SUPPORTING STATEMENT FOR EPA’s
INFORMATION COLLECTION REQUEST (ICR)
UNDER TITLE I OF THE MARINE PROTECTION, RESEARCH, AND
SANCTUARIES ACT
Prepared by
Environmental Protection Agency
Oceans, Wetlands and Communities Division
Washington, D.C.
Final October 26, 2022
SUPPORTING STATEMENT FOR THE COLLECTION OF INFORMATION
UNDER TITLE I OF THE MARINE PROTECTION, RESEARCH, AND
SANCTUARIES ACT
EPA ICR No. 0824.08
ICR OMB Control No. 2040-0008
ICR Title: Implementation of Title I of the Marine Protection, Research, and Sanctuaries Act
This document supports EPA’s compliance with requirements of the Paperwork Reduction Act for the Marine Protection, Research, and Sanctuaries Act (MPRSA). The purposes of the Paperwork Reduction Act of 1980 (PRA) (P. L. 96-511) and implementing regulations (44 U.S.C. Chapter 35) are to: 1) minimize the federal paperwork burden for small businesses, state and local governments, and other individuals; 2) minimize the Federal government's cost of collecting, maintaining, using, and disseminating information; and 3) maximize the usefulness of information collected by federal agencies.
This Information Collection Request (ICR), “Implementation of Title I of the Marine Protection, Research, and Sanctuaries Act,” is made by the Oceans, Wetlands, and Communities Division in the Office of Water, EPA Headquarters. The proposed information collection activities are accomplished by the least burdensome and least costly means and are not duplicated by other sources.
EPA administers the MPRSA, as amended. The MPRSA is also referred to as the Ocean Dumping Act. The MPRSA regulates the dumping and transportation for the purpose of dumping of material into ocean waters. The collections of information described in this document derive from EPA's authorities under and responsibilities in implementing the MPRSA.
EPA plays a primary role in protecting and preserving our ocean and coastal resources from dumping at sea. The Oceans, Wetlands, and Communities Division in the Office of Water at EPA Headquarters and the seven coastal EPA Regional Offices (Regions 1, 2, 3, 4, 6, 9, and 10) jointly administer EPA’s Ocean Dumping Management Program. Ocean dumping cannot occur unless a permit is issued under the MPRSA. EPA is responsible for issuing ocean dumping permits for all materials except dredged material. The U.S. Army Corps of Engineers (USACE) is responsible for issuing ocean dumping permits for dredged material. In the case of Federal navigation projects, USACE may implement the MPRSA directly in the Federal projects involving ocean disposal of dredged materials in lieu of the permit process. USACE relies on EPA's ocean dumping criteria when evaluating permit requests for (and implementing Federal projects involving) the transportation of dredged material for the purpose of dumping it into ocean waters. Ocean dumping permits for dredged material (and federal projects involving ocean dumping of dredged material) are subject to EPA review and concurrence. EPA is also responsible for designating and managing ocean disposal sites for the disposal of wastes and other materials,and establishing Site Management and Monitoring Plans (SMMPs) for ocean disposal sites.
EPA regulations establish ocean dumping criteria (hereinafter the “Ocean Dumping Criteria”) for the evaluation of MPRSA permit applications. The Ocean Dumping Criteria consider, among other things: the environmental impact of the dumping; the need for the dumping; the effect of the dumping on aesthetic, recreational, or economic values; land-based alternatives to ocean dumping; and the adverse effects of the dumping on other uses of the ocean. The Ocean Dumping Criteria are codified in 40 CFR parts 220-228.
Congress vested EPA with the authority and discretion to issue ocean dumping permits for all materials except dredged material. The other materials for which EPA issues permits, and that are currently dumped in the ocean include human remains, vessels, marine mammal carcasses and fish processing wastes. Section 101 of the MPRSA (33 U.S.C. 1411) prohibits all ocean dumping activities except those activities authorized by a permit. Dumping of some materials is prohibited by the statute and may not be permitted. Under MPRSA section 102, EPA can issue various types of permits: special, general, research (including incineration at sea),1 or emergency permits. EPA may issue special permits to applicants seeking to dump materials in the ocean. EPA may issue a general permit for materials that will have a minimal adverse environmental impact and are generally disposed of in small quantities. EPA may issue research permits for the dumping of materials as part of a research project when it is determined that the scientific merit of the proposed project outweighs the potential environmental or other damage that may result from dumping. EPA may issue emergency permits only in situations where the material to be disposed poses “an unacceptable risk relating to human health and admits of no other feasible solution.” “Emergency” refers to situations requiring action with a marked sense of urgency but is not limited to circumstances requiring immediate action.
The United States is a Contracting Party to the London Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972. The United States implements the London Convention through the MPRSA. In compliance with treaty obligations, the United States (through EPA and USACE) provides annual reports to the treaty organization regarding the ocean dumping of materials authorized over the preceding year.
Lastly, EPA works closely with USACE and the U.S. Coast Guard to implement the MPRSA. Compliance and enforcement of the MPRSA are the responsibilities of EPA, USACE, and the U.S. Coast Guard. EPA also works with the other federal agencies, as needed, on particular issues (e.g., the National Oceanic and Atmospheric Administration (NOAA) in mapping vessels disposed under the vessel disposal general permit).
This document follows the format for ICR outlined in the Information Collection Review Handbook (Office of Management and Budget, 1989) and the Instructions for Standard Form 83 (revised version dated September 1983). No exceptions to this format are taken. Those topics identified in the Information Collection Review Handbook, which are not relevant to this application, are noted and the basis for this determination stated. EPA's Information Resources Management Policy Manual (July 1987), Regulation Development in EPA (September 1992), and EPA's Instructions for Preparing Information Collection Requests (June 1992) also guided the development of this document.
The approved ICR categories are being revised back to (1) new permitting actions (see Chapter 1 of the Supporting Statement – New Permits) and (2) Existing General Permits (see Chapter 2 of the Supporting Statement – Existing General Permits). The previous 3 category format used for the 2019 ICR renewal do not align with the current format of the ICR analysis.
This ICR is organized into two chapters. Both chapters address activities that are subject to the requirements of the PRA. Chapters 1 and 2 address ocean dumping activities for materials other than dredged material.
Chapter 1 analyzes activities associated with new MPRSA special, general, research, and emergency permits. In addition to the permits themselves, this chapter also includes reporting requirements associated with dumping of material for an emergency to safeguard life at sea, where no permit is required.
Chapter 2 analyzes activities associated with the three existing general permits that have applicable collections of information within the meaning of the Paperwork Reduction Act. Currently, there are three existing general permits with applicable collections of information within the meaning of the Paperwork Reduction Act: 1) burial at sea general permit, 2) transportation and disposal of vessels at sea general permit, and 3) ocean disposal of marine mammal carcasses.
EPA has taken a conservative approach, specifically to overstate potential burden and costs, throughout this analysis, and all information collection and record keeping requirements are included in this analysis.
This ICR was developed based on program office knowledge of the process, a review of collections of information similar to those being called for under this ICR, a review of EPA regional practices in collecting information, a review of the literature on the ocean dumping program and, ultimately, by an independent review by three likely respondents.
On March 19, 2020, in concluding on the previous renewal ICR (EPA ICR # 0824.07), OMB issued the following terms of clearance.
As terms of clearance, OMB requests that EPA (1) explain clearly how permit applications get submitted, (2) explain clearly how respondents learn about the need to submit a permit application; (3) demonstrate that agency has considered creating a standard application form to reduce possible confusion and public burden; and (4) include a table that clearly lays out the total burden associated with the collection that is currently presented in separate tables.
