Data becomes available more quickly. The process of creating, mailing, receiving, entering, verifying, and correcting paper reports consumes both resources and time. This delays the ability of EPA to analyze data and make it available to the public.

  More Enforcement Certainty . The purpose of CROMERR is primarily to ensure that as State, Tribal or local governments implement electronic reporting for the EPA authorized or delegated programs they administer, the electronic documents that receive are as legally dependable as their paper counterparts, especially for purposes of providing evidence in the context of legal proceedings of who attested by signature to the truth and accuracy of what data. The requirements set by CROMERR are specifically designed to provide for this legal dependability, and they will do so by providing:

  standards for valid electronic signatures and authentic electronic documents   to be admitted as evidence in a judicial proceeding, electronic signatures and documents may need to be shown to satisfy standards of validity and authenticity. Absent clearly identifiable standards, it may be difficult to environmental litigators to make such a showing. CROMERR will provide such standards.

  assurance that electronic documents can be authenticated   to provide evidence of what an individual submitted and/ or attested to, there must be clear and straightforward methods of showing that the electronic document an environmental agency received is in fact what the individual submitted. CROMERR requirements for electronic document receiving systems will ensure that these systems receive and maintain electronic documents so as to ensure that such authentication methods are available.   assurance that electronic signatures resist repudiation by the signatory   in at least some enforcement proceedings, a critical issue is whether a particular individual is responsible for the content of a submitted document, and the issue turns on whether that individual was the signatory of the certification statement. If the individual in question is able to repudiate his or her electronic signature   that is, successfully deny that it was his or hers  then the enforcement case may collapse. CROMERR requirements for electronic signatures, and for the identity proofing needed to issue a signature device or credential, are designed to ensure that signatories are not able to repudiate signatures that they create, that is, that there is sufficient evidence to show when an individual has created a signature.

By providing for these and other facets of an electronic document's legal dependability, CROMERR provides certainty that EPA and its authorized or delegated programs can continue 41 to ensure compliance with environmental laws and statutes by being able to hold individuals responsible for being truthful when they report on their companies' compliance status. By the same token, CROMERR also provides certainty that when EPA or its authorized or delegated programs discover actionable cases of false or fraudulent reporting that they will have the documentary evidence they need to bring such cases into court.

6.0 Limitations of the Analysis The following paragraphs describe the model's primary limitations.

  Information Collections under the National Emissions Standards for Hazardous Air Pollutants ( NESHAPS). The model examines only one information collection under NESHAPS, ( i. e., the NESHAPS collection on radionuclides). EPA intends to use this collection as a model for incorporating additional NESHAPS collections into the CDX over the coming years. At present, however, the inclusion of these additional collections into the CDX is in a state of flux, and therefore, they have not been examined in the model. It is important to note, however, that insofar as additional NESHAPS collections are incorporated into the CDX during the modeling period, the model's results do not reflect their associated costs or benefits.

  Annual Implementation Rate. The costs presented in Sections 2.0 and 3.0 reflect an annual implementation rate for electronic reporting of 30 percent of facilities during the first year of an information collection's automation start date. The annual implementation rate is assumed to be 10 percent per annum for the rest of the modeling years. EPA notes that these rates are a simplifying assumption, since they likely will vary greater depending on many factors. Because of this, EPA has performed sensitivity runs based on different implementation rates.

  " Baseline" Automation Start Dates. EPA believes that, under " Baseline", EPA would generally be less expedient in promulgating rules that would allow for automation. The model assumes that, in comparison to the automation start dates under " To Be", information collections under " Baseline" would be delayed by 2 years. For example, the model assumes that, under " To Be", the OSWER's Notification Form would be automated in 2003. As such, the model assumes that it would be automated in 2005 under " Baseline". EPA notes, however, that its assumption of a 2 year delay is speculative. In terms of the regulatory impact analysis, changes in our assumptions about the " Baseline" ( or " As Is") automation start date would affect the outcome as follows, based on Appendix XII Tables XII 5 and XII 8 and assuming that the period of analysis remained 2004  2012, . If we moved the assumed start date forward two years, to 2004, then the " Baseline" costs to facilities would decrease by approximately $ 56 million, while the Baseline costs to states would increase by approximately $ 16 million, yielding a net " Baseline" cost decrease of approximately $ 40 million. If we moved the assumed start date back two years, to 2008, then the " Baseline" costs for facilities would increase by approximately $ 30 million, while the " Baseline" costs to states would decrease by approximately $ 16 million, yielding a net " Baseline" cost increase of approximately $ 14 million. In general then, it appears that moving the assumed Baseline automation start date forward lowers the net Baseline costs to the benefit of facilities but not states, while moving the assumed date back raises the net Baseline costs to the detriment of facilities but not states.

  Scaling Factors. The model examines the cost impacts associated with direct reporters in submitting paper and electronic reports to EPA under " Baseline" and " To Be". As explained 42 in Appendix IV, EPA reviewed each information collection, extracted the hour burden, and attempted to determine the percent of hours associated only with direct reporters. To do so, EPA developed " scaling factors" based on state authorization assumptions. The scaling factors were then applied to the hour burden of each collection, as described in Appendix VII.

EPA notes, however, that these scaling factors are based on the highly simplified assumption that authorized states collect all the information under their programs. This is not necessarily the case, e. g., where states are authorized for only portions of an EPA program, or where EPA shares program administration with states.

  Upgrade Costs. In estimating upgrade costs to State/ Locals, EPA examined the state summary table ( Table V 7, State Overview) in Appendix V. EPA attempted to identify State/ Locals receiving systems that would not satisfy CROMERR standards ( e. g., copy of record requirements). Although EPA believes its estimates are reasonable, it notes that they are highly speculative, since State/ Locals specific factors ( e. g., enforcement priorities, state resources, etc.) will determine the State/ Locals' need for upgrading its systems. 43 Appendix I. Information Collections To Be Automated by EPA Table I 1. Information Collections To Be Automated*

