  SEQ CHAPTER \h \r 1 Supporting Statement for Renewal of OECA Tips &
Complaints Webpage

Part A

1.	Identification of the Information Collection – 

	1(a)	Title of the Information Collection

Tips and Complaints Webpage Regarding Environmental Violations

	1(b)	Short Characterization/Abstract

The Office of Enforcement and Compliance Assurance (OECA) is the
component of the Environmental Protection Agency responsible for
administrative, civil, and criminal enforcement of the environmental
laws that EPA administers.  EPA's criminal enforcement program, and, to
a lesser extent, its civil enforcement program are, like other federal
law enforcement programs, dependent on tips and complaints from
concerned citizens and members of the regulated community. The OECA Tips
& Complaints webpage provides a convenient means by which these
individuals can voluntarily submit tips and complaints regarding
suspected violations of environmental law.

Tips or complaints received through the webpage are used by civil and/or
criminal enforcement personnel at EPA to determine whether an
investigation is warranted into the suspected or alleged misconduct.  In
some cases, EPA may decide to refer tips or complaints for investigation
to other federal agencies or to State or local authorities within whose
jurisdiction the matter may appropriately fall.

			The OECA Tips and Complaints webpage does not replace or otherwise
supplant other means of providing tips or complaints to EPA; it merely
provides a new and convenient means by which to supply these tips or
complaints online.  As with complaints provided by phone, fax, or
electronic mail, we expect that tippers or complainants are already in
the possession of information that leads them to suspect a violation of
environmental law when then contact EPA to report the matter. 
Accordingly, EPA believes that the burden associated with the webpage is
merely that arising from the need to read the instructions and type
information into the appropriate fields on the webpage.  In our
estimate, this amounts to approximately ½ hour per tip or complaint,
for total annualized burden for all tippers and complainants of 1,800
hours.  While we do not expect actual labor costs associated with these
burden hours, at the current average wage, the opportunity cost of 1,800
burden hours would be approximately $33,462.

2.	Need For and Use of the Collection

	2(a)	Need/Authority for the Collection

Under the statutes that EPA is charged to administer, apprehending
violators and responding to ongoing environmental violations is central
to the Agency's mission.  See, e.g., 33 U.S.C. § 1319 (Clean Water
Act), 42 U.S.C. § 7413 (Clean Air Act).  EPA's criminal enforcement
program, and, to a lesser extent, its civil enforcement program are,
like other federal law enforcement programs, dependent on tips and
complaints from concerned citizens and members of the regulated
community.  In fact, in some cases, the statute expressly contemplates
that EPA will take action on citizen complaints.  See, e.g., 15 U.S.C.
§ 2647(d) (citizen complaints regarding asbestos hazards).  These tips
and complaints help EPA focus its investigative resources on violations
of environmental law that could otherwise escape detection.

	2(b)	Practical Utility/Users of the Data

			Tips and complaints received through the EPA tips and complaints
webpage are used principally by civil and criminal law enforcement
personnel at EPA to investigate reported accidental violations and
intentional misconduct.  When appropriate, the collected information may
be shared with other law enforcement agencies that may have jurisdiction
over the matter reported.

3.	Non-duplication, Consultations, and Other Collection Criteria

	3(a)	Non-duplication

				

			OECA’s tips and complaints webpage does not duplicate other EPA
web-based information collections.  OECA’s Senior Information
Resources Management Office (SIRMO) has confirmed that the tips and
complaints webpage does not duplicate other web-based information
collections.  

			As noted in Section 1, above, the OECA tips and complaints webform
does not replace or otherwise supplant other means of providing tips or
complaints to EPA; it merely provides a new and convenient means by
which to supply these tips or complaints online.  Accordingly, tippers
or complainants remain free to submit their tips or complaints in person
or by telephone, fax, or e-mail.

	3(b)	Public Notice Required Prior to ICR Submission to OMB.

			EPA has published notice of its intent to renew the ICR for the OECA
tips and complaints webpage.  EPA received one comment in response to
this notice.  That comment recommended that EPA accept tips or
complaints in any form possible and that tippers or complainants should
not be required to use a specific form.  EPA does, in fact, accept tips
or complaints in any form, and tippers or complainants are not required
to use the Tips & Complaints webpage in order submit a tip or complaint.


								

3(c)	Consultations

In order to confirm its burden estimates, EPA timed the entries of
actual tippers or complainants who have used the OECA tips and
complaints webpage.  In order to preserve the confidentiality of these
tippers or complainants, EPA did not record the names of these tippers
or complainants or otherwise record any identifying information.

			

	3(d)	Effects of Less Frequent Collection

			Tips and Complaints are provided to EPA on an entirely voluntary
basis; accordingly, there is no specified frequency with which tips or
complaints should or must be provided.  There is, therefore, no basis to
assess the effects of less frequent collection.

