This ICR for the
additional burden from the proposed Coliform rule is disapproved
pending the consideration and evaluation of the following items.
First, the incremantal burden (and cost) imposed on non-community
and community water systems serving les than 500 people and using
groundwater is potentially severe. The one million estimated
incremental burden hours (and $100 M) of taking five coliform
samples per month rather than one a month is contrary to the
Paperwork Reduction Act's requirements (5CFR 1320.6(h)) to develop
separate and simplified requirements for small businesses. Also the
incremental value of this information has not been demonstrated. As
a result, EPA should consider adopting as minimum requirements the
alternative presented in the proposal for states to reduce
monitoring to systems serving less than 3,300 people. If states
believe addition monitoring is warranted then they always can
increase it. Additional analysis of the incremental burden and
value of this monitoring should be completed. Second, the costs to
the Federal Government and States (item 12) cannot be insignificant
when the amount of coliform samples being processed could double or
quadruple. Please reevaluate the assumptions and include new cost
and burden estimates as appropriate. Finally, the need to retain
records of reduced monitoring authoriza for ten years is not
adequately justified and should be years to be consistant with
5CFR1320.6(f).Earlier remarks s
Inventory as of this Action
Requested
Previously Approved
09/30/1990
09/30/1990
09/30/1990
214,445
0
214,445
1,403,210
0
1,403,210
0
0
0
UNDER THE PROPOSED REGULATION, STATE
AND LOCAL RESPONDENTS WILL COLLECT AND REPORT INFORMATION ON A
MONTHLY, QUARTERLY AND ANNUAL BASIS. THE EPA, THROUGH THE FEDERAL
REPORTING DATA SYSTEM, USES THE INFORMATION TO ENSURE COMPLIANCE
WITH THE RULE AND TO PROTECT PUBLIC HEALTH.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.