FR 2021-04197

The document under discussion is a notice from the Environmental Protection Agency (EPA) regarding the planned submission of an Information Collection Request (ICR) for the reinstatement of the Clean Watersheds Needs Survey (CWNS) to the Office of Management and Budget (OMB). This survey is important for periodically evaluating the infrastructure needs of publicly owned wastewater and pollution control facilities across the United States.

General Summary

The CWNS aims to collect and assess data from states and local facilities concerning existing and needed facilities for wastewater conveyance, treatment, stormwater management, and other water pollution controls. The information collected informs the federal government and stakeholders about the required investments to maintain and improve water quality. The survey seeks to evaluate these needs on a four-year cycle, and compliance with this data collection is deemed voluntary for respondents. The EPA is currently seeking public commentary on specific components of this information gathering process as part of its responsibility under the Paperwork Reduction Act (PRA) before formally submitting to the OMB for approval.

Significant Issues or Concerns

One of the key issues that arises from this document relates to the clarity of the survey's purpose and scope. While it outlines the objective of identifying facility needs, the language could be clearer about how that information is utilized and its importance to broader environmental goals. The increase in estimated respondent burden—from both a time and cost perspective—raises questions as well. It would be helpful for the document to provide a more detailed breakdown of the projected annual cost of $505,004 and better justify the increase in burden hours and costs due to an expanded facility universe and changes in labor rates.

The document also does not adequately explain the voluntary nature of the respondents' obligation. Making clearer the voluntary aspect would help respondents understand their rights and options regarding participation. Furthermore, the document lacks detail on the validation techniques used for achieving national consistency in the survey results. Information on data protection measures for personal information is also insufficient, particularly in the context of public docket submissions.

Public and Stakeholder Impact

For the general public, this survey's implications center around the effective management of water pollution issues which impact public health and environmental quality. A well-conducted needs survey can lead to better-targeted infrastructure investments and federal funding allocations for maintaining healthy water systems that benefit all layers of society.

Stakeholders such as state agencies and local facilities might have mixed responses. On one hand, the data collected could guide and support requests for necessary upgrades or maintenance funding. Conversely, the burden associated with data submission, both in terms of administrative time and cost, may weigh heavily on local government resources, especially in smaller municipalities that might lack the personnel to address federal information requests efficiently.

Overall, while the CWNS serves a vital role in environmental planning and policymaking, the issues delineated, if not addressed, can affect participation rates and the quality of data collected. More clarity and transparency in the process and expectations can enhance the trust and cooperation between the EPA and its respondents.

The document in question addresses a planned submission by the Environmental Protection Agency (EPA) for an information collection request regarding the Clean Watersheds Needs Survey (CWNS). This proposal includes references to financial estimates and burdens that relate directly to the execution and management of the survey.

The primary financial reference within the document discloses a total estimated cost of $505,004 per year. This figure represents the operating expense anticipated for the undertaking of the CWNS. It is important to note that this amount is reported to include no annualized capital or operation and maintenance costs. The implication here is that the stated amount primarily accounts for the personnel and administrative costs associated with conducting the survey.

In a comparison with a previous iteration of the information collection request, there is a reported increase of 541 hours and an additional cost of $134,820 in the estimated respondent burden. This financial increase is attributed to two key factors: an expansion in the facility universe, implying more facilities will be surveyed, and changes in labor rates and benefits, which suggest adjustments in compensation or benefits for those involved in administering or responding to the survey.

The document could benefit from further clarity regarding how the total estimated cost of $505,004 per year is calculated. A more detailed breakdown of this amount would provide transparency concerning the allocation of funds across various components of the survey. For instance, distinguishing between administrative costs, survey implementation, data analysis, and reporting would help to understand the financial structure better.

Additionally, the increase of 541 hours and $134,820 suggests a significant change compared to previous estimates. However, the document lacks sufficient detail to justify the necessity or reasoning behind this substantial increase. Specifically, while it is noted that this change stems partly from an increase in the facility universe and labor rate adjustments, it might be beneficial for the document to specify whether these are the exclusive reasons or if other factors also contribute to the heightened burden.

Given these financial considerations, aligning cost estimates with clear, justifiable reasons can help address concerns regarding the necessity and efficiency of the proposed spending. Moreover, ensuring clarity in the expenditure and financial planning process will support the EPA's efforts in conducting an effective and transparent survey.