Supporting Statement for an Information Collection Request (ICR)
Under the Paperwork Reduction Act (PRA)
EXECUTIVE SUMMARY
Identification of the Information Collection  -  Title and Numbers
Title:
Residential Lead-Based Paint Hazards Disclosure Requirements
EPA ICR No.:
1710.09
OMB Control No.:
2070-0151
Docket ID No.:
EPA-HQ-OPPT-2017-0631
Abstract
This ICR will cover the information collection activities associated with the reporting and recordkeeping requirements for sellers, lessors, and their agents' disclosure activities in target housing including the allowance of up to ten days for an optional risk assessment or inspection before being obligated under purchase or lease contract.
Summary Table 
                                  IC Category
                          Total Number of Respondents
                           Total Number of Responses
                            Response per Respondent
                             Annual Burden (hours)
                                Total Cost ($)
IC 1: Real Estate and Lessor Agents
                                    695,958
                                  11,917,193
                                     17.1
                                    775,797
                                  35,528,425
IC 2: Individuals
                                  16,097,600
                                  32,624,400
                                      2.0
                                   4,705,272
                                  97,792,282
Total
                                  16,793,558
                                  44,541,593
                                      2.7
                                   5,481,069
                                 $133,320,708
Agency 
                                       -
                                       -
                                       -
                                       -
                                       -
      
SUPPORTING STATEMENT
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
Section 1018 of the Residential Lead-Based Paint Hazard Reduction Act of 1992 (the Act) (42 U.S.C. 4852d) directs the Environmental Protection Agency (EPA) and the Department of Housing and Urban Development (HUD) to jointly issue regulations requiring disclosure of known lead-based paint and/or lead-based paint hazards by persons selling or leasing housing constructed before the phase out of residential lead-based paint use in 1978. Under that authority, EPA and HUD established requirements at 40 CFR 745, Subpart F and 24 CFR 35, Subpart A. More details are provided in Unit 2(a) of this Supporting Statement.
The related legal authority is the Toxic Substances Control Act (TSCA), 15 U. S. C. 2601 et seq., with related requirements provided in 40 CFR part 745. The various applicable sections are provided in Attachment A and are briefly summarized here along with their implementing regulations, which are provided in Attachment B and C. TSCA section 401 defines target housing as any housing constructed before 1978 except housing for the elderly or  persons with disabilities or 0bedroom dwelling (unless any child who is less than 6 years of age resides or is expected to reside in such housing).
 
