Supporting Statement

INFORMATION COLLECTION REQUEST

for

ASSESSMENT OF COMPLIANCE ASSISTANCE PROJECTS

EPA

The United States Environmental Protection Agency

Table of Contents

Title Page

1. Identification of the Information Collection 1

1(a) Title of the Information Collection 1

1(b) Short Characterization/Abstract 1

2. Need for and Use of the Collection 3

2(a) Need/Authority for the Collection 3

2(b) Practical Utility/Users of the Data 3

3. Non-duplication, Consultations, and Other Collection Criteria 4

3(a) Non-duplication 4

3(b) Public Notice Required Prior to ICR Submission to OMB 4

3(c) Consultations 4

3(d) Effects of Less Frequent Collection 4

3(e) General Guidelines 4

3(f) Confidentiality 5

3(g) Sensitive Questions 5

4. The Respondents and The Information Requested 5

4(a) Respondents/SIC Codes 5

4(b) Information Requested 5

(I) Data items, including record keeping requirements 5

(II) Respondent Activities 5

5. The Information Collected--Agency Activities, Collection Methodology,

and Information Management 5

5(a) Agency Activities 6

5(b) Collection Methodology and Management 6

5(c) Small Entity Flexibility 7

5(d) Collection Schedule 7

6. Estimating the Burden and Cost of the Collection 7

6(a) Estimating Respondent Burden 7

(I) Number of Respondents 8

(II) Burden Per Survey Type 9

6(b) Estimating Respondent Costs 10

(I) Estimating Labor Costs 10

(II) Estimating Capital and Operations and Maintenance Costs 11

(III) Capital/Start-up vs. Operations and Maintenance (O&M) Costs 11

(IV) Annualizing Capital Costs 11

6(c) Estimating Agency Burden and Cost 11

6(d) Estimating the Respondent Universe and Total Burden and Costs 12

6(e) Bottom Line Burden Hours and Cost Tables 12

(I) Respondent Tally 12

(II) The Agency Tally 12

(III) Burden Statement 12

List of Tables

Table 5-1 Follow-up Methods Allowed by Assistance Activity

Table 6-1 Three-Year Compliance Assistance Assessment Activities

Table 6-2 Three-Year Burden Table by Evaluation Survey Type

Table 6-3 Three-Year Agency Burden/Cost for Implementing Surveys

Table 6-4 Total Annual Estimated Respondent Burden and Cost Summary

Table 6-5 Total Annual Estimated Agency Burden and Cost Summary

U.S. ENVIRONMENTAL PROTECTION AGENCY

ASSESSMENT OF COMPLIANCE ASSISTANCE PROJECTS

1. Identification of the Information Collection

1(a) Title of the Information Collection: Assessment of Compliance Assistance Projects, EPA ICR Number 1860.03, OMB Control Number 2020-0015.

1(b) Short Characterization/Abstract

The Environmental Protection Agency (EPA) is seeking re-approval for a three year generic clearance from the Office of Management and Budget (OMB) to determine how well EPA compliance assistance tools and services meet customers needs and to assess the effectiveness of its compliance assistance activities. As with the former ICR, this will be a voluntary collection of information to gauge customer satisfaction with the compliance assistance projects, measure any resulting changes in knowledge or behavior, and evaluate environmental and human health impacts. EPA proposes to use assessment surveys to obtain feedback on the compliance assistance documents, onsite visits, telephone assistance, Web sites, and compliance assistance seminars and workshops delivered by Headquarters and Regional compliance assistance programs to the regulated community. This feedback will help EPA improve the quality and delivery of compliance assistance tools and services.

The affected audience for this ICR includes members of the regulated community and, to a lesser extent, state and local regulators and compliance assistance providers that receive EPA compliance assistance tools or services. The large majority of EPA compliance assistance tools are targeted to small businesses (e.g., those employing fewer than 100 employees) that frequently lack environmental officers and programs, and traditionally have little familiarity with environmental regulations and procedures.

