| Proposed 2022 CGP ICR - Agency Labor Burden |
|
|
|
|
|
|
Federal: |
Labor rate (2017) |
Labor rate (2020) |
|
|
|
|
|
|
|
|
$42.82 |
$45.63 |
|
Hours Per Response |
Number of Annual Reponses |
|
|
|
|
| Activity |
2017 NPDES Program ICR 1 |
Proposed 2022 CGP Incremental Change |
Proposed 2022 CGP Total Hours per Response |
2017 NPDES Program ICR Annual Reponses |
Proposed 2022 CGP No. Annual Responses |
Approximate 2017 NPDES Program Annual Burden (hrs) |
2022 CGP Annual Burden (hrs) |
Approximate 2017 NPDES Programmatic ICR Cost 2 |
2022 CGP Annual Cost |
| NOI review |
1 |
0 |
1 |
4227 |
2,600 |
4227 |
2600 |
$181,000 |
$118,638 |
| NOT review |
0.25 |
0 |
0.25 |
4227 |
2,600 |
1057 |
650 |
$45,250 |
$29,660 |
| Waiver Certification Review |
1 |
0 |
1 |
211 |
130 |
211 |
130 |
$9,035 |
$5,932 |
| SWPPP review |
1 |
0 |
1 |
4227 |
2,600 |
4227 |
2600 |
$181,000 |
$118,638 |
| Standard/Other Reports |
12.0 |
0 |
12 |
203 |
126 |
2436 |
1512 |
$104,310 |
$68,993 |
| Total Agency Activities |
|
|
|
13,095 |
8,056 |
12,158 |
7,492 |
$520,595 |
$341,860 |
|
|
|
|
|
|
Incremental change between 2017 NPDES Programmatic ICR and 2022 CGP |
|
|
|
| Table Endnotes |
|
|
|
|
|
Change in Hours |
-4,666 |
|
|
| 1 NA indicates that the 2017 NPDES Programmatic ICR did not account for this burden item. |
|
|
|
|
|
Change in $ |
-$178,735 |
|
|
| 2 In the 2017 NPDES Programmatic ICR, EPA assumed that the fully loaded cost of employment for a federal employee is $42.82. |
|
|
|
|
|
|
|
|
|
| Proposed 2022 CGP ICR - Respondent Labor Burden |
|
|
|
|
|
|
|
|
|
|
Labor rate (2017) |
Labor rate (2020) |
|
|
|
|
|
|
|
|
|
|
|
$57.42 |
$62.45 |
|
Hours Per Response |
|
Number of Annual Reponses |
Annual Hours Burden |
Annual Cost Burden |
| Activity |
2017 NPDES Program ICR 1 |
Proposed 2022 CGP Incremental Change |
Proposed 2022 CGP Total |
2017 NPDES Program ICR # of Annual Respondents |
Proposed 2022 CGP Number of Respondents |
Number of Occurrences Per Year |
2017 NPDES Program Number of Annual Responses |
Proposed 2022 CGP Number of Annual Responses |
Approximate 2017 NPDES Program Annual Burden (hrs) |
Proposed 2022 CGP Annual Burden (hrs) |
Approximate 2017 NPDES Programmatic ICR Cost 2 |
Proposed 2022 CGP Total Annual Cost |
| Reporting Requirements |
|
| NOI for Large Sites |
|
| With ESA Evaluation and No Consultation |
1.5 |
0.1 |
1.6 |
938 |
577 |
1 |
938 |
577 |
1,408 |
924 |
$80,824 |
$57,674 |
| With ESA Evaluation and Informal Consultation |
6 |
0.1 |
6.1 |
583 |
359 |
1 |
583 |
359 |
3,500 |
2,189 |
$200,983 |
$136,693 |
| With ESA Evaluation and Formal Consultation |
20 |
0.1 |
20.1 |
42 |
26 |
1 |
42 |
26 |
845 |
522 |
$48,495 |
$32,604 |
| NOI - Small Sites with ESA Evaluation and Consultation |
3.7 |
0.1 |
3.8 |
2663 |
1638 |
1 |
2,663 |
1638 |
