Overview
Title
Proposed Information Collection Request; Comment Request; Data Reporting Requirements for State and Local Vehicle Emission Inspection and Maintenance (I/M) Programs
Agencies
ELI5 AI
The EPA wants to keep track of how well cars are checked for pollution by states and cities, and they need people's ideas to make this better. They're asking for helpful thoughts before they ask for permission again to keep doing this, kind of like asking to keep using a library book, and you can tell them what you think by April 30, 2021.
Summary AI
The Environmental Protection Agency (EPA) is planning to submit a request to extend an existing information collection related to vehicle emission inspection and maintenance programs run by state and local governments. The EPA wants public feedback on different aspects of this collection, which helps evaluate and improve these programs, ensuring they meet set emission reduction standards. The current approval for this data collection is valid only till October 31, 2021, and such projects require displaying a valid approval number to legally collect information from the public. Comments must be submitted by April 30, 2021, through the federal regulations website.
Abstract
The Environmental Protection Agency is planning to submit an information collection request (ICR), "Data Reporting Requirements for State and Local Vehicle Emission Inspection and Maintenance (I/M) Programs" (EPA ICR No.1613.07, OMB Control No. 2060-0252) 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 October 31, 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 is a notice from the Environmental Protection Agency (EPA) regarding its intent to extend a data collection initiative related to the inspection and maintenance of vehicle emissions across state and local programs. This effort is part of the broader mission to ensure compliance with emission reduction standards set forth in federal regulations. The notice invites public comments until April 30, 2021, focusing on various aspects of the data collection to refine its process and effectiveness.
General Summary
The EPA is proposing to renew an Information Collection Request (ICR) concerning the reporting requirements associated with vehicle emission inspection and maintenance programs. This initiative, previously approved through October 31, 2021, aims to ensure these programs diligently meet emission reduction commitments. The document also clarifies that the EPA is seeking public feedback on the necessity and utility of the data collection, as well as on ways to minimize the burden on respondents participating in this effort.
Significant Issues and Concerns
Several key issues arise from the document. Firstly, there is a lack of detailed explanation regarding how the "burden" of data collection is calculated, including the estimated 2,236 hours and associated costs. This can obscure the basis of the workload and financial implications for respondents. Additionally, extensive use of technical jargon and regulatory references (e.g., "40 CFR part 51, subpart S") may alienate readers unfamiliar with these legal frameworks. Lastly, instructions for submitting comments are somewhat lacking in clarity, which may confuse individuals new to the online submission process at regulations.gov.
Public Impact
On a broader scale, the extension of this data collection process signifies a continued commitment to monitoring and improving vehicle emission standards. This has potential environmental benefits by ensuring that emission reduction targets are achieved, possibly leading to cleaner air and a healthier ecosystem. However, if the process remains burdensome or unclear, it may deter full participation and the effectiveness of the initiative.
Stakeholder Impact
The primary stakeholders include state and local government entities managing vehicle emission programs. For these parties, the renewal of the ICR means continued administrative responsibilities, requiring regular data submission to the EPA. While potentially time-consuming, this process aids in evaluating program efficacy and identifying areas needing improvement. On the flip side, a group that could be negatively impacted by unclear documentation or burdensome procedures comprises the program managers who may find themselves facing challenges in compliance without adequate guidance or resources.
Overall, while the intention behind the document is to bolster compliance and enhance environmental protection standards, clearer communication and reduced administrative burden could lead to more effective participation and outcomes.
Financial Assessment
The document from the Environmental Protection Agency (EPA) includes a financial reference that details the total estimated cost related to the information collection request (ICR) for state and local vehicle emission inspection and maintenance (I/M) programs. The estimated cost is stated as $148,824 per year, which notably includes $0 in annualized capital or operation and maintenance costs.
This financial reference is crucial for understanding the anticipated financial impact on the state-level programs tasked with reporting. The document provides a clear annual cost, yet it does not specify how this cost is distributed across the various components of the ICR process. The absence of capital or operational costs suggests that the estimated expense is primarily related to labor, likely encompassing staff time for data collection, analysis, and reporting.
However, there are some issues related to this financial estimate that warrant discussion:
Burden Calculation: The document states a total estimated burden of 2,236 hours per year for the respondents. While the overall cost is noted, the document does not outline how this time translates into monetary expense or breaks down the hourly rates or other contributing factors to arrive at the cost of $148,824. This lack of detail can make it difficult for readers to assess the reasonableness of the cost estimate or to understand what specific activities contribute to this financial burden.
Reduction in Respondents: There is an identified decrease in the total estimated respondent burden, attributed to a reduction in the number of respondents. Despite this decrease affecting the financial aspect of the reporting program, the document fails to explain why the number of respondents has decreased. Understanding the context behind this reduction could provide valuable insights into the financial implications, as fewer respondents might indicate changes in program scope, efficiency improvements, or other factors that could influence costs.
These issues underline the need for EPA to provide additional detail on how financial estimates are derived and to clarify any changes that might affect those estimates. Such clarity would aid respondents and stakeholders in evaluating the financial aspects more effectively and ensure a deeper understanding of their obligations and the program's overall financial impact.
Issues
• The document lacks specific details on how the 'burden' is calculated, which could make it difficult for readers to understand the basis of the estimated 2,236 hours and the costs involved.
• The document uses technical jargon and references to specific regulations (e.g., 40 CFR part 51, subpart S) without providing a simplified explanation, which may be challenging for readers unfamiliar with these references.
• There is an implicit assumption that respondents understand their reporting obligations under 40 CFR 51.366, but this is not clearly explained for those unfamiliar with the regulation.
• The document mentions a decrease in the total estimated respondent burden due to a reduction in the number of respondents covered by the collection, but it does not explain why the number of respondents has decreased, which may be important for understanding the context.
• Instructions for submitting comments via regulations.gov could be more explicit about the steps required, potentially confusing first-time users of the portal.