The current regulations in 40 CFR part 745, subpart F cover the types of regulated sale and lease transactions in target housing, the disclosure requirements, and the recordkeeping requirements (Attachment B).
In addition, the EPA has developed extensive guidance and other materials that are available at https://www.epa.gov/lead.
The following provides a general overview for requirements covered in this ICR for each entity:
 Sellers of Pre-1978 Residential Housing:  The rule requires that sellers of pre-1978 housing (1) provide an EPA approved lead hazard information pamphlet to contract offerors, and (2) complete and attach a disclosure form to their sales contracts. A sample form is provided in the preamble to the regulations, but only the information elements are required, each respondent can develop its own form. The form must be signed by the seller, purchaser, and any agent(s) acting on behalf of the seller.
 Lessors of Pre-1978 Residential Housing:  The rule requires lessors of pre-1978 housing to (1) provide an EPA approved lead hazard information pamphlet to lessees, and (2) complete and attach a disclosure form to their leasing contracts. Again, while a sample form is provided, each respondent is permitted to develop its own form. The form must be signed by the lessor and any agent(s) acting on behalf of the lessor. The form must then be retained by the lessor, and any agents acting on their behalf.
 Agents Acting On Behalf of Sellers or Lessors:  Section 1018 of the Act specifically directs EPA to require agents acting on behalf of sellers or lessors to ensure compliance with the disclosure regulations.
EPA and HUD jointly administer and enforce the rule and have agreed to maintain a single ICR for these information collection activities. EPA will take the lead in preparing the necessary documentation for renewals.
2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the Agency has made of the information received from the current collection.
The information collection activities covered by this ICR are necessary components of the Lead Program established under the TSCA mandates discussed in section 2(a) of this Supporting Statement.
The third-party disclosure requirements that are contained in the regulations are specifically mandated by section 1018 of the Act. The recordkeeping requirements contained in the regulations are necessary for ensuring compliance with the provisions of the regulations.
Owners/Occupants of target housing. The third-party disclosure requirements attempt to ensure that families receive both specific information on the housing's lead history and general information on lead exposure prevention. With this information, consumers may be able to make more informed decisions concerning home purchase, lease, and maintenance to protect families from lead hazard exposure.
EPA, HUD, Local Governments. The recordkeeping requirements enable EPA and HUD, as well as tribal governments, state and local regulators and the courts, to both determine compliance and effectively enforce section 1018 and the provisions of the rule. In addition, the Act provides a private cause of action for persons harmed by violations of section 1018, and records kept pursuant to this rule may be important evidence for these parties.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
The EPA will make use of existing technology to simplify the application and notification processes where available. However, due to the requirements outlined in this ICR, electronic submissions are not generally applicable as submissions are not required to the Agency. Responses to consultations can be sent via electronic mail or other means by preference of the respondent.
4. Describe efforts to identify duplication Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The third-party disclosure and recordkeeping requirements covered by this ICR are unique and are not in any way duplicated by another information collection
5. If the collection of information impacts small businesses or other small entities, describe the methods used to minimize burden.
 The affected population for this rule is largely comprised of small entities, and all of the requirements have been crafted to maximize flexibility. EPA and HUD have also developed guidance and a sample form to further facilitate and assist small entities with compliance.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden. 
The third-party disclosure is transaction specific and only occurs when the regulated entities are engaged in a specific transaction, i.e., the sale or lease of target housing.
7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
   a)  requiring respondents to report information to the agency more often than quarterly; 
   b)  requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it; 
   c)  requiring respondents to submit more than an original and two copies of any document; 
   d)  requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years; 
   e)  in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
   f)   requiring the use of a statistical data classification that has not been reviewed and approved by OMB; 
   g)  that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
   h)  requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.  
Not applicable. 
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken in response to the comments. Specifically address comments received on cost and hour burden. 
Describe efforts to consult with persons outside EPA to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or report. 
Pursuant to 5 CFR 1320.8(d), EPA will publish a notice in the Federal Register, announcing the planned renewal of this information collection activity, soliciting public comment on specific aspects of the ICR and providing a 60-day public comment period.
In addition to the public notice that EPA will publish in the Federal Register concerning the renewal of this ICR, EPA staff will contact appropriate stakeholders and ask them for their assessment of the regulatory burden estimates expressed by the Agency in this ICR. A summary of these consultations will be provided in Attachment D.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. 
This question is not applicable to this ICR
10. Describe any assurance of. confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
This collection does not require the disclosure or retention of confidential information. The third-party disclosure requirements also comply with the provisions of the Privacy Act of 1974 and OMB Circular A-108.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
EPA asks no questions of a sensitive nature. 
12. Provide estimates of the hour burden of the collection of information.The statement should:
 Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
 If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens. 
 Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included under `Annual Cost to Federal Government'
Agent Start-up, Disclosure and Record Preparation, Recordkeeping and Materials Burden
The third-party disclosure requirements specify the communication and recordkeeping for agents and individuals undertaking the purchase, sale, or rental of a target housing unit. The North American Industrial Classification System (NAICS) codes associated with industries most likely affected by the paperwork requirements are described below: 

 5312		Real Estate Agents
 5311		Lessors of Real Estate
 5312		Real Estate Agents
 5311		Lessors of Real Estate

The start-up burden involves the time and cost required for agents to learn the disclosure rule's requirements and set up procedures for meeting those requirements. EPA estimates that the paperwork burden related to learning the rule and setting up compliance procedures is one hour. This estimate assumes real estate sales agents, sellers of rental property, and property managers only incur this start-up burden once, when they initially enter the profession. Since the rule's initial year has passed, the calculation assumes each year has an average number of new entrants incurring the start-up costs in their first year. 

