SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 2002.06

“CROSS-MEDIA ELECTRONIC REPORTING RULE”

February 26, 2015

Office of Environmental Information

U.S. Environmental Protection Agency

Washington, D.C. 20460

TABLE OF CONTENTS

  TOC \o "1-2" \h \z \u    HYPERLINK \l "_Toc296521689"  1.
IDENTIFICATION OF THE INFORMATION COLLECTION	  PAGEREF _Toc296521689 \h
3

  HYPERLINK \l "_Toc296521690"  1(a)	TITLE AND NUMBER OF THE INFORMATION
COLLECTION	  PAGEREF _Toc296521690 \h  3

  HYPERLINK \l "_Toc296521691"  1(b)	CHARACTERIZATION OF THE INFORMATION
COLLECTION	  PAGEREF _Toc296521691 \h  3

  HYPERLINK \l "_Toc296521692"  2.	NEED FOR AND USE OF THE COLLECTION
PAGEREF _Toc296521692 \h  5

  HYPERLINK \l "_Toc296521693"  2(a)	NEED AND AUTHORITY FOR THE
COLLECTION	  PAGEREF _Toc296521693 \h  5

  HYPERLINK \l "_Toc296521694"  2(b)	PRACTICAL UTILITY AND USERS OF THE
DATA	  PAGEREF _Toc296521694 \h  6

  HYPERLINK \l "_Toc296521695"  3.	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION CRITERIA	  PAGEREF _Toc296521695 \h  8

  HYPERLINK \l "_Toc296521696"  3(a)	NONDUPLICATION	  PAGEREF
_Toc296521696 \h  8

  HYPERLINK \l "_Toc296521697"  3(b)	PUBLIC NOTICE	  PAGEREF
_Toc296521697 \h  8

  HYPERLINK \l "_Toc296521698"  3(c)	CONSULTATIONS	  PAGEREF
_Toc296521698 \h  8

  HYPERLINK \l "_Toc296521699"  3(d)	EFFECTS OF LESS FREQUENT COLLECTION
  PAGEREF _Toc296521699 \h  15

  HYPERLINK \l "_Toc296521700"  3(e)	GENERAL GUIDELINES	  PAGEREF
_Toc296521700 \h  15

  HYPERLINK \l "_Toc296521701"  3(f)	CONFIDENTIALITY	  PAGEREF
_Toc296521701 \h  16

  HYPERLINK \l "_Toc296521702"  3(g)	SENSITIVE QUESTIONS	  PAGEREF
_Toc296521702 \h  16

  HYPERLINK \l "_Toc296521703"  4.	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc296521703 \h  17

  HYPERLINK \l "_Toc296521704"  4(a)	RESPONDENTS AND NAICS CODES
PAGEREF _Toc296521704 \h  17

  HYPERLINK \l "_Toc296521705"  4(b)	INFORMATION REQUESTED	  PAGEREF
_Toc296521705 \h  17

  HYPERLINK \l "_Toc296521706"  5.	THE INFORMATION COLLECTED:  AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc296521706 \h  24

  HYPERLINK \l "_Toc296521707"  5(a)	AGENCY ACTIVITIES	  PAGEREF
_Toc296521707 \h  24

  HYPERLINK \l "_Toc296521708"  5(b)	COLLECTION METHODOLOGY AND
MANAGEMENT	  PAGEREF _Toc296521708 \h  25

  HYPERLINK \l "_Toc296521709"  5(c)	SMALL ENTITY FLEXIBILITY	  PAGEREF
_Toc296521709 \h  25

  HYPERLINK \l "_Toc296521710"  5(d)	COLLECTION SCHEDULE	  PAGEREF
_Toc296521710 \h  25

  HYPERLINK \l "_Toc296521711"  6.	ESTIMATING THE HOUR AND COST BURDEN
OF THE COLLECTION	  PAGEREF _Toc296521711 \h  27

  HYPERLINK \l "_Toc296521712"  6(a)	ESTIMATING RESPONDENT BURDEN HOURS
 PAGEREF _Toc296521712 \h  27

  HYPERLINK \l "_Toc296521713"  6(c)	ESTIMATING AGENCY HOUR AND COST
BURDEN	  PAGEREF _Toc296521713 \h  30

  HYPERLINK \l "_Toc296521714"  6(d)	ESTIMATING RESPONDENT UNIVERSE AND
TOTAL HOUR AND

COST BURDEN	  PAGEREF _Toc296521714 \h  30

  HYPERLINK \l "_Toc296521715"  6(e)	BOTTOM LINE HOUR AND COST BURDEN
PAGEREF _Toc296521715 \h  40

  HYPERLINK \l "_Toc296521716"  6(f)	REASONS FOR CHANGE IN BURDEN
PAGEREF _Toc296521716 \h  41

  HYPERLINK \l "_Toc296521717"  6(g)	PUBLIC BURDEN STATEMENT	  PAGEREF
_Toc296521717 \h  41

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	TITLE AND NUMBER OF THE INFORMATION COLLECTION

This Information Collection Request (ICR) is entitled “Cross-Media
Electronic Reporting Rule (Renewal)” EPA ICR Number 2002.06, OMB
Control Number 2025-0003.

	1(b)	CHARACTERIZATION OF THE INFORMATION COLLECTION

The U.S. Environmental Protection Agency (EPA) allows regulated entities
to report electronically to EPA by allowing the use of electronic
document receiving systems to receive electronic documents in
satisfaction of certain document submission requirements in EPA’s
regulations.  The Cross-Media Electronic Reporting Rule (CROMERR) also
allows state, tribal, and local governments to seek EPA approval, as
provided under 40 Code of Federal Regulations (CFR) 3.1000, to accept
electronic documents to satisfy reporting requirements under authorized
or delegated environmental programs that they administer.  In seeking
EPA approval, these state, tribal, and local governments must upgrade
existing electronic document receiving systems or develop new electronic
document receiving systems to satisfy the criteria laid out at 40 CFR
3.2000.  Regulated entities that use an electronic signature device in
submitting electronic documents to the EPA or a state, tribal, or local
government receiving system must comply with identity proofing
requirements, as applicable.  In the remainder of this document, we
refer to state, tribal, and local governments as “States/Locals”
because, at the current time, EPA is not aware of any tribal governments
that have electronic document receiving systems or are planning to
develop such systems during the next three years.

CROMERR does not require any regulated entity to report electronically
to EPA or States/Locals.  CROMERR establishes requirements for utilizing
electronic reporting as an alternative to paper-based reporting.  It
does not require States/Locals to implement electronic reporting;
rather, it establishes the framework for implementing the electronic
reporting alternative for Federal laws that they administer.  In this
regard, regulated entities are affected only as follows:

Entities that report electronically to EPA have to register with EPA’s
electronic document receiving system (e.g., log on to the EPA Web site
and enter requested information), comply with the identity proofing
provisions, and then commence electronic reporting.  In this document,
we refer to these entities as “direct reporters.”

States/Locals must upgrade existing electronic document receiving
systems or develop new electronic document receiving systems to meet 40
CFR 3.2000 requirements.  These States/Locals must apply for EPA program
modification approval under 40 CFR 3.1000.  They also must implement the
identity proofing requirements at 40 CFR 3.2000(b)(5).

Entities that report electronically to States/Locals must comply with
the identity proofing requirements at 40 CFR 3.2000(b)(5).  In this
document, we refer to these entities as “indirect reporters.”

Entities that opt to implement the local registration authority (LRA)
alternative for identity proofing must identify an individual who will
collect subscriber agreements from each individual that intends to use
an electronic signature device in reporting electronically to a
State/Local electronic document receiving system.  In this document, we
refer to these entities as “indirect reporting firms.”

The LRA must collect and store subscriber agreements from individuals in
his/her indirect reporting firm.  The LRA also must prepare an agreement
collection certification and submit a certification of receipt and
secure storage to the corresponding State/Local agency.

Sections 1 through 5 of this document describe the information
collection requirements covered in this ICR (e.g., in regard to need and
use of the information collected).  Section 6 estimates the annual
burden to respondents.  This ICR does not address the burden savings to
respondents in reporting electronically under EPA programs.  EPA’s
programs will amend their program-specific ICRs to address these
impacts.

CROMERR establishes requirements applicable to electronic reporting and
receiving systems, as specified.  Many of the activities to be conducted
by direct reporters will be determined by the instructions associated
with EPA’s electronic document receiving system.  Specifically, EPA
has developed an Agency-wide receiving system, the Central Data Exchange
(CDX), which guides direct reporters through the registration and
reporting procedures. In developing this ICR, EPA referred to the
regulatory text, as well as CDX, in describing direct reporters’
activities and associated burden.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)	NEED AND AUTHORITY FOR THE COLLECTION

EPA established the CROMERR requirements to ensure compliance with the
Government Paperwork Elimination Act (GPEA).  GPEA requires that Federal
agencies be prepared, by October 21, 2003, to allow persons who are
required to maintain, submit, or disclose information, the option of
doing so electronically, when practicable, as a substitute for paper;
and to use electronic authentication (electronic signature) methods to
verify the identity of the sender and the integrity of electronic
content.  GPEA specifically provides that electronic records, and their
related electronic signatures, are not to be denied legal effect,
validity, or enforceability merely because they are in electronic form.

(1)	Registering with EPA Electronic Document Receiving System

Regulated entities must initially register with the EPA electronic
document receiving system to establish a user account.  EPA needs the
registration information to identify the registrant, contact
information, and registrant’s organization.  Registrants also select a
password and user name during registration.  This information is needed
to ensure that only the registrant has access to his/her account.

Compliance with Identity Proofing Requirements

The identity proofing provisions in 40 CFR 3.2000(b)(5) are needed to
strengthen the non-repudiation provisions of CROMERR.  The electronic
signature agreement, required in Section 3.2000(b)(5)(v), establishes
that the signatory was informed of their obligation to keep the
signature device from compromise, by ensuring that it is not made
available to anyone else.  These provisions are intended to ensure that
the Federal laws regarding the falsification of information submitted to
the government still apply to any and all electronic transactions, and
that fraudulent electronic submissions will be prosecuted to the fullest
extent of the law.  In establishing clear requirements for electronic
reporting systems, CROMERR helps to minimize fraud by assuring that the
responsible individuals can be readily identified.

(3)	Approval of State/Local Electronic Document Receiving System
Applications

EPA needs information submitted by States/Locals in their program
modification applications to evaluate the States/Locals’ upgraded or
new electronic document receiving systems to ensure they satisfy the
criteria at 40 CFR 3.2000.

EPA also needs the information to evaluate whether the State/Local’s
modified program has been satisfactorily revised or modified in regard
to their electronic document receiving system.  In particular, the
application must include a certification that the State/Local has
sufficient legal authority provided by lawfully enacted or promulgated
statutes or regulations to implement the electronic reporting component
of its authorized program covered by the application; and to enforce the
affected programs using electronic documents collected under these
programs.  The certification must be signed by the governmental official
who is legally competent to certify with respect to legal authority on
behalf of their government.  In the case of a state, this official must
be the Attorney General or designee.  In the case of a tribe or local
government, this official must be the chief administrative official or
officer or designee.  As a legal matter, EPA’s position is that
Attorneys General or their designees are the only officials capable of
certifying with respect to their states’ legal authority.  Where there
are substantial administrative obstacles involving the Attorney General
in such certifications, EPA urges the State Attorney General to provide
for a legally competent designee who is available to participate in the
submission of the state’s application.

2(b)	PRACTICAL UTILITY AND USERS OF THE DATA

(1)	Registering with EPA Electronic Document Receiving System

Regulated entities must initially register with the EPA electronic
document receiving system to establish a user account and create a
password.  EPA uses the information to identify the registrant (e.g., by
name and/or organization), establish the account, and contact the
registrant if needed.  Regulated entities use the password to access
their account and to protect it from unauthorized use.

Compliance with Identity Proofing Requirements

EPA, States/Locals, and LRAs use the identity proofing information from
registrants to determine each registrant’s identity and relationship
to their regulated entity.  The information may be used in an EPA or
State/Local enforcement action to rebut a signatory’s attempt to
repudiate their electronic signature and/or other elements of the
document that was signed.

When EPA or State/Local agency receives a subscriber agreement,
certification of receipt and secure storage, or other identity-proofing
information, the agency will review, process, and file the submittal.
EPA or State/Local agency would then provide the registrant with access
to the electronic document receiving system (e.g., open its account) so
that it may begin using the electronic signature device in reporting
electronically.

(3)	Approval of State/Local Electronic Document Receiving System
Applications

EPA uses the information submitted by States/Locals in their program
modification applications to evaluate the States/Locals’ upgraded or
new electronic document receiving systems against the criteria at
40 CFR 3.2000(b)(1)-(5).  For example, EPA will review the application
to determine if the systems are able to generate data as needed, and in
a timely manner, including copy of record for each electronic document
received, sufficient to prove that the electronic document was not
altered without detection during transmission or at any time after
receipt.

EPA also reviews the application to ensure that the State/Local has
taken all necessary steps to modify its regulations and statutes, as
needed, so that it has authority to implement electronic reporting and
enforce the affected programs using electronic documents collected under
its programs.  This includes, among other things, an evaluation of the
Attorney General’s certification under 40 CFR 3.1000(b)(1)(i).

