Cross­
Media
Electronic
Reporting
Rule
(
CROMERR)
Cost
Benefit
Analysis
Final
November
17,
2004
ii
EXECUTIVE
SUMMARY
Background
of
the
Rule
On
August
31,
2001,
the
proposed
Cross­
Media
Electronic
Reporting
and
Records
Rule
was
published
in
the
Federal
Register.
As
proposed,
the
rule
was
intended
to
provide
a
uniform
legal
framework
for
paperless
electronic
reporting
and
record­
keeping,
including
electronic
signature/
certification,
across
the
Environmental
Protection
Agency's
(
EPA's)
environmental
programs.
Based
on
public
comment,
however,
EPA
is
now
finalizing
only
the
electronic
reporting
(
ER)
components
of
the
proposed
rule
and
deferring
further
action
on
the
ER­
keeping
components
until
a
later
time.
As
currently
drafted,
the
final
ER
rule
will:

 
Modify
the
current
Code
of
Federal
Regulations
(
CFR)
requirements
to
remove
any
obstacles
to
electronic
reporting
 
Provide
general,
performance­
based
criteria
for
acceptable
electronic
reporting
systems
 
Specify
that
acceptable
electronic
reports
must
by
submitted
using
EPA's
Central
Data
Exchange
(
CDX),
or
comparable
systems
certified
to
satisfy
the
performance­
based
criteria
 
Establish
the
process
for
EPA
oversight
of
electronic
reporting
under
authorized
state,
tribal,
or
local
government
programs,
including
special
streamlined
procedures
for
EPA
approval
of
modifications
or
revisions
to
authorized
programs
to
allow
for
electronic
reporting.

The
final
ER
rule
is
intended
to
make
electronic
reporting
as
simple,
efficient,
and
cost­
effective
as
possible
for
regulated
companies,
while
ensuring
that
a
transition
from
paper
to
electronic
reporting
does
not
compromise
EPA's
compliance
and
enforcement
programs.
Consequently,
the
regulatory
strategy
is
to
impose
as
few
specific
requirements
as
possible
and
to
keep
those
requirements
neutral
with
respect
to
technology,
so
the
rule
will
pose
no
obstacles
to
adopting
new
technologies
as
they
emerge.
Electronic
document
submission
will
be
totally
voluntary;
EPA
will
not
require
the
submission
of
electronic
documents
in
lieu
of
paper
documents.
EPA
will
only
begin
to
accept
direct
submission
of
an
electronic
document
once
EPA
has
provided
public
notice
that
its
electronic
document
receiving
system
is
prepared
to
receive
the
document
in
electronic
form.

For
regulated
entities
that
choose
to
submit
electronic
documents
directly
to
EPA,
the
rule
would
require
that
these
documents
be
submitted
to
a
centralized
Agency­
wide
electronic
documentreceiving
system,
called
the
CDX,
or
to
alternative
systems
designated
by
the
Administrator.
Regulated
entities
that
wish
to
submit
electronic
documents
directly
to
EPA
will
satisfy
the
requirements
in
the
rule
by
successfully
submitting
their
reports
to
the
CDX.

The
rule
also
establishes
provisions
for
regulated
entities
to
comply
with
identity­
proofing
procedures,
as
applicable.

Methodology
In
preparing
this
analysis,
EPA
developed
a
computer
model
that
estimates
the
annual
costs
to
EPA,
State/
Locals,
and
facilities
under
the
final
Cross­
Media
Electronic
Reporting
Rule
(
CROMERR)
and
CDX,
as
well
as
under
an
alternative
scenario.
The
model
then
compares
the
annual
costs
under
both
scenarios
to
assess
the
cost
impact
of
CROMERR
and
CDX.

The
two
scenarios
modeled
were:

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

 
A
"
To
Be"
scenario,
in
which
EPA
enables
electronic
reporting
under
CROMERR
and
CDX.
iii
Table
ES­
1
summarizes
the
scope
of
activities
examined
in
the
model.

Table
ES­
1.
Activities
Examined
in
the
Model
under
"
Baseline"
and
"
To
Be"

"
Baseline"
"
To
Be"

EPA
Establish
program
portals
and
rules
enabling
automation
Establish
the
CDX
and
CROMERR
Automate
individual
information
collections
according
to
the
time
frames
in
Appendix
II
for
"
Baseline"
Automate
individual
collections
according
to
the
time
frames
in
Appendix
II
for
"
To
Be"
and
issue
Federal
Register
notice
for
each
collection
Maintain
Help
Desk*

Process
paperwork
under
electronic
signature
Review/
approve
State/
Locals
Program
modification
requests*

Process
electronic
and
paper
submittals
from
direct
reporters*

State/
Locals
Upgrade
receiving
systems
and
prepare/
submit
program
modification
application
to
EPA
program
areas
Upgrade
receiving
systems
and
prepare/
submit
consolidated
modification
application
to
EPA
Process
paperwork
under
electronic
signature
agreement
Direct
Reporters
(
facilities
that
report
directly
to
EPA)

Register
with
each
program's
gateway,
call
the
program's
Help
Desk,
and
obtain
digital
signature
certificate,
as
applicable
Register
with
CDX,
call
the
CDX
Help
Desk,
and
obtain
digital
signature
certificate,
as
applicable
Process
paperwork
under
electronic
signature
agreement
Perform
extensible
markup
language
(
XML)
or
flat
file
mapping,
if
applicable*

Report
to
EPA
by
paper
or
electronic
method*

Indirect
Reporters
(
i.
e.,
facilities
that
report
to
the
States/
Locals)

Report
to
EPA
by
paper
or
electronic
signature
agreement
Process
paperwork
under
electronic
signature
agreement
*
Same
under
"
Baseline"
and
"
To
Be"

In
developing
the
model,
EPA
identified
the
primary
activities
that
EPA,
State/
Locals,
and
facilities
would
take
under
the
"
Baseline"
and
"
To
Be"
scenarios
as
summarized
above.
For
each
activity,
EPA
estimated
four
basic
parameters
that
govern
the
total
annual
costs
to
them,
respectively:

 
Unit
costs
 
Labor
hour
burden
iv
 
Time
frame
of
activity
 
Number
of
entities
performing
the
activity
EPA
entered
these
parameters
into
the
model's
spreadsheets
for
all
activities
taken
by
EPA,
State/
Locals,
and
facilities.
The
spreadsheets
then
applied
equations
to
these
parameters
to
estimate
the
annual
costs
to
these
entities,
respectively,
across
all
activities
in
each
year
of
the
modeling
period.
Finally,
the
model
discounted
these
costs
to
2003
levels
based
on
both
a
7
percent
discount
rate
and
a
3
percent
discount
rate,
as
recommended
by
the
Office
of
Management
and
Budget
(
OMB)
guidelines.

Refer
to
Table
III­
1
in
Appendix
III
of
this
document
for
a
summary
of
the
data
and
assumptions
used
in
estimating
the
cost
impacts
to
government
and
facilities
in
the
model.

Conclusion/
Findings
In
this
analysis,
the
"
To
Be"
scenario
represents
the
costs
actually
incurred
to
date
under
the
rulemaking
and
CDX,
as
well
as
the
expected
costs
going
forward.
As
shown
in
Table
ES­
2,
EPA
estimates
that
the
total
cumulative
costs
incurred
by
EPA,
State/
Locals,
and
facilities
under
"
To
Be"
from
2003
to
2012
would
be
higher
than
their
costs
incurred
under
"
Baseline"
over
the
same
period.
The
estimated
total
incremental
costs
under
"
To
Be"
range
from
$
34.4
million
to
$
41.7
million,
depending
on
the
discount
rate
used.
Throughout
this
analysis,
in
the
Tables
and
discussion,
the
dollars
referred
to
are
2003
dollars.

Table
ES­
2.
A
Comparison
of
Total
Cumulative
Costs
under
"
To
Be"
Relative
to
"
Baseline"
Between
2003
and
2012*
(
in
millions
of
dollars)

Entity
Cumulative
Costs**
Baseline
To
Be
Difference
in
Cumulative
Costs
To
Be
Relative
to
Baseline
Difference
in
Cumulative
Costs
To
Be
Relative
to
Baseline
Discounted
at
7%
Rate
Difference
in
Cumulative
Costs
To
Be
Relative
to
Baseline
Discounted
at
3%
Rate
EPA
$
703.78
$
618.02
($
85.76)
($
64.44)
($
75.41)

State/
Locals
$
76.29
$
149.04
$
72.75
$
57.19
$
65.20
Facilities
$
7039.34
$
7101.31
$
61.97
$
41.61
$
51.93
Total
$
7819.41
$
7868.37
$
48.96
$
34.36
$
41.72
*
Cost
savings
shown
in
parentheses.

**
Not
discounted.

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

 
Annual
Implementation
Rate.
The
costs
presented
in
Table
ES­
2
reflect
an
annual
implementation
rate
for
electronic
reporting
of
30
percent
of
facilities
during
the
first
year
of
an
information
collection's
automation
start
date.
The
annual
implementation
rate
is
assumed
to
be
10
percent
per
annum
for
the
rest
of
the
modeling
years.
EPA
notes
that
these
rates
are
a
simplifying
assumption,
since
they
likely
will
vary
depending
on
many
factors.
Because
of
this,
EPA
has
performed
sensitivity
runs
based
on
different
implementation
rates.
Refer
to
Section
4.0
for
the
results
of
these
sensitivity
runs.

 
"
Baseline"
Automation
Start
Dates.
EPA
believes
that,
under
"
Baseline",
EPA
would
generally
be
less
expedient
in
promulgating
rules
that
would
allow
for
automation.
The
model
assumes
that,
in
comparison
to
the
automation
start
dates
under
"
To
Be",
information
v
collections
under
"
Baseline"
would
be
delayed
by
2
years.
EPA
notes,
however,
that
its
assumption
of
a
2­
year
delay
is
speculative.

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

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

 
Upgrade
Costs.
In
estimating
upgrade
costs
to
State/
Locals,
EPA
examined
the
state
summary
table
in
Appendix
V.
EPA
attempted
to
identify
State/
Locals
receiving
systems
that
would
not
satisfy
CROMERR
standards
(
e.
g.,
copy
of
record
requirements).
Although
EPA
believes
its
estimates
are
reasonable,
the
Agency
notes
that
they
are
highly
speculative,
since
State/
Locals­
specific
factors
(
e.
g.,
enforcement
priorities,
state
resources,
etc.)
will
determine
each
State/
Locals'
need
for
upgrading
its
systems.
vi
Table
of
Contents
List
of
Exhibits.............................................................................................................
vii
List
of
Tables
...............................................................................................................
vii
1.0
Introduction.........................................................................................................
1
1.1
Background
.................................................................................................................
1
1.1.1
Summary
of
the
Rule
...........................................................................................
1
1.2
Problem
Statement
......................................................................................................
2
1.3
Consideration
of
Alternatives
...........................................................................................
3
1.4
Other
CROMERR
Goals
.............................................................................................
5
1.5
Document
Organization...............................................................................................
6
2.0
Methodology
and
Assumptions.........................................................................
7
2.1
Introduction.................................................................................................................
7
2.1.1
Summary
of
"
Baseline"
and
"
To
Be"
Scenarios
...................................................
7
2.2
Development/
Operation
of
the
Model........................................................................
10
2.3
Model
Data
and
Assumptions
....................................................................................
15
2.3.1
EPA...................................................................................................................
15
2.3.2
State
and
Local
Environmental
Programs...........................................................
22
2.3.3
Facilities
............................................................................................................
26
2.3.4
Electronic
Signature
Agreement.........................................................................
28
3.0
Conclusions
and
Findings
...............................................................................
34
3.1
Total
Costs
................................................................................................................
34
3.2
EPA...........................................................................................................................
34
3.3
State/
Locals...............................................................................................................
34
3.4
Facilities....................................................................................................................
35
4.0
Sensitivity
Analysis
..........................................................................................
37
5.0
Qualitative
Benefits
of
CROMERR
and
CDX...................................................
39
5.1
Summary
of
Other
Impacts........................................................................................
39
6.0
Limitations
of
the
Analysis
..............................................................................
41
Appendix
I.
Information
Collections
To
Be
Automated
by
EPA
...............................................
43
Appendix
II.
Information
Collections
Under
Which
Direct
Reporting
Will
Occur
.....................
51
Appendix
III.
Summary
of
the
Model
Data
and
Assumptions....................................................
56
Appendix
IV.
Labor
Rates
Used
in
the
Analysis.......................................................................
64
Appendix
V.
State
Survey
Data.................................................................................................
66
Appendix
VI.
State
Contacts
.................................................................................................
73
Appendix
VII.
Burden
Hours
and
Costs
to
Direct
Reporters......................................................
74
Appendix
VIII.
Multi­
Media
Reporting
Scaling
Factor
.............................................................
81
Appendix
IX.
Number
of
Direct
Reporters...............................................................................
82
vii
Appendix
X.
XML
and
Flat
File
Usage
.....................................................................................
84
Appendix
XI.
Industry
Consultations
........................................................................................
86
Appendix
XV.
Acronyms
and
Terms
........................................................................................
91
Appendix
XV.
Acronyms
and
Terms
........................................................................................
91
List
of
Exhibits
Exhibit
2­
1.
Activities
Examined
in
the
Model
under
"
Baseline"
and
"
To
Be"
.............................
10
Exhibit
2­
2.
Inputs
and
Outputs
of
the
Model
............................................................................
11
Exhibit
2­
3.
Hourly
Labor
Costs
................................................................................................
12
Exhibit
2­
4.
Example
of
Timeframe
of
Activities
for
OSWER
Under
"
Baseline"..........................
14
Exhibit
2­
5.
Other
Model
Operating
Parameters........................................................................
15
List
of
Tables
Table
ES­
1.
Activities
Examined
in
the
Model
under
"
Baseline"
and
"
To
Be"
...........................
iii
Table
ES­
2.
A
Comparison
of
Total
Cumulative
Costs
under
"
To
Be"
Relative
to
"
Baseline"
Between
2003
and
2012*
(
in
millions
of
dollars)................................................................
iv
Table
2­
1.
Model
Inputs:
Portal
and
Rule
Development
............................................................
16
Table
2­
2.
Model
Inputs:
Developing
Automated
Collections
...................................................
16
Table
2­
3.
Model
Inputs:
EPA
Help
Desk
Costs........................................................................
17
Table
2­
4.
Model
Inputs:
Program
Modification
Applications
...................................................
17
Table
2­
5.
Model
Inputs:
CDX
Development
and
Maintenance
Costs
(
in
millions
of
dollars)...
18
Table
2­
6.
Model
Input:
CROMERR
Development
Costs
.........................................................
18
Table
2­
7.
Model
Input:
Developing
Automated
Collections.....................................................
19
Table
2­
8.
Model
Inputs:
Help
Desk
.........................................................................................
19
Table
2­
9.
Implementation
of
Electronic
Signature
Agreement
Provisions
................................
19
Table
2­
10.
Model
Inputs:
Program
Modification
Applications
.................................................
22
Table
2­
11.
Authorized
State
EPAs
and
State/
Locals
Jurisdictions
............................................
22
Table
2­
12.
Model
Inputs:
State/
Locals
Receiving
Systems
Upgrades
and
Modification
Application
under
"
Baseline"
............................................................................................
23
Table
2­
13.
Model
Inputs:
State/
Locals
Receiving
Systems
Upgrades
and
Modification
Applications
under
"
To
Be"
..............................................................................................
24
Table
2­
14.
State/
Locals
Implementation
of
Electronic
Signature
Agreement
Provisions
for
Submissions
by
Indirect
Reporters
....................................................................................
25
Table
2­
15.
Number
of
Facility
and
Employee
Registrants
under
"
Baseline"*
..........................
27
Table
2­
16.
Number
of
Facility
and
Employee
Registrants
under
"
To
Be"*
..............................
27
Table
2­
17.
Model
Input:
Registration
and
Help
Desk...............................................................
28
Table
2­
18.
Digital
Signature
Certification
Costs
......................................................................
28
Table
2­
19.
Model
Input:
Electronic
Signature
Agreement
Costs
..............................................
28
Table
2­
20.
Annual
Number
of
Facility
and
Employee
Registrants
that
Become
Subject
to
Identity
Proofing
Requirements,
by
Firm
Size
...................................................................
30
Table
2­
21.
Direct/
Indirect
Reporters
Implementation
of
Electronic
Signature
Agreement
Provisions
with
Burden
Assumptions
................................................................................
31
Table
3­
1.
Total
Cost
Impacts
under
o
Be"*
(
in
millions
of
dollars)
.......................................
34
viii
A
Comparison
of
Total
Cumulative
Costs
under
"
To
Be"
Relative
to
"
Baseline"
Between
2003
and
2012*
(
in
millions
of
dollars)......................................................................................
34
Table
4­
1.
A
Comparison
of
Total
Cumulative
Costs
under
"
To
Be"
Relative
to
"
Baseline"
Between
2003
and
2013*
at
Different
Annual
Automation
Rates
(
in
millions
of
dollars)...
38
Table
I­
1.
Information
Collections
To
Be
Automated*..............................................................
43
Table
II­
1.
Information
Collections
Under
Which
Direct
Reporting
Will
Occur*
......................
52
Table
III­
1.
Summary
of
the
Model
Data
and
Assumptions*
.....................................................
56
Table
IV­
1.
Labor
Rates
and
Weight
for
EPA
Employees
.........................................................
64
Table
IV­
2.
Labor
Rates
and
Weight
for
State/
Locals
Employees
.............................................
65
Table
IV­
3.
Labor
Rates
and
Weight
for
Facility
Employees.....................................................
65
Table
V­
1.
State
Overview........................................................................................................
68
Table
V­
2.
Existing
State
Receiving
Systems............................................................................
68
Table
V­
3.
Planned
State
Receiving
Systems
............................................................................
69
Table
V­
4.
Summary
of
State/
Locals
System
Upgrade
Costs
Per
Receiving
System..................
71
Table
V­
5.
Annual
Number
of
State/
Locals
Receiving
System
Employee
Registratants
Under
"
Baseline".........................................................................................................................
71
Table
V­
6.
Annual
Number
of
State/
Locals
Receiving
System
Employee
Registrants
under
"
To
Be"*..................................................................................................................................
72
Table
V­
7.
Upgrade
Costs
Per
State/
Locals
Receiving
System
under
Electronic
Signature
Agreement
Provisions
.......................................................................................................
72
Table
VI­
1.
State
Survey
Contacts
............................................................................................
73
Table
VII­
1.
Scaling
Factors
.....................................................................................................
74
Table
VII­
2.
Annual
Burden
Hours
to
Direct
Reporters*...........................................................
74
Table
VIII­
1.
Facility
Count......................................................................................................
81
Table
IX­
1.
Scaling
Factors.......................................................................................................
82
Table
IX­
2.
Direct
Reporters
and
Registrants*
..........................................................................
83
Table
X­
1.
Number
of
Companies
Implementing
XML/
Flat
File
under
"
Baseline"
...................
84
Table
X­
2.
Number
of
Companies
Implementing
XML/
Flat
File
under
"
To
Be".......................
84
1
1.0
Introduction
1.1
Background
1.1.1
Summary
of
the
Rule
EPA
is
finalizing
a
rule,
referred
to
as
the
Cross­
Media
Electronic
Reporting
and
Records
Rule
(
CROMERR),
to
allow
electronic
reporting
to
EPA
by
permitting
the
use
of
electronic
documentreceiving
systems
to
receive
electronic
documents
in
satisfaction
of
certain
document
submission
requirements
in
EPA's
regulations.
In
addition,
states,
tribes,
and
local
jurisdictions
will
be
able
to
seek
EPA
approval
to
accept
electronic
documents
to
satisfy
reporting
requirements
under
authorized
or
delegated
environmental
programs
that
they
administer.
In
this
analysis,
EPA
refers
to
these
regulators
collectively
as
State/
Locals.
This
rule
includes
criteria
against
which
a
State/
Locals
electronic
document­
receiving
system
will
be
evaluated
before
EPA
can
approve
changes
to
the
authorized
program
that
allows
electronic
reporting.