Table A. Total Respondent Burden and Costs Associated with this ICR Collection
Total Respondent Burden for new for the Collection of Information for Special, General, Research, and Emergency Ocean Dumping Permits and Existing General Permits for Burial at Sea, Vessel Disposal, and Disposal of Marine Mammal Carcasses General Permits Respondent Burden and Costs* under 40 CFR 229.3 |
|||||
Permit: |
Respondents Per Year |
Total Hours Per Year |
Total Labor Cost Per Year ($) |
Total Annual O&M Costs ($) |
Total Annual Cost ($) |
Special |
0.2 |
274.8 |
$13,473.06 |
$60,004.00 |
$73,477.06 |
General (other than burial at sea and vessel disposal) |
0.1 |
54.2 |
$2,685.48 |
$2.00 |
$2,687.48 |
Research |
0.5 |
687 |
$33,682.66 |
$500,010.00 |
$533,692.66 |
Emergency Permit Dumping |
0.2 |
119.4 |
$5,941.94 |
$4.00 |
$5,945.94 |
Emergency Dumping |
0.1 |
7 |
$357.39 |
$1.00 |
$358.39 |
Existing Burial at Sea General Permit |
2475.67 |
2,054.80 |
$92,287.95 |
$4,951.33 |
$97,239.28 |
Existing Vessel Disposal General Permit |
2.67 |
93.4 |
$4,550.00 |
$226.92 |
$4,776.92 |
Existing Disposal of Marine Mammal Carcasses General Permit |
10 |
79 |
$4,062.59 |
$100.00 |
$4,162.59 |
TOTAL |
2,489.44 |
3,369.60 |
$157,041.07 |
$565,299.25 |
$722,340.32 |
|
|
|
|
|
|
Table B. Total EPA Burden and Costs Associated with this ICR Collection
Total Agency (EPA) Burden for new for the Collection of Information for Special, General, Research, and Emergency Ocean Dumping Permits and Existing General Permits for Burial at Sea, Vessel Disposal, and Disposal of Marine Mammal Carcasses General Permits Respondent Burden and Costs* under 40 CFR 229.3 |
|||||
Permit: |
Respondents Per Year |
Total Hours Per Year |
Total Labor Cost Per Year ($) |
Total Annual O&M Costs ($) |
Total Annual |
Cost ($) |
|||||
Special |
0.2 |
220 |
$15,002.82 |
$4.00 |
$15,006.82 |
General (other than burial at sea and vessel disposal) |
0.1 |
50 |
$3,520.63 |
$2.00 |
$3,522.63 |
Research |
0.5 |
465 |
$30,966.03 |
$10.00 |
$30,976.03 |
Emergency Permit Dumping |
0.2 |
32.8 |
$2,320.27 |
$4.00 |
$2,324.27 |
Emergency Dumping |
0.1 |
2.4 |
$169.78 |
$1.00 |
$170.78 |
Existing Burial at Sea General Permit |
2,475.67 |
272.32 |
$18,818.41 |
$495.13 |
$19,313.54 |
Existing Vessel Disposal General Permit |
2.67 |
24.03 |
$1,959.58 |
$80.10 |
$2,039.68 |
Existing Disposal of Marine Mammal Carcasses General Permit |
10 |
20 |
$1,382.06 |
$0.00 |
$1,382.06 |
TOTAL |
2,489.44 |
1086.55 |
$74,139.58 |
$596.23 |
$74,735.81 |
Collection of Information for Special, Research, Emergency, and new General (other than for Burial at Sea, Vessel Disposal and Marine Mammal Carcasses) Ocean Dumping Permits
Chapter 1 of this ICR covers collections of information associated with new ocean dumping permits. This chapter is organized by each category of ocean dumping permit according to EPA's regulations:
Special
General (other than for burial at sea, vessel disposal at sea, and ocean disposal of marine mammal carcasses)
Research
Emergency
In addition to these permits, this chapter includes the following reporting requirements where no permit is required:
Emergency to Safeguard Life at Sea
Section 104(e) of the MPRSA authorizes EPA to collect permit application information. The information collected is codified in 40 CFR 221.1 based on the category of permit sought (special, general, research, and emergency). EPA collects this information to ensure that ocean dumping is appropriately regulated and will not harm human health or the marine environment, based on applying the Ocean Dumping Criteria. To meet United States’ reporting obligation under the London Convention, EPA also reports some of this information in the annual United States Ocean Dumping Report.
EPA uses ocean dumping information to make decisions regarding whether to issue or deny a permit. This information is also used to develop the conditions in ocean dumping permits issued by EPA in order to ensure consistency with the Ocean Dumping Criteria. EPA uses monitoring and reporting data to assess compliance with ocean dumping permits, including associated monitoring activities.
All information requested from respondents under this ICR is required to ensure that material proposed for ocean dumping is appropriately regulated and does not harm human health or the marine environment, based on applying the Ocean Dumping Criteria. The information is not generally available from other sources.
Public comments were previously requested via the Federal Register (87 FR 41716) on July 13, 2022, during a 60-day comment period. No comments were received.
The permits in this chapter occur infrequently and are on a case-by-case basis. Burden estimates for Chapter 1 are based on best professional judgement.
The application is only filed once in order to obtain the benefit of a permit and less frequent filing (i.e., no application) would preclude EPA from providing the benefit.
The information collection activities discussed in this chapter of the ICR are fully consistent with all guidelines in 5 CFR § 1320.5(d)(2).
To the extent that information collection activities discussed in this chapter of the ICR require the submission of any confidential information, EPA ensures compliance with the Agency's confidentiality regulations. 40 CFR 2.201 et seq.
3(g): Sensitive Questions
The information collection activities discussed in this chapter of the ICR do not require the submission of any sensitive information concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private.
Any private person or entity, or any officer, employee, agent, department, agency, or instrumentality of the federal government, of any state or local unit of government, or of any foreign government may apply for an MPRSA permit. This broad range of potential respondents precludes EPA from identifying particular respondents based on SIC/NAICS Codes.
As described above, EPA seeks information necessary to evaluate a permit application, including reporting requirements such as records, reports, and monitoring information that may be prescribed as part of an ocean dumping permit.
Pursuant to 40 CFR 221.1-221.2, and as part of the initial application, EPA requires all ocean dumping permit applicants to supply the following information:
Name and address of applicant.
Name of the person or firm transporting the material for dumping, the name of the person(s) or firm(s) producing or processing all materials to be transported for dumping, and the name or other identification, and usual location, of the conveyance to be used in the transportation and dumping of the material to be dumped, including information on the transporting vessel's communications and navigation equipment.
Adequate physical and chemical description of material to be dumped, including results of tests necessary to apply the Ocean Dumping Criteria, and the number, size, and physical configuration of any containers to be dumped.
Quantity of material to be dumped.
Proposed dates and times of dumping.
Proposed dump site, and, in the event the proposed dump site is not designated in subchapter H, detailed physical, chemical and biological information relating to the proposed dump site and sufficient to support its designation as a site according to part 228 of subchapter H.
Proposed method of releasing the material at the dump site and means by which the disposal rate can be controlled, as required.
Identification of the specific process or activity producing the material.
Description of the manner in which the type of material proposed to be dumped has been previously disposed of by or on behalf of the person(s) or firm(s) producing such material.
A statement of the need for the proposed dumping and an evaluation of short- and long-term alternative means of disposal, treatment or recycle of the material. Alternative means of disposal shall include but is not limited to: landfill, well injection, incineration, spread of material over open ground; biological, chemical or physical treatment; recovery and recycle of material, and storage. The statement shall also include an analysis of the availability and environmental impact of such alternatives.
An assessment of the anticipated environmental impact of the proposed dumping, including but not limited to: the relative duration of the effect of the proposed dumping on the marine environment, navigation, living and non-living marine resource exploitation, scientific study, recreation and other uses of the ocean.
Under 40 CFR 222.2, after EPA notifies an applicant that its permit application is complete, EPA makes a tentative determination whether the proposed ocean dumping activity meets the Ocean Dumping Criteria. A final determination is made after the opportunity for a public hearing or after a hearing is conducted.
EPA manages each ocean dumping permit over the term of the permit. EPA’s management role may involve reviewing periodic reports, site visits, and other measures on a case-by-case basis in compliance with 40 CFR part 224.
Each permittee must maintain complete records of the following information in compliance with 40 CFR 224.1:
The physical and chemical characteristics of the material dumped pursuant to the permit.
The precise times and locations of the dumping.
Any other information required as a condition of the permit by EPA.
Situations involving an emergency to safeguard life at sea are excluded from the ocean dumping regulations under 40 CFR 220.1(c). The exclusion, however, is subject to the reporting requirement contained in 40 CFR 224.2(b). The owner or operator of the vessel or aircraft from which ocean dumping occurred under 40 CFR 220.1(c)(4) must, as soon as feasible:
Inform the Administrator, Regional Administrator, or nearest Coast Guard district of the incident.
Within 10 days, file a written report to the Administrator or Regional Administrator with the following information.
The physical and chemical characteristics of the material dumped.
The precise times and locations of dumping.
Any other information required by the Administrator or the Regional Administrator.
A complete description of the circumstances under which the dumping occurred, including how human life at sea was in danger and how the emergency dumping reduced that danger.
If the material dumped included containers, the vessel owner or operator shall immediately request the U.S. Coast Guard to publish in the local Notice to Mariners the dumping location, the type of container, and whether the contents are toxic or explosive.
Notify the Food and Drug Administration, Shellfish Sanitation Branch, Washington, DC 20204, as soon as possible.
EPA collects the information submitted by applicants as part of an initial ocean dumping permit application under 40 CFR 221.1-221.2. After EPA issues an ocean dumping permit, EPA collects records and reports as described in 40 CFR 224.1-224.2.
EPA’s collection activities begin with the receipt of an ocean dumping permit application. Applicants requesting general,2 special, emergency, and research permits under section 102 of the MPRSA must submit a formal application to either EPA Headquarters or to the appropriate Regional Office, authorized by 40 CFR 220.4 to act on the application. Under 40 CFR 222.2(a), upon receipt of an initial application, the Administrator or the Regional Administrator, has 30 days to notify the applicant in writing whether or not the application is complete or whether additional information is needed.
Pursuant to 40 CFR 222.2(b), and after EPA provides notice that an application is complete, EPA makes a tentative determination to issue or to deny the permit. If EPA proposes to issue the permit, it also provides notice of:
proposed time limitations, if any;
proposed rate of discharge from the barge or vessel transporting the material;
proposed dumping site; and
a brief description of any other proposed conditions determined to be appropriate for inclusion in the permit.