3.	  SEQ CHAPTER \h \r 1 NONDUPLICATION, CONSULTATIONS, AND OTHER
COLLECTION CRITERIA

3(a)	NONDUPLICATION

CROMERR establishes uniform, Agency-wide criteria for electronic
document receiving systems, thereby minimizing the potential for
duplication or redundancy across EPA or State/Local programs.  In
addition, electronic reporting is voluntary, and will likely be used by
facilities only if cost-effective and non-duplicative with their other
compliance activities.  CROMERR does not alter the reporting
requirements under existing regulations and statutes, and does not
affect whether a document must be created, submitted, or retained under
the existing provisions 40 CFR.

3(b)	PUBLIC NOTICE

	In compliance with the Paperwork Reduction Act of 1995 (PRA), EPA
issued a public notice in the Federal Register on November 4, 2014 (79
FR 65391).  The notice indicated that EPA was planning to submit an ICR,
“Cross-Media Electronic Reporting Rule” (EPA ICR No. 2002.06, OMB
Control No. 2025–0003), to the Office of Management and Budget (OMB)
for review and approval in accordance with the PRA.  The notice also
requested comments on the information collection and burden estimates
covered in the ICR.  The public comment period extended through  January
5, 2015.  EPA did not receive any written comments on the ICR in
response to the Federal Register notice.

3(c)	CONSULTATIONS

Most of the underlying assumptions in this ICR (e.g., hour and cost
burden estimates) are based on EPA consultations with industry and
States/Locals during the development of CROMERR and renewal of previous
CROMERR ICRs.  In developing this current ICR, EPA carefully reviewed
all of the ICR’s data and assumptions and determined that a few should
be strengthened based on additional consultations.

Table 1 identifies the organizations contacted.

Table 1

Organizations EPA Contacted during the Development of this ICR (February
2015)

Organization	Contact Name	Phone Number

Industry (i.e., Direct/Indirect Reporters)

3M	Linda Murray<PHONE_NUMBER>

Maersk Line, Limited	Larry Bowling<PHONE_NUMBER>

OVS	Ken Wessels<PHONE_NUMBER>

Shields Bag and Printing Company	Derek LaFramboise<PHONE_NUMBER>

State/Local Agencies

Arkansas Department of Environmental Quality	Letty Hardee<PHONE_NUMBER>

New York Department of Environmental Conservation	Robert Wither	(518)
402-8154

Ohio Environmental Protection Agency	Adele Vogelgesang<PHONE_NUMBER>

The following paragraphs summarize the feedback obtained on the burden
associated with various information collection activities.

Direct/Indirect Reporters

(a)	Identity Proofing Activities

Prepare and submit a non-electronic (paper) subscriber agreement.  EPA
received mixed feedback about the ICR’s original burden for preparing
and submitting a non-electronic (paper) subscriber agreement (i.e., 15
minutes or 0.25 hour per subscriber agreement) from the employee
registrants contacted.  One registrant indicated that the ICR’s
original burden estimate was a realistic industry average, while two
registrants disagreed with the burden estimate.  (One registrant did not
provide feedback on this information collection activity.)  The
registrants contacted suggested a revised burden estimate of 30 minutes
or 0.50 hour.  Based on the consultation information, the average burden
for preparing and submitting a non-electronic (paper) subscriber
agreement was estimated to be 25 minutes or 0.42 hour per subscriber
agreement.

Prepare and submit an electronic, reuse (consolidated), or third-party
subscriber agreement.  EPA received mixed feedback about the ICR’s
original burden for preparing and submitting an electronic, reuse
(consolidated), or third-party subscriber agreement (i.e., 10 minutes
or 0.17 hour per subscriber agreement) from the employee registrants
contacted.  One registrant indicated that the ICR’s original burden
estimate was a realistic industry average, while two registrants
disagreed with the burden estimate.  (One registrant did not provide
feedback on this information collection activity.)  The registrants
contacted suggested a revised burden estimate of 20 minutes or 0.33
hour.  Based on the consultation information, the average burden for
preparing and submitting an electronic, reuse (consolidated), or
third-party subscriber agreement was estimated to be 17 minutes or
0.28 hour per subscriber agreement.

File subscriber agreement.  EPA was informed that, generally, the
ICR’s original burden for filing a subscriber agreement
(i.e., 5 minutes or 0.08 hour per subscriber agreement) was a
realistic industry average.  However, one of the four registrants
contacted suggested a revised burden estimate of 15 minutes or 0.25
hour.  Based on the consultation information, the average burden for
filing a subscriber agreement was estimated to be 7 minutes or 0.12 hour
per subscriber agreement.

Report compromised or surrendered electronic signature device and
prepare/submit new subscriber agreement.  EPA was informed that,
generally, the ICR’s original burden for reporting a compromised or
surrendered electronic signature device and preparing/submitting a new
subscriber agreement (i.e., 5 minutes or 0.08 hour per subscriber
agreement) was a realistic industry average.  However, one of the four
registrants contacted suggested a revised burden estimate of 20 minutes
or 0.33 hour.  (One registrant did not provide feedback on this
information collection activity.)  Based on the consultation
information, the average burden for reporting a compromised or
surrendered electronic signature device and preparing/submitting a new
subscriber agreement was estimated to be 10 minutes or 0.17 hour per
subscriber agreement.

Contact the Help Desk for technical support.  EPA received mixed
feedback about the ICR’s original burden for contacting the Help Desk
for technical support (i.e., 3.6 minutes or 0.06 hour per subscriber
agreement) from the employee registrants contacted.  One registrant
indicated that the ICR’s original burden estimate was a realistic
industry average, while two registrants disagreed with the burden
estimate.  (One registrant did not provide feedback on this information
collection activity.)  The registrants contacted suggested a revised
burden estimate that ranged from 7.5 minutes to 10 minutes, or 0.13 hour
to 0.17 hour.  Based on the consultation information, the average burden
for contacting the Help Desk for technical support was estimated to be
7 minutes or 0.12 hour per subscriber agreement.

Prepare subscriber agreement and send to LRA.  EPA received mixed
feedback about the ICR’s original burden for preparing a subscriber
agreement and sending it to the LRA (i.e., 20 minutes or 0.33 hour per
subscriber agreement) from the employee registrants contacted.  One
registrant indicated that the ICR’s original burden estimate was a
realistic industry average, while one registrant disagreed with the
burden estimate.  (Two registrants did not provide feedback on this
information collection activity.)  The registrants contacted suggested a
revised burden estimate of 30 minutes or 0.50 hour.  Based on the
consultation information, the average burden for preparing a subscriber
agreement and sending it to the LRA was estimated to be 25 minutes or
0.42 hour per subscriber agreement.

Report breach of security or compromised/surrendered electronic
signature device to LRA.  EPA received mixed feedback about the ICR’s
original burden for reporting a breach of security or a
compromised/surrendered electronic signature device (i.e., 5 minutes or
0.08 hour per report) from the employee registrants contacted.  One
registrant indicated that the ICR’s original burden estimate was a
realistic industry average, while one registrant disagreed with the
burden estimate.  (Two registrants did not provide feedback on this
information collection activity.)  The registrants contacted suggested a
revised burden estimate of 15 minutes or 0.25 hour.  Based on the
consultation information, the average burden for reporting a breach of
security or a compromised/surrendered electronic signature device was
estimated to be 10 minutes or 0.17 hour per report.

 (b)	Local Registration Authority Activities

Develop a process or plan to implement the requirement, designate the
LRA, and submit LRA application to agency.  EPA was informed by the
employee registrants contacted that the ICR’s original burden for
developing a process or plan to implement the requirement, designate the
LRA, and submit an LRA application to an agency (i.e., 13 hours per
reporting firm) was a realistic industry average.  (Two registrants did
not provide feedback on this information collection activity.)  Based on
the consultation information, the average burden for developing a
process or plan to implement the requirement, designate the LRA, and
submit an LRA application to an agency was not revised and thus,
remained at 13 hours per reporting firm.

Register LRA with the electronic document receiving system.  EPA was
informed by the employee registrants contacted that the ICR’s original
burden for registering the LRA with the electronic document receiving
system (i.e., 10 minutes or 0.17 hour per reporting firm) was a
realistic industry average.  (Two registrants did not provide feedback
on this information collection activity.)  Based on the consultation
information, the average burden for registering the LRA with the
electronic document receiving system was not revised and thus, remained
at 10 minutes or 0.17 hour per reporting firm.

Re-designate LRA, due to turnover, and send application materials.  EPA
was informed by the employee registrants contacted that the ICR’s
original burden for re-designating an LRA, due to turnover, and sending
application materials (i.e., 1 hour per reporting firm) was a realistic
industry average.  (Two registrants did not provide feedback on this
information collection activity.)  Based on the consultation
information, the average burden for re-designating an LRA, due to
turnover, and sending application materials was not revised and thus,
remained at 1 hour per reporting firm.

Collect and securely store subscriber agreements.  EPA was informed by
the employee registrants contacted that the ICR’s original burden for
an LRA to collect and securely store subscriber agreements (i.e., 10
minutes or 0.17 hour per subscriber agreement) was a realistic industry
average.  (Two registrants did not provide feedback on this information
collection activity.)  Based on the consultation information, the
average burden for collecting and securely storing subscriber agreements
was not revised and thus, remained at 10 minutes or 0.17 hour per
subscriber agreement.

Prepare agreement collection certification after securely storing
subscriber agreements, and submit certification of receipt and secure
storage.  EPA was informed by the employee registrants contacted that
the ICR’s original burden for preparing an agreement collection
certification after securely storing subscriber agreements, and
submitting the certification of receipt and secure storage (i.e., 10
minutes or 0.17 hour per certification) was a realistic industry
average.  (Two registrants did not provide feedback on this information
collection activity.)  Based on the consultation information, the
average burden for preparing an agreement collection certification after
securely storing subscriber agreements, and submitting the certification
of receipt and secure storage was not revised and thus, remained at 10
minutes or 0.17 hour per certification.

(c)	On-Going Management Activities

Identify and resolve problems.  EPA was informed that, generally, the
ICR’s original burden for identifying and resolving problems (i.e., 1
hour per employee registrant) was a realistic industry average.
However, one of the four registrants contacted suggested a revised
burden estimate of 3 hours.  (One registrant did not provide feedback on
this information collection activity.)  Based on the consultation
information, the average burden for identifying and resolving problems
was estimated to be 1.67 hours per employee registrant.

State/Local Agencies

(a)	Identity Proofing Activities

Receive, process, review, approve and file a subscriber agreement.  EPA
was informed by two of the three state agencies contacted that the
ICR’s original burden for receiving, processing, reviewing, approving
and filing a subscriber agreement (i.e., 10 minutes or 0.17 hour per
subscriber agreement) was a realistic national average.  (One state
agency did not provide feedback on this information collection
activity.)  Based on the consultation information, the average burden
for receiving, processing, reviewing, approving and filing a subscriber
agreement was not revised and thus, remained at 10 minutes or 0.17 hour
per subscriber agreement.

(b)	Local Registration Authority Activities

Receive, process, review, and approve certification of receipt and
secure storage.  EPA was informed by one of the three state agencies
contacted that the ICR’s original burden for receiving, processing,
reviewing, and approving a certification of receipt and secure storage
(i.e., 10 minutes or 0.17 hour per certification) was a realistic
national average.  (The remaining two state agencies did not provide
feedback on this information collection activity.)  Based on the
consultation information, the average burden for receiving, processing,
reviewing, and approving a certification of receipt and secure storage
was not revised and thus, remained at 10 minutes or 0.17 hour per
certification.

Receive notification of breach of security or compromised/surrendered
electronic signature device, and take action.  EPA was informed by one
of the three state agencies contacted that the ICR’s original burden
for receiving a notification of breach of security or
compromised/surrendered electronic signature device, and taking action
(i.e., 1 hour per notification) was a realistic national average.  (The
remaining two state agencies did not provide feedback on this
information collection activity.)  Based on the consultation
information, the average burden for receiving a notification of breach
of security or compromised/surrendered electronic signature device, and
taking action was not revised and thus, remained at 1 hour per
notification.

Receive application to designate LRA.  EPA was informed by one of the
three state agencies contacted that the ICR’s original burden for
receiving an application to designate an LRA (i.e., 30 minutes or 0.50
hour per reporting firm) was a realistic national average.  (The
remaining two state agencies did not provide feedback on this
information collection activity.)  Based on the consultation
information, the average burden for receiving an application to
designate an LRA was not revised and thus, remained at 30 minutes or
0.50 hour per reporting firm.

(c)	On-Going Management Activities

Identify and resolve problems.  EPA was informed by two of the three
state agencies contacted that the ICR’s original burden for
identifying and resolving problems (i.e., 1 hour per employee
registrant) was a realistic national average.  (One state agency did not
provide feedback on this information collection activity.)  Based on the
consultation information, the average burden for identifying and
resolving problems was not revised and thus, remained at 1 hour per
employee registrant.

Respond to information requests.  EPA was informed by two of the three
state agencies contacted that the ICR’s original burden for responding
to information requests (i.e., 1.5 hours per employee registrant) was
a realistic national average.  (One state agency did not provide
feedback on this information collection activity.)  Based on the
consultation information, the average burden for responding to
information requests was not revised and thus, remained at 1.5 hours per
employee registrant.