9,853 |
6,224 |
$565,765 |
$388,714 |
| Appendix E - Historic Property Screening Step 5 (Contact SHPO/THPO) |
Included in NOI burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
| Appendix L - Cationic Treatment Chemicals Notification |
Included in NOI burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
| Appendix C - Small Construction Waiver |
1 |
0 |
1 |
211 |
130 |
1 |
211 |
130 |
211 |
130 |
$12,116 |
$8,119 |
| NOT |
0.5 |
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Comment:
Site stabilization photos
0.25 |
0.75 |
4227 |
2600 |
1 |
4,227 |
2600 |
2,114 |
1,950 |
$121,357 |
$121,778 |
| Standard/Other Reporting |
|
| Planned Facility Changes |
4 |
0 |
4 |
21 |
13 |
1 |
21 |
13 |
84 |
52 |
$4,823 |
$3,247 |
| Anticipated Noncompliance |
5 |
0 |
5 |
4 |
3 |
1 |
4 |
3 |
20 |
15 |
$1,148 |
$937 |
| 24hr reporting - Unanticipated Bypass or Upset (Verbal) |
5 |
0 |
5 |
4 |
3 |
1 |
4 |
3 |
20 |
15 |
$1,148 |
$937 |
| 24hr reporting - Unanticipated Bypass or Upset (Written) |
2 |
0 |
2 |
3 |
2 |
1 |
3 |
2 |
6 |
4 |
$345 |
$250 |
| 24hr reporting - Violation of Maximum Daily Discharge (Verbal) |
3 |
0 |
3 |
85 |
52 |
1 |
85 |
52 |
255 |
156 |
$14,642 |
$9,742 |
| 24hr reporting - Violation of Maximum Daily Discharge (Written) |
2 |
0 |
2 |
42 |
26 |
1 |
42 |
26 |
84 |
52 |
$4,823 |
$3,247 |
| Other Noncompliance reporting |
5 |
0 |
5 |
42 |
26 |
1 |
42 |
26 |
210 |
130 |
$12,058 |
$8,119 |
| Other Info - Permittee Report of Inaccurate Previous Information |
2 |
0 |
2 |
2 |
1 |
1 |
2 |
1 |
4 |
2 |
$230 |
$125 |
| Reporting Subtotal |
|
8,868 |
5,456 |
18,613 |
12,365 |
1,068,758 |
772,184 |
| Recordkeeping Requirements |
|
| Develop New SWPPP - Large Sites |
36.4 |
0 |
36.4 |
1564 |
962 |
1 |
1,564 |
962 |
56,930 |
35,017 |
$3,268,898 |
$2,186,799 |
| Develop New SWPPP - Small Sites |
22.7 |
0 |
22.7 |
2663 |
1638 |
1 |
2,663 |
1638 |
60,450 |
37,183 |
$3,471,045 |
$2,322,053 |
| Update SWPPP |
Included in SWPPP development burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
| Conduct Routine Inspections - Large Sites |
0.5 |
|
0.5 |
1564 |
962 |
26 |
40,664 |
25,012 |
20,332 |
12,506 |
$1,167,463 |
$781,000 |
| Conduct Routine Inspections - Small Sites |
0.25 |
|
0.25 |
2663 |
1638 |
26 |
69,238 |
42,588 |
17,310 |
10,647 |
$993,911 |
$664,905 |
| Dewatering Inspections |
NA |
0.25 |
0.25 |
NA |
2600 |
29 |
NA |
75,400 |
NA |
18,850 |
NA |
$1,177,183 |
| Corrective Action Records |
Included in inspection burden |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
- |
| Recordkeeping Subtotal |
|
114,129 |
145,600 |
155,021 |
114,202 |
$8,901,317 |
$7,131,940 |
| Total Respondent Activities |
|
122,997 |
151,056 |
173,634 |
126,567 |
$9,970,075 |
$7,904,124 |
|
|
|
|
|
|
|
|
|
Incremental change between 2017 NPDES Programmatic ICR and 2022 CGP |
