Overview
Title
Agency Information Collection Activities; Maintenance of State Programs and Procedures for Substituting Federal Enforcement of State Programs and Withdrawing Approval of State Programs
Agencies
ELI5 AI
The Office of Surface Mining Reclamation and Enforcement wants people to give their thoughts about renewing a form that checks if states are following the rules for using federal land properly. They want to know if the way they check is good or if it needs to change to make sure everything is fair.
Summary AI
The Office of Surface Mining Reclamation and Enforcement (OSMRE) under the Interior Department is requesting public comments on a proposal to renew an information collection, as part of their efforts to reduce paperwork burdens. This notice is in accordance with the Paperwork Reduction Act of 1995 and the information collection focuses on the maintenance and evaluation of State programs in relation to federal enforcement. The public is invited to share their views on the necessity, accuracy, and methods of this information collection by February 10, 2025. Comments may impact how the OSMRE evaluates state programs and could influence federal involvement if certain requirements are unmet.
Abstract
In accordance with the Paperwork Reduction Act of 1995, we, the Office of Surface Mining Reclamation and Enforcement (OSMRE), are proposing to renew an information collection.
Keywords AI
Sources
AnalysisAI
The document from the Federal Register announces that the Office of Surface Mining Reclamation and Enforcement (OSMRE), a branch of the U.S. Interior Department, is seeking public feedback on a proposed renewal of an information collection. This request for comments stems from the Paperwork Reduction Act of 1995, which aims to minimize the paperwork burden for individuals and organizations. The information collection in question relates to the maintenance and evaluation of State programs concerning federal enforcement.
General Summary
The document is a formal notice inviting public participation in assessing and commenting on the proposed renewal of data collection by the OSMRE. The agency seeks to understand how this data collection supports the oversight and enforcement of state programs that align with federal requirements. The public is encouraged to submit their comments by February 10, 2025.
Significant Issues and Concerns
Several issues arise from the specifics of the notice:
Unclear Information Requirements: The document does not detail the exact nature of the information to be collected. This lack of specificity could leave potential respondents unsure about what is expected from them, possibly leading to hesitance or confusion.
Completion Time Variability: The document states that the time to complete a response ranges from 20 to 120 hours. This broad range suggests possible inconsistencies or ambiguities in the requirements, indicating a need for clearer guidelines.
Low Respondent Estimate: The notice projects an exceptionally low number of annual respondents and responses—only one each. This raises questions about the importance and effectiveness of the data collection effort and whether it justifies the administrative process involved.
Evaluation Request Procedure: While the document mentions that any interested person can request a state program evaluation, it does not clarify the criteria or method for such requests. This lack of transparency could lead to procedural ambiguities.
Unclear Benefits: It is mentioned that respondents are required to provide information to "obtain or retain a benefit," yet this benefit is not defined. Without understanding what they stand to gain, respondents may be less motivated to comply.
Privacy Concerns: If personal information is included in public comments, the document states that confidentiality of such information cannot be guaranteed. This could deter individuals from participating in the comment process.
Impact on the Public
Broadly, this request for comments may influence how the OSMRE carries out its mandate to supervise and evaluate state programs. By soliciting public feedback, the agency strives to enhance its processes and address any concerns that the collection of information might be overly burdensome. The feedback received could shape future policies and actions regarding federal oversight of state-managed programs.
Impact on Specific Stakeholders
State Governments: These entities might be directly affected by changes in evaluation and enforcement procedures. Clearer guidance and efficient processes could help state governments better comply with federal standards.
Individual Respondents: Those who wish to participate in the comment process may face difficulties if the expectations and outcomes of providing their information aren't clearly communicated.
Federal Agencies: Improved data collection practices could foster better cooperation and compliance across federal and state lines, potentially leading to more seamless management of programs.
In conclusion, while the document serves an important procedural purpose, there are several areas where additional clarification would benefit potential respondents and stakeholders. Ensuring that the public understands the process and objectives of the information collection will be crucial in garnering meaningful participation and improving the administrative efficiency of the OSMRE.
Financial Assessment
In the Federal Register document titled "Agency Information Collection Activities; Maintenance of State Programs and Procedures for Substituting Federal Enforcement of State Programs and Withdrawing Approval of State Programs," there are specific references to financial aspects that warrant examination.
Summary of Financial References
The document specifically mentions that the total estimated annual nonhour burden cost is $0. This statement indicates that, apart from the time required for respondents to fulfill the information collection requirements, there are no additional monetary costs expected to be incurred by the respondents as a result of this information collection activity. Such a reference underscores the financial simplicity of the process, emphasizing that individuals or state governments are not expected to spend any money beyond their time (which is accounted for separately in "burden hours").
Financial Implications and Related Issues
The absence of a nonhour financial burden suggests that the agency aims to simplify compliance by not requiring respondents to incur any additional monetary expenses. While this may seem advantageous, it ties into one of the identified issues regarding the clarity of the benefits for the respondents, who are required to gather and submit this information. The document mentions that responses are "required to obtain or retain a benefit," yet it does not provide details on what this benefit is. The lack of financial cost could potentially indicate minimal or intangible benefits, which may not justify the significant time investment estimated for completing the required response.
Additionally, the document estimates a wide range of completion times per response, from 20 to 120 hours. This substantial variance in time commitment can reflect inconsistencies or a lack of clarity in the requirements, potentially leading to variable costs in terms of labor or absorbed personnel time within the responding entities, despite the stated zero-dollar financial cost. It also suggests that more complex or comprehensive responses may require significantly more time and resources, raising questions about the fairness and feasibility of such demands on different respondents.
In summary, while the document makes it clear that no direct nonhour costs are expected, the wide variation in the time required reflects potential underlying challenges and indirect costs for respondents. Understanding how the zero-dollar burden aligns with the expected tangible or intangible benefits is crucial, as it informs the perceived value and practicality of the information collection effort for stakeholders.
Issues
• The document does not specify what specific information is being collected, which might make it unclear for respondents to understand what is expected.
• The estimated completion time per response varies significantly from 20 to 120 hours, which could imply a lack of clarity or consistency in the requirements or the expected response.
• The total estimated number of annual respondents and responses is very low (1 each), which might raise questions about the significance of the information collection and whether it justifies the process under the Paperwork Reduction Act.
• The abstract mentions a regulation that allows any interested person to request an evaluation of a state program, but it does not clarify the criteria or procedure for such evaluations, potentially leading to ambiguity in implementation.
• The obligation to respond is listed as 'Required to obtain or retain a benefit,' but there is no detail on what this benefit is, making it unclear why respondents should comply.
• There is no mention of any actions or processes in place for handling requests to withhold personal information from public records, other than stating that withholding cannot be guaranteed.