Office Name ICR Title ICR Number Automation Date OAR EPA Indoor Environmental Quality, Occupant Questionnaire 1619.03 9/ 30/ 99 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 1/ 2000 OEI Toxic Chemical Release Reporting, Recordkeeping, Supplier Notification and Petitions 1363.11 9/ 1/ 2000 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2000 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2000 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2000 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/ 30/ 2000 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/ 30/ 2000 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/ 30/ 2000 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/ 30/ 2000 OW Clean Water Needs Survey 318.09 12/ 31/ 2000 OPPTS TSCA Section 12( b) Notification of Chemical Exports 795.10 9/ 30/ 2001 OPPTS Partial Updating of TSCA Inventory Data Base; Production and Site Reports 1011.05 9/ 30/ 2001 OA Amendment to Regulatory Reinvention Pilot Projects ( Project XL) ICR; New York State 1755.06 10/ 30/ 2001 OGC National Roster of Environmental Dispute Resolution and Consensus Building 1888.01 10/ 30/ 2001 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 5/ 1/ 2002 OPPTS Voluntary Cover Sheet for TSCA Submissions 1780.02 9/ 1/ 2002 44 Office Name ICR Title ICR Number Automation Date OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2002 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2002 OW Questionnaire for Operations and Maintenance, Biosolids Use, Combined Sewer Over 1287.06 9/ 30/ 2002 OW CWA State Revolving Fund Program 1391.06 9/ 30/ 2002 OW National Water Quality Inventory Reports ( TMDL Final Rule: Clean Water Act Section 1560.06 9/ 30/ 2002 OW Drinking Water State Revolving Fund Program ( DWSRF) 1803.03 9/ 30/ 2002 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 10/ 30/ 2002 OAR NESHAPS: Radionuclides 1100.11 12/ 31/ 2002 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2003 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2003 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2003 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2003 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2003 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2003 OARM General Administrative Requirements for Assistance Programs 938.08 9/ 30/ 2003 OW Water Alliances for Voluntary Efficiency ( WAVE) Program 1654.03 9/ 30/ 2003 OAR IAQ Practices in Large Buildings Survey 1917.01 9/ 30/ 2003 OW National Program to Regulate Nondomestic Discharges to Municipal Sanitary Sewer 2.09 10/ 31/ 2003 OAR Importation Requirements for Importation of 10.09 10/ 31/ 2003 45 Office Name ICR Title ICR Number Automation Date Nonconforming Vehicles OAR Motor Vehicle and Non Road Engine Exclusion Determination 12.11 10/ 31/ 2003 OW Modification of Secondary Treatment Requirements for Discharges into Marine Water 138.06 10/ 31/ 2003 OAR Investigations into Possible Noncompliance of Motor Vehicle with Federal Emission 222.05 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2003 OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/ 31/ 2003 OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2003 OW NPDES DMR ICR 229.15 10/ 31/ 2003 OSWER Notification of Regulated Waste Activity 261.13 10/ 31/ 2003 OSWER RCRA Hazardous Waste Permit Application and Modification, Part A 262.09 10/ 31/ 2003 OW Revision to the Existing Variance and Exemptions Rule to Comply with the Safe Dr 270.41 10/ 31/ 2003 46 Office Name ICR Title ICR Number Automation Date OAR Emission Defect Information and Voluntary Emission Recall Reports 282.12 10/ 31/ 2003 OAR Registration of Fuels and Fuel Additives 309.10 10/ 31/ 2003 OAR Registration of Fuels and Fuel Additives 309.10 10/ 31/ 2003 OAR Registration of Fuels and Fuel Additives 309.10 10/ 31/ 2003 OAR Registration of Fuels and Fuel Additives: Requirements for Manufacturers 309.10 10/ 31/ 2003 OAR Registration of Fuels and Fuel Additives 309.10 10/ 31/ 2003 OAR Registration of Fuels and Fuel Additives 309.10 10/ 31/ 2003 OAR Registration of Fuels and Fuel Additives 309.10 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 47 Office Name ICR Title ICR Number Automation Date OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2003 OSWER Requirements for Generators, Transporters and Disposers under the RCRA Hazardous 801.14 10/ 31/ 2003 OW Construction Grants Program 827.05 10/ 31/ 2003 OARM General Administrative Requirements for Assistance Programs 938.08 10/ 31/ 2003 OW Water Quality Standards Regulation 988.08 10/ 31/ 2003 OARM Oral and Written Purchase Orders 1037.06 10/ 31/ 2003 OARM IFBs and RFPs 1038.10 10/ 31/ 2003 OARM IFBs and RFPs 1038.10 10/ 31/ 2003 OARM Monthly Progress Reports ( EPA contracts office) 1039.09 10/ 31/ 2003 OSWER Application for Reimbursement to Local Governments for Emergency Response toHaz 1425.05 10/ 31/ 2003 OSWER EPA Worker Protection Standard for Hazardous Waste Operations & Emergency Response 1426.05 10/ 31/ 2003 OAR Recordkeeping and Periodic Reporting of the Production, Import, of Ozone Depletion 1432.21 10/ 31/ 2003 OAR Modifications to Standards and Requirements for Reformulated and Conventional Ga 1591.14 10/ 31/ 2003 OAR Modifications to Standards and Requirements for Reformulated and Conventional Ga 1591.14 10/ 31/ 2003 48 Office Name ICR Title ICR Number Automation Date OAR Servicing of Motor Vehicle Air Conditioners 1617.03 10/ 31/ 2003 OAR National Recycling and Emissions Reduction Program 1626.07 10/ 31/ 2003 OAR Compression Ignition Non Road Engine Certification Application 1684.05 10/ 31/ 2003 OAR Certification and Averaging, Banking, and Trading for Nonroad Spark Ignition Eng 1695.07 10/ 31/ 2003 OAR Fuels and Fuel Additives Registration Regulations: Health Effects Protocols ( 40C 1696.03 10/ 31/ 2003 OSWER Reporting and Recording Requirements under EPA's Wastewise Program 1698.04 10/ 31/ 2003 OAR Retrofit/ Rebuild Requirements for 1993 and Earlier Model Year Urban Buses 1702.03 10/ 31/ 2003 OAR Spark Ignition Marine Engine Application for Emission Certification and Participation 1722.03 10/ 31/ 2003 OAR Marine Engine Manufacturers Production Line Testing Reporting and Recordkeeping 1725.03 10/ 31/ 2003 OAR Marine Engine Manufacturer In Use Emission Testing Program and Recordkeeping Req 1726.03 10/ 31/ 2003 OAR Information Requirements for Locomotives and Locomotive Engines 1800.02 10/ 31/ 2003 OW National Health Protection Survey of Beaches 1814.02 10/ 31/ 2003 OW Phase II of the NPDES Stormwater Program ( Final Rule ICR) 1820.02 10/ 31/ 2003 OW Consumer Confidence Reports 1832.02 10/ 31/ 2003 OW Notice of Intent for Storm Water discharges Associated with Construction Activity 1842.02 10/ 31/ 2003 OW Revisions to UIC Regulations for Class V Injection Wells; Final Rule ICR 1874.02 10/ 31/ 2003 OW Unregulated Contaminants Monitoring Regulation 1882.02 10/ 31/ 2003 OW Final National Primary Drinking Water Regulations; Interim Enhanced Surface Water 1895.02 10/ 31/ 2003 OW Final National Primary Drinking Water Regulations; Stage 1 Disinfectants/ Disinfe 1896.03 10/ 31/ 2003 49 Office Name ICR Title ICR Number Automation Date OW Public Water System Supervision Program Public Notification Requirements ( Final 1898.02 10/ 31/ 2003 OARM Synopses of Proposed Contract Actions and Market Research Activity 1910.01 10/ 31/ 2003 OW National Primary Drinking Water Regulations for Lead and Copper; Final Rule 1912.01 10/ 31/ 2003 OAR Alternate Threshold for Low Annual Reportable Amounts; Toxic Chemical Reporting 1704.05 10/ 31/ 2003 OAR Exclusion Determinations for New Non road Sparkignited Engines at and Below 20 1852.02 11/ 1/ 2003 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/ 1/ 2003 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/ 31/ 2003 OW Beach Closing Survey Report on the Great Lakes 994.05 10/ 30/ 2003 OAR Transition Program for Equipment Manufacturers, 40 CFR Part 89.101 1862.02 10/ 31/ 2003 OAR EPA's Natural Gas STAR Program 1763.03 10/ 31/ 2003 OAR Motor Vehicle Emission and Fuel Economy Compliance; Light Duty Vehicles; Light Duty Trucks and Motorcycles 783.42 2004 OPPTS TSCA Section 402/ 404 Training, Certification, Accreditation and Standards for Lead Based Paint Activities 1715.03 2004 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/ 1/ 2005 OAR Acid Rain Program under Title IV of the CAA Amendments of 1990 1633.12 12/ 31/ 2005 OPPTS Request for Contractor Access to TSCA Confidential Business Information 1250.06 2005 OPPTS Correction of Misreported Chemical Substances on the Toxic Substances Control Act 1741.03 2005 50 Office Name ICR Title ICR Number Automation Date OPPTS Pre Manufacture Review Reporting and Exemption Requirements for New Chemical 574.11 2005 OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2005 OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2005 * This table lists all the ICRs to be automated by the CDX as identified by the EPA programs. Note that certain programs listed an ICR more than once if it contained multiple collections that will be automated through the CDX. For example, UIC ICR # 370.18 is listed multiple times for each collection in the ICR that will be automated. On the other hand, other EPA programs listed an ICR once regardless of the number of collections it contained. 51 Appendix II. Information Collections Under Which Direct Reporting Will Occur As described in Section 1, this CBA estimates costs to ( 1) EPA for developing and implementing electronic reporting under its programs ( e. g., building portals, publishing rules, implementing identity proofing); ( 2) State/ Locals for upgrading their receiving systems, applying for EPA program modification approval, and implementing identity proofing; ( 3) direct reporters for registering with the CDX and complying with identity proofing requirements, as applicable, and reporting by paper or electronically under information collections to be automated by EPA ( direct reporting); and ( 4) indirect reporters for complying with identity proofing requirements under information collections automated by State/ Locals.

The EPA programs identified 137 information collections to be automated by EPA during the modeling period. These information collections are currently contained in 73 ICRs, which estimate the hour and cost burden to respondents and the Agency.

In reviewing the 137 information collections, EPA noted two types of information collections that required particular consideration in estimating costs to direct reporters. One type included collections that would not be implemented by EPA under the CROMERR/ CDX ( the hazardous waste manifest system will be automated independently of CROMERR and the CDX). Any information collection that would not be implemented under CROMERR/ CDX was excluded from analysis in this CBA.

The other type included collections that are fully administered by State/ Locals in lieu of EPA. For purposes of this analysis, EPA assumed that collections under the Clean Air Act ( CAA) and the Safe Drinking Water Act ( SDWA) are fully administered by the states; and hence, only indirect reporters would have an opportunity to report electronically under them. 1 For this reason, the CBA does not estimate any costs to direct reporters under them. The CBA does, however, estimate costs to State/ Locals in upgrading their receiving systems, applying for EPA program modification approval, and implementing identity proofing under them, as applicable. The CBA also estimates costs to indirect reporters for complying with identity proofing requirements under them, as applicable.

Based on the above assumptions, the CBA estimates the costs of direct reporting under 68 information collections. These collections are listed in Table II 1, along with their automation start dates under " Baseline" and " To Be".

Table II 1 lists all the ICRs to be automated by the CDX as identified by the EPA programs. Note that certain programs listed an ICR more than once if it contained multiple collections that will be automated through the CDX. For example, UIC ICR # 370.18 is listed multiple times for each collection in the ICR that will be automated. On the other hand, other EPA programs listed an ICR once regardless of the number of collections it contained.

1 The only CAA information collection in the model is the radionuclide emissions reports under NESHAPS ( ICR # 1100.11). This collection is administered primarily by EPA, not the states. EPA intends to use this collection as a model for incorporating additional NESHAPS collections into the CDX over the coming years. At present, however, the inclusion of these additional collections into the CDX is in a state of flux, and therefore, they have not been examined in the model. 52 Table II 1. Information Collections Under Which Direct Reporting Will Occur*

Office Name ICR Title ICR Number Automation Date " Baseline" Automation Date " To Be"

OEI Toxic Chemical Release Reporting, Recordkeeping, Supplier Notification and Petitions 1363.11 9/ 1/ 2000 9/ 1/ 2000 OW Clean Water Needs Survey 318.09 12/ 31/ 2000 12/ 31/ 2000 OPPTS TSCA Section 12( b) Notification of Chemical Exports 795.1 9/ 30/ 2001 9/ 30/ 2001 OPPTS Partial Updating of TSCA Inventory Data Base; Production and Site Reports 1011.05 9/ 30/ 2001 9/ 30/ 2001 OA Amendment to Regulatory Reinvention Pilot Projects ( Project XL) ICR; New York State 1755.06 10/ 30/ 2001 10/ 30/ 2001 OGC National Roster of Environmental Dispute Resolution and Consensus Building 1888.01 10/ 30/ 2001 10/ 30/ 2001 OPPTS Voluntary Cover Sheet for TSCA Submissions 1780.02 9/ 1/ 2002 9/ 1/ 2002 OW Questionnaire for Operations and Maintenance, Biosolids Use, Combined Sewer Over 1287.06 9/ 30/ 2002 9/ 30/ 2002 OW CWA State Revolving Fund Program 1391.06 9/ 30/ 2002 9/ 30/ 2002 OW National Water Quality Inventory Reports ( TMDL Final Rule: Clean Water Act Section 1560.06 9/ 30/ 2002 9/ 30/ 2002 OW Drinking Water State Revolving Fund Program ( DWSRF) 1803.03 9/ 30/ 2002 9/ 30/ 2002 OAR NESHAPS: Radionuclides 1100.11 12/ 31/ 2002 12/ 31/ 2002 OW Water Alliances for Voluntary Efficiency ( WAVE) Program 1654.03 9/ 30/ 2005 9/ 30/ 2003 OAR IAQ Practices in Large Buildings Survey 1917.01 9/ 30/ 2005 37893 OW National Program to Regulate Nondomestic Discharges to Municipal Sanitary Sewer 2.09 10/ 31/ 2005 10/ 31/ 2003 OW Modification of Secondary Treatment Requirements for Discharges into Marine Water 138.06 10/ 31/ 2005 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 10/ 31/ 2005 10/ 31/ 2003 53 Office Name ICR Title ICR Number Automation Date " Baseline" Automation Date " To Be"

