FR 2025-01112

General Summary

The document in question is a notice from the Environmental Protection Agency (EPA) announcing a new information collection request related to their Construction Material Opportunities to Reduce Emissions (C-MORE) Program. This initiative aims to gather data about the use of construction materials with low embodied carbon, such as concrete and steel. The purpose of this data collection is to develop standards for labeling these materials based on their greenhouse gas emissions. The EPA calls for public comments until February 18, 2025, as part of the review and approval process overseen by the Office of Management and Budget (OMB).

Significant Issues and Concerns

Several aspects of the document merit attention. First, the estimated costs associated with this initiative are listed as $2,137624, a figure presented without a comma, making it harder to read at a glance. Notably, there's a lack of breakdown regarding how these costs are allocated, which obscures whether there is any potential wasteful spending.

The document employs technical language and acronyms such as "ICR" (Information Collection Request) and "OMB control number" without elaborating on their meanings, potentially alienating readers not versed in EPA jargon. Additionally, while the document mentions the objective of setting thresholds for labeling low carbon materials, it lacks practical examples or case studies to illustrate these efforts' real-world applications and benefits.

Public Impact

Broadly, the document signifies the EPA's ongoing commitment to reducing carbon emissions within the construction sector, an endeavor that could have substantial environmental benefits. By setting thresholds for low embodied carbon materials, the program potentially impacts public awareness and industry standards regarding sustainable construction practices. However, without clear communication and contextual framing, the public might find it challenging to grasp the immediate relevance or long-term benefits of the program.

Impact on Specific Stakeholders

The proposed initiative is poised to impact several stakeholders, including state and local government agencies, architectural and engineering firms, and entities involved in salvage and reuse operations. For these stakeholders, the program might provide opportunities to contribute to sustainable practices, possibly offering them competitive advantages or positioning them as leaders in environmental responsibility.

Conversely, some entities may perceive the data collection as an additional administrative burden, particularly if they lack an understanding of how the data will be used to shape industry practices. Ensuring that stakeholders understand the rationale behind data requests and the potential positive outcomes could mitigate any perceived negativity and foster greater collaboration.

The document in question provides information about the Environmental Protection Agency's (EPA) new information collection request (ICR) related to the Label Program for Low Embodied Carbon Construction Materials. This commentary will focus exclusively on the financial references within the document.

Financial Summary

The document outlines the total estimated costs associated with this information collection request. The annual estimated cost is stated as $2,137,624. Notably, this figure includes $0 for annualized capital investment or maintenance and operational costs. This implies that all the costs are likely operational or related to the process of data collection and analysis itself, without any additional expenses for new equipment or infrastructure.

Issues Related to Financial References

1. Formatting for Readability: One issue identified is the presentation of the total estimated cost figure: $2,137624. For readability and common formatting standards, a comma should separate groups of three digits, i.e., $2,137,624.

2. Lack of Cost Breakdown: The document does not provide a detailed breakdown of how the $2,137,624 is allocated. Without this information, it is challenging to assess whether there is any potential waste in budget allocation. A more detailed explanation of how funds will be spent, such as specifying amounts for personnel, data analysis, and administrative costs, could provide greater transparency and understanding of budget efficiency.

General Observations

While the document specifies the total cost associated with the program, the omission of a detailed budget breakdown makes it difficult for the public to fully understand the financial implications or evaluate the possibility of cost savings. This information could be crucial for stakeholders interested in the economic impact of the EPA's initiatives. Providing such details would not only enhance understanding but also increase the public's trust in how government resources are being utilized for environmental programs.

Further, simplifying complex financial language or providing clearer definitions of key terms could improve the document's accessibility to a broader audience.