(d)	State/Local Electronic Document Receiving System Application
Activities

Read the regulations.  EPA received mixed feedback about the ICR’s
original burden for reading the regulations (i.e., 1.5 hours per
State/Local agency) from the state agencies contacted.  One state agency
indicated that the ICR’s original burden estimate was a realistic
industry average, while one state agency disagreed with the burden
estimate.  (One state agency’s feedback on the burden estimate
included other activities and thus, was excluded from the analysis for
consistency purposes.)  The state agencies contacted suggested a revised
burden estimate of 1.5 hours.  Based on the consultation information,
the average burden for reading the regulations was estimated to be 2.26
hours per State/Local agency.

Upgrade existing electronic document receiving system or develop new
electronic document receiving system to meet 40 CFR 3.2000 and apply for
EPA program modification approval under 40 CFR 3.1000 (state agency).
EPA was informed by two of the three state agencies contacted that the
ICR’s original burden for upgrading an existing electronic document
receiving system or developing a new electronic document receiving
system to meet 40 CFR 3.2000 and applying for EPA program modification
approval (i.e., 331 hours per state agency) was a realistic national
average.  (One state agency’s feedback on the burden estimate seemed
to include other activities and thus, was excluded from the analysis for
consistency purposes.)  Based on the consultation information, the
average burden for upgrading an existing electronic document receiving
system or developing a new electronic document receiving system to meet
40 CFR 3.2000 and applying for EPA program modification approval was
estimated to be 331 hours per state agency.

Submit amendment to original application for EPA program modification
approval under 40 CFR 3.1000.  EPA was informed by one of the three
state agencies contacted that the ICR’s original burden for submitting
an amendment to the original application for EPA program modification
approval under 40 CFR 3.1000 (i.e., 24 hours per State/Local agency)
was a realistic national average.  (The remaining two state agencies did
not provide feedback on this information collection activity.)  Based on
the consultation information, the average burden for submitting an
amendment to the original application for EPA program modification
approval under 40 CFR 3.1000 was not revised and thus, remained at 24
hours per State/Local agency.

Submit notification to EPA about changes to laws, policies, or
electronic document receiving systems that have the potential to affect
program conformance with 40 CFR 3.2000.  EPA received mixed feedback
about the ICR’s original burden for submitting a notification to EPA
about changes to laws, policies, or electronic document receiving
systems that have the potential to affect program conformance with 40
CFR 3.2000 (i.e., 45 minutes or 0.75 hour per State/Local agency) from
the state agencies contacted.  One state agency indicated that the
ICR’s original burden estimate was a realistic industry average, while
one state agency disagreed with the burden estimate.  (One state agency
did not provide feedback on this information collection activity.)  The
state agencies contacted suggested a revised burden estimate of 22
hours.  Based on the consultation information, the average burden for
submitting a notification to EPA about changes to laws, policies, or
electronic document receiving systems that have the potential to affect
program conformance with 40 CFR 3.2000 was estimated to be 11.39 hours
per State/Local agency.

Cost for upgrading or developing electronic document receiving system
(state agency).  EPA was informed by one of the three state agencies
contacted that the ICR’s original cost estimate for upgrading or
developing an electronic document receiving system (i.e., $152,701 per
state agency) was a realistic national average.  However, the remaining
two state agencies disagreed with the cost estimate.  The state agencies
contacted suggested revised cost estimates that ranged from $300,000 to
$479,364.06.  Based on the consultation information, the average cost
for upgrading or developing an electronic document receiving system was
estimated to be $310,688 per state agency.

The above feedback is reflected in the burden assumptions of this ICR,
as appropriate.  Detailed information on EPA’s assumptions regarding
these and other activities are fully discussed in Section 6 of this
document.

3(d)	EFFECTS OF LESS FREQUENT COLLECTION

(1)	Registering with EPA Electronic Document Receiving System

Facilities must initially register with the EPA electronic document
receiving system to establish a user account.  Registration information
is collected at the time of registration (i.e., a one-time event) and
updated if needed.  Because it is a one-time activity, the information
cannot be collected less frequently.  If this information were not
collected, EPA would not have a way to learn the identity of the
registrant and establish its account.

Compliance with Identity Proofing Requirements

Facilities must comply with the identity proofing provisions of CDX and
40 CFR 3.2000(b)(5), as applicable.  These provisions provide that, in
the case of priority reports for which an electronic signature device
was used to create an electronic signature, a determination of identity
must be made before the electronic document is received.  It is critical
that registrants submit the identity proofing paperwork in advance of
their priority reports so that the Agency can establish a link between
each registrant and its electronic signature device to hold them
accountable for their submittals.  Facilities also must report any
compromise or surrender of its electronic signature device to EPA or
State/Local.

LRAs must report any breach of storage of its subscriber agreements.
These are as-needed submittals.  If these reports were not collected,
EPA and States/Locals would not have a way to learn about the signature
compromise/surrender or storage breaches.  Hence, they would not be in a
position to take follow up action as needed (e.g., to temporarily
prevent access to an account whose signature device has been
compromised).  This could result in the unauthorized use an electronic
signature device.

(3)	Approval of State/Local Electronic Document Receiving System
Applications

CROMERR sets forth timeframes for EPA receipt, review, and approval of
State/Local program modification applications to implement electronic
document receiving systems.  States/Locals that did not have an
electronic document receiving system in use or substantially developed
on or before October 13, 2005 must apply to EPA for program modification
approval before receiving electronic documents (40 CFR 3.10000(a)(2)).
If this frequency were not specified, EPA would not have assurance that
States/Locals are developing and using electronic document receiving
systems that comply with CROMERR’s provisions at 40 CFR 3.2000.

3(e)	GENERAL GUIDELINES

This ICR adheres to the guidelines stated in the PRA, OMB’s
implementing regulations, applicable OMB guidance, and EPA’s ICR
Handbook.

EPA notes that subscriber agreements must be kept on file until five
years after deactivation of the associated electronic signature device.
A five-year retention period is necessary to ensure that such records
are available in case of an EPA or State/Local enforcement action.  EPA
recognizes that a registrant may use an electronic signature device in
signing a range of enforcement-sensitive reports.  Certain reports may
have relevance to an enforcement action long after it is submitted to
EPA or State/Local.  Because of this, EPA needed to establish a
sufficiently long retention period for the subscriber agreements so that
they would available for such enforcement actions.

3(f)	CONFIDENTIALITY

If a confidentiality claim were asserted, EPA would treat the
information in accordance with the confidentiality regulations at 40 CFR
Part 2, Subpart B.  EPA also would ensure that the information
collection procedures comply with the Privacy Act of 1974 and the OMB
Circular 108.

3(g)	SENSITIVE QUESTIONS

Persons registering with CDX are asked to provide knowledge-based
information (e.g., date of birth) to ensure the security of their
password, user name, and other information supplied.  If the person
loses his/her password or user name, or otherwise needs to confirm
his/her identity to EPA, EPA could use the knowledge-based information
to confirm his/her identity.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	RESPONDENTS AND NAICS CODES

	The information collection requirements covered in this ICR will likely
have broad applicability across industries.  Refer to Appendix A for a
list of the North American Industry Classification System (NAICS) codes
associated with industries most likely affected by these requirements.

4(b)	INFORMATION REQUESTED

Following is a description of the data items and activities associated
with the information collection requirements covered in this ICR.  Refer
to Section 1(b) for the types of respondents examined in this
subsection.

(1)	Registering with EPA Electronic Document Receiving System

Facilities must register their employees with CDX before reporting
electronically to EPA.  The employees must update their registration
information if it changes.

(i)	Data Items:

An on-line registration application:

Registrant name.

Organization name.

Address.

Knowledge-based information (e.g., user-supplied secret
question-and-answer pair).

(ii)	Respondent Activities:

Facility employees must perform the following activities:

Log on to receiving system site and enter requested information.

Update the information, as needed.

(2)	Compliance with Identity Proofing Requirements

Direct reporters, indirect reporters, indirect reporting firms, and LRAs
must comply with the identity proofing provisions of CDX and CROMERR, as
applicable.  In addition, States/Locals that accept electronic documents
to satisfy reporting requirements under authorized or delegated
environmental programs that they administer must process, review, and
approve the identity proofing information submitted by indirect
reporters.

CDX and 40 CFR 3.2000(a)(2) require that any electronic document must
bear the valid electronic signature of a signatory if that signatory
would be required under the authorized program to sign the paper
document for which the electronic document substitutes, except as
otherwise specified.  In the case of an electronic document that must
bear electronic signatures of individuals as provided by CDX and 40 CFR
3.2000(a)(2), each signatory must sign either an electronic signature
agreement, or a subscriber agreement with respect to the electronic
signature device used to create their electronic signature on the
electronic document.

CDX and 40 CFR 3.2000(b)(5)(vii) require that the identity of the
individual uniquely entitled to use the device and their relation to any
entity for which he or she will sign electronic documents must be
determined with legal certainty by EPA or State/Local, as applicable.
In the case of priority reports, this determination must be made before
the electronic document is received, by means of:

Identifiers or attributes that are verified by attestation of
disinterested individuals to be uniquely true of the individual in whose
name the application is submitted, based on information or objects of
independent origin, at least one item of which is not subject to change
without governmental action or authorization.

A method of determining identity no less stringent than the one above.

Collection of either a subscriber agreement or a certification from a
LRA that such an agreement has been received and securely stored.

The term “subscriber agreement” means an electronic signature
agreement signed by an individual with a handwritten signature.  The
agreement must be signed by an individual with respect to an electronic
signature device that the individual will use to create his/her
electronic signature requiring such individual to protect the electronic
signature device from compromise; to promptly report to the agency or
agencies relying on the electronic signatures created any evidence
discovered that the device has been compromised; and to be held as
legally bound, obligated, or responsible by the electronic signatures
created as by a handwritten signature.  This agreement must be stored
until five years after the associated electronic signature device has
been deactivated.

The term “Local Registration Authority” means an individual who is
authorized by a State/Local to issue an agreement collection
certification, whose identity has been established by notarized
affidavit, and who is authorized in writing by a regulated entity to
issue agreement collection certifications on its behalf.  Once approved
by EPA or State/Local, the LRA would collect subscriber agreements from
each individual in the regulated entity that intends to use an
electronic signature device in reporting electronically to EPA or
State/Local electronic document receiving system.  The LRA would collect
and store the subscriber agreements in a manner that prevents authorized
or unauthorized access to these agreements by anyone other than the LRA.
 The LRA would prepare an agreement collection certification and submit
a certification of receipt and secure storage to the EPA or State/Local.

(i)	Data Items:

Compliance with identity proofing requirements by means of identifiers,
attributes, or alternative method:

Identifiers or attributes that are verified by attestation of
disinterested individuals to be uniquely true, as specified.

Other information necessary to determine identity.

Compliance with subscriber agreement provisions:

Subscriber agreement.

Report of compromised or surrendered electronic signature.

Submission of subscriber agreement to LRA:

Subscriber agreement.

Report of breach of security.

Report of compromised or surrendered electronic signature.

Designation of LRA:

Application to designate a LRA, including notarized affidavit and a
written authorization from the regulated entity to issue collection
agreement certifications on its behalf.

Collection of subscriber agreements by LRA:

Agreement collection certification.  This is a signed statement by which
a LRA certifies that a subscriber agreement has been received from a
registrant; the agreement has been stored in a manner that prevents
authorized or unauthorized access to these agreements by anyone other
than the LRA; and the LRA has no basis to believe that any of the
collected agreements have been tampered with or prematurely destroyed.

Certification of receipt and secure storage.

(ii)	Respondent Activities:

Direct and indirect reporters must perform the following activities, as
applicable:

Comply with requirements for identifier, attribute, or alternative
method:

Prepare and submit information on identifiers, attributes, or other
identity-proofing information.

Comply with subscriber agreement provisions:

Prepare and submit a subscriber agreement.

File subscriber agreement.

Prepare and submit new subscriber agreement, for employee turnover.

File new subscriber agreement, for employee turnover.

Contact the Help Desk for technical support.

Report compromised or surrendered electronic signature device and
prepare/submit new subscriber agreement if necessary.

Submit subscriber agreement to LRA:

Prepare subscriber agreement and send to LRA.

Prepare and submit new subscriber agreement to LRA, for employee
turnover.

Report breach of security or compromise/surrender of electronic
signature device.

Prepare and submit new subscriber agreement to LRA subsequent to breach
of security or compromise of electronic signature device, if necessary.

Conduct ongoing management:

Identify and resolve problems.

Indirect reporting firms and LRAs must perform the following activities,
as applicable:

Designating a LRA:

Develop a process or plan to implement the requirement, designate the
LRA, and submit LRA application to agency.

Register the LRA with the electronic document receiving system.

Redesignate LRA, due to turnover, and send application materials.

Register new LRA with electronic document receiving system.

Collect subscriber agreements from reporters:

Collect and securely store subscriber agreements

Prepare agreement collection certification after securely storing
subscriber agreements, and submit certification of receipt and secure
storage.

Collect and securely store subscriber agreements, for employee turnover.

Prepare agreement collection certification after securely storing
subscriber agreements, and submit certification of receipt and secure
storage, for employee turnover.

Collect and securely store subscriber agreements, for breach of
security/compromise of electronic signature device.

Prepare agreement collection certification after securely storing
subscriber agreements, and submit certification of receipt and secure
storage, for breach of security/compromise of electronic signature
device.

		State/Local agencies acting as regulators must perform the following
activities:

Collect identifiers, attributes, or alternative information:

Receive, process, review, and approve identifier, attribute, or
alternative information.

