Overview
Title
Information Collection Request Submitted to OMB for Review and Approval; Comment Request; NSPS for Electric Utility Steam Generating Units (Renewal)
Agencies
ELI5 AI
The EPA wants to keep checking if big power plants that make electricity from steam are following rules that help keep the air clean. They are asking for permission to keep doing this and want people to say what they think by February 10, 2021.
Summary AI
The Environmental Protection Agency (EPA) has submitted an information collection request to the Office of Management and Budget (OMB) for review and approval, seeking an extension for the "NSPS for Electric Utility Steam Generating Units." This extension is essential for compliance with air quality standards and involves periodic reporting and recordkeeping by electric utility steam generating unit operators. The EPA expects a decrease in the burden on these operators due to fewer respondents, as there are no new coal-fired boilers being added and some existing units are being phased out. Public comments on this request are invited until February 10, 2021.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), NSPS for Electric Utility Steam Generating Units (EPA ICR Number 1053.13, OMB Control Number 2060- 0023), 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.
Keywords AI
Sources
AnalysisAI
The document discusses a proposal by the Environmental Protection Agency (EPA) to extend an information collection request (ICR) for the New Source Performance Standards (NSPS) applicable to Electric Utility Steam Generating Units. This request has been submitted to the Office of Management and Budget (OMB) for approval. As described, this extension aims to ensure continued compliance with air quality standards under existing regulations and involves periodic reporting and recordkeeping by operators of electric utility steam generating units.
General Summary
The EPA is seeking to renew a previously approved information collection request that expired in February 2021. This renewal is essential because it allows the agency to collect necessary data from electric utility steam generating units to ensure compliance with environmental regulations. Respondents, who are generally operators of these units, are required to submit reports and records concerning operational changes and performance tests. The document provided also mentions a period for public comment lasting until February 10, 2021, giving the public one last opportunity to provide input on the proposed renewal.
Significant Issues or Concerns
There are several important issues identified within this notice:
Cost Breakdown and Burden Explanation: The estimated cost of $31,000,000 per year is considerable, yet the document does not break down how these funds are allocated within the information collection request. This lack of financial clarity might obscure specific areas where costs could be optimized or reduced.
Decrease in Respondents: The proposal suggests a decrease in the burden due to a reduced number of respondents. However, there is no specific figure provided to convey the exact reduction in participants. Concrete numerical data would help stakeholders understand the impact.
Technical Language: The document makes heavy use of technical jargon and references specific legal subparts of the Code of Federal Regulations (CFR), potentially alienating readers who are not well-versed in legal or environmental regulatory language.
Public Impact
This proposal may have broad implications:
General Public: For the general public, this information collection seeks to monitor and manage air quality, which is critical for public health and environmental sustainability. Effective implementation could lead to cleaner air and reduced emissions from power-generating units.
Regulatory Transparency: By inviting public comments, the EPA presents an opportunity for individuals and organizations to contribute feedback and concerns, though the guide on what input is particularly valuable remains vague.
Impact on Stakeholders
The potential impacts on specific stakeholders are both positive and negative:
Operators of Electric Utility Steam Generating Units: On the positive side, stakeholders who operate these units may benefit from reduced reporting burdens due to fewer overall respondents. On the negative side, the continued requirement for extensive recordkeeping and reporting may still impose significant operational costs and administrative challenges despite this reduction.
Environmental Advocacy Groups: These groups might view the renewal as a positive step towards maintaining and possibly enhancing air quality standards, especially if it enables better enforcement of environmental regulations.
Industry Impact from Technological Innovation: The document does not account for how new technology might lessen the operational burden, which could be a point of concern as innovations in monitoring and reporting might lead to efficiencies not yet realized.
In conclusion, while the EPA's renewal of this information collection is crucial for upholding environmental controls, clarity around costs, respondent numbers, and the potential for technological advancements would improve stakeholders' understanding and engagement in shaping these regulatory efforts.
Financial Assessment
The document refers to the total estimated cost of compliance with the New Source Performance Standards (NSPS) for Electric Utility Steam Generating Units at $31,000,000 per year. This figure includes $11,000,000 in annualized capital/startup and/or operation & maintenance costs. However, the document does not provide a breakdown of how these costs are distributed across various activities within the Information Collection Request (ICR).
The lack of detailed financial breakdown presents a challenge. Without more information, it is difficult for stakeholders to understand how much of the estimated cost is dedicated to specific activities, such as recordkeeping, performance testing, or compliance monitoring. This absence of detail relates to the issue of transparency in financial allocations, which could impact the assessment of whether the resources are being utilized effectively or if they align with the expected outcomes.
Additionally, the document notes a decrease in the burden due to a reduction in the number of respondents, but does not specify how this impacts the $31,000,000 cost. Understanding how changes in the number of facilities or operational changes might decrease this cost, and by how much, is important for evaluating the accuracy and relevance of the financial estimates. This gap speaks to the lack of clarity in the document regarding the recalibration of costs in light of reduced participation.
Financial terms used throughout the regulatory language, like "capital/startup and/or operation & maintenance costs," might also be challenging for those outside the regulatory or utility industry. More explanation of what these terms encompass could help a broader audience better understand the financial commitments required for compliance.
In conclusion, while the document provides a high-level estimate of the costs involved, the lack of detail in both the breakdown of the overall cost and the financial impact of the reduced number of respondents remains a significant issue. Such information is essential for stakeholders aiming to provide informed feedback during the public comment period and to understand the financial obligations of compliance.
Issues
• The document does not provide a breakdown of the estimated $31,000,000 cost per year, making it unclear how much is allocated to specific activities within the ICR.
• The document states that there is a decrease in burden due to a reduction in respondents but does not specify the precise number of respondents who will no longer be participating.
• There is a mention of a decrease in burden due to a 'slight decrease in the number of respondents' and a reduction in labor burden, but specific figures or percentages illustrating this decrease are not provided.
• The document uses technical terms and references specific subparts of the CFR (Code of Federal Regulations), which might be difficult to understand for readers not familiar with this regulatory language.
• The phrase 'mandatory (40 CFR part 60, subpart Da)' under 'Respondent's obligation to respond' could be clarified to explain the obligations or consequences for respondents more explicitly.
• Though the document mentions allowances for public comments, it lacks clear instructions or guidelines on what specific information or feedback the EPA is seeking from the public comment period.
• The document does not address or provide considerations for how technological advancements or changes in the industry might impact the estimates provided, such as automation reducing man-hours needed.