EPA then develops the terms and conditions of the permit consistent with the ocean dumping regulations and finalizes the permit. Notice of tentative determination is required for every complete application for a general, special, and research permit. In the case of an emergency permit, the Administrator determines that the emergency poses an unacceptable risk relating to human health, that no other feasible solution exists, and that the public interest requires the issuance of an emergency permit as soon as possible. Notice of issuance of the emergency permit is published as soon as practicable after issuance. Upon receipt, and until a final determination to grant or deny a general, special, research or emergency permit, EPA may collect additional information from the applicant to make its decision.
EPA collects information related to ocean dumping permits and monitoring information to determine compliance with permit conditions and to evaluate the impact of the disposal on the marine environment. These permits require the permittee to submit the information to the Administrator or the Regional Administrator. This information also helps EPA manage the dump site. All of the information pertaining to a permit will be stored in a database.
The collections of information described in this chapter of the ICR will only affect a de minimis number of small entities. Since enactment of the Ocean Dumping Ban Act amendment prohibiting the ocean dumping of industrial wastes, EPA has received very few ocean dumping permit applications from small entities. The small entities that do dump materials in the ocean are, for the most part, authorized under the general permits for burial at sea, vessel disposal at sea, and ocean disposal of marine mammal carcasses, none of which requires an individual application. The general permits for burial at sea, vessel disposal at sea, and ocean disposal of marine mammal carcasses are specifically discussed in Chapter 2. Given the lack of interest and inquiries regarding ocean dumping permits from small entities, this ICR is not excessively burdensome on small entities.
Permit applications for MPRSA special, general, research, and emergency permits occur on infrequent intervals, approximately 1 to 3 of each per every 10 years. The requirements for a permit application are described in 40 CFR part 222. If a permit is issued, or material is dumped for an emergency to safeguard life at sea, records and reporting are required according to 40 CFR 224.1-224.2.
This section estimates the relative annual burden (time in hours) and burden per response for each permit category, as well as for emergencies to safeguard life at sea.
Information collection burden hours were reviewed by respondents who had previously participated in the permit application process during the ten-year period 2011-2021. The estimated burden hours reflect the burden (time in hours) that an individual respondent will require to complete an activity needed for an ocean dumping permit application. The level of effort estimates presented for these tables were reviewed by EPA staff and managers, all of whom have experience in assessing information collection work similar to that described in this chapter of this ICR. An effort has been made to consistently use conservative estimates.
In summary, the estimated burden per respondent to complete an application and reporting requirements is 1,374 hours for a special permit, 542 hours for a new general permit, 1,374 hours for a research permit and 597 hours for an emergency permit. The estimated burden per respondent to complete the necessary reporting requirements for an emergency to safeguard life at sea is 70 hours. The total burden per year was calculated by multiplying the burden hours per response by the number of respondents, which corresponds to the number of permit applications the EPA expects per year. This analysis is shown in Tables 2 through 6. See section 6(d) of chapter 1 of this supporting statement for a description of how the respondent numbers (i.e., respondent universe) were estimated.
To estimate the labor costs, EPA used labor and cost-rate data listed on the U.S. Bureau of Labor Statistics (BLS) Compensation Cost Trends homepage.3 The BLS homepage includes links to publications and reports related to labor costs by category. Given the broad range of potential respondents, EPA used average rates for the following three general respondent occupation categories to derive its burden and cost estimates:
Management occupations4 (Management)
Environmental scientists5 (Technical)
Office and administrative support occupations6 (Clerical)
EPA used the hourly figures listed by BLS to approximate the labor burdened hourly rates for the occupational categories contained in this chapter of the ICR. These are listed in Table 17.
Table 1. Respondent Labor Costs: Hourly Loaded Wage Estimate of Affected Industry
BLS: Occupational Earnings (May 2017) |
ICR Respondent Job Classification Titles |
Hourly Rate (USD) |
Benefits Factor |
Loaded Hourly Rate (USD) |
Management Occupations |
Management |
$59.31/hr |
1.3 |
$77.10/hr |
Environmental Scientists |
Technical |
$39.06/hr |
1.3 |
$50.78/hr |
Office and administrative support occupations |
Clerical |
$20.88/hr |
1.3 |
$27.14/hr |
EPA predicts no respondent capital or start-up costs associated with the activities described in this chapter of the ICR. Non-labor operations and maintenance (O&M) include the cost of contracted services expected to be needed, where the cost is not tied to labor hours for the respondent or EPA. These costs in include costs for photocopying, postage, telephone charges, as well as major activities associated with ocean monitoring or laboratory analyses. O&M expenses listed in Tables 2 through 6 are predominantly internet (including email), printing, photocopy, postage, and related paperwork distribution expenses, as well as contracted services.
Respondent costs are compiled in Tables 2 through 6 for each ocean dumping permit category and for emergencies to safeguard life at sea. In summary, the estimated labor cost per respondent to complete an application and its corresponding reporting requirements is $67,365.32 for special permits, $26,854.78 for a new general permit, $67,365.32 for research permits, and $29,707.69 for emergency permits. The estimated cost per respondent to complete the reporting requirements for an emergency to safeguard life at sea is $3,573.88. Annualized costs are based on the number of permits expected per year and include both labor costs and non-labor O&M costs.
Table 2. Respondent Burden and Cost for Special Permits
Special Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $77.10/ hr |
Technical $50.78/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Application (40 CFR 221.1) |
|
|
|
|
|
|
|
|
|
a. Read regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.20 |
2.00 |
$97.37 |
b. Plan Activities |
20.00 |
100.00 |
20.00 |
140.00 |
$7,162.74 |
$0.00 |
0.20 |
28.00 |
$1,432.55 |
c. Create/obtain new information |
20.00 |
500.00 |
18.00 |
538.00 |
$27,419.65 |
$300,000.00* |
0.20 |
107.60 |
$65,483.93 |
d. Gather existing information |
20.00 |
120.00 |
40.00 |
180.00 |
$8,721.18 |
$0.00 |
0.20 |
36.00 |
$1,744.24 |
e. Complete application |
16.00 |
100.00 |
60.00 |
176.00 |
$7,940.09 |
$10.00 |
0.20 |
35.20 |
$1,590.02 |
2. Reporting Requirements (40 CFR 224.1-224.2) |
|
|
|
|
|
|
|
|
|
a. Read permit/ regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.20 |
2.00 |
$97.37 |
b. Record dumping and monitoring activity information |
20.00 |
150.00 |
40.00 |
210.00 |
$10,244.52 |
$0.00 |
0.20 |
42.00 |
$2,048.90 |
c. Submit dumping and monitoring reports |
10.00 |
60.00 |
40.00 |
110.00 |
$4,903.47 |
$10.00 |
0.20 |
22.00 |
$913.17 |
Subtotal (hours and costs) |
1 108.00 |
1044.00 |
222.00 |
1374.00 |
$67,365.32 |
$300,020.00 |
0.20* |
274.80 |
$73,477.06 |
*Assumes the cost for five samples of material proposed for dumping to be collected and analyzed based on the ocean dumping regulations (bioassays for toxicity and bioaccumulation, chemical analyses for water quality) procedures in the ocean dumping testing manual.
Table 3. Respondent Burden and Cost for General Permits
General Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $77.10/ hr |
Technical $50.78/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Application (40 CFR 221.1) |
|
|
|
|
|
|
|
|
|
a. Read regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.10 |
1.00 |
$48.68 |
b. Plan Activities |
10.00 |
50.00 |
10.00 |
70.00 |
$3,581.37 |
$0.00 |
0.10 |
7.00 |
$358.14 |
c. Create/obtain new information |
10.00 |
250.00 |
9.00 |
269.00 |
$13,709.83 |
$0.00 |
0.10 |
26.90 |
$1,370.98 |
d. Gather existing information |
10.00 |
60.00 |
20.00 |
90.00 |
$4,360.59 |
$0.00 |
0.10 |
9.00 |
$436.06 |
e. Complete application |
8.00 |
50.00 |
30.00 |
88.0 |
$3,970.04 |
$10.00 |
0.10 |
8.80 |
$398.00 |
2. Reporting Requirements (40 CFR 224.1-224.2) |
|
|
|
|
|
|
|
|
|
a. Read permit/ regulations/ guidance |
1.00 |
2.00 |
0.00 |
3.00 |
$178.66 |
$0.00 |
0.10 |
0.30 |
$17.87 |
b. Record dumping and monitoring activity information |
2.00 |
5.00 |
3.00 |
10.00 |
$489.53 |
$0.00 |
0.10 |
1.00 |
$48.95 |
c. Submit dumping and monitoring report(s) |
0.00 |
1.00 |
1.00 |
2.00 |
$77.92 |
$10.00 |
0.10 |
0.20 |
$8.79 |
Subtotal (hours and costs) |
42.00 |
425.00 |
75.00 |
542.00 |
$26,854.78 |
$20.00 |
0.10 |
54.20 |
$2,687.48 |
Table 4. Respondent Burden and Cost for Research Permits
Research Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $77.10/ hr |
Technical $50.78/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Application (40 CFR 221.1) |
|
|
|
|
|
|
|
|
|
a. Read regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.50 |
5.00 |
$243.42 |
b. Plan Activities |
20.00 |
100.00 |
20.00 |
140.00 |
$7,162.74 |
$0.00 |
0.50 |
70.00 |
$3,581.37 |
c. Create/obtain new information |
20.00 |
500.00 |
18.00 |
538.00 |
$27,419.65 |
$1,000,000* |
0.50 |
269.00 |
$513,709.83 |
d. Gather existing information |
20.00 |
120.00 |
40.00 |
180.00 |
$8,721.18 |
$0.00 |
0.50 |
90.00 |
$4,360.59 |
e. Complete application |
16.00 |
100.00 |
60.00 |
176.00 |
$7,940.09 |
$10.00 |
0.50 |
88.00 |
$3,975.04 |
2. Reporting Requirements (40 CFR 224.1-224.2) |
|
|
|
|
|
|
|
|
|
a. Read permit/ regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.50 |
5.00 |
$243.42 |
b. Record dumping and monitoring activity information |
20.00 |
150.00 |
40.00 |
210.00 |
$10,244.52 |
$0.00 |
0.50 |
105.00 |
$5,122.26 |
c. Submit dumping and monitoring reports |
10.00 |
60.00 |
40.00 |
110.00 |
$4,903.47 |
$10.00 |
0.50 |
55.00 |
$2,456.74 |
Subtotal (hours and costs) |
108.00 |
1,044.00 |
222.00 |
1374.00 |
$67,365.32 |
$1,000,020 |
0.50 |
687.00 |
$533,692.66 |
* Assumes the cost for five samples of material proposed for dumping to be collected and analyzed based on the ocean dumping regulations (bioassays for toxicity and bioaccumulation, chemical analyses for water quality) procedures in the ocean dumping testing manual. This also includes assumed environmental oceanographic monitoring during research, including water and sediment sampling with associated chemical and biological testing.
