This ICR is
approved for 18 months. OMB does not believe that concerns raised
in the previous terms of clearance have been adequately addressed.
BEFORE beginning preparation of the next renewal of this ICR, EPA
shall orally brief OMB on its progress to date on addressing the
issues outlined below in these terms of clearance. The next renewal
of this ICR shall also include a written update on progress in this
area. The previous terms of clearance noted the temporary
suspension of EPA's consultations on modifying the 7520 Forms in
favor of the National Source Water Contamination Prevention
Strategy, which was designed to focus reporting within the UIC
program on more meaningful measures of program progress. Following
completion of this progress, modification of the 7520 Reporting
Forms was to be completed. EPA was to report to OMB on its progress
in this area during the current renewal of this ICR. A brief report
accompanying the current ICR indicates that the Strategy has now
evolved into two national guidances plus several EPA program
activity measures. These guidances are not described, other than to
indicate that they instruct states and Federal programs on how to
report crucial data that is largely required by regulations with
the same focus. Measures are to focus specifically on meaningful
data element collections to Headquarters that will give a national
picture. Somewhere along the way in this evolving process, the
focus on on ensuring that all data have practical utility and that
burden is reduced to the extent practical and appropriate (both of
which are required by 5 CFR 1320.9) seems to have gotten lost.
There has been no modification to the 7520 Forms, and no other
actions to reduce burden since FY 1996, when EPA reduced the
frequency of some reporting requirements. There appears to have
been no followup on recommended changes by the Federal Reporting
Forms workgroup. While a new Excell Spreadsheet reporting process
has been added to track four new Performance Activity Measures
(PAMs), none of the existing reporting requirements have been
eliminated or reduced. The annual burden of this report has
increased by 22%. While the agency has characterized this increase
as an adjustment, OMB notes that 127,843 hours reflects new
permitting and closure requirements for operators of certain Class
V wells, and has reclassified this burden. During the next year,
prior to beginning the renewal process for this ICR, EPA needs to
review the recommendations of the Federal Reporting Forms workgroup
and determine whether these or other changes to the Forms, with the
specific goal of reducing unnecessary burden, are appropriate._EPA
needs to provide OMB a full report on how it has addressed each of
the specific recommendations of the Federal Reporting Forms
workgroup.
Inventory as of this Action
Requested
Previously Approved
04/30/2007
04/30/2007
10/31/2005
478,189
0
422,287
1,334,054
0
1,091,945
89,415,000
0
31,828,000
This ICR estimates the burden and cost
to owners and operators of Class I-V injection wells to submit
information to demonstrate compliance with Underground Injection
Control regulations. Respondents submit permit applications,
wastewater monitoring data, mechanical integrity testing reports,
and well closure reports. Primacy states submit information to EPA
on permits compliance and enforcement, inspections, and inventory
for all well classes.
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.
Underground Injection Control Program (Renewal)