	3(f)	Confidentiality

			Tippers or complainants are not required to provide contact
information in order to submit a tip or complaint.  However, if contact
information is provided, EPA may use this information to initiate
follow-up communications with the tipper or complainant and may be
shared by EPA with appropriate administrative, law enforcement, and
judicial entities engaged in investigating or adjudicating the tip or
complaint.  The information is otherwise protected from disclosure to
third parties to the extent permitted by law.

Authorized access to the database application that is associated with
the tips and complaints webpage is limited and monitored by ID and
password by the Application System Administrators.  Regional and
Criminal Tip Administrators govern who can modify information stored in
the application.  Access to data in the application is ID and Password
protected and is not shared with other systems or personnel outside the
Criminal Investigation personnel, Regional Tip Administrators and
Information Technology staff directly responsible for its development
and/or security. 

			

EPA does not maintain hardcopies of the information supplied through the
webpage.  Tips or complaints not acted upon within 30 days are
automatically purged from the database.  Tips or complaints upon which
some action is taken are preserved for a period of five years, pursuant
to the record schedule for criminal investigations.

			

	3(g)	Sensitive Questions

The tips and complaints web page does not pose any sensitive questions.

4.	The Respondents and the Information Requested

	4(a)	Respondents/SIC Codes

Respondents are expected to be members of the general public as well as
employees of any company subject to federal environmental regulation. 
There is no specific industry or group of industries about which EPA
expects tips or complaints.  For the foregoing reasons, it is not
possible to classify the expected universe of respondents by SIC code.

	4(b)	Information Requested

			(I)	Data items, including recordkeeping requirements

			The information requested on the tips and complaints web page is
listed below.  Items of information that are required in order to submit
a tip or complaint are shown in italics.

If known, the suspected violator’s name

If known, the suspected violator’s street address

If known, the suspected violator’s city

If known, the suspected violator’s zip code

Tipper’s name

Tipper’s email address

Tipper’s phone number

Tipper’s street address

Tippers city

Tipper’s zip code

Is the violation is ongoing?

Has the tipper has already contacted other authorities?

If another authority already contacted, the name of the department
contacted, if known.

If known, is the violation accidental or intentional?

What type of act constitutes the violation? (Release, dumping, spill,
spraying, etc.)

Does the violation affect land, water, air, workers, or documents?

If known, is the violator an individual, company, or government/military
agency or department?

A description of the incident or hazard.

Directions to the site of the violation.

Checkbox attestation of awareness and understanding of the meaning and
significance of submitting a tip or complaint.



			Generally speaking, the items of information requested are not
dictated by environmental statute or regulation; instead, the
information is intended to make it possible to route the tip or
complaint within EPA (or to another, appropriate law enforcement agency)
and to provide inspectors and/or investigators the information that they
need to follow-up on the tip or complaint.  The sole exception is the
checkbox attestation at the end of the web form.  The items of knowledge
to which a tipper or complainant attests by checking this box are
dictated by the general false statements provision of the U.S. Criminal
Code, 18 U.S.C. § 1001.  In the event that EPA prosecutes a tipper of
complainant for deliberately supplying false information on this
webpage, this attestation is intended to frustrate a mistake-of-fact
defense that the tipper or complainant did not understand the nature
and/or significance of submitting a tip or complaint using this web
form.  

		(ii)	Respondent Activities

			

Tippers or complainants are generally expected to review the web form
and complete the form by answering the questions posed.  Those who
choose to do so may also review a general information web page on
reporting an environmental violation and/or a web page that describes
the EPA web privacy policy – the form provides links to these
documents.

Generally speaking, EPA expects tippers to be either a general member of
the public or an employee who believes that their employer has violated
an environmental law.  In either case, EPA expects that tippers or
complainants will come to the web form already in possession of all of
the information needed to submit a tip or complaint.  Even where the
form calls for information that a general member of the public may not
have (say, for example, the address of the suspected violator), the
instructions on the web form explain that the tipper or complainant may
simply enter “unknown” in the field provided for their response.

EPA expects that tippers or complainants who are an employee of the
company about which they are filing a tip or complaint will maintain, as
a matter of customary business practice, the name and address of the
suspected violator.  In all other cases, EPA has no basis to presume
that data items would be maintained as a matter of customary business
practice.  

5.	The Information Collected – Agency Activities, Collection
Methodology, and Information Management

	5(a)	Agency Activities

Many of the activities associated with this webpage are either one-time
events that have already occurred or are ongoing agency activities that
are fully automated (such that they do not constitute an ongoing burden
or expense).  The only activities that are ongoing but not automated are
as follows:



Answer respondent questions

Review and distribute tips or complaints

General maintenance of the system

		

	5(b)	Collection Methodology and Management

The EPA tips and complaints web form was tested as a “pilot” at a
less prominent location on EPA’s website for a period of months.  Only
after this evaluation period did EPA provide a link to the webpage on
its internet home page.

