October
31,
2001
INFORMATION
COLLECTION
REQUEST
for
ASSESSMENT
OF
COMPLIANCE
ASSISTANCE
PROJECTS
EPA
The
United
States
Environmental
Protection
Agency
Table
of
Contents
Title
Page
1.
Identification
of
the
Information
Collection
1
1(
a)
Title
of
the
Information
Collection
1
1(
b)
Short
Characterization/
Abstract
1
2.
Need
for
and
Use
of
the
Collection
3
2(
a)
Need/
Authority
for
the
Collection
3
2(
b)
Practical
Utility/
Users
of
the
Data
3
3.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
4
3(
a)
Non­
duplication
4
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
4
3(
c)
Consultations
4
3(
d)
Effects
of
Less
Frequent
Collection
4
3(
e)
General
Guidelines
4
3(
f)
Confidentiality
5
3(
g)
Sensitive
Questions
5
4.
The
Respondents
and
The
Information
Requested
5
4(
a)
Respondents/
SIC
Codes
5
4(
b)
Information
Requested
5
(
I)
Data
items,
including
record
keeping
requirements
5
(
II)
Respondent
Activities
5
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5
5(
a)
Agency
Activities
6
5(
b)
Collection
Methodology
and
Management
6
5(
c)
Small
Entity
Flexibility
7
5(
d)
Collection
Schedule
7
6.
Estimating
the
Burden
and
Cost
of
the
Collection
7
6(
a)
Estimating
Respondent
Burden
7
(
I)
Number
of
Respondents
8
(
II)
Burden
Per
Survey
Type
9
6(
b)
Estimating
Respondent
Costs
10
(
I)
Estimating
Labor
Costs
10
(
II)
Estimating
Capital
and
Operations
and
Maintenance
Costs
11
(
III)
Capital/
Start­
up
vs.
Operations
and
Maintenance
(
O&
M)
Costs
11
(
IV)
Annualizing
Capital
Costs
11
6(
c)
Estimating
Agency
Burden
and
Cost
11
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
12
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
12
(
I)
Respondent
Tally
12
(
II)
The
Agency
Tally
12
(
III)
Burden
Statement
12
List
of
Tables
Table
5­
1
Follow­
up
Methods
Allowed
by
Assistance
Activity
Table
6­
1
Three­
Year
Compliance
Assistance
Assessment
Activities
Table
6­
2
Three­
Year
Burden
Table
by
Evaluation
Survey
Type
Table
6­
3
Three­
Year
Agency
Burden/
Cost
for
Implementing
Surveys
Table
6­
4
Total
Annual
Estimated
Respondent
Burden
and
Cost
Summary
Table
6­
5
Total
Annual
Estimated
Agency
Burden
and
Cost
Summary
1
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
ASSESSMENT
OF
COMPLIANCE
ASSISTANCE
PROJECTS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection:
Assessment
of
Compliance
Assistance
Projects
1(
b)
Short
Characterization/
Abstract
The
affected
audience
for
this
ICR
includes
members
of
the
regulated
community
and,
to
a
lesser
extent,
state
and
local
regulators
and
compliance
assistance
providers
that
receive
EPA
compliance
assistance
tools
or
services.
The
large
majority
of
EPA
compliance
assistance
tools
are
targeted
to
small
businesses
(
e.
g.,
those
employing
less
than
100
employees)
that
frequently
lack
environmental
officers
and
programs,
and
traditionally
have
little
familiarity
of
environmental
regulations
and
procedures.

All
assessments
undertaken
under
this
ICR
will
follow
stringent
procedures
to
ensure
that
data
are
collected
and
used
properly
and
efficiently.
2
3.
What
management
changes
at
your
facility
do
you
intend
to
take
(
did
take)
as
a
result
of
the
<
compliance
>?

a.
Conduct
a
self
audit
b.
Institute
an
environmental
management
policy,
system
or
procedure
c.
Institute
training
or
other
communication
to
improve
awareness
and/
or
practices
d.
No
management
action
will
be
taken
e.
Other
specify
4.
Who
(
if
anyone)
have
you
contacted
(
will
contact)
someone
for
further
assistance
as
a
result
of
the
<
compliance
>?

a.
A
vendor
b.
A
state
or
local
regulatory
agency
c.
A
non­
regulatory
local
source
for
additional
compliance
assistance
d.
No
contacts
will
be
made
e.
Other
specify
5.
Of
the
activities
that
you
have
implemented
as
a
result
of
the
<
compliance
assistance
activity>
what
have
been
the
resultant
pollutant
reductions
and
cost
savings,
if
applicable?

