Overview
Title
Information Collection Request Submitted to OMB for Review and Approval; Comment Request; Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills (Renewal)
Agencies
ELI5 AI
The EPA is asking for more time to gather important information about how trash sites manage air pollution. They want people to share their thoughts until February 10, 2021, to help make sure the rules are fair and useful.
Summary AI
The Environmental Protection Agency (EPA) has submitted a request to the Office of Management and Budget (OMB) to extend the information collection regarding emission guidelines for municipal solid waste landfills. This extension is essential for the compliance with the EPA's regulations under the Paperwork Reduction Act. Public comments on this request are invited until February 10, 2021. The proposal aims to reduce the burden on landfills over time, as many have already completed their initial compliance requirements under state and federal plans.
Abstract
The Environmental Protection Agency has submitted an information collection request (ICR), Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills (EPA ICR Number 2522.03, OMB Control Number 2060-0720), to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. This is a proposed extension of the ICR, which is currently approved through February 28, 2021. Public comments were previously requested, via the Federal Register, on May 12, 2020 during a 60-day comment period. This notice allows for an additional 30 days for public comments. A fuller description of the ICR is given below, including its estimated burden and cost to the public. An agency may neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.
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AnalysisAI
General Summary of the Document
The document submitted by the Environmental Protection Agency (EPA) to the Office of Management and Budget (OMB) seeks an extension concerning the collection of information related to emission guidelines for municipal solid waste landfills. This request ensures compliance with existing regulations under the Paperwork Reduction Act, and public feedback is sought until February 10, 2021. The primary goal of this extension is to continue monitoring and reducing the burden on landfills, many of which have already met initial compliance targets through both federal and state plans.
Significant Issues or Concerns
One major issue with the document lies in its heavy reliance on technical and legal terminology, such as references to specific Code of Federal Regulations (CFR) sections. This can be confusing for readers without a background in environmental law or waste management regulations. Additionally, the financial details and estimated burdens outlined might be too complex without adequate context or explanation. The document's comprehensive nature might overwhelm those unfamiliar with how these processes function.
There is also a section dedicated to adjustments in the estimated burden; however, the detailed information could be difficult to understand without prior knowledge of the criteria leading to those adjustments. Such technical details may obfuscate the document's purpose and intent for readers not acquainted with the subject matter. Lastly, it fails to elucidate how public comments might influence the final decision-making process, making it unclear how public opinions could shape outcomes.
Public Impact
Broadly, this document impacts the public by ensuring ongoing oversight and regulation of waste landfill emissions—a critical environmental concern affecting air quality and public health. By maintaining or potentially improving emission guidelines, the EPA aims to safeguard communities from potential hazards associated with landfill emissions.
The inclusion of public commentary provides a degree of democratic engagement, although, without clear guidance on how such comments will influence decisions, some members of the public may find it challenging to see the relevance or importance of their participation.
Impact on Specific Stakeholders
For municipal solid waste landfills, especially those who have already complied with initial compliance requirements, the proposal could mean reduced administrative and operational burdens over time. This could translate to cost savings and more efficient operations, benefiting both privately and publicly owned landfills.
However, the impacts can be negative if the document's technical complexity remains a barrier to stakeholder engagement and understanding. State and local agencies implementing these plans must understand the implications fully, and any perceived ambiguity might affect their ability to conform to the guidelines effectively.
Overall, while the proposal's intent and purpose may hold potential benefits, the document's complexity and language might deter meaningful public participation and understanding. For a process dependent on clarity and transparency, enhancing accessibility and comprehension should be considered a priority.
Financial Assessment
The document outlines financial details concerning the Environmental Protection Agency’s (EPA) information collection request related to emission guidelines for municipal solid waste landfills. The financial references are primarily centered around estimated costs and expenditures for compliance with set regulatory standards.
Summary of Financial Allocations
The document states a total estimated annual cost of $45,600,000 for compliance, which encompasses both privately-owned and publicly-owned municipal solid waste landfills. This expenditure figure also includes $2,760,000 in annualized capital or startup and operational maintenance costs. Furthermore, there is an allocation of $135,000 annually for state and local agencies-controlled landfills.
Financial References and Identified Issues
The substantial sum allocated for compliance reflects the complexity and scope of adhering to the emissions guidelines. However, the financial information is dispersed within technical jargon that might not be easily digestible for the general public. This is evident from the use of terms like "capital/startup costs" and "operation & maintenance costs," which are specific to those familiar with regulatory and environmental compliance.
Moreover, the mention of these financial commitments is tied to issues highlighted in the broader text. For instance, the document outlines adjustments in burdens due to the anticipated decrease in the number of landfills required to meet stricter monitoring and testing criteria. Here, it is beneficial to relate the $45,600,000 annual cost to the evolving regulatory expectations, indicating a dynamic compliance landscape affecting financial predictions and budgets.
The complexity of these adjustments may obscure understanding without accompanying clarification. Furthermore, how these financial commitments might shift based on public commentary—which the document encourages—is not explicitly linked. While public participation is influenced by financial stakes, the document lacks clear guidance on the impact of these comments on final decisions or budget allocations.
In all respects, conveying how these financial elements interplay with regulatory compliance could benefit from more straightforward language. This would ensure stakeholders without in-depth regulatory familiarity can comprehend the financial implications embedded within these guidelines.
Issues
• The document uses technical legal references (e.g., 40 CFR part 60, subpart A, Cf), which may be unclear to readers unfamiliar with these regulations.
• The financial details are extensive and might be complex for general public comprehension without background context or expertise.
• The changes in estimates section is dense with information and could be challenging to parse without background knowledge on the criteria and reasons behind the adjustments.
• The explanation regarding the adjustment decrease in the total estimated burden could benefit from a more simplified clarification of why these changes occur.
• There is no explicit mention of how public comments might influence the final decision or what the typical outcomes of these comment requests have been in the past.
• The document assumes familiarity with EPA jargon (e.g., NSPS, O&M costs, initial compliance requirements) which may not be accessible to all stakeholders.
• There is a heavy reliance on references to supporting documents and regulations, which may not be readily accessible or explainable to all readers, potentially limiting public engagement.