The disclosure record preparation burden involves the time and cost for performing the disclosure activities in conjunction with the sale or rental of target housing as specified by the rule. Each instance is estimated to take five minutes for each of the parties. For each sale handled by an agent on the seller's side, the agent is expected to explain the rule to the seller. For each offer in each sale handled by an agent on the offeror's side, the agent is expected to explain the rule to the offeror. Thus for each sale without an agent the analysis assumes a total burden of twenty minutes (five minutes on each of two sides, for two offers), and a total burden of thirty-five minutes when the sale has an agent for each offeror and for the seller (twenty minutes plus five minutes for each of three agents).
The record-keeping provisions of this rule require the seller and the selling agent (or in the case of rentals, both the owners/lessors and their agents) maintain records of the signed disclosure. The record-keeping requirement causes them to spend time filing the specified documents. In all likelihood, some type of filing system - either in physical or digital form - already exists for each party. The incremental filing time that may reasonably be attributed to the disclosure rule itself should be very small, or approximately 0.5 minutes (0.0083 hours) per record.
The materials burden involves the cost of materials required for rule compliance. Materials costs include the lead hazard information pamphlets, filing materials, and copies to be made. The sellers and lessors may choose to provide these materials themselves or to have their agents manage these materials. For simplicity, this analysis assumes that these costs are borne by agents when they are involved, and otherwise assumed by the sellers and lessors. Of important note: modern technology allows for real estate transactions and documentation to be completed entirely using digital processes. When this technology is used for a transaction, the material cost of including LBP disclosure paperwork falls to zero. This analysis conservatively assumes that 83% of agent-based transactions and 0% of non-agent-based transactions use such software. 
For transactions that incur material costs, it is assumed that there is one copy of a two-page signed acknowledgment and disclosure statement for every offer or rental contract. For sales and rentals involving agents, up to four sets of the contract must be generated by the agent (one for the buyer/lessee, one for the seller/lessor and one for each agent). Sales transactions will also require a one-page lead-based paint inspection contingency clause for each party. Those are not required for rentals. This analysis assumes two offers per sale. Copy costs are assumed to be an average of $0.10 per page, the standard price per page at copy centers for black and white copies (November 2021). For simplicity, all transactions involving an agent on the seller/lessor side are also assumed to have an agent on the buyer/lessee side. 
In addition, filing-related material costs include the cost of storing the signed disclosure and acknowledgment statements that result from a completed transaction. Filing costs for individual buyers and sellers and owners and renters are considered a negligible incidental expense. The filing costs are assumed to apply only for agents. For filing materials, it is assumed a four-drawer, 26.5-inch deep filing cabinet can hold 26,500 sheets of paper and costs approximately $260 (average price at large office supply stores, November 2021). This translates into an approximate $0.01 cost per sheet of paper. For each sale or rental transaction, agents are assumed to retain one sheet of paper containing a signed disclosure and acknowledgment statement.

IC# 1. Agent Start-up, Disclosure and Record Preparation, Recordkeeping, and Material Burden
                        Citation: 40 CFR 745, subpart F
Data Element
Form
Responses
Burden (hours)
Materials
Cost ($)
Start-up Burden Real Estate Agents
N/A
                                                                         17,744
                                                                         17,744
N/A
                                                                        665,755
Start-up Burden Lessor Agents
N/A
                                                                         15,201
                                                                         15,201
N/A
                                                                        469,711
Disclosure and Record Preparation for Seller Agents (89% of total sales)
Disclosure Form
                                                                      2,515,140
                                                                        209,595
N/A
                                                                      9,494,654
Disclosure and Record Preparation for Offeror Agents (88% of total sales x2)
Disclosure Form
                                                                      4,973,760
                                                                        414,480
N/A
                                                                     18,775,944
Disclosure and Record Preparation for Owner/Lessor Agents (15% of total rentals)
Disclosure Form
                                                                        783,420
                                                                         65,285
N/A
                                                                      2,706,063
Disclosure and Record Preparation for Tenant/Lessee Agents (6% of total rentals)
Disclosure Form
                                                                        313,368
                                                                         26,114
N/A
                                                                        511,834
Recordkeeping for Seller Agents (89%)
N/A
                                                                      2,515,140
                                                                         20,876
N/A
                                                                        945,667
Recordkeeping for Owner/Lessor Agents (15%)
N/A
                                                                        783,420
                                                                          6,502
N/A
                                                                        269,524
                                                                       Subtotal
                                                                     11,917,193
                                                                        775,797
 