All assessments undertaken under this ICR will follow stringent procedures to ensure that data are collected and used properly and efficiently. This ICR will only provide anecdotal data for the purpose of informing EPA of the effectiveness of compliance assistance tools, and customer satisfaction with those tools. The information collection is voluntary, and will be limited to non-sensitive data concerning the quality of compliance assistance activities. No industry sector data will be used to make broad generalizations or policy decisions. Questions indicating behavior change will be limited to the six below:

1. What regulatory actions do you intend to take (did take) as a result of the <compliance assistance activity>?

a. File a notification

b. Obtain a permit or certification

c. Provide data to EPA, state, or local regulator

d. Submit reports to EPA, state, or local regulator

e. Comply with an environmental requirement

f. No regulatory actions will be taken

g. Other, specify

2. What process changes at your facility do you intend to make (did make) as a result of the <compliance assistance activity>?

a. Change the storage or handling of a waste or emission

b. Change a process or practice

c. Purchase new process equipment

d. Implement material or waste recycling system

e. Install pollution control equipment (e.g., scrubbers, control technique)

f. Install a waste treatment system

g. Switch to renewable energy

h. No process changes will be taken

i. Other, specify

3. What management changes at your facility do you intend to take (did take) as a result of the <compliance assistance activity>?

a. Conduct a self audit

b. Institute an environmental management policy, system or procedure

c. Institute training or other communication to improve awareness and/or practices

d. Identify pollution prevention opportunity

e. No management action will be taken

f. Other, specify

4. Who (if anyone) have you contacted (will contact) for further assistance as a result of the <compliance assistance activity>?

a. A vendor

b. A state or local regulatory agency

c. A non-regulatory local source for additional compliance assistance

d. No contacts will be made

e. Other, specify

5. Please identify any reductions or the elimination of a pollutant(s) that resulted, or will result, from the actions taken as a result of the CA activity.

__ reduced or eliminated waste (solid/hazardous)

__ reduced or eliminated air emissions (air, fugitive)

__ reduced or eliminated pollutant emissions (wastewater)

__ other, specify ____________

__ none

__ don’t know.

6. Have you realized, or expect to realize, a cost savings from actions taken as a result of the <compliance assistance activity.>

__ Yes

__ No

This process does not involve fact-finding for the purposes of regulatory development or enforcement.

EPA will provide OMB with an annual summary of surveys conducted in accordance with OMB’s Resource Manual for Customer Surveys (dated October 1993). EPA estimates that a combination of surveys (mail, Internet, telephone, and onsite) will generate voluntary responses from approximately 77,028 respondents for an estimated burden of 11,868 hours over a three year period. On an annual basis, EPA estimates feedback from approximately 25,676 respondents for an estimated annual burden of 3,956 hours.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

To help fulfill the broad mandate of protecting human health and the environment, EPA provides compliance assistance activities and services to businesses and other regulated entities. Compliance assistance activities provide the regulated community with the specific information necessary to achieve and maintain regulatory compliance.

EPA believes that evaluating compliance assistance activities is compulsory to ensure customer needs are met, as well as to maintain efficient and effective assistance. Understanding our customers’ ability to use our tools and services in their practical applications will assist the Agency in planning its future compliance assistance efforts.

2(b) Practical Utility/Uses of the Data

EPA believes customer feedback is a requirement of a well managed program. The feedback will help the Agency: design compliance tools and services that continuously improve to meet the needs of our customers; increase the effectiveness of compliance assistance activities; and improve the access and delivery of tools and services.

This ICR only supports “anecdotal” assessments which describe accomplishments, yet make no broad generalizations or claims. The ICR will not be used to make generalizations to overall populations (e.g., industry sectors or geographic regions), and therefore does not require the development of statistical methodologies or sampling designs. The ICR does not involve “fact-finding” for the purposes of regulatory development or enforcement, and the information obtained will not be used to make major policy decisions. Additionally, no sensitive data will be collected under this ICR.