Table 5. Respondent Burden and Cost for Emergency Permits
Emergency Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $77.10/ hr |
Technical $50.78/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Application (40 CFR 221.1) |
|
|
|
|
|
|
|
|
|
a. Read regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.20 |
2.00 |
$97.37 |
b. Plan Activities |
10.00 |
50.00 |
10.00 |
70.00 |
$3,581.37 |
$0.00 |
0.20 |
14.00 |
$716.27 |
c. Create/obtain new information |
10.00 |
250.00 |
10.00 |
269.00 |
$13,736.97 |
$0.00 |
0.20 |
53.80 |
$2,747.39 |
d. Gather existing information |
10.00 |
60.00 |
20.00 |
90.00 |
$4,360.59 |
$0.00 |
0.20 |
18.00 |
$872.12 |
e. Complete application |
8.00 |
50.00 |
30.00 |
88.00 |
$3,970.04 |
$10.00 |
0.20 |
17.60 |
$796.01 |
2. Reporting Requirements (40 CFR 224.1-224.2) |
|
|
|
|
|
|
|
|
|
a. Read permit/ regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.20 |
2.00 |
$97.37 |
b. Record dumping and monitoring activity information |
10.00 |
20.00 |
10.00 |
40.00 |
$2,058.03 |
$0.00 |
0.20 |
8.00 |
$411.61 |
c. Submit dumping and monitoring reports |
5.00 |
10.00 |
5.00 |
20.00 |
$1,029.02 |
$10.00 |
0.20 |
4.00 |
$207.80 |
Subtotal (hours and costs) |
55.00 |
454.00 |
89.00 |
597.00 |
$29,709.69 |
$20.00 |
0.20 |
119.40 |
$5,945.94 |
Table 6. Respondent Burden and Cost for Emergencies to Safeguard Life at Sea
Emergency to Safeguard Life at Sea - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $77.10/ hr |
Technical $50.78/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Reporting Requirements |
|
|
|
|
|
|
|
|
|
a. Read regulations/ guidance |
1.00 |
7.00 |
2.00 |
10.00 |
$486.84 |
$0.00 |
0.10 |
1.00 |
$48.68 |
b. Record dumping and monitoring activity information according to 40 CFR 224.1 |
10.00 |
20.00 |
10.00 |
40.00 |
$2,058.03 |
$0.00 |
0.10 |
4.00 |
$205.80 |
c. Submit report to EPA under 40 CFR 224.2(b) |
5.00 |
10.00 |
5.00 |
20.00 |
$1,029.02 |
$10.00 |
0.10 |
2.00 |
$103.90 |
Subtotal (hours and costs) |
16.00 |
37.00 |
17.00 |
70.00 |
$3,573.88 |
$10.00 |
0.10 |
7.00 |
$358.39 |
EPA’s labor costs data associated with this chapter of the ICR reflect the pay scale rates for GS-9, GS-12, and GS-14 employees.8 The salary rates for EPA’s labor costs apply to the Agency job classifications listed in Table 2 below for:
GS-14 (Management)
GS-12 (Technical)
GS-9 (Clerical)
To arrive at the loaded hourly rates listed in Table 7, hourly rates were multiplied by 160% to reflect a fully loaded (wages + benefits) hourly rate.
Table 7. Agency Labor Costs: Hourly Loaded Agency Wage Estimate
ICR Agency Job Classification |
January 2022 Annual GS Salary (Step 1) |
Work Hours Per Year Factor |
Benefits Factor |
Loaded Hourly Rate |
Management |
GS-14, $126,233 |
2,080 |
1.6 |
$97.10/hr |
Technical |
GS-12, $89,834 |
2,080 |
1.6 |
$69.10/hr |
Clerical |
GS-9, $61,947 |
2,080 |
1.6 |
$47.65/hr |
In summary, the estimated EPA burden per respondent for a special permit is 1,100 hours with a labor cost per respondent of $75,014.08. The estimated EPA burden per respondent for a general permit is 500 hours with a labor cost per respondent of $35,206.31. The estimated EPA burden per respondent for a research permit is 930 hours with a labor cost per respondent of $61,932.07. The estimated burden per respondent for an emergency permit is 164 hours with a labor cost per respondent of $11,601.36. The estimated burden per respondent to complete the requirements for an emergency to safeguard life at sea is 24 hours with a labor cost per respondent of $1,697.76. Annualized burden and costs are based on the number of permits expected per year. This analysis is shown in Tables 8 through 12.
Table 8. Agency (EPA) Burden and Cost for Special Permits
Special Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/hr |
Technical $69.10/hr |
Clerical $47.65/hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Application |
|
|
|
|
|
|
|
|
|
a. Receive and review application information under 40 CFR 221.1 and issue of permit |
100.00 |
500.00 |
100.00 |
700.0 |
$49,026.92 |
$10.00 |
0.20 |
140.00 |
$9,807.38 |
b. Maintain records throughout the application process under 40 CFR Part 222 |
50.00 |
100.00 |
150.00 |
300.0 |
$18,913.15 |
$0.00 |
0.20 |
60.00 |
$3,782.63 |
2. Reporting Requirements |
|
|
|
|
|
|
|
|
|
a. Collect reported information and review for consistency with permit / MPRSA requirements |
20.00 |
40.00 |
20.00 |
80.0 |
$5,659.20 |
$10.00 |
0.20 |
16.00 |
$1,133.84 |
b. Maintain reports and monitoring information for future reviews
|
5.00 |
10.00 |
5.00 |
20.0 |
$1,414.80 |
$0.00 |
0.20 |
4.00 |
$282.96 |
Subtotal (hours and costs) |
175.0 |
650.0 |
275.0 |
1,100.0 |
$75,014.08 |
$20.00 |
0.20 |
220.00 |
$15,006.82 |
Table 9. Agency (EPA) Burden and Cost for General Permits
General Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|
|||||||
Mgmt. $97.10/hr |
Technical $69.10/hr |
Clerical $47.65/hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($)* |
Number Responses /Year |
Total Hours/ Year |
Total Cost/ Year ($) |
||
1. Application |
|
|
|
|
|
|
|
|
|
|
a. Receive and review application information under 40 CFR 221.1 and issue permit |
50.00 |
200.00 |
50.00 |
300.00 |
$21,058.31 |
$10.00 |
0.10 |
30.00 |
$2,106.83 |
|
b. Maintain records throughout the application process under 40 CFR Part 222 |
25.00 |
50.00 |
25.00 |
100.00 |
$7,074.00 |
$0.00 |
0.10 |
10.00 |
$707.40 |
|
2. Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
a. Collect reported information and review for consistency with permit / MPRSA requirements |
20.00 |
40.00 |
20.00 |
80.00 |
$5,659.20 |
$10.00 |
0.10 |
8.00 |
$566.92 |
|
b. Maintain reports and monitoring information for future reviews |
5.00 |
10.00 |
5.00 |
20.00 |
$1,414.80 |
$0.00 |
0.10 |
2.00 |
$141.48 |
|
Subtotal (hours and costs) |
100.00 |
300.00 |
100.00 |
500.00 |
$35,206.31 |
$20.00 |
0.10 |
50.00 |
$3,522.63 |
|
Table 10. Agency (EPA) Burden and Cost for Research Permits
Research Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/hr |
Technical $69.10/hr |
Clerical $47.65/hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($)* |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Application |
|
|
|
|
|
|
|
|
|
a. Receive and review application information under 40 CFR 221.1 and issue permit |
80.00 |
300.00 |
100.00 |
480.00 |
$33,264.26 |
$10.00 |
0.50 |
240.00 |
$16,637.13 |
b. Maintain records throughout the application process under 40 CFR Part 222 |
25.00 |
150.00 |
150.00 |
325.00 |
$19,940.75 |
$0.00 |
0.50 |
162.50 |
$9,970.38 |
2. Reporting Requirements |
|
|
|
|
|
|
|
0.00 |
|
a. Collect reported information and review for consistency with permit / MPRSA requirements |
25.00 |
50.00 |
30.00 |
105.00 |
$7,312.26 |
$10.00 |
0.50 |
52.50 |
$3,661.13 |
b. Maintain reports and monitoring information for future reviews |
5.00 |
10.00 |
5.00 |
20.00 |
$1,414.80 |
$0.00 |
0.50 |
10.00 |
$707.40 |
Subtotal (hours and costs) |
135.00 |
510.00 |
285.00 |
930.00 |
$61,932.07 |
$20.00 |
0.50 |
465.00 |
$30,976.03 |
Table 11. Agency (EPA) Burden and Cost for Emergency Permits
Emergency Permit - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/hr |
Technical $69.10/hr |
Clerical $47.65/hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Application |
|
|
|
|
|
|
|
|
|
a. Receive and review application information under 40 CFR 221.1 and issue permit |
25.00 |
50.00 |
25.00 |
100.00 |
$7,074.00 |
$10.00 |
0.20 |
20.00 |
$1,416.80 |
b. Maintain records throughout the application process under 40 CFR Part 222 |
10.00 |
20.00 |
10.00 |
40.00 |
$2,829.60 |
$0.00 |
0.20 |
8.00 |
$565.92 |
2. Reporting Requirements |
|
|
|
|
|
|
|
|
|
a. Collect reported information and review for consistency with permit / MPRSA requirements |
