Response (Hours)1 |
2. Weighted Labor |
3. Number of Responses |
4. Total Burden Hours (3 years)4 |
5. Total Labor Cost (3 years)5 |
Prepare, Complete, and Submit Progress Reports |
20 |
$1,145.80 (hourly = $57.29) |
1,260
|
25,200 hours |
$1,443,708 |
Prepare, Complete, and Submit |
20 |
$1,145.80 (hourly = $57.29) |
105 |
2,100 hours |
$120,309 |
6. TOTALS for all three years6 |
27,300 hours |
$1,564,017 |
|||
7. ANNUAL TOTALS per year7 |
9,100 hours |
||||
Notes:
Column 1 = Number of burden hours spent on each response across all staff roles at relevant levels of seniority. For full calculations, please see Table 12.1 in Appendix 1.
Column 2 = Weighted labor cost for each response based upon percentage of staff labor at different levels of seniority. For full calculations and reference sources for wage rates, please see Tables 12.2 and 12.3 in Appendix 1.
Column 3 = Expected number of responses for the three years, based on reporting framework outlined in each Grantee’s signed Terms and Conditions.
Column 4 = Total burden hours, calculated by multiplying the burden hours per response (Column 1) by the number of responses (Column 3).
Column 5 = Total labor cost, calculated by multiplying the weighted labor cost per response (Column 2) by the number of responses (Column 3).
Row 6 = Totals for all three years = Sum of total hours and costs, for all instruments.
Row 7 = Annual totals per year = Average number of hours and costs per year over the three-year period, for all instruments.
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.
Capital and Start-Up Costs
There are no specified capital or start-up costs for grantees to meet the Community Change Grant Program’s post-award reporting requirements, as each grantee should already have the standard equipment (e.g., computer, relevant software packages) and infrastructure (e.g., work space, access to internet services) that is required to collate, store, and report the required information for the progress reports and final report. No specialist equipment or infrastructure is needed to complete the post-award reports.
Operation and Maintenance and Purchase of Services
Grantees are not expected to incur any specified operation or maintenance costs in order to meet the program’s post-award reporting requirements. This is because they can use the standard equipment and infrastructure that they use for other aspects of their work in the organization; thus, the costs associated with operation and maintenance should already be included as standard items in their annual budgets.
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 via two post-award reports from Grantees: progress reports and final reports.
14b. Agency Labor Cost
Total Annual Hour Burden to the Agency (across all instruments) = 2,625 hours
Total Annual Cost to the Agency (across all instruments) = $252,866.25
Methodology: The burden imposed upon EPA was estimated using a seven-step process for each information collection instrument:
Calculate the number of hours to review and process each response, across all staff roles at relevant levels of seniority: management, technical, clerical/support (based on consultations with EPA staff).
Calculated the loaded weighted labor cost to review and process each response, across all staff levels involved (based on salaries for relevant GS levels and a 64% loading to account for the additional costs of employee benefits incurred by the Agency as part of its overall labor costs).
Determine the number of responses for the three years (based on signed Terms and Conditions agreements with each Grantee).
Calculate the total burden hours per instrument (number of hours per response x number of responses).
Calculate the total cost per instrument (labor cost per response x number of responses).
Calculate the total burden hours and costs across all instruments for the three years.
Calculate the annualized burden hours and costs across all instruments for each year.
Table 2 (below) includes the information calculated in each step of the methodology, with the total burden hours and costs and annualized burden hours and costs presented in the bottom two rows. Appendix 2 includes the calculations and reference sources for Steps 1 and 2 of the methodology.
Table 2: Estimated burdens and costs associated with post-award reports – EPA Staff |
|||||
Activity |
1. Burden per Response (Hours)1 |
2. Weighted Loaded Labor |
3. Number of Responses |
4. Total Burden Hours (3 years)4 |
5. Total Labor Cost (3 years)5 |
Review and Process Progress Report |
5 |
$481.65 |
1,260
(4
reports x |
6,300 |
$606,879 |
Review and Process |
15 |
$1,444.95 |
105 |
1,575 |
$151,719.75 |
6. TOTALS for all three years6 |
7,875 hours |
$758,598.75 |
|||
7. ANNUAL TOTALS per year7 |
2,625 hours |
||||
Notes:
Column 1 = Number of burden hours spent on each response across all staff roles at relevant levels of seniority. For full calculations, please see Table 14.1 in Appendix 2.