Electronic
document
submission
will
be
totally
voluntary.
EPA
will
not
require
the
submission
of
electronic
documents
in
lieu
of
paper
documents.
EPA
will
only
begin
to
accept
direct
submission
of
an
electronic
document
once
EPA
has
provided
public
notice
that
its
electronic
document
receiving
system
is
prepared
to
receive
the
document
in
electronic
form.

For
regulated
entities
that
choose
to
submit
electronic
documents
directly
to
EPA,
the
rule
would
require
that
these
documents
be
submitted
to
a
centralized
Agency­
wide
electronic
document
receiving
system,
Central
Data
Exchange
(
CDX),
or
to
alternative
systems
designated
by
the
Administrator.
Regulated
entities
that
wish
to
submit
electronic
documents
directly
to
EPA
will
satisfy
the
requirements
in
the
rule
by
successfully
submitting
their
reports
to
the
CDX.

Many
facilities
submit
documents
directly
to
State/
Locals
that
are
approved,
authorized,
or
delegated
to
administer
a
federal
environmental
program
on
EPA's
behalf
or
to
administer
an
environmental
program
in
lieu
of
the
federal
regulatory
program.
The
rule
provides
for
EPA
approval
of
changes
to
authorized
State/
Locals
programs
to
provide
for
electronic
reporting,
and
EPA
approval
will
be
based
largely
on
an
assessment
of
the
State/
Locals'
electronic
documentreceiving
system
that
will
be
used
to
implement
the
electronic
reporting
provisions.
For
this
purpose,
this
rule
includes
performance­
based
criteria
that
EPA
will
use
to
determine
that
an
electronic
document­
receiving
system
is
acceptable.
To
implement
electronic
reporting
under
authorized
State/
Locals
programs,
EPA
is
creating
an
optional
streamlined
procedure
that
State/
Locals
may
use
to
revise
their
programs
to
incorporate
electronic
reporting.
The
rule
also
includes
special
provisions
for
existing
state
electronic
reporting
systems
in
place
at
the
time
of
publication
of
this
rule.

In
addition,
regulated
entities
reporting
electronically
to
EPA
or
State/
Locals
must
comply
with
the
identity­
proofing
provisions
of
the
rule,
as
applicable.
An
electronic
document
must
bear
the
valid
electronic
signature
of
a
signatory
if
that
signatory
would
be
required
under
the
EPA
or
State/
Locals
environmental
program
to
sign
the
paper
document
for
which
the
electronic
document
substitutes
unless
the
program
makes
special
provisions
to
accept
a
handwritten
signature
on
a
separate
paper
submission,
as
specified.
In
the
case
of
an
electronic
document
that
must
bear
electronic
signatures
of
individuals,
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.
The
rule
further
requires
that,
for
each
electronic
signature
device
used
to
create
an
electronic
signature
on
the
document,
the
identity
of
the
individual
uniquely
entitled
to
use
the
device
and
their
relation
to
any
entity
for
which
they
will
sign
electronic
documents
must
be
determined
with
legal
certainty
by
EPA
or
State/
Locals,
as
applicable.
In
the
case
of
priority
reports,
this
determination
must
be
made
before
the
electronic
document
is
received,
by
means
of:
2
 
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.

 
Completion
and
submittal
of
a
subscriber
agreement
directly
to
the
receiving
agency.
A
subscriber
agreement
is
an
electronic
signature
agreement
signed
by
an
individual
in
ink
on
paper.
The
agreement
is
signed
by
the
individual
with
respect
to
an
electronic
signature
device
that
the
individual
will
use
to
create
their
electronic
signatures
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,
and
responsible
by
the
electronic
signatures
created
as
by
a
handwritten
signature.

 
Designation
of
a
local
registration
authority
(
LRA).
The
LRA
is
an
individual
who
is
authorized
by
EPA
or
the
state
to
issue
an
agreement
collection
certification.
An
agreement
collection
certification
is
a
signed
statement
by
which
an
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
that
the
local
registration
authority;
and
that
the
local
registration
authority
has
no
basis
to
believe
that
any
of
the
collected
agreements
have
been
tampered
with
or
prematurely
destroyed.

1.2
Problem
Statement
The
primary
purpose
of
CROMERR
is
to
set
standards
for
electronic
reporting
as
it
is
implemented
by
State,
Tribal
or
local
governments
administer
environmental
programs
under
EPA
authorization
or
delegation.
EPA
has
been
motivated
to
set
such
standards
primarily
by
considering:

 
The
roles
that
many
electronically
submitted
documents
would
likely
play
in
environmental
program
management,
including
compliance
monitoring
and
enforcement;

 
EPA's
statutory
obligation
to
ensure
that
authorized
or
delegated
programs
maintain
the
enforceability
of
environmental
law
and
regulations;
and
 
The
consequent
need
to
ensure
that
enforceability
is
not
compromised
as
authorized
or
delegated
program
make
the
transition
from
paper
to
electronic
submission
of
compliance­
or
enforcement­
related
documents.

Concerning
this
last
point,
in
many
respects
electronic
submission
enhances
a
document's
utility
for
environmental
programs:
it
significantly
reduces
the
resources
and
time
involved
in
making
the
content
available
to
its
users,
and
can
greatly
facilitate
data
quality
assurance
and
analysis.
Nonetheless,
the
federal
government's
experience
with
prosecuting
computer­
related
crimes
has
shown
us
that
electronic
submissions
may
also
be
open
to
challenge,
primarily
with
respect
to
their
authenticity
 
and
particularly
where
they
are
used
to
establish
the
actions
and
intentions
of
the
submitters.
We
have
to
consider
such
uses
in
the
case
of
environmental
reporting,
especially
where
3
electronic
submissions
are
made
to
report
on
an
entity's
compliance
status
and
where
the
submission
includes
a
responsible
individual's
certification
to
the
truth
of
what
is
reported.
For
such
cases,
EPA
has
identified
a
programmatic
need
to
be
able
to
authenticate
the
submission
content
and
the
certification
 
for
example,
to
be
able
to
address
issues
of
fraud
or
false
reporting
where
they
arise
 
and
it
is
primarily
to
address
this
problem
of
authentication
that
EPA
is
setting
standards
for
electronic
reporting
through
CROMERR.

The
point
of
these
standards
is
to
assure
the
authenticity
of
electronic
documents
submitted
in
lieu
of
paper
reports,
so
that
they
are
able
to
play
the
same
role
as
their
paper
counterparts
in
providing
evidence
of
what
was
reported
and
of
what
an
identified
individual
certified
to
with
respect
to
the
report.
For
example,
in
the
case
of
paper
submissions,
the
evidence
surrounding
a
handwritten
signature
is
normally
sufficient
to
demonstrate
that
the
signature
is
authentic
and
rebut
any
attempt
by
the
signatory
to
repudiate
it
 
and
EPA
intends
the
CROMERR
standards
ensure
that
electronic
signatures
have
a
corresponding
level
of
non­
repudiation.
Since
these
evidentiary
issues
typically
arise
in
the
context
of
judicial
or
other
legal
proceedings,
electronic
documents
need
to
have
the
same
"
legal
dependability"
as
their
paper
counterparts.
The
over­
arching
standard
here
is
that
any
electronic
document
used
as
evidence
to
prosecute
an
environmental
crime
or
to
enforce
against
a
civil
violation
must
have
no
less
evidentiary
value
than
its
paper
equivalent.
For
example,
where
there
is
a
question
of
deliberate
falsification
of
compliance
data,
whether
the
submission
was
electronic
or
paper,
it
must
be
possible
to
establish
the
signatory's
identity
beyond
a
reasonable
doubt.
Hence,
in
general,
the
goal
of
the
CROMERR
standards
is
to
ensure
that
a
system
used
to
receive
electronic
documents
is
capable
of
reliably
generating
evidence
for
use
in
private
litigation,
in
civil
enforcement
proceedings,
and
in
criminal
proceedings
in
which
the
standard
for
conviction
is
proof
beyond
a
reasonable
doubt
that
the
electronic
document
was
actually
signed
by
the
individual
identified
as
the
signatory
and
that
the
data
it
contains
was
not
submitted
in
error.

1.3
Consideration
of
Alternatives
EPA
considered
both
a
more
stringent
and
a
less
stringent
alternative
to
the
regulatory
approach
taken
in
final
CROMERR.
The
more
stringent
alternative
is
reflected
in
the
electronic
provisions
published,
August
31,
2001,
in
the
Notice
of
Proposed
Rulemaking
for
CROMERR.
The
proposed
version
of
CROMERR
is
more
stringent
by
virtue
of
setting
much
more
prescriptive,
detailed
requirements
that
acceptable
electronic
document
receiving
systems
would
have
to
satisfy.
For
example,
proposed
§
3.2000(
d)
set
very
specific
requirements
for
submitter
identity
management
that
a
system
would
have
to
satisfy,
including
detailed
requirements
for
renewal
of
registration
and
revocation
of
registration
under
specified
circumstances.
Again,
§
3.2000(
e)
set
very
detailed
requirements
for
the
signature/
certification
scenario
that
a
system
would
have
to
provide
for,
specifying
the
exact
sequence
of
steps
to
be
followed
in
electronically
signing
a
submission,
and
requiring
such
features
as
on­
screen,
scroll­
4
through
presentation
of
the
data
to
be
submitted
for
review
of
the
signatory
prior
to
signing
(
§
3.2000(
e)(
1)(
i)).
EPA
received
significant
public
comment
on
this
approach,
both
from
States
and
from
regulated
companies,
and
there
were
at
least
three
closely
related
themes.
The
first
was
that
such
prescriptive
requirements
would
greatly
limit
the
flexibility
of
States
to
implement
electronic
reporting
in
cost­
effective
way.
Many
of
the
comments
pointed
that
such
requirements
would
render
the
investments
that
States
had
already
made
in
electronic
reporting
infrastructure
virtually
worthless,
would
prohibit
their
use
of
COTS
products,
and
would
require,
instead,
the
development
of
very
costly
customized
systems
that
might
be
both
difficult
and
expensive
to
operate
and
maintain.
The
second
theme
was
that
many
of
the
requirements
 
especially
those
specifying
the
signature/
certification
scenario
 
were
simply
not
appropriate
to
many
cases
where
electronic
reporting
would
occur.
Some
commenters
cited
examples
where
very
large
data
files
would
be
transferred,
rendering
on­
screen
review
impractical;
others
pointed
out
that
company
business
processes
involved
in
internal
review,
approval
and
certification
of
regulatory
submissions
was
simply
not
compatible
with
the
specified
scenario.
Third
and
finally,
many
of
these
commenters
expressed
skepticism
that
these
very
detailed
requirements
represented
the
only
possible
approach
to
ensuring
the
legal
dependability
of
electronic
submissions
and
signatures.
In
considering
such
comments,
EPA
has
concluded
that,
given
our
inexperience
with
electronic
reporting,
we
simply
lack
a
basis
for
certainty
that
any
particular
set
of
function­
based
requirements
at
the
level
of
specificity
reflected
in
proposed
CROMERR
is
(
or
is
not)
necessary
for
legally
dependable
electronic
submissions.
Given
the
evidently
high
cost
 
to
both
States
and
regulated
entities
 
that
such
requirements
would
impose,
we
decided
it
would
be
better
to
focus
on
criteria
that
directly
articulate
these
basic
issues,
that
is,
the
underlying
goal
of
assuring
legal
dependability,
including
the
authenticity
of
electronic
documents
and
the
nonrepudiation
of
electronic
signatures.
Accordingly,
we
are
setting
standards
in
terms
of
general
system
performance
goals
that
are
less
stringent
by
virtue
of
allowing
much
greater
flexibility
in
how
such
goals
are
met
in
specific
implementations.

In
writing
these
general
performance
goals,
EPA
also
considered
a
less
stringent
alternative
that
would
have
refrained
from
specifying
performance
in
terms
of
establishing
the
identity
of
an
individual
to
whom
a
signature
device
or
credential
(
e.
g.
a
PIN,
password,
or
PKI
certificate)
is
issued.
With
reference
to
the
final
CROMERR
provisions,
this
less
stringent
alternative
would
have
omitted
§
3.2000(
b)(
5)(
vii)
identity­
proofing
provisions.
In
terms
of
regulatory
impact,
this
would
be
a
significant
reduction
in
stringency,
insofar
as
most
of
CROMERR's
burden
on
regulated
entities
is
associated
with
have
to
register
to
obtain
a
signature
device
or
credential,
and
any
identity­
proofing
requirement
raises
at
least
the
aggregate
burden
substantially.
EPA
rejected
this
alternative,
because
we
believe
that
it
would
seriously
 
perhaps
fatally
 
undermine
the
rule's
ability
to
assure
the
legal
dependability
of
electronic
submissions.
It
is
a
basic
principle
of
electronic
authentication
(
E­
authentication)
 
whether
in
the
context
of
validating
an
individual's
signature,
or
for
other
purposes
 
that
our
confidence
that
the
individual
being
authenticated
is
who
we
believe
him
or
her
to
be
depends
critically
on
the
degree
of
trust
we
can
place
in
the
5
credential
the
individual
presents.
Trust
is
largely
a
function
of
the
identityproofing
process
conducted
when
the
individual
registered
for
the
credential
in
the
first
place
 
the
process
must
have
been
sufficiently
stringent
and
credible.
If
we
did
not
establish
with
sufficient
certainty
who
this
individual
was
when
we
issued
the
credential,
then
we
cannot
be
certain
who
is
using
the
credential
in
a
specific
instance
where
it
is
presented.
Where
the
credential
is
used
to
create
an
electronic
signature,
then,
inadequate
identityproofing
would
mean
that
we
cannot
be
certain
who
the
signatory
is
 
that
is,
no
specific
individual
would
be
bound
with
any
certainty
by
the
signature
 
and
this
would
render
the
signature
virtually
worthless
for
any
legal
purpose.
In
view
of
this,
EPA
felt
that,
notwithstanding
the
cost,
it
was
necessary
to
specify
that
identity
proofing
be
conducted.
Additionally,
for
electronic
documents
of
particular
legal
importance
to
environmental
programs
 
identified
as
the
"
priority
reports"
 
we
felt
that
is
was
necessary
to
specify,
at
least
to
a
degree,
how
the
identity
proofing
had
to
be
performed.
We
believe
we
need
this
additional
specification
for
cases
where
signatory
identity
may
be
a
legal
issue,
so
that
we
are
assured
that
electronic
reporting
implementations
give
us
clear
and
predictable
methods
to
establish
this
identity
that
conform
to
the
standard
practices
of
electronic
commerce.