After the compliance assistance programs collect data under each survey, the responses will be reported to OC as specified in section 5(b). Following analysis, the synthesized findings will be shared with the appropriate Agency offices, which may use them to:

• identify methods to improve the effectiveness and efficiency of compliance assistance tools and delivery; and

• develop new compliance assistance tools to address identified problem areas.

EPA anticipates that the results of compliance assistance assessments will lead to improved compliance assistance services. Ultimately, these changes could result in improved compliance with environmental regulations.

3. Non-duplication, Consultations, and Other Collection Criteria

3(a) Non-duplication

EPA will evaluate customer satisfaction with compliance assistance services, and in some cases, the effectiveness (including improved understanding, behavioral change, and environmental results) of the compliance assistance services. The information collected through this ICR will not overlap with other EPA surveys.

3(b) Public Notice Required Prior to ICR Submission to OMB

On August 18, 2004, EPA published a Federal Register Notice (66 FR 45982) announcing its intent to submit an ICR to OMB regarding the assessment of compliance assistance projects. EPA did not receive any comments on this ICR.

3(c) Consultations

EPA has received feedback on this information collection from key stakeholders including trade associations representing the businesses expected to respond to surveys, and EPA’s Compliance Assistance Advisory Committee (a workgroup of industry, government, and community stakeholders created under the Federal Advisory Committee Act to obtain feedback on EPA’s compliance assistance activities).

To project survey needs through the year 2007, EPA also consulted with regional compliance assistance programs within the Agency, staff within the Office of Enforcement and Compliance Assurance (OECA), and Office of Compliance (OC) staff responsible for developing the Agency’s annual Compliance Assistance Plan. This feedback, along with OC’s experience with surveys conducted over the past three years under ICR 1860.02 and the projections of CA activities planned for 2005 and beyond, were used to develop the estimated number of activities and the estimates of respondent and Agency burden described in Section 6.

3(d) Effects of Less Frequent Data Collection

The surveys conducted under this ICR will be one-time data-collection efforts; therefore this information collection could not be conducted less frequently.

3(e) General Guidelines

This ICR complies with OMB’s general guidelines for the collection of information.

3(f) Confidentiality

No confidential data will be collected.

3(g) Sensitive Questions

No sensitive data will be collected.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

For this ICR, the term “respondents” refers to individuals who provide feedback on EPA’s compliance assistance tools and activities. Potential respondents include small businesses, state and local regulators, and compliance assistance providers. Small businesses are traditionally the primary recipients and users of compliance assistance tools and services, and will make up the bulk of respondents.

4(b) Information Requested

Information requested by surveys developed under this ICR will be used to assess compliance assistance activities. Each survey will request specific information related to the compliance assistance activity being evaluated. EPA delivers compliance assistance in several forms to a wide range of audiences. Section 1(b) identifies the general types of questions that will be asked in the surveys. Surveys developed under this ICR will be limited to those types of questions.

5. The Information Collected --Agency Activities, Collection Methodology, and Information Management

Table 5-1 summarizes the methods OC will allow for different types of assistance under this ICR.

Table 5-1 Follow-up Methods Allowed by Assistance Activity

CA Activity	Preferred Follow-up Method	Conditions
On-Site Visits	1. On-site revisit; or 2. Phone call survey	1. Must do at least 25% revisits; or 2. Call 100% of sites
Workshop/Training	1. Pre/post tests; and 2a. Phone survey if <50 attendees; or 2b. Mail survey if >50 attendees	1. 100% workshop participants; and 2a. Phone all participants; or 2b. Use the Tailored Design Method (TDM)
Compliance Guides Distributed through Workshops	1. Phone survey if <50; or 2. Mail survey if >50	No Mail Back Cards 1. Phone all participants; or 2. Use the TDM
Compliance Guides Distributed via Mail	Mail survey	No Mail Back Cards 1. Maintain a list of mailed recipients and use the TDM
Compliance Guides Distributed via the Internet	No followup for outcome measurement; count # of guides downloaded only	No Mail Back Cards
Hotlines	Periodic user survey	Must use phone surveys
Compliance Assistance Centers - Internet	On-line survey	Secured site that would eliminate the ability to take the survey multiple times