Collect subscriber agreements:

Receive, process, review, approve, and file new subscriber agreements.

Receive, process, review, approve, and file new subscriber agreements,
for employee turnover.

Receive, process, review, and approve report of compromise or surrender
of electronic signature device.

Collect submittals from LRAs:

Receive, process, review, and approve certification of receipt and
secure storage.

Receive, process, review and approve updated certification of receipt
and secure storage, for employee turnover.

Receive notification of breach of security or compromise/surrender of
electronic signature and take action.

Receive, process, review, and approve certification of receipt and
secure storage, for breach of security or compromise/surrender of
electronic signature device.

Collect applications for designation of LRAs:

Receive application to designate first-time LRA.

Receive application to designate LRA, for LRA turnover.

Conduct ongoing management:

Identify and resolve problems.

Respond to information requests.

(3)	Approval of State/Local Electronic Document Receiving System
Applications

	To obtain EPA approval of authorized program revision or modification
using procedures provided under 40 CFR 3.1000, a State /Local must
submit an application for program revision to EPA that includes the
elements specified in Sections 3.1000(b)(1)(i) through(iv).

	A State/Local that revises or modifies more than one (1) authorized
program for receipt of electronic documents, in lieu of paper documents,
may submit a consolidated application covering more than one authorized
program, provided the consolidated application complies with applicable
requirements for each authorized program.

	If the State/Local receives a notice from EPA that its application is
incomplete or does not satisfy the requirements at 40 CFR 3.2000, the
State/Local must submit an amendment to the original application that
includes the missing information.

	A State/Local that accepts electronic documents in lieu of paper
documents under an authorized program for which EPA has approved program
revisions or modifications under the procedures provided in 40 CFR
3.2000(a)(1) must keep EPA apprised of those changes to laws, policies,
or the electronic document receiving systems that have the potential to
affect program conformance with Section 3.2000.

	The State/Local program must satisfy the requirements at 40 CFR 3.2000.
 Pursuant to Section 3.2000, authorized programs that receive electronic
documents, in lieu of paper documents, to satisfy requirements under
such programs must use an acceptable electronic document receiving
system as specified and require that any electronic document must bear
valid electronic signatures to the same extent that the paper submission
for which it substitutes would bear handwritten signatures under the
authorized program, unless otherwise specified.  An electronic document
receiving system that receives electronic documents, submitted in lieu
of paper documents, to satisfy requirements under an authorized program
must be able to generate data with respect to any such electronic
document, as needed and in a timely manner, including a copy of record
for the electronic document, that meets the criteria specified at
Sections 3.2000(b)(1) through (5).

(i)	Data Items:

An application (or application amendment) for program revision that
includes the following elements:

A certification that the State/Local has sufficient legal authority
provided by lawfully enacted or promulgated statutes or regulations that
are in full force and effect on the date of certification to implement
the electronic reporting component of its authorized programs covered by
the application in conformance with Section 3.2000 and to enforce the
affected programs using electronic documents collected under these
programs,  together with copies of the relevant statutes and
regulations, signed by the State Attorney General or designee, or in the
case of an authorized tribal or local government program, by the Chief
Administrative Official or Officer of the governmental entity or
designee.

A listing of all State/Local electronic document receiving systems to
accept the electronic documents being addressed by the program
modification or revisions that are covered by the application, together
with a description for each such system that specifies how the system
meets the applicable criteria in Section 3.2000(b) with respect to those
electronic documents.

A schedule of upgrades for electronic document receiving systems that
have the potential to affect the program’s continued conformance with
Section 3.2000, if appropriate.

Other such information as the Administrator may request to fully
evaluate the application.

Appraisals to EPA of changes to laws, policies, or electronic document
receiving systems.

	(ii)	Respondent Activities:

State/Local agencies that are regulated entities must perform the
following activities:

Upgrade existing electronic document receiving system or develop new
electronic document receiving system to meet 40 CFR 3.2000 requirements
and apply for EPA program modification approval under 40 CFR 3.1000.

Submit amendment to original application for EPA program modification
approval under 40 CFR 3.1000.

Submit notification to EPA about changes to laws, policies, or
electronic document receiving systems that have the potential to affect
program conformance with 40 CFR 3.2000.

5.	THE INFORMATION COLLECTED:  AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	AGENCY ACTIVITIES

(1)	Registering with EPA Electronic Document Receiving System

	EPA activities associated with facility reporting to EPA’s electronic
document receiving system (i.e., CDX) include:

Develop, operate, and maintain CDX.

Compliance with Identity Proofing Requirements

	EPA activities associated with the identity proofing requirements
covered in this ICR include:

Collect identifiers or attributes or other information:

Receive, process, review, and approve identifier, attribute, or
alternative information.

Collect subscriber agreements:

Receive, process, review, approve, and file new subscriber agreements.

Receive, process, review, approve, and file new subscriber agreements,
for employee turnover.

Receive, process, review, and approve report of compromise or surrender
of electronic signature device.

Conduct ongoing management:

Identify and resolve problems.

Respond to information requests.

(3)	Approval of State/Local Electronic Document Receiving System
Applications

	EPA activities associated with the approval of State/Local electronic
document receiving systems include:

Process and file applications submitted by States/Locals seeking to
modify their programs, as required by 40 CFR 3.1000.

Process and file amendments to program modification applications
submitted by States/Locals.

Process and file appraisals of changes to laws, policies, or electronic
document receiving systems.

5(b)	COLLECTION METHODOLOGY AND MANAGEMENT

CDX serves as EPA’s primary gateway for electronic documents received
by EPA.  CDX functions include:

Access management allowing or denying an entity access to CDX.

Data interchange accepting and returning data via various file transfer
mechanisms.

Signature/certification management providing devices and required
scenarios for individuals to sign and certify what they submit.

Submitter and data authentication assuring that electronic signatures
are valid and data is uncorrupted.

Transaction logging providing date, time, and source information for
data received to establish “chain of custody.”

Acknowledgment and provision of copy of record providing the submitter
with confirmations of the data received.

Archiving placing files received and transmission logs into secure, long
term storage.

Error checking flagging obvious errors in documents and document
transactions, including duplicate documents and unauthorized
submissions.

Translating, forwarding, and converting submitted documents into formats
that will load to EPA databases, and forwarding them to the appropriate
systems.

Outreach providing education and other customer services to CDX users
(e.g., user manuals, Help Desk).

5(c)	SMALL ENTITY FLEXIBILITY

CROMERR allows electronic reporting by permitting the use of electronic
document receiving systems to receive electronic documents in
satisfaction of certain document submission requirements in EPA’s
regulations.  Electronic reporting under CROMERR is voluntary.  These
changes will reduce the burden on all affected entities, including small
businesses.  In addition, facilities will find that the initial set up
process requires little expenditure of time and resources, and in the
long run, this process will reduce the time spent on submissions each
year.

5(d)	COLLECTION SCHEDULE

The collection frequencies associated with CDX include the following:

Registrants must initially register with the electronic document
receiving system and obtain electronic signature certification, if
applicable.

Facilities must comply with requirements for determining the identity of
individuals who use electronic signature devices (e.g., prepare/submit
subscriber agreements or certification of receipt and secure storage),
before submitting electronic reports using the associated device.

Registrants must submit a notice of compromise or surrender of
electronic signature device promptly, should this occur.

States/Locals that did not have an electronic document receiving system
in use or substantially developed on or before October 13, 2005 must,
using specified procedures, apply for and receive EPA approval of
revisions or modifications to the authorized program before the program
may receive electronic documents in lieu of paper documents to satisfy
requirements of such program.

Within 75 calendar days of receiving an application for program revision
or modification, the Administrator will respond with a letter that
either notifies the State/Local that the application is complete or
identifies deficiencies in the application that render the application
incomplete.  The State/Local receiving a notice of deficiencies may
amend the application and resubmit it.  Within 30 calendar days of
receiving the amended application, the Administrator will respond with a
letter that either notifies the applicant that the amended application
is complete or identifies remaining deficiencies that render the
application incomplete.

Except where an opportunity for public hearing is required, if the
Administrator does not take any action on a specific request for
revision or modification of a specific authorized program addressed by
an application submitted within 180 calendar days of notifying the
State/Local that the application is complete, the specific request for
program revision or modification for the specific authorized program is
considered automatically approved by EPA at the end of the 180 calendar
days unless the review period is extended at the request of the
State/Local submitting the application.

If a State/Local submits material to amend its application after the
date that the Administrator sends notification that the application is
complete, this new submission will constitute withdrawal of the pending
application and submission of a new, amended application for program
revision or modification, and the 180-day time period will begin again
only when the Administrator makes a new determination and notifies the
State/Local under that the amended application is complete.

6.	ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a)	ESTIMATING RESPONDENT BURDEN HOURS

Exhibit 1 provides estimates of the respondent hourly burden associated
with the information collection requirements covered in this ICR.  The
exhibit includes burden hours (total and by labor type) per respondent,
as well as the overall burden hours for all respondents.  The majority
of the hour estimates in Exhibit 1 are based on the Agency’s technical
background document, Cross Media Electronic Reporting Rule Cost Benefit
Analysis, and consultations with industry and states.

	6(b)	ESTIMATING RESPONDENT COSTS

Exhibit 1 provides estimates of the annual respondent costs associated
with the information collection requirements covered in this ICR.  These
costs are based on the cost of labor, capital, and operation and
maintenance (O&M).

(1)	Labor Costs

	Using the total burden hours discussed in Section 6(a) and the hourly
respondent labor costs outlined in this section, Exhibit 1 illustrates
the labor costs associated with the information collection requirements
covered in this ICR.

Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and

Local Registration Authorities

	EPA estimates an average hourly respondent labor cost (including fringe
and overhead) of $61.63 for legal staff, $39.50 for managerial staff,
$39.17 for technical staff, and $17.23 for clerical staff.  These
respondent labor costs were obtained from the previously approved
CROMERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and
updated to 2014 levels using Employment Cost Indexes developed by the
Bureau of Labor Statistics.

State/Local Agencies

	EPA estimates an average hourly respondent labor cost (including fringe
and overhead) of $41.13 for legal staff, $41.13 for managerial staff,
$31.15 for technical staff, and $14.78 for clerical staff.  These
respondent labor costs were obtained from the previously approved
CROMERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and
updated to 2014 levels using Employment Cost Indexes developed by the
Bureau of Labor Statistics.

(2)	Capital Costs

Capital costs usually include any produced physical good needed to
provide the needed information, such as machinery, computers, and other
equipment.

Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and

Local Registration Authorities

	EPA does not anticipate that direct reporters, indirect reporters,
indirect reporting firms, and LRAs will incur capital costs in carrying
out the information collection requirements covered in this ICR.

State/Local Agencies

	EPA anticipates that State/Local agencies will incur capital costs in
upgrading their existing electronic document receiving systems or
developing new electronic document receiving systems to satisfy CROMERR
standards at 40 CFR 3.2000 (e.g., copy of record, Secure Sockets Layer
(SSL), e-mail notification, electronic signature, electronic signature
agreement).  In particular, EPA estimates that each state agency will
incur a cost of $310,688 and that each local agency will incur a cost of
$57,996.  The capital costs for state agencies were obtained from
consultations (refer to Section 3(c) of this document).  The capital
costs for local agencies were obtained from the previously approved
CROMERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and
updated to 2014 levels using Consumer Price Indexes developed by the
Bureau of Labor Statistics.  The above capital costs are shown in
Exhibit 1 for all applicable respondent activities.

	EPA notes that capital costs for local agencies are estimated to be
lower than the capital costs for state agencies because local agencies
are expected to have simpler electronic document receiving systems that
cover fewer programs and fewer electronic reports than state systems.
For example, EPA has received only one application from a local agency
under CROMERR, and that system only accepts reports under one authorized
program.

(3)	Operation and Maintenance Costs

O&M costs are those costs associated with an information collection
requirement incurred continually over the life of the ICR.

Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and

Local Registration Authorities

O&M costs include:

EPA estimates that employee registrants that submit subscriber
agreements to EPA or States/Locals will incur a cost of $3.82 to mail a
one-ounce letter by certified mail (i.e., $0.49 for first-class letter
postage, $3.30 for the certified-mail fee, and $0.03 for standard
business envelope)., ,

EPA estimates that employee registrants that submit subscriber
agreements to their LRA will incur a cost of $0.52 to mail a one-ounce
letter using first-class mail (i.e., $0.49 for first-class letter
postage and $0.03 for standard business envelope).,

EPA estimates that indirect reporting firms will incur a cost of $2.78
for obtaining a notarized affidavit to establish the identity of a LRA.
This O&M cost was obtained from the previously approved CROMERR ICR
(i.e., EPA ICR Number 2002.05, dated June 22, 2011), and updated to
2014 levels using Consumer Price Indexes developed by the Bureau of
Labor Statistics.

	The above O&M costs are shown in Exhibit 1 for all applicable
respondent activities.

State/Local Agencies

For State/Local agencies, O&M costs include mailing costs.  In
particular, EPA estimates that State/Local agencies submitting
documentation to EPA (e.g., applications for program modification
approval under 40 CFR 3.1000) will incur a cost of $6.09 to mail a
nine-ounce large envelope by certified mail ($2.66 for first-class large
envelope postage, $3.30 for the certified-mail fee, and $0.13 for
catalog envelope)., ,   These O&M costs are shown in Exhibit 1 for all
applicable respondent activities.

