Justification to reinstate to pre-Burden Reduction Rule

1704.10 Omnibus Change 03-24-09.doc

Toxic Chemical Release Reporting, Alternate Threshold for Low Annual Reportable Amounts (Form A) (Renewal)

Justification to reinstate to pre-Burden Reduction Rule

OMB: 2025-0010

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Estimate of Burden Changes due to the Toxics Release Inventory Form A Eligibility Revisions Implementing the 2009 Omnibus Appropriations Act




Form R's



Burden:

Responses

Hours

Previous1

67,707

3,218,179

New2

81,382

3,677,162

Difference between Previous and New

 

 

Change due to New Statute3

13,675

458,983

Change due to Agency Discretion

 

 

Change due to Agency Adjustment

 

 

Change due to Potential Violation of PRA

 

 

NOTES:

1Previous is defined as the "New" estimate of hours and responses from the NOA dated 3/23/09.

2Sum of Previous (above) and Change due to New Statute responses and hours.

3 Number of forms that will lose Form A eligibility and must be reported on Form Rs minus the Form Rs that may revert to Form A eligibility. Estimate of hours reflects the increase in Form R reporting burden. Note that these estimates of responses are calculated using the RY 2007 PDR. Burden hours are calculated based on the Form R ICR dated December 10, 2007.







Form A



Burden:

Responses

Hours

Previous1

10,235

515,901

New2

4,019

197,483

Difference between Previous and New

 

 

Change due to New Statute3

-6216

-318,418

Change due to Agency Discretion

 

 

Change due to Agency Adjustment

 

 

Change due to Potential Violation of PRA

 

 

NOTES:

1Previous is defined as the universe of Form As and associated reporting burden from the NOA dated 3/2/08 for the Form A ICR. Note that these estimates were generated using the RY2005 PDR.

2Sum of Previous (above) and Change due to New Statute responses and hours.

3 Number of Forms that will lose Form A eligibility and must be filed as Form Rs minus the Form Rs that may revert to Form A eligibility. Since Form As on average address 2.2 chemicals, the number of Form A "Responses" is the number estimated for Form Rs, above, divided by 2.2, and is listed as a loss instead of a gain. Note that these estimates of responses are calculated using the RY 2007 PDR. Burden hours are calculated based on the Form A ICR approved by OMB in the NOA dated 3/2/08.




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File TitleEstimate of Burden Changes due to theT oxics Release Inventory Form A Eligibility Revisions Implementing the 2009 Omnibus Approp
Authorctsuser
Last Modified Byctsuser
File Modified2009-03-24
File Created2009-03-24

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