1.4
Other
CROMERR
Goals
EPA
also
envisions
that
the
goals
of
the
CROMERR
and
CDX
will:

 
Reduce
the
cost
and
burden
of
data
transfer
and
maintenance
for
all
parties
to
the
data
exchanges;

 
Improve
the
data
and
the
various
business
processes
associated
with
its
use
in
ways
that
may
not
be
reflected
directly
in
cost
reduction
(
e.
g.,
through
improvements
in
data
quality),
and
the
speed
and
convenience
with
which
data
may
be
transferred
and
used.

 
Maintain
the
level
of
corporate
and
individual
responsibility
and
accountability
for
electronic
reports
and
records
that
currently
exists
in
the
paper
environment.

The
intended
effect
of
this
regulation
is
to
permit
use
of
electronic
technologies
in
a
manner
that
is
consistent
with
EPA's
overall
mission
and
that
preserves
the
integrity
of
the
Agency's
compliance
and
enforcement
activities.
Concerning
the
third
goal,
the
Agency
continues
to
believe
that
it
is
essential
that
EPA
continue
to
ensure
sufficient
personal
and
corporate
responsibility
and
accountability
in
the
submission
of
electronic
reports
and
the
maintenance
of
electronic
records;
otherwise,
EPA
places
at
risk
the
continuing
viability
of
self­
monitoring
and
self­
reporting
that
provides
the
framework
for
compliance
under
most
of
our
environmental
programs.

In
recent
years,
electronic
reporting
and
record­
keeping
have
had
strong
mandate
in
federal
policy
and
law.
The
Government
Paperwork
Elimination
Act
(
GPEA)
of
1998,
Public
Law
105­
277,
requires
that
agencies
be
prepared
to
allow
electronic
reporting
and
record­
keeping
under
their
regulatory
programs
by
October
21,
2003.
Given
the
enormous
strides
in
data
transfer
and
management
technologies
since
1990,
particularly
in
connection
with
the
Internet,
replacing
paper
with
electronic
data
transfer
now
promises
increased
productivity
across
almost
all
facets
of
business
and
government.

In
short,
the
purpose
of
the
rule
is
to
permit
the
use
of
a
technology
that
was
not
contemplated
when
most
existing
EPA
regulations
were
written,
without
undermining
in
any
way
the
integrity
of
environmental
compliance
documents
or
the
ability
of
EPA
to
carry
out
its
statutory
6
environmental
and
health
protection
mandate.
The
rule
will
permit
regulated
industry,
EPA,
and
State/
Locals
to
operate
with
greater
flexibility
in
ways
that
improve
both
efficiency
and
the
speed
of
regulatory
processes.
At
the
same
time,
it
ensures
that
individuals
will
assign
the
same
level
of
importance
to
affixing
their
electronic
signatures
(
and
to
the
documents
to
which
the
signature
attests)
as
they
currently
do
to
a
handwritten
signature.

1.5
Document
Organization
The
remainder
of
this
document
is
organized
as
follows:

 
Section
2.0
­
Methodology
and
Assumptions
 
Section
3.0
­
Conclusions
and
Findings
 
Section
4.0
­
Sensitivity
Analysis
 
Section
5.0
­
Qualitative
Benefits
of
CROMERR
and
CDX
 
Section
6.0
­
Limitations
of
the
Analysis
7
2.0
Methodology
and
Assumptions
2.1
Introduction
2.1.1
Summary
of
"
Baseline"
and
"
To
Be"
Scenarios
In
preparing
this
analysis,
EPA
developed
a
computer
model
that
estimates
the
annual
costs
to
EPA,
State/
Locals,
and
facilities
under
the
final
CROMERR
and
CDX,
as
well
as
under
an
alternative
scenario.
The
model
then
compares
the
annual
costs
under
both
scenarios
to
assess
the
cost
impact
of
CROMERR
and
CDX.
As
described
earlier,
the
CROMERR
and
CDX
would
have
the
primary
effect
of
allowing
facilities
to
report
electronically
to
EPA
under
its
information
collections,
as
provided
by
GPEA.
The
rule
would
also
require
State/
Locals
to
upgrade
their
receiving
systems
to
meet
the
CROMERR
standards,
if
needed,
and
apply
for
EPA
program
modification
approval.
EPA
chose
a
10­
year
period
for
the
regulatory
impact
analysis,
because
we
believe
that
this
is
roughly
the
time
frame
for
EPA
and
our
authorized
or
delegated
State,
Tribal
and
local
government
programs
to
achieve
full
implementation
of
electronic
reporting
under
CROMERR.
Accordingly,
looking
at
the
out­
years
beyond
the
10­
year
time
frame
would
not
provide
any
additional
analytic
information
about
CROMERR's
impacts.

As
a
first
step
in
developing
the
model,
EPA
surveyed
its
program
offices
to
identify
the
specific
information
collections
they
intend
to
automate
under
GPEA,
as
well
as
the
anticipated
year
each
collection
will
be
automated
(
i.
e.,
the
automation
start
date).
In
total,
the
programs
identified
137
information
collections
to
be
automated.
These
collections
are
identified
in
Appendix
I,
along
with
their
expected
automation
start
date.
1
Note
that
each
collection
in
Appendix
I
is
identified
by
the
title
of
its
corresponding
Information
Collection
Request
(
ICR).
That
is,
under
the
1995
Paperwork
Reduction
Act
(
PRA),
EPA
is
required
to
prepare
ICRs
for
all
of
its
information
collections.
The
ICRs
in
Appendix
I
estimate
the
annual
hour
burden
to
EPA
and
facilities
under
the
collections
and
were,
therefore,
used
as
a
basis
for
developing
the
model.

In
addition,
during
the
Summer
of
2002,
EPA
spoke
with
regulators
in
15
states
to
learn
about
their
progress
in
automating
their
collections.
EPA
found
that
each
of
these
states
has
at
least
one
existing
or
planned
receiving
system
for
collecting
electronic
information
from
facilities.
EPA,
therefore,
believes
that
State/
Locals
are
developing
electronic
receiving
systems
irrespective
of
CROMERR.
CROMERR
would
have
little
cost
impact
on
them,
except
to
require
(
1)
upgrades
to
their
receiving
systems,
if
necessary,
to
meet
the
rule's
standards
at
40
CFR
3.2000;
(
2)
EPA
program
modification
approval
of
their
receiving
systems
in
accordance
with
40
CFR
3.10002
;
(
3)
and
development/
implementation
of
the
identity­
proofing
provisions.
From
this,
EPA
concluded
that
the
model
should
examine
cost
impacts
to
State/
Locals
only
in
upgrading
their
systems,
applying
to
EPA
for
program
modification
approval,
and
carrying
out
electronic
signature
agreement
provisions.
The
model
should
not
examine
their
costs
for
originally
developing
the
systems
or
receiving/
processing
submittals
from
facilities
using
these
systems.
They
would
have
incurred
these
costs
irrespective
of
EPA's
actions.

In
regard
to
facilities,
the
final
rule
and
CDX
would
affect
those
facilities
that
report
directly
to
EPA
(
also
referred
to
as
direct
reporters
in
this
document)
in
that
electronic
reporting
would
now
be
available.
The
final
rule
and
CDX
would
not
impact
facilities
in
reporting
under
State/
Locals
collections
(
also
referred
to
as
indirect
reporters),
except
to
require
them
to
comply
with
its
identity­
proofing
requirements.
Therefore,
EPA
has
concluded
that
the
model
should
examine
1
Note
that
EPA
removed
some
of
these
collections
from
this
analysis
(
e.
g.,
collections
administered
completely
at
the
State/
Locals
level).
2
It
should
also
be
noted
that
CROMERR
does
not
require
State/
Locals
to
provide
for
electronic
reporting.
Therefore,
any
automation
taking
place
at
the
State/
Locals
level
would
be
completely
voluntary.
8
the
costs
to
direct
reporters
for
all
activities
associated
with
paper
and
electronic
reporting
(
e.
g.,
registering
with
the
CDX,
complying
with
identity­
proofing
provisions,
and
submitting
electronic
documents
to
the
CDX
under
EPA's
information
collections).
The
model
should
examine
cost
impacts
to
indirect
reporters
only
for
the
identity­
proofing
provisions.

Note
that
the
rule
provides
considerable
flexibility
for
regulatory
agencies
to
decide
on
the
most
appropriate
identity­
proofing
approach
for
their
receiving
systems
and
electronic
signature
devices.
EPA
expects
that
many
State/
Locals
will
require
regulated
entities
to
submit
subscriber
agreements
or
designate
an
LRA.
Other
State/
Locals
(
e.
g.,
those
implementing
Public
Key
Infrastructure)
may,
at
their
own
initiative,
implement
other
approaches,
e.
g.,
approaches
that
involve
the
use
of
identifiers
or
attributes.
In
this
Cost
Benefit
Analysis
(
CBA),
EPA
makes
the
simplifying
assumption
that
all
regulatory
agencies
will
require
submittal
of
subscriber
agreements
or
use
of
an
LRA.
In
this
regard,
the
CBA
estimates
costs
to
all
direct
and
indirect
reporters
for
carrying
out
the
rule's
provisions
for
subscriber
agreements
and
LRAs.

Based
on
the
above
research
and
assumptions,
EPA­
developed
and
estimated
cost
impacts
under
two
scenarios:

 
An
"
Baseline"
scenario,
in
which
EPA
would
enable
electronic
reporting
through
an
approach
other
than
CROMERR
and
CDX3.

 
A
"
To
Be"
scenario,
in
which
EPA
enables
electronic
reporting
under
CROMERR
and
CDX.

2.1.1.1
"
Baseline"

In
developing
the
"
Baseline"
scenario,
EPA
envisions
that
it
would
have
pursued
electronic
reporting
through
an
alternate
approach
were
it
not
for
CROMERR
and
CDX.
The
GPEA
of
1998
requires
the
Agency
to
allow
electronic
reporting
by
2003.
In
addition,
EPA
is
firmly
committed
to
reducing
burden
under
its
information
collections,
not
only
as
part
of
its
own
internal
agenda,
but
also
in
response
to
Congressional
mandates
(
e.
g.,
the
1995
PRA)
and
stakeholder
requests.
Therefore,
it
is
reasonable
to
assume
that
EPA
would
have
pursued
automation
even
in
the
absence
of
CROMERR
and
the
CDX
and
that
a
"
no­
action"
alternative
(
i.
e.,
where
EPA
takes
no
action
to
automate
its
collections)
is
not
realistic.

In
the
absence
of
an
Agency­
wide
rule
and
portal,
EPA
envisions
that
it
would
have
enabled
automation
on
a
piecemeal
basis
across,
and
even
within,
program
areas.
Individual
programs
would
be
responsible
for
developing
their
own
portals
for
receiving
electronic
information
and
publishing
rules
amending
their
regulations
(
e.
g.,
to
allow
for
the
use
of
electronic
signatures
in
lieu
of
handwritten
signatures).
EPA
estimates
that
nine
Agency
program
areas
would
have
developed
portals
and
rules.
4
3
As
mentioned
above,
the
"
Baseline"
scenario
does
not
involve
reporting
to
the
CDX.
It
is
important
to
note
that
EPA
views
the
CDX
and
CROMERR
as
the
outcomes
of
the
Agency's
longstanding
effort
to
enable
uniform
electronic
reporting
across
the
Agency.
Their
development
has
been
inextricably
intertwined,
in
that
the
CDX's
reporting
process
and
technology
standards
have
influenced
EPA's
research
and
analysis
performed
on
behalf
of
the
rule.
CROMERR
codifies
standards
for
electronic
documentsreceiving
systems
operated
by
authorized
state
and
local
governmental
entities.
These
standards,
as
a
practical
(
but
not
legal)
matter,
have
defined
the
requirements
of
CDX.
In
this
regard,
EPA
views
the
historical
development
of
the
CDX
and
CROMERR
as
inextricably
related
and,
therefore,
does
not
include
the
CDX
as
part
of
the
"
Baseline"
scenario.

4
In
general,
EPA
expects
that
the
standards
established
under
EPA's
rules
under
the
"
Baseline"
scenario
would
be
comparable
in
scope
and
stringency
to
CROMERR
and
the
CDX.
The
CROMERR
and
CDX
reflect
EPA's
programmatic
goals,
the
existing
capabilities
of
electronic
systems,
as
well
as
EPA's
deliberations
with
its
stakeholders.
Under
"
Baseline",
EPA
would
have
encountered
these
same
issues
in
establishing
its
portals
and
rules.
Therefore,
the
model
assumes
that,
under
"
Baseline",
EPA's
gateways
and
rulemakings
would
be
comparable
in
scope
and
stringency
to
the
CDX
and
CROMERR.
Note,
however,
that
the
model
differs
in
its
examination
of
electronic
signature
agreement
costs
under
"
Baseline"
and
"
To
Be".
Under
"
Baseline",
the
model
assumes
registrants
would
follow
relatively
simple
procedures
for
preparing
and
keeping
records
of
an
agreement.
Under
"
To
Be",
the
model
examines
in
significantly
greater
detail
all
of
the
activities
that
EPA,
State/
Locals,
and
facilities
would
take
in
preparing,
keeping
records
of,
and
submitting/
processing
subscriber
agreements
and
other
paperwork.
9
In
addition,
EPA
envisions
that
it
would
have
automated
the
same
collections
under
"
Baseline"
and
"
To
Be".
As
described
earlier,
EPA
polled
the
programs
to
identify
the
information
collections
they
intend
to
automate
in
compliance
with
GPEA.
In
total,
137
collections
were
identified,
as
listed
in
Appendix
I.
Note
that,
for
purposes
of
this
analysis,
EPA
subsequently
reviewed
and
modified
this
list
by
removing
certain
collections
that
are
outside
the
scope
of
this
analysis.
Based
on
this
review,
EPA
produced
a
revised
list
of
information
collections,
as
shown
in
Appendix
II.
The
appendix
also
describes
EPA's
rationale
for
eliminating
them.
In
total,
the
model
examines
68
information
collections
under
"
Baseline"
and
"
To
Be".

The
model
also
assumes
the
Agency
will
convert
its
collections
to
an
electronic
format
(
e.
g.,
preparation
of
Web
forms,
schemas,
etc.)
by
the
automation
start
dates
in
Appendix
II
for
"
Baseline".

The
model
assumes
that,
after
EPA
publishes
its
rules
enabling
automation
under
"
Baseline",
authorized
State/
Locals
would
upgrade
their
receiving
systems
to
satisfy
the
rule's
standards,
as
necessary.
They
would
also
prepare
and
submit
modification
requests
to
the
EPA
programs,
as
applicable.

In
addition,
direct
reporters
would
register
with
a
program's
receiving
system,
obtain
an
electronic
signature
certificate,
if
required,
and
begin
to
report
electronically
by
Web
form,
XML,
or
flat
file.
The
model
examines
paper
and
electronic
reporting
to
the
CDX
throughout
the
modeling
period
under
the
68
collections.

Facilities
reporting
to
State/
Locals
(
i.
e.,
indirect
reporters)
would
be
required
to
prepare
and
keep
a
handwritten
electronic
signature
agreement
on
site
for
each
employee
who
reports
to
the
State/
Locals
receiving
system.

2.1.1.2
"
To
Be"

Under
"
To
Be",
CROMERR
would
provide
for
uniform
receiving
system
standards
for
the
CDX
and
other
approved
EPA
systems.
The
model
assumes
EPA
began
development
of
the
CDX
and
CROMERR
in
2000
and
publishes
the
final
CROMERR
in
2003.
The
model
also
assumes
the
Agency
will
convert
its
collections
to
an
electronic
format
(
e.
g.,
preparation
of
Web
forms,
schemas,
etc.)
by
the
automation
start
dates
in
Appendix
II
for
"
To
Be".
The
model
assumes
that
EPA
would
issue
a
notice
in
the
Federal
Register
announcing
the
availability
of
electronic
reporting
for
each
collection.

The
model
assumes
that
authorized
State/
Locals
would
begin
to
upgrade
their
receiving
systems
to
satisfy
CROMERR,
as
necessary,
and
prepare
their
program
modification
requests
to
EPA,
once
CROMERR
is
published.
Note
that
CROMERR
gives
State/
Locals
the
option
of
either
submitting
a
consolidated
application
to
EPA
or
separate
applications
to
each
EPA
program,
as
applicable.
The
model
assumes
that
State/
Locals
would
submit
a
consolidated
application,
because
it
would
streamline
the
application­
preparation
process.
State/
Locals
also
will
implement
the
rule's
electronic
signature
agreement
provision
(
e.
g.,
receiving,
processing,
and
keeping
records
of
submittals
from
indirect
reporters).

In
addition,
direct
reporters
would
register
with
the
CDX,
obtain
an
electronic
signature
certificate,
if
required,
and
begin
to
report
electronically
by
Web
form,
XML,
or
flat
file.

Finally,
the
model
assumes
that
all
direct
and
indirect
reporters
would
comply
with
the
rule's
electronic
signature
agreement
requirements.
Refer
to
Appendix
III
for
a
full
description
of
these
activities.
Exhibit
2­
1
summarizes
the
broad
activities
examined
in
the
model
for
"
Baseline"
and
"
To
Be".

