EPA is to be
commended for its efforts to update and refine its estimate of the
burden associated with this information collection. However, when
significant changes to burden estimates are made that do not
reflect underlying program changes, both the basis and the
quantitative effect of each changed assumption or calculation needs
to be documented. The documentation provided with this ICR did not
allow an itemization of changed assumptions and their effects.
Instead, detailed qualitative documentation of the revised
methodology was provided. Some of the revisions (eg, use of current
information on the number of affected systems) were clearly
appropriate, while others (eg, monetization of contractor burden
previously expressed in hours, elimination of burden that was
previously amortized over 18 years because the actual burden has
already been incurred) were not. Still others may have been
appropriate (eg, reduction of burden associated with sanitary
surveys because initial round of sanitary surveys had been
completed) but it was impossible to tell if the magnitude of burden
reduction associated with the reviision was appropriate or not (eg,
becuase there is still an on-going requirement to conduct sanitary
surveys at least once every 5 years). The revised estimates suggest
that there may be significant areas where burden has previously
been either overstated or understated. When this information
collection is submitted for renewal in 3 years, EPA should reassess
whether it is appropriate to recalculate burden, and if so, provide
the appropriate documentation with the revised estimates. In the
mean time, however, this ICR is being approved with no change in
burden. Since there has been no change in the underlying program
requirements, this is an appropriate way to account for the burden
until a reassessment, including adequate documentation of any
changes, has been completed.
Inventory as of this Action
Requested
Previously Approved
09/30/2001
09/30/2001
09/30/1998
4,157,056
0
17,621,954
12,386,280
0
12,386,280
204,700,000
0
0
This ICR contains recordkeeping and
reporting requirements that are mandatory for compliance with 40
CFR parts 141 and 142. Sections 1401 and 1412 of the Safe Drinking
Water Act (SDWA), as amended, require EPA to establish National
Primary Drinking Water Regulations (NPDWRs) for contaminants that
may have any adverse human health effect. The Act further requires
EPA to monitor and enforce these regulations to ensure a supply of
drinking water, which dependably complies with the maximum
contaminant levels (MCLs) set forth in 40 CFR part 141, subpart
B.
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.
Public Water Systems Supervision Program