Activity
Pollution/
Reduction
Cost
Savings
_______
________________
___________
3
EPA
will
provide
OMB
with
an
annual
summary
of
surveys
conducted
in
accordance
with
OMB's
Resource
Manual
for
Customer
Surveys
(
dated
October
1993).
EPA
estimates
that
a
combination
of
surveys
(
mail,
Internet,
telephone,
and
onsite)
will
generate
voluntary
responses
from
approximately
77,028
respondents
for
an
estimated
burden
of
11,868
hours
over
a
three
year
period.
On
an
annual
basis,
EPA
estimates
feedback
from
approximately
25,676
respondents
for
an
estimated
annual
burden
of
3,956
hours.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
To
help
fulfill
the
broad
mandate
of
protecting
human
health
and
the
environment,
EPA
provides
compliance
assistance
activities
and
services
to
businesses
and
other
regulated
entities.
Compliance
assistance
activities
provide
the
regulated
community
with
the
specific
information
necessary
to
achieve
and
maintain
regulatory
compliance.

EPA
believes
that
evaluating
compliance
assistance
activities
is
compulsory
to
ensure
customer
needs
are
met,
as
well
as
to
maintain
efficient
and
effective
assistance.

2(
b)
Practical
Utility/
Uses
of
the
Data
After
the
compliance
assistance
programs
collect
data
under
each
survey,
the
responses
will
be
reported
to
OC
as
specified
in
section
5(
b).
Following
analysis,
the
synthesized
findings
will
be
shared
with
the
appropriate
Agency
offices,
which
may
use
them
to:

°
identify
methods
to
improve
the
effectiveness
and
efficiency
of
compliance
assistance
tools
and
delivery;
and
°
develop
new
compliance
assistance
tools
to
address
identified
problem
areas.
4
EPA
anticipates
that
the
results
of
compliance
assistance
assessments
will
lead
to
improved
compliance
assistance
services.
Ultimately,
these
changes
could
result
in
improved
compliance
with
environmental
regulations.

3.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non­
duplication
EPA
will
evaluate
customer
satisfaction
with
compliance
assistance
services,
and
in
some
cases,
the
effectiveness
(
including
improved
understanding,
behavioral
change,
and
environmental
results)
of
the
compliance
assistance
services.
The
information
collected
through
this
ICR
will
not
overlap
with
other
EPA
surveys.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
On
August
31,
2001,
EPA
published
a
Federal
Register
Notice
(
66
FR
45982)
announcing
its
intent
to
submit
an
ICR
to
OMB
regarding
the
assessment
of
compliance
assistance
projects.
EPA
did
not
receive
any
comments
on
this
ICR.

3(
c)
Consultations
EPA
has
received
feedback
on
this
information
collection
from
key
stakeholders
including
trade
associations
representing
the
businesses
expected
to
respond
to
surveys,
and
EPA's
Compliance
Assistance
Advisory
Council
(
a
workgroup
of
industry,
government,
and
community
stakeholders
created
to
obtain
feedback
on
EPA's
compliance
assistance
activities).

To
project
survey
needs
through
the
year
2004,
EPA
also
consulted
with
regional
compliance
assistance
programs
within
the
Agency,
staff
within
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA),
and
Agency
staff
responsible
for
developing
the
Agency's
Annual
Compliance
Assistance
Plan.
This
feedback,
along
with
OC's
past
experience
with
surveys
conducted
over
the
past
three
years
under
ICR
1860.01
and
the
projections
of
projects
planned
for
2001
and
beyond,
were
used
to
develop
the
estimated
number
of
activities
and
the
estimates
of
respondent
and
Agency
burden
described
in
Section
6.

3(
d)
Effects
of
Less
Frequent
Data
Collection
The
surveys
conducted
under
this
ICR
will
be
one­
time
data­
collection
efforts;
therefore
this
information
collection
could
not
be
conducted
less
frequently.

3(
e)
General
Guidelines
This
ICR
complies
with
OMB's
general
guidelines
for
the
collection
of
information.
5
3(
f)
Confidentiality
No
confidential
data
will
be
collected.

