FR 2025-03219

The Environmental Protection Agency (EPA) has put forward a request for an extension of an information collection requirement. This is specifically aimed at brick and structural clay product manufacturing facilities. The goal is to ensure continued compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP). The proposed extension of the information collection request (ICR) covers a wide range of activities and is currently approved through February 2025. The public has been invited to submit comments on this matter until March 31, 2025.

General Summary

The document outlines EPA's intention to extend an existing ICR related to air pollutant standards in manufacturing processes. Initially prompted by regulations published under NESHAP, the document details the collection of compliance data from manufacturers. This is a continuation of efforts to monitor and control hazardous emissions from brick and structural clay product manufacturers to protect environmental and public health.

Significant Issues and Concerns

Several issues emerge within the document:

1. Increased Burden: The EPA acknowledges a notable increase in the total estimated respondent burden, jumping by 12,410 hours. This raises concerns about the efficiency of processes and the potential impact on businesses, particularly smaller firms that might struggle with the increased workload and associated costs.

2. Complexity in Explanation: The explanation provided about the increase in the estimated burden and cost is complex and detailed. It may prove challenging for stakeholders to fully grasp, particularly for those not familiar with regulatory language or the specific technical requirements of NESHAP.

3. Repetition and Clarity: The document repeats information about the ICR extension multiple times, which could be condensed for better clarity. A streamlined version might be easier for public stakeholders to understand and engage with.

4. Number of Respondents: While there is a decrease in the number of respondents from 69 to 57, the document does not clearly explain the reason for this change. This absence of detail might lead to questions about whether some facilities are no longer covered or if compliance has shifted significantly.

5. Complex Technical Language: The document is laden with technical and legal jargon. This could present a barrier to meaningful public involvement, as individuals without specialized knowledge may find it difficult to engage fully with the content or submit informed comments.

Impact on the Public and Stakeholders

Public Impact

For the general public, the extension of the ICR mainly reflects ongoing efforts to protect air quality by regulating emissions from specific manufacturing processes. Clean air standards are important for public health, and continued oversight can contribute to a healthier environment. However, the indirect impacts, especially concerning increased costs of product manufacturing, might affect consumer prices over time.

Stakeholder Impact

Manufacturers within the brick and structural clay product sector are most directly impacted by this EPA initiative. The increased burden in reporting and compliance could pose financial and administrative challenges. This might disproportionately affect smaller businesses with fewer resources to handle additional administrative duties. On the positive side, compliance helps ensure that these manufacturers are reducing their environmental impact, potentially improving their reputation and long-term viability.

Overall, while the document seeks to uphold important environmental standards, the challenges it could pose to manufacturers, especially regarding increased costs and administrative burdens, highlight the importance of balancing regulatory requirements with practical implications on stakeholders.

The document outlines a submission by the Environmental Protection Agency (EPA) to the Office of Management and Budget (OMB) regarding the renewal of an Information Collection Request (ICR) for the National Emission Standards for Hazardous Air Pollutants (NESHAP) related to Brick and Structural Clay Products Manufacturing. In the context of financial references, the document provides a detailed look into both the estimated costs associated with this program as well as changes in financial obligations over time.

Summary of Financial Implications

The total estimated cost for the respondents involved in this ICR is set at $4,880,000 per year. This figure includes $673,000 designated for annualized capital or operation and maintenance costs. These financial allocations highlight the ongoing expenses that facilities engaged in the manufacturing of bricks and structural clay products face to comply with the EPA's regulatory requirements.

Relation to Identified Issues

One significant issue identified within the document is the increase in the estimated respondent burden. This increased burden—totaling an additional 12,410 hours—could naturally lead to higher costs. The document specifies that the current costs are an ongoing reflection of compliance requirements, distinguishing between the initial compliance phase and continuing obligations. This progression from initial to ongoing compliance usually entails a broader scope of activities or upgraded operations, hinting at why expenses have risen.

Furthermore, the estimated cost increase may raise concerns about the impact on small businesses within the brick and structural clay industry. Higher operational costs, including compliance expenses, can present challenges to smaller entities that might have fewer resources compared to larger corporations. These financial pressures may complicate their ability to adjust to new regulations or sustain profitability.

Complexity and Clarity in Presentation

The document attempts to justify the new estimates, but the explanation is dense and might be perplexing for those not versed in regulatory or financial jargon. While the document mentions a reduction in the number of respondents from 69 to 57, it does not clearly explain the financial rationale behind this decrease. Such a lack of clarity could lead to uncertainty regarding how the financial assessments were derived and why fewer respondents still result in a higher total cost.

In conclusion, the financial references in this document underscore a notable increase in estimated costs associated with compliance efforts for the brick and structural clay products manufacturing sector. This amplifies concerns surrounding operational burdens, particularly affecting small businesses. Moreover, the presentation of financial and operational data would benefit from simplification to better assist stakeholders and the general public in understanding and responding to the proposed ICR extension.