FR 2021-03794

The document under consideration is an official notice from the Environmental Protection Agency (EPA) regarding the renewal of information collection requirements related to public notifications of Combined Sewer Overflows (CSOs) in the Great Lakes Basin. This initiative ensures that members of the public and relevant health departments are promptly informed about such overflows, which can pose significant health risks due to potential exposure to sewage-related pathogens.

General Summary

The main thrust of this notice is the EPA's proposal to extend these requirements, as they are currently set to expire on April 30, 2021. The extension seeks to maintain the framework for monitoring and notification procedures regarding CSO discharges. Additionally, the EPA is currently seeking public comments on this plan, with the submission deadline marked as March 26, 2021. Such comments can help shape the final version of the proposed regulations.

Significant Issues or Concerns

Several issues arise from the document:

1. Complexity and Jargon: The document is laden with regulatory and legal jargon, which might be challenging for the general public to understand. Terms like "OMB control number," "capital or operation & maintenance costs," and references to legal codes (e.g., 40 CFR 122.38) may confuse readers, especially those without a legal or regulatory background.

2. Cost and Efficiency: There is an estimated annual cost of $426,059 associated with this program. However, the document does not provide a clear alignment of these costs with the potential health benefits, which might indicate inefficient use of resources. Readers might question whether the benefits justify the financial outlay.

3. Insufficient Context for Changes: The document outlines specific changes in estimates, like a net decrease of 1,607 burden hours and adjustments in financial costs. However, it lacks sufficient context or explanations to help readers understand the reasons for these fluctuations. This lack of clarity could lead to misunderstandings regarding the implications of these changes.

4. Specific Examples and Implications: Although the document highlights Woodville, Ohio, as a permittee that has exited the scope of the rule, it fails to elaborate on the broader implications of such exemptions for other regions or entities.

Broad Public Impact

For the general public, the continued enforcement of CSO notification regulations is primarily a positive endeavor, as it aims to enhance public health safety by keeping citizens informed of potential health risks associated with sewage overflows. By proactively notifying communities and health officials, the policy may help reduce exposure to harmful pathogens, thereby preventing related health issues.

Impact on Specific Stakeholders

Specifically, this rule impacts CSO permit holders in states surrounding the Great Lakes, which include Illinois, Indiana, Michigan, New York, Ohio, Pennsylvania, and Wisconsin. These permit holders bear the responsibility—and associated costs—of compliance, including developing public notification plans, which are mandatory under current regulations.

For local health departments and state environmental agencies, the rule provides necessary information to enforce public health measures effectively. On the downside, for municipalities like Woodville, Ohio, which have separated their combined sewer systems, facilitating exemption reduces their regulatory burden, but changes like these require clear communication within the community to prevent mixed messaging.

Overall, while the initiative underscores an important public health measure, the document could benefit from greater clarity and transparency in presenting the estimated costs and procedural changes to ensure broader public understanding and acceptance.

The document submitted by the Environmental Protection Agency (EPA) focuses on the financial aspects related to the public notification requirements for Combined Sewer Overflows in the Great Lakes Basin. It outlines the costs and budgetary changes related to the implementation and maintenance of the program.

Summary of Financial Allocations

The total estimated cost for this initiative is $426,059 per year. This amount incorporates $5,412 allocated for annualized capital or operation and maintenance costs. The financial commitment reflects the costs associated with ensuring compliance with public notification requirements, including the necessity for signage and communications with potentially affected public entities.

Contextualizing Financial References and Issues

A closer look at the document reveals that there is an increase in labor costs by $31,841. This adjustment is attributed to projected increases in labor base wages and the overall compensation, which includes benefits. Such increments could pose concerns if the cost increases are not matched by a corresponding benefit to public health and safety, highlighting potential inefficiencies in spending.

Conversely, the document notes a decrease in non-labor costs of $65,038. This reduction is largely due to a drop in capital costs following the initial setup phase of the prior Information Collection Request (ICR). A significant portion of initial costs often involves capital expenses, suggesting that ongoing expenses might be more sustainable in the long term once the infrastructure is in place.

Additionally, the document reports a decrease in total burden hours and costs, leading to a net reduction of $31,048 over a three-year period. This indicates a degree of streamlining in the processes, potentially reflecting efficiencies gained through experience and completion of initial activities.

Implications of Financial Changes

The financial changes, such as the exit of Woodville, Ohio from the scope of the regulation, seem to have impacted the overall cost and burden reductions mentioned. However, the document fails to explain comprehensively how these financial implications translate into practical outcomes or benefits for the community, which could present a communication gap for those unfamiliar with regulatory processes.

Overall, while the reduction in both gross burden hours and costs suggests improved efficiency over the previous cycle, it is imperative that these financial changes are effectively communicated to stakeholders to ensure transparency and build trust in the regulatory process. Stakeholders may require clearer explanations of how these changes will continue to support public health outcomes, particularly in the sensitive environmental context of the Great Lakes Basin.