"
Baseline"
"
To
Be"
10
"
Baseline"
"
To
Be"

EPA
Establish
program
portals
and
rules
enabling
automation
Establish
the
CDX
and
CROMERR
Automate
individual
information
collections
according
to
the
time
frames
in
Appendix
II
for
"
Baseline"
Automate
individual
collections
according
to
the
time
frames
in
Appendix
II
for
"
To
Be"
and
issue
Federal
Register
notice
for
each
collection
Maintain
Help
Desk*

Process
paperwork
under
electronic
signature
Review/
approve
State/
Locals
Program
modification
requests*

Process
electronic
and
paper
submittals
from
direct
reporters*

State/
Locals
Upgrade
receiving
systems
and
prepare/
submit
program
modification
application
to
EPA
program
areas
Upgrade
receiving
systems
and
prepare/
submit
consolidated
modification
application
to
EPA
Process
paperwork
under
electronic
signature
agreement
Direct
Reporters
(
facilities
that
report
directly
to
EPA)

Register
with
each
program's
gateway,
call
the
program's
Help
Desk,
and
obtain
digital
signature
certificate,
as
applicable
Register
with
CDX,
call
the
CDX
Help
Desk,
and
obtain
digital
signature
certificate,
as
applicable
Process
paperwork
under
electronic
signature
agreement
Perform
XML
or
flat
file
mapping,
if
applicable*

Report
to
EPA
by
paper
or
electronic
method*

Indirect
Reporters
(
i.
e.,
facilities
that
report
to
the
States/
Locals)

Report
to
EPA
by
paper
or
electronic
signature
agreement
Process
paperwork
under
electronic
signature
agreement
*
Same
under
"
Baseline"
and
"
To
Be"

Exhibit
2­
1.
Activities
Examined
in
the
Model
under
"
Baseline"
and
"
To
Be"

2.2
Development/
Operation
of
the
Model
In
developing
the
model,
EPA
identified
the
primary
activities
that
EPA,
State/
Locals,
and
facilities
would
take
under
the
"
Baseline"
and
"
To
Be"
scenarios
as
summarized
above.
For
11
each
activity,
EPA
estimated
four
basic
parameters
that
govern
the
total
annual
costs
to
them,
respectively:

 
Unit
costs
 
Labor
hour
burden
 
Time
frame
of
activity
 
Number
of
entities
conducting
activity
EPA
entered
these
parameters
into
the
model's
spreadsheets
for
all
activities
taken
by
EPA,
State/
Locals,
and
facilities.
The
spreadsheets
were
then
used
to
apply
equations
to
these
parameters
to
estimate
the
annual
costs
to
these
entities,
respectively,
across
all
activities
in
each
year
of
the
modeling
period.
In
general,
the
model
used
straightforward
calculations
to
estimate
the
cost
impacts
to
these
entities
(
e.
g.,
annual
number
of
entities
performing
an
activity
multiplied
by
its
unit
cost
equals
the
total
annual
cost
for
activity).
In
certain
cases,
the
equations
were
more
complex.
In
these
cases,
the
equations
are
presented
in
Appendix
XII
to
this
analysis.
Exhibit
2­
2
illustrates
the
basic
inputs
of
the
model.

Exhibit
2­
2.
Inputs
and
Outputs
of
the
Model
Unit
Costs.
Unit
costs
include
labor,
capital,
and
maintenance
costs
associated
with
activities
examined
in
the
model.
In
regard
to
labor
costs,
the
model
drew
from
two
sources
of
labor
costs
for
the
calculations.

 
Average
hourly
labor
costs
associated
with
facility
reporting
under
EPA's
information
collections.
These
costs
were
obtained
from
the
specific
ICRs
associated
with
each
collection
and
include
overhead
and
fringe
as
applicable,
as
described
in
the
ICRs.

 
Average
hourly
labor
costs
associated
with
all
other
activities
in
the
model.
EPA
developed
standard
hourly
labor
rates
for
EPA,
State/
Locals,
and
facility
employees.
These
costs
include
overhead
and
fringe.
Refer
to
Appendix
IV
for
information
on
how
EPA
derived
these
hourly
rates.
12
Type
of
Personnel
Hourly
Labor
Rate
EPA
$
41.68/
hr
State/
Local
$
30.42/
hr
Facility
$
39.23/
hr
Exhibit
2­
3.
Hourly
Labor
Costs
The
model
also
examines
the
capital
(
i.
e.,
start­
up)
and
maintenance
costs
associated
with
each
activity.
These
costs
vary
by
activity
and
are
presented
in
Section
2.3
as
specific
to
the
activity
and
in
the
appendices,
as
applicable.

Labor
Hour
Burden.
For
each
activity,
EPA
estimated
the
labor
hour
burden
and
entered
it
into
the
model
as
a
basic
input
assumption.

 
In
regard
to
EPA,
the
model
includes
labor
hours
for
providing
Help
Desk
support,
reviewing
State/
Locals
program
modification
applications,
and
implementing
electronic
signature
agreement
provisions.
EPA
used
its
best
judgment
in
estimating
the
time
associated
with
these
activities.

The
model
also
includes
labor
hours
for
EPA
to
receive
and
process
both
paper
and
electronic
submittals
from
direct
reporters.
These
hours
were
obtained
from
the
68
information
collections
in
Appendix
II.
Note
that
the
appendix
does
not
show
hours
for
EPA
labor.
5
 
State/
Locals
labor
hours
are
primarily
associated
with
preparation/
submittal
of
program
modification
applications
to
EPA
and
implementing
electronic
signature
agreement
provisions.
EPA
consulted
regulators
in
15
states
in
estimating
the
hour
burden
for
many
of
these
activities.
Refer
to
Appendix
V
for
additional
information
on
EPA's
analysis
of
these
data
and
Appendix
VI
for
the
names
of
EPA's
contacts.

The
labor
hours
for
direct
reporters
are
drawn
primarily
from
the
68
information
collections
in
Appendix
II,
which
estimate
the
total
annual
hour
burden
to
facilities
under
the
information
collections
being
automated.
EPA
reviewed
each
ICR
and
extracted
the
hours
associated
with
document
preparation
and
submittal
and
entered
them
into
the
model,
as
appropriate.
Appendix
VII
describes
in
more
detail
how
EPA
derived
these
labor
hours.

 
In
addition,
EPA
used
its
best
judgment
to
estimate
the
hour
burden
for
direct
and
indirect
reporters
to
carry
out
the
electronic
signature
agreement
provisions
under
the
CDX
and
rule.

Time
Frame
of
Activities.
The
model
examines
costs
to
EPA,
State/
Locals,
and
facilities
from
2000
to
2012.
Note,
however,
that
the
model
results
presented
in
Section
3.0
of
this
document
address
the
period
2003
through
2012
only.
That
is,
this
document
examines
those
cost
impacts
incurred
in,
and
subsequent
to,
2003.
Throughout
this
analysis,
in
the
Tables
and
discussion,
the
dollars
referred
to
are
2003
dollars.
The
model
accounts
for
the
time
value
of
money
expended
during
the
period
by
discounting
the
annual
costs
to
2003
levels
using
both
a
7
percent
discount
rate
and
a
3
percent
discount
rate,
as
recommended
by
the
Office
of
Management
and
Budget
(
OMB)
guidelines.

5
The
hours
for
EPA
labor
are
not
shown
in
the
appendix
due
to
space
constraints.
The
CROMERR
model,
as
well
as
the
cost
estimates
in
this
CBA,
include
EPA
labor
hours.
13
In
comparison
with
"
To
Be",
EPA
expects
that
the
rollout
of
automation
under
"
Baseline"
would
be
generally
less
expedient.
The
offices
would
have
resolved
issues
on
a
piecemeal
fashion.
Lessons
learned
in
one
office
might
not
be
shared
across
initiatives,
resulting
in
reinventing
the
wheel.
In
this
regard,
the
model
assumes
that
the
automation
start
dates
of
information
collections
under
"
Baseline"
would
be
delayed
by
2
years
in
comparison
with
"
To
Be".

Exhibit
2­
4
provides
an
example
of
how
the
model
examines
EPA,
State/
Locals,
and
facility
activities
over
the
modeling
period
under
"
Baseline".
The
exhibit
illustrates
Office
of
Solid
Waste
and
Emergency
Response's
(
OSWER's)
collections
as
the
example.
6
.
The
model
assumes
that
OSWER
portal
and
rule
development
would
last
3
years,
until
2005.
It
also
assumes
OSWER
would
convert
its
information
collections
to
electronic
format
over
2
years,
from
2003
to
2005.
In
2005,
OSWER's
information
collections
would
be
available
for
electronic
reporting.

In
addition,
State/
Locals
would
begin
upgrading
and
preparing/
submitting
their
program
modification
requests
to
EPA
upon
finalization
of
OSWER's
rule
in
2005.

Direct
reporters
would
submit
reports
to
OSWER
by
paper
until
its
information
collections
are
automated.
Direct
reporters
would
then
gradually
implement
electronic
reporting,
beginning
in
2005,
based
on
the
model's
annual
implementation
rate.
Indirect
reporters
would
not
be
affected
by
the
EPA
actions,
except
that
they
would
be
required
to
comply
with
the
rule's
electronic
signature
agreement
provisions
once
their
State/
Locals
submits
the
program
modification
application
to
EPA,
(
i.
e.,
in
2007.)

The
sequence
of
activities
for
EPA,
State/
Locals,
and
facilities
shown
in
Exhibit
2­
4
pertains
to
OSWER's
regulatory
programs
under
"
Baseline".
However,
the
model
follows
a
comparable
sequencing
approach
in
estimating
the
timeframe
for
all
EPA,
State/
Locals,
and
facility
activities
under
all
EPA
programs
under
"
Baseline"
and
"
To
Be".
For
example,
the
model
assumes
that
each
information
collection
under
"
Baseline"
and
"
To
Be"
will
take
2
years
to
be
automated
and
that
electronic
reporting
under
the
collection
will
commence
at
the
end
of
the
2­
year
period
and
increase
incrementally
based
on
the
model's
annual
implementation
rate.
It
also
assumes
that
State/
Locals
under
"
Baseline"
and
"
To
Be"
will
take
2
years
to
develop
their
program
modification
applications.
The
model
assumes
that
some
State/
Locals
will
submit
their
applications
2
years
after
promulgation
of
the
electronic
reporting
rule
(
e.
g.,
CROMERR).
The
remaining
State/
Locals
will
submit
their
applications
in
later
years,
based
on
the
assumptions
laid
out
in
Section
2.3.

6
Note
that
the
same
approach
was
taken
for
all
programs
and
collections.
14
2000
2001
2002
2003
2004
2006
2007
2008
2009
2010
2011
2012
2005
OSWER
develops
portals
and
rulemakings
OSWER
develops
web
forms,
XML
schemas,
etc.

Direct
reporters
report
to
OSWER
by
paper
only
States/
locals
upgrade
their
receiving
systems
and
apply
for
program
modification
approval
Indirect
reporters
comply
with
electronic
signature
agreement
Direct
reporters
graduallytransition
from
paper
to
electronic
reporting
OSWER
Automation
Start
Date
=
2005
Exhibit
2­
4.
Example
of
Timeframe
of
Activities
for
OSWER
Under
"
Baseline"

Number
of
Entities
Performing
the
Activity.
In
developing
the
model,
EPA
estimated
the
number
of
entities
performing
each
activity.
The
numbers
of
entities
per
activity
vary
by
activity
in
the
model
and
are
discussed
in
Section
2.3.
Refer
to
Table
2­
10
for
the
universe
of
State/
Locals
jurisdictions,
Table
2­
12
for
facility
registrants
to
EPA's
gateways
under
"
Baseline",
and
Table
2­
13
for
facility
registrants
to
the
CDX
under
"
To
Be".

Exhibit
2­
5
summarizes
other
key
model
operating
parameters.

Parameter
Description
Annual
Implementation
Rate
for
Electronic
Reporting
The
annual
implementation
rate
is
the
rate
at
which
direct
reporters
would
adopt
electronic
reporting
each
year
under
each
information
collection.
The
costs
reflect
a
30­
percent
first­
year
implementation
rate
and
a
10­
percent
rate
per
annum
thereafter.
The
model
applies
this
rate
to
derive
the
total
annual
costs
associated
with
both
paper
and
electronic
submittals,
as
well
as
the
number
of
registrants
each
year.
The
implementation
rate
was
applied
on
a
collection­
by­
collection
basis,
based
on
the
collection's
automation
start
date
under
"
Baseline"
and
"
To
Be".
An
information
collection's
automation
start
date
determines
the
percentage
of
facilities
and
submittals
that
will
be
automated
by
the
end
of
the
modeling
period.
As
an
example,
information
collections
with
an
automation
start
date
of
2003
would
be
automated
in
the
2003
to
2005
timeframe
under
"
Baseline"
and
"
To
Be".
15
Parameter
Description
Electronic
Reporting
Savings
Rate
The
model
assumes
that
electronic
reporters
would
save
time
and
costs
in
relation
to
submittal
of
paper
documents.
The
model
assumes
that
facilities
that
report
by
Web
form
would
save
10
percent
of
the
hours
and
costs
per
document
preparation
and
submittal
and
that
facilities
that
report
by
XML
or
flat
file
would
save
25
percent.
Web
Form
Usage
Rate
The
model
assumes
that
94
percent
of
direct
reporters
reporting
electronically
would
use
a
Web
form.
The
model
assumes
no
hardware
or
software
costs
in
reporting
by
Web
form.
XML
or
Flat
File
Usage
Rate
The
model
assumes
that
the
remaining
6
percent
of
electronic
reporters
would
use
XML
or
flat
file
reporting.
Refer
to
Appendix
X
for
additional
information
on
the
XML
and
flat
file
usage
and
cost
assumptions.
Aggregate
Annual
Change
in
Total
Hour
Burden
The
model
assumes
that,
each
year,
the
total
aggregate
hour
burden
under
all
68
information
collections
decreases
by
1
percent
per
year.
This
rate
is
based
on
EPA's
review
of
the
historical
growth
trends
of
the
68
collections.

Exhibit
2­
5.
Other
Model
Operating
Parameters
2.3
Model
Data
and
Assumptions
This
section
describes
the
activities
EPA,
State/
Locals,
and
facilities
are
expected
to
take
under
the
"
Baseline"
and
"
To
Be"
scenarios.
It
also
describes
the
unit
costs,
hour
labor
burden,
and
timeframe
of
activities,
as
applicable.
All
costs
presented
in
this
chapter
are
undiscounted.
Refer
to
Table
III­
1
of
Appendix
III
of
this
document
for
a
summary
of
the
data
and
assumptions
used
in
estimating
the
cost
impacts
to
government
and
facilities
in
the
model.

2.3.1
EPA
2.3.1.1
"
Baseline"

Development
of
Program
Portals
and
Rules.
Under
the
"
Baseline"
scenario,
EPA
assumes
that
nine
program
areas
would
each
develop
a
portal
for
receiving
electronic
submissions
and
exchanging
information
with
co­
regulators.
The
programs
also
would
incur
annual
maintenance
costs
for
these
portals
following
portal
development.
EPA
also
assumes
each
program
would
establish
a
rulemaking
enabling
electronic
reporting.
All
model
input
assumptions
for
these
activities
are
shown
in
Table
2­
1.
16
Table
2­
1.
Model
Inputs:
Portal
and
Rule
Development
Portal
Development
Program
Areas
Development
Period
Total
Cost/
Portal
Annual
Portal
Maintenance
Costs*
Total
Cost/
Rule*

2000­
2002
$
6,200,000
$
2,100,000
$
1,500,000
OAR­
OAQPS
2000­
2002
$
6,200,000
$
2,100,000
$
1,500,000
OPPTS­
TSCA
1999­
2001
$
6,200,000
$
2,100,000
$
1,500,000
OPPTS­
FIFRA
1999­
2001
$
6,200,000
$
2,100,000
$
1,500,000
OSWER­
OSW
2003­
2005
$
6,200,000
$
2,100,000
$
1,500,000
OSWER­
CEPPO
2003­
2005
$
6,200,000
$
2,100,000
$
1,500,000
OSWER­
CERCLA
2003­
2005
$
6,200,000
$
2,100,000
$
1,500,000
OW­
NPDES
1998­
2000
$
6,200,000
$
2,100,000
$
1,500,000
OW­
SDW
2003­
2005
$
6,200,000
$
2,100,000
$
1,500,000
*
Annual
maintenance
costs
are
incurred
following
the
portal
development
period.

**
The
rulemaking
costs
for
each
program
are
incurred
during
the
portal
development
period.

Development
of
Automated
Collections.
The
model
assumes
information
collections
would
be
automated
according
to
the
automation
start
dates
presented
in
Appendix
II
for
"
Baseline".
EPA
would
incur
costs
for
converting
each
collection
to
an
electronic
format
(
e.
g.,
developing
Web
form,
and
XML
schema,
etc.).
Table
2­
2
presents
the
model's
input
assumptions,
which
were
used
to
cost
out
EPA's
development
of
the
68
collections.

Table
2­
2.
Model
Inputs:
Developing
Automated
Collections
Number
of
Information
Collections
Cost
per
Collection
Development
Period
Conversion
of
Collections
to
Electronic
Format
68
$
200,000
2
years
Help
Desk.
The
model
assumes
that
each
registrant
to
a
program's
gateway
would
need
to
contact
the
program
for
assistance.
Further,
EPA
has
determined
that
facilities
are
subject
to
1.3
EPA
programs,
on
average.
7
EPA
assumes
that
each
program's
portal
would
be
different
in
regard
to
registration
and
use.
Therefore,
the
model
assumes
that,
on
average,
each
employee
registrant
would
make
1.3
calls
to
EPA's
Help
Desk.
The
model
estimates
the
costs
to
EPA
for
handling
these
calls.
Refer
to
Tables
2­
15
and
2­
16
for
the
number
of
employee
registrants
expected
to
contact
EPA
each
year.

