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. Some
qualitative explanation of the reasons for the change were
provided, but this explanation did not account for a significant
fraction of the total change. The revised estimate suggests that
there may be significant areas where burden has previously been
eitehr 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 all changes in the underlying program requirements that
affect burden (eg, EPA's 1996 Guidance on Performance Based
Monitoring Reductions) had already been accounted for in the
existing burden estimate, it is appropriate to carry this estimate
forward unchanged until a reassessment, including appropriate
documentation of any changes, has been completed.
Inventory as of this Action
Requested
Previously Approved
09/30/2001
09/30/2001
09/30/1998
611,205
0
1,011,592
13,333,396
0
13,333,396
0
0
0
This ICR estimates the current
monitoring, reporting, recordkeeping burden and cost associated
with submitting and reviewing Discharge Monitoring Reports (DMRs),
sewage sludge monitoring reports, and other monitoring reports
under the Environmental Protection Agency's (EPA) NPDES Program.
The NPDES program regulations, codified at 40 CFR parts 122 through
125, require permitted municipal and non-municipal point source
discharges to collect, analyze, and submit data on their wastewater
discharges.
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.