Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; NESHAP for Carbon Black Production (Renewal)
Agencies
ELI5 AI
The Environmental Protection Agency wants to keep checking how factories that make a material called "carbon black" follow pollution rules. They are asking for permission to keep doing this, and they want people to share their thoughts about it by January 17, 2025.
Summary AI
The Environmental Protection Agency (EPA) has submitted a request to extend an information collection requirement concerning carbon black production, under the National Emission Standards for Hazardous Air Pollutants (NESHAP), to the Office of Management and Budget (OMB) for approval. This would allow for continued compliance checks on facilities that produce carbon black to ensure they follow existing pollution standards. Public comments are being invited until January 17, 2025, and detailed information about what the EPA will be collecting can be found online. The increase in estimated costs and time reflects the application of updated labor rates and adjustments to previous reporting frequency errors.
Abstract
The Environmental Protection Agency has submitted an information collection request (ICR), NESHAP for Carbon Black Production (EPA ICR Number 2677.03, OMB Control Number 2060-0738) 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 August 6, 2024 during a 60-day comment period. This notice allows for an additional 30 days for public comments.
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Sources
AnalysisAI
The document outlined in the Federal Register is a notice from the Environmental Protection Agency (EPA) regarding an extension request for collecting information about carbon black production. This is part of the National Emission Standards for Hazardous Air Pollutants (NESHAP). The EPA is seeking approval from the Office of Management and Budget (OMB) to continue ensuring that facilities producing carbon black comply with pollution standards aimed at maintaining environmental safety. Public comments on this request can be submitted until January 17, 2025, which gives concerned parties an opportunity to voice their opinions or concerns about this proposed extension.
Significant Issues and Concerns
Several issues are notable within the document. Firstly, the document refers to the "burden" as defined at 5 CFR 1320.3(b) without detailing what this entails. This omission leaves room for confusion about what specific obligations are being placed on respondents.
Furthermore, the document mentions changes in cost and burden estimates due to a "revised application of costs." However, it does not provide specifics about what revisions were made, thus leaving stakeholders guessing about the nature of these updates. Similarly, the previous errors in reporting frequency and their correction are only broadly mentioned, without comprehensive clarification.
Additionally, the methodology for determining the number of respondents, set at 15, is not clearly explained. This can raise questions about the accuracy or representativeness of the data.
Another issue is the limited explanation of terms like "Capital/Startup and O&M costs," which may confuse readers not familiar with economic or industrial terminology. Moreover, while the document references updated labor rates from the Bureau of Labor Statistics, it lacks a clear citation or explanation of how these rates specifically informed the cost calculations.
Lastly, the procedural note stating that all comments will be included in the public docket "without change" unless they contain certain types of restricted information might be insufficiently cautious. It does not discuss any process to redact sensitive personal information that might be submitted inadvertently, posing potential privacy issues.
Public Impact
Broadly, this document has implications for both general public health and environmental safety. By extending the information collection regarding compliance with air pollution standards, the EPA aims to ensure that industrial facilities operate within the limits that protect the environment from harmful emissions. This oversight is crucial in safeguarding the community and environmental health by holding industries accountable for their emissions.
Impact on Specific Stakeholders
For stakeholders, particularly those in the carbon black production industry, the document signifies a regulatory burden. Facilities must comply with detailed reporting and record-keeping to maintain their operational permits, which can incur additional operational costs and require resource allocation to ensure compliance.
However, this requirement also promotes responsible business practices and a level playing field among industry participants, encouraging the adoption of cleaner technologies and processes. Advocates for environmental conservation would likely view this renewed emphasis on compliance positively, as it aligns with broader goals of reducing pollution and its associated health risks.
The document underscores the ongoing challenge of balancing industrial growth with environmental stewardship, reflecting the EPA's role in enforcing standards that ultimately benefit both the public and the planet.
Financial Assessment
The document under review involves financial implications linked to the renewal of information collection activities by the Environmental Protection Agency (EPA). This EPA action pertains to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Carbon Black Production. Financial components within this document are crucial for understanding the overall impact of this initiative.
Summary of Financial Implications
The text outlines the total estimated cost associated with this information collection, amounting to $84,300 per year. This figure encompasses $51,500 in annualized capital or operation and maintenance (O&M) costs. These expenses are part of the resources needed to ensure compliance with the NESHAP.
Analysis of Financial References
The document mentions changes or adjustments in the financial estimates compared to previous assessments. There is an increase in costs and burden due to several revisions. One notable change is that semiannual reports were previously mislabeled as once-per-year occurrences. This adjustment has a direct impact on the estimated costs and burden, but the document lacks specific clarification on how these figures were initially calculated or corrected, which relates to one of the identified issues regarding the clarity of changes in estimates.
Financial Adjustments and Their Basis
Additionally, the document references the use of updated labor rates based on the "most recent Bureau of Labor Statistics report (December 2023)" as a factor contributing to the increased estimated costs. However, it does not provide a specific citation or explanation of how these labor rates were applied within the context of the ICR, creating a potential gap in understanding the financial rationale. This relates to another identified issue regarding the transparency and methodology of updating financial figures.
The conversion of Capital/Startup and O&M costs from 2021 dollars to 2023 dollars uses the CEPCI Index. While this index is typically utilized for such adjustments, the document does not elaborate on its application specifics, which may lead to confusion for readers unfamiliar with this procedure.
Considerations for Cost Clarity
Efforts to elucidate how estimations are derived and adjusted could enhance understanding. While the document does estimate the number of respondents as 15, it doesn't clearly explain how this figure affects financial allocations or if it has been verified, posing an additional area for improvement in financial reporting.
By examining these financial references and corrections, stakeholders are better positioned to assess the allocation of resources for compliance efforts related to environmental standards. Ensuring more detailed explanations and justifications can promote greater transparency and comprehension among the audience.
Issues
• The document refers to the burden defined at 5 CFR 1320.3(b), but does not provide details, making it unclear what specifically constitutes the 'burden'.
• The explanation of changes in estimates refers to a 'revised application of costs' without detailing what specific revisions were made, making it difficult to fully understand the increase in estimated costs and burden.
• The language in the 'Changes in the Estimates' section regarding the incorrect labeling of semiannual reports is somewhat unclear, and could benefit from clarification on how this error was previously calculated and how it is corrected now.
• The document does not provide clear information on how the number of respondents (15) is derived or verified.
• There is a lack of comprehensive definition or explanation of the term 'Capital/Startup and O&M costs', which may pose difficulties for readers unfamiliar with the terminology.
• The basis for updating labor rates using the 'most recent Bureau of Labor Statistics report (December 2023)' lacks a specific citation or detailed explanation of how these updates were calculated in the context of the ICR.
• The requirement that all comments will be included in the public docket 'without change' unless they contain certain types of restricted information could be seen as potentially problematic, as it doesn't mention procedures for removing or redacting sensitive personal information inadvertently submitted.
• There is a slight inconsistency in names, as 'EPA Docket Center' in the 'ADDRESSES' section is referred to both with its full address and with a different address in the 'SUPPLEMENTARY INFORMATION' section, which could cause confusion.