3(
g)
Sensitive
Questions
No
sensitive
data
will
be
collected.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
For
this
ICR,
the
term
"
respondents"
refers
to
individuals
who
provide
feedback
on
EPA's
compliance
assistance
tools
and
activities.
Potential
respondents
include
small
businesses,
state
and
local
regulators,
and
compliance
assistance
providers.
Small
businesses
are
traditionally
the
primary
recipients
and
users
of
compliance
assistance
tools
and
services,
and
will
make
up
the
bulk
of
respondents.

4(
b)
Information
Requested
Information
requested
by
surveys
developed
under
this
ICR
will
be
used
to
assess
compliance
assistance
activities.
Each
survey
will
request
specific
information
related
to
the
compliance
assistance
activity
being
evaluated.
EPA
delivers
compliance
assistance
in
several
forms
to
a
wide
range
of
audiences.
Section
1(
b)
identifies
the
general
types
of
questions
that
will
be
asked
in
the
surveys.
Surveys
developed
under
this
ICR
will
be
limited
to
those
types
of
questions.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
Table
5­
1
summarizes
the
methods
OC
will
allow
for
different
types
of
assistance
under
this
ICR.

Table
5­
1
Follow­
up
Methods
Allowed
by
Assistance
Activity
CA
Activity
Preferred
Follow­
up
Method
Conditions
On­
Site
Visits
1.
On­
site
revisit;
or
2.
Phone
call
survey
1.
Must
do
at
least
25%
revisits;
or
2.
Call
100%
of
sites
6
Workshop/
Training
1.
Pre/
post
tests;
and
2a.
Phone
survey
if
<
50
attendees;
or
2b.
Mail
survey
if
>
50
attendees
1.
100%
workshop
participants;
and
2a.
Phone
all
participants;
or
2b.
Use
the
Tailored
Design
Method
(
TDM)

Compliance
Guides
Distributed
through
Workshops
1.
Phone
survey
if
<
50;
or
2.
Mail
survey
if
>
50
No
Mail
Back
Cards
1.
Phone
all
participants;
or
2.
Use
the
TDM
Compliance
Guides
Distributed
via
Mail
Mail
survey
No
Mail
Back
Cards
1.
Maintain
a
list
of
mailed
recipients
and
use
the
TDM
Compliance
Guides
Distributed
via
the
Internet
No
followup
for
outcome
measurement;
count
#
of
guides
downloaded
only
No
Mail
Back
Cards
Hotlines
Periodic
user
survey
Must
use
phone
surveys
Compliance
Assistance
Centers
­
Internet
On­
line
survey
Secured
site
that
would
eliminate
the
ability
to
take
the
survey
multiple
times
5(
a)
Agency
Activities.
Agency
activities
associated
with
the
collection
of
information
may
include:

S
Developing
individual
surveys;

S
Disseminating
questionnaires
to
respondents;

S
Gathering
information
from
respondents;

S
Filtering/
screening
response
data
obtained
through
Internet
feedback
screens;

S
Reviewing
data;

S
Preparing
findings;

S
Storing
and
maintaining
results;
and
S
Adjusting
compliance
assistance
activities
based
on
assessment
results.

5(
b)
Collection
Methodology
and
Information
Management.

An
internal
review
and
oversight
process,
independent
of
the
originating
program
office,
has
been
established
for
all
assessment
activities
conducted
under
this
ICR.
Prior
to
initiating
an
assessment,
each
program
will
provide
to
OC
a
memo
with
the
following
information:

S
Title,
identification
of
originator,
and
appropriate
contact
information;

S
Summary
and
description
of
the
intended
purpose
as
it
relates
to
OECA's
mission;

S
Delivery
method
(
e.
g.,
mail/
email/
fax,
phone),
collection
schedule,
and
follow
up
plans;
1See,
Dillman,
Don
A.,
"
Mail
and
Internet
Surveys:
The
Tailored
Design
Method"

7
S
Planned
use
of
information
collected;
and
S
Number
of
respondents,
and
burden
in
costs
and
hours
to
respondents
and
the
Agency.

OC
will
submit
surveys
to
OMB
for
a
10­
business
day
expedited
review
and
determination.
A
summary
including
title,
sponsoring
office,
number
of
respondents,
and
estimated
burden
hours
and
costs
will
be
attached.
Following
the
completion
of
assessment
activities,
all
offices
will
provide
copies
of
their
approved
assessment
tool,
analytical
reports,
and
a
description
of
any
follow
up
actions
to
OC.