Management Permit OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 10/ 31/ 2005 10/ 31/ 2003 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 10/ 31/ 2005 10/ 31/ 2003 OW NPDES DMR ICR 229.15 10/ 31/ 2005 10/ 31/ 2003 OSWER Notification of Regulated Waste Activity 261.13 10/ 31/ 2005 10/ 31/ 2003 OSWER RCRA Hazardous Waste Permit Application and Modification, Part A 262.09 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 54 Office Name ICR Title ICR Number Automation Date " Baseline" Automation Date " To Be"

OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW UIC Program 370.18 10/ 31/ 2005 10/ 31/ 2003 OW Construction Grants Program 827.05 10/ 31/ 2005 10/ 31/ 2003 OW Water Quality Standards Regulation 988.08 10/ 31/ 2005 10/ 31/ 2003 OSWER Application for Reimbursement to Local Governments for Emergency Response to Hazardous Substance Releases 1425.05 10/ 31/ 2005 10/ 31/ 2003 OSWER Reporting and Recording Requirements under EPA's Wastewise Program 1698.04 10/ 31/ 2005 10/ 31/ 2003 OW National Health Protection Survey of Beaches 1814.02 10/ 31/ 2005 10/ 31/ 2003 OW Phase II of the NPDES Stormwater Program ( Final Rule ICR) 1820.02 10/ 31/ 2005 10/ 31/ 2003 OW Notice of Intent for Storm Water discharges Associated with Construction Activity 1842.02 10/ 31/ 2005 10/ 31/ 2003 OAR Motor Vehicle Emission and Fuel 783.42 2006 2004 55 Office Name ICR Title ICR Number Automation Date " Baseline" Automation Date " To Be"

Economy Compliance; Light Duty Vehicles; Light Duty Trucks and Motorcycles OPPTS TSCA Section 402/ 404 Training, Certification, Accreditation and Standards for Lead Based Paint Activities 1715.03 2006 2004 OPPTS Request for Contractor Access to TSCA Confidential Business Information 1250.06 2007 2005 OPPTS Correction of Misreported Chemical Substances on the Toxic Substances Control Act 1741.03 2007 2005 OPPTS Pre Manufacture Review Reporting and Exemption Requirements for New Chemical 574.11 2007 2005 OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2007 2005 OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 2007 2005 * In developing automation start dates for " Baseline", EPA assumed that an information collection would be delayed by 2 years in relation to " To Be". Hence, each information collection under " Baseline" begins 2 years after its automation start date under " To Be ". 56 Appendix III. Summary of the Model Data and Assumptions Table III 1 summarizes the primary model data and assumptions used in estimating costs to EPA, State/ Locals, and facilities. Table III 1 summarizes the primary data and assumptions for all activities taken by these entities under " Baseline" and " To Be".

Table III 1. Summary of the Model Data and Assumptions*

Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario Scope of the Rule The model estimates the annual cost impact to EPA, State/ Locals, and facilities under two scenarios:

An " Baseline" scenario, in which EPA would enable electronic reporting through an approach other than CROMERR and CDX; and

A " To Be" scenario, in which EPA enables electronic reporting under CROMERR and CDX. In both scenarios, the model includes activities and costs most likely to be incurred by these entities in complying with EPA's rules and receiving systems. In developing the model, EPA surveyed all of its programs and identified all information collections that they expect to automate over the coming years, as well as the expected date of automation ( i. e., " automation start date").** EPA reviewed their feedback and determined that a number of collections were outside the scope of the model's analysis. Hence they are not included in the model:

Information collections being implemented, or planned to be implemented, under a separate, non CDX receiving system. These include information collections under the Reformulated Gas, RCRA Manifest System, and Acid Rain Programs.

Information collections implemented under non EPA programs, e. g., the Federal Acquisition Regulations ( i. e., 48 CFR).

Number of Information Collections Included in the Model 68 Environmental Protection Agency Activities and Burdens Portal and Rule Development Under the " Baseline" scenario, EPA estimates that nine program areas would develop a portal and rulemaking for receiving electronic submissions: OAR OMS, OAR OAQPS, OPPTS TSCA, OPPTS FIFRA, OSWER OSW, OSWER CEPPO, OSWER CERCLA, OW NPDES, and OWSDW Under the " To Be" scenario, EPA assumes that CDX and CROMERR would be developed.

Total Number of Portals Developed 9 1 Total Development Cost per Portal $ 6.2 million $ 95.6 million Annual Maintenance Cost per Portal $ 2.1 million $ 0.4 million to $ 3.9 million Total Number of Rulemakings 9 1 Development of Automated Collections Under both the " Baseline" and " To Be" scenarios, the model assumes that EPA would incur costs for converting each collection to an electronic format. Under the " To Be" scenario, EPA would also issue a Federal Register notice announcing the availability of electronic reporting of each 57 Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario collection.

Total Cost for Converting Each Collection to Electronic Format $ 0.2 million Total Number of Federal Register Notices Prepared NA 68 Total Development Cost per Federal Register Notice NA $ 0.03 million Help Desk Under the " Baseline" scenario, the model assumes that each employee registrant to a program's portal would need to contact the program for assistance. Further, EPA has determined that EPAregulated facilities are subject to 1.3 EPA programs on average. Therefore, the model assumes that each employee registrant would make 1.3 calls to EPA's Help Desk on average. Under the " To Be" scenario, the model assumes that each employee registrant to the CDX would make one call to EPA's Help Desk.

Total Number of Calls per Registrant 1.3 1 Time per Call 6 minutes 8 minutes Implementation Wet Ink on Paper Signature Agreements Receive, process, review, approve, and file new wet ink on paper signature agreements 0.17 Receive, process, review, approve, and file new wet ink on paper signature agreements ( employee turnover) 0.17 Receive, process, review, approve, and file wet ink on paper signature agreements renewals 0.17 LRA Certification and Notification of Registered Users Receive application to designate first time local authority 0.5 Receive, store, process and review notification of registered users 0.17 Receive application to designate local authority ( local authority turnover) 0.5 Receive, process, review, and approve updated notification of certificate ( employee turnover) 0.17 Receive notification of breach of storage security and take appropriate follow up action 1 Receive, process, review, and approve updated notification of certificate ( breach of security) 0.17 Receive, process, review, approve, and file application renewals 0.5 58 Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario Ongoing Management Identify and resolve problems 1 Respond to information requests 1.5 Review of State/ Locals Program Modification Applications The model estimates costs to EPA for reviewing program modification applications from State/ Locals. Under the " Baseline" scenario, the model assumes that each authorized state environmental protection agency would submit three program modification applications to EPA on average. Under the " To Be" scenario, the model assumes that each authorized state environmental protection agency would submit one consolidated program modification application to EPA. In addition, the model assumes that under both the " Baseline" and " To Be" scenarios, " other authorized State/ Locals jurisdictions" ( e. g., county governments) would each submit one application to EPA on average. 3 1 Total Number of Applications submitted by each State EPA 80 160 Total EPA Hours for Review/ Approval of a State EPA Application 1 Total Number of Applications submitted by each " Other State/ Locals Jurisdiction" 80 Total EPA Hours for Review/ Approval of an " Other State/ Locals Jurisdiction" Application Wet ink on paper signature agreements 20 Develop a process for collecting, processing, and storing wet inkon paper signature agreements 8 Local Registration Authority ( LRA) Certification and Notification of Registered Users Develop a process for collecting, processing, and storing applications and other submittals 20 Develop Web certification guidance 8 Processing of Paper/ Electronic Submittals The model assumes EPA would incur annual costs for processing paper and electronic submittals from direct reporters under all of the collections under " Baseline" and " To Be". Refer to Figure VII 1 of Appendix VII for the equation used in the model to estimate EPA costs in processing paper and electronic submittals under each of the collections. ( Although the equation, as written, is directed at facility burden in submitting information, the model uses the same equation to estimate EPA burden in processing submittals.) 59 Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario State and Local Environmental Programs Activities and Burdens Number of State/ Locals Jurisdictions Expected to Have Electronic Receiving Systems During Modeling Period EPA believes that many State/ Locals jurisdictions are implementing or are planning to implement electronic receiving systems. The model assumes that a percentage of State/ Locals will upgrade their systems and apply for EPA program modification approval throughout the modeling period. Refer to Section 2.3.2 of this document for the percentage of State/ Locals expected to upgrade and apply for modification approval each year. 56 Number of State EPAs Examined During the Modeling Period 20 Number of Tribes Examined During the Modeling Period 40 Number of County Air Programs Examined During the Modeling Period 412***

Number of POTWs Examined During the Modeling Period 22 Number of State Health Departments Examined During the Modeling Period 19 Number of Oil and Gas Agencies Examined During the Modeling Period Upgrade Costs Under the " To Be" scenario, EPA believes that a percentage of State/ Locals would need to upgrade their receiving systems to make them CROMERR compliant. EPA believes that the standards established under EPA's rules under the " Baseline" scenario would be comparable in scope and stringency to CROMERR and the CDX and hence would require the same level of upgrades. Following is information on the features expected to be upgraded and the percentage of State/ Locals performing the upgrades under " Baseline" and " To Be". Upfront Start up: $ 50,000  $ 208,333 Annual Maintenance: $ 10,000 $ 28,333 Copy of Record ( COR) Upgrade Costs 58%

Percent of State/ Locals Receiving Systems that Would Need COR Upgrade Upfront Start up: $ 25,000 Annual Maintenance: $ 600 Secure Socket Layer ( SSL) Upgrade Costs 27%

Percent of State/ Locals Receiving Systems that Would Need SSL Upgrade Upfront Start up: $ 56,000 Annual Maintenance: NA Email Notification Upgrade Costs 7% 60 Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario Percent of State/ Locals Receiving Systems that Would Need Email Notification Upgrade Upfront Start up: $ 15,270 Annual Maintenance: NA Electronic Signature Upgrade Costs 100%

