FR 2025-03262

The recent notice from the Environmental Protection Agency (EPA) extends the public comment period for the National Emission Standards for Hazardous Air Pollutants (NESHAP) relevant to leather finishing operations. This rule primarily affects facilities identified as major sources of hazardous air pollutants. Originally, there was a 60-day period allocated for public comments, starting in May 2023, but now an additional 30 days have been granted. The aim is to ensure these leather finishing facilities adhere to specific environmental regulations set forth by the EPA.

Summary of the Document

This notice primarily concerns the EPA's submission of an Information Collection Request (ICR) to the Office of Management and Budget (OMB) for review. The EPA is extending the timeline for public comments on regulations overseeing hazardous air pollutants related to leather finishing operations. This ICR ensures that these operations follow the regulations outlined in 40 CFR part 63, subpart TTTT. The document points out that this extension doesn't change the estimated respondent burden in terms of time or financial costs.

Significant Issues and Concerns

One key issue is the complexity and density of the document's content, which might be overwhelming to general audiences. The inclusion of several detailed instructions for comment submission, while necessary, could benefit from simplification or the highlighting of key points to improve clarity.

The reference to specific regulatory codes, such as "40 CFR part 63, subpart TTTT," may be challenging for those without familiarity with legal or environmental regulations. Including a brief explanation or context for these references could aid in understanding.

An important point that might be unclear to some readers is the mandatory nature of the respondent's obligation. The document specifies that compliance is required yet does not detail the implications or potential penalties for non-compliance, which could be pertinent information for stakeholders.

Furthermore, the mention of an estimated burden of 138 hours and cost of $17,400 per year for only four respondents might raise questions about the efficiency and necessity of the data collection, highlighting potential concerns about resource allocation.

Impact on the Public

Broadly speaking, this notice allows the public more time to engage and respond to national environmental standards concerning air pollutants, which can impact community health and environmental quality. Additional public input might contribute to more comprehensive regulatory measures that mitigate potential environmental hazards.

Impact on Specific Stakeholders

For leather finishing operations, this regulatory oversight ensures adherence to structured standards, potentially leading to changes in operational practices to meet compliance obligations. This could mean undertaking measures to reduce emissions, which might initially raise operational costs but ultimately improve environmental sustainability and public health.

At the same time, stakeholders in the leather industry might feel the financial and administrative burdens more acutely, particularly smaller businesses, due to the mandatory compliance and associated costs. On the other side, environmental advocacy groups might view the notice positively, as it represents continued efforts to hold industries accountable for environmental impacts.

In summary, while the extended comment period and regulations may impose additional requirements on industry stakeholders, they also reflect ongoing efforts to ensure environmental protection and public health through detailed and structured regulatory oversight.

The document discusses an information collection request (ICR) related to the National Emission Standards for Hazardous Air Pollutants (NESHAP) focusing on leather finishing operations. This commentary centers exclusively on the monetary aspects outlined in the document.

Summary of Financial Allocation

The document specifies that the total estimated cost associated with this ICR is $17,400 per year. This total cost encompasses necessary activities for compliance but does not include any annualized capital or operation and maintenance costs, which are both listed as $0. This suggests that the expenditure is mainly allocated to administrative or procedural requirements involved in adhering to the standards set forth by the EPA.

Relation to Identified Issues

The financial reference highlights a significant expense attributed to only four respondents, equating to a sizeable amount of $4,350 per respondent per year. Although the document is transparent regarding costs, such a financial burden might seem high relative to the small number of affected entities. This cost allocation prompts queries regarding the efficiency or necessity of the ICR process, especially given the low industry growth rate noted in the document. This could suggest inefficiencies that might be streamlined to reduce costs per respondent.

Additionally, the requirement of 138 hours per year for compliance might raise questions about whether the output or environmental benefit justifies the financial and time expenditures, especially in the context of minimal industry changes or growth. The document lacks a clear narrative connecting these financial obligations to tangible benefits, which could cause stakeholders to question the cost-benefit balance of the regulation.

In essence, while the financial aspects are transparently stated, they raise important considerations about the efficiency and necessity of the regulatory processes involved, given the limited scale of affected entities.