7
Refer
to
Appendix
VIII
for
EPA's
calculation
of
this
estimate.
17
Table
2­
3
presents
the
model's
input
assumptions,
which
were
used
in
conjunction
with
the
EPA
labor
costs
in
Exhibit
2­
3
and
number
of
employee
registrants
in
Tables
2­
15
and
2­
16,
in
order
to
estimate
EPA's
costs
per
year.

Table
2­
3.
Model
Inputs:
EPA
Help
Desk
Costs
Annual
Number
of
Calls
Time/
Call
Varies*
6
minutes
*
Based
on
the
annual
number
of
employee
registrants
in
Table
2­
13.

Review
of
State/
Locals
Program
Modification
Applications.
The
model
estimates
costs
to
EPA
for
reviewing
State/
Locals
program
modification
requests.
Based
on
the
discussion
in
Appendix
V,
the
model
estimates
that
each
authorized
state
environmental
protection
agency
would
submit
three
program
modification
applications
to
EPA,
on
average
(
i.
e.,
one
application
for
each
receiving
system).
The
other
authorized
State/
Locals
jurisdictions
(
e.
g.,
county
governments)
would
submit
one
application
to
EPA,
on
average.

Table
2­
4
presents
the
model's
input
assumptions,
which
were
used
in
conjunction
with
the
EPA
labor
rates
in
Exhibit
2­
3,
to
estimate
the
annual
costs
to
EPA.

Table
2­
4.
Model
Inputs:
Program
Modification
Applications
Agencies
EPA
Hours
per
Application
Review
Number
Applications
Submitted
per
Agency
Number
of
Applications
Received
and
Time
frame
42
from
state
EPAs
in
2007
3
from
state
EPAs/
yr
in
2008
to
2011
State
EPAs
80
3
2
from
state
EPAs
in
2012
111
from
other
State/
Locals
jurisdictions
in
2007
All
Other
State/
Locals
Jurisdictions*
80
1
27
from
other
State/
Locals
jurisdictions/
yr
in
2008
to
2012
*
Includes
tribes,
county
air
programs,
publicly
owned
treatment
works
(
POTWs),
state
health
departments,
and
state
oil
and
gas
agencies.

Processing
of
Paper/
Electronic
Submittals.
The
model
assumes
EPA
would
incur
annual
costs
for
processing
paper
and
electronic
submittals
from
direct
reporters
under
all
of
the
collections.
Refer
to
Appendix
VII
for
the
model's
equation
for
deriving
EPA's
annual
costs.
8
2.3.1.2
"
To
Be"

Development/
Maintenance
of
the
CDX.
Table
2­
5
presents
the
total
annual
estimated
CDX
development
and
maintenance
costs.
This
includes,
among
other
things,
upgrading
the
CDX
to
implement
the
electronic
signature
agreement
requirements
(
e.
g.,
upgrading
the
CDX
to
control
8
Note
that
Appendix
VII
discusses
EPA's
approach
for
estimating
costs
to
direct
reporters
in
submitting
information
under
the
collections.
However,
EPA
took
an
identical
approach
for
estimating
costs
to
EPA
in
processing
the
submittals
under
them.
Refer
to
Figure
VII­
1
for
the
equation
used
in
the
model
to
estimate
EPA
costs
in
processing
paper
and
electronic
submittals
under
each
of
the
collections.
18
registrants'
access
into
their
CDX
accounts
and
data
flows
pending
EPA
receipt/
approval
of
the
agreement
or
notification
of
certification).
The
model
assumes
EPA
would
incur
development
and
maintenance
costs
over
the
duration
of
the
modeling
period.
Table
2­
5
presents
all
of
the
model's
inputs.

Table
2­
5.
Model
Inputs:
CDX
Development
and
Maintenance
Costs
(
in
millions
of
dollars)

2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
Development
$
3.8
$
4.4
$
6.6
$
10.9
$
10.9
$
11.2
$
8.9
$
6.6
$
6.6
$
6.6
$
6.6
$
6.6
$
6.6
Maintenance
$
0.4
$
1.5
$
1.3
$
3.1
$
3.1
$
3.3
$
3.6
$
3.9
$
3.9
$
3.9
$
3.9
$
3.9
$
3.9
Total
$
4.2
$
5.9
$
7.9
$
13.4
$
14.0
$
14.5
$
12.5
$
10.5
$
10.5
$
10.5
$
10.5
$
10.5
$
10.5
Development
of
CROMERR.
Table
2­
6
presents
all
model
inputs
for
estimating
costs
to
EPA
in
developing
CROMERR.

The
table
also
presents
EPA's
costs
for
preparing
for
implementation
of
the
electronic
signature
agreement
provisions.
The
model
assumes
EPA
would
need
to
develop
a
process
and
procedures
to
implement
the
requirement
for
the
electronic
signature
agreements,
the
agreement
collection
certifications,
and
related
submittals.
EPA
will
need
to
consider,
among
other
things,
appropriate
routing,
processing,
and
records
management
of
the
submittals
when
received
by
EPA;
what
the
staff
assignments
and
responsibilities
will
be;
what
policies
and
criteria
will
govern
the
review
and
approval
process
for
the
agreements;
LRA
applications;
and
certifications.

Finally,
the
model
assumes
that
EPA
would
prepare
a
brief
guidance
to
assist
registrants,
local
authorities,
and
EPA
Help
Desk
staff
in
resolving
questions
or
problems
associated
with
the
requirement.
This
could
be
in
the
form
of
a
simple
fact
sheet
or
a
question­
and­
answer
document.
EPA
will
need
to
purchase
file
cabinets
for
storing
submittals
under
the
electronic
signature
provision.

Table
2­
6.
Model
Input:
CROMERR
Development
Costs
Development
Period
Total
Development
Costs
Development
of
CROMERR
2000­
2003
$
1,547,502
Planning/
Development
for
Implementation
of
Electronic
Signature
Agreement
Provisions
2003­
2004
$
17,334
Purchase
of
File
Cabinets
for
Storing
Electronic
Signature
Agreement
and
Certification
Submittals
2003­
2012
$
8,996
Development
of
Automated
Collections.
The
model
assumes
information
collections
would
be
automated
according
to
the
automation
start
dates
presented
in
Appendix
II
for
"
To
Be".
EPA
would
incur
costs
for
converting
their
collections
to
an
electronic
format
(
e.
g.,
developing
Web
form,
and
XML
schema,
etc.).
EPA
would
also
issue
a
Federal
Register
notice
announcing
the
availability
of
electronic
reporting
of
each
collection.
Table
2­
7
presents
the
model's
input
assumptions.
19
Table
2­
7.
Model
Input:
Developing
Automated
Collections
Number
of
Information
Collections
Cost
per
Collection
Development
Period
Conversion
of
Collections
to
Electronic
Format
68
$
200,000
2
years
Development
of
Federal
Register
Notice
68
$
300,000
1
year
Help
Desk.
The
model
assumes
that
each
registrant
to
the
CDX
would
need
to
contact
the
program
for
assistance,
and
that
EPA
would
incur
costs
for
handling
these
calls.
Refer
to
Tables
2­
15
and
2­
16
for
the
number
of
employee
registrants
expected
to
contact
EPA
each
year.
Table
2­
8
presents
the
model's
input
assumptions,
which
were
used
in
conjunction
with
the
EPA
labor
rates
in
Exhibit
2­
3
and
the
number
of
employee
registrants
in
Tables
2­
15
and
2­
16,
in
order
to
estimate
costs
to
EPA.

Table
2­
8.
Model
Inputs:
Help
Desk
Annual
Number
of
Calls
Time/
Call
Varies*
8
minutes
*
Based
on
the
annual
number
of
employee
registrants
in
Tables
2­
15
and
2­
16.

Implementation
of
Electronic
Signature
Agreement
Provisions.
The
model
assumes
that
EPA
will
receive
and
process
the
subscriber
agreements,
certifications,
and
related
documents
submitted
by
small
and
medium­
size/
large
direct
reporters
under
the
CDX's
electronic
signature
agreement
provisions.
These
activities
are
described
in
Table
2­
9,
along
with
the
burden
assumptions
for
each
submittal
received
by
the
Agency.
Refer
to
Table
2­
20
for
the
number
of
small
and
medium­
size/
large
firms
that
will
submit
the
paperwork
each
year.

Table
2­
9.
Implementation
of
Electronic
Signature
Agreement
Provisions
Wet­
Ink
Signature
Agreement
Burden
Hrs/
Submittal
O&
M
costs
Annual
Number
of
Submittals
Receive,
process,
review,
approve,
and
file
new
subscriber
agreements
0.17
$
0.00
Varies
annually.*

Receive,
process,
review,
approve,
and
file
new
electronic
agreements
(
employee
turnover)
0.17
$
0.00
Varies
annually.**
Based
on
an
assumption
that
registrants
of
small
firms
will
submit
new
wet­
ink
agreements
due
to
employee
turnover.

Receive,
process,
review,
approve,
and
file
wet­
ink
signature
agreement
renewals
0.17
$
0.00
Varies
annually.**
Model
assumes
small
firms
will
renew
their
wet­
ink
agreements
every
2
years
by
submitting
a
new
wet­
ink
agreement.

LRA
Notification
of
Registered
Users
20
Wet­
Ink
Signature
Agreement
Burden
Hrs/
Submittal
O&
M
costs
Annual
Number
of
Submittals
Receive
application
to
designate
first­
time
local
authority
0.5
$
0.00
Varies
annually.***

Receive,
store,
process,
and
review
notification
of
registered
users
0.17
$
0.00
Varies
annually.***

Receive
application
to
designate
local
authority
(
local
authority
turnover)
0.5
$
0.00
Varies
annually.****
The
model
assumes
EPA
will
receive
applications
from
some
medium­
size
and
large
firms
to
designate
a
replacement
local
authority
as
a
result
of
local
authority
turnover
(
e.
g.,
if
original
local
authority
leaves
the
firm
or
transfer
to
another
position).

Receive,
process,
review,
and
approve
updated
notification
of
certificate
(
employee
turnover)
0.17
$
0.00
Varies
annually.****
The
model
assumes
each
local
authority
will
update
their
certifications
as
needed
due
to
employee
turnover.
Updates
will
be
made
electronically
via
the
CDX.
EPA
will
need
to
review
and
validate
these
updates
and
reflect
them
in
the
appropriate
CDX
accounts.

Receive
notification
of
breach
of
storage
security
and
take
appropriate
follow­
up
action
1
$
10.00
Varies
annually.****
A
local
authority
is
required
to
ensure
the
security
of
the
wet­
ink
agreements
in
storage.
If
security
is
breached,
the
local
authority
will
notify
EPA.
EPA
will
receive
these
notifications
and
take
appropriate
action.
The
model
assumes
1
percent
of
medium­
size
and
large
firms
experience
a
breach
annually.

Receive,
process,
review,
and
approve
updated
notification
of
certificate
(
breach
of
security)
0.17
$
0.00
Varies
annually.****
In
response
to
a
breach,
each
local
authority
will
collect
newly
signed
wet­
ink
agreements
from
employees
and
will
store
the
signed
agreements
on­
site.
Local
authorities
will
then
send
EPA
the
information
required
to
update
the
CDX
security
profiles
(
list
of
employees,
data
flows
for
which
each
is
authorized
to
represent
the
company,
other
pertinent
information).

Receive,
process,
review,
approve,
and
0.5
$
0.00
Varies
annually.****
Each
local
authority
is
expected
to
renew
their
21
Wet­
Ink
Signature
Agreement
Burden
Hrs/
Submittal
O&
M
costs
Annual
Number
of
Submittals
file
application
renewals
designation
every
2
years.
EPA
will
receive,
review,
and
approve/
deny
the
application
and
notify
the
local
authority.

Ongoing
Management
Identify
and
resolve
problems
1
$
10.00
Varies
annually
based
on
the
total
number
of
direct
facility
and
employee
registrants
to
the
CDX.
The
model
assumes
EPA
will
periodically
encounter
problems
that
require
resolution.
The
model
includes
$
10
per
long­
distance
call
to
a
facility
to
resolve
the
problem.
The
model
assumes
3
percent
of
registrants
will
be
involved
in
a
problem
that
must
be
resolved
annually.

Respond
to
information
requests
1.5
$
0.00
Varies
annually
based
on
the
total
number
of
direct
facility
and
employee
registrants
to
the
CDX.
The
model
assumes
EPA
will
respond
to
FOIA
requests,
management
inquiries,
internal
requests,
and
budget
updates
related
to
wet­
ink­
on­
paper
signature
agreements
to
support
the
process.
The
model
assumes
that
EPA
will
respond
to
information
requests
involving
3
percent
of
registrants'
accounts
each
year.

*
Based
on
the
number
of
small
direct
reporter
employees
registering
with
the
CDX
each
year.
Refer
to
Table
2­
20
for
the
annual
number
of
small
direct
reporter
employee
registrants.

**
Based
on
the
number
of
small
direct
reporter
facility
employees
that
have
registered
with
the
CDX.
Refer
to
Table
2­
20
for
the
annual
number
of
small
direct
reporter
employee
registrants.

***
Based
on
the
number
of
medium­
size
and
large
direct
reporter
employees
registering
with
the
CDX
each
year.
Refer
to
Table
2­
20
for
assumptions
on
the
annual
number
of
medium­
size
and
large
employee
registrants.

****
Based
on
the
number
of
medium­
size
and
large
direct
reporter
employees
that
have
registered
with
the
CDX.
Refer
to
Table
2­
20
for
assumptions
on
the
annual
number
of
medium­
size
and
large
employee
registrants.

Review
of
State/
Locals
Program
Modification
Applications.
The
model
estimates
costs
to
EPA
for
reviewing
program
modifications
from
State/
Locals.
The
model
estimates
that
each
authorized
state
EPA
(
i.
e.,
state
environmental
protection
agency)
would
submit
one
consolidated
program
modification
application
to
EPA,
on
average.
The
other
authorized
State/
Locals
jurisdictions
would
submit
one
application
to
EPA,
on
average.

Table
2­
10
presents
the
model's
input
assumptions,
which
were
used
in
conjunction
with
the
EPA
labor
rates
in
Exhibit
2­
3,
to
estimate
costs
to
EPA.
22
Table
2­
10.
Model
Inputs:
Program
Modification
Applications
Agencies
EPA
Hours
per
Application
Review
Number
Applications
Submitted
per
Agency
Number
of
Applications
Received
and
Time
frame
42
from
state
EPAs
in
2005
3
from
state
EPAs/
yr
in
2006
to
2009
State
EPAs
160
1
2
from
state
EPAs
in
2010
111
from
other
State/
Locals
jurisdictions
in
2005
All
Other
State/
Locals
Jurisdictions*
80
1
27
from
other
State/
Locals
jurisdictions/
yr
in
2008
to
2010
22
from
other
State/
Locals
jurisdictions
in
2011
21
from
other
State/
Locals
jurisdictions
in
2012
*
Includes
tribes,
county
air
programs,
publicly
owned
treatment
works
(
POTWs),
state
health
departments,
and
state
oil
and
gas
agencies.

2.3.2
State
and
Local
Environmental
Programs
Table
2­
11
presents
the
total
universe
of
authorized
state
environmental
protection
agencies
and
other
authorized
State/
Locals
jurisdictions.
The
model
examines
these
State/
Locals'
costs
under
"
Baseline"
and
"
To
Be"
for:

 
Upgrading
their
receiving
systems.

 
Applying
to
EPA
for
program
modification
approval.

Table
2­
11.
Authorized
State
EPAs
and
State/
Locals
Jurisdictions
Entity
Total
Universe
State
EPA
56
Tribes
20
County
Air
Programs
40
POTWs
412
State
Health
Department
22
State
Oil
and
Gas
Agencies
19
Based
on
EPA's
best
judgment,
the
model
assumes
that
these
agencies
would
upgrade
their
systems
and
apply
for
program
modifications
according
to
the
following
frequency:

 
Seventy­
five
percent
of
state
EPAs
within
the
first
2
years
of
promulgation
of
EPA's
rules,
and
5
percent
annually
thereafter.

 
Forty­
five
percent
of
tribes
within
the
first
2
years
of
EPA
rule
promulgation,
and
10
percent
annually
thereafter.
23
 
Ten
percent
of
POTWs
within
the
first
2
years
of
EPA
rule
promulgation,
and
5
percent
annually
thereafter.

 
Seventy­
five
percent
of
all
other
State/
Locals
jurisdictions
within
the
first
2
years
of
EPA
rule
promulgation,
and
5
percent
annually
thereafter.