                                                                     33,839,152
                                Material Burden
Pamphlets for Sales (15% of total sales x2)
EPA747-K-99-001
N/A
N/A
                                                                        855,148
                                                                       615,706 
Pamphlets for Rentals (2.5% of total rentals)
EPA747-K-99-001
N/A
N/A
                                                                        266,363
                                                                       191,781 
Copied Pages for non-electronic sales with Agents (15% of total sales)
N/A
N/A
N/A
                                                                      7,696,328
                                                                       769,633 
Copied Pages for non-electronic rentals with Agents (2.5% of total rentals)
N/A
N/A
N/A
                                                                      1,065,451
                                                                       106,545 
Filed Pages for non-electronic sales with Agents (15% of total sales)
N/A
N/A
N/A
                                                                        427,574
                                                                         4,276 
Filed Pages for non-electronic rentals with Agents (2.5% of total rentals)
N/A
N/A
N/A
                                                                        133,181
                                                                         1,332 
                                                                       Subtotal
 
                                                                      1,689,273
                                                                    Grand Total
                                                                     11,917,193
                                                                        775,797
 
                                                                     35,528,425
            
            
            
Seller, Offeror, and Tenant Disclosure and Record Preparation, Recordkeeping, and Material 
Burden
The disclosure requirements also apply to sellers, offerors, and tenants undertaking the purchase, sale, or rental of a target housing unit. For these individuals, the start-up burden involves the time and cost required for individuals to learn the disclosure rule's requirements and set up procedures for meeting those requirements. EPA estimates that the paperwork burden related to learning the rule and setting up compliance procedures is one hour. To be conservative in analysis and because suitable data does not exist, each seller is assumed to incur the start-up burden, regardless of potential previous experience with the rule.
The disclosure record preparation burden involves the time and cost for performing the disclosure activities in conjunction with the sale or rental of target housing as specified by the rule. Each instance is estimated to take five minutes for each of the parties. Thus for each sale without an agent the analysis assumes a total burden of twenty minutes (five minutes on each of two sides, for two offers).
The record-keeping provisions of this rule require the seller, or lessor in the case of rentals, to maintain records of the signed disclosure. The record-keeping requirement causes them to spend time in filing the specified documents. In all likelihood, some type of filing system -- either physical or digital -- exists for each party. The incremental filing time that may reasonably be attributed to the disclosure rule itself should be very small, or approximately 0.5 minutes (0.0083 hours) per record.
The materials burden involves the cost of materials required for rule compliance. Sellers/lessors must pay these costs if they are transacting without an agent. Due to a lack of data on the subject, it is conservatively assumed that sellers/lessors without agents do not use electronic transaction/documentation technologies. Thus, material costs include pamphlets and copies provided by sellers or lessors. Again, there is one two-page copy of a signed acknowledgment and disclosure statement per party for every offer or rental contract. Sales transactions also require a one-page lead-based paint inspection contingency clause for each party. Those are not required for rentals. This analysis assumes two offers per sale. Copy costs are assumed to be an average of $0.10 per page, the standard price per page at copy centers for black and white copies (November 2021). For simplicity, all transactions involving an agent on the seller/lessor side are also assumed to have an agent on the buyer/lessee side. 
IC# 2. Seller, Offeror, and Tenant Disclosure and Record Preparation, Recordkeeping, and Material Burden
                        Citation: 40 CFR 745, subpart F
Data Element
Form
Responses
Burden (hours)
Materials
Cost ($)
Start-up Burden to Sellers unlikely to have previous experience with LBP disclosure
N/A
   2,826,000 
                                                                      2,826,000
N/A
                                                                     55,389,600
Disclosure and Record Preparation for Sellers (x2)
Disclosure Form
                                                                      5,652,000
                                                                        471,000
N/A
                                                                      9,231,600
Disclosure and Record Preparation for Offerors (x2)
Disclosure Form
   5,652,000 
                                                                        471,000
N/A
                                                                      9,231,600
Disclosure and Record Preparation for Owners/Lessors
Disclosure Form
                                                                      5,222,800
                                                                        435,233
N/A
                                                                      8,530,573
Disclosure and Record Preparation for Tenants
Disclosure Form
                                                                      5,222,800
                                                                        435,233
N/A
                                                                      8,530,573
Recordkeeping for Sellers
N/A
                                                                      2,826,000
                                                                         23,456
N/A
                                                                        459,734
Recordkeeping for Owner/Lessors
N/A
                                                                      5,222,800
                                                                         43,349
N/A
                                                                        849,645
                                                                       Subtotal
                                                                     32,624,400
                                                                      4,705,272
 