5.00 |
10.00 |
5.00 |
20.00 |
$1,414.80 |
$10.00 |
0.20 |
4.00 |
$284.96 |
b. Maintain reports and monitoring information for future reviews |
1.00 |
2.00 |
1.00 |
4.00 |
$282.96 |
$0.00 |
0.20 |
0.80 |
$56.59 |
Subtotal (hours and costs) |
41.00 |
82.00 |
41.00 |
164.00 |
$11,601.36 |
$20.00 |
0.20 |
32.80 |
$2,324.27 |
Table 12. Agency (EPA) Burden and Cost for Emergency to Safeguard Life at Sea
Emergency to Safeguard Life at Sea - Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/hr |
Technical $69.10/hr |
Clerical $47.65/hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Reporting Requirements |
|
|
|
|
|
|
|
|
|
a. Collect reported information and review for consistency with permit / MPRSA requirements |
5.00 |
10.00 |
5.00 |
20.00 |
$1,414.80 |
$10.00 |
0.10 |
2.00 |
$142.48 |
b. Maintain reports and monitoring information for future reviews |
1.00 |
2.00 |
1.00 |
4.00 |
$282.96 |
$0.00 |
0.10 |
0.40 |
$28.30 |
Subtotal (hours and costs) |
6.00 |
12.00 |
6.00 |
24.00 |
$1,697.76 |
$10.00 |
0.10 |
2.40 |
$170.78 |
The potential respondent universe consists of any “person” as defined by the MPRSA, interested in applying for a new permit. The estimated number of respondents for the special, general (other than burial at sea and vessel disposal), research, and emergency permits, as well as the reporting requirements for an emergency to safeguard life at sea are based on historical data. Applications for these permits occur infrequently (< 1 per year) and in order for burdens and costs to be annualized, the respondent numbers are represented as a decimal.
The number of respondents for these permits was based on an estimate of permit applications expected per year based on historical permits issued in the past. The burden and cost for the general permit for the burial at sea, general permit for marine mammal carcasses, and the general permit for the transportation and disposal of vessels are not included in this section, as they are accounted for separately in Chapter 2. We assume one new general permit will be issued per every 10 years or 0.1 per year. The same assumption is made for emergencies to safeguard life at sea. We assume one emergency permits will be issued every five years or .2 per year. There were zero research or special permits issued in the past ten-years, and we used the frequency of 1 per 10 years or 0.10 per year as a precaution.
The total estimated ocean dumping burdens and costs associated with chapter 1 of the ICR are as follows:
1) Respondent
Respondents per year: 1.1
Total hours per year: 1,142.40
Total labor cost per year: $56,140.53
Total annual O&M costs: $560,021.00
Total annual cost: $616,161.53
1) Agency
Respondents per year: 1.1
Total hours per year: 770.20
Total labor cost per year: $51,979.53
Total annual O&M costs: $21.00
Total annual cost: $52,000.53
The total estimated ocean dumping burdens associated with Chapter 1 are summarized in Tables 13 and 14 for respondents and agencies, respectively.
Table 13. Total Estimated Respondent Burden and Cost* Summary+
Permit: |
Respondents Per Year |
Total Hours Per Year |
Total Labor Cost Per Year ($) |
Total Annual O&M Costs ($) |
Total Annual Cost ($) |
Special |
0.20 |
274.80 |
$13,473.06 |
$60,004.00 |
$73,477.06 |
General (other than burial at sea and vessel disposal) |
0.10 |
54.20 |
$2,685.48 |
$2.00 |
$2,687.48 |
Research |
0.50 |
687.00 |
$33,682.66 |
$500,010.00 |
$533,692.66 |
Emergency Permit Dumping |
0.20 |
119.40 |
$5,941.94 |
$4.00 |
$5,945.94 |
Emergency Dumping |
0.10 |
7.00 |
$357.39 |
$1.00 |
$358.39 |
Total |
1.10 |
1,142.40 |
$56,140.53 |
$560,021.00 |
$616,161.53 |
* These data are from Tables 2 through 6 of this ICR
Table 14: Total Estimated Agency (EPA) Burden and Cost* Summary
Permit: |
Respondents Per Year |
Total Hours Per Year |
Total Labor Cost Per Year ($) |
Total Annual O&M Costs ($) |
Total Annual Cost ($) |
Special |
0.20 |
220.00 |
$15,002.82 |
$4.00 |
$15,006.82 |
General (other than burial at sea and vessel disposal) |
0.10 |
50.00 |
$3,520.63 |
$2.00 |
$3,522.63 |
Research |
0.50 |
465.00 |
$30,966.03 |
$10.00 |
$30,976.03 |
Emergency Permit Dumping |
0.20 |
32.80 |
$2,320.27 |
$4.00 |
$2,324.27 |
Emergency Dumping |
0.10 |
2.40 |
$169.78 |
$1.00 |
$170.78 |
Total |
1.10 |
770.20 |
$51,979.53 |
$21.00 |
$52,000.53 |
* These data are from Tables 8 through 12 of this ICR
There is an increase in the respondent burden for the permits covered in Chapter 1. When compared to the existing ICR, there is an increase in the Total Hours and in the Total Annual Cost. The total hours respondent hours increased slightly from 1,070.40 to 1,142.40 and the total estimated respondent burden increased from $209,665.48 to $616,161.53 as compared with the ICR currently approved by OMB. This increased estimate is due to the assumption that Research Permits will occur once every two years instead of once every ten years. This assumption is based on more recent inquiries into this area of permitting.
The annual public reporting and record keeping burden for this collection of information is 542.0 hours for a new general permit, 1,374.0 hours for a special permit, 1,374.0 hours for a research permit, and 597 hours for an emergency permit, per response. The estimated burden per respondent to complete the necessary reporting requirements for an emergency to safeguard life at sea is 70 hours 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 Number EPA-HQ-OW-2015-0613, which is available for online viewing at www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. 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 Water Docket is (202) 566-2426. An electronic version of the public docket is available at www.regulations.gov. This site can be used 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. When 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, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OW-2015-0613 and OMB Control Number 2040-0008 in any correspondence.
Chapter 2. Supporting Statement for the Collection of Information for General Permits: Burial at Sea, Transportation and Disposal of Vessels, and Disposal of Marine Mammal Carcasses
Chapter 2 of this ICR covers collections of information associated with three general permits. Specifically, this chapter addresses information collections associated with the general permits for (1) burial at sea, (2) transportation and disposal of vessels and (3) disposal of marine mammal carcasses.
Section 104(b) of the MPRSA authorizes the Administrator to prescribe reporting requirements for permits “as he [EPA] deems appropriate.” The information that EPA collects in the general permits for burial at sea, vessel disposal at sea, and ocean dumping of marine mammal carcass disposal ensures that ocean dumping is appropriately regulated and will not harm human health or the marine environment, based on applying the Ocean Dumping Criteria. To meet United States’ reporting obligation under the London Convention, EPA also reports some of this information in the annual United States Ocean Dumping Report.
EPA uses monitoring and reporting data from permittees to assess compliance with ocean dumping permits, including associated monitoring activities.
All information requested from respondents under this ICR is required to ensure that material proposed for ocean dumping is appropriately regulated and does not harm human health or the marine environment, based on applying the Ocean Dumping Criteria. The information is not generally available from other sources.
Public comments were previously requested via the Federal Register (87 FR 41716) on July 13, 2022, during a 60-day comment period. No comments were received.
