EPA must
thoroughly review the requirements in this ICR and develop a more
exhaustive justification statement. The current statement give
cursory and useless answers to important questions. Why must all
contractors report monthly regardless of size? EPA should consult
with the contractors to see if they have any problems or
suggestions. If EPA pays for the contract, then the Federal
government eventually pays for the contractors cost of complying
with the reporting requirements. Does EPA review what the
contractors send in? If so, then there must be some direct cost to
EPA. OMB did not give credit for any program reduction in burden
because the reason was not explained in any detail. This ICR is a
poor job.
Inventory as of this Action
Requested
Previously Approved
10/31/1987
10/31/1987
16,800
0
0
998,000
0
0
0
0
0
EPA CONTRACTS REQUIRE DELIVERABLES IN
THE FORM OF MONTHLY PROGRESS AND FINANCIAL REPORTS TO ENSURE THAT
WORK IS PROGRESSING SATISFACTORIL AND WITHIN BUDGET
CONSTRAINTS.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.