5(a) Agency Activities. Agency activities associated with the collection of information may include:

• Developing individual surveys;

• Disseminating questionnaires to respondents;

• Gathering information from respondents;

• Filtering/screening response data obtained through Internet feedback screens;

• Reviewing data;

• Preparing findings;

• Storing and maintaining results; and

• Adjusting compliance assistance activities based on assessment results.

5(b) Collection Methodology and Information Management.

An internal review and oversight process, independent of the originating program office, has been established for all assessment activities conducted under this ICR. Prior to initiating an assessment, each program will provide to OC a memo with the following information:

• Title, identification of originator, and appropriate contact information;

• Summary and description of the intended purpose as it relates to OECA’s mission;

• Delivery method (e.g., mail/email/fax, phone), collection schedule, and follow up plans;

• Planned use of information collected; and

• Number of respondents, and burden in costs and hours to respondents and the Agency.

OC will submit surveys to OMB for a 10-business day expedited review and determination, and for a regular 30 day review. A summary including title, sponsoring office, number of respondents, and estimated burden hours and costs will be attached. Following the completion of assessment activities, all offices will provide copies of their approved assessment tool, analytical reports, and a description of any follow up actions to OC.

The Agency will maximize the efficiency of information collection by making every effort to improve response rates to assessment activities. In order to use this ICR, staff conducting compliance assistance activities must notify their audiences at the time of compliance assistance delivery that EPA plans to follow up with them to assess the quality of the assistance. At this time staff will indicate the assessment method to be used (e.g., phone, letter, email).

To improve response rates for mailed and phone surveys, OC recommends using the “Tailored Design Method.”¹ Users of the “Tailored Design Method” have achieved greater than 90 percent response rates for their surveys. The method includes the following steps:

• Send advance notice;

• Send the survey;

• Thank everyone;

• Send replacement survey to non-responders; and

• Try a different mode for remaining non-responders.

5(c) Small Entity Flexibility.

Not applicable.

5(d) Collection Schedule.

This will be dependent upon the needs of each originator of a survey. Schedules for customer surveys will be documented by the survey sponsors.

6. Estimating the Burden and the Cost of the Collection

6(a) Estimating Respondent Burden

Respondent activities are expected to include only a few steps: reviewing instructions, responding to surveys, and sending (via mail or e-mail) responses (for those surveys not conducted over the phone or in person). To minimize the respondent burden, EPA will use simple, clear survey designs that are easy to respond to and are of limited scope. There will be no requirement for respondents to develop data gathering systems, train personnel, or maintain records.

Tables 6-1 and 6-2, presented in Section 6(b) below, present the respondent burden estimates. These estimates are based on OC’s experience with actual surveys conducted under generic ICR 1860.02, OC’s projected compliance assistance activities, and the applicable compliance assistance activities included in EPA’s annual Compliance Assistance Plan. The burden is expected to be relatively consistent over the three years of this ICR. To estimate the burden, OC first estimated the number of respondents, then estimated the burden per survey type.

I Number of Respondents

The number of respondents for each type of compliance activity is presented below.

Workshops

OC anticipates that approximately 100 workshops will evaluated under this ICR over the three-year period. Of these 100 workshops, OC estimates that:

∙ 10 will have 40 attendees. EPA will evaluate these workshops with phone surveys to all of the attendees, with an 80% phone survey response rate, giving 320 respondents.