Captain Dawn Mergelsberg of New Choice Burials in North Miami, Florida, reviewed the estimates for the costs and time to comply with the Burial at Sea general permit provided in the Information Collection Request Supporting Statement. She felt that the time and costs associated with compliance were fairly represented. She could not think of any way to enhance the quality, utility, or clarity of the data. Furthermore, she felt the online reporting system worked well to collect the data.
Reverend Bodhi Be of Doorway into Light in Maui, Hawaii, reviewed the estimates for the costs and time to comply with the Burial at Sea general permit provided in the Information Collection Request Supporting Statement. He felt that the time associated with compliance were 1-2 times higher than his experience and he could not think of any way to enhance the quality, utility, or clarity of the data. He also felt the online reporting system worked well to collect the data.
Michael Galaviz of Funeral and Cremation Care of Washington & Oregon headquartered in Bellingham, Washington, discussed the estimates for the costs and time to comply with the Burial at Sea general permit provided in the Information Collection Request Supporting Statement. He felt that the actual time associated with compliance was less than the 50 minutes (0.83 hours) estimated and that the hourly rates estimated were reasonable. Mr. Galaviz felt the online reporting system worked well to collect the data; however, he did note that the longitude being negative in North America did create some confusion when uploading information.
The collection of information described in this chapter of the ICR occurs only once per authorization: once after the burial has been conducted under the burial at sea general permit, once each time a general permittee seeks authorization under the general permit for transportation and disposal of vessels, and once after each disposal of marine mammal(s) carcasses. Thus, collections cannot occur on a less frequent basis. The notification required under the burial at sea general permit is necessary to track burials at sea and enable EPA to evaluate impacts on human health or the marine environment. Information collected under the transportation and disposal of vessels and marine mammal disposal general permits is necessary to ensure the dumping does not unreasonably endanger human health or the marine environment, or other uses of the ocean (such as fisheries and navigation), and to ensure the disposal is conducted in a safe manner. Collection of this information less frequently (i.e., not at all) would preclude EPA from accomplishing these purposes.
The information collection activities discussed in this chapter of the ICR are fully consistent with all guidelines in 5 CFR § 1320.5(d)(2).
To the extent that information collection activities discussed in this chapter of the ICR do require the submission of any confidential information, EPA ensures compliance with the Agency's confidentiality regulations 40 CFR 2.201 et seq.
The information collection activities discussed in this chapter of the ICR do not require the submission of any sensitive information concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private.
Any private person or entity, or any officer, employee, agent, department, agency, or instrumentality of the federal government, of any state or local unit of government, or of any foreign government is eligible to use the burial at sea general permit. Funeral homes, mortuaries, cemeteries, and crematories (SIC 7261/NAICS 812200), and deep-sea passenger transportation (SIC 4481/NAICS 483112) are likely respondents for activities relevant to this chapter of the ICR related to burials at sea.
Any private person or entity, or any officer, employee, agent, department, agency, or instrumentality of the federal government, of any state or local unit of government, or of any foreign government is eligible to use the disposal of vessels general permit. Navigational services related to shipping (includes cargo salvaging, marine docking and undocking marine vessel services, marine salvaging services, marine vessel traffic reporting services (NAICS 488330)) and towing and tugboat services (SIC 4492/ NAICS 488330) are potential respondents for collections of information as described in this chapter of the ICR related to vessel disposals.
Any officer, employee, agent, department, agency, or instrumentality of federal, state, tribal, or local unit of government, as well as any Marine Mammal Health and Stranding Response Program (MMHSRP) Stranding Agreement Holder, and any Alaskan Native, who already may take a marine mammal under the Marine Mammal Protection Act (MMPA) and Endangered Species Act (ESA), are eligible to use the general permit for ocean disposal of marine mammal carcasses.
Information collected by EPA related to the burial at sea general permit includes the following:
• Full name of the deceased.
• Date of the burial/scattering of the remains of the deceased.
• Describe whether the remains of the deceased were either cremated or whole body.
• The approximate latitude of the site at which the burial or scatter took place.
• The approximate longitude of the site at which the burial/scatter took place.
• Confirm that the burial at sea was conducted at least 3 nautical miles (nm) from the baseline.
• The approximate depth of water at which the burial/scatter took place.
• At least one vessel point of contact, including the contact’s name, address, phone number, and e-mail.
• The port of departure from which the vessel carrying the remains departed.
• Director or responsible person for the burial arrangements (if applicable), including at least one method of contacting this person.
• Describe whether the remains of the deceased appeared to rapidly sink below the surface.
• Report the EPA Region from which the vessel carrying the remains departed.
There are five collections of information in sequential time intervals contained in the transportation and disposal of vessels general permit, though the timing requirement of each need not apply in emergency situations:
A statement detailing the need for the disposal of the vessel.
Type and description of vessel to be disposed of and type of cargo normally carried.
Detailed description of the proposed disposal procedures.
Information on the potential effect of the vessel disposal on the marine environment.
v. Documentation of an adequate evaluation of alternatives to ocean disposal (i.e., scrap, salvage, and reclamation).
the proposed departure time and place;
disposal site location;
estimated time of arrival on site; and
the name and communication capability of the towing vessel.
There are two separate collections of information in sequential time intervals contained in the transportation and disposal of marine mammals.
General Requirements for Governmental Entities and Stranding Agreement Holders
(1) The permittee shall submit a report on the ocean disposal activities authorized by this general permit to the applicable EPA Regional Office within 30 days after carcass disposal. This report shall include:
a. A description of the carcass(es) disposed:
• Identify the mammal species, the approximate length and any other descriptive
information.
b. The date and time of the disposal as well as the latitude and longitude of the disposal site. Latitude and longitude of the disposal site shall be reported at the highest degree of accuracy available on board the vessel or vehicle that transported the carcass (e.g., onboard geographic position system technology):
• Report the time, date and approximate latitude and longitude of the disposal site.
c. The name, title, affiliation, and contact information of the person in charge of the disposal operation and the person in charge of the vessel or vehicle that transported the carcass (if different than the person in charge of the disposal):
• List the name, title, affiliation and contact information of the person in charge of the
disposal and the person in charge of the vessel.
d. A statement of need and rationale for selecting ocean disposal rather than other disposal options:
• Provide a statement identifying the need for an ocean disposal.
(2) The permittee shall immediately notify EPA of any violation of any condition of this general permit.
• Report any violations immediately to the EPA Region.
B. Requirements for any Alaskan Native Engaged in Subsistence Uses
(1) Notwithstanding Section A, any Alaskan Native engaged in subsistence uses is hereby granted a general permit to transport and dispose of marine mammal carcasses in ocean waters subject to the following conditions: The permittee shall submit a report (via email or letter) on all disposal activities authorized by this general permit that the permittee has conducted in the prior calendar year. Reports shall be submitted to EPA Region 10 within 30 days of the end of the calendar year. This report shall include:
a. The number and type of carcasses disposed:
• Report the number of carcasses and the species.
b. A description of the general vicinity in which the carcasses were dispose:
• Describe the general area where the carcass(es) is(are) disposed using proximity to
cities, towns or latitude and longitude coordinates.
c. The name and contact information of the permittee:
• Provide the name and contact information of the permittee.
EPA collects information from persons who dispose of human remains pursuant to the burial at sea general permit codified in 40 CRF 229.1. The information is not required to be reported until after the burial has been conducted, specifically, within 30 days of the burial.
EPA sponsors collections of information as specified in the vessel disposal general permit. The collection process is codified in 40 CFR 229.3.
EPA collects information from persons who dispose of marine mammal carcasses. For Part A, the permittee may obtain concurrence via telephone and then submit information within 30 days after carcass disposal. For Part B, any Alaskan Native shall submit reports to EPA within 30 days of the end of the calendar year.
Burials conducted under the burial at sea general permit are to be reported within 30 days to the EPA Regional Administrator of the EPA Region from which the vessel carrying the remains departed.
In 2018, EPA implemented an online reporting tool (https://burialatsea.epa.gov/) for persons to report burials at sea. This tool creates consistency, facilitates compliance with 40 CFR 229.1(d), and reduces burdens on respondents by allowing for online reporting. This tool provides better information management by centrally recording and storing the burial at sea activity covered by the general permit.
Under the general permit for transportation and disposal of vessels, information is collected and managed by EPA, U.S. Coast Guard (USCG), including the relevant USCG Captain-of-the-Port (COTP), and NOAA. Each of the following collections of information assists EPA in ensuring that material proposed for ocean dumping is appropriately regulated by relevant federal entities and does not harm human health or the marine environment.
The corresponding EPA Region collects all information pertaining to a vessel disposal and submits it to EPA Headquarters, where it is stored in a database. EPA submits an annual ocean dumping report to the International Maritime Organization. EPA’s ocean dumping website includes an interactive map, which includes location and basic information of all vessels disposals which occurred from 2006-2021.
Disposals of marine mammal carcasses conducted under the general permit for Part A are to be reported within 30 days to the applicable EPA Regional Administrator of the EPA Region from which the carcass is disposed and for Part B to EPA Region 10 within 30 days of the end of the calendar year. EPA Regions keep record of all reports, including faxes, emails, mail, and other online submissions. The total number of marine mammal carcasses disposed for each EPA Region is reported to EPA Headquarters.