The
Agency
will
maximize
the
efficiency
of
information
collection
by
making
every
effort
to
improve
response
rates
to
assessment
activities.
In
order
to
use
this
ICR,
staff
conducting
compliance
assistance
activities
must
notify
their
audiences
at
the
time
of
compliance
assistance
delivery
that
EPA
plans
to
follow
up
with
them
to
assess
the
quality
of
the
assistance.
At
this
time
staff
will
indicate
the
assessment
method
to
be
used
(
e.
g.,
phone,
letter,
email).

To
improve
response
rates
for
mailed
and
phone
surveys,
OC
recommends
using
the
"
Tailored
Design
Method."
1
Users
of
the
"
Tailored
Design
Method"
have
achieved
greater
than
90
percent
response
rates
for
their
surveys.
The
method
includes
the
following
steps:

S
Send
advance
notice;

S
Send
the
survey;

S
Thank
everyone;

S
Send
replacement
survey
to
non­
responders;
and
S
Try
a
different
mode
for
remaining
non­
responders.

5(
c)
Small
Entity
Flexibility.

Not
applicable.

5(
d)
Collection
Schedule.

This
will
be
dependent
upon
the
needs
of
each
originator
of
a
survey.
Schedules
for
customer
surveys
will
be
documented
by
the
survey
sponsors.

6.
Estimating
the
Burden
and
the
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
Respondent
activities
are
expected
to
include
only
a
few
steps:
reviewing
instructions,
responding
to
surveys,
and
sending
(
via
mail
or
e­
mail)
responses
(
for
those
surveys
not
8
conducted
over
the
phone
or
in
person).
To
minimize
the
respondent
burden,
EPA
will
use
simple,
clear
survey
designs
that
are
easy
to
respond
to
and
are
of
limited
scope.
There
will
be
no
requirement
for
respondents
to
develop
data
gather
systems,
train
personnel,
or
maintain
records.

Tables
6­
1
and
6­
2,
presented
in
Section
6(
b)
below,
present
the
respondent
burden
estimates.
These
estimates
are
based
on
OC's
experience
with
actual
surveys
conducted
under
generic
ICR
1860.01,
OC's
projected
compliance
assistance
activities,
and
the
applicable
compliance
assistance
activities
included
in
EPA's
Annual
Compliance
Assistance
Plan.
The
burden
is
expected
to
be
relatively
consistent
over
the
three
years
of
this
ICR.
To
estimate
the
burden,
OC
first
estimated
the
number
of
respondents,
then
estimated
the
burden
per
survey
type.

I
Number
of
Respondents
The
number
of
respondents
for
each
type
of
compliance
activity
is
presented
below.

Workshops
OC
anticipates
that
approximately
50
workshops
will
evaluated
under
this
ICR
over
the
three­
year
period.
Of
these
50
workshops,
OC
estimates
that:


25
will
have
40
attendees.
EPA
will
evaluate
these
workshops
with
phone
surveys
to
all
of
the
attendees,
with
an
80%
phone
survey
response
rate,
giving
800
respondents.


25
will
have
60
attendees.
EPA
will
evaluate
these
workshops
with
mail
surveys
to
all
of
the
attendees,
with
an
80%
mail
survey
response
rate,
giving
1,200
respondents.


EPA
will
also
evaluate
all
workshops
using
pre­
and
post­
tests
given
to
all
survey
attendees,
giving
2,500
respondents.

Compliance
Guides
OC
anticipates
that
150
compliance
guides
will
be
evaluated
under
this
ICR
over
the
threeyear
period.
Of
these
guides,
OC
estimates
that:


5
will
be
distributed
at
workshops
with
40
attendees.
EPA
will
evaluate
these
guides
with
phone
surveys
to
all
recipients,
with
an
80%
phone
survey
response
rate,
giving
160
respondents.


75
will
be
distributed
by
mail
to
1,000
recipients
each.
EPA
will
evaluate
these
guides
with
mail
surveys
to
the
recipients,
with
an
80%
mail
survey
response
rate,
giving
60,000
respondents.
9

70
will
be
distributed
by
the
Internet
to
an
undetermined
number
of
recipients.
EPA
will
evaluate
these
guides
through
output
measures
only
(
e.
g.,
the
number
of
guides
downloaded).
There
will
be
no
follow­
up
with
recipients.