                                                                     92,223,325
                                Material Burden
Pamphlets for Sales, No Agent (11% of total sales x2)
EPA747-K-99-001
N/A
N/A
                                                                        310,860
                                                                       223,819 
Pamphlets for Rentals, No Agent (85% of total rentals)
EPA747-K-99-001
N/A
N/A
                                                                      4,439,380
                                                                     3,196,354 
Copied Pages for Sales without Agents (11% of total sales)
N/A
N/A
N/A
                                                                      3,730,320
                                                                       373,032 
Copied Pages for rentals without Agents (85% of total rentals)
N/A
N/A
N/A
                                                                     17,757,520
                                                                     1,775,752 
                                                                       Subtotal
 
                                                                      5,568,957
                                                                    Grand Total
                                                                     32,624,400
                                                                      4,705,272
 
                                                                     97,792,282

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
 The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.
 If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
 Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There are no operational and/or maintenance costs.
14.  Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
The primary purpose of this information collection activity is the provision of certain information between two parties in a transaction, i.e., third-party disclosure. The agencies are therefore primarily engaged in the following basic activities:
 Public outreach to assist in the understanding of, and compliance with, the rule requirements
 The development and maintenance of an infrastructure for receiving tips and complaints regarding alleged violations of the regulations
 Compliance monitoring and enforcement of the provisions in the regulation

The primary purpose of this information collection activity is the provision of certain information between two parties in a transaction, and constitutes a third-party disclosure under the PRA. The Agency burden and costs associated with this activity are, therefore, limited to the provision of guidance and program oversight or enforcement. As such, there is no need to estimate the related Agency burden and costs under the PRA. There are no costs to the Agency. 

15. Explain the reasons for any program changes or adjustments reported in hour or cost burden. 
The burden from the previously approved ICR was 5,952,344 hours. The total burden requested for this ICR is 5,481,069 hours, or a decrease of 471,275 hours from the previous total burden. The previously approved ICR estimated 56,299,873 responses while the new estimated number of responses is 44,541,593. These differences in the current burden request and the previously approved request are due to adjustments in EPA's calculation of the burden. Several adjustments to the estimates were made, including:

 Revisions to the estimated number of respondents based on updates to data sources such as the American Housing Survey, Bureau of Labor Statistics, and the National Association of Realtors; 
 Revisions to estimated real estate agent use rates due to new, previously unused data in the Rental Housing Finance Survey and American Housing Survey;
 Revisions to estimated material costs based on technological innovation in the real estate industry. Per the 2021 National Association of Realtors' Profile of Real Estate Firms, the use of electronic transaction/documentation technologies is now fairly ubiquitous in the industry (83% of residential agents/brokers); and
 Revisions based on market factors. There was an 18% decrease in new rentals of target properties compared with the previous ICR. There was also a decline in the percent of owner-occupied target housing stock; during the previous ICR it was 50.2 percent, while for this ICR it is 47.9 percent. These changes are expected as older houses and buildings are torn down and as new houses are built and enter the market. Despite the decline in the fraction of the owner-occupied target housing stock, a hotter sales market at the present time has resulted in a slight increase in forecasted total sales of target housing. 