|
|
|
|
|
|
|
|
|
|
|
|
Change in Hours |
-47,067 |
annually |
|
|
|
|
|
|
|
|
|
|
Change in $ |
-$2,065,951 |
annually |
|
| Table Endnotes |
|
|
|
|
|
|
|
|
|
|
|
|
| 1 NA indicates that the 2017 NPDES Programmatic ICR did not account for this burden item. |
|
|
|
|
|
|
|
|
|
|
|
|
| 2 In the 2017 NPDES Program ICR, EPA assumed the average hourly rate in the private sector is $57.42. This was determined based on the U.S. Department of Labor, Bureau of Labor Statistics, Total Compensation for Management, professional, and related; Table 5. Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers, by major occupational group and bargaining unit status, June 2016. |
|
|
|
|
|
|
|
|
|
|
|
|
|
Respondent Percentage |
2017 NPDES Program ICR (0229.23) |
Proposed 2021 CGP ICR |
Notes |
|
|
|
|
|
| # of NOIs (including Idaho) |
|
4227 |
|
https://permitsearch.epa.gov/epermit-search/ui/search |
|
|
|
|
|
| # of NOIs (excluding Idaho) |
|
NA |
2600 |
2017 CGP NOI Data |
|
|
3926 |
start - 2020 NOIs w/o Idaho |
|
| Large Sites (37%) |
37% |
1564 |
962 |
Same assumption made in 2017 NPDES Program ICR |
|
|
2561 |
1,365 |
remove Texas sites (oil & gas) |
| NOI - Large Sites (ESA Criterion A, B) |
60% |
938 |
577 |
Same assumption made in 2017 NPDES Program ICR: 60% of large sites |
|
|
2571 |
10 |
add back Idaho Tribal land |
| NOI - Large Sites (ESA Criterion C, D, E - Informal Eval) |
37% |
583 |
359 |
Same assumption made in 2017 NPDES Program ICR: 37.3% of large sites |
|
|
2571 |
end - estimated 2021 NOIs |
|
| NOI - Large Sites (ESA Criterion F - Formal Eval) |
3% |
42 |
26 |
Same assumption made in 2017 NPDES Program ICR: 2.7% of large sites |
|
|
2600 |
rounded - proposed 2021 NOIs |
|
| Small Sites (63%) |
63% |
2663 |
1638 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| Waivers (5%) |
5% |
211 |
130 |
Same assumption made in 2017 NPDES Program ICR: 5% on top of the total number of NOIs submitted each year |
|
|
|
|
|
| # NOTs |
100% |
4227 |
2600 |
|
|
|
|
|
|
| Planned Facility Changes |
0.50% |
21 |
13 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| Anticipated Noncompliance |
0.10% |
4 |
3 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| 24hr reporting - Unanticipated Bypass or Upset (Verbal) |
0.10% |
4 |
3 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| 24hr reporting - Unanticipated Bypass or Upset (Written) |
0.08% |
3 |
2 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| 24hr reporting - Violation of Maximum Daily Discharge (Verbal) |
2% |
85 |
52 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| 24hr reporting - Violation of Maximum Daily Discharge (Written) |
1% |
42 |
26 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| Other Noncompliance reporting |
1% |
42 |
