ICR Attachment H: Consultation Response from Bedoukian Research, Inc.

Consultation Questions
(1) Publicly Available Data
(1) Is the data that the Agency seeks available from any public source, or already
collected by another office at EPA or by another agency?
No
(2) If yes, where can you find the data?
-(2) Frequency of Collection
Can the Agency collect the information less frequently and still produce the same
outcome?
I do not believe so
(3) Clarity of Instructions
(1) The ICR is intended to require that respondents provide certain data so that the
Agency can utilize them.
(1) Based on the instructions (regulations, PR Notices, etc.), is it clear
what you are required to do and how to submit such data?
Yes
(2) If not, what suggestions do you have to clarify the instructions?
(2) Do you understand that you are required to maintain records?
Yes
(3) Considering that there is no required submission format, is it difficult to
submit information in ways that are clear, logical and easy to complete?
No, it is clear what is needed
(4) Regarding the any [specific program] forms, do you use them?
Are they clear, logical, and easy to complete?
n/a
(4) Electronic Reporting and Record keeping
The Government Paperwork Elimination Act requires agencies make available to the
public electronic reporting alternatives to paper-based submissions by 2003, unless there
is a strong reason for not doing so. One such reason is that, at the present time, the
Agency is unable to ensure the security of CBI that might be transmitted over the
Internet.
(1) What do you think about electronic alternatives to paper-based records and
data submissions? Current electronic reporting alternatives include the use of
“web forms”/XML based submissions via the Agency’s Internet site and magnetic
media-based submissions, e.g., diskette, CD-ROM, etc. Would you be interested
in pursuing electronic reporting?
Are you keeping your records electronically? If yes, in what format?
For our business, switching to electronic reporting may have added
costs based on initial set-up of such a system and requisite training in
its use/procedures
(2) Although the Agency does not offer an electronic reporting option because of
CBI-related security concerns at this time
(1) Would you be more inclined to submit CBI on diskette than on paper?

Not a concern
(3) What benefits would electronic submission bring you in terms of burden
reduction or greater efficiency in compiling the information?
Unsure of any benefit
(5) Burden and Costs
(1) Are the labor rates accurate?
Accurate
(2) The Agency assumes there is no capital cost associated with this activity. Is
that correct?
Accurate
(3) Bearing in mind that the burden and cost estimates include only burden hours
and costs associated with the paperwork involved with this ICR, e.g., the ICR
does not include estimated burden hours and costs for conducting studies, are the
estimated burden hours and labor rates accurate? If you provide burden and cost
estimates that are substantially different from EPA’s, please provide an
explanation of how you arrived at your estimates.
Accurate
(4) Are there other costs that should be accounted for that may have been missed?
Not that I am aware of