EPA does not check the quality of data entry by tippers or complainants.
 Of course, where a tip or complaints appears to warrant further
investigation, EPA conducts an investigation into the tip or complaint. 
Only in this respect does EPA check data quality.

EPA does not employ special machines or processing technology in
evaluating tips or complaints.  The information supplied by the tipper
or complainant automatically populates a database that is regularly
reviewed by EPA personnel for matters that warrant investigation.  The
information stored in this database cannot be accessed by the public
and, within EPA, access to the database is limited by system
administrators to a small universe of people who are responsible for
reviewing the tips and complaints.

EPA has not eliminated more traditional means of collecting tips and
complaints; the tips and complaints web form simply adds an additional,
convenient method of providing a tip or complaint for those with
internet access.  EPA expects that this method of accepting tips or
complaints will reduce burden for many individuals.  As expected, the
prominence of the tips and complaint web form on our site, the ease with
which the form may be completed, and the relative anonymity that the
internet affords tippers or complainants has resulted in a significant
increase in the number of tips or complaints received.  The web form
also elicits specific items of information that allow EPA to efficiently
route tips or complaints within EPA to the appropriate office.  The
standardized format of the form also represents an advantage over tips
or complaints received by phone, where items of information needed to
evaluate a tip or complaints are more likely to be accidentally omitted.

		5(c)	Small Entity Flexibility

The tips and complaints web form is an addition to, not a substitution
for, other methods of supplying tips or complaints to EPA; accordingly,
the form, itself, constitutes an increase in agency flexibility with
respect to small entities as well as anyone else who may wish to supply
a tip or complaint.

	5(d)	Collection Schedule

Individuals may submit a tip or complaint at any time.  There is no
schedule associated with this collection.

6.	Estimation of the Burden and Cost of the Collection

	6(a),(b)	Annual Respondent Burden & Cost

EPA receives approximately 300 tips or complaints per month through the
existing webpage, for a total of approximately 3,600 responses per year.
 Reading instructions and completing the webform takes approximately a
half hour per response; accordingly, respondents collectively spend
approximately 1,800 hours per year providing tips or complaints through
the tips and complaints webform.  Assuming an average annual wage of
$18.59, the opportunity cost of these burden hours is approximately
$33,462 per year.  This information is summarized in the table shown
below.

Annual Respondent Burden & Cost

Information collection activity	Respondent hours per year	Labor
opportunity

cost per year	Capital/startup costs per year	O&M costs 	Number of
respondents	Total hours per year	Total cost per year



Reading instructions	1,200	22,308	0	0	3,600	1,200	

33,462



Completing form	600	11,154	0	0	3,600	600

	

	

	6(c),(d)	Annual Agency Burden & Cost

EPA technical staff spends approximately 65 hours per month on system
maintenance and upkeep, for a total of 780 hours of technical work on
the system per year.  At an hourly wage of $24, system maintenance costs
EPA approximately $18,720 per year.  EPA receives very few queries from
respondents; accordingly, EPA desk officers spend barely a quarter of an
hour answering respondent questions per year.  They spend approximately
10 hours per month reviewing tips and complaints received through the
system.  At an hourly wage of $39, these functions collectively cost EPA
approximately $4,690 per year.  The total cost to the agency of
operating the tips and complaints webpage is approximately, $23,410. 
This information is summarized in the table shown below.



Annual Agency Burden & Cost

Information collection activity	Agent hours ($39/hour)	Technical hours

($24/hour)	Annual labor cost	Capital/startup costs per year	Total cost
per year

System maintenance	0	780	18,720	0	$18,720

Answer respondent questions	.25	0	9.75	0	$10



Review and distribute tips and complaints	120	0	4,680	0	

$4,680





TOTAL	$23,410



	6(e)	Bottom Line Burden & Cost Tables

		The tables set forth above reflect bottom line estimates.  	

	6(f)	Reasons for Burden Change

		EPA expects no changes in burden associated with this renewal.

	6(g)	Burden Statement

			

ICR: Tips and Complaints Webpage Regarding Environmental Violations

OMB Control Number:  2020-0032

	Providing a tip or complaint to EPA is entirely voluntary and use of
the tips and complaints webpage to provide a tip or complaint is also
entirely a matter of tipper or complainant choice.  EPA estimates that
it will take tippers or complainants approximately ½ hour to provide a
tip or complaint using the tips and complaints webpage.  This estimate
includes time for reading the instructions, gathering required
information, and completing the webform.  There are no associated
record-keeping requirements and, accordingly, no associated
record-keeping burden.

	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-OECA-2006-0557, which is available for online viewing at    
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Enforcement and Compliance Docket and Information
Center 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
(202) 566-1744, and the telephone number for the Enforcement and
Compliance Docket and Information Center is 202-566-1744.  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-OECA-2006-0557and
OMB Control Number 2020-0032 in any correspondence.

			

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