6(c)	ESTIMATING AGENCY HOUR AND COST BURDEN

EPA estimates the Agency hour and cost burden associated with the
information collection requirements covered in this ICR in Exhibit 2.
As shown in the exhibit, EPA estimates an average hourly labor cost of
$65.58 for legal staff (GS-14, Step 5), $55.50 for managerial staff
(GS-13, Step 1), $46.67 for technical staff (GS-12, Step 1), and  $23.68
for clerical staff (GS-06, Step 1).  To derive these hourly estimates,
EPA referred to the General Schedule (GS) Salary Table 2014.  This
publication summarizes the unloaded (base) hourly rate for various labor
categories in the Federal government.  EPA then applied the standard
government overhead factor of 1.6 to the unloaded rate to derive loaded
hourly rates.

EPA estimates that, each year, the Agency will incur a capital cost of
$173,600 in CDX development, operation, and maintenance activities.
This capital cost is shown in Exhibit 2.

O&M costs include electronic transaction fees associated with the
processing of electronic subscriber agreements (ESA) by a third party
vendor.  In particular, EPA estimates that the Agency will incur an
electronic transaction cost of $0.61 per subscriber agreement.  This O&M
cost is shown in Exhibit 2 for all applicable activities.

6(d)	ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND COST BURDEN

In this section, EPA first describes the estimated respondent universe.
EPA then estimates the annual burden to respondents under the
information collection requirements covered in this ICR.

EPA notes that, as used in this document, the term “respondent”
includes:

Direct reporters, indirect reporters, indirect reporting firms, and LRAs
complying with the registration and identity proofing requirements
covered in this ICR, as applicable.  This includes:

Private sector entities; and

State/Local agencies that are regulated entities.

State/local agencies administering electronic document receiving systems
subject to CROMERR.  In this document, we refer to these respondents as
“State/Local agencies acting as regulators.”

State/local agencies seeking EPA approval to allow electronic reporting
under CROMERR.  In this document, we refer to these respondents as
“State/Local agencies that are regulated entities.”

(1)	Respondent Universe

EPA estimates that, in total, 102,387 respondents will be subject to the
information collection requirements covered in this ICR.  This includes
77,482 direct reporters, 24,834 indirect reporters, 48 State/Local
agencies acting as regulators, and 23 State/Local agencies that are
regulated entities.  The following paragraphs provide additional
information on how these respondent universe estimates were derived.

Direct Reporter Employees

EPA estimates that, each year, 77,482 direct reporters will be subject
to the information collection requirements covered in this ICR.  This
includes 55,483 direct reporter employees expected to register with CDX
and 21,999 direct reporters expected to submit subscriber agreements.

Table 2 presents information on the annual number of employee
registrants expected to register with CDX during the three-year period
covered by the ICR.  As shown in the table, EPA estimates that, on
average, 55,483 employees will register with CDX each year.

Appendix B provides detailed information on the methodology used to
estimate the average annual number of direct reporters expected to
register with the CDX during the three-year period covered by this ICR.

Table 2

Annual Number of Direct Reporter Employees Expected to Register with

EPA’s CDX during the Three-Year Period Covered by the ICR

Respondent Universe	Average Annual Number of New Employee Registrants a

Private Sector Entities	47,772

State/Local Agencies that are Regulated Entities	7,711

Total	55,483

a Federal government employees are not reflected in the table because
they are exempt from ICR requirements.

Table 3 presents information on the estimated annual number of
subscriber agreements to be submitted to EPA during the three-year
period covered by the ICR.  As shown in the table, direct reporters have
various options for complying with the subscriber agreement requirements
covered in this ICR:

Paper subscriber agreement.  Direct reporters have the option of
preparing and mailing a paper subscriber agreement (i.e., a non-ESA).

Electronic subscriber agreement (ESA).  Direct reporters have the option
of completing and submitting an ESA directly to CDX (i.e., without using
a third party vendor).  This eliminates the requirement to prepare and
mail new paper subscriber agreements.

Reuse (Consolidated) ESA.  Direct reporters now have the option of
“reusing” an ESA.  CDX has the ability to recognize when a
registrant has already provided sufficient forensic evidence through
wet-ink signature, organization information, and audit information tying
forensic evidence to CDX credentials in order to allow reuse of the
forensic evidence and accept a digitally signed (electronic) signature
using the registrant’s existing CDX credential.  This eliminates the
requirement to prepare and mail new paper subscriber agreements.

Third Party ESA.  Direct reporters now have the option of completing and
submitting an ESA through a third party vendor.  CDX provides a
voluntary method for real-time identity proofing using a third party
vendor to validate government identification (ID) and additional
personal information in compliance with OMB Memorandum M-04-04, while
retaining repeatable digital evidence of validation using cryptographic
hash technology and not retaining the highly sensitive personally
identifying information.  The third party process validates both
identity and business affiliation.  This eliminates the requirement to
prepare and mail new paper subscriber agreements.

Appendix B provides detailed information on the methodology used to
estimate the average annual number of subscriber agreements to be
submitted to EPA during the three-year period covered by this ICR.

Table 3

Annual Number of Subscriber Agreements to Be Submitted to EPA

during the Three-Year Period Covered by the ICR a

Type of Subscriber Agreement	Annual Number of

Subscriber Agreements b, c	Average

	2015	2016	2017

	Private Sector Entities

Non-ESA Registrants	1,696	1,867	1,856	1,806

ESA Registrants	8,701	9,693	9,792	9,395

Reuse (Consolidated) ESA Registrants	1,040	506	68	538

Third Party ESA Registrants	6,476	6,872	8,256	7,201

Subtotal	17,913	18,938	19,972	18,941

State/Local Agencies that Are Regulated Entities

Non-ESA Registrants	274	301	300	292

ESA Registrants	1,404	1,565	1,581	1,517

Reuse (Consolidated) ESA Registrants	168	82	11	87

Third Party ESA Registrants	1,045	1,109	1,333	1,162

Subtotal	2,891	3,057	3,225	3,058

Total

Non-ESA Registrants	1,970	2,168	2,156	2,098

ESA Registrants	10,105	11,258	11,373	10,912

Reuse (Consolidated) ESA Registrants	1,208	588	79	625

Third Party ESA Registrants	7,521	7,981	9,589	8,364

Total	20,804	21,995	23,197	21,999

a Table includes rounding error.

a Table contains data provided by EPA’s Office of Information
Collection (OIC), and are current as of August 8, 2014.

c Federal government employees are not reflected in the table because
they are exempt from ICR requirements.

Indirect Reporter Employees

Table 4 presents information on the annual number of employee
registrants expected to register and comply with identify proofing
requirements of State/Local electronic document receiving systems during
the three-year period covered by the ICR.  As shown in the table, EPA
estimates that, on average, 24,834 employees from indirect reporting
facilities will register and comply with identify proofing requirements
of State/Local electronic document receiving systems each year.

For indirect reporters, EPA assumes that only a portion of employee
registrants from medium-size and large firms will use the LRA
alternative.  The remaining facility employees will comply with the
subscriber agreement provisions.  Thus, in order to perform the
analysis, EPA categorized employee registrants based on the size of
their firms (i.e., small firm or medium-size and large firm).  Table 4
presents information on the annual number of employee registrants by
type of firm.

As shown in Table 4, EPA estimates that, on average, 13,372 employees
from small firms and 11,462 employees from medium-size and large firms
will register and comply with identify proofing requirements of
State/Local electronic document receiving systems each year.

Appendix C provides detailed information on the methodology used to
estimate the average annual number of indirect reporters for the
three-year period covered by this ICR.

Table 4

Annual Number of Indirect Reporter Employees Expected to Register and
Comply with

Identify Proofing Requirements during the Three-Year Period Covered by
the ICR

Type of Firm	Average Annual Number of Employee Registrants a

Private Sector Entities

Small Firms	11,514

Medium-Size and Large Firms	9,869

Subtotal	21,383

State/Local Agencies that are Regulated Entities

Small Firms	1,858

Medium-Size and Large Firms	1,593

Subtotal	3,451

Total

Small Firms	13,372

Medium-Size and Large Firms	11,462

Total	24,834

a Federal government employees are not reflected in the table because
they are exempt from ICR requirements.

Indirect Reporting Firms

As shown in Table 4, EPA estimates that, on average, 13,372 employees
from small indirect reporting firms will register and comply with
identify proofing requirements of State/Local electronic document
receiving systems each year.  Each small firm is expected to have an
average of three employees, for a total of 4,457 small firms (i.e.,
13,372 employees ÷ 3 employees/firm).

EPA also estimates that, on average, 11,462 employees from medium-size
and large indirect reporting firms will register with State/Local
electronic document receiving systems each year.  Each medium-size and
large firm is expected to have an average of 18 employees, for a total
of 637 medium-size and large firms (i.e., 11,462 employees ÷ 18
employees/firm).

State/Local Agencies Acting as Regulators

Based on data from EPA’s CROMERR Program and Stakeholder Management
(PSM) System, EPA estimates that, currently, 48 State/Local agencies
administer electronic document receiving systems subject to CROMERR.

States/Locals Agencies That Are Regulated Entities

Based on information currently available to EPA on the submission and
approval of program modification applications under 40 CFR 3.1000 (i.e.,
CROMERR applications), EPA estimates that, on average,
four States/Locals (i.e., 3 state agencies and 1 local agency) will
upgrade their existing electronic document receiving systems or develop
new electronic document receiving systems and submit CROMERR
applications each year.

EPA also estimates that, on average, 15 States/Locals (i.e., 15 state
agencies and 0 local agencies) will submit amendments to their original
CROMERR applications each year.

In addition, EPA estimates that, on average, 4 States/Locals (i.e., 4
state agencies and 0 local agencies) will submit notifications to EPA
about changes to laws, policies, or electronic document receiving
systems each year.

Based on the above information, EPA estimates that, each year, 23
State/Local agencies will be regulated entities during the three-year
period covered by this ICR.

(2)	Annual Respondent Burden (Exhibit 1)

(a)	Registering with EPA Electronic Document Receiving System – Direct
Reporters

EPA estimates that, on average, 55,483 employees of direct reporting
facilities will register with EPA’s electronic document receiving
system each year.  EPA also estimates that, of the 55,483 employee
registrants, approximately 10 percent (or5,548) will need to update
their registration information each year.

(b)	Compliance with Identity Proofing Requirements – Direct Reporters

The following paragraphs discuss the assumptions associated with
compliance with the identity proofing requirements by direct reporters.

Comply with Requirements for Identifier, Attribute, or Alternative
Method

EPA does not anticipate that direct reporters will prepare and submit
information on identifiers or attributes, or other identity-proofing
information.

Comply with Subscriber Agreement Provisions

EPA assumes that all direct reporters will comply with the subscriber
agreement requirements.

Non-ESA Registrants.  EPA estimates that, on average, employee
registrants from direct reporting facilities will prepare, submit, and
file a total of 2,097 paper subscriber agreements each year.  EPA also
estimates that, of the 2,097 paper subscriber agreements prepared each
year, 89 percent (1,867) will be from new and existing employee
registrants (e.g., employees registering for the first time with a data
flow); 10 percent (209) will be associated with employee turnover, which
requires the submittal of a new subscriber agreement by the employee
replacement; and one percent (21) will be associated with a compromised
electronic signature, which requires the submittal of a new subscriber
agreement.  EPA anticipates that all employee registrants preparing a
paper subscriber agreement will contact the Help Desk for technical
support.

ESA Registrants.  EPA estimates that, on average, employee registrants
from direct reporting facilities will prepare, submit, and file a total
of 10,912 ESAs each year.  EPA also estimates that, of the 10,912 ESAs
prepared each year, 89 percent (9,712) will be from new and existing
employee registrants (e.g., employees registering for the first time
with a data flow); 10 percent (1,091) will be associated with employee
turnover, which requires the submittal of a new subscriber agreement by
the employee replacement; and one percent (109) will be associated with
a compromised electronic signature, which requires the submittal of a
new subscriber agreement.  EPA anticipates that all employee registrants
preparing an ESA will contact the Help Desk for technical support.

Reuse (Consolidated) ESA Registrants.  EPA estimates that, on average,
625 employee registrants from direct reporting facilities will reuse
their ESA each year.  EPA also estimates that, of the 625 reuse
(consolidated) ESAs, 89 percent (556) will be from existing employee
registrants (e.g., existing employee registrants registering for the
first time with a data flow); 10 percent (63) will be associated with
employee turnover, which requires the submittal of a new subscriber
agreement by the employee replacement; and one percent (6) will be
associated with a compromised electronic signature, which requires the
submittal of a new subscriber agreement.  EPA anticipates that all
employee registrants reusing an ESA will contact the Help Desk for
technical support.

Third Party ESA Registrants.  EPA estimates that, on average, employee
registrants from direct reporting facilities will prepare, submit, and
file a total of 8,364 third party ESAs each year.  EPA also estimates
that, of the 8,364 third party ESAs prepared each year, 89 percent
(7,444) will be from new and existing employee registrants (e.g.,
employees registering for the first time with a data flow); 10 percent
(836) will be associated with employee turnover, which requires the
submittal of a new subscriber agreement by the employee replacement; and
one percent (84) will be associated with a compromised electronic
signature, which requires the submittal of a new subscriber agreement.
EPA anticipates that all employee registrants preparing a third party
ESA will contact the Help Desk for technical support.