2.3.2.1
"
Baseline"

Table
2­
12
presents
the
model
inputs
for
the
number
of
State/
Locals
upgrading
their
receiving
systems
and
developing/
submitting
their
program
modification
applications
under
"
Baseline".
Based
on
the
discussion
in
Appendix
V,
the
model
assumes
each
state
environmental
protection
agency
would
spend
180
hours
in
preparing/
submitting
each
program
application,
and
that
each
would
submit
three
applications
(
i.
e.,
one
for
each
receiving
system).
The
model
assumes
each
of
the
other
State/
Locals
jurisdictions
would
spend
180
hours
in
preparing/
submitting
one
application.
The
model
applies
the
data
in
Table
2­
12
to
these
hourly
estimates
and
the
hourly
State/
Locals
labor
costs
in
Exhibit
2­
3
in
order
to
estimate
annual
costs
to
State/
Locals
in
preparing/
submitting
their
applications.
In
addition,
the
model
estimates
upgrade
costs
to
State/
Locals
based
on
the
data
in
Table
2­
12
and
the
upgrade
assumptions
in
Appendix
V,
Table
V­
4.

Table
2­
12.
Model
Inputs:
State/
Locals
Receiving
Systems
Upgrades
and
Modification
Application
under
"
Baseline"

Universe
Timeframe*
Number
of
Agencies
Number
of
Receiving
Systems
2006
and
2007
42
126
2007
and
2008
3
9
2008
and
2009
3
9
2009
and
2010
3
9
2010
and
2011
3
9
State
EPA
2011
and
2012
2
6
2006
and
2007
111
111
2007
and
2008
27
27
2008
and
2009
27
27
2009
and
2010
27
27
2010
and
2011
27
27
All
other
agencies
2011
and
2012
27
27
*
Time
frame
pertains
to
agency's
development
of
their
program
modification
requests
and
performance
of
startup
upgrades
to
their
receiving
systems.
It
does
not
apply
to
their
ongoing
maintenance
of
their
upgraded
systems,
because
these
costs
would
be
incurred
annually
following
the
startup
upgrade.

2.3.2.2
"
To
Be"

Table
2­
13
presents
the
model
inputs
for
State/
Locals
upgrades
to
their
receiving
system
and
development/
submittal
of
their
program
modification
applications
under
"
To
Be".
Based
on
the
discussion
in
Appendix
V,
the
model
assumes
each
state
environmental
protection
agency
would
spend
245
hours
in
preparing/
submitting
a
consolidated
modification
application
to
EPA.
In
addition,
EPA
assumes
that
10
percent
of
states
adopting
CROMERR
annually
will
conduct
a
24
rulemaking,
incurring
an
additional
120
hours
and
$
20,000
in
contractor
costs
to
support
rule
development.

The
model
assumes
each
of
the
other
State/
Locals
jurisdictions
would
spend
210
hours
in
preparing/
submitting
one
application.
The
model
applies
the
data
in
Table
2­
13
to
these
hourly
estimates
and
the
hourly
State/
Locals
labor
costs
in
Exhibit
2­
3
in
order
to
estimate
annual
costs
to
State/
Locals
in
preparing/
submitting
their
applications.

In
addition,
the
model
estimates
upgrade
costs
to
State/
Locals
based
on
the
data
in
Table
2­
13,
in
conjunction
with
the
upgrade
assumptions
in
Appendix
V,
Tables
V­
4
and
V­
7.

Table
2­
13.
Model
Inputs:
State/
Locals
Receiving
Systems
Upgrades
and
Modification
Applications
under
"
To
Be"

Universe
Timeframe*
Number
of
Agencies**
Number
of
Receiving
Systems
2004
and
2005
42
126
2005
and
2006
3
9
2006
and
2007
3
9
2007
and
2008
3
9
2008
and
2009
3
9
2009
and
2010
2
6
State
EPA
2010
and
2011
0
0
2004
and
2005
111
111
2005
and
2006
27
27
2006
and
2007
27
27
2007
and
2008
27
27
2008
and
2009
27
27
All
other
agencies
2009
and
2010
27
27
2010
and
2011
22
22
2011
and
2012
21
21
*
Time
frame
pertains
to
Agency's
development
of
their
program
modification
requests
and
performance
of
startup
upgrades
to
their
receiving
systems.
It
does
not
apply
to
their
ongoing
maintenance
of
their
upgraded
systems,
because
these
costs
would
be
incurred
annually
following
the
startup
upgrade.

**
In
both
Tables
2­
12
and
2­
13,
the
"
Number
of
Agencies"
column
refers
to
the
number
of
agencies
implementing
electronic
reporting.
The
total
of
agencies
in
this
column
is
43
less
in
Table
2­
12
than
in
Table
2­
13,
because
Table
2­
12
reflects
the
Baseline
(
or
"
As
Is"
model)
while
2­
13
reflects
CROMERR.
Under
the
Baseline
model,
implementation
begins
two
years
later
than
under
CROMERR,
so
 
for
the
same
2004
­
2012
period
 
fewer
systems
(
i.
e.
two
years
worth)
implement
under
the
Baseline
than
under
CROMERR.
That
is,
starting
two
years
earlier,
implementation
under
CROMERR
reaches
43
more
systems
by
2012
than
under
the
Baseline.

In
addition,
the
model
assumes
that
State/
Locals
will
receive
and
process
the
subscriber
agreements,
certifications
and
related
documents
submitted
by
indirect
reporters
under
the
rule's
electronic
signature
agreement
provisions.
These
activities
are
described
in
Table
2­
14,
25
along
with
the
burden
assumptions
for
each
submittal
received
by
the
State/
Locals.
Refer
to
Table
2­
20
for
the
number
of
small
and
medium­
size/
large
firms
that
will
submit
the
paperwork
each
year
and
a
description
of
their
activities.

Table
2­
14.
State/
Locals
Implementation
of
Electronic
Signature
Agreement
Provisions
for
Submissions
by
Indirect
Reporters
Wet­
Ink
Signature
Agreement
Burden
Hrs/
Submittal
O&
M
Costs
Annual
Number
of
Submittals
Receive,
process,
review,
approve,
and
file
new
subscriber
agreements
0.17
$
0.00
Varies
annually.*

Receive,
process,
review,
approve,
and
file
new
electronic
agreements
(
employee
turnover)
0.17
$
0.00
Varies
annually.**
Based
on
an
assumption
that
registrants
of
small
firms
will
submit
new
wetink
agreements
due
to
employee
turnover.
Receive,
process,
review,
approve,
and
file
wet­
ink
signature
agreement
renewals
0.17
$
0.00
Varies
annually.**
Model
assumes
small
firms
will
renew
their
wet­
ink
agreements
every
2
years
by
submitting
a
new
wetink
agreement.
LRA
Notification
of
Registered
Users
Receive
application
to
designate
first­
time
local
authority
0.50
$
0.00
Varies
annually.***

Receive,
store,
process
and
review
notification
of
registered
users
0.17
$
0.00
Varies
annually.***

Receive
application
to
designate
local
authority
(
local
authority
turnover)
0.50
$
0.00
Varies
annually.****
The
model
assumes
State/
Locals
will
receive
applications
from
some
medium­
size
and
large
firms
to
designate
a
replacement
local
authority
as
a
result
of
local
authority
turnover
(
e.
g.,
if
original
local
authority
leaves
the
firm
or
transfer
to
another
position).
Receive,
process,
review,
and
approve
updated
notification
of
certificate
(
employee
turnover)
0.17
$
0.00
Varies
annually.****
The
model
assumes
each
local
authority
will
update
their
certifications
as
needed
due
to
employee
turnover.
Updates
will
be
made
electronically
via
the
State/
Locals.
The
State/
Locals
will
need
to
review
and
validate
these
updates
and
reflect
them
in
the
appropriate
accounts.
Receive
notification
of
breach
of
storage
security
and
take
appropriate
follow­
up
action
1
$
10.00
Varies
annually.****
A
local
authority
is
required
to
ensure
the
security
of
the
wet­
ink
agreements
in
storage.
If
security
is
breached,
the
local
authority
will
notify
the
State/
Locals.
The
State/
Locals
will
receive
these
notifications
and
take
appropriate
action.
The
model
assumes
1
percent
of
medium­
size
and
large
firms
experience
a
breach
annually.

Ongoing
Management
Identify
and
resolve
problems
1
$
10.00
Varies
annually
based
on
the
26
Wet­
Ink
Signature
Agreement
Burden
Hrs/
Submittal
O&
M
Costs
Annual
Number
of
Submittals
total
number
of
direct
facility
and
employee
registrants
to
the
CDX.
The
model
assumes
the
State/
Locals
will
periodically
encounter
problems
that
require
resolution.
The
model
includes
$
10
per
long­
distance
call
to
a
facility
to
resolve
the
problem.
The
model
assumes
3
percent
of
registrants
will
be
involved
in
a
problem
that
must
be
resolved
annually.
Respond
to
information
requests
1.5
$
0.00
Varies
annually
based
on
the
total
number
of
direct
facility
and
employee
registrants
to
the
State/
Locals
system.
The
model
assumes
the
State/
Locals
will
respond
to
FOIA
requests,
management
inquiries,
internal
requests,
and
budget
updates
related
to
wet­
ink­
on­
paper
signature
agreements
to
support
the
process.
The
model
assumes
that
EPA
will
respond
to
information
requests
involving
3
percent
of
registrants'
accounts
each
year.
*
Based
on
the
number
of
small
direct
reporter
employees
registering
with
the
State/
Locals
systems
each
year.
Refer
to
Table
2­
20
for
the
annual
number
of
small
direct
reporter
employee
registrants.

**
Based
on
the
number
of
small
direct
reporter
facility
employees
that
have
registered
with
the
State/
Locals
systems.
Refer
to
Table
2­
20
for
the
annual
number
of
small
direct
reporter
employee
registrants.

***
Based
on
the
number
of
medium­
size
and
large
direct
reporter
employees
registering
with
the
State/
Locals
systems
each
year.
Refer
to
Table
2­
20
for
assumptions
on
the
annual
number
of
medium­
size
and
large
employee
registrants.

****
Based
on
the
number
of
medium­
size
and
large
direct
reporter
employees
that
have
registered
with
the
State/
Locals
systems.
Refer
to
Table
2­
20
for
assumptions
on
the
annual
number
of
medium­
size
and
large
employee
registrants.

2.3.3
Facilities
As
described
in
Appendix
IX,
EPA
estimated
the
total
number
of
facilities
that
will
need
to
register
with
EPA's
receiving
systems
under
"
Baseline"
and
"
To
Be".
EPA
also
estimated
the
number
of
employees
within
these
facilities
that
will
perform
the
registration
process.
EPA
generally
believes
that
the
majority
of
facilities
(
89
percent)
will
be
small
(
i.
e.,
fewer
than
20
employees);
the
remainder
(
11
percent)
are
considered
medium­
size
or
large.
EPA
estimates
that
small
facilities
will
designate
three
employees
and
medium­
size
and
large
facilities
will
designate
six,
on
average.

For
both
"
Baseline"
and
"
To
Be",
the
model
applied
the
annual
implementation
rate,
described
in
Exhibit
2­
5,
to
the
total
number
of
registering
employees
(
shown
in
Table
IX­
2
of
Appendix
IX)
in
order
to
estimate
the
annual
number
of
employee
registrants
per
year.
The
model
took
into
account
the
automation
start
date
of
each
collection
under
each
scenario,
as
well
as
the
number
of
direct
reporters
subject
to
these
collections,
in
determining
the
number
of
registrants
in
each
year.

In
general,
EPA
does
not
expect
that
registrants
will
incur
any
notable
costs
in
registering
or
reporting
electronically,
except
for
the
activities
listed
in
Exhibit
2­
1.
In
particular,
EPA
does
not
expect
registrants
to
buy
a
personal
computer
or
Internet
access
in
order
to
report
electronically.
EPA
assumes
that
facilities
will
pursue
electronic
reporting
only
if
they
already
have,
or
plan
to
27
purchase,
computer
capabilities
as
part
of
their
normal
business
practices.
Therefore,
the
model
does
not
include
costs
to
them
for
buying
a
computer
or
Internet
access.

Tables
2­
15
and
2­
16
present
the
annual
number
of
facility
and
employee
registrants
to
EPA
under
"
Baseline"
and
"
To
Be"
during
2003
through
2012.

Table
2­
15.
Number
of
Facility
and
Employee
Registrants
under
"
Baseline"*

2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
Facilities
1,467
1,320
14,551
4,863
4,996
3,783
3,405
3,064
2,758
2,484
Employee
Registrants
4,885
4,396
48,455
16,194
16,637
12,597
11,339
10,203
9,184
8,265
*
Table
includes
rounding
error.

Table
2­
16.
Number
of
Facility
and
Employee
Registrants
under
"
To
Be"*

2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
Facilities
14,830
8,302
5,221
3,986
3,588
3,229
2,906
2,615
2,354
2,118
Employee
Registrants
49,384
27,646
17,386
13,273
11,948
10,753
9,677
8,708
7,839
7,053
*
Table
includes
rounding
error.

2.3.3.1
"
Baseline"
and
"
To
Be"

Registration
and
Help
Desk.
The
model
assumes
that,
under
"
Baseline",
each
employee
registrant
in
Table
2­
15
will
register
with
1.3
EPA
receiving
systems,
on
average.
9
The
model
assumes
each
employee
registrant
will
need
to
call
the
EPA
Help
Desk
each
time
they
register.

The
model
assumes
that,
under
"
To
Be",
each
employee
registrant
will
register
with
the
CDX
once.
It
also
assumes
each
employee
registrant
will
call
the
Help
Desk
once.

Table
2­
17
presents
model
inputs
for
registration
and
Help
Desk
costs
under
"
Baseline"
and
"
To
Be".
They
were
used
in
conjunction
with
the
number
of
employee
registrants
in
Table
2­
15
and
2­
16,
as
well
as
the
facility
labor
costs
in
Exhibit
2­
3,
to
estimate
registration
and
Help
Desk
costs
to
facilities
under
"
Baseline"
and
"
To
Be".
EPA
performed
consultations
with
the
industry
representatives
in
Appendix
XI
in
developing
these
estimates.

9
This
1.3­
estimate
is
based
on
EPA's
analysis
of
facility
data
in
its
Envirofacts
database,
as
described
in
Appendix
VIII.
28
Table
2­
17.
Model
Input:
Registration
and
Help
Desk
Activity
Annual
Number
of
Employee
Registrants
Time/
Registrant
Registration
Varies
annually*
3
minutes
under
"
Baseline"
and
"
To
Be"

Help
Desk
Varies
annually*
6
minutes
under
"
Baseline"
8
minutes
under
To
Be
*
Based
on
the
annual
number
of
employee
registrants
in
Table
2­
15
for
"
Baseline"
and
2­
16
for
"
To
Be".

Digital
Signature
Certification
and
Re­
Certification.
The
model
assumes
that
20
percent
of
employee
registrants
would
be
required
to
submit
enforcement­
sensitive
information
to
EPA.
To
preserve
the
integrity
of
the
data
submitted,
the
model
assumes
that
these
registrants
would
need
to
obtain
and
install
a
digital
electronic
signature
certificate
on
their
browser.
EPA
estimates
that
a
registrant
would
need
30
minutes
to
obtain
and
install
the
certificate.
The
registrants
would
need
to
renew
their
registration
with
EPA
every
2
years.

Table
2­
18
presents
model
inputs,
which
were
used
in
conjunction
with
the
facility
labor
rates
in
Exhibit
2­
3
and
the
number
of
employee
registrants
in
Table
2­
15
or
2­
16,
in
order
to
estimate
costs
for
digital
signature
certifications.

Table
2­
18.
Digital
Signature
Certification
Costs
Number
of
Registrants
Requiring
Digital
Certificate
Time/
Certificate
Varies
annually*
30
minutes
*
Based
on
20
percent
of
the
annual
number
of
employee
registrants
in
Table
2­
15
or
2­
16.

2.3.4
Electronic
Signature
Agreement
2.3.4.1
"
Baseline"

Under
"
Baseline",
facilities
reporting
to
State/
Locals
receiving
systems
(
i.
e.,
indirect
reporters)
must
ensure
that
their
employees
sign
an
electronic
signature
agreement.
The
annual
number
of
facility
employee
registrants
to
State/
Locals
receiving
systems
is
presented
in
Table
V­
5
of
Appendix
V.
The
model
assumes
that
each
employee
would
take
10
minutes
to
prepare,
sign,
and
keep
records
of
the
signature
agreement,
on
average.
Refer
to
Appendix
V
for
additional
information
on
how
EPA
derived
the
number
of
employees
registering
with
State/
Locals
systems.

Table
2­
19
presents
the
hour
burden
per
employee
registrant,
which
the
model
applied
to
the
annual
number
of
registrants
in
Table
V­
5
of
Appendix
V
and
the
facility
labor
costs
in
Exhibit
2­
3,
in
order
to
estimate
total
costs
to
them.

Table
2­
19.
Model
Input:
Electronic
Signature
Agreement
Costs
Number
of
Registrants
Time/
Registrant
Varies*
10
minutes
*
Based
on
the
annual
number
of
employee
registrants,
as
shown
in
Table
V­
5
of
Appendix
V.
29
2.3.4.2
"
To
Be"

Under
"
To
Be",
the
model
assumes
that
facilities
that
report
to
both
EPA
and
State/
Locals
receiving
systems
must
comply
with
the
electronic
signature
agreement
requirement
for
both
EPA
and
the
State/
Locals
systems.
The
model
also
assumes
that
facilities
subject
to
multiple
State/
Locals
receiving
systems
must
comply
with
the
requirement
for
each
system.
The
model
assumes
that
each
indirect
reporter
reports
to,
on
average,
2.5
State/
Locals
systems.