Column 2 = Weighted loaded labor cost for each response based upon percentage of staff labor at different levels of seniority. For full calculations and reference sources for wage rates, please see Tables 14.2 and 14.3 in Appendix 2.
Column 3 = Expected number of responses for the three years, based on reporting framework outlined in each Grantee’s signed Terms and Conditions.
Column 4 = Total burden hours, calculated by multiplying the burden hours per response (Column 1) by the number of responses (Column 3).
Column 5 = Total labor cost, calculated by multiplying the loaded weighted labor cost per response (Column 2) by the number of responses (Column 3).
Row 6 = Totals for all three years = Sum of total hours and costs, for all instruments.
Row 7 = Annualized totals per year = Average number of hours and costs per year, for all instruments.
14c. Agency Non-Labor Costs
There are no expected operational costs unique to this information collection, as EPA Project Officers are reviewing the collected information as part of their work in supporting the grantees.
Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.
Not applicable: This is a new collection, and so does not involve any program changes or burden adjustments.
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.
Use and Publication of Information
This ICR seeks authorization for the collection of information to support performance measurement. The administrative data collected under this ICR may be used as part of other analytical studies as appropriate. EPA will submit additional ICR packages to seek authorization for program evaluation studies that involve additional collections of information beyond those outlined in this ICR.
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. 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—including quantitative metrics, success stories, and photographs submitted by Grantees—will be publicly reported 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 (e.g., progress reports) and the methodology used to collect the information (e.g., self-report).
Collection,
Tabulation, and Public Reporting of Information
Quarterly: Grantees submit progress
reports to EPA.
Annually: EPA summarizes aggregated
information in reports to OMB
(e.g., budget data requests,
Annual Performance Reports).
Periodically: EPA summarizes aggregated
information to respond to requests for data
and information
from the Congressional and/or Executive Branch.
End of Award: Grantees submit final reports to EPA.
EPA reviews information for each grantee to assess individual progress.
EPA aggregates and reviews information
across grantees to identify themes.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
Not applicable: All instruments will display the expiration date for OMB approval of the information collection.
Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”
Not applicable: EPA does not seek any exceptions to the topics for the certification statement identified in the “Certification for Paperwork Reduction Act Submissions.”
Appendix 1
Calculations for Section 12: Respondent Burden Hours & Costs
Step 1: Calculate proportion of respondent burden hours across all staff roles at relevant levels of seniority.
TABLE 12.1: PROPORTION of Respondent Hours |
|||
Number of Hours: Management |
Number of Hours: Technical |
Number of Hours: Clerical/Support |
Total Proportion |
0.15 |
0.7 |
0.15 |
1 |
Step 2: Calculate weighted labor cost across all staff roles involved.
TABLE 12.2: WAGE RATES for Respondents (2023$) |
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Labor Category |
Data Series a |
Period |
Wage ($/hour) |
Fringe Benefitb |
Total Compen-sation |
Overhead as % of Total Compensationc |
Overhead |
Hourly Loaded Wages |
(a) |
(b) |
(c) =(b)+(a) |
(d) |
(e)=(c)*(d) |
(f)=(c)+(e) |
|||
Managerial |
BLS OEWS, National Industry-Specific Estimates, 813400, General and Operations Managers |
May/June 2023 |
$48.77 |
33.8% |
$65.27 |
20% |
$13.05 |
$78.33 |
Professional / Technical |
BLS OEWS, National Industry-Specific Estimates, 813400, Social Scientists and Related Workers |
May/June 2023 |
$36.00 |
$12.18 |
$48.18 |
20% |
$9.64 |
$57.82 |
Production Worker / Clerical |
BLS OEWS, National Industry-Specific Estimates, 813400, Secretaries and Administrative Assistants |
May/June 2023 |
$21.05 |
$7.12 |
$28.17 |
20% |
$5.63 |
$33.81 |
Footnotes a Source of wage: U.S. Bureau of Labor Statistics. Occupational Employment and Wage Statistics. May 2023 National Industry-Specific Occupational Employment and Wage Estimates NAICS 813400 - Civic and Social Organizations. (https://www.bls.gov/oes/current/naics4_813400.htm#21-0000) b Fringe is calculated using total benefits as a percent of wage. Source: U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation. Table 4. Private industry workers by occupational and industry group. June 2023. Other Services Industry. (https://www.bls.gov/news.release/archives/ecec_09122023.pdf) c An overhead rate of 20% is used based on assumptions in EPA’s Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other U.S. EPA Actions |
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TABLE 12.3: WEIGHTED LABOR COSTS for Respondents |
|
Weighted Hourly Labor Cost |
Explanation of Calculations |
$57.29 |
Weighted
Hourly Labor Cost = |
Total burden calculations (hours and costs) are shown in Section 12.
