Overview
Title
Agency Information Collection Activities; Proposed Information Collection Request; Comment Request; Application for Preauthorization of a CERCLA Response Action and Claim for CERCLA Response Action
Agencies
ELI5 AI
The EPA wants to make sure that people who help clean up dangerous messes can fill out forms to ask for money to pay for their work. They want to check if these forms can be made better and want everyone to share their thoughts about it. It only affects a tiny number of people each year (just two).
Summary AI
The Environmental Protection Agency (EPA) is planning to submit a request to the Office of Management and Budget (OMB) to approve the reinstatement of two forms related to CERCLA (a federal environmental program). These forms are needed when someone wants to take action to clean up hazardous substances and then claim reimbursement from a special fund. The EPA is asking for public comments on this proposal before they submit it to the OMB. The total estimated cost of responding to this action is about $11,828.67 per year, and it would affect approximately two respondents annually.
Abstract
The Environmental Protection Agency (EPA) is planning to submit the reinstatement of the information collection request (ICR), (1) Application for Preauthorization of a CERCLA Response Action and (2) Claim for CERCLA Response Action (EPA ICR Number 12512-01-OLEM, OMB Control Number 2050-0106) to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act. Before doing so, EPA is soliciting public comments on specific aspects of the proposed information collection as described below. This is a proposed extension of the ICR, which was approved through April 30, 2001. This notice allows 60 days for public comments.
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AnalysisAI
The Environmental Protection Agency (EPA) has issued a notice in the Federal Register about its intention to submit a request for the reinstatement of certain information collection forms related to the Comprehensive Environmental Response, Compensation, and Liability Act, known as CERCLA. These forms are key for parties who want to take action to clean up hazardous waste sites and seek reimbursement from a federally managed fund. Before submitting this request to the Office of Management and Budget (OMB) for approval, the EPA is seeking public comments on various details of this proposal. The deadline for public comments is April 29, 2025.
Summary of the Document
The document details the process by which individuals or entities can apply for preauthorization to undertake remedial actions under CERCLA and subsequently claim reimbursements. The importance of this process is underlined by CERCLA's role in managing hazardous waste sites and protecting public health and the environment. The forms involved—Application for Preauthorization and Claim for CERCLA Response Action—have been in need of reinstatement and update since their previous approval expired in 2001. The EPA estimates a rather modest annual burden, both in terms of hours and financial cost, with only two respondents expected each year.
Significant Issues and Concerns
One notable issue stemming from this document is the lack of detailed explanation regarding changes in the respondent burden compared with prior assessments. While technological advancements and a decrease in the number of requests are generally cited reasons, more specific information could enhance public understanding. Furthermore, the significantly low number of respondents raises questions about the cost-effectiveness of the process and whether there are alternative approaches that could achieve the same regulatory purposes more efficiently.
Additionally, the document uses regulatory jargon and acronyms such as "CERCLA," "ICR," "PRA," and "OMB Control Number," which might be unfamiliar to those new to or outside environmental regulatory circles. Clarification or simplification of these terms would make the document more accessible to a broader audience.
Potential Impact on the Public
The potential impact on the general public appears relatively minimal, given the low number of estimated respondents. However, individuals living near hazardous waste sites might find indirect impacts more significant if the reinstatement and subsequent approvals streamline cleanup activities. The process ensures that the parties responsible for pollution can efficiently contribute to remediation efforts, thereby safeguarding public health and environmental quality.
Impact on Specific Stakeholders
Specific stakeholders, particularly those involved in environmental remediation or who manage properties with potential hazardous waste issues, are likely to be directly affected. For these entities, access to a streamlined, officially sanctioned reimbursement process could offer financial support to alleviate cleanup costs. Conversely, the discontinuation history of the ICR and the lack of clarity around capital costs require stakeholders to proceed carefully, ensuring informed decisions when engaging with this process.
Overall, while the EPA's proposal offers a pathway for addressing hazardous waste cleanup, further clarity and stakeholder engagement could bolster its effectiveness and public acceptance.
Financial Assessment
The document in question discusses the Environmental Protection Agency's (EPA) intention to seek approval from the Office of Management and Budget (OMB) for reinstating an information collection request (ICR). This ICR pertains specifically to applications for preauthorization and claims associated with CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) response actions. Within this context, several financial aspects are highlighted.
Financial Overview
The document provides a detailed breakdown of the total estimated cost associated with the ICR. Annually, the cost is estimated to be $11,828.67. This figure incorporates the costs of submissions related to the ICR, with no additional annualized capital or operational and maintenance costs. The absence of these additional costs is particularly notable and may warrant further scrutiny to ensure hidden costs are not overlooked.
Cost Breakdown
The total estimated cost includes two primary components: 1. The submission of one pre-authorization form, which is expected to cost $8,081.70. 2. The submission of one claim reimbursement form, estimated at $3,746.97.
These figures indicate that the bulk of the expense stems from the pre-authorization form process.
Relation to Identified Issues
One issue highlighted was the change in the total estimated respondent burden compared to prior ICR approvals, potentially due to advancements in technology and a reduction in demand. The lower number of anticipated respondents (merely two annually) suggests that while costs per response remain specific, the overall volume of requests has decreased significantly. This reduced demand aligns with the principle that fewer entities have requested this authority over recent years, thus impacting both the financial estimates and the need for an ICR.
Moreover, the document notes that the usage of internet and computer-based tools has lowered the time needed to compile the necessary information, which could imply decreased costs in terms of time and labor. However, it remains imperative that the absence of capital or operational maintenance costs does not neglect potential minor expenses that can accrue, even with digital efficiencies.
Consideration of these financial elements in light of the document’s issues reveals the broader context of technological advancements and reduced engagement, which have accordingly influenced the financial allocations for the ICR process. Despite the detailed financial allocation described, the underlying rationales for past discontinuations or the need for current reinstatements remain less clear and need to be communicated thoroughly for comprehensive understanding.
Issues
• The document mentions a change in the total estimated respondent burden compared with the ICR previously approved by OMB, but does not provide specific details on what the changes are or why they're occurring, beyond technological improvements and fewer entities requesting the authority.
• The estimated number of respondents is very low (only two annually), which might warrant further investigation into the need for the ICR or whether there is a more efficient way to handle such a low volume of requests.
• The complexity and specificity of certain terms like 'CERCLA', 'ICR', 'PRA', and 'OMB Control Number' without clear explanations might render the document difficult to understand for individuals not already familiar with these regulatory terms.
• The abstract refers to the ICR as being proposed for reinstatement, suggesting it was previously discontinued, but it does not clarify why it was discontinued or what changes have been made to warrant reinstatement.
• The document indicates no annualized capital or operation & maintenance costs, which should be evaluated to ensure accuracy and inclusiveness of potential hidden costs.