Percent of State/ Locals Receiving Systems that Would Need Electronic Signature Upgrade Program Modification Application 3 1 Total Number of Applications Submitted per State EPA 1 Total Number of Applications Submitted per " Other State/ Locals Jurisdiction" 180 225 to 425 Total Hours per State EPA for Application Development/ Submittal 180 225 Total Hours per " Other State/ Locals Jurisdiction" for Application Development/ Submittal Wet Ink On Paper Signature Agreements 20 Develop a process for collecting, processing, and storing wet inkon paper signature agreements 8 Develop Web guidance Facility Activities and Burdens Direct Reporters 9 minutes 11 minutes Time for Registration and Help Desk per Employee Registrant 30 minutes Time for Digital Signature Certification and Re Certification per Employee Registrant 20%

Percent of Employee Registrants that will Require Digital Signature Refer to Appendix VII Costs for reporting to EPA by paper and electronic methods Indirect Reporters under Electronic Signature Agreement for " Baseline" Scenario 10 minutes See " Electronic Signature Agreement" below Time per employee registrant to prepare, sign, and keep records of electronic signature agreement 61 Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario Direct and Indirect Reporters under Electronic Signature Agreement for " To Be"

Implementation Small facilities/ wet ink on paper signature agreements Prepare, submit, and file wet ink on paper signature agreements 0.25 Prepare, submit, and file new wet ink on paper signature agreements ( employee turnover) 0.25 Help Desk/ technical support 0.033 Renew wet ink on paper signature agreements 0.25 Medium Size and Large Facilities/ Local Registration Authority Develop a plan/ process to collect and wet ink on paper signature agreements, designate local authority, and submit application material 12 Obtain legal counsel 1 Register local authority with CDX or State/ Locals system 0.183 Prepare/ send wet ink on paper signature agreements to local authority 0.25 Prepare local authority certification and submit notification of certificate 1 Prepare/ send new wet ink on paper signature agreements to local authority ( employee turnover) 0.25 Submit updated notification of certificate ( employee turnover) 0.08 Re designate local authority and send application material ( local authority turnover) 1 Register new local authority 0.183 Report breach of storage security 0.5 Prepare/ send wet ink on paper signature agreements to local authority ( breach of security) 0.25 Prepare and submit notification of certificate ( breach of security) 0.08 Renew local authority designation 1 Ongoing Management Identify and resolve problems 1 62 Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario Other Model Operating Parameters Annual implementation Rates for Electronic Reporting The annual implementation rate is the rate at which direct reporters would adopt electronic reporting each year under each information collection. The costs in this chapter reflect a 30 percent first year implementation rate and a 10 percent rate per annum thereafter. The model applies this rate to derive the total annual costs associated with both paper and electronic submittals, as well as the number of registrants each year. The implementation rate was applied on a collection by collection basis, based on the collection's automation start date under " Baseline" or " To Be". An information collection's automation start date determines the percentage of facilities and submittals that will be automated by the end of the modeling period. As an example, information collections with an automation start date of 2003 would see 73 percent automation by the end of 2012. The majority of collections would be automated in the 2003 to 2005 timeframe under " Baseline" and " To Be". The results presented in Section 3 and the appendices of this CBA are based on the central rates shown below. In Section 4 of this document, EPA conducted sensitivity runs using the low and high rates, referred to as Scenario 1 and Scenario 2, respectively, in Section 4. First Year: 25% Annually thereafter: 8.5%

Low Implementation Rate First Year: 30% Annually thereafter: 10%

Central Implementation Rate First Year: 45% Annually thereafter: 15%

High Implementation Rate N/ A Electronic Reporting Savings Rate The model assumes that facilities that report electronically would save time and costs per document preparation and submittal in comparison with paper submittals. 10%

Percent of Time Saved Per Document Submittal ( Web Form) 25%

Percent of Time Saved Per Document Submittal ( XML/ Flat File) N/ A 63 Estimate of Parameter Parameters " Baseline" Scenario " To Be" Scenario Usage Rate of Web Forms and XML/ Flat File The model assumes that EPA would make both Web forms and XML/ flat file available to reporters under all 68 collections. The model assumes that most small and medium size reporters, as well as some large reporters, will opt for Web forms. The model assumes that a subpopulation of medium size and large reporters will opt for XML/ flat file for all of their electronic reporting. Refer to Appendix X for more information on XML and flat file assumptions. 94%

Annual Percent of Electronic Reporters Using Web Forms 6%

Annual Percent of Electronic Reporters Using XML or Flat File N/ A * This table presents the basic data and assumptions used in the model. Refer to Section 2 for additional discussion on how the data and assumptions were incorporated into the model.

** The automation start dates under " To Be" reflect EPA program feedback. In developing automation start dates for " Baseline", EPA assumed that an information collection would be delayed by 2 years in relation to its start date under " To Be".

*** The model assumes that 10% of POTWs would implement electronic receiving systems in the first 2 years of EPA rule promulgation and 5% annually thereafter. Because the modeling period for State/ Locals receiving system implementation spans roughly 7 years, the model does not assume that all 412 POTWs would implement electronic systems during that timeframe. 64 Appendix IV. Labor Rates Used in the Analysis As described in Section 2, EPA accessed two data sources for the model's hourly labor costs. For facility reporting costs under specific collections, EPA referred to the average hourly labor costs in the corresponding ICR. For all other labor activities, EPA developed its own costs. In doing so, EPA developed weighted average labor cost for EPA, State/ Locals, and facilities. The weighted average costs reflect an assumed " weight" for each labor category, i. e., the percent of time that the labor category is assumed to be involved in the activities being modeled. EPA developed the weights using its best judgment. EPA multiplied each weight by the corresponding average loaded hourly rate ( i. e., loaded with fringe and overhead) and summed these products in order to derive a single loaded hourly rate for each labor category for EPA, State/ Locals, and facilities, respectively.

  For EPA employees, EPA referred to the 2002 General Services Pay Schedule to ascertain the annual average salary of legal, managerial, technical, and administrative staff. EPA divided total annual salaries by 2080, the total hours in the work year, to derive annual hours. EPA then applied a 1.6 loading factor to account for overhead and fringe.

  For State/ Locals employees, EPA referred to Table 3, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: State and Local government, by selected characteristics, June 2002, U. S. Department of Labor, Bureau of Labor Statistics, Employer Costs for Employee Compensation June 2002.

  For facility employees, EPA referred to Table 5, Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers, by major industry group, June 2002, U. S. Department of Labor, Bureau of Labor Statistics, Employer Costs for Employee Compensation   June 2002.

Updated hourly wage rates were inflated to 2003 dollars. The Bureau of Labor Statistics ( BLS) employment cost index ( available at http:// www. bls. gov/ news. release/ eci. t02. htm) was used to inflate the wage rates.

The tables below present these loaded rates and corresponding weights. Refer to Exhibit 2 3 for the weighted average rates used in the model.

Table IV 1. Labor Rates and Weight for EPA Employees Labor Category Wage Weight Lawyers $ 65.59 10%

Managers $ 55.94 20%

Technical Staff $ 40.40 50%

Administrative Staff $ 18.65 20% 65 Table IV 2. Labor Rates and Weight for State/ Locals Employees Labor Category Wage Weight Lawyers $ 43.28 10%

Managers $ 40.58 20%

Technical Staff $ 27.53 50%

Administrative Staff $ 21.07 20%

Table IV 3. Labor Rates and Weight for Facility Employees Labor Category Wage Weight Lawyers $ 69.34 10%

Managers $ 51.47 20%

Technical Staff $ 34.69 50%

Administrative Staff $ 23.25 20%

Contractors $ 93.51 66 Appendix V. State Survey Data During the Summer of 2002, EPA consulted with regulators in 15 states to learn about their automation activities and receiving systems. EPA believes the states contacted are sufficiently representative of all states in the U. S. to enable an extrapolation of the summary data to all State/ Locals.

Tables V 1 through V 3 present the raw data used in estimating cost impacts to State/ Locals and facilities under the " Baseline" and " To Be" scenarios.

EPA reviewed the data in the tables to:

  Estimate the average number of receiving systems per state environmental protection agency and other State/ Locals jurisdictions. EPA's review of the state data suggests that the state environmental protection agencies are implementing, or plan to implement, three receiving systems on average. Therefore, the model assumes that each state environmental protection agency would implement three receiving systems, on average, during the duration of the modeling period. Based on the table, the model also assumes that other State/ Locals jurisdictions ( e. g., county agencies, etc.) would implement one receiving system, on average.

  Estimate the percentage of receiving systems that would need to upgrade to meet CROMERR's standards at 40 CFR 3.2000. EPA's review of the state survey data, in relation to the 3.2000 standards, suggests the following upgrades would be needed:

  Copy of Record with Context ( 40 CFR 3.2000( b)). EPA identified eight or nine of the 15 state receiving systems that potentially would not satisfy the 3.2000( b) standard for copy of record with context. Therefore, the model extrapolates to the universe State/ Locals to assume that 58 percent of their receiving systems would need to be upgraded for copy of record with context.

  EPA used its best judgment to estimate the costs associated with each of the upgrade options below. EPA was unable to collect sufficient information to enable it to precisely predict the level of upgrades needed for the state environmental protection agencies' receiving systems. Therefore, the model derived the average startup and maintenance cost across all three options ( i. e., $ 208,000 in startup and $ 28,333 in annual maintenance costs), and assumed the state environmental protection agencies would incur these average costs for each receiving system.