Conduct On-Going Management

EPA assumes that, of the 21,999 employee registrants from direct
reporting facilities, three percent (660) will have to work with EPA to
resolve problems involving their agreements or certifications each year.

(c)	Compliance with Identity Proofing Requirements – Indirect
Reporters

The following paragraphs discuss the assumptions associated with
compliance with the identity proofing requirements by indirect
reporters.

Comply with Requirements for Identifier, Attribute, or Alternative
Method

EPA does not anticipate that indirect reporters will prepare and submit
information on identifiers or attributes, or other identity-proofing
information.

Comply with Subscriber Agreement Provisions

For indirect reporters, EPA assumes that all employee registrants from
small firms (13,372) and 98 percent of employee registrants from
medium-size and large firms (11,462 x 0.98 =11,233) will comply with the
subscriber agreement requirements.  In addition, EPA estimates that
indirect reporters submit information to 1.3 State/Local electronic
document receiving systems, on average; hence, their employees must
submit subscriber agreements for 1.3 receiving systems, on average.  EPA
assumes that all employee registrants from indirect reporting facilities
will submit paper subscriber agreements.

Based on the above assumptions, EPA estimates that, on average, employee
registrants from indirect reporting facilities will prepare, submit, and
file a total of  31,986 subscriber agreements each year (i.e., [13,372
small firm employees + 11,233 medium-size and large firm employees] x
1.3 subscriber agreements/employee).

EPA also estimates that, of the 31,986 subscriber agreements prepared
each year, 89 percent ( 28,468) will be from new and existing employee
registrants (e.g., employees registering for the first time with a data
flow); 10 percent ( 3,199) will be associated with employee turnover,
which requires the submittal of a new subscriber agreement by the
employee replacement; and one percent (320) will be associated with a
compromised electronic signature, which requires the submittal of a new
subscriber agreement

EPA anticipates that all employee registrants preparing a subscriber
agreement will contact the Help Desk for technical support.

Submit Subscriber Agreements to Local Registration Authority

EPA assumes that two percent of medium-size and large firms will use the
LRA alternative.  EPA also assumes that indirect reporting firms submit
information to 1.3 State/Local electronic document receiving systems, on
average; hence, their employees must submit subscriber agreements for
1.3 receiving systems, on average.  Based on these assumptions, EPA
estimates that, on average, employees from indirect reporting firms will
prepare and send to their LRA a total of 298 subscriber agreements each
year (i.e., [11,462 medium-size and large firm employees x 0.02] x 1.3
subscriber agreements/employee).

EPA estimates that, of the 298 subscriber agreements prepared each year,
89 percent (265) will be from new employee registrants; 10 percent (30)
will be associated with employee turnover, which requires the submittal
of a new subscriber agreement by the employee replacement; and one
percent (3) will be associated with a compromised electronic signature,
which requires the submittal of a new subscriber agreement.

Conduct On-Going Management

EPA assumes that, of the 24,605 employee registrants from indirect
reporting facilities (13,372 + 11,233 = 24,605), three percent (738)
will have to work with States/Locals to resolve problems involving their
agreements each year.

(c)	Implementation of Local Registration Authority Alternative –
Indirect Reporting Firms and Local Registration Authorities

The following paragraphs discuss the assumptions associated with
implementation of the LRA alternative by indirect reporting firms and
LRAs.

Designating a Local Registration Authority

As stated above, EPA assumes that two percent of medium-size and large
indirect reporting firms (637 x 0.02 =13) will use the LRA alternative.
These firms will develop a process or plan to implement the LRA
alternative, designate the LRA, submit the LRA application to the
agency, and register the LRA with the electronic document receiving
system.

Of the 13 medium-size and large indirect reporting firms that will use
the LRA alternative, two percent (1) will need to redesignate the LRA
annually due to turnover, which requires registration of the new LRA
with the electronic document receiving system.

Collect Subscriber Agreements from Reporters

EPA estimates that, on average, LRAs will collect a total of 298
subscriber agreements each year.  Of these 298 subscriber agreements,
265 will be from new employee registrants, 30 will be associated with
employee turnover, and 3 will be associated with a compromised
electronic signature.  For each of these subscriber agreements, LRAs
will need to prepare an agreement collection certification after
securely storing the subscriber agreements, and submit a certification
of receipt and secure storage.

(d)	Compliance with Identity Proofing Requirements – State/Local
Agencies Acting as Regulators

Collect Identifier, Attribute, or Alternative Information

EPA does not anticipate that indirect reporters will prepare and submit
information on identifiers or attributes, or other identity-proofing
information.

Collect Subscriber Agreements

EPA estimates that, on average, employee registrants from indirect
reporting facilities will prepare, submit, and file a total of
31,987subscriber agreements each year.  This includes 28,468 subscriber
agreements from new employee registrants, 3,199 subscriber agreements
associated with employee turnover, and 320 subscriber agreements
associated with a compromised electronic signature.  State/Local
agencies will receive, process, review, approve, and file all these
subscriber agreements.

Collect Submittals from Local Registration Authority

EPA estimates that, each year, employee registrants from indirect
reporting facilities will submit 298 subscriber agreements to their
LRAs.  This includes 265 subscriber agreements from new employee
registrants, 30 subscriber agreements associated with employee turnover,
and 3 subscriber agreements associated with a compromised electronic
signature.  State/Local agencies will need to receive, process, review,
and approve the certification of receipt and secure storage submitted by
the LRAs.

Collect Applications for Designation of Local Registration Authority

EPA estimates that, each year, 13 indirect reporting firms will use the
LRA alternative.  EPA also estimates that, each year, one of these firms
will need to redesignate the LRA due to turnover.  State/Local agencies
will need to receive and approve these LRA applications.

Conduct On-Going Management

EPA estimates that, each year, State/Local agencies will have to work
with 738 employee registrants to resolve problems involving their
agreements or certifications, and respond to information requests.

(e)	Approval of State/Local Electronic Document Receiving System

Applications – State/Local Agencies that Are Regulated Entities

Read the Regulations

EPA estimates that, on average, 23 States/Locals will submit
documentation to EPA associated with the approval of State/Local
electronic document receiving systems each year.  These States/Locals
are expected to read the regulations at 40 CFR Part 3.

Submit Electronic Document Receiving System Application

EPA estimates that, on average, 4 States/Locals will upgrade their
existing electronic document receiving systems or develop new electronic
document receiving systems and submit a CROMERR application each year.
This includes 3 state agencies and 1 local agency.

Submit Amendment to Original Application

EPA estimates that, on average, 15 states will submit amendments to
their original CROMERR application each year.  EPA does not anticipate
that Locals will submit amendments to their original CROMERR
applications during the three-year period covered by this ICR.

Submit Notification on Changes to Laws, Policies, or Electronic Document
Receiving System

EPA estimates that, on average, 4 state agencies will submit a
notification about changes to laws, policies, or electronic document
receiving systems that have the potential to affect program conformance
with 40 CFR 3.2000.  EPA does not anticipate that local agencies will
submit this notification during the three-year period covered by this
ICR.

  SEQ CHAPTER \h \r 1 	6(e)	BOTTOM LINE HOUR AND COST BURDEN

(1)	Respondent Tally

Exhibits 3 and 4 summarize the total annual respondent hour and cost
burden associated with all the requirements covered in this ICR.
Exhibit 3 presents information on the total estimated respondent hour
and cost burden for all respondents.  Exhibit 4 presents information on
the total estimated respondent hour and cost burden, by type of
respondent.  As used in this document, the term “respondent”
includes private sector and State/Local entities.  As shown in the
exhibits, EPA estimates the annual respondent burden to be 49,604 hours
and $2,995,642.  The bottom line burden to respondents over three years
is estimated to be 148,812 hours and $8,986,926.

(2)	Agency Tally

Exhibit 5 summarizes the total annual EPA hour and cost burden
associated with all the requirements covered in this ICR.  As shown in
the exhibit, EPA estimates the annual agency burden to be 22,393 hours
and $1,226,664.  The bottom line burden to the agency over three years
is estimated to be 67,179 hours and $3,679,992.

6(f)	REASONS FOR CHANGE IN BURDEN

The annual respondent burden estimate in the previously approved CROMERR
ICR (EPA ICR Number 2002.05) was 39,763 hours.  The annual respondent
burden estimate for this ICR (EPA ICR Number 2002.06) is 49,604 hours.
This represents an increase of 9,841 hours.

This increase in burden occurred primarily because, in developing this
ICR, EPA carefully reviewed the respondent activities.  Based on
consultations with industry and state agencies, EPA increased some of
the hourly burden estimates.  EPA believes that the revised burden
estimates included in this ICR reflect a realistic average.

Note, however, that the increase in burden associated with the revised
hourly burden estimates was offset by a decrease in the total annual
number of employees complying with CROMERR’s identity proofing
requirements, from 58,996 employees (i.e., 33,072 direct reporters +
25,924  indirect reporters) in the previously approved ICR to 46,833
employees (i.e., 21,999 direct reporters + 24,834  indirect reporters)
in this ICR.  In estimating the annual number of employees complying
with the CROMERR’s identity proofing requirements for this ICR, EPA
was able to take advantage of improvements in data software and hardware
capabilities and thus, develop estimates based on actual data instead of
the complex calculations used in the previously approved ICR.  In
particular, EPA was able to obtain actual numbers and growth rates for
the annual number of subscriber agreements submitted to CDX over the
past several years.  These data were used to improve the estimate for
the annual number of subscriber agreements submitted by direct
reporters.  EPA believes that the respondent estimates included in this
ICR are a reasonable approximation of the actual respondent universe.

All changes in burden are considered “adjustments,” since they
resulted from changes in the size of the respondent universe and
refinements to the assumptions used in the development of the ICR.

6(g)	PUBLIC BURDEN STATEMENT

(1)	Registering with EPA Electronic Document Receiving System – Direct
Reporters

The reporting burden is estimated to be 10 minutes for a facility
employee to register with CDX.  This includes time for preparing the
on-line application and calling the CDX Help Desk.  There are no
recordkeeping requirements associated with registering with the CDX
application.

Compliance with Identity Proofing Requirements – Direct and Indirect
Reporters

The reporting burden is estimated to be about 80 minutes for a facility
employee to prepare and submit identifier, attribute, or alternative
information.  There are no recordkeeping requirements associated with
this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to range from 17 minutes to 25 minutes
for a facility employee to prepare and submit a subscriber agreement.
The recordkeeping burden for the facility employee is estimated to be
about 7 minutes to file an agreement on site.

Implementation of Local Registration Authority Alternative – Indirect
Reporting Firms and Local Registration Authorities

	The reporting burden is estimated to be 13 hours for a firm to develop
a process or plan to use the LRA alternative, designate the LRA, submit
the LRA application to the agency, and register the LRA with the
electronic document receiving system.  There are no recordkeeping
requirements associated with this requirement, and as such, there is no
recordkeeping burden.

The reporting burden is estimated to be 1 hour for a firm to redesignate
the LRA, due to turnover; send the LRA application to the agency; and
register the new LRA with the electronic document receiving system.
There are no recordkeeping requirements associated with this
requirement, and as such, there is no recordkeeping burden.

	The reporting burden is estimated to be 10 minutes for a LRA to prepare
and submit a certification of receipt and secure storage after receiving
a subscriber agreement.  The recordkeeping burden is estimated to be 10
minutes for a LRA to compile subscriber agreements from employee
registrants within the LRA’s firm and place them in secure storage.

Compliance with Identity Proofing Requirements – State/Local Agencies
Acting as Regulators

The reporting burden is estimated to be 30 minutes for a State/Local
agency to receive, process, review, and approve identifier, attribute,
or alternative information.  There are no recordkeeping requirements
associated with this requirement, and as such, there is no recordkeeping
burden.

The reporting burden is estimated to be 10 minutes for a State/Local
agency to receive, process, review, and approve subscriber agreements.
There are no recordkeeping requirements associated with this
requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 30 minutes for a State/Local
agency to receive, process, review, and approve an LRA application.
There are no recordkeeping requirements associated with this
requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 2.5 hours for a State/Local
agency to resolve problems involving subscriber agreements or
certifications, and respond to information requests.  There are no
recordkeeping requirements associated with this requirement, and as
such, there is no recordkeeping burden.

(5)	Approval of State/Local Electronic Document Receiving System

Applications – State/Local Agencies that Are Regulated Entities

The reporting burden is estimated to range from 210 hours to 331 hours
for a State/Local agency to prepare and submit the CROMERR application
to EPA.  The recordkeeping burden is estimated to be 90 minutes to read
the regulations.

The reporting burden is estimated to be 24 hours for a State/Local
agency to prepare and submit an amendment to its original CROMERR
application to EPA.  The recordkeeping burden is estimated to be 90
minutes to read the regulations.

The reporting burden is estimated to be about 11 hours for a State/Local
agency to notify EPA about changes to laws, policies, or electronic
document receiving systems that have the potential to affect program
conformance with 40 CFR 3.2000.  The recordkeeping burden is estimated
to be 90 minutes to read the regulations.

	Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control numbers for EPA’s regulations are
listed in 40 CFR Part 9 and 48 CFR Chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA–HQ–OEI–2011–0096, which is available for online viewing at
www.regulations.gov, or in person viewing at the Office of Environmental
Information (OEI) Docket in the EPA Docket Center (EPA/DC), EPA West,
Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is<PHONE_NUMBER>, and the telephone number for the
OEI Docket is (202) 566-1752.  An electronic version of the public
docket is available at www.regulations.gov.  This site can be used to
submit or view public comments, access the index listing of the contents
of the public docket, and to access those documents in the public docket
that are available electronically.  When in the system, select
“search,” then key in the Docket ID Number identified above.  Also,
you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA–HQ–OEI–2011–0096 and OMB Control
Number 2025–0003 in any correspondence.

Appendix A

List of North American Industry Classification System (NAICS)

Codes Associated with Industries Most Likely Affected by the

Information Collection Requirements Covered in this ICR

11	Agriculture, Forestry, Fishing and Hunting

111	Crop Production

112	Animal Production

113	Forestry and Logging

114	Fishing, Hunting and Trapping

115	Support Activities for Agriculture and Forestry

21	Mining

211	Oil and Gas Extraction

212	Mining (except Oil and Gas)

213	Support Activities for Mining

22	Utilities

221	Utilities

23	Construction

233	Building, Developing, and General Contracting

234	Heavy Construction

235	Special Trade Contractors

31	Manufacturing

311	Food Manufacturing

312	Beverage and Tobacco Product Manufacturing

313	Textile Mills

314	Textile Product Mills

315	Apparel Manufacturing

316	Leather and Allied Product Manufacturing

321	Wood Product Manufacturing

322	Paper Manufacturing

323	Printing and Related Support Activities

324	Petroleum and Coal Products Manufacturing

325	Chemical Manufacturing

326	Plastics and Rubber Products Manufacturing

327	Nonmetallic Mineral Product Manufacturing

331	Primary Metal Manufacturing

332	Fabricated Metal Product Manufacturing

333	Machinery Manufacturing

334	Computer and Electronic Product Manufacturing

335	Electrical Equipment, Appliance, and Component Manufacturing

336	Transportation Equipment Manufacturing

337	Furniture and Related Product Manufacturing

339	Miscellaneous Manufacturing

42	Wholesale Trade

421	Wholesale Trade, Durable Goods

422	Wholesale Trade, Nondurable Goods

44-45	Retail Trade

441	Motor Vehicle and Parts Dealers

442	Furniture and Home Furnishings Stores

443	Electronics and Appliance Stores

444	Building Material and Garden Equipment and Supplies Dealers

445	Food and Beverage Stores

446	Health and Personal Care Stores

447	Gasoline Stations

448	Clothing and Clothing Accessories Stores

451	Sporting Goods, Hobby, Book, and Music Stores

452	General Merchandise Stores

453	Miscellaneous Store Retailers

454	Nonstore Retailers

48-49	Transportation and Warehousing

481	Air Transportation

482	Rail Transportation

483	Water Transportation

484	Truck Transportation

485	Transit and Ground Passenger

	Transportation

486	Pipeline Transportation

487	Scenic and Sightseeing Transportation

488	Support Activities for Transportation

491	Postal Service

492	Couriers and Messengers

493	Warehousing and Storage

51	Information

511	Publishing Industries

512	Motion Picture and Sound Recording

	Industries

513	Broadcasting and Telecommunications

514	Information Services and Data Processing Services

52	Finance and Insurance

521	Monetary Authorities   Central Bank

522	Credit Intermediation and Related Activities

523	Securities, Commodity Contracts, and Other Financial Investments and
Related Activities

524	Insurance Carriers and Related Activities

525	Funds, Trusts, and Other Financial Vehicles

53	Real Estate and Rental and Leasing

531	Real Estate

532	Rental and Leasing Services

533	Lessors of Nonfinancial Intangible Assets (except Copyrighted Works)

54	Professional, Scientific, and Technical Services

541	Professional, Scientific, and Technical Services

55	Management of Companies and Enterprises

551	Management of Companies and Enterprises

56	Administrative and Support and Waste Management and Remediation
Services

561	Administrative and Support Services

562	Waste Management and Remediation Services

61	Educational Services

611	Educational Services

62	Health Care and Social Assistance

621	Ambulatory Health Care Services

622	Hospitals

623	Nursing and Residential Care Facilities

624	Social Assistance

71	Arts, Entertainment, and Recreation

711	Performing Arts, Spectator Sports, and Related Industries

712	Museums, Historical Sites, and Similar Institutions

713	Amusement, Gambling, and Recreation Industries

72	Accommodation and Food Services

721	Accommodation

722	Food Services and Drinking Places

81	Other Services (except Public Administration)

811	Repair and Maintenance

812	Personal and Laundry Services

813	Religious, Grantmaking, Civic, Professional, and Similar

814	Private Households

92	Public Administration

921	Executive, Legislative, and Other General Government Support

922  	Justice, Public Order, and Safety Activities

923  	Administration of Human Resource Programs

924	Administration of Environmental Quality Programs

925	Administration of Housing Programs, Urban Planning, and C

926  	Administration of Economic Programs

927  	Space Research and Technology

928  	National Security and International Affair

Appendix B

Methodology for Estimating the Annual Number of Facility Employees
Expected

to Register and Comply with the Identity Proofing Requirements of
EPA’s Electronic Document Receiving System during the Three-Year
Period Covered by the ICR

This appendix describes the methodology for estimating the annual number
of facility employees expected to register and comply with the identity
proofing requirements of EPA’s electronic document receiving system
(i.e., CDX) during the three-year period covered by the ICR.

Annual Number of New Employee Registrants

This section describes the methodology for estimating the annual number
of facility employees expected to register with CDX during the
three-year period covered by the ICR (i.e., new employee registrants).
Section 1.1 provides an overview of the methodology, Section 1.2
provides a detailed discussion of the methodology, and Section 1.3
presents the results.

Overview

In estimating the annual number of facility employees expected to
register with CDX, EPA first compiled historical information on the
number of new employee registrants for years 2011 through 2013.  We then
estimated the annual number of new employee registrants for the
three-year period covered by the ICR (i.e., years 2015 through 2017).

Detailed Discussion

EPA took the following steps to carry out the methodology.

Compile historical information on number of new employee registrants.
EPA referred to CDX in order to compile historical information on the
number of new registrants for years 2011 through 2013.

Year	Number of New

Employee Registrants

2011	45,755

2012	83,701

2013	40,511

Estimate annual number of new employee registrants over the three-year
period covered in the ICR.  We estimated the annual number of new
employee registrants over the three-year period covered by the ICR
(i.e., years 2015 through 2017) by averaging the number of new employee
registrants for years 2011 through 2013.  That is, we assumed that
56,656 new registrants (i.e., (45,755 + 83,701 + 40,511) ÷ 3) will
register with CDX each year.

Estimate annual number of new registrants by type of ownership (i.e.,
private sector vs. State/Local) and remove Federal government employee
registrants from this analysis.  We referred to data published by the
Bureau of Labor Statistics on the number of employees in the U.S.  These
data indicate that 84.32 percent of U.S. employees work for the private
sector, 13.61 percent of employees work for States/Locals, and 2.07
percent of employees work for the Federal government.  We applied these
percentages to the annual number of new employee registrants in Step B.
We then excluded Federal Government employees from the analysis because
they are exempt from ICR requirements.

Results

Exhibit B-1 presents information on the average annual number of
facility employees expected to register with CDX.

Exhibit B-1

Annual Number of Facility Employees Expected to Register with

EPA’s CDX during the Three-Year Period Covered by the ICR

Respondent Universe	Average Annual Number of

New Employee Registrants a

Private Sector	47,772

States/Locals	7,711

Total	55,483

a  Federal government employees are not reflected in the table because
they are exempt from ICR requirements.

Annual Number of Subscriber Agreements

This section describes the methodology for estimating the annual number
of subscriber agreements submitted to EPA to comply with the identity
proofing requirements of CDX during the three-year period covered by the
ICR.  Section 2.1 provides an overview of the methodology, Section 2.2
provides a detailed discussion of the methodology, and Section 2.3
presents the results.

Overview

In estimating the annual number of subscriber agreements submitted to
CDX, EPA first compiled information on the number of ESAs for years 2012
through 2014.  We then estimated the annual number of subscriber
agreements (i.e., paper subscriber agreements, electronic subscriber
agreements (ESAs), reuse (consolidated) ESAs, and third party ESAs) for
the three-year period covered by the ICR (i.e., years 2015 through
2017) based on analysis of growth rates and implementation rates.

Detailed Discussion

EPA took the following steps to carry out the methodology.

Non-Electronic Subscriber Agreements

Compile historical information on number of non-ESAs (i.e., paper
subscriber agreements), by CROMERR data flow.  Some of the CROMERR data
flows do not support ESAs.  For purposes of this analysis, the
subscriber agreements associated with these data flows are categorized
as “non-ESAs” or paper subscriber agreements.

To estimate the number of non-ESAs or paper subscriber agreements for
years 2015 through 2017, we referred to CDX in order to compile
historical information on the number of non-ESAs, by CROMERR data flow,
for years 2012 through 2014.

CROMERR

Data Flow	Number of Non-ESAs or Paper Subscriber Agreements

	2012	2013	2014 a

ARCS	3	26	9

CEDRI

23	314

CEDRI1	5	45

	CSPP	10	46	36

eSIPS

	11

LEAD	36	500	349

MYRCRAID

17	11

ODS	1	2	1

OTAQDCFUEL	46	176	58

SSTS

6	39

TRIMEweb	1	1,317	1,719

Total	102	2,158	2,547

a  Number of paper subscriber agreements were available through July
2014.  EPA projected the number of paper subscriber agreements for the
entire year, based on available 2014 data.

Estimate total number of non-ESAs or paper subscriber agreements, by
CROMERR data flow, for the three-year period covered in the ICR.  We
estimated the total number of non-ESAs or paper subscriber agreements,
by CROMERR data flow, for years 2015 through 2017 by using the following
equations:

Number of

Non-ESAs

for Year Y	=	([3 x RegistrantsY-1] + [2 x RegistrantsY-2] +
[RegistrantsY-3]) / 6

The table below shows the estimated number of non-ESAs or paper
subscriber agreements, by CROMERR data flow, for years 2015 through
2017.

CROMERR

Data Flow	Number of Paper Subscriber Agreements a

	2015	2016	2017

ARCS	14	14	13

CEDRI	165	191	203

CEDRI1	16	16	13

CSPP	35	37	36

eSIPS	6	7	7

LEAD	347	373	360

MYRCRAID	11	12	12

ODS	1	1	1

OTAQDCFUEL	95	96	89

SSTS	22	25	26

TRIMEweb	1,299	1,442	1,441

Total	2,011	2,214	2,201

a  Table includes rounding error.

Electronic Subscriber Agreements

Compile historical information on number of ESAs, by CROMERR data flow.
EPA referred to CDX in order to compile historical information on the
number of ESAs, by CROMERR data flow, for years 2012 through 2014.

CROMERR Data Flow	Number of ESAs

	2012	2013	2014 a

ARCS	2	1	0

CEDRI	 	32	1,731

CEDRI1	5	66	0

CSPP	30	66	35

eSIPS	 	 	21

LEAD	377	4,971	5,954

MYRCRAID	 	11	3

ODS	 	4	12

OTAQDCFUEL	3	2	110

SSTS	 	19	109

TRIMEweb	5	3,758	6,567

Total	422	8,930	14,542

a  Number of paper subscriber agreements were available through July
2014.  EPA projected the number of paper subscriber agreements for the
entire year, based on available 2014 data.

Estimate number of ESAs, by CROMERR data flow, for the three-year period
covered in the ICR.  We estimated the number of ESAs, by CROMERR data
flow, for years 2015 through 2017 by using the following equation:

Number of ESAs

for Year Y	=	([3 x RegistrantsY-1] + [2 x RegistrantsY-2] +
[RegistrantsY-3]) / 6

The table below shows the estimated number of ESAs, by CROMERR data
flow, for years 2015 through 2017.

CROMERR Data Flow	Number of ESAs a

	2015	2016	2017

ARCS	1	1	1

CEDRI	876	1,020	1,091

CEDRI1	23	23	19

CSPP	45	45	43

eSIPS	11	13	14

LEAD	4,697	5,162	5,139

MYRCRAID	5	5	5

ODS	7	8	8

OTAQDCFUEL	56	65	70

SSTS	61	70	74

TRIMEweb	4,537	5,084	5,149

Total	10,319	11,496	11,613

a  Table includes rounding error.

Estimate number of reuse (consolidated) ESAs, by CROMERR data flow, for
the three-year period covered in the ICR.  We estimated the number of
reuse (consolidated) ESAs, for participating data flows, by applying
implementation rates derived from data provided by CDX to the number of
ESAs obtained in Step D.  The implementation rates are presented in the
table below:

CROMERR Data Flow	Implementation Rates for Reuse (Consolidated) ESAs

	2012	2013	2014

ARCS

4%

	CEDRI

49%	1%

CSPP	97%	18%	29%

LEAD	2%	0.3%	0.02%

MYRCRAID

6%

	ODS	67%	50%	67%

OTAQDCFUEL	2%	2%	7%

SSTS

11%	2%

TRIMEweb	24%	1%	1%

The table below shows the estimated number of reuse (consolidated) ESAs,
by CROMERR data flow, for years 2015 through 2017.

CROMERR Data Flow	Number of Reuse (Consolidated) ESAs a

	2015	2016	2017

ARCS

0

	CEDRI

499	16

CSPP	44	8	13

LEAD	94	14	1

MYRCRAID

0

	ODS	5	4	5

OTAQDCFUEL	1	1	5

SSTS

8	1

TRIMEweb	1,089	66	40

Total	1,233	600	81

a  Table includes rounding error.

