Overview
Title
Proposed Information Collection Request; Comment Request; 43 Source Categories
Agencies
ELI5 AI
The EPA wants to hear what people think before they send some important paperwork requests to the review office. They're checking if the rules to keep air clean are still good and want to make sure they aren't making too much work for people.
Summary AI
The U.S. Environmental Protection Agency (EPA) has announced plans to submit Information Collection Requests (ICRs) for review and approval in line with the Paperwork Reduction Act (PRA). They are requesting public feedback on aspects of these proposed information collections. These ICRs, which are extensions of currently approved ones, involve various industrial sectors, such as sulfuric acid manufacturing and polymeric coating of substrates, and cover topics like emissions standards and recordkeeping requirements. Public comments are invited by April 9, 2021.
Abstract
The U.S. Environmental Protection Agency (EPA) is planning to submit the below listed Information Collection Requests (ICR) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act (PRA). Before doing so, the EPA is soliciting public comments on specific aspects of the proposed information collection as described below. These are proposed extensions of the currently approved ICRs. An agency may not conduct or 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 recent document from the Federal Register outlines the U.S. Environmental Protection Agency’s (EPA) intent to seek public input on various Information Collection Requests (ICRs). These requests are part of the agency’s effort to renew several existing information collections that are due to expire. The ICRs, which span multiple industrial sectors such as sulfuric acid manufacturing, polymeric coating, and emissions standards, are aimed at ensuring compliance with regulatory standards under the Paperwork Reduction Act (PRA).
Summary of the Document
In essence, the EPA is inviting public comments on several proposed extensions of existing data collection initiatives. These initiatives involve systematic collection of information from various industries to ascertain adherence to emissions standards. Information such as performance tests and reports on operational malfunctions is collected regularly, aiding the EPA in monitoring and enforcing compliance with established standards.
Significant Issues and Concerns
The document is laden with technical jargon and references numerous specific CFR (Code of Federal Regulations) parts and subparts. This level of detail may be inaccessible to those without expertise in environmental law or industrial regulation, posing a barrier to full public understanding and engagement. Moreover, there is a lack of transparency regarding how public comments will influence the final decisions on these ICRs. Questions remain about the past accuracy of burden estimates, as well as the justification for the estimated costs and administrative burdens placed on respondents.
Impact on the Public and Stakeholders
For the general public, the document serves as an invitation to participate in environmental regulatory processes. However, the highly technical nature of the text may limit effective public participation unless efforts are made to simplify and clarify the proposal details. For industry stakeholders, these ICR renewals represent the continuation of regulatory compliance obligations. The compliance process entails a significant amount of time and financial expenditure, which can have varying impacts depending on the size and resources of the facility.
Positive and Negative Stakeholder Impacts
Industries involved in sulfuric acid production, polymeric coating, natural gas transmission, and many others are required to submit specific data under these ICRs. While compliance ensures alignment with environmental laws and potentially garners positive public sentiment, the associated costs and administrative workload can pose challenges, especially for smaller operations. Conversely, these regulations promote environmental health and safety by holding industries accountable to strict standards, reflecting a positive impact on community health and ecological integrity.
Overall, while the intent of EPA’s ICRs aligns with the goal of maintaining environmental standards, the document could benefit from clearer communication that demystifies the technical aspects for a broader audience, thus ensuring a more inclusive public dialogue.
Financial Assessment
The document outlines several Information Collection Requests (ICRs) that the Environmental Protection Agency (EPA) intends to submit for review. These requests involve various sectors and are accompanied by estimates of costs associated with the required responses from facilities. Below is a detailed commentary on the financial aspects discussed in the document.
Overview of Financial References
The document specifies 43 different ICRs, each with associated costs for compliance. These costs are identified in terms of both the estimated annual burden in hours and annual costs in dollars. The costs often include both operational and maintenance expenses.
For example, the Standards of Performance for Sulfuric Acid Plants list an estimated annual cost of $1,660,000, which includes $239,000 for annualized capital or operations and maintenance (O&M) costs. On the higher end, the Standards of Performance for Petroleum Refineries involving construction after May 2007 are estimated at $143,000,000, with $102,000,000 allocated for capital or O&M costs.
Connection to Issues
The document's use of financial references highlights several concerns:
Complexity and Accessibility: The complexity and specificity in financial details may be challenging for non-experts to grasp, aligning with the issue that the document uses complex language without high-level overviews. This can make it difficult to assess the practicality or necessity of such expenditures.
Lack of Justification: While the document lists extensive costs and burdens, it lacks a detailed justification for the methodologies used in these estimates. This absence of clarity can lead to skepticism regarding whether the expenditures are justified and whether past expenditures were accurately assessed, an issue raised in the commentary.
Efficiency and Necessity: The absence of a clear explanation regarding how these financial allocations ensure efficiency or necessity relates to concerns of potential wasteful spending. Without understanding the decision-making process behind these costs, there is no assurance that funds are being used effectively, echoing the issue of a lack of clarity on how collected data influences final decisions.
Detailed Financial References
Some sectors show a significant increase in financial burden due to changes in the number of sources subject to regulation. For instance:
Polymeric Coating of Supporting Substrates Facilities demonstrates an increase in estimated costs to $2,190,000, which includes $700,000 in annualized capital or O&M costs.
Nonmetallic Mineral Processing Plants show a projected increase in the burden, with costs mounting to $2,450,000.
Conclusion
Overall, the document presents a thorough financial outline for complying with EPA regulations, but it also raises potential issues regarding transparency, clarity, and justification. The financial allocations need to be clearer in how they are assessed and justified, especially given the varying costs associated with different sectors. This would help address concerns related to the necessity and efficiency of the spending and enhance understanding for a broader audience.
Issues
• The document uses complex legal and regulatory language, which may be difficult for non-experts to understand.
• The document lists many specific information collection requests without providing a high-level overview or summary, which might be challenging to follow.
• There is a lack of clarity regarding the process involved once public comments are submitted—it's unclear how these comments influence the final decision-making.
• The document does not provide a detailed justification for the methodology used in estimating the burden and costs associated with the information collection requests.
• There is potential for wasteful spending as the document doesn't explain how the EPA ensures the efficiency and necessity of each information collection request.
• Some of the changes in estimates are mentioned as 'no change' without a detailed explanation, which could raise concerns on whether the previous burdens were accurately evaluated.
• The document contains multiple specific details about costs and burdens for each ICR, but it does not provide a comparative analysis to justify whether these costs are reasonable.
• While the document describes the procedure to submit and process public comments, it lacks clarity on how the feedback impacts the decision-making process beyond just acknowledgement.
• The text often assumes prior knowledge of specific CFR parts and subparts, which might not be accessible to all readers, particularly those less familiar with the EPA regulations.