Overview
Title
Proposed Information Collection Request; Comment Request; EPA's WaterSense Program (Renewal)
Agencies
ELI5 AI
The EPA wants to keep making sure that products (like faucets and toilets) use less water. They're asking people for thoughts on this plan, which will take some extra work, but they've worked hard to make it simpler and less costly to do.
Summary AI
The Environmental Protection Agency (EPA) plans to submit a request to renew its WaterSense Program, which promotes water-efficient products and practices, to the Office of Management and Budget (OMB) for approval. Public comments are being sought on various aspects of the information collection before submission. WaterSense partners, including manufacturers and retailers, will be involved voluntarily, with the estimated total burden over three years expected to be 6,830 hours annually, at a cost of $598,527 per year. Recent program changes have reportedly reduced the estimated burden and operational costs.
Abstract
The Environmental Protection Agency (EPA) is planning to submit an information collection request (ICR), "EPA's WaterSense Program (Renewal)" (EPA ICR No. 2233.08, OMB Control No. 2040-0272) 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.
Keywords AI
Sources
AnalysisAI
The document from the Federal Register is a notice from the Environmental Protection Agency (EPA) about its intention to renew the WaterSense Program's information collection. This program is designed to promote the use of water-efficient products and practices, offering incentives to manufacturers and retailers who participate voluntarily. The EPA seeks public comments on this renewal prior to submitting it to the Office of Management and Budget (OMB) for approval. The agency has projected that the information collection effort will require around 6,830 hours of work annually, costing approximately $598,527 each year.
Significant Issues and Concerns
One of the main concerns is the use of technical jargon and references to regulatory numbers such as the OMB control number and the EPA ICR number. These might not be clear to the general public who are not familiar with federal regulatory processes. Additionally, the document mentions "confidential business information" without providing an explanation of what it includes or the measures taken to ensure confidentiality. This could lead to confusion or mistrust among stakeholders who provide data to the program.
The estimated cost of nearly $600,000 per year to manage this program might appear high without a detailed breakdown of expenses. This could lead to public concern about the efficient use of taxpayer dollars. Moreover, while the document mentions a significant decrease in the estimated participant burden by over 2,000 hours, it provides scant details, potentially raising questions about the reliability of the new estimate.
Furthermore, the mention of multiple specific forms without explaining their purpose or content can be confusing, potentially hindering understanding amongst stakeholders who are required to complete them.
Public Impact
On a broad level, the public may benefit from the EPA renewing its focus on water conservation, which is a critical environmental goal. Programs like WaterSense can drive significant water savings, reducing water bills for households and allowing communities to better manage water resources. The program generally promotes awareness and market creation for products that help consumers save water and, consequently, energy.
However, the potential burden on small businesses or individuals participating voluntarily could be considerable. Understanding whether these benefits outweigh the costs might be a concern for some.
Impact on Stakeholders
Positive Impacts:
Manufacturers and Builders: Partners in the program receive marketing incentives and support from the EPA to create and promote water-efficient products. This could lead to increased sales and market visibility.
Consumers: Through awareness and accessibility to water-efficient products, consumers could see a reduction in utility expenses and contribute positively to environmental conservation.
Negative Impacts:
Potential Partners: The process of becoming a partner involves numerous paperwork and forms, which, despite the reduction in burden, could still be a hurdle, particularly for smaller entities.
Program Participants: The lack of clarity on the handling and security of confidential business information might deter participation, especially among those cautious about data privacy.
In conclusion, while the EPA's initiative encourages significant strides in environmental responsibility, clarity, and transparency about the administrative aspects and cost allocations would reassure public and partner confidence in its continued efficacy. The public comment period is an opportunity for stakeholders to voice their concerns and contribute to shaping the program's future implementation.
Financial Assessment
The Federal Register document under review outlines the Environmental Protection Agency's (EPA) intention to extend its WaterSense Program, a voluntary initiative aimed at promoting water-efficient products and practices. A crucial aspect of this document is its discussion of the financial implications and estimated costs associated with the program.
Summary of Financial References
The document projects a total estimated cost of $598,527 per year for both the respondents (participants in the WaterSense Program) and the EPA itself. This annual cost encompasses all activities related to the program, including administrative tasks and data collection efforts. Additionally, the document notes $1,578 in annualized capital or operation and maintenance costs.
Relation to Identified Issues
One notable issue referencing financial aspects is the cost estimation. The sum of $598,527 may appear substantial for a voluntary program, yet the document lacks a detailed breakdown of how this figure is allocated. The absence of a clear explanation, combined with technical jargon like "capital or operation & maintenance costs," makes it difficult for the general public to discern how funds are precisely utilized. This concern is further compounded by the document's use of specialized financial and regulatory terms, such as "confidential business information (CBI)," without elaborating on their practical implications in the context of financial accountability.
Moreover, the document indicates a decrease in the estimated burden hours for respondents, lowering the associated costs. However, it does not sufficiently detail the primary drivers behind this reduction, presenting only a generalized explanation of changing program requirements and simplifying reporting processes. This decrease could significantly impact financial allocations, yet it is not fully addressed or quantified in a manner accessible to all readers.
In conclusion, while the document provides an overarching view of the financial commitments related to the WaterSense Program, a more detailed elucidation of how funds are allocated and the factors contributing to projected cost reductions would enhance transparency and public understanding. More comprehensive coverage would help demystify the financial workings behind governmental voluntary programs, potentially increasing public engagement and support.
Issues
• The document references a specific OMB control number and EPA ICR number, which may not be clear to those unfamiliar with federal regulatory processes.
• The estimated cost of $598,527 per year for both respondents and EPA might be perceived as high, without a detailed breakdown of how the funds are allocated.
• The term 'confidential business information (CBI)' is used without a detailed explanation of what it entails or how confidentiality is maintained.
• The use of technical terms, such as 'Paperwork Reduction Act' and specific section codes, may not be easily understood by all readers.
• The document mentions a 'Consumer Awareness Survey' but does not provide detailed information on the survey's scope, methodology, or frequency.
• Details on the decrease of 2,096 hours in the respondent burden compared to the previous estimate are somewhat brief, which might lead to questions about the validity of the new estimate.
• The document contains multiple references to specific forms (6100-X3, 6100-09, etc.), which may be confusing without additional context or explanations for each form.
• While the document provides general information about the WaterSense program, it lacks specific examples or case studies that might illustrate the program's impact.
• The language in the document, while formal and appropriate for a Federal Register notice, might be considered complex or difficult to understand for those not versed in bureaucratic or legal language.