Overview
Title
Proposed Information Collection Request; Comment Request; Annual Public Water Systems Compliance Report
Agencies
ELI5 AI
The EPA wants to hear people's thoughts on their plan to keep water safe by checking if places are following water rules. They think it will take a long time and quite a bit of money to do this, and they're asking for ideas to make their plan better.
Summary AI
The Environmental Protection Agency (EPA) plans to submit an information collection request for the "Annual Public Water System Compliance Report" to the Office of Management and Budget. They are seeking public comments on the proposal before it is finalized. This report concerns the violations of water regulations by states and is mandatory under the Safe Drinking Water Act. The estimated burden for states is 4,400 hours annually, with costs totaling $530,000 per year. There are no significant changes in requirements or costs from previous years, aside from updated labor rates.
Abstract
The Environmental Protection Agency is planning to submit an information collection request (ICR), "Annual Public Water System Compliance Report" (EPA ICR No. 1812.07, OMB Control No. 2020-0020) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. Before doing so, EPA is soliciting public comments on specific aspects of the proposed information collection as described below. This is a proposed extension of the ICR, which is currently approved through June 30, 2021. 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.
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Sources
AnalysisAI
The document from the Federal Register details the Environmental Protection Agency's (EPA) plan to extend an information collection request (ICR) for the "Annual Public Water System Compliance Report." This report, mandated by the Safe Drinking Water Act, is required from states that monitor violations of national primary drinking water regulations. The EPA is inviting public comments before this request is officially submitted to the Office of Management and Budget. Stakeholders have until April 23, 2021, to submit their observations or concerns regarding the proposal.
General Summary
The EPA's proposal underscores the necessity for states to report any infractions concerning water quality, particularly those related to maximum contaminant levels, treatment methods, and other monitoring requirements. The estimated workload for states related to this report is calculated at 4,400 hours annually, translating to a financial burden of approximately $530,000. Importantly, the EPA has noted that there will be no major changes to the regulatory requirements from previous years, except for a slight increase in costs due to updated labor rates.
Significant Issues and Concerns
While the document is comprehensive in its coverage, several notable issues deserve attention:
Cost Increases Due to Labor Rates: The document mentions an increase in costs linked to updated labor rates. However, it lacks detailed insights into how this impacts the overall budget. Understanding these specifics could better justify the revised expenditure expectations.
Complexity of Submitting Comments: The process for submitting comments to the regulatory docket is mentioned, including referencing a specific Docket ID. For individuals unfamiliar with regulatory procedures, this could present a challenge, potentially hindering public engagement.
Lack of Specific Examples or Breakdown: The EPA provides guidance and templates to assist states, but the absence of explicit examples may cause ambiguity. Similarly, the vague description of "significant" violations and insufficient breakdown of the estimated 4,400-hour burden may not provide enough clarity for stakeholders to fully engage with the proposal.
Methodology and Assumptions: The document references evaluation methodologies for assessing burdens but falls short of detailing these assumptions. Consequently, this raises questions about the reliability and transparency of these estimates.
Impact on the Public
The broader impact on the public primarily relates to ensuring safe drinking water through consistent and reliable compliance reporting by states. By maintaining rigorous standards and regular monitoring, the public can expect safer drinking water, potentially reducing health risks associated with contaminants.
Impact on Specific Stakeholders
States with Primacy Enforcement Authority: These entities are directly affected, as they are burdened with compiling and submitting compliance reports annually. Although no new requirements are introduced, updated labor costs could marginally increase financial outlays.
Environmental and Public Health Advocates: For these groups, the document offers a chance to influence regulatory frameworks by submitting comments. Ensuring high safety standards for drinking water aligns with their mission to safeguard public health.
Regulatory Compliance Professionals: The need for clarity in the templates and reporting frameworks is crucial. Ambiguity in these resources could complicate compliance processes, increasing the workload for those professionals tasked with compiling reports.
Overall, while the EPA's proposal aims to maintain water safety standards, addressing the issues highlighted could enhance transparency and participation across various stakeholder groups. By clarifying submission processes and detailing methodological assumptions, the EPA could make the document more accessible and impactful.
Financial Assessment
The document under review is an official notice regarding an information collection request (ICR) by the Environmental Protection Agency (EPA) concerning compliance reports from public water systems. Each year, states with primary enforcement authority under the Safe Drinking Water Act (SDWA) must submit these reports. Several financial aspects are mentioned in relation to this initiative.
Financial Summary
The primary financial detail provided in the document is the total estimated cost of $530,000 per year associated with the information collection request. This cost is noted to include $0 annualized capital or operation & maintenance costs. It primarily accounts for the labor required to carry out the tasks related to the collection of compliance information from public water systems.
Financial Context and Issues
Lack of Detail on Cost Increases
One of the issues identified in the document is a reference to a "slight increase in costs" attributed to updated labor rates, drawn from the Bureau of Labor Statistics report from September 2020. However, the document fails to provide detailed information about how this increase affects the overall budget. Without a breakdown of the prior versus current estimates or a detailed justification, it might be challenging for stakeholders to understand or verify the necessity of the increased financial allocation. This opacity potentially undermines confidence in the accuracy of the cost estimates.
Estimation of Time Burden
The document estimates a total burden of 4,400 hours per year for respondents. Again, while this figure is provided, there is no accompanying context or explanation of how this time translates into financial terms or how it contributes to the overall $530,000 annual cost. This lack of detail can be problematic for assessing the feasibility and efficiency of the collection process. Stakeholders might find it difficult to weigh the financial burden against the benefits or outcomes expected from the initiative.
Financial Implications of State Compliance
The document briefly mentions that states are provided with "model language and reporting templates" to ease their compliance burden. However, from a financial perspective, the document does not quantify the savings or financial efficiency achieved through these measures. Since states are involved in developing and submitting compliance reports, understanding any potential financial offsets these templates provide could be crucial for justifying the overall financial projections of the initiative.
Reliability of Financial Estimates
Lastly, the text suggests that financial estimations remain unchanged due to a lack of regulatory changes or industry growth. However, the methodology and assumptions influencing these financial projections are not thoroughly discussed. This omission can lead to uncertainties over the reliability and accuracy of the reported financial impact, leaving room for questioning whether the cost allocation is truly reflective of the work involved.
In conclusion, while the document outlines the basic financial cost associated with the ICR, there is a noticeable lack of detailed justification and breakdown of these costs. This lack of transparency could limit stakeholders' ability to fully understand or evaluate the financial reasoning behind the proposed budget.
Issues
• The document mentions a 'slight increase in costs' due to updated labor rates without providing detailed information on the specific impact this has on the overall budget or how it has been justified.
• The language used regarding the submission process of comments (e.g., 'referencing Docket ID No. EPA-HQ-OECA-2020-0438') may be unclear to individuals unfamiliar with the process of submitting public comments to regulatory dockets.
• There is a mention of 'model language and reporting templates' issued by the EPA to states but no specific examples or descriptions of what these templates include, which may lead to ambiguity for those responsible for compliance.
• The abstract and text both mention that states must submit reports showing 'violations of maximum contaminant levels, treatment requirements, variances and exemptions, and monitoring requirements,' but it lacks detail on what specifically constitutes a 'significant' violation and how these determinations are made.
• The estimation of 4,400 hours per year as the total burden is provided without context or breakdown, making it difficult to assess if this estimate is reasonable or if it accurately reflects the effort required by affected entities.
• The methodology and assumptions used for evaluating the accuracy of the Agency's estimate of the burden (Section (ii) in the Supplementary Information) are not detailed, which creates uncertainty about the reliability of these estimates.