FR 2025-03337

The document from the Environmental Protection Agency (EPA) submitted to the Office of Management and Budget (OMB) pertains to the Cross-Media Electronic Reporting Rule (CROMERR). This regulation facilitates electronic reporting across all EPA programs to align with the Government Paperwork Elimination Act. Although initially open for public commentary for 60 days earlier, an additional 30-day extension for public comments has been provided, which will conclude by March 31, 2025. The proposed extension estimates an annual implementation cost of $4,614,717 and a total burden of 65,319 hours annually.

General Summary

The document outlines the EPA's formal request to the OMB for continued authorization to collect information under the CROMERR. This rule underscores the importance of a unified electronic reporting system to streamline compliance for organizations interacting with different EPA programs. The document details the estimated costs and stipulated burdens associated with this information collection request (ICR), showing a notable reduction in the time burden on respondents compared to prior estimates.

Significant Issues and Concerns

Despite the apparent efforts to reduce administrative burdens, several issues within the document may pose challenges for a broader audience. Technical Jargon: The document relies heavily on specialized terminology and references to the regulatory framework, which might not be easily understood by the public. Explaining Changes in Burden: The reduction in the estimated burden, primarily due to fewer reporters needed to register electronically, isn't clearly described in layman's terms, leaving those affected by these changes potentially confused. Transparency and Public Input: There's a lack of clarity on how public comments will influence the final decision-making process, which can raise questions about the effectiveness of public engagement. Protection of Confidential Information: Although the document mentions protecting Confidential Business Information (CBI), it lacks specific details on how this is achieved, which may concern businesses and other entities.

Impact on the General Public

Broadly speaking, the shift towards electronic reporting promises greater efficiency in managing regulatory compliance, potentially reducing processing times and errors associated with managing paper documents. This progress aligns with general advances in governmental digital transformations, intending to offer more streamlined public services.

Impact on Specific Stakeholders

For businesses and local governments required to interact with EPA programs, this rule's extension might present both challenges and opportunities. The decrease in the expected time burden can reduce compliance costs, reflecting positively on entities with limited resources. However, the need to adapt to technological changes could initially pose logistical and financial challenges.

For regulatory bodies and the EPA, the document underscores an administrative commitment to harmonizing electronic reporting standards, which may lead to improved data management and regulatory oversight. Nonetheless, these bodies must also ensure robust mechanisms are in place to protect sensitive information, as indicated by the referenced confidentiality regulations and privacy act requirements.

In conclusion, while the move towards electronic processes under CROMERR offers potential advantages, clarity and transparency regarding process specifics and public engagement remain critical to maximizing benefits and minimizing obstacles for all stakeholders involved.

The document discusses the Environmental Protection Agency’s (EPA) extension of an information collection request related to the Cross-Media Electronic Reporting Rule. The financial aspects of this extension are critical to understanding the implications for stakeholders, including those who report electronically to the EPA and related state or local government programs.

Summary of Financial References

The document states that the total estimated cost associated with this information collection is $4,614,717 per year. Within this total, $1,283,547 is allocated annually for various capital or operation and maintenance costs. These figures are essential for stakeholders, as they depict the financial burden of complying with the reporting requirements.

Relation to Identified Issues

1. Clarification on Financial Burden: There's an acknowledgment within the document that the financial burden has shifted. Specifically, there is a decrease in respondent burden by 81,985 hours, which could potentially affect the total estimated cost. The document does not, however, clearly explain how this decrease in hours translates into a change in financial burden for the respondents or if it directly impacts the $4,614,717 figure.

2. Cost Calculation Transparency: The document lacks a detailed account of how the total estimated cost and associated capital or operation & maintenance costs were calculated per respondent. This could impact stakeholders' understanding and acceptance of the financial implications. Transparent calculations or at least a summary would provide better insight into the financial expectations from parties involved.

3. Protected Confidentiality and Cost Impacts: While there are references to protecting Confidential Business Information (CBI) and compliance with the Privacy Act of 1974, it is unclear how the costs associated with these protections are factored into the $1,283,547 allocated for maintenance. Understanding this relationship might clarify whether additional hidden costs exist for ensuring data protection under the reporting requirements.

Overall, while the total and annual maintenance costs are explicitly mentioned, further breakdown and transparency on these financial references could help all stakeholders understand the precise financial implications of complying with the EPA's information collection request. Improving clarity on these points would aid in addressing some of the document's noted issues, especially those concerning the complexity and burden of regulatory compliance costs.