Appendix 2
Calculations for Section 14: Agency Hours & Costs
Step 1: Calculate proportion of respondent burden hours across all staff roles at relevant levels of seniority.
TABLE 14.1: PROPORTION OF Agency Hours |
|||
Number
of Hours: Management |
Number
of Hours: Program Lead |
Number
of Hours: Project Officer |
Total Proportion |
0.10 |
0.20 |
0.70 |
1 |
Step 2: Calculate weighted loaded labor cost across all staff roles involved.
TABLE 14.2: LOADED WAGE RATES for Agency Staff (2023$) |
||||||||
Labor Category |
Data Series a |
Period |
Wage ($/hour) |
Fringe Benefitb |
Total Compen-sation |
Overhead as % of Total Compensationc |
Overhead |
Hourly Loaded Wages |
(a) |
(b) |
(c) =(b)+(a) |
(d) |
(e)=(c)*(d) |
(f)=(c)+(e) |
|||
EPA staff - Management |
Annual federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV area, GS-15 Step 1 pay rates a |
2023 |
$78.56 |
$50.20 |
$128.76 |
20% |
$25.75 |
$154.51 |
EPA staff - Program Lead |
Annual federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV area, GS-14 Step 1 pay rates a |
2023 |
$66.79 |
$42.68 |
$109.47 |
20% |
$21.89 |
$131.36 |
EPA staff - Project Officer |
Annual federal staff cost: OPM Washington-Baltimore-Northern Virginia, DC-MD-PA-VA-WV area, GS-11 Step 1 pay rates a |
2023 |
$39.66 |
$25.34 |
$65.00 |
20% |
$13.00 |
$78.00 |
Footnotes a Source of wage: Source: U.S. Office of Personnel Management. (2023). Salary Table 2023-DCB. (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/DCB_h.pdf). b Fringe is calculated using total benefits as a percent of wage. A percentage of 63.9% is used based on: Falk, J. 2012. “Comparing Benefits and Total Compensation in the Federal Government and the Private Sector.” Congressional Budget Office Working Paper Series. c An overhead rate of 20% is used based on assumptions in EPA’s Handbook on Valuing Changes in Time Use Induced by Regulatory Requirements and Other U.S. EPA Actions. |
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TABLE 14.3: WEIGHTED LOADED LABOR COSTS for Agency Staff |
|
Weighted Loaded Hourly Labor Cost |
Explanation of Calculations |
$96.33 |
Weighted
Hourly Labor Cost = |
Total burden calculations (hours and costs) are shown in Section 14.
1 URL: https://www.congress.gov/bill/117th-congress/house-bill/5376/text
2 URL: https://www.congress.gov/bill/101st-congress/senate-bill/1630
3 URL: https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-advancing-racial-equity-and-support-for-underserved-communities-through-the-federal-government/
4 URL: https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/27/executive-order-on-tackling-the-climate-crisis-at-home-and-abroad/
5 URL: https://www.whitehouse.gov/briefing-room/presidential-actions/2023/02/16/executive-order-on-further-advancing-racial-equity-and-support-for-underserved-communities-through-the-federal-government/
6 URL: https://www.federalregister.gov/documents/2023/04/26/2023-08955/revitalizing-our-nations-commitment-to-environmental-justice-for-all
7 URL: https://www.govinfo.gov/app/details/CFR-2014-title2-vol1/CFR-2014-title2-vol1-part200
8 URL: https://www.govinfo.gov/app/details/CFR-2015-title2-vol1/CFR-2015-title2-vol1-part1500
9 URL: https://www.congress.gov/bill/111th-congress/house-bill/2142
10 URL: https://www.congress.gov/bill/113th-congress/senate-bill/994
11 URL: https://www.whitehouse.gov/environmentaljustice/justice40/
12 URL: https://www.whitehouse.gov/wp-content/uploads/2021/07/M-21-28.pdf
13 URL: https://www.congress.gov/bill/115th-congress/house-bill/4174
14 URL: https://www.epa.gov/sites/default/files/2015-03/documents/epa_order_5700_7a1.pdf
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 18Q Supporting Statement Instructions_draft |
| Author | McGrath, Daniel |
| File Modified | 0000-00-00 |
| File Created | 2025-01-17 |