This ICR for the
additional burden from the proposed Filtration rule i disapproved
pending the consideration and evaluation of the following. First, a
disproportionate amount of the burden and cost falls on small
systems (<3,300 people)--approximately 62% of cost ($16.3M) and
burden (718,643). It is unclear from the ICR, especially the
discussion of small businesses, whether this is justified, but
appears to contradict the PRA requirement (5CFR 1320.6(h)) to
simplify requirements for smal businesses. Separate analysis of per
system burden and per household cost should be done to evaluate
need. Second, the need to retain records of coliform and turbidity
sampling for five years and other analytical and evaluation results
for at least ten years is not adequately justified, especially the
differential treatment and is inconsistant with 5CFR 1320.6(f).
Unless necessary, these requirement should be changed to three
years. Third, the burden to the estimated 463 systems obtaining
exceptions seems excessive when the purpose is t reduce burden and
cost. For example, the very small systems' househol costs could
still increase by over $250. Fourth, the need to have monthly PWS
and quarterly State reporting is not justified (item #7) a the
monthly reporting violates the provisions of 5CFR 1320.6(a). Serio
consideration should be given to reporting based on compliance or
severity of non-compliance. Finally, the cost to Federal government
should be estimated and not declared insignificant.Earlier remarks
app
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.