EPA certifies that this chapter of the ICR will not have a significant economic impact on a substantial number of small entities. While the three general permits described in this chapter of the ICR are available to any private person or entity, or any officer, employee, agent, department, agency, or instrumentality of the federal government, of any state or local unit of government, or of any foreign government, the transportation and disposal of vessels general permit and the ocean disposal of marine mammal carcasses permit are used much more infrequently than the burial at sea general permit. Respondents to the burial at sea permit are estimated to be less than 1 hour with a total cost estimate of less than $39.00 per response.
Reporting for each of the general permits depends on how many respondents choose to use the general permit. For burials at sea, EPA assumes an average of 2,475.7 events per year. For vessel disposals, EPA assumes an average of 2.7 events per year. For disposal of marine mammal carcasses, EPA assumes an average of 9 events per year for Part A General Permits and 1 event per year for Part B Alaskan Native engaged in subsistence uses. See Section 6 below for information on how these values were determined.
Under 40 CFR 229.1(d), a burial conducted under the burial at sea general permit must be reported within 30 days to the Regional Administrator of the EPA Region from which the vessel carrying the deceased’s remains departed.
The collection schedule for the transportation and disposal of vessels general permit is described in 40 CFR 229.3(a)(1-9).
EPA collects information at four sequential time intervals under the transportation and disposal of vessels general permit, though the timing requirement of each need not apply in emergency situations.
EPA
EPA receives the following notifications:
One month prior to disposal (40 CFR 229.3(a)(1)).
Ten days prior to disposal – notification that vessel has been cleaned (40 CFR 229.3(a)(4).
Forty-eight (48) hours prior to disposal (40 CFR 229.3(a)(8)).
Twelve (12) hours prior to departure (40 CFR 229.3(a)(8)).
USCG
Under 40 CFR 229.3(a)(4) and 229.3(a)(8), USCG receives notification no later than 10 days prior to the proposed disposal date that the vessel has been cleaned and is available for inspection. The COTP at USCG also receives confirmatory notification. Under 40 CFR 229.3(a)(8), the COTP receives notification 48 hours prior to the proposed disposal and telephonic notification 12 hours prior to the vessel’s departure from port.
NOAA
Under 40 CFR 229.3(a)(9), NOAA receives notification in writing within one week after the disposal with the exact coordinates of the disposal site so that it may be marked on appropriate charts.
The collection schedule for the reporting of marine mammal carcass disposal is described in the general permit. For Part A, the permittee may obtain concurrence via telephone and then submit information within 30 days after carcass disposal. For Part B, any Alaskan Native shall submit reports to EPA within 30 days of the end of the calendar year.
This section estimates the annual burden for the burial at sea, transportation and disposal of vessels, and disposal of marine mammal carcasses general permits information collection burden hours/costs. The estimates were reviewed by respondents who had previously participated in burials at sea, vessel disposals, and/or carcass disposals. The estimated burden hours reflect the time taken to assemble and submit written information needed for a burial at sea, vessel disposal, and/or carcass disposal.
The estimated burden per respondent to complete reporting requirements for the burial at sea general permit is 0.83 hours. The activities required to complete notification requirements for a vessel disposal under the transportation and disposal of vessels general permit is broken down into four main categories. The estimated burden per respondent is 15.0 hours to complete activities related to a one-month notification, 10.0 hours for the notification of vessel cleaning and inspection, 9.5 hours for a 12- and 48-hour notification and 1.0 hour for the submission of coordinates. The EPA estimates a total of 35.5 hours per respondent to complete all activities pertaining to a vessel disposal under the general permit. The estimated burden for respondents under Section A of the marine mammal carcass disposal general permit is 8.5 hours. For Alaskan Natives under Section B of the marine mammal carcass disposal general permit, the estimated burden is 2.5 hours per response. The total burden per year was calculated by multiplying the burden hours per response by the number of respondents, which corresponds to the number of respondents expected to use the permit per year. This analysis is shown in Tables 18 through 24. See section 6(d) of Chapter 2 of this supporting statement for a description of how the respondent numbers (i.e., respondent universe) were estimated.
To estimate the labor costs, EPA used labor and cost-rate data listed on the U.S. Bureau of Labor Statistics (BLS) Compensation Cost Trends homepage.9 EPA used the following labor categories for the burial at sea, transportation and disposal of vessels, and disposal of marine mammal carcasses general permits, respectively:
Burial at Sea
Office and administrative support occupations10 (Clerical)
Vessel Disposal
Ship and boat captains and operators13 (Management)
Compliance officers14 (Technical)
Office and administrative support occupations15 (Clerical)
3) Disposal of Marine Mammal Carcasses
Manager16 (Management)
Compliance officers17 (Technical)
Office and administrative support occupations18 (Clerical)
EPA used the mean hourly figures listed by BLS to approximate the labor burdened hourly rates for the occupational categories contained in this chapter of the ICR. EPA used the 90th percentile hourly wage for the funeral home director’s hourly wage. These are listed below in Tables 15 and 16.
Table 15. Respondent Labor Costs: Burial at Sea Hourly Loaded Wage Estimate of Affected Industry [40 CFR 229.1]
BLS: Occupational Earnings 2021 |
ICR Agency Job Classification |
Hourly Rate |
Benefits Factor |
Loaded Hourly Rate |
Funeral Home Director |
Management |
$39.86/hr |
1.3 |
$50.52/hr |
Ship and boat captains and operators |
Management |
$47.27/hr |
1.3 |
$61.45/hr |
Average rate (ship and boat captains and operators and funeral home director) |
Management (Avg.) |
$43.57/hr |
1.3 |
$56.64/hr |
Office and administrative support occupations |
Clerical |
$20.88/hr |
1.3 |
$27.14/hr |
Table 16. Respondent Labor Costs: Vessel Disposal Hourly Loaded Wage Estimate of Affected Industry [40 CFR 229.3]
BLS: Occupational Earnings May 2021 |
ICR Agency Job Classification |
Hourly Rate |
Benefits Factor |
Loaded Hourly Rate |
Ship and boat captains and operators |
Management |
$47.27/hr |
1.3 |
$61.45/hr |
Compliance officers |
Technical |
$36.45/hr |
1.3 |
$47.39/hr |
Office and administrative support occupations |
Clerical |
$20.88/hr |
1.3 |
$27.14/hr |
Table 17. Respondent Labor Costs: Disposal of Marine Mammal Carcasses Hourly Loaded Wage Estimate of Affected Industry for Parts A and B [40 CFR 222.1-221.2]
BLS: Occupational Earnings May 2021 |
ICR Agency Job Classification |
Hourly Rate |
Benefits Factor |
Loaded Hourly Rate |
Manager |
Management |
$59.31/hr |
1.3 |
$77.10/hr |
Compliance officers |
Technical |
$36.45/hr |
1.3 |
$47.39/hr |
Office and administrative support occupations |
Clerical |
$20.88/hr |
1.3 |
$27.14/hr |
Non-labor O&M includes costs for photocopying, postage, telephone charges, expenses, and contracted services. Contracted services costs include costs for vessel cleaning before a vessel disposal as required by the general permit.
In summary, the estimated labor cost to complete all activities required under the burial at sea general permit is $37.28 per response.
The activities required to complete the reporting requirements of a vessel disposal under the transportation and disposal of vessels general permit is broken down into four main categories. The estimated labor cost per respondent is $675.59 to complete activities related to a one-month notification, $509.02 for the notification of vessel cleaning and inspection, $465.94 for a 12 and 48-hour notification, and $54.42 for the submission of coordinates. EPA estimates a total labor cost of $1,704.97 per respondent to complete all activities pertaining to the reporting requirements for a vessel disposal under the general permit. Annualized costs are based on the number of respondents expected to use the permit per year and include both labor costs and non-labor O&M costs.
