FR 2021-00899

The document from the Environmental Protection Agency (EPA) outlines a proposed extension of the Information Collection Request (ICR) related to the "Cross-Media Electronic Reporting Rule." This proposal is part of an effort to streamline the electronic reporting process and decrease the paperwork burden on entities that report electronically to the EPA. The current approval for this ICR extends until August 31, 2021. Public comments on this proposed extension are invited until March 16, 2021.

General Summary

The main focus of the document is on seeking an extension for the ICR aimed at enhancing the efficiency of electronic reporting practices. The EPA wishes to gather public feedback on aspects such as the necessity of the information collection and ways to further reduce burdens on respondents. The initiative reflects a decrease in estimated respondent burden by approximately 9,554 hours per year, due to technological improvements and changes in the number of registrants.

Significant Issues and Concerns

A few noteworthy issues arise from the document:

1. Lack of Detailed Technological Descriptions
   The document mentions improvements made to the Central Data Exchange (CDX) to ease the burden on users, yet it does not specify what these technological advancements entail. This lack of transparency may impede a comprehensive evaluation of the improvements' effectiveness.

2. Insufficient Supporting Data
   While the document attributes a reduction in respondent burden to factors such as fewer registrants and technological efficiencies, it fails to present concrete data or analytical metrics that substantiate these claims.

3. Ambiguity on Data Use
   The use of Google Analytics for refining burden estimates is mentioned, but the document does not provide a detailed explanation of how this data is employed to influence these estimates.

4. Generalized Language on Confidentiality
   The section discussing compliance with confidentiality regulations and the Privacy Act employs standard language, which might benefit from a more explicit description of how confidentiality is maintained in practice.

5. Lack of Clear Form Identification
   The absence of mentioned form numbers or names could lead to ambiguity about the specific requirements for respondents, possibly leading to confusion.

Potential Impact on the Public

The proposed extension may affect the public broadly by potentially enhancing the efficiency of EPA's data collection processes. This could lead to better environmental oversight due to improved data quality and collection efficiency.

Impact on Specific Stakeholders

• Entities Reporting Electronically
  For businesses and organizations involved in electronic reporting to the EPA, these changes could mean less time and resource commitment due to the reduced burden and streamlined processes. This positive impact aligns with administrative efficiency goals.

• State and Local Governments
  Government bodies implementing electronic reporting might benefit from the framework provided by the EPA to improve their reporting systems, which could lead to broader adoption of technology-neutral standards and possibly reduced administrative costs.

Conclusion

The EPA's proposed extension of the ICR holds potential benefits by further reducing the burden on entities involved in electronic reporting, improving efficiency and data collection practices. However, the document may benefit from enhanced clarity and detail, particularly in terms of technological improvements, data use, and specific documentation requirements. Stakeholders involved, notably those in electronic reporting, stand to gain from streamlined processes, although further transparency could enhance understanding and acceptance of the proposed changes.

The document in question discusses the Environmental Protection Agency's (EPA) plan to renew an Information Collection Request (ICR) related to the Cross-Media Electronic Reporting Rule (CROMERR). One key component of this document is the financial estimations associated with the proposed information collection activities. This commentary will explore the financial references and relate them to identified issues.

Summary of Financial References

The document specifies that the total estimated cost for the activities under this ICR is approximately $3,979,500 per year. This figure encompasses broad activities required for maintaining the electronic reporting framework. Within this total, the document notes that $586,300 is allocated to annualized capital or operation and maintenance costs. This cost breakdown helps to understand the scale of the financial commitment needed to ensure efficient electronic reporting processes across various EPA-associated programs.

Financial Allocations and Related Issues

One major issue highlighted is the absence of specific details regarding the "technological improvements" to the Central Data Exchange (CDX), which purportedly led to a reduced respondent burden. While the financial estimates suggest a substantial investment in maintaining and potentially upgrading such systems, the lack of clarity or specific data makes it challenging to assess the use of these funds effectively. Therefore, providing a more detailed breakdown of how these financial allocations impact technological improvements is crucial for evaluating the success and efficiency of the spending.

The estimated respondent burden has decreased by 9,554 hours, mainly attributed to improvements and data insights from real-world metrics like Google Analytics. While financial allocations likely played a role in these improvements (through enhanced Help Desk support and better registration systems), the document does not provide explicit evidence or financial analysis supporting these efficiency claims. Again, without specific metrics or financial tracking, evaluating the return on investment for this budget allocation remains difficult.

Lastly, the general mention of capital or operation and maintenance costs amounting to $586,300 raises questions about what specific actions or improvements were covered under this budget. Bringing more transparency to these allocations could address concerns regarding compliance with confidentiality regulations and ensure that funds are being utilized in alignment with EPA’s objective to improve electronic reporting functionalities.

In conclusion, while the document outlines estimated financial commitments, readers might benefit from a more granular and transparent breakdown of how these resources are being utilized, ensuring they directly correlate with the claimed improvements and reduced respondent burdens.