Copy of Record Upgrade Costs Upgrade Options Initial/ Startup Cost Annual Maintenance Cost Print out and file hardcopy of each submittal and keep transaction log $ 50,000 $ 10,000 Use Web upload approach that captures transaction history and copy of record $ 20,000 $ 25,000 Reconfigure backend of receiving system to enable electronic archiving of records $ 375,000 $ 50,000   The model assumes that the other State/ Locals jurisdictions would generally be collecting less enforcement sensitive information from facilities and face greater resource limitations than the state environmental protection agencies. Therefore, the model assumes that, on average, these other State/ Locals jurisdictions would opt for the least cost option of maintaining a paper based copy of record system ( i. e., $ 50,000 in start up and $ 10,000 ongoing maintenance). 67   Secure Sockets Layer. EPA expects that all State/ Locals receiving system would need to have SSL to provide for data encryption, server authentication, and message integrity among other things. The state survey table suggests that four states' receiving systems do not have SSL technology. Therefore, the model assumes that 27 percent of State/ Locals receiving systems would need to be upgraded for SSL. EPA used its best judgment to estimate one time SSL costs of $ 25,000 for network administration and $ 600/ yr for maintaining the vendor certificate.

  E mail Notification. EPA expects that all State/ Locals receiving systems would need to have a process to confirm receipt of the facilities' electronic submittals. The model assumes notification would be accomplished by sending an e mail confirmation to the facility's e mail inbox. EPA's review of the state summary table suggests that one state has a receiving system that would need to be upgraded for e mail notification. Therefore, the model assumes that 7 percent of State/ Locals systems would need to be upgraded for e mail notification. EPA used its best judgment to estimate one time upgrade costs of $ 56,000 per system. This includes $ 12,000 to $ 20,000 for an e mail server and $ 40,000 to bring the e mail server online.

  Electronic Signature ( 40 CFR 3.2000( a) ( 2)). EPA's review of the state summary table suggests that 50 percent of receiving systems do not have electronic signature features in satisfaction of CROMERR. However, EPA does not expect that all receiving systems would need to be upgraded. Rather, only those systems that receive information of a sufficiently enforcement sensitive nature would need to meet the signature standards. EPA used its best judgment to assume that 20 percent of these receiving systems would receive sensitive information and need to upgrade ( i. e., 50% x 20% = 10% of receiving systems). The model assumes these state systems would need to implement a process for maintaining a database of registrants' signature information. The model assumes this would require about 0.25 of a full time equivalent, at about $ 15,270/ system/ year.

Refer to Table V 4 for EPA's upgrade cost estimates and the percentage of State/ Locals performing the upgrades annually.

  Estimate the average hour burden to State/ Locals in applying to EPA for program modification approval. EPA's review of the state summary table suggests that, on average, a State/ Local would take about 180 hours/ program to apply to EPA for program modification approval. EPA believes this per program estimate is relevant to state environmental protection agencies under the " Baseline" scenario, since they would be submitting program specific applications to EPA. The estimate is also appropriate for other State/ Locals jurisdictions under both " Baseline" and " To Be", because it is assumed they generally administer one program. For state EPAs under " To Be", EPA believes the burden for preparing the consolidated program modification application would be greater, because it would encompass all of the Agency's receiving systems across its programs. The State Overview Table suggests that it would take a state environmental protection agency about 245 hours under " To Be" for preparing/ submitting the consolidated application.

  Estimate the number of facilities reporting to State/ Locals receiving systems ( i. e., indirect reporters). EPA tallied up the total number of electronic reporters to the 15 states' receiving systems and extrapolated to the U. S., to estimate the total number of indirect reporters that would report electronically. In total, EPA estimates that 490,218 indirect facilities would be reporting electronically.

Refer to Tables V 5 and V 6 for EPA's estimated number of indirect employee registrants. 68 Table V 1. State Overview System Credential Signature Scenario Archive System Security E mail notification ( Y = yes, N = no, U = under consideration) Transmission Protocol ( E = Email, HS = HTTPS, H = HTTP)

States P = Planned or E = Existing System( s) Staff Mgmt PS = Shared PIN; PA = PIN Self Assigned; DS = Digital Signature Warnings A = Affix Signature to Document; S = pr Associated; NA = No Signature Human readable COR COR w. context or audit trail Hash/ Sign General Arizona P 320 20 PS 1 S Y Y N Y Y HS Florida E 240 20 PA, PS 1 A Y N Y Y Y N Georgia P NONE 0 NA Y N N N Y N Illinois P DS 1 A Y N Y Y Y Y HS,

Kentucky P PS, Encryption Mississippi E PS, Encryption Nebraska ( oil and gas) E 320 20 PS 1 S Y N N N Y Y H, HS North Dakota ( OIL and GAS) E 120 20 PS 1 S Y N N N Y N E, H New Mexico E 200 20 PS, Encryption 1 A Y N Y Y Y U E P PS 1 S Y N N N Y U HS New Jersey P 120 15 PS 1 A Y N N N Y Y HS E PS, Encryption 1 S Y N Y Y Y N Ohio E 320 20 PS 1 S y N N N Y E,

Pennsylvania P 320 40 PS 1 A Y Y N N Y Y HS E PS 1 S Y Y N N Y E Tennessee P PS, Encryption Virginia P DS 1 A Y N Y Y Y HS, H Wisconsin E PS, HASH 1 A Y N Y N Y Y Table V 2. Existing State Receiving Systems State Existing Systems Start Date Program Number of Entities Arizona Florida 2000 EDMR 3 Georgia Illinois Kentucky Michigan 69 State Existing Systems Start Date Program Number of Entities Mississippi Nebraska ( oil and gas)

North Dakota ( oil and gas) 2000 UIC 250 New Mexico 1999 Air ( NEI) 200 New Jersey 2000 Air ( CEM) 12 2000 EPCRA( Tier II) 28000 2002 UST 1000 2002 P2 250 2002 Air Permits 1500 Ohio 2001 HW annual report 480 2000 Drinking/ Ground Water 5700 1999 Wastewater 1550 1999 Air title V emissions 780 1999 Air Permits ( PTIs) 200 1999 Risk Management 500 1999 PTO applications 780 1999 Emission Reports ( non title V) 2400 Pennsylvania Air Facility Trust 4000 Air Quality 125 Asbestos Notification 6000 Texas Tennessee Virginia Wisconsin 2002 Consolidated ( air, haz waste) 5800 2002 EDMR 22 Table V 3. Planned State Receiving Systems State Planned Systems Start Date Implementation Date Program Number of Entities Arizona 37621 37986 Drinking Water 1800 37986 38352 NPDES ( NOI) 60000 70 State Planned Systems Start Date Implementation Date Program Number of Entities Florida 37621 37986 NPDES ( DMR) 900 37543 37986 Drinking Water 7000 Georgia 37680 37986 EPCRA ( Tier II) 5000 Illinois 37621 37986 DMR 800 Indiana Kentucky Michigan Mississippi Nebraska ( oil and gas) 37621 37986 UIC 177 North Dakota ( oil and gas) 37621 UIC 250 New Mexico 37621 37986 Air Excess Emissions 1000 37621 1/ 2 / 04 NEI 1000 37621 37988 Title V 200 37986 37989 Air Emissions Scan New Jersey 37590 Water ( DMR) 2000 Ohio 37621 37986 HW Annual report 1200 37621 37986 Drinking Water Ground Water 5700 37621 37986 Wastewater 37621 37986 Air title V emissions 780 37621 37986 Air Permits 200 37621 37986 Risk Management 500 37621 37986 PTO applications 780 71 State Planned Systems Start Date Implementation Date Program Number of Entities 37621 37986 Emission Reports ( non title V) 2400 Pennsylvania 37772 38138 DMR 6000 Texas Tennessee Virginia 37346 37955 DMRs 3000 Wisconsin 37955 38321 DMRs 1800 Compliance NESHAPS Table V 4. Summary of State/ Locals System Upgrade Costs Per Receiving System Copy of Record SSL Email Notification E Signature Cost Per System Upgrade Cost Per System Upgrade Startup Cost Annual Maintenance % of Systems Needing Upgrade Startup Cost Annual Maintenance % of Systems Needing Upgrade Cost Per System Upgrade % of Systems Needing Upgrade Cost Per System Upgrade % of Systems Needing Upgrade State EPAs $ 208,333 $ 28,333 58% $ 25,000 $ 600 27% $ 56,000 7% $ 15,270 10%

All Other State and Local Agencies $ 50,000 $ 10,000 58% $ 25,000 $ 600 27% $ 56,000 7% $ 15,270 10%

Table V 5. Annual Number of State/ Locals Receiving System Employee Registratants Under " Baseline"

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Total     489,726 114,270 102,840 95,562 83,301 74,973 72 Table V 6. Annual Number of State/ Locals Receiving System Employee Registrants under " To Be"*

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 Total   489,726 114,270 102,840 92,562 83,301 74,973 67,476 60,729 * Table includes rounding error.

Table V 7. Upgrade Costs Per State/ Locals Receiving System under Electronic Signature Agreement Provisions Activities for Upgrade Receiving Systems Burden Hours Cost per Hour Total Cost Requirements analysis 49 $ 93.51 $ 4,581.99 System design analysis 73 $ 93.51 $ 6,826.23 Database changes and testing 35 $ 93.51 $ 3,272,85 Application changes and testing 73 $ 93.51 $ 6,826.23 QA testing and rework 35 $ 93.51 $ 3,272.85 Deployments 22 $ 93.51 $ 2,057.22 Project management 47 $ 93.51 $ 4,394.97 Totals: Hours, Rate, Cost 334 $ 93.51 $ 31,232.34 73 Appendix VI. State Contacts The information pertinent to State/ Locals Agency's existing and planned receiving systems have been obtained from the following individuals via a phone interview.

Table VI 1. State Survey Contacts Name Entity Tom Aten Wisconsin Department of Environmental Quality Russ Brodie Arizona Department of Environmental Quality John Coates Florida Mike Garretson Illinois EPA Allison Kittle Virginia Renee Martinez New Mexico Greg Nudd Texas Pete Tenebruso New Jersey Stan Belieu NB Oil and Gas 74 Appendix VII. Burden Hours and Costs to Direct Reporters EPA reviewed the ICRs in Appendix II to estimate the hours and cost burden to direct reporters and the Agency under each collection. In doing so, EPA " scaled" the hour and cost burden in each ICR to determine the burden associated only with these direct reporters.