Table
2­
20
presents
the
annual
number
of
direct
and
indirect
reporting
facilities
and
their
employees
that
are
expected
to
register
with
EPA
or
State/
Locals
receiving
systems
and
become
subject
to
the
identity­
proofing
requirements.
However,
note
that,
in
regard
to
compliance
with
the
electronic
signature
agreement
requirements,
the
model
makes
a
number
of
additional
assumptions
to
estimate
the
annual
number
of
employees
and
facilities
that
will
submit
subscriber
agreements,
LRA
certifications,
and
other
paperwork
to
the
CDX
and
State/
Locals
systems.

The
model
assumes
that
small
firms
(
i.
e.,
20
or
fewer
employees)
would
opt
to
have
each
of
their
employee
registrants
submit
the
wet­
ink
agreement
directly
to
EPA
or
State/
Locals.
Specifically,
the
model
assumes
that
a
registrant
would
log
onto
the
agency's
receiving
system,
create
an
account,
and
generate
a
signature
(
e.
g.,
PIN
or
password).
They
would
then
prepare
and
submit
the
subscriber
agreement
to
the
receiving
agency
and
keep
it
on
file.
The
agency
would
conduct
a
review
of
the
agreement
and,
if
accepted,
open
the
system's
account
so
that
the
registrant
can
begin
use.
Employee
registrants
would
renew
their
agreements
every
2
years.
The
model
assumes
that
small
firms
have,
on
average,
three
employee
registrants
each.
In
addition,
the
model
assumes
an
annual
employee
turnover
rate
of
10
percent.

The
model
assumes
that
medium­
to
large­
sized
firms
would
exercise
the
local
authority
option
under
EPA
and
State/
Locals
systems.
The
model
assumes
that
the
local
authority
would
be
an
official
designated
by
their
entity
to
act
in
that
capacity.
To
be
designated
as
a
local
authority,
the
official
must
submit
to
EPA
or
State/
Locals,
a
notarized
affidavit
of
identity,
as
well
as
a
written
authorization
from
their
entity
that
they
are
authorized
to
issue
agreement
collection
certifications
on
its
behalf.
After
being
designated,
the
official
would
compile
wet­
ink
signature
agreements
from
their
employee
registrants,
prepare
an
agreement
collection
certification,
and
store
the
documents
in
a
secured
location.
The
official
would
then
electronically
submit
a
notification
to
the
receiving
agency
for
review
and
approval.
The
agency
would
conduct
a
review
of
the
notification
and,
if
accepted,
open
the
accounts
so
that
the
registrants
can
begin
use.
In
addition,
the
model
assumes
an
annual
employees
and
local
authority
turnover
rate
of
10
percent.

The
model
assumes
that
medium­
and
large­
sized
firms
own
on
average,
three
facilities,
each
of
which
has
six
employee
registrants.
Hence,
medium­
and
large­
sized
firms
are
assumed
to
have,
on
average,
18
employee
registrants
each.

Table
2­
20
presents
the
annual
number
of
direct
and
indirect
facility
and
employee
registrants,
by
firm
size,
that
become
subject
to
the
electronic
signature
agreement
requirements.
30
Table
2­
20.
Annual
Number
of
Facility
and
Employee
Registrants
that
Become
Subject
to
Identity
Proofing
Requirements,
by
Firm
Size
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
Direct
Reporters
Small
Facilities
13,199
7,388
4,647
3,548
3,193
2,874
2,586
2,327
2,095
1,885
Small
Facility
Employee
Registrants
39,597
22,164
13,941
10,644
9,579
8,622
7,758
6,981
6,285
5,655
Medium/
Large­
Size
Facilities
1,631
914
574
438
395
355
320
288
259
233
Medium/
Large­
Size
Facility
Employee
Registrants
9,786
5,484
3,444
2,628
2,370
2,130
1,920
1,728
1,554
1,398
Indirect
Reporters
Small
Facilities
­
­
130.888
30,540
27,486
24,738
22,263
20,037
18,034
16,231
Small
Facility
Employee
Registrants
­
­
392,664
91,620
82,458
74,214
66,789
60,111
54,102
48,693
Medium/
Large­
Size
Facilities
­
­
16,177
3,775
3,397
3,058
2,752
2,477
2,229
2,006
Medium/
Large­
Size
Facility
Employee
Registrants
­
­
97,062
22,650
20,382
18,348
16,512
14,862
13,374
12,036
XML
and
Flat
File
Mapping
Costs.
The
model
estimates
XML
and
flat
file
mapping
costs
to
the
registrants
shown
in
Table
X­
1
or
X­
2
of
Appendix
X
for
"
Baseline"
or
"
To
Be",
respectively.
Refer
to
the
Appendix
X
for
additional
model
assumptions.

Reporting
to
EPA
by
Paper
and
Electronic
Methods.
The
model
estimates
the
total
costs
to
direct
reporters
in
preparing
and
submitting
documents
by
paper
and
electronically.
Refer
to
Appendix
VII
for
the
model's
equations
in
calculating
these
costs.

Table
2­
21
presents
the
activities
and
burden
assumptions
associated
with
direct
and
indirect
reporter
compliance
with
the
electronic
signature
agreement
requirements.
These
burden
assumptions
were
multiplied
by
the
facility
employee
labor
rates
shown
in
Exhibit
2­
3
and
the
number
of
employee
registrants
in
Table
2­
20
in
order
to
estimate
costs
to
them.
Note
that
all
employee
registrants
in
small
firms
are
expected
to
submit
a
subscriber
agreement
when
they
register.
Medium­
and
large­
size
firms
are
expected
to
designate
a
local
registration
authority
that
will
collect
and
store
subscriber
agreements
from
the
firm's
employees,
prepare
an
agreement
collection
certification,
and
send
a
certification
of
receipt
and
secure
storage
to
a
receiving
agency.
31
Table
2­
21.
Direct/
Indirect
Reporters
Implementation
of
Electronic
Signature
Agreement
Provisions
with
Burden
Assumptions
Facilities
Hour
Burden
Capital/
O&
M
Cost
Number
of
Submittals
Prepare,
submit,
and
file
wet­
ink
signature
agreements
0.25
$
2.50
Varies
annually.*
Each
small
firm
will
submit
wet­
ink
agreements
for
their
employees
using
certified
mail.
This
includes
all
new
registrants
in
2003
through
2012
($
2.50/
submittal).
It
also
includes
registrants
that
had
registered
with
EPA
or
State/
Locals
system
prior
to
publication
of
the
final
rule.
The
model
assumes
these
registrants
would
have
to
submit
their
wet­
ink
agreements
in
2004.

Prepare,
submit,
and
file
new
wet­
ink
signature
agreements
(
employee
turnover)
0.25
$
2.50
Varies
annually.**
Small
firms
must
submit
a
new
wet­
ink
signature
agreement
when
it
replaces
an
existing
employee
registrant
(
due
to
employee
turnover).

Renew
wet­
ink
signature
agreements
0.25
$
2.50
Varies
annually.**
Employee
registrants
at
small
firms
must
renew
their
signature
agreements
every
2
years.

Develop
a
plan/
process
to
collect
and
store
wetink
signature
agreements,
designate
local
authority,
and
submit
application
material
12
$
5.00
Varies
annually.*
Medium­
size
and
large
firms
will
develop
a
plan/
process
to
comply
with
the
requirement,
identify
who
their
local
authority
should
be,
and
submit
application
materials
to
EPA
or
State/
Locals
to
designate
a
local
authority.
The
application
must
establish
the
identity
of
the
individual
by
notarized
affidavit
and
include
written
statement
that
the
individual
is
authorized
by
the
regulated
entity
to
issue
an
agreement
certificate
on
its
behalf.
This
includes
all
new
registrants
in
2003
through
2012.
It
also
includes
registrants
that
had
registered
with
EPA
or
State/
Locals
system
prior
to
publication
of
the
final
rule.
The
model
assumes
these
registrants
would
have
to
submit
their
applications
in
2004.
Model
includes
$
2.50
for
notary
public
and
$
2.50
for
certified
mail
delivery.

Obtain
legal
counsel
1
$
0.00
Varies
annually.*
Each
medium­
size
and
large
firm
will
obtain
legal
counsel
in
establishing
a
process.

Register
local
authority
with
CDX
or
State/
Locals
system
0.183
$
0.00
Varies
annually.*
Each
local
authority
will
establish
an
account
at
the
CDX
or
State/
Locals
system
so
that
they
can
32
Facilities
Hour
Burden
Capital/
O&
M
Cost
Number
of
Submittals
transmit
submittals
electronically.
The
local
authority
will
also
ask
questions
of
the
identity­
proofing
requirement
when
they
call
the
CDX
or
State/
Locals
Help
Desk.

Prepare/
send
wet­
ink
signature
agreement
to
local
authority
0.25
$
0.37
Varies
annually.*
All
employee
registrants
within
a
medium­
size
or
large
firm
must
prepare
and
submit
wet­
ink
agreements
to
the
local
authority.
The
model
assumes
the
local
authority
is
at
an
offsite
local
(
e.
g.,
headquarters
office).

Prepare
local
authority
certification
and
submit
notification
of
certificate
1
$
0.00
Varies
annually.*
Each
local
authority
will
store
the
signed
agreements
on­
site.
Local
authorities
will
then
send
EPA
the
information
required
to
update
the
CDX
security
profiles
(
list
of
employees,
data
flows
for
which
each
is
authorized
to
represent
the
company,
other
pertinent
information).
EPA
will
receive/
process
the
security
information
and
review
it
for
completeness
and
acceptability.

Prepare/
send
new
agreements
to
local
authority
(
employee
turnover)
0.25
$
0.37
Varies
annually.**
New
wet­
ink
signature
agreements
will
be
prepared
and
sent
by
new
employee
registrants
who
replace
an
existing
employee
registrant
who
is
leaving
the
company
(
employee
turnover).
The
agreements
will
be
sent
to
their
local
authority
for
record
keeping.

Submit
updated
notification
of
certificate
(
employee
turnover)
0.08
$
0.00
Varies
annually.**
When
the
local
authority
receives
the
new
wet­
ink
agreement
from
the
replacement
employee,
they
will
file
the
agreement
on
site
and
electronically
submit
an
updated
notification
of
certificate
to
EPA
or
State/
Locals
system
(
employee
turnover).

Redesignate
local
authority
and
send
application
material
(
local
authority
turnover)
1
$
5.00
Varies
annually.**
Some
local
authorities
will
leave
the
firm
(
or
current
position/
role)
and
have
to
be
replaced.
Their
firm
must
identify
a
new
local
authority
and
submit
a
new
application
to
EPA
or
State/
Locals
agency
to
designate
him.

Register
new
local
authority
0.183
$
0.00
Varies
annually.**
The
replacement
local
authority
must
register
with
the
CDX
in
order
to
submit
updates
to
the
certification
electronically.
33
Facilities
Hour
Burden
Capital/
O&
M
Cost
Number
of
Submittals
Report
breach
of
storage
security
0.5
$
0.00
Varies
annually.**
Some
firms
will
experience
a
breach
of
security
of
their
stored
agreements.
The
local
authority
must
report
such
breach.
The
model
assumes
1
percent
of
medium­
size
and
large
firms
will
experience
a
breach
annually.

Prepare/
send
wet­
ink
signature
agreement
to
local
authority
(
breach
of
security)
0.25
$
0.37
Varies
annually.**
All
employee
registrants
must
prepare
and
submit
a
new
wet­
ink
agreement
to
the
local
authority.

Prepare
and
submit
notification
of
certificate
(
breach
of
security)
0.08
$
0.00
Varies
annually.**
When
the
local
authority
receives
the
new
wet­
ink
agreements
from
the
employees,
they
will
file
the
agreement
on­
site
and
electronically
submit
an
updated
notification
of
certificate
to
EPA
or
State/
Locals
system
(
employee
turnover).

Renew
local
authority
designation
1
$
5.00
Varies
annually.**
The
local
authority
must
renew
their
designation
every
2
years
by
resubmitting
the
application
to
EPA
or
State/
Locals.
Model
includes
$
2.50
for
notary
public
and
$
2.50
for
certified
mail
delivery.

Identify
and
resolve
problems
1
$
0.00
Varies
annually.**
Some
small,
mediumsize
and
large
firms
will
have
to
work
with
EPA
or
State/
Locals
to
resolve
problems
involving
their
agreements
or
certifications.
The
model
assumes
3
percent
of
registrants
will
be
involved
in
a
problem
that
must
be
resolved
annually.

*
Based
on
the
annual
number
of
direct
or
indirect
reporter
employees
registering
with
the
CDX
and/
or
State/
Locals
receiving
system
each
year.

**
Based
on
the
number
of
direct
and
indirect
reporter
employees
that
have
already
registered
with
the
CDX
and/
or
State/
Locals
receiving
systems
each
year.
34
3.0
Conclusions
and
Findings
3.1
Total
Costs
In
this
analysis,
the
"
To
Be"
scenario
represents
the
costs
actually
incurred
to
date
under
the
rulemaking
and
CDX,
as
well
as
the
expected
costs
going
forward.
As
shown
in
Table
3­
1,
EPA
estimates
that
the
cumulative
costs
incurred
by
EPA,
State/
Locals,
and
facilities
under
"
To
Be"
from
2003
to
2012
would
be
higher
than
their
cumulative
costs
incurred
under
"
Baseline"
over
the
same
period.
The
estimated
total
incremental
costs
under
"
To
Be"
range
from
$
34.4
million
to
$
41.7
million,
depending
on
the
discount
rate
used.
(
Refer
to
Appendix
XII
for
summary
tables
of
the
total
annual
costs
to
EPA,
State/
Locals,
and
facilities
under
"
Baseline"
and
"
To
Be".
The
costs
in
Table
3­
1
are
based
on
the
tables
in
the
appendix.
The
tables
in
the
appendix
are
not
discounted,
however.)

Table
3­
1.
Total
Cost
Impacts
under
To
Be"*
(
in
millions
of
dollars)

A
Comparison
of
Total
Cumulative
Costs
under
"
To
Be"
Relative
to
"
Baseline"
Between
2003
and
2012*
(
in
millions
of
dollars)

Entity
**
Cumulative
Costs
Baseline
To
Be
Difference
in
Cumulative
Costs
To
Be
Relative
to
Baseline
Difference
in
Cumulative
Costs
To
Be
Relative
to
Baseline
Discounted
at
7%
Rate
Difference
in
Cumulative
Costs
To
Be
Relative
to
Baseline
Discounted
at
3%
Rate
EPA
$
703.78
$
618.02
($
85.76)
($
64.44)
($
75.41)

State/
Locals
$
76.29
$
149.04
$
72.75
$
57.19
$
65.20
Facilities
$
7039.34
$
7101.31
$
61.97
$
41.61
$
51.93
Total
$
7819.41
$
7868.37
$
48.96
$
34.36
$
41.72
*
Cost
savings
shown
in
parentheses.

**
Not
discounted.

3.2
EPA
EPA
estimates
an
overall
cost
savings
to
EPA
from
2003
to
2012
under
"
To
Be"
relative
to
"
Baseline."
As
shown
in
Table
3­
1,
these
estimated
savings
range
from
$
64.4
million
to
$
75.4
million,
depending
on
the
discount
rate
used.
Under
both
"
Baseline"
and
"
To
Be,"
EPA
must
develop
receiving
systems
and
rules
to
allow
for
automated
submittals.
However,
EPA
would
develop
one
gateway
and
rule
under
"
To
Be,"
instead
of
nine
rules
and
gateways
under
"
Baseline."
In
this
regard,
CROMERR/
CDX
would
be
more
efficient
than
the
approach
under
"
Baseline,"
where
nine
programs
would
have
to
enable
automation
on
a
more
piecemeal
basis,
which
is
less
efficient.

3.3
State/
Locals
EPA
estimates
that
State/
Locals
will
incur
greater
costs
between
2003
and
2012
under
"
To
Be"
than
"
Baseline."
As
shown
in
Table
3­
1,
cumulative
incremental
costs
to
State/
Locals
under
"
To
Be"
are
estimated
to
range
from
$
57.2
million
to
$
65.2
million,
depending
on
the
discount
rate
used.
As
an
initial
point,
it
is
important
to
understand
that
the
State/
Locals'
costs
estimated
in
the
model
for
both
"
Baseline"
and
"
To
Be"
are
solely
those
costs
that
result
from
EPA's
rules.
35
Specifically,
the
model
examines
State/
Locals'
costs
for
complying
with
EPA
rule
requirements
for
upgrading
their
electronic
receiving
systems
to
meet
EPA
standards,
applying
to
EPA
for
approval
of
their
program
changes,
and
administering
electronic
signature
agreement
provisions
as
applicable.
The
model
does
not
consider
the
potential
savings
(
e.
g.,
efficiencies)
to
State/
Locals
in
processing
electronic
submittals
from
indirect
reporters,
as
these
impacts
are
considered
outside
the
scope
of
this
analysis.