Table 18. Respondent Burden and Cost for Burial at Sea General Permit [40 CFR 229.1]
Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
||||||
Mgmt. (Avg.) $56.64/hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. 1. Respondent conducts Burial at Sea |
|
|
|
|
|
|
|
|
a. Prepare and review information necessary to complete reporting questions |
0.50 |
0.00 |
0.50 |
$28.32 |
$1.00 |
2475.67 |
1,237.83 |
$72,587.78 |
b. Submit information to EPA |
0.00 |
0.33 |
0.33 |
$8.96 |
$1.00 |
2475.67 |
816.97 |
$24,651.50 |
Subtotal (hours and costs) |
0.50 |
0.33 |
0.83 |
$37.28 |
$2.00 |
2475.67 |
2,054.80 |
$97,239.28 |
Table 19. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 229.3(a)(1) – 1 Month Notification to EPA
Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $61.45/ hr |
Technical $47.39/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Preparation |
|
|
|
|
|
|
|
|
|
a. Read regulations |
0.50 |
0.50 |
0.00 |
1.00 |
$54.42 |
$0.00 |
2.67 |
2.67 |
$145.11 |
2. 2. Prepare information: |
|
|
|
|
|
|
|
|
|
a. a. Need for the disposal of the vessel |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$0.00 |
2.67 |
1.33 |
$81.93 |
b. Type and description of vessel to be disposed of and type of cargo normally carried |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$0.00 |
2.67 |
1.33 |
$63.18 |
c. Detailed description of the proposed disposal procedures |
0.00 |
1.00 |
0.00 |
1.00 |
$47.39 |
$0.00 |
2.67 |
2.67 |
$126.36 |
d. Information on the potential effect of the vessel disposal on the marine environment |
0.50 |
2.00 |
0.00 |
2.50 |
$125.50 |
$0.00 |
2.67 |
6.67 |
$334.65 |
e. Documentation of an adequate evaluation of alternatives to ocean disposal |
1.00 |
3.00 |
0.00 |
4.00 |
$203.61 |
$0.00 |
2.67 |
10.67 |
$542.95 |
3. Review and edit information for accuracy |
1.00 |
0.00 |
2.00 |
3.00 |
$115.74 |
$0.00 |
2.67 |
8.00 |
$308.64 |
4. Provide written information to EPA |
0.00 |
1.00 |
1.00 |
2.00 |
$74.53 |
$10.00 |
2.67 |
5.33 |
$225.41 |
Subtotal (hours and costs) |
4.00 |
8.00 |
3.00 |
14.50 |
$675.59 |
$10.00 |
2.67 |
38.67 |
$1,828.24 |
Table 20. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 229.3(a)(4) – 10 days Notification that the Vessel has been Cleaned and is Available for Inspection
Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $61.45/ hr |
Technical $47.39 hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Preparation |
|
|
|
|
|
|
|
|
|
a. Read regulations |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$0.00 |
2.67 |
1.34 |
$63.26 |
b. Ensure that the requirements listed in 40 CFR 229.3(a)(3) are met |
0.50 |
5.00 |
0.00 |
5.50 |
$267.65 |
$0.00 |
2.67 |
14.69 |
$714.63 |
2. Notify Coast Guard that the vessel has been cleaned and is ready for inspection |
1.00 |
1.00 |
0.00 |
2.00 |
$108.84 |
$5.00 |
2.67 |
5.34 |
$303.94 |
3. Notify EPA that the vessel has been cleaned and is ready for inspection |
1.00 |
1.00 |
0.00 |
2.00 |
$108.84 |
$5.00 |
2.67 |
5.34 |
$303.94 |
Subtotal (hours and costs) |
2.50 |
7.50 |
0.00 |
10.00 |
$509.02 |
$10.00 |
2.67 |
26.70 |
$1,385.77 |
Table 21. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 229.3(a)(8) – 12- and 48-Hour Notifications
Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $61.45/ hr |
Technical $47.39/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Read regulations |
0.00 |
0.00 |
0.00 |
0.00 |
$0.00 |
$0.00 |
2.67 |
0 |
$0.00 |
2. Prepare the following information for notification per 40 CFR 229.3(a)(8) |
|
|
|
|
|
|
|
|
|
Proposed departure time and place |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$5.00 |
2.67 |
1.34 |
$76.61 |
Proposed disposal site location |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$5.00 |
2.67 |
1.34 |
$76.61 |
c. Estimated time of arrival on site |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$5.00 |
2.67 |
1.34 |
$76.61 |
d. Name and communication capability of the towing vessel |
0.00 |
1.00 |
0.00 |
1.00 |
$47.39 |
$5.00 |
2.67 |
2.67 |
$139.87 |
3. Review and edit information for accuracy |
1.00 |
1.00 |
2.00 |
4.00 |
$163.12 |
$5.00 |
2.67 |
10.68 |
$448.89 |
4. Notify EPA 48 hours prior to disposal |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$5.00 |
2.67 |
1.34 |
$95.39 |
5. Notify Coast Guard 48 hours prior to disposal |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$5.00 |
2.67 |
1.34 |
$95.39 |
6. Notify COTP 48 hours prior to disposal |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$5.00 |
2.67 |
1.34 |
$95.39 |
7. Telephonically notify EPA 12 hours prior to vessel’s departure |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$5.00 |
2.67 |
1.34 |
$95.39 |
8. Telephonically notify Coast Guard 12 hours prior to vessel’s departure |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$5.00 |
2.67 |
1.34 |
$95.39 |
9. Telephonically notify COTP 12 hours prior to vessel’s departure |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$5.00 |
2.67 |
1.34 |
$95.39 |
Subtotal (hours and costs) |
4.00 |
3.50 |
2.00 |
9.50 |
$465.94 |
$55.00 |
2.67 |
25.37 |
$1,390.91 |
Table 22. Vessel Disposal General Permit Respondent Burden and Cost under 40 CFR 229.3(a)(9) – Submission of Exact Coordinates of Disposal to NOAA
Information Collection Activity |
Total Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $61.45/ hr |
Technical $47.45/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Preparation |
|
|
|
|
|
|
|
|
|
a. Read regulations |
0.00 |
0.00 |
0.00 |
0.00 |
$0.00 |
$0.00 |
2.67 |
0.00 |
$0.00 |
b. Prepare and verify coordinates of disposal |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$0.00 |
2.67 |
1.34 |
$63.26 |
1. 2. Submit coordinates of disposal to NOAA |
0.50 |
0.00 |
0.00 |
0.50 |
$30.73 |
$10.00 |
2.67 |
1.34 |
$108.74 |
Subtotal (hours and costs) |
0.50 |
0.50 |
0.00 |
1.00 |
$54.42 |
$10.00 |
2.67 |
2.67 |
$172.00 |
The activities required to complete the reporting requirements of a marine mammal carcass disposal under the general permit for ocean disposal of marine mammal carcasses is broken down into two main categories. The estimated labor cost per respondent is $436.59 to complete activities related to a Part A – marine mammal General Permit and $133.32 for the notification of Part B - Alaskan Native engaged in subsistence uses to complete reporting. Annualized costs are based on the number of respondents expected to use the permit per year and include both labor costs and non-labor O&M costs.
Table 23. Disposal of Marine Mammal Carcasses General Permit Respondent Burden and Cost under 40 CFR 220.4
Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $77.10/ hr |
Technical $47.39hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Preparation |
|
|
|
|
|
|
|
|
|
a. Read permit |
0.00 |
0.00 |
0.00 |
0.00 |
$0.00 |
$0.00 |
9.00 |
0.00 |
$0.00 |
2. b. Describe carcass |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$0.00 |
9.00 |
4.50 |
$213.23 |
a. c. Record date, time and location |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$0.00 |
9.00 |
4.50 |
$213.23 |
d. Provide contact information for the person in charge of disposal operation and vessel |
0.00 |
1.00 |
0.00 |
1.00 |
$47.39 |
$10.00 |
9.00 |
9.00 |
$516.47 |
e. Statement of need and rationale for ocean disposal |
1.00 |
1.00 |
1.00 |
3.00 |
$151.63 |
$0.00 |
9.00 |
27.00 |
$1,364.69 |
f. Submit information to EPA |
0.50 |
0.00 |
0.00 |
0.50 |
$38.55 |
$0.00 |
9.00 |
4.50 |
$346.96 |
2. Immediately notify EPA of any violation |
1.00 |
1.00 |
1.00 |
3.00 |
$151.63 |
$0.00 |
9.00 |
27.00 |
$1,364.69 |
Subtotal (hours and costs) |
2.50 |
4.00 |
2.00 |
8.50 |
$436.59 |
$10.00 |
9.00 |
76.50 |
$4,019.27 |
Table 24. Disposal of Marine Mammal Carcasses General Permit for Alaskan Native Engaged in Subsistence Respondent Burden and Cost under 40 CFR 220.4
Information Collection Activity |
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $77.10/ hr |
Technical $47.39/ hr |
Clerical $27.14/ hr |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Preparation |
|
|
|
|
|
|
|
|
|
a. Read permit |
0.00 |
0.00 |
0.00 |
0.00 |
$0.00 |
$0.00 |
1.00 |
0.00 |
$0.00 |
2. b. Record number and type of carcass(es) |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$0.00 |
1.00 |
0.50 |
$23.69 |
a. c. Describe general vicinity of disposal |
0.00 |
1.00 |
0.00 |
1.00 |
$47.39 |
$0.00 |
1.00 |
1.00 |
$47.39 |
d. Provide contact information for the person in charge of disposal |
0.00 |
0.50 |
0.00 |
0.50 |
$23.69 |
$0.00 |
1.00 |
0.50 |
$23.69 |
e. Submit information to EPA |
0.50 |
0.00 |
0.00 |
0.50 |
$38.55 |
$10.00 |
1.00 |
0.50 |
$48.55 |
Subtotal (hours and costs) |
0.50 |
2.00 |
0.00 |
2.50 |
$133.32 |
$10.00 |
1.00 |
2.50 |
$143.32 |
EPA’s labor costs data associated with this chapter of the ICR reflect the pay scale rates for GS-9, GS-12, and GS-14 employees. EPA’s labor costs apply to the Agency job classifications listed in Table 25 (below) for:
GS-14 (Management)
GS-12 (Technical)
GS-9 (Clerical)
To arrive at the loaded hourly rates listed in Table 25, hourly rates were multiplied by 160% to reflect a fully loaded (wages + benefits) hourly rate.
Table 25. Agency Labor Costs [40 CFR 229.1, 229.3] Hourly Loaded Agency Wage Estimate
ICR Agency Job Classification |
January 2021 Annual GS