∙ 10 will have 60 attendees. EPA will evaluate these workshops with mail surveys to all of the attendees, with an 80% mail survey response rate, giving 480 respondents.

∙ 80 will have 50 attendees. EPA will evaluate these workshops using pre- and post-tests given to all workshop attendees, giving 4,000 respondents.

Compliance Guides

OC anticipates that 150 compliance guides will be evaluated under this ICR over the three-year period. Of these guides, OC estimates that:

∙ 5 will be distributed at workshops with 40 attendees. EPA will evaluate these guides with phone surveys to all recipients, with an 80% phone survey response rate, giving 160 respondents.

∙ 75 will be distributed by mail to 1,000 recipients each. EPA will evaluate these guides with mail surveys to the recipients, with an 80% mail survey response rate, giving 60,000 respondents.

∙ 70 will be distributed by the Internet to an undetermined number of recipients. EPA will evaluate these guides through output measures only (e.g., the number of guides downloaded). There will be no follow-up with recipients.

Hotlines

OC anticipates that six compliance assistance hotlines will be evaluated under this ICR over the three-year period. EPA will evaluate these hotlines through phone surveys of 50 callers to each hotline, with a 100% response rate, giving 300 respondents.

Onsite Visits

OC anticipates that 130 onsite visits will be evaluated under this ICR over the three-year period. Of these visits, OC estimates that:

∙ EPA will evaluate 65 of these visits by revisiting 25% of the visited facilities, giving 16 respondents.

∙ EPA will evaluate 65 of these visits through phone surveys to all of the visited facilities, with an 80% response rate, giving 52 respondents.

Internet Web Sites

OC anticipates that 60 compliance assistance Web site evaluations will be conducted through on-line surveys. OC estimates that 200 users will respond to each on-line survey, giving 12,000 respondents.

II Burden Per Survey Type

As discussed above and shown on Table 6-1, OC estimates that there will be 25,776 respondents annually to the compliance assistance evaluation surveys. OC estimates the following burden per respondent, for each evaluation survey type:

∙ Phone survey: 10 minutes/respondent;

∙ Mail survey: 10 minutes/respondent;

∙ Pre-/post-test: 10 minutes/respondent;

∙ Onsite revisit: 120 minutes/respondent; and

∙ Online survey: 5 minutes/respondent.

Table 6-1 presents the total estimated respondent burden for each compliance assistance activity, broken down by evaluation survey type. Table 6-2 presents the total estimated respondent burden by evaluation survey type.

6(b) Estimating Respondent Costs

In order to minimize the respondent burden, survey designs will be simple, convenient, easy to respond to, and clear in content and purpose. Surveys will be of limited scope and require only a short time to complete.

I Labor Costs

OC estimated labor costs by multiplying the estimated respondent burden (in hours) by estimated labor rates. OC obtained wage estimates from the Bureau of Labor Statistics (May 2001, Employer Costs for Employment Compensation, Table 10: White Collar, Professional specialty and technical). The hourly labor rates are estimated at $32.68 plus a 110%overhead for a total hourly rate of $68.63. This rate applies to both the regulated community and state and local technical assistance staff.

Tables 6-1 and 6-2 present the respondent costs according to compliance assistance activity and evaluation survey type, respectively. Each table displays the annual and three-year total burden estimates for respondents in hours and dollars. The average burden per response is a little over nine minutes (11,918 total hours divided by 77,328 respondents, converted to minutes). The average cost per response is less than $11.