Estimate number of third party ESAs, by CROMERR data flow, for the
three-year period covered in the ICR.  We estimated the number of third
party ESAs for participating data flows by applying implementation rates
derived from data provided by CDX to the number of ESAs obtained in
Step D.  The implementation rates are provided in the table below:

CROMERR Data Flow	Implementation Rates for Third Party ESAs

	2012	2013	2014

CEDRI

	81%

CEDRI1	50%	37%

	CSPP	2%	46%	47%

eSIPS

	56%

LEAD	90%	86%	93%

OTAQDCFUEL	2%	6%	50%

SSTS

56%	67%

TRIMEweb	76%	71%	78%

The table below shows the estimated number of third party ESAs, by
CROMERR data flow, for years 2015 through 2017.

CROMERR Data Flow	Implementation Rates for Third Party ESAs a

	2012	2013	2014

CEDRI

	882

CEDRI1	12	8

	CSPP	1	21	20

eSIPS

	8

LEAD	4,227	4,456	4,801

OTAQDCFUEL	1	4	35

SSTS

39	50

TRIMEweb	3,439	3,622	3,995

Total	7,680	8,150	9,791

a  Table includes rounding error.

All Subscriber Agreements

Estimate annual number of subscriber agreements for the three-year
period covered by the ICR.  Using the number of subscriber agreements
obtained in Steps B, D, E, and F, we estimated the annual number of
subscriber agreements for the three-year period covered by the ICR.  To
do this, we averaged the number of subscriber agreements for years 2015
through 2017.  The results are presented in the table below.

Type of Subscriber Agreement	Number of Subscriber Agreements a

	Year 2015	Year 2016	Year 2017	Average

Non-ESAs (Paper Subscriber Agreements)	2,011	2,214	2,201	2,142

ESAs	10,319	11,496	11,613	11,143

Reuse (Consolidated) ESAs	1,233	600	81	638

Third Party ESAs	7,680	8,150	9,791	8,540

a  Table includes rounding error.

Estimate number of subscriber agreements by type of ownership (i.e.,
private sector vs. State/Local) and remove subscriber agreements from
Federal government employee registrants from this analysis.  We referred
to data published by the Bureau of Labor Statistics on the number of
employees in the U.S.  These data indicate that 84.32 percent of U.S.
employees work for the private sector, 13.61 percent of employees work
for States/Locals, and 2.07 percent of employees work for the Federal
government.  We applied these percentages to the number of ESAs obtained
in Step G.  We then excluded the subscriber agreements from Federal
Government employees from the analysis because Federal government
employees are exempt from ICR requirements.

Results

Exhibit B-2 presents information on the average annual number of
subscriber agreements to be submitted to CDX during the three-year
period covered by this ICR.

Exhibit B-2

Annual Number Subscriber Agreements to be Submitted to

EPA’s CDX during the Three-Year Period Covered by the ICR a

Type of Subscriber Agreement	Average Annual Number

of Subscriber Agreements b

Private Sector

Non-ESAs (Paper Subscriber Agreements)	1,806

ESAs	9,395

Reuse (Consolidated) ESAs	538

Third Party ESAs	7,201

Subtotal	18,941

States/Locals

Non-ESAs (Paper Subscriber Agreements)	292

ESAs	1,517

Reuse (Consolidated) ESAs	87

Third Party ESAs	1,162

Subtotal	3,058

All (Private Sector and States/Locals)

Non-ESAs (Paper Subscriber Agreements)	2,098

ESAs	10,912

Reuse (Consolidated) ESAs	625

Third Party ESAs	8,364

Total	21,999

a  Exhibit includes rounding error.

b  Federal government employees are exempt from ICR requirements.  As a
result, their subscriber agreements are not included in the exhibit.

Appendix C

Methodology for Estimating the Annual Number of Facility Employees
Expected to Register and Comply with Identity Proofing Requirements of
State/Local Electronic Document Receiving Systems during the Three-Year
Period Covered by the ICR

This appendix describes the methodology for estimating the annual number
of facility employees expected to register and comply with identity
proofing requirements of State/Local electronic document receiving
systems during the three-year period covered by the Information
Collection Request (ICR).  Section 1 provides an overview of the
methodology, Section 2 provides a detailed discussion of the
methodology, and Section 3 presents the results.

Overview

EPA estimated the number of facilities reporting to State/Local
electronic document receiving systems by first identifying states with
existing and new systems and compiling them into a table (referred to as
the “Master Table” in this analysis).,   We then referred to survey
data compiled by EPA in 2002 from states that estimated the number of
facilities subject to their respective receiving systems by
environmental program.  We updated these state estimates to current
(2014) levels based on analysis of respondent universe growth rates in
EPA program ICRs.  We then extrapolated the updated survey data to the
states in the Master Table to estimate their number of facilities.  The
extrapolation was performed by first finding the total number of
commercial establishments in each state based on U.S. Census data,
comparing the number of establishments in the survey states to the
states in the Master Table, and using a scaling factor to extrapolate
the number of facilities in the survey states to the states in the
Master Table based on their respective number of commercial
establishments.  We performed this extrapolation by environmental
program for all states in the Master Table.  Finally, we estimated the
number of employees based on the number of facilities.

Detailed Discussion

EPA took the following steps to carry out the methodology.

Find the Number of States with Receiving Systems, by State Environmental
Program

Identify states with existing and new electronic document receiving
systems.  To identify states with existing and new electronic document
receiving systems, we referred to EPA’s CROMERR Program and
Stakeholder Management (PSM) System.  PSM is a custom implementation of
a Salesforce.com platform that integrates database records, online file
storage, multiple distinct spreadsheets, and email logs, to support the
reduction of Technical Review Committee (TRC) and EPA’s Office of
Environmental Information (OEI) levels of effort in managing the
application approval process.

For purposes of this analysis, EPA categorized systems based on the
following criteria:

Existing Electronic

Document Receiving Systems	New Electronic

Document Receiving Systems

System Type	System Stage	System Type	System Stage

Existing

New	Approval Review

Completeness Review

Draft Received

EPA Approved

Incomplete

TRC Approved	New	Pending Receipt

Scoping

EPA used data current as of October 9, 2014.

Estimate the number of existing and new state receiving systems, by
environmental program.  Existing and new receiving systems were
categorized into state environmental programs based on the statute
associated with the authorized program (e.g., Clean Air Act (CAA), Clean
Water Act (CWA)).  Attachment C-1 presents a table of the states with
existing and new receiving systems, by state environmental program.
This table is called the “Master Table” in this appendix.

Estimate the Number of Facilities, by State Environmental Program

Estimate number of facilities by state environmental program, based on
CROMERR cost-benefit analysis (CBA) survey data.  To obtain information
on the number of facilities by state environmental program, we referred
to “Table V-2. Existing State Receiving Systems” of Cross-Media
Electronic Reporting and Records Rule (CROMERRR) Cost Benefit Analysis -
Final; dated November 17, 2004.  This table contains information on the
number of facilities associated with state receiving systems reported in
a survey conducted by EPA during the summer of 2002.  Attachment C-2
shows the number of facilities by state environmental program based on
CBA survey data.

Update CBA’s facility estimate for each state environmental program,
based on ICR respondent data.  The data on number of facilities
developed under Step C are based on 2002 data.  In order to bring these
numbers to the present (2014), we took the following steps:

Obtained data on annual number of respondents in the ICRs listed in
Attachment C-3.  For each ICR, we obtained respondent universe
estimates for at least two different years (e.g., 2003 and 2012) to
enable us to estimate the annual percent change in the universe.

Estimated the annual percent change in number of respondents for each
ICR.

Multiplied the annual percent change by 12 to estimate percent change
over the 2002-2014 period.

Applied the 2002-2014 percent change to facility estimates in order to
update the number of facilities for each environmental program.

Attachment C-4 shows the ICR data used to update the CBA’s facility
estimates, by state environmental program.

Extrapolate Updated State Survey Data on Number of Facilities to All
States in Master Table

Develop a scaling factor for use in extrapolation.  We referred to U.S.
Census Bureau data on number of establishments by employment size for
states.  Based on these data, which are presented in Attachment C-5, we
obtained the following information for each environmental program:

Number of commercial establishments in the survey states for which
respondent data were available; and

Number of commercial establishments in states in the Master Table with
existing and/or planned receiving systems.

We then used these data to derive a scaling factor to be used in Step F.
 This scaling factor was derived using the following equation:

Scaling Factor =	Number of establishments in states in Master Table

	Number of establishments in survey states

Extrapolate the CBA’s updated facility estimates to states with
existing and new receiving systems.  In deriving the total number of
facilities in all states in the Master Table, we first estimated the
total number of facilities associated with each environmental program.
To do this, we multiplied the updated survey data (Step D) by the
corresponding scaling factor derived in Step E.  This gave us the total
number of facilities reporting to the receiving systems of states in the
Master Table, by environmental program.  We then added up the total
number of facilities in states in the Master Table across all
environmental programs.

Estimate annual number of facilities subject to the ICR requirements.
In estimating the annual number of facilities subject to the ICR
requirements, we made the following assumptions:

Existing receiving systems:  For purposes of this analysis, we assume
that existing systems have been in operation since 2005.  EPA estimates
that 30 percent of facilities began to use the receiving system in the
first year (i.e., 2005) and 10 percent in each subsequent year.

New receiving systems:  We assume that one third of facilities will
begin reporting in each year of the three-year period covered by the
ICR.  In each year of the ICR, EPA estimates that 30 percent of
facilities will begin to use the receiving system in the first year and
10 percent in each subsequent year.

The above implementation rates for use of an electronic receiving system
were taken from the CBA (Exhibit 2-5).

Estimate average annual number of facilities subject to the ICR
requirements, by employment size.  In estimating the average annual
number of facilities by employment size, we referred to the U.S. Census
Bureau data presented in Attachment C-5.  Based on these data, in the
U.S., 70 percent of establishments have less than 20 employees and
30 percent of establishments have 20 or more employees.  We applied
these percentages to the annual number of facilities in Step G.  Once we
estimated the annual number of facilities for each year from 2015
through 2017 (i.e., the three-year period covered by the ICR), we
obtained the average over three years.

Estimate average annual number of facility employees subject to the ICR
requirements.  In estimating the average annual number of facility
employees, we assumed that small firm facilities have three employees
and that medium/large firm facilities have six employees.  These
estimates were taken from the CBA (Section 2.3.3, “Facilities;”
page 26).

Estimate average annual number of facility employees subject to the ICR
requirements by type of ownership (i.e., private sector vs. State/Local)
and remove Federal government facilities from this analysis.  In
estimating the average annual number of facility employees by type of
ownership, we referred to data published by the Bureau of Labor
Statistics on the number of employees in the U.S.  These data indicate
that 84.32 percent of U.S. employees work for the private sector, 13.61
percent of employees work for States/Locals, and 2.07 percent of
employees work for the Federal government.  We applied these percentages
to the annual number of facility employees in Step I.  We then excluded
Federal government employees from the analysis because they are exempt
from ICR requirements.

Attachments C-6 and C-7 present details on the application of the above
methodology to existing and new receiving systems, respectively.

Results

Exhibit C-1 presents information on the average annual number of
facility employees expected to register with existing and new
State/Local receiving systems.

Exhibit C-1

Average Annual Number of Facility Employees Expected to

Register with Existing and New State/Local Receiving Systems

during the Three-Year Period Covered by the ICR a

Type of Firm	Average Annual Number of Facility Employees b

	Existing Receiving Systems	New Receiving System	All Receiving Systems

(i.e., Existing and New)

Private Sector

Small Firms	6,769	4,988	11,757

Medium-Size and Large Firms	5,803	4,275	10,078

Subtotal	12,572	9,263	21,835

States/Locals

Small Firms	1,093	805	1,898

Medium-Size and Large Firms	937	690	1,627

Subtotal	2,030	1,495	3,525

All (Private Sector and States/Locals)

Small Firms	7,862	5,793	13,655

Medium-Size and Large Firms	6,740	4,965	11,705

Total	14,602	10,758	25,360

a  Exhibit includes rounding error.

b  Federal government employees are not reflected in the table because
they are exempt from ICR requirements.

Attachment C-1

Number of Existing and New State/Local Electronic Document

Receiving Systems, by State Environmental Program

(also referred to as the “Master Table”)

State	Existing Systems	New Systems

	Air	Water	Waste	Air	Water	Waste

Alabama	 	X

Alaska	X	X

American Samoa

Arizona	 	X	 	X

Arkansas	X	X	X

California	X	X	 	 	X

Colorado	 	X

Connecticut	 	X	 	 	X

Delaware	X	X	X

District of Columbia	X	X	X	X

Florida	X	X	X

Georgia	X	X

Guam

Hawaii	 	X	 	 	X

Idaho	X

Illinois	X	X

Indiana	X	X	X

Iowa	X	X

Kansas	X	X	X

Kentucky	X	X	X

Louisiana	 	X

Maine	 	X

Maryland	 	X

Massachusetts	X	X	X	 	 	X

Michigan	X	X	X

Minnesota	X	X	X

Mississippi	X	X	X

Missouri b	X	X	X	 	X

Montana	 	X

Nebraska	 	 	 	X	X

Nevada	 	X	X