FR 2021-03793

Summary of the Document

The document from the Federal Register pertains to the Environmental Protection Agency (EPA), which is seeking extended approval for an Information Collection Request (ICR) related to the national emissions standards for hazardous air pollutants (NESHAP) concerning epoxy resin and non-nylon polyamide production. Essentially, the EPA is collecting data to ensure compliance with existing environmental regulations. The document outlines the submission process to the Office of Management and Budget (OMB) and invites public comments until March 26, 2021. It estimates the number of facilities affected, the total hours spent on compliance annually, and the associated costs.

Significant Issues and Concerns

Several concerns arise from this notice. First, the technical language and references such as "NESHAP", "ICR", and "40 CFR part 63, subpart W" may not be easily understood by individuals without specialized knowledge, which can be a barrier to public engagement. Additionally, the document includes details and dates that, without proper context, might be confusing or seem outdated, like its reference to being currently approved through April 30, 2021.

The costs associated with this information collection are stated explicitly but lack context regarding their necessity or how they compare with historical expenditures. Although it mentions that costs are updated using financial indices, this might not resonate with a general audience who would want to know why these costs fluctuate.

Public and Stakeholder Impact

Broadly speaking, this regulatory notice has a twofold impact. For the general public, the maintenance and extension of environmental standards signify ongoing efforts to protect air quality and public health, which is a positive outcome. By ensuring companies comply with existing rules, the EPA aims to reduce hazardous air emissions, ultimately benefiting the environment and health standards.

However, for the specific facilities involved in epoxy resin and non-nylon polyamide production, these regulations mean a continuous commitment both in terms of time and financial resources. With a mandatory obligation to respond to these data collections, these businesses experience a significant operational burden, estimated at 3,940 hours of work per year, and a cost totaling $476,000 annually. The document's acknowledgment of increased costs could be seen as concerning for these stakeholders, suggesting an ongoing escalation in compliance costs relative to previous years.

This notice underscores the delicate balance regulatory bodies must maintain between public health protection and the operational realities of businesses. While it assures the public of continued environmental vigilance, it also serves as a reminder of the economic implications for industries tasked with adhering to these standards.

The document at hand from the Environmental Protection Agency (EPA) references financial aspects related to the Information Collection Request (ICR) for the NESHAP for Epoxy Resin and Non-Nylon Polyamide Production.

Estimated Costs and Burden

The total estimated cost mentioned in the document for this ICR amounts to $476,000 per year. This figure includes $14,000 allocated for annualized capital, startup, and operation and maintenance costs. The estimated burden is defined as 3,940 hours per year. These numbers represent the financial investment and time required of the affected parties to comply with the standards set forth by the EPA.

Context and Comparison

It is noted that there has been no increase in the burden from the most recently approved ICR in terms of hours. This stability is attributed to two factors: no changes in the regulations over the past three years and a stagnant growth rate in the industry. The continuity in regulatory requirements suggests that affected facilities are able to maintain the same level of compliance efforts without additional time investments.

However, there is a 'slight increase in costs' mentioned, despite the consistent burden. This increase is primarily due to an update in operation and maintenance costs from 1998 dollars to 2019 dollars, using the CEPCI CE Index. Although the document specifies this update as a reason for the increase, it lacks a comprehensive explanation comparing current costs to those in previous years. The mention of these updates without further details might lead to queries about accountability and transparency in cost escalation.

Financial Transparency and Justification

The inclusion of specific financial figures and the update of cost calculations are aimed at providing clarity regarding the financial responsibilities imposed on businesses. Yet, the document might benefit from more detailed justification regarding why these costs are considered necessary or how they relate to potential benefits to the environment or public health. Additionally, more context is needed to understand if these costs are consistent with those typically seen in similar industries or compliance activities.

Overall, while the document attempts to provide a clear financial picture, the general public would likely appreciate additional context and explanations, particularly concerning the cost updates and how these compare with historical figures or expected outcomes.