Table 6.1. Three-Year Compliance Assistance Assessment Activities - FY2002-FY2005

Assistance Activity (number of events )	Type of Survey (number of events )	Estimated # of Respondents	Estimated survey time in minutes	TOTAL BURDEN (HOURS)	TOTAL COST
Workshops (100)	Phone (10)	320	10	53	$3,651
	Mail (10)	480	10	80	$5,490
	Pre/post-test (80)	4,000	10	667	$45,680
Compliance Guides (150)	Phone (5)	160	10	27	$1,853
	Mail (75)	60,000	10	10,000	$686,300
	Internet (70)	0 (no follow up)	0	0	$0
Assistance Hotlines (6)	Phone (6)	300	10	50	$3,432
Onsite Visits (130)	Onsite Revisit (65)	16	120	32	$2,196
	Phone (65)	52	10	9	$618
Internet Web sites (60)	Online (60)	12,000	5	1,000	$68,630
Totals over 3 years		77,328		11,918	$817,850
ANNUAL TOTALS		25,776		3,973	$272,617

Table 6-2 Three-Year Burden Table by Evaluation Survey Type

Evaluation Survey Type	Estimated # of Respondents	Estimated survey time in minutes	TOTAL BURDEN (HOURS)	TOTAL COST
Phone	832	10	139	$9,554
Mail	60,480	10	10,080	$691,790
Pre/post-test	4,000	10	667	$45,680
Onsite	16	20	32	$2,196
Online	12,000	5	1,000	$68,630
3-Year Total	77,328		11,918	$817,850
Annual Total	25,776		3,973	$272,617

II Capital and Operations and Maintenance Costs

Activities supported by this ICR do not involve the purchase of monitoring or reporting equipment.

III Capital/Start-up vs. Operating and Maintenance (O & M) Costs

Activities supported by this ICR do not involve the purchase of monitoring or reporting equipment.

IV Annualizing Capital Costs

Not applicable.

6(c) Estimating Agency Burden and Cost.

Tables 6-3 provides the annual estimates for EPA burden associated with developing and disseminating evaluation surveys and analyzing the results. The number of events is based on the total number of surveys conducted, as indicated in Table 6-1. Wage estimates are based on the 2001 GS-13-01 annual salary of $63,211 or $ 30.29/hr. With a 30% overhead the hourly rate is $39.38/hr. This estimate assumes that every survey is independently created. EPA expects that, in practice, many offices will customize existing surveys to suit their goals, thereby reducing the Agency burden.

Table 6-3 Three-Year Agency Burden/Cost for Implementing Surveys

Activities	Hours	No. of Events	TOTAL BURDEN (HOURS)	TOTAL COST
Survey Development	1.5	446	669	$26,345
OC Review of Survey	0.25	446	112	$4,411
Administration of survey	0.5	446	223	$8,782
Compilation of survey results	1	446	446	$17,563
Analysis of Survey Results	1	446	446	$17,563
3-Year Total		446	1896	$74,664
Annual Total		149	632	$24,888

6(d) Estimating the Respondent Universe and Total Burden and Costs Burden

EPA estimates that over the three year life of the umbrella clearance, 77,328 respondents will voluntarily respond to compliance assistance assessment programs conducted under this ICR for a total burden of 11,918 hours and a total cost of $817,850.

6(e) Bottom Line Burden Hours and Cost Tables

I Respondent Tally

Table 6-4 Total Annual Estimated Respondent Burden and Cost Summary

	No. Of Respondents	No. Of Events	ANNUAL BURDEN HOURS	ANNUAL COST
TOTAL	25,776	149	3,973	$272,617

II Agency Tally

Table 6-5 Total Annual Estimated Agency Burden and Cost Summary

	No. of Events	ANNUAL BURDEN HOURS	ANNUAL COST
TOTAL	149	632	$24,888

III Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 9 minutes per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. OECA-2004-0028, which is available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Enforcement and Compliance Docket and Information Center is (202) 566-1752. An electronic version of the public docket is available through EPA Dockets (EDOCKET) at http://www.epa.gov/edocket. Use EDOCKET to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. Once in the system, select “search,” then key in the docket ID number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No. (OECA-2004-0028) and OMB control number (2020-0015) in any correspondence.

1See, Dillman, Don A., “Mail and Internet Surveys: The Tailored Design Method”