FR 2021-01971

General Summary

The Environmental Protection Agency (EPA) has put forth an information collection request concerning municipal solid waste landfills. This request seeks approval from the Office of Management and Budget (OMB) and pertains to ensuring compliance with existing environmental standards. Essentially, affected landfill operators, estimated at approximately 190, are required to submit notifications, carry out performance tests, and maintain certain records related to their operations. The EPA is inviting additional public comments over a 30-day window. The annual burden from these requirements is estimated to be 176,000 hours with an associated cost of around $12.5 million.

Significant Issues or Concerns

The EPA document raises several key issues and concerns. Firstly, while it mentions an increase in the total estimated burden, it lacks detailed information about specific factors contributing to this increase. Instead, it offers a broad explanation without specifying which requirements have changed. Furthermore, the document does not provide a clear understanding of how public comments will be evaluated or utilized. The jargon-laden language around performance tests and periodic reports could pose an accessibility issue for the general public, making it challenging to fully comprehend.

Moreover, there is a lack of clarity regarding the changes in the burden estimates, especially in distinguishing between one-time and recurring activities. The absence of discussion on the potential benefits or impacts of these compliance costs poses another concern, as it leaves the necessity and justification for these costs somewhat unexamined. Additionally, the document does not explain why there are more existing sources performing routine activities than previously forecasted, which could influence the cost analysis.

Public Impact

On a broad scale, this document and its requirements are poised to impact public interests by enforcing environmental regulations that aim to control emission levels at municipal waste landfills. Compliance with these rules is crucial for mitigating pollution and protecting environmental and public health.

For the general public, enhanced regulation of waste landfills often translates into cleaner air, better waste management practices, and overall healthier living conditions. However, the associated compliance costs are likely to be significant, with potential implications for public budgets and resource allocation.

Impact on Specific Stakeholders

For stakeholders such as municipal landfill operators, this document signifies an increased regulatory burden. The necessity to adhere to expanded reporting and monitoring requirements could involve substantial time and financial resources. These stakeholders might face operational challenges and increased costs associated with compliance under stricter standards.

On the other hand, communities residing near municipal landfills stand to benefit positively from the enforcement of these environmental controls. They can expect improved air quality and minimized emissions, fostering a better quality of life. Nevertheless, the economic implications for local governments and waste management entities, potentially passed down to taxpayers, remain a consideration.

In conclusion, while the EPA's document aims to reinforce environmental safeguards, it also highlights significant areas that require further elaboration to ensure clear communication to both the public and involved stakeholders.

The document in question outlines updates to an Information Collection Request (ICR) submitted by the Environmental Protection Agency (EPA) concerning municipal solid waste landfills. A focal point of the document is the financial impact of this ICR, which is presented through an estimated cost analysis.

Financial Overview

The document specifies a total estimated cost of $12,500,000 per year related to the ICR for municipal solid waste landfills. This total includes $858,000 in annualized capital/startup and/or operation & maintenance costs. These figures represent the calculated financial commitment necessary for landfill operators to comply with the EPA's regulatory requirements.

Financial Context and Issues

The $12,500,000 per year represents a comprehensive estimation of costs that landfill operators will incur. These costs cover various compliance activities such as initial notifications, performance tests, maintaining operational records, and complying with startup, shutdown, or malfunction protocols. Importantly, it reflects the financial implications for the operators responding to mandatory requirements under 40 CFR part 60 subpart XXX.

The document highlights an increase in the total estimated burden compared to previous reports, which implies a financial escalation for landfill operators. This increase is due to adjustments made for new requirements and the number of respondents expected to control under the stricter 34 Mg/yr standards anticipated between 2022 and 2024. The financial description mirrors these changes but lacks explicit details on which specific compliance areas saw increased costs, possibly leaving stakeholders wanting more precise information on where financial burdens have shifted.

Furthermore, the financial summary does not delve into the potential benefits or adverse effects of this expenditure. This represents an identified issue: the document describes the compliance costs without exploring how these costs might impact municipal solid waste landfills financially or operationally, nor does it discuss potential long-term financial benefits such as environmental improvements that might offset these compliance costs.

Conclusion

The financial references made in the document underscore a significant financial commitment required from landfill operators to meet EPA standards. While the document provides a broad overview of financial allocations, further specificity regarding the exact sources of increased costs and their implications could provide a clearer picture to the general audience, enabling better understanding and preparation for these financial responsibilities.