One
of
the
primary
reasons
for
the
greater
costs
under
"
To
Be"
is
that
State/
Locals
would
be
required
to
comply
with
more
robust
electronic
signature
agreement
requirements
than
under
"
Baseline."
Under
"
Baseline,"
it
is
assumed
State/
Locals
would
require
indirect
reporters
to
prepare
and
keep
electronic
signature
agreements
on
site.
Because
State/
Locals
would
not
collect
them,
there
is
negligible
cost
to
them
under
this
requirement.
Under
"
To
Be,"
State/
Locals
need
to
perform
significantly
more
activities.
They
must
plan
for
implementation
of
the
signature
agreement
provisions
(
e.
g.,
develop
systems
for
processing
the
paperwork)
and
carry
out
implementation
activities
(
e.
g.,
working
with
entities
to
designate
an
LRA,
processing/
filing
agreements
and
other
submittals
received,
and
upgrading
their
receiving
systems
as
appropriate).

In
addition,
the
model
assumes
that
EPA
would
be
more
efficient
in
promulgating
CROMERR
under
"
To
Be"
than
it
would
under
"
Baseline"
in
promulgating
its
program
rules
enabling
automation.
This
greater
efficiency
leads
to
the
earlier
publication
of
CROMERR
under
"
To
Be"
than
publication
of
the
program
rules
under
"
Baseline."
Because
of
its
earlier
publication,
CROMERR
would
prompt
State/
Locals
to
begin
upgrading
their
systems
and
applying
for
EPA
program
modification
approval
sooner
under
"
To
Be"
(
i.
e.,
beginning
in
2004)
than
under
"
Baseline"
(
i.
e.,
beginning
in
2006).
Once
they
finalize
their
initial
system
upgrades
and
submit
their
applications
to
EPA,
they
would
begin
to
incur
annual
maintenance
costs
for
their
systems.

In
this
regard,
the
model
estimates
State/
Locals'
upgrade
and
application
costs
under
"
To
Be"
for
the
period
2004
through
2012
(
i.
e.,
a
9­
year
period).
The
model
estimates
State/
Locals'
upgrade
and
application
costs
under
"
Baseline"
for
the
period
2006
through
2012
(
i.
e.,
a
7­
year
period).
As
such,
the
cumulative
costs
to
State/
Locals
under
"
To
Be"
involve
a
greater
number
of
years
than
the
cumulative
costs
for
"
Baseline."
As
a
consequence,
the
cumulative
costs
under
"
To
Be",
including
the
cumulative
discounted
costs
shown
in
Table
3­
1,
are
greater.

3.4
Facilities
EPA
estimates
that
facilities
will
incur
greater
costs
between
2003
and
2012
under
"
To
Be"
than
"
Baseline."
As
shown
in
Table
3­
1,
incremental
costs
to
facilities
under
"
To
Be"
are
estimated
to
range
from
$
41.6
million
to
$
51.9
million,
depending
on
the
discount
rate
used.

The
model
examines
cost
impacts
to
both
direct
and
indirect
facility
reporters.
The
model
examines
costs
to
direct
and
indirect
reporters
using
different
assumptions
because
they
would
be
affected
differently
under
EPA's
regulatory
actions.

With
regard
to
direct
reporters
under
"
Baseline"
and
"
To
Be",
it
is
assumed
the
EPA's
rulemaking
and
other
actions
would
enable
them
to
report
electronically
to
EPA
under
existing
information
collections,
as
an
alternative
to
paper­
based
reporting.
Direct
reporters
also
would
be
subject
to
specific
other
requirements
as
applicable
(
e.
g.,
registration
with
EPA
receiving
system).
Therefore,
the
model
estimates
costs
to
direct
reporters
under
"
Baseline"
and
"
To
Be"
for
both
(
1)
the
ongoing
reporting
to
EPA
electronically
and
by
paper
and
(
2)
compliance
costs
with
specified
other
requirements.

In
this
respect,
the
model
assumes
that
direct
reporters
will
incur
some
efficiencies
and
other
benefits
under
"
To
Be"
relative
to
"
Baseline".
First,
the
model
assumes
they
would
have
to
register
only
once
with
the
CDX
under
"
To
Be"
because
the
gateway
is
Agency­
wide.
Under
36
"
Baseline",
they
may
need
to
register
with
multiple
program
gateways,
because
the
programs
would
have
separate
gateways.
Second,
the
model
assumes
that,
by
and
large,
direct
reporters
would
begin
reporting
electronically
to
EPA
sooner
under
"
To
Be"
than
"
Baseline".
The
model
assumes
that
the
Agency
would
be
more
efficient
in
establishing
CROMERR
and
the
CDX
under
"
To
Be"
than
in
establishing
program­
specific
rules
and
gateways
under
"
Baseline".
Hence
the
model
assumes
the
Agency
would
automate
a
number
of
its
information
collections
sooner
under
"
To
Be".
This
would
allow
direct
reporters
to
begin
experiencing
the
savings/
efficiencies
of
electronic
reporting
sooner.
However,
the
model
assumes
that
direct
reporters
would
not
be
required
to
comply
with
electronic
signature
agreement
requirements
under
"
Baseline".
By
contrast,
it
assumes
that
direct
reporters
must
comply
with
robust
electronic
signature
agreement
requirements
under
"
To
Be".
They
must
conduct
a
number
of
activities
under
these
requirements
(
e.
g.,
prepare/
submit
agreement
paperwork
or
implement
an
LRA
approach).

Despite
the
signature
agreement
costs
under
"
To
Be",
the
model
assumes
that
direct
reporters
would
experience
a
net
cumulative
cost
savings
under
"
to
Be"
in
comparison
with
"
Baseline"
during
the
period
2003
through
2012.
(
Note
that
Table
3­
1
does
not
break
out
the
respective
cost
impacts
for
direct­
versus­
indirect
reporters.
Rather,
it
shows
only
the
combined
cost
of
impacts
during
the
period.)
With
regard
to
direct
reporters
under
"
Baseline"
and
"
To
Be",
it
is
assumed
that
EPA's
rulemaking
actions
would
have
no
effect
on
indirect
reporter
costs,
except
to
require
State/
Locals
to
impose
electronic
signature
agreement
provisions
on
them.
It
is
assumed
that
the
pace
of
State/
Locals
electronic
reporting
initiatives
would
not
be
affected
by
EPA's
regulatory
actions
and
that
indirect
reporters
would,
therefore,
implement
electronic
reporting
on
a
schedule
that
is
independent
of
EPA's
regulations.
Hence,
the
model
examines
the
costs
to
indirect
reporters
for
complying
with
EPA
electronic
signature
requirements.
It
does
not
examine
their
cost
savings/
efficiencies
in
reporting
electronically
tp
State/
Locals
receiving
systems
on
an
ongoing
basis
because
these
impacts
are
considered
outside
the
scope
of
this
analysis.

In
this
respect,
the
model
assumes
that
the
electronic
signature
provisions
under
"
To
Be"
would
be
significantly
more
robust
than
under
"
Baseline."
Under
"
Baseline,"
they
would
only
prepare
and
keep
records
of
an
electronic
signature
agreement
on
site.
Under
"
To
Be,"
they
must
implement
significantly
more
activities
(
e.
g.,
prepare/
submit
electronic
signature
agreements
or
implement
LRA
approach,
report
to
State/
Locals
as
specified).
The
more
robust
electronic
signature
agreement
provisions
under
"
To
Be"
result
in
incremental
costs
to
indirect
reporters
in
comparison
with
"
Baseline".
Table
3­
1
shows
that
the
combined
cumulative
costs
to
direct
and
indirect
reporters
under
"
To
Be"
are
higher
than
their
combined
cumulative
costs
under
"
Baseline".
Specifically,
the
cost
savings
to
direct
reporters
under
"
To
Be"
as
described
above
are
more
than
offset
by
the
incremental
costs
to
indirect
reporters
under
the
signature
agreement
requirements
of
"
To
Be".
37
4.0
Sensitivity
Analysis
Based
on
past
data
on
the
CDX,
the
Agency
estimates
that
30
percent
of
facilities
would
implement
electronic
reporting
during
the
first
year
of
an
information
collection's
automation
start
date.
The
annual
implementation
rate
is
assumed
to
be
10
percent
per
annum
during
the
rest
of
the
modeling
years.
The
model
applies
this
rate
to
derive
the
total
annual
costs
associated
with
both
paper
and
electronic
submittals,
as
well
as
the
number
of
registrants
each
year.
The
implementation
rate
was
applied
on
a
collection­
by­
collection
basis,
based
on
the
collection's
automation
start
date
under
"
Baseline"
or
"
To
Be".

An
information
collection's
automation
start
date
determines
the
percentage
of
facilities
and
submittals
that
will
be
automated
by
the
end
of
the
modeling
period.
As
an
example,
information
collections
with
an
automation
start
date
of
2003
would
see
73
percent
automation
by
the
end
of
2012.
The
majority
of
collections
would
be
automated
in
the
2003
to
2005
timeframe
under
"
Baseline"
and
"
To
Be".

EPA
notes,
however,
that
these
rates
are
speculative
and
subject
to
wide
variation.
Therefore,
EPA
performed
sensitivity
analyses
to
assess
cost
impacts
using
two
different
implementation
rate
scenarios:

 
Scenario
1.
An
annual
implementation
rate
of
25
percent
for
the
first
year
in
which
an
information
collection
is
automated
and
8.5
percent
annually
thereafter.
As
a
basis
of
comparison
to
the
annual
implementation
rate
above
(
i.
e.,
30/
10),
an
information
collection
with
an
automation
start
date
of
2003
would
see
66
percent
automation
by
the
end
of
2012.

 
Scenario
2.
An
annual
implementation
rate
of
45
percent
for
the
first
year
in
which
an
information
collection
automates
and
15
percent
annually
thereafter.
As
a
basis
of
comparison
to
the
annual
implementation
rate
above
(
i.
e.,
30/
10),
an
information
collection
with
an
automation
start
date
of
2003
would
see
87
percent
automation
by
the
end
of
2012.

Table
4­
1
compares
the
overall
cumulative
costs
to
EPA,
State/
Locals,
and
facilities
under
"
To
Be"
relative
to
"
Baseline"
under
the
three
different
implementation
rate
scenarios.
The
results
suggest
that
the
overall
costs
to
these
entities
are
sensitive
to
the
annual
implementation
rate.
For
example,
the
annual
implementation
rates
under
Scenario
2
are
50
percent
higher
than
the
rates
used
in
this
analysis
(
i.
e.,
30/
10).
However,
the
costs
under
Scenario
2
are
almost
70
percent
higher
than
that
of
the
modeled
scenario.
38
Table
4­
1.
A
Comparison
of
Total
Cumulative
Costs
under
"
To
Be"
Relative
to
"
Baseline"
Between
2003
and
2013*
at
Different
Annual
Automation
Rates
(
in
millions
of
dollars)

Entity
Difference
in
Cumulative
Costs
with
Implementation
Rates
at
25%
and
8.5%

(
Scenario
1)
Difference
in
Cumulative
Costs
with
Implementation
Rates
at
30%
and
10%
Difference
in
Cumulative
Costs
with
Implementation
Rates
at
45%
and
15%

(
Scenario
2)

EPA
($
64.55)
($
64.44)
($
64.25)

States/
Locals
$
53.36
$
57.19
$
67.31
Facilities
$
36.48
$
41.61
$
55.11
Total
$
25.30
$
34.36
$
58.17
*
Seven
percent
discount
rate
used.
Cost
savings
shown
in
parentheses.
39
5.0
Qualitative
Benefits
of
CROMERR
and
CDX
5.1
Summary
of
Other
Impacts
The
preceding
analysis
in
Sections
2.0
and
3.0
of
this
memorandum
examines
the
cost
burden
to
EPA,
State/
Locals,
and
facilities
solely
with
developing
and
implementing
the
identity­
proofing
requirement.
The
analysis
does
not
consider
other
impacts,
such
as
the
following:

 
The
identity­
proofing
requirement
will
most
likely
discourage
a
number
of
facilities
from
choosing
electronic
reporting
over
paper
reporting
for
certain
information
collections.
Under
the
requirement,
facilities
would
incur
upfront
and
ongoing
compliance
costs
(
e.
g.,
establishing
a
local
authority,
preparing
the
wet­
ink­
on­
paper
signature
agreements,
renewing
the
wet­
ink­
on­
paper
signature
agreements).
These
compliance
costs
will
partially
or
fully
offset
the
cost
savings
that
some
facilities
would
expect
from
reporting
electronically.
This
is
particularly
true
for
one­
time
and
infrequent
collections,
as
well
as
voluntary
collections
(
e.
g.,
surveys).
As
a
result,
a
number
of
facilities
will
determine
that
electronic
reporting
under
such
collections
is
not
cost
effective
or
is
simply
inconvenient
and
opt
for
paper
reporting.
In
the
end,
these
facilities
will
not
incur
the
burden
savings/
efficiencies
associated
with
electronic
reporting;
rather,
they
will
incur
the
higher
burden
associated
with
paper
reporting.

 
CSC
has
not
performed
any
in­
depth
quantitative
analysis
to
determine
what
the
cost
impacts
would
be.
However,
a
review
of
the
CROMERR
CBA
spreadsheets
suggest
that
a
1­
percent
decrease
in
facilities'
annual
automation
rate
with
the
CDX
would
translate
into
$
2
million
or
more
in
incremental
costs
to
facilities
annually.
This
suggests
that
costs
under
the
CDX
are
highly
influenced
by
minor
changes
in
the
automation
rate
and
that
the
identityproofing
requirement
could
have
a
significant
cost
impact
beyond
the
cost
estimates
presented
in
Section
3.0
of
this
document.
Impacts
to
facilities
reporting
to
State/
Locals
receiving
systems
would
likely
be
similar.

 
Along
these
same
lines,
the
identity­
proofing
requirement
will
likely
discourage
State/
Locals
from
automating
some
of
their
information
collections.
This
is
partly
because
some
State/
Locals
government
offices
will
not
want
to
incur
the
burden
of
planning
for,
and
implementing
the
requirement,
as
it
will
require
ongoing
resources
(
e.
g.,
receiving,
processing,
filing
wet­
ink­
on­
paper
signature
agreements).
As
described
earlier
in
this
analysis,
some
states
may
also
need
to
conduct
rulemakings
to
implement
the
requirement.
Further,
State/
Locals
will
recognize
that
it
would
not
be
cost
effective
for
facilities
to
report
electronically
under
some
collections
(
e.
g.,
one­
time
collections,
surveys),
and
therefore,
the
State/
Locals
will
not
automate
them
in
the
first
place.

Implementing
electronic
reporting
under
CROMERR
and
CDX
will
result
in
a
number
of
important
benefits
that
cannot
readily
be
quantified.
Some
of
the
benefits
are
described
below:

 
More
accurate
data.
Replacing
paper
forms
with
electronic
forms
will
result
in
more
accurate
data.
Electronic
forms
can
perform
real­
time
edit
checks
that
will
reduce
the
number
of
input
errors.
These
checks
can
range
from
simple
verification
of
valid
date
formats
to
complex
validations
of
proper
nomenclature
and
limits
of
chemicals
emitted
into
the
environment.
Other
aspects
of
data
accuracy
include:
Duplication
of
data
entry
efforts.
As
they
receive
paper
submissions,
environmental
agencies
often
key
or
scan
in
the
data.
That
duplicative
effort
can
result
in
data
errors.
These
errors
can
cause
confusion
because
the
agency
could
act
on
information
that
is
different
from
what
the
submitter
believes
was
submitted.
40
 
Time
required
for
remediation.
When
data
errors
are
detected
by
agencies,
remedial
action
must
be
undertaken.
These
remedial
actions
require
participation
by
both
the
submitter
and
the
receiving
agencies,
and
are
extremely
time­
consuming.

 
Effect
of
inaccurate
data.
If
the
data
that
passes
through
agency
systems
is
inaccurate
and
made
publicly
available,
it
creates
additional
costs
and
inefficiencies
and
could
lead
to
more
significant
problems,
such
as
enforcement
actions.
The
effect
of
inaccurate
data
has
reached
a
point
that
EPA
has
initiated
a
data­
correction
effort.
This
initiative
uses
Help
Desk
personnel
to
receive
calls,
take
complaints,
and
oversee
corrective
action.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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


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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Annual
Percent
of
Electronic
Reporters
Using
Web
Forms
6%

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

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

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

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

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

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

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

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

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

Managers
$
55.94
20%

Technical
Staff
$
40.40
50%

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

Managers
$
40.58
20%

Technical
Staff
$
27.53
50%

Administrative
Staff
$
21.07
20%

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

Managers
$
51.47
20%

Technical
Staff
$
34.69
50%

Administrative
Staff
$
23.25
20%

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

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

EPA
reviewed
the
data
in
the
tables
to:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Table
VII­
1
shows
the
scaling
factors
for
each
program.

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

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

Table
VII­
2.
Annual
Burden
Hours
to
Direct
Reporters*

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

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

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

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

OW
UIC
Program
370.18
0.04
­

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

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

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

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

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

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

where
i
=
1 
k*

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

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

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

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

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

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

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

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

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

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

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

Table
IX­
2.
Direct
Reporters
and
Registrants*

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

 
Steve
McSherry
­
Decatur
Utilities,
Alabama
(
UCMR:
PWS)

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

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

 
Ruth
Curfman
­
Dow
Corning
Corporation,
Michigan
­
(
TSCA­
HASD)

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

*
Costs
presented
for
Scenario
1.

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

*
Costs
presented
for
Scenario
1.

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

*
Costs
presented
for
Scenario
1.

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

*
Costs
presented
for
Scenario
2.

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

*
Costs
presented
for
Scenario
2.

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

*
Costs
presented
for
Scenario
2.

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