The total combined cost burden of the previously approved ICR was $130,047,705. The total cost burden requested for this ICR is $133,320,708. The difference of $3,273,003 between the current cost burden request and the previously approved requests is due only to adjustments in EPA's estimates of the burden. In addition to the adjustments listed above, the wage rates and material costs were revised to reflect 2021 dollars for this information collection request. In all, wage rates have increased. And while increases to material costs are small on a per-unit basis, once aggregated over millions of responses, they also contribute a noticeable increase in the overall cost of the ICR. 
Due to ongoing volatility in housing sales and rental markets, EPA considered the potential impact on estimated paperwork burden and cost if the sales or rentals were five percent greater than or five percent less than projected in the Supporting Statement. The total burden and cost could not simply be increased or decreased by five percent because not all burden and cost estimates are impacted equally by either sales or rentals. And while the pass-through impacts on sales and rentals of housing are related, there is not a perfect correlation between the trends. 
A five percent change in housing sales results in the target housing changing by 141,000 units, creating a range from 2.685 million housing units to 2.967 million housing units. The Supporting Statement assumed target housing sales were 2.826 million units. Total burden in the Supporting Statement was an estimated 5,481,069 hours at a cost of $133,320,708. The five percent change would result in a change of 222,000 hours and $5.3 million dollars. The total burden would range from 5,259,248 to 5,702,889 hours and the cost from $128,044,944 to $138,596,471. These ranges were calculated assuming no change in the rental estimate presented in the Supporting Statement.
A five percent change in target housing rentals results in a change of 261,000 units, creating a range from 4.96 million units to 5.48 million units. The Supporting Statement assumed new housing rentals were 5.22 million units. Total burden in the Supporting Statement was an estimated 5,481,069 hours at a cost of $133,320,708. The five percent change would result in a change of 50,586 hours and $1.3 million dollars. The total burden would range from 5,430,483 to 5,531,654 hours and the cost from $131,987,209 to $134,654,206. These ranges were calculated assuming no change in the sales estimate presented in the Supporting Statement.

EPA is also revising the seller's and lessor's disclosure of information sample forms to provide greater clarity on how to fill out the forms under 40 CFR 745, Subpart F and 24 CFR 35, Subpart A. EPA appreciates comments regarding these clarifying revisions to the sample forms. 
16. For collections whose results will be published, outline the plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
Not applicable. 
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate. 
This question not applicable to this ICR
18. Explain each exception to the certification statement identified in Item 19 of OMB Form 83-I. 
EPA does not request an exception to the certification of this information collection.
SUPPLEMENTAL INFORMATION
This collection of information is approved by OMB under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. (OMB Control No. 2070-0151). Responses to this collection of information are mandatory (40 CFR 745). An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The public reporting and recordkeeping burden for this collection of information is estimated to be 0.12 hours per response. Send comments on the Agency's need for this information, the accuracy of the provided burden estimates and any suggested methods for minimizing respondent burden to the Regulatory Support Division Director, U.S. Environmental Protection Agency (2821T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the OMB control number in any correspondence. Do not send the completed form to this address."
LIST OF ATTACHMENTS
The attachments listed below can be found in the docket for this ICR or by using the hyperlink that is provided in the list below. The docket for this ICR is accessible electronically through http://www.regulations.gov using Docket ID Number: EPA-HQ-OPPT-2017-0631.
                                       A
42 USC 4852d - Residential Lead-Based Paint Hazard Reduction Act of 1992, Section 1018. Also available online at the U.S. House of Representatives' US Code website.
                                       B
40 CFR part 745, Subpart F - Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards Upon Sale or Lease of Residential Property. Also available online at the National Archives and Records Administration's Electronic CFR Website.
                                       C
24 CFR part 35, Subpart A  - Disclosure of Known Lead-Based Paint and/or Lead-Based Paint Hazards Upon Sale or Lease of Residential Property. Also available online at the National Archives and Records Administration's Electronic CFR Website.
                                       D
Reserved for consultation 
                                       E
Seller's Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards (Sample Form) with edits. Current version is available online at https://www.epa.gov/lead/sellers-disclosure-information-lead-based-paint-andor-lead-based-paint-hazards.
                                       F
Lessor's Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards (Sample Form) with edits. Current version is available at online at https://www.epa.gov/lead/lessors-disclosure-information-lead-based-paint-andor-lead-based-paint-hazards.
                                       G
Lead Hazard Information Pamphlet - "Protect Your Family from Lead
In Your Home" (EPA747-K-12-001). Also available at online at https://www.epa.gov/lead/protect-your-family-lead-your-home-english.
   