Hotlines
OC
anticipates
that
six
compliance
assistance
hotlines
will
be
evaluated
under
this
ICR
over
the
three­
year
period.
EPA
will
evaluate
these
hotlines
through
phone
surveys
of
50
callers
to
each
hotline,
with
a
100%
response
rate,
giving
300
respondents.

Onsite
Visits
OC
anticipates
that
130
onsite
visits
will
be
evaluated
under
this
ICR
over
the
three­
year
period.
Of
these
visits,
OC
estimates
that:


EPA
will
evaluate
65
of
these
visits
by
revisiting
25%
of
the
visited
facilities,
giving
16
respondents.


EPA
will
evaluate
65
of
these
visits
through
phone
surveys
to
all
of
the
visited
facilities,
with
an
80%
response
rate,
giving
52
respondents.

Internet
Web
Sites
OC
anticipates
that
60
compliance
assistance
Web
site
evaluations
will
be
conducted
through
on­
line
surveys.
OC
estimates
that
200
users
will
respond
to
each
on­
line
survey,
giving
12,000
respondents.

II
Burden
Per
Survey
Type
As
discussed
above
and
shown
on
Table
6­
1,
OC
estimates
that
there
will
be
25,676
respondents
annually
to
the
compliance
assistance
evaluation
surveys.
OC
estimates
the
following
burden
per
respondent,
for
each
evaluation
survey
type:


Phone
survey:
10
minutes/
respondent;


Mail
survey:
10
minutes/
respondent;


Pre­/
post­
test:
10
minutes/
respondent;


Onsite
revisit:
120
minutes/
respondent;
and

Online
survey:
5
minutes/
respondent.

Table
6­
1
presents
the
total
estimated
respondent
burden
for
each
compliance
assistance
activity,
broken
down
by
evaluation
survey
type.
Table
6­
2
presents
the
total
estimated
respondent
burden
by
evaluation
survey
type.
10
6(
b)
Estimating
Respondent
Costs
In
order
to
minimize
the
respondent
burden,
survey
designs
will
be
simple,
convenient,
easy
to
respond
to,
and
clear
in
content
and
purpose.
Surveys
will
be
of
limited
scope
and
require
only
a
short
time
to
complete.

I
Labor
Costs
OC
estimated
labor
costs
by
multiplying
the
estimated
respondent
burden
(
in
hours)
by
estimated
labor
rates.
OC
obtained
wage
estimates
from
the
Bureau
of
Labor
Statistics
(
May
2001,
Employer
Costs
for
Employment
Compensation,
Table
10:
White
Collar,
Professional
specialty
and
technical).
The
hourly
labor
rates
are
estimated
at
$
32.68
plus
a
110%
overhead
for
a
total
hourly
rate
of
$
68.63.
This
rate
applies
to
both
the
regulated
community
and
state
and
local
technical
assistance
staff.

Tables
6­
1
and
6­
2
present
the
respondent
costs
according
to
compliance
assistance
activity
and
evaluation
survey
type,
respectively.
Each
table
displays
the
annual
and
three­
year
total
burden
estimates
for
respondents
in
hours
and
dollars.
The
average
burden
per
response
is
a
little
over
nine
minutes
(
11,868
total
hours
divided
by
77,028
respondents,
converted
to
minutes).
The
average
cost
per
response
is
less
than
$
11.

