Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; NSPS for Polymeric Coating of Supporting Substrates Facilities (Renewal)
Agencies
ELI5 AI
The Environmental Protection Agency wants to renew rules for factories that make shiny coatings, and people have 30 more days to tell them what they think about it. These rules make sure 74 places check their work and tell the EPA every few months, and this takes many hours and costs a lot of money.
Summary AI
The Environmental Protection Agency (EPA) has submitted a request to renew the information collection for the New Source Performance Standards (NSPS) related to polymeric coating at supporting substrates facilities, extending its approval until December 31, 2024, under the Paperwork Reduction Act. This notice was published to allow an additional 30 days for public comments. The rules apply to 74 facilities, requiring responses initially, quarterly, and semiannually, with an estimated total burden of 16,400 hours and a cost of $3,330,000 annually. No changes in the regulations or burden are anticipated in the next three years.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), NSPS for Polymeric Coating of Supporting Substrates Facilities (EPA ICR Number 1284.13, OMB Control Number 2060-0181) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. This is a proposed extension of the ICR, which is currently approved through December 31, 2024. Public comments were previously requested via the Federal Register on May 18, 2023 during a 60-day comment period. This notice allows for an additional 30 days for public comments.
Keywords AI
Sources
AnalysisAI
The document in question is a notice from the Environmental Protection Agency (EPA) regarding the continuation of regulations relating to the New Source Performance Standards (NSPS) for polymeric coating facilities. This regulation is primarily concerned with how coatings are applied to substrates, which are materials that support a layer of another substance (like paint or film). The EPA seeks to extend the approval of this information collection until December 31, 2024. Public feedback has been invited, with an additional 30-day window for submitting comments.
General Summary
This notice highlights the procedural steps the EPA is taking to renew the information collection process associated with these standards. The rules currently apply to 74 facilities, which are expected to respond with information as part of regulatory compliance. The document outlines that the estimated effort needed to comply with these rules is significant, requiring 16,400 hours of work each year and costing around $3,330,000. Despite the substantial efforts involved, there are no anticipated changes to the existing regulations for the next three years.
Significant Issues or Concerns
Several issues emerge from the document:
Cost Breakdown: The notice states a total annual cost but doesn't provide detailed information on how this cost is broken down across capital, operation, and maintenance expenses. A more transparent breakdown would help the public understand the financial implications.
Historical Context: The regulations were established over three decades ago, in 1989. The document does not discuss any updates or changes that have occurred since then, leaving room for questions about their current relevance or adaptation to modern practices and technological changes.
Lack of Updates: The document confirms that no changes in burdens have been observed, which raises questions since industry practices and technologies have evolved. The absence of updates suggests a potential oversight in adapting the regulations to contemporary contexts.
Unknown Respondent Determination: It does not clarify how the number of impacted facilities (74) was determined. This lack of clarity might lead to skepticism about the accuracy and relevance of the estimated figures.
Technical Language: The use of technical terms and specific legal citations can make the notice difficult for a general audience to read and understand. Simpler language or explanations would increase accessibility and public engagement.
Impact on the Public
For the general public, especially those not directly involved in the industry, this document may little impact their daily lives. However, understanding such regulatory processes is crucial as it reflects ongoing efforts to monitor and manage industrial environmental impacts, which indirectly benefits everyone by maintaining environmental standards.
Impact on Specific Stakeholders
The primary stakeholders directly affected are the polymeric coating facilities. For these businesses, the need to comply with ongoing regulations and associated costs can be significant. Preparing and submitting information requires labor and financial resources that could impact their operating budgets.
On the positive side, compliance confirms adherence to environmental standards, which can enhance a company's reputation for environmental responsibility. Nonetheless, without updates to accommodate new technologies or practices, some stakeholders might feel these regulations are outdated and potentially burdensome.
In summary, while the continuation of these regulations indicates the EPA's ongoing commitment to enforcing environmental standards, the document could benefit from heightened transparency and updates. This approach would ensure the regulations remain relevant and effectively promote both industry compliance and public awareness.
Financial Assessment
The document from the Environmental Protection Agency (EPA) involves a financial reference concerning the regulatory requirements for certain facilities. This detailed commentary will provide a closer look at this financial reference and its implications.
Financial Summary
The document highlights that the total estimated cost associated with the compliance for the New Source Performance Standards (NSPS) for Polymeric Coating of Supporting Substrates Facilities is $3,330,000 per year. This cost includes $826,000 annually in capital or operation and maintenance costs.
Context and Considerations
The financial estimate is significant as it reflects the annual economic burden placed on the entities required to comply with these standards. However, the lack of a detailed breakdown for these costs in the document raises some concerns. Specifically, the document does not elucidate how the total cost is divided between capital expenses and operation and maintenance costs, which includes no breakdown or explanation on what exactly comprises these figures.
Relation to Identified Issues
One of the primary issues with the financial references is their lack of transparency. While the document states that there is no change in burden from the most-recently approved information collection request (ICR), it does not provide reasons for the static nature of these financial estimates. Such stagnation in cost could suggest a lack of diligence in considering advancements in technology that could potentially reduce the costs associated with compliance. Moreover, without an understanding of how these financial figures were derived, stakeholders are left without clear justification for the substantial financial demands these regulations put on facilities.
Further complicating the matter is the technical nature of the document which might obscure understanding for those not well-versed in regulatory language. References such as "NSPS" and "subpart VVV" without gloss can make it difficult for a general audience to grasp the financial implications fully.
In summary, while the document provides a clear figure for the annual costs involved, it could benefit from additional clarity and transparency to justify the expenses and help stakeholders understand the financial obligations and benefits better.
Issues
• The document does not provide specific details on how the estimated total cost of $3,330,000 per year was calculated, including the breakdown of capital, operation, and maintenance costs. This lack of transparency can be considered as unclear or ambiguous.
• The abstract mentions that the regulations were proposed in 1987 and promulgated in 1989. However, it does not provide context on any changes or updates in regulations since then, which could make understanding the historical context and current relevance difficult.
• The document mentions that there is no change in burden from the most-recently approved ICR, but it does not explain why there has been no change despite potential advancements in technology or changes in industry practices over the years. This could appear as a lack of diligence in updating relevant metrics.
• While the estimated number of respondents is provided, the document does not explain how this number was determined. Without this information, it might be seen as unclear or lacking justification.
• The language used is quite technical and could be difficult for a layperson to understand, particularly terms like 'NSPS', 'subpart VVV', and references to the Code of Federal Regulations (CFR). A simpler explanation or gloss would be beneficial.