To do so, the Agency developed a scaling factor for each EPA program. The scaling factor reflects the percentage of burden in each of the program's ICRs that is associated with only direct reporting. Specifically, a program's scaling factor is derived by the following equation:

Number of Regulated Entities in Nonauthorized States in Program = Program Scaling Factor Total number of Regulated Entities in all States The equation reflects the general assumption that facilities located in nonauthorized states submit information to EPA for any given program. That is, EPA generally administers information collections in nonauthorized states, whereas authorized states generally collect the information themselves. For example, OSWER/ Office of Solid Waste ( OSW) oversees the Resource Conservation and Recovery Act ( RCRA) hazardous waste program and has authorized 48 of the 50 states to administer state RCRA programs in lieu of EPA. In these 48 states, facilities generally submit reports to the state, not EPA. In only the two nonauthorized states ( i. e., Alaska and Iowa) are information collections administered by EPA. Because 1 percent of the regulated universe is located in these states, the model multiplies the hour and cost burden in OSWER/ OSW's ICRs by 1 percent, in order to derive the burden associated with direct reports. The model performed a similar computation for each of the collections in Appendix II.

Table VII 1 shows the scaling factors for each program.

Table VII 1. Scaling Factors Program Scaling Factor Source CWA 0.09 http:// www. epa. gov/ npdes/ pubs/ npdes modules. pdf http:// oaspub. epa. gov/ enviro/ ef_ home2. water OSW 0.01145 National Biennial RCRA Hazardous Waste Report ( 1999 data)

SDWADrinking Water Systems 0 http:// www. epa. gov/ safewater/ dwinfo. htm. http:// www. epa. gov/ safewater/ dwa/ electronic/ intropwss/ pwss. pdf epa. gov/ safewater/ data/ 00factoid. pdf TRI 1 EPA's best judgment CERCLA 1 EPA's best judgment Based on this analysis, EPA reduced the hours in each ICR, as appropriate, by applying the scaling factors. These hours are shown in Table VII 2.

Table VII 2. Annual Burden Hours to Direct Reporters*

Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours 75 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours OEI Toxic Chemical Release Reporting, Recordkeeping, Supplier Notification and Petitions 1363.11 1.00 6,870,800 OW Clean Water Needs Survey 318.09 1.00 7,700 OPPTS TSCA Section 12( b) Notification of Chemical Exports 795.10 1.00 10,400 OPPTS Toxic Substances Partial Updating of TSCA Inventory Data Base; Production and Site Reports 1011.05 1.00 53,600 OA Amendment to Regulatory Reinvention Pilot Projects ( Project XL) ICR; New York State 1755.06 1.00 58,300 OGC National Roster of Environmental Dispute Resolution and Consensus Building Profe 1888.01 1.00 500 OPPTS Voluntary Cover Sheet for TSCA Submissions 1780.02 1.00 900 OW Questionnaire for Operations and Maintenance, Biosolids Use, Combined Sewer Over 1287.06 0.09 300 OW CWA State Revolving Fund Program 1391.06 1.00 34,400 OW National Water Quality Inventory Reports ( TMDL) Final Rule: Clean Water Act 1560.06 1.00 4,243,500 OW Drinking Water State Revolving Fund ( DWSRF) Program 1803.03 1.00 29,800 76 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours OAR NESHAP: Radionuclides 1100.11 1.00 5,400 OW Water Alliances for Voluntary Efficiency ( WAVE) Program 1654.03 1.00 2,600 OAR IAQ Practices in Large Buildings Survey 1917.01 1.00 1,100 OW National Program to regulate nondomestic discharges to municipal sanitary sewer 2.09 0.09 85,000 OW Modification of Secondary Treatment Requirements for Discharges into Marine Water 138.06 0.09 5,900 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 3,100 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 120,300 OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 0.09 1,400 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 1,300 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 1,100 OW Applications for NPDES Discharge Permits and the Sewage Sludge 226.15 0.09 5,800 77 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours Management Permit OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 3,600 OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 0.09 100 OW Application for NPDES Discharge Permits and the Sewage Sludge Management Permits 226.15 0.09 24,300 OW Applications for NPDES Discharge Permits and the Sewage Sludge Management Permit 226.15 0.09 12,400 OW NPDES DMR ICR 229.15 0.09 199,500 OSWER Notification of Regulated Waste Activity 261.13 0.01 1,100 OSWER RCRA Hazardous Waste Permit Application and Modification, Part A 262.09 0.01 10 OW UIC Program 370.18 0.04 27,300 OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04  78 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW UIC Program 370.18 0.04

OW Construction Grants Program 827.05 0.09 118.10 OW Water Quality Standards Regulation 988.08 1.00 238,800 OSWER Application for Reimbursement to Local Governments for Emergency Response to Hazardous Substance Releases 1425.05 1.00 1,600.00 OSWER Reporting and Recording Requirements under EPA's Wastewise Program 1698.04 1.00 57,600 OW National Health Protection Survey of Beaches 1814.02 1.00 1,300 OW Phase II of the NPDES Stormwater Program ( Final Rule ICR) 1820.02 0.09 74,200 OW Notice of Intent for 1842.02 0.09 671,600 79 Office Name ICR Title ICR Number Scaling Factor Annual Scaled Burden Hours Storm Water Discharges Associated with Construction Activity OAR Motor Vehicle Emission and Fuel Economy Compliance; Light Duty Vehicles; Light Duty Trucks and Motorcycles 783.42 1.00 489,000 OPPTS TSCA Section 402/ 404 Training, Certification, Accreditation and Standards for Lead Based Paint Activities 1715.03 1.00 93,200 OPPTS Request for Contractor Access to TSCA Confidential Business Information 1250.06 1.00 300 OPPTS Correction of Misreported Chemical Substances on the Toxic Substances Control Act 1741.03 1.00 200 OPPTS Pre Manufacture Review Reporting and Exemption Requirements for New Chemical 574.11 1.00 178,700 OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 1.00 800 OPPTS PCBs: Consolidated Reporting and Recordkeeping Requirements 1446.07 1.00 62,900 * This table lists all the ICRs to be automated by the CDX as identified by the EPA programs. Note that certain programs listed an ICR more than once if it contained multiple collections that will be automated through the CDX. For example, UIC ICR # 370.18 is listed multiple times for each collection in the ICR that will be automated. On the other hand, other EPA programs listed an ICR once regardless of the number of collections it contained.

Based on the hours in Table VII 2, the model uses the equation in Figure VII 1 to estimate the total costs to direct reporters in preparing and submitting information under EPA's information collections. The model uses the equation for both " Baseline" and " To Be". Specifically, the model applies the equation to each of the collection's scaled hours, as described above. Through the equation, the model applies the annual automation implementation rate described 80 in Exhibit 2 5. The model then applies the Web form and XML form usage and savings rates described in Exhibit 2 5 to reduce the electronic hours by the savings rate.

Following this, the model sums up both the paper and electronic hours and applies the ICR's average hour labor rate to derive total costs. Through this process, the model estimates the total annual cost to direct reporters under the collection. Finally, the model sums up the total annual costs for each of the 68 collections to derive total annual aggregate costs for all collections per year.

From this, the model estimates total aggregate annual costs to direct reporters under " Baseline" and " To Be" across all collections for each year during the modeling period. Note that the model performs the same process for estimating costs to EPA in receiving and processing paper and electronic submittals.

Figure VII 1. Model Equation for Estimating Costs under EPA Collections Total ICR Hours for Reporting Hours for Paper Submittals Implementation Rate Hours for Electronic Submittals Web Form Usage Rate Hours for Web Submittals Hours for XML Submittals ( 1  Savings Rate) Total Hours Average ICR Hourly Labor Rate X =

i = 1 Total Annual Cost For ICR X X ( 1  Savings Rate) k Total Annual Cost i * k = number of ICRsused in the analysis ( 1  Implementation Rate)

where i = 1  k*

XML Form Usage Rate 81 Appendix VIII. Multi Media Reporting Scaling Factor In several places in the analysis, the model examines the universe of " unique" facilities subject to EPA's collections. EPA notes, however, that the number of facilities in the ICRs in Appendix II is potentially overlapping across programs. That is, a facility in an OSWER ICR might also be examined in an OW ICR. Given this, EPA derived a multi media scaling factor ( i. e., 1.3), which reflects the average number of EPA programs to which the average facility is subject. The scaling factor was derived by the equation shown in Table VIII 1:

Table VIII 1. Facility Count Multi Media Frequency Count Single 873,253 Double 83,847 Triple 30,600 Four 13,881 Five 7,489 Six 4,474 Seven 2,564 Eight 1,265 Nine 589 Ten 234 Eleven 41 Twelve 2 Thirteen 0 Source: FRS Statistics as of October 16, 2002. 82 Appendix IX. Number of Direct Reporters To derive the number of facilities reporting to the CDX, EPA obtained the number of respondents associated with each of the information collections in Appendix II. Note that each collection is examined in an ICR that estimates the total annual number of respondents to that collection. EPA then " scaled" the number respondents in each ICR to determine the number of facilities reporting directly to the Agency.

To estimate the number facilities reporting to EPA, the Agency developed a scaling factor for each of EPA's environmental programs. The scaling factor reflects the percentage of respondents in each program that is located in a nonauthorized state. Specifically, a program's scaling factor is derived by the following equation:

No. of Regulated Entities in Nonauthorized States in Program = Program Scaling Factor Total No. of Regulated Entities in all States The equation reflects the general assumption that facilities located in nonauthorized states submit information directly to EPA, not the state. That is, EPA generally administers information collections in nonauthorized states until the state receives authorization. For example, OSWER/ OSW oversees the RCRA hazardous waste program and has authorized 48 of the 50 states to administer state RCRA programs in lieu of EPA. In these 48 states, facilities generally submit reports to the state, not EPA. In only the two nonauthorized states ( i. e., Alaska and Iowa) are information collections administered by EPA. Because 1 percent of the regulated universe is located in these states, the model multiplies the total number of respondents in OSWER/ OSW's ICRs by 1 percent, in order to derive the number that reports directly to EPA. Scaling factors are presented in Table IX 1.