Table
6.1.
Three­
Year
Compliance
Assistance
Assessment
Activities
­
FY2002­
FY2005
Assistance
Activity
(
number
of
events
)
Type
of
Survey
(
number
of
events
)
Estimated
#
of
Respondents
Estimated
survey
time
in
minutes
TOTAL
BURDEN
(
HOURS)
TOTAL
COST
Workshops
(
50)
Phone
(
25)
800
10
133
$
9,128
Mail
(
25)
1,200
10
200
$
13,726
Pre/
post­
test
(
50)
2,500
10
417
$
28,550
Compliance
Guides
(
150)
Phone
(
5)
160
10
27
$
1,853
Mail
(
75)
60,000
10
10,000
$
686,300
Internet
(
70)
0
(
no
follow
up)
0
0
$
0
Assistance
Hotlines
(
6)
Phone
(
6)
300
10
50
$
3,432
Onsite
Visits
(
130)
Onsite
Revisit
(
65)
16
120
32
$
2,196
Phone
(
65)
52
10
9
$
618
Internet
Web
sites
(
60)
Online
(
60)
12,000
5
1,000
$
68,630
Totals
over
3
years
77,028
11,868
$
814,433
ANNUAL
TOTALS
25,676
3,956
$
271,478
Table
6­
2
Three­
Year
Burden
Table
by
Evaluation
Survey
Type
Evaluation
Survey
Type
Estimated
#
of
Respondents
Estimated
survey
time
in
minutes
TOTAL
BURDEN
(
HOURS)
TOTAL
COST
Phone
1,312
10
219
$
15,031
11
Mail
61,200
10
10,200
$
700,026
Pre/
post­
test
2,500
10
417
$
28,550
Onsite
16
20
32
$
2,196
Online
12,000
5
1,000
$
68,630
3­
Year
Total
77,028
11,868
$
814,433
Annual
Total
25,676
3,956
$
271,478
II
Capital
and
Operations
and
Maintenance
Costs
Activities
supported
by
this
ICR
do
not
involve
the
purchase
of
monitoring
or
reporting
equipment.

III
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O
&
M)
Costs
Activities
supported
by
this
ICR
do
not
involve
the
purchase
of
monitoring
or
reporting
equipment.

IV
Annualizing
Capital
Costs
Not
applicable.

6(
c)
Estimating
Agency
Burden
and
Cost.

Tables
6­
3
provides
the
annual
estimates
for
EPA
burden
associated
with
developing
and
disseminating
evaluation
surveys
and
analyzing
the
results.
The
number
of
events
is
based
on
the
total
number
of
surveys
conducted,
as
indicated
in
Table
6­
1.
Wage
estimates
are
based
on
the
2001
GS­
13­
01
annual
salary
of
$
63,211
or
$
30.29/
hr.
With
a
30%
overhead
the
hourly
rate
is
$
39.38/
hr.
This
estimate
assumes
that
every
survey
is
independently
created.
EPA
expects
that,
in
practice,
many
offices
will
customize
existing
surveys
to
suit
their
goals,
thereby
reducing
the
Agency
burden.

Table
6­
3
Three­
Year
Agency
Burden/
Cost
for
Implementing
Surveys
Activities
Hours
No.
of
Events
TOTAL
BURDEN
(
HOURS)
TOTAL
COST
Survey
Development
1.5
446
669
$
26,345
OC
Review
of
Survey
0.25
446
112
$
4,411
Administration
of
survey
0.5
446
223
$
8,782
Compilation
of
survey
results
1
446
446
$
17,563
Analysis
of
Survey
Results
1
446
446
$
17,563
3­
Year
Total
446
1896
$
74,664
Activities
Hours
No.
of
Events
TOTAL
BURDEN
(
HOURS)
TOTAL
COST
12
Annual
Total
149
632
$
24,888
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Burden
EPA
estimates
that
over
the
three
year
life
of
the
umbrella
clearance,
77,028
respondents
will
voluntarily
respond
to
compliance
assistance
assessment
programs
conducted
under
this
ICR
for
a
total
burden
of
11,868
hours
and
a
total
cost
of
$
814,433.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
I
Respondent
Tally
Table
6­
4
Total
Annual
Estimated
Respondent
Burden
and
Cost
Summary
No.
Of
Respondents
No.
Of
Events
ANNUAL
BURDEN
HOURS
ANNUAL
COST
TOTAL
25,676
149
3,956
$
271,478
II
Agency
Tally
Table
6­
6
Total
Annual
Estimated
Agency
Burden
and
Cost
Summary
No.
of
Events
ANNUAL
BURDEN
HOURS
ANNUAL
COST
TOTAL
149
632
$
24,888
III
Burden
Statement
The
following
statement
applies
overall
to
the
planned
surveys
for
the
next
three
years:

Public
reporting
burden
for
this
collection
of
information
is
estimated
to
average
slightly
over
minutes
per
response,
including
the
time
for
reviewing
instructions,
gathering
information,
and
completing
and
reviewing
the
collection
of
information.
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggestions
for
reducing
the
burden,
including
the
use
of
automated
collection
techniques
to
the
Assistant
Administrator,
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency
(
Mail
Code
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20004;
and
to
the
Office
of
Information
&
Regulatory
Affairs,
Office
of
Management
&
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
(
1860.02)
and
the
OMB
control
number
(
2020­
0015)
in
any
correspondence.
13