26 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| Other Info - Permittee Report of Inaccurate Previous Information |
0.05% |
2 |
1 |
Same assumption made in 2017 NPDES Program ICR |
|
|
|
|
|
| Table 1 - Estimated Annual Burden for the Proposed 2022 CGP |
|
|
|
|
|
|
|
| Burden Category |
NPDES Program ICR (2017) Burden for EPA CGP |
Proposed 2022 CGP Incremental Change in Burden |
Proposed 2022 CGP Total Burden |
|
| Labor Burden (hours) |
Labor Cost ($) |
Labor Burden (hours) |
Labor Cost ($) |
Labor Burden (hours) |
Labor Cost ($) |
|
| Total for Respondents |
173,634 |
$9,970,075 |
-47,067 |
-$2,065,951 |
126,567 |
$7,904,124 |
|
| Total for Agency |
12,158 |
$520,595 |
-4,666 |
-$178,735 |
7,492 |
$341,860 |
|
|
|
|
|
|
|
|
|
| Table 3 - Estimated Agency Burden and Cost |
Hours Per Response |
Annual Hours Burden |
Annual Cost Burden |
| Activity |
2017 NPDES Program ICR 1 |
Proposed 2022 CGP Incremental Change |
Proposed 2022 CGP Total Hours per Response |
Approximate 2017 NPDES Program Annual Burden (hrs) |
2022 CGP Annual Burden (hrs) |
Approximate 2017 NPDES Programmatic ICR Cost 2 |
2022 CGP Annual Cost |
| NOI review |
1 |
0 |
1 |
4,227 |
2600 |
$181,000 |
$118,638 |
| NOT review |
0.25 |
0 |
0.25 |
1,057 |
650 |
$45,250 |
$29,660 |
| Waiver Certification Review |
1 |
0 |
1 |
211 |
130 |
$9,035 |
$5,932 |
| SWPPP review |
1 |
0 |
1 |
4,227 |
2600 |
$181,000 |
$118,638 |
| Standard/Other Reports |
12 |
0 |
12 |
2,436 |
1512 |
$104,310 |
$68,993 |
| Total Agency Activities |
|
|
|
12,158 |
7,492 |
$520,595 |
$341,860 |
|
|
|
|
|
|
|
|
| Table 4 - Estimated Respondent Burden and Cost |
|
|
|
|
|
|
|
| Activity |
Hours Per Response |
Annual Hours Burden |
Annual Cost Burden |
| 2017 NPDES Program ICR 1 |
Proposed 2022 CGP Incremental Change |
Proposed 2022 CGP Total |
Approximate 2017 NPDES Program Annual Burden (hrs) |
Proposed 2022 CGP Annual Burden (hrs) |
Approximate 2017 NPDES Programmatic ICR Cost 2 |
Proposed 2022 CGP Total Annual Cost |
| Reporting Requirements |
|
| NOI for Large Sites |
|
| With ESA Evaluation and No Consultation |
1.5 |
0.1 |
1.6 |
1,408 |
924 |
$80,824 |
$57,674 |
| With ESA Evaluation and Informal Consultation |
6 |
0.1 |
6.1 |
3,500 |
2,189 |
$200,983 |
$136,693 |
| With ESA Evaluation and Formal Consultation |
20 |
0.1 |
20.1 |
845 |
522 |
$48,495 |
$32,604 |
| NOI - Small Sites with ESA Evaluation and Consultation |
3.7 |
0.1 |
3.8 |
9,853 |
6,224 |
$565,765 |
$388,714 |
| Appendix E - Historic Property Screening Step 5 (Contact SHPO/THPO) |
Included in NOI burden |
- |
- |
- |
- |
- |
- |
| Appendix L - Cationic Treatment Chemicals Notification |
Included in NOI burden |
- |
- |
- |
- |
- |
- |
| Appendix C - Small Construction Waiver |
1 |
0 |
1 |
211 |
130 |
$12,116 |
$8,119 |
| NOT |
0.5 |
0.25 |
0.75 |
2,114 |