Table IX 1. Scaling Factors Program Scaling Factor Source CWA 0.09 \ d 4http:// www. epa. gov/ npdes/ pubs/ npdes modules. pdf \ d 4http:// oaspub. epa. gov/ enviro/ ef_ home2. water OSW 0.01145 National Biennial RCRA Hazardous Waste Report ( 1999 data)

SDWA Drinking Water Systems 0 \ d 4http:// www. epa. gov/ safewater/ dwinfo. htm. \ d 4http:// www. epa. gov/ safewater/ dwa/ electronic/ intropwss/ pwss. pdf epa. gov/ safewater/ data/ 00factoid. pdf TRI 1 EPA best judgment CERCLA 1 EPA best judgment SDWA UIC 0.04 http:// www. epa. gov/ safewater/ uic. tml OAR 0 EPA best judgment Through the calculations above, EPA estimated the number of respondents who report directly to EPA. Note, however, that EPA needed to further refine these estimates to determine the number of unique respondents to EPA. That is, regulated entities may be subject to more than one information collection in Appendix II. This could include, for example, more than one information collection within any program or more than one information collection across 83 programs ( e. g., information collections under the hazardous waste and water programs). To eliminate this potential duplication, EPA took the following two steps:

  Reviewed all ICRs within each program to determine if the ICRs contained overlapping respondent universes. EPA used its best judgment in determining if two or more ICRs within the same program applied to the same population of respondents, using information such as the Standard Industrial Classification codes and respondent universe descriptions in the ICR supporting statement. In doing so, EPA eliminated potential duplication within programs.

  Once EPA had eliminated potential duplication within each program, the Agency summed up to the total number of respondents that remained and divided this sum by the multimedia scaling factor described in Appendix VIII to eliminate duplication across programs.

From these calculations, EPA estimated the total number of unique respondents to EPA under each of the information collections. EPA then further refined these estimates by distinguishing the size of facilities in terms of number of employees. Understanding the breakdown in number of small vs. medium/ large facilities assisted the Agency in configuring the model to account for differences in number of employees who would register with EPA's receiving systems. It also informed the Agency of appropriate implementation rate assumptions, in that smaller facilities might not have the same level of capabilities in reporting electronically.

For purposes of this analysis, EPA has defined a " small" facility as one with 20 employees or fewer. EPA believes this is a reasonable threshold, as it focuses in on the smallest and most vulnerable of facilities and those most likely to face resource constraints in reporting electronically. The U. S. Census data indicate that 89 percent of all businesses employ 20 or fewer persons, and the remaining 11 percent employ 21 or more. 2 EPA used these percentages to estimate the number of small and large facilities reporting to EPA. These estimates are shown in Table IX 2.

In addition, EPA estimated the average number of employees per facility that would register with EPA's receiving systems. Based on public comments on the proposed CROMERR, EPA estimates that the typical small facility will designate three employee registrants and the typical large facility will designate six employee registrants, on average. Table IX 2 presents the total number of employee registrants per facility and for all facilities.

Table IX 2. Direct Reporters and Registrants*

Unique Facilities No. of Registrants per Facility Total No. of Registrants Small Facilities 67263 3 201,790 Large Facilities 8313 6 49,881 TOTAL 75577  251671 * Table includes rounding error.

2 U. S. Bureau of Census. Statistics of U. S. Businesses: 1999: All industries in the United States. http:// www. census. gov/ epcd/ susb/ 1999/ us/ US. HTM 84 Appendix X. XML and Flat File Usage To derive the number of XML/ flat file users, EPA's first assumption was that XML or flat file would be used only by medium and large facilities, because of the upfront costs and technical expertise required. Given this assumption, EPA reviewed all of the ICRs in Appendix II to estimate the total number of respondents under each information collection. EPA then assumed that 11 percent of them are medium or large. 12 In total, EPA estimates 8,313 medium and large facilities are subject to the information collections.

EPA further assumed that approximately 50 percent of these facilities would opt for XML or flat file, while the rest would opt for Web form, for each collection. 13 EPA also assumed that each facility is part of a business that consists of, on average, three facilities each,

and that XML or flat file mapping ( or purchase of off the shelf software) would be done centrally at one facility location ( e. g.,

headquarters location) and then distributed to the other two facilities. 14 EPA consulted with several of the respondents in Appendix XI,

who agreed with this assumption. Tables X 1 and X 2 present the total number of facilities that are expected to conduct XML or flat file mapping across all of the ICRs in Appendix II.

Table X 1. Number of Companies Implementing XML/ Flat File under " Baseline"

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 No. of Companies Implementing XML 108 39 34 25 23 377 113 115 92 82 74 66 59 Table X 2. Number of Companies Implementing XML/ Flat File under " To Be"

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 No. of Companies Implementing XML 108 39 34 382 118 119 95 85 77 69 61 55 49 In addition, EPA estimated the total XML or flat file mapping cost to facilities. EPA recognizes that, in actuality, mapping costs will vary greatly during the modeling period. They will be higher during the earlier years as facilities begin to use XML or flat files and then decline over time because of greater user sophistication. In addition, EPA anticipates the emergence of customizable off

theshelf software that can work within a user's environment, eliminating the need for significant mapping.

12 U. S. Bureau of Census. Statistics of U. S. Businesses: 1999: All industries in the United States.

13 " eMarketplaces Spur XML Adoption," Business Technographics of North America, May 11, 2001. The article estimates that more than 50 percent of Global 3,500 companies are implementing, rolling out, or piloting XML.

14 U. S. Bureau of Census. Statistics of U. S. Businesses: 1999: All industries in the United States. The Census estimates that firms with 20 or more employees consist of three establishments, on average. 85 EPA estimates that current XML and flat file mapping costs are roughly $ 25,000 for a facility per collection, on average. This estimate is based on EPA's best judgment and consultations with industry representatives listed in Appendix XI. EPA estimates that the cost to a facility to purchase and install the off the shelf software would be approximately $ 1,000 for a facility per collection.

EPA further expects that the vast majority of users will opt for the off the shelf software, on average, over the modeling period. This is due to its lower cost and greater convenience. For purposes of this analysis, the model assumes that 5 percent of users would opt to perform their own mapping and that the remaining 95 percent would purchase/ install the software, on average, over the modeling period. Note that EPA fully expects that, during the early years, the majority of facilities will map on their own. However, as the Agency implements greater electronic reporting across its programs, commercial vendors will increasingly supply software applicable to EPA's collections. As such, facilities will transition from mapping on their own to purchasing the software. 86 Appendix XI. Industry Consultations EPA contacted industry stakeholders on November 6 and 7, 2002, to collect information used in this cost analysis. The industry contacts are as follows:

  Salman Shaikh  Suffolk County Water Authority, New York ( UCMR: Lab and PWS)

  Steve McSherry  Decatur Utilities, Alabama ( UCMR: PWS)

  Brad Bollen  New Jersey Bureau of Air Quality Evaluation  ( AEI: State)

  Angelique Luedeker  Institute for Tribal Professionals, Arizona  ( AEI: Tribe)

  Ruth Curfman  Dow Corning Corporation, Michigan  ( TSCA HASD)

  Jack Halstuch  JH Consulting Group, New York  ( UCMR: PWS Consultant) 87 Appendix XIV. Background Tables on Sensitivity Runs Table XIV 1. EPA Costs under Baseline", " To Be", and Difference ( in millions of dollars)*

* Costs presented for Scenario 1.

** Cost savings shown in parentheses. Table XIV 2. State/ Locals Costs under " Baseline", " To Be", and Difference ( in millions of dollars)*

* Costs presented for Scenario 1.

** Cost savings shown in parentheses. 88 Table XIV 3. Facility Costs under " Baseline", " To Be", and Difference ( in millions of dollars)*

* Costs presented for Scenario 1.

** Cost savings shown in parentheses. 89 Table XIV 4. EPA Costs under " Baseline", " To Be", and Difference ( in millions of dollars)*

* Costs presented for Scenario 2.

** Cost savings shown in parentheses. Table XIV 5. State/ Locals Costs under " Baseline", " To Be", and Difference ( in millions of dollars)*

* Costs presented for Scenario 2.

** Cost savings shown in parentheses. 90 Table XIV 6. Facility Costs under " Baseline", " To Be", and Difference ( in millions of dollars)*

* Costs presented for Scenario 2.

** Cost savings shown in parentheses. 91 Appendix XV. Acronyms and Terms BLS Bureau of Labor Statistics CAA Clean Air Act CBA Cost Benefit Analysis CDX Central Data Exchange CEPPO Chemical Emergency Preparedness and Prevention Office CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COR copy of record CROMERR Cross Media Electronic Reporting Rule CWA Clean Water Act DMR Discharge Monitoring Report DWSRF Drinking Water State Revolving Fund EDMR Electronic Discharge Monitoring Report EPA Environmental Protection Agency EPCRA Emergency Planning and Community Right to Know Act FBCA Federal Bridge Certificate Authority FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FOIA Freedom of Information Act GPEA Government Paperwork Elimination Act 92 HW hazardous waste IAQ indoor air quality IFB Invitation for Bid ICR Information Collection Request LRA local registration authority NEIN National Environmental Integrated Network NESHAPS National Emissions Standards for Hazardous Air Pollutants NPDES National Pollutant Discharge Elimination System OA Office of Administrator OAQPS Office of Air Quality Planning and Standards OAR Office of Air and Radiation OARM Office of Administration and Resource Management OEI Office of Environmental Information OGC Office of General Counsel OMB Office of Management and Budget OMS Office of Mobile Sources OPPTS Office of Prevention, Pesticides and Toxic Substances OSW Office of Solid Waste OSWER Office of Solid Waste and Emergency Response OW Office of Water 93 PIN personal identification number POTW publicly owned treatment works PRA Paperwork Reduction Act RCRA Resource Conservation and Recovery Act RFP Request for Proposals SDW safe drinking water SDWA Safe Drinking Water Act SSL secure socket layer TRI Toxics Release Inventory TSCA Toxic Substances Control Act UIC Underground Injection Code UST Underground Storage Tank SML Extensive Markup Language WAVE Water Alliances for Voluntary Efficiency WWW World Wide Web


[Federal Register Volume 86, Number 42 (Friday, March 5, 2021)]
[Notices]
[Pages 12983-12984]
[FR Doc No: 2021-04550]

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DEPARTMENT OF LABOR

Occupational Safety and Health Administration

[Docket No. OSHA-2006-0041]

Southwest Research Institute: Grant of Renewal of Recognition

AGENCY: Occupational Safety and Health Administration (OSHA), Labor.

