Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; NESHAP for Marine Tank Vessel Loading Operations (Renewal)
Agencies
ELI5 AI
The Environmental Protection Agency (EPA) wants to keep checking how much pollution big ships make when loading stuff like oil or gas. They are asking people to share their thoughts on this for a little longer, and they promise it won't cost anyone extra money or time.
Summary AI
The Environmental Protection Agency (EPA) is seeking an extension for an information collection request related to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for marine tank vessel loading operations. These standards apply to facilities loading vessels with petroleum or gasoline that exceed specific hazardous air pollutant emissions thresholds. The public has an additional 30 days to comment on this proposed extension, which requires affected entities to respond initially, semiannually, and annually. There are no changes to the estimated burdens or costs as compared to previous assessments since regulations and industry growth have remained stable.
Abstract
The Environmental Protection Agency (EPA) has submitted an information collection request (ICR), NESHAP for Marine Tank Vessel Loading Operations (EPA ICR Number 1679.12, OMB Control Number 2060- 0289) 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 February 28, 2025. 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.
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Sources
AnalysisAI
The Environmental Protection Agency (EPA) has issued a notice to extend an information collection request related to the National Emission Standards for Hazardous Air Pollutants (NESHAP) associated with marine tank vessel loading operations. This extension has been submitted for review and approval by the Office of Management and Budget in line with regulatory requirements. The standards primarily target marine facilities that handle petroleum or gasoline and discharge hazardous air pollutants at or above certain thresholds.
General Summary
The document outlines EPA's efforts to continue gathering information on hazardous emissions from marine tank vessel operations. Facilities involved in loading petroleum or gasoline into marine vessels are required to follow these standards if they release substantial quantities of emissions. The agency has previously solicited public opinion over a 60-day period and is now extending that opportunity by an additional 30 days, giving the public a chance to contribute further feedback. Respondents are expected to engage with this request regularly - initially, semiannually, and annually.
Significant Issues and Concerns
The notice appears to present some repetition, particularly in its abstract and supplementary sections, concerning the extension and previous public comments. This redundancy might confuse readers seeking clarity. Additionally, there is a mention of a total annual cost of $1,350,000 to maintain compliance; however, the document does not clearly explain how these costs are determined or broken down.
For respondents, the lack of form numbers might complicate their documentation submissions, leading to potential misunderstandings. Moreover, the introduction of terms like "reasonably available control technology (RACT)" without further explanation could leave stakeholders unclear about specific compliance requirements.
Impact on the Public
Broadly, this document offers the public insight into EPA's regulatory mechanisms designed to minimize hazardous emissions from marine loading operations. It serves as an opportunity for concerned individuals or organizations to voice their opinions, strengthening transparency and community involvement in environmental governance.
Impact on Specific Stakeholders
For marine terminal operators, this continuation of regulatory oversight maintains a stable compliance landscape since the regulations are not changing. However, they are required to evaluate their operations continuously and potentially allocate resources to adhere to these standards. This could be financially burdensome, particularly with no explicit mention of changes in estimated costs or burdens, reinforcing the need for precise operation planning.
In contrast, communities near marine terminals might view the EPA’s strict regulations as beneficial, as they aim to reduce harmful emissions and improve air quality in their vicinity. Nevertheless, stakeholders from these communities may want to see detailed outcomes of past public consultations to understand better how their feedback influences regulatory practices.
Overall, while the document seeks to further environmental protection objectives, it would benefit from greater clarity in justifying its financial and compliance expectations. This would not only reassure stakeholders but also bolster the transparency and utility of public involvement.
Financial Assessment
The document centers around the Environmental Protection Agency (EPA) seeking to extend an information collection request regarding the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Marine Tank Vessel Loading Operations. In the context of this notice, financial references primarily revolve around the total estimated cost of $1,350,000 per year.
Financial Summary
The document specifies that the total estimated cost of $1,350,000 represents the annual burden associated with compliance and information collection for 804 respondents involved in marine tank vessel loading operations. This cost covers the entire process of fulfilling the mandated reporting and compliance requirements as dictated by the NESHAP regulation, which aims to control hazardous air pollutants in marine terminal facilities.
Relation to Identified Issues
One issue identified is the lack of detailed justification for the estimated $1,350,000 annual cost. The document mentions that this cost is linked to the compliance burden, which is defined in terms of hours spent fulfilling the regulation's requirements. However, the document does not break down how this total cost is derived or how it is distributed among the respondents. This lack of transparency may make it difficult for stakeholders to understand how financial resources are being allocated specifically for compliance activities.
Furthermore, while the document mentions that there are no changes to the regulatory framework or industry growth, it does not provide data to validate the claim that the burden and associated costs remain unchanged. This lack of supporting financial analysis could lead to questions about the rationale behind maintaining the same financial estimate.
Conclusion
In summary, the primary financial reference in the document is the $1,350,000 annual cost associated with the ICR for NESHAP compliance. However, the document could benefit from additional clarity and transparency regarding how this cost figure is derived and justified, especially in light of unchanged regulatory and industry conditions. Providing such detailed financial insights would enhance the document's clarity and support the rationale for the current estimates.
Issues
• The document's abstract and supplementary information sections are repetitive, both mentioning the extension of the ICR and previous requests for public comments, which could be streamlined for clarity.
• The text provides no detailed justification for the estimated $1,350,000 annual cost, which could be seen as lacking transparency in terms of spending.
• There are no form numbers mentioned, potentially causing confusion for respondents regarding documentation requirements.
• The term 'reasonably available control technology (RACT)' is not defined within the document, potentially leading to ambiguity about compliance requirements.
• The document states that there is no change in burden since the regulations have not changed and the industry's growth is low, yet it does not provide detailed data or analysis to justify this claim.
• Although the document allows for additional public comments, it does not explain the outcomes or changes resulting from the previous 60-day comment period, which might lead to concerns about the effectiveness or consideration of public feedback.