1,950 |
$121,357 |
$121,778 |
| Standard/Other Reporting |
|
| Planned Facility Changes |
4 |
0 |
4 |
84 |
52 |
$4,823 |
$3,247 |
| Anticipated Noncompliance |
5 |
0 |
5 |
20 |
15 |
$1,148 |
$937 |
| 24hr reporting - Unanticipated Bypass or Upset (Verbal) |
5 |
0 |
5 |
20 |
15 |
$1,148 |
$937 |
| 24hr reporting - Unanticipated Bypass or Upset (Written) |
2 |
0 |
2 |
6 |
4 |
$345 |
$250 |
| 24hr reporting - Violation of Maximum Daily Discharge (Verbal) |
3 |
0 |
3 |
255 |
156 |
$14,642 |
$9,742 |
| 24hr reporting - Violation of Maximum Daily Discharge (Written) |
2 |
0 |
2 |
84 |
52 |
$4,823 |
$3,247 |
| Other Noncompliance reporting |
5 |
0 |
5 |
210 |
130 |
$12,058 |
$8,119 |
| Other Info - Permittee Report of Inaccurate Previous Information |
2 |
0 |
2 |
4 |
2 |
$230 |
$125 |
| Reporting Subtotal |
|
18,613 |
12,365 |
1,068,758 |
772,184 |
| Recordkeeping Requirements |
|
| Develop New SWPPP - Large Sites |
36.4 |
0 |
36.4 |
56,930 |
35,017 |
$3,268,898 |
$2,186,799 |
| Develop New SWPPP - Small Sites |
22.7 |
0 |
22.7 |
60,450 |
37,183 |
$3,471,045 |
$2,322,053 |
| Update SWPPP |
Included in SWPPP development burden |
- |
- |
- |
- |
- |
- |
| Conduct Routine Inspections - Large Sites |
0.5 |
0 |
0.5 |
20,332 |
12,506 |
$1,167,463 |
$781,000 |
| Conduct Routine Inspections - Small Sites |
0.25 |
0 |
0.25 |
17,310 |
10,647 |
$993,911 |
$664,905 |
| Dewatering Inspections |
NA |
0.25 |
0.25 |
NA |
18,850 |
NA |
$1,177,183 |
| Corrective Action Records |
Included in inspection burden |
- |
- |
- |
- |
- |
- |
| Recordkeeping Subtotal |
|
155,021 |
114,202 |
$8,901,317 |
$7,131,940 |
| Total Respondent Activities |
|
173,634 |
126,567 |
$9,970,075 |
$7,904,124 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 5 - Bottom line respondent burden hours and cost |
|
|
|
|
|
|
Total |
Incremental Change |
|
|
|
|
|
| Unique Respondents (number) |
2600 |
-1627 |
|
|
|
|
|
| Responses (number) |
151,056 |
28,059 |
|
|
|
|
|
| Burden (hours) |
126,567 |
-47,067 |
|
|
|
|
|
| Costs (labor) |
$7,904,124 |
-$2,065,951 |
|
|
|
|
|
| Costs (capital) |
None |
None |
|
|
|
|
|
| Costs (O&M) |
None |
None |
|
|
|
|
|
| Total costs |
$7,904,124 |
-$2,065,951 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Table 6 - Bottom line Agency burden hours and cost |
|
|
|
|
|
|
Total |
Incremental Change |
|
|
|
|
|
| Responses (number) |
8,056 |
-5,039 |
|
|
|
|
|
| Burden (hours) |
7,492 |
-4,666 |
|
|
|
|
|
| Costs (labor) |
$341,860 |
-$178,735 |
|
|
|
|
|
| Costs (capital) |
None |
None |
|
|
|
|
|
| Costs (O&M) |
None |
None |
|
|
|
|
|
| Total costs |
$341,860 |
-$178,735 |
|
|
|
|
|
|
|
|
|
|
|
|
|
| Respondent Summary Calcs |
Total |
Incremental |
|
|
|
|
|
| Hours per respondent |
48.68 |
28.93 |
|
|
|
|
|
| Hours per response |
0.84 |
-1.68 |
|
|
|
|
|