ACTION: Notice.

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SUMMARY: In this notice, OSHA announces the final decision to grant
renewal of recognition to Southwest Research Institute as a Nationally
Recognized Testing Laboratory (NRTL).

DATES: The renewal of recognition becomes effective on March 5, 2021.

FOR FURTHER INFORMATION CONTACT: Information regarding this notice is
available from the following sources:
    Press inquiries: Contact Mr. Frank Meilinger, Director, OSHA Office
of Communications, U.S. Department of Labor, telephone:<PHONE_NUMBER>;
email<EMAIL_ADDRESS>    General and technical information: Contact Mr. Kevin Robinson,
Director, Office of Technical Programs and Coordination Activities,
Directorate of Technical Support and Emergency Management, Occupational
Safety and Health Administration, U.S. Department of Labor, phone:
(202) 693-2110 or email<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

I. Notice of Final Decision

    OSHA hereby gives notice that it is granting the renewal of
recognition of Southwest Research Institute, Inc. (SWRI) as a NRTL
under 29 CFR 1910.7.
    OSHA recognition of a NRTL signifies that the organization meets
the requirements in Section 1910.7 of Title 29, Code of Federal
Regulations (29 CFR 1910.7). Recognition is an acknowledgment that the
organization can perform independent safety testing and certification
of the specific products covered within the scope of recognition and is
not a delegation or grant of government authority. As a result of
recognition, employers may use products properly approved by the NRTL
to meet OSHA standards that require testing and certification. OSHA
maintains an informational web page for each NRTL that details the
scope of recognition available at http://www.osha.gov/dts/otpca/nrtl/index.html.
    OSHA processes applications submitted by an NRTL for renewal of
recognition following requirements in Appendix A to 29 CFR 1910.7. OSHA
conducts renewals in accordance with the procedures in 29 CFR 1910.7,
App. A II.C. In accordance with these procedures, NRTLs submit a
renewal request to OSHA between nine months and one year before the
expiration date of the current recognition. A renewal request includes
a request for renewal and any additional information demonstrating
their continued compliance with the terms of the recognition and 29 CFR
1910.7. If OSHA has not conducted an on-site assessment of the NRTL
headquarters and any key sites within the past 18 to 24 months, it will
schedule the necessary on-site assessment prior to the expiration date
of the NRTL's recognition. Upon review of the submitted material and,
as necessary, the successful completion of the on-site assessment, OSHA
announces the preliminary decision to grant or deny renewal in the
Federal Register and solicits comments from the public. OSHA then
publishes a final Federal Register notice responding to any comments
and renewing the NRTL's recognition for a period of five years, or
denying the renewal of recognition.
    SWRI initially received OSHA recognition as a NRTL on July 13, 1993
(58 FR 37752). SWRI's most recent renewal was granted on July 30, 2014,
for a five-year period ending on July 30, 2019. SWRI submitted a timely
request for renewal, dated September 14, 2018 (OSHA-2006-0041-0008),
and retains their recognition pending OSHA's final decision in this
renewal process. The current address of the SWRI facility recognized by
OSHA and included as part of the renewal request is: Southwest Research
Institute, 6220 Culebra Road, Post Office Drawer 28510, San Antonio,
Texas 78238.
    OSHA evaluated SWRI's application for renewal and made a
preliminary determination that SWRI can continue to meet the
requirements prescribed by 29 CFR 1910.7 for recognition.
    OSHA published the preliminary notice announcing SWRI's renewal
application in the Federal Register on July 13, 2020 (85 FR 42015). The
agency requested comments by July 28, 2020, and received no comments in
response to this notice. OSHA is now proceeding with this final notice
to renew SWRI NRTL recognition.
    To obtain or review copies of all public documents pertaining to
the SWRI application, go to www.regulations.gov or contact the Docket
Office, Occupational Safety and Health Administration, U.S. Department
of Labor, 200 Constitution Avenue NW, Room N-3655, Washington, DC
20210; telephone<PHONE_NUMBER>. Docket No. OSHA-2006-0041 contains all
materials in the record concerning SWRI's NRTL recognition. Please
note: Due to the COVID-19 pandemic, the Docket Office is closed to the
public at this time but can be contacted at<PHONE_NUMBER>.

II. Final Decision and Order

    OSHA hereby gives notice of the renewal of recognition of SWRI as a
NRTL. OSHA examined SWRI's renewal application and all pertinent
information related to SWRI's request for renewal of NRTL recognition.
Based on this review of the renewal request and other pertinent
information, OSHA finds that SWRI meets the requirements of 29 CFR
1910.7 for renewal of recognition as a NRTL, subject to the specified
limitation and conditions. OSHA limits the renewal of SWRI's
recognition to include the terms and conditions of SWRI's recognition
found in 58 FR 37752. The NRTL scope of recognition for SWRI is also
available on the OSHA website at: https://www.osha.gov/dts/otpca/nrtl/swri.html. This renewal extends SWRI's recognition as a NRTL for a
period of five years from March 5, 2021.

A. Conditions

    In addition to those conditions already required by 29 CFR 1910.7,
SWRI must abide by the following conditions of recognition:
    1. SWRI must inform OSHA as soon as possible, in writing, of any
change of ownership, facilities, or key personnel, and of any major
change in their operations as a NRTL, and provide details of the
change(s);
    2. SWRI must meet all the terms of their recognition and comply
with all OSHA policies pertaining to this recognition; and
    3. SWRI must continue to meet the requirements for recognition,
including all previously published conditions on SWRI's scope of
recognition, in all areas for which it has recognition.
    Pursuant to the authority in 29 CFR 1910.7, OSHA hereby renews the
recognition of SWRI as a NRTL.

III. Authority and Signature

    Amanda L. Edens, Deputy Assistant Secretary of Labor for
Occupational Safety and Health, 200 Constitution Avenue NW, Washington,
DC 20210, authorized the preparation of this notice. Accordingly, the
agency is issuing this notice pursuant to 29 U.S.C. 657(g)(2)),
Secretary of Labor's Order No. 8-2020 (85 FR 58393, Sept. 18, 2020),
and 29 CFR 1910.7.

    Signed at Washington, DC, on March 1, 2021.
Amanda L. Edens,
Deputy Assistant Secretary of Labor for Occupational Safety and Health.
[FR Doc. 2021-04550 Filed 3-4-21; 8:45 am]
BILLING CODE 4510-26-P


[Federal Register Volume 79, Number 200 (Thursday, October 16, 2014)]
[Notices]
[Page 62170]
[FR Doc No: 2014-24483]

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DEPARTMENT OF HOMELAND SECURITY

Federal Emergency Management Agency

[Docket ID FEMA-2014-0024; OMB No. 1660-0057]

Agency Information Collection Activities: Submission for OMB
Review; Comment Request; Chemical Stockpile Emergency Preparedness
Program (CSEPP) Evaluation and Customer Satisfaction Survey

AGENCY: Federal Emergency Management Agency, DHS.

ACTION: Notice.

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SUMMARY: The Federal Emergency Management Agency (FEMA) will submit the
information collection abstracted below to the Office of Management and
Budget for review and clearance in accordance with the requirements of
the Paperwork Reduction Act of 1995. The submission will describe the
nature of the information collection, the categories of respondents,
the estimated burden (i.e., the time, effort and resources used by
respondents to respond) and cost, and the actual data collection
instruments FEMA will use.

DATES: Comments must be submitted on or before November 17, 2014.

ADDRESSES: Submit written comments on the proposed information
collection to the Office of Information and Regulatory Affairs, Office
of Management and Budget. Comments should be addressed to the Desk
Officer for the Department of Homeland Security, Federal Emergency
Management Agency, and sent via electronic mail to
<EMAIL_ADDRESS>or faxed to<PHONE_NUMBER>.

FOR FURTHER INFORMATION CONTACT: Requests for additional information or
copies of the information collection should be made to Director,
Records Management Division, 500 C Street SW., Room 7NE, Washington, DC
20472-3100, facsimile number<PHONE_NUMBER>, or email address<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

Collection of Information

    Title: Chemical Stockpile Emergency Preparedness Program (CSEPP)
Evaluation and Customer Satisfaction Survey.
    Type of Information Collection: Revision of a currently approved
information collection.
    FEMA Forms: FEMA Form 008-0-3, Pueblo EPZ Residential Survey; FEMA
Form 008-0-3INT, Pueblo EPZ Residential Survey; FEMA Form 008-0-4,
Pueblo City Residential Survey; FEMA Form 008-0-5, Pueblo EPZ Business
Survey; and FEMA Form 008-0-7, Blue Grass EPZ Residential Survey.
    Abstract: To support the development of public outreach and
education efforts that will improve emergency preparedness, DHS/FEMA's
Chemical Stockpile Emergency Preparedness Program (CSEPP) will collect
data from the citizens living in the Immediate Response Zones and
Protective Action Zones surrounding stockpile sites. Program managers
use survey data findings to evaluate public awareness of protective
actions at CSEPP sites, and identify outreach weaknesses and strengths
to develop effective outreach and education campaigns. Results from
this information collection are shared with State, local, Tribal, and
other FEMA officials for subsequent action plans addressing program-
wide and stockpile site-specific issues. Results are also shared with
other Federal agencies that lend expertise in specific areas of the
program.
    Affected Public: Individuals or households, business or other for-
profit.
    Estimated Number of Respondents: 2,078.
    Estimated Number of Responses: 2,078.
    Estimated Total Annual Burden Hours: 490 hours.
    Estimated Cost: There are no record keeping, capital, startup or
maintenance costs associated with this information collection.

    Dated: October 8, 2014.
Charlene D. Myrthil,
Director, Records Management Division, Mission Support Bureau, Federal
Emergency Management Agency, Department of Homeland Security.
[FR Doc. 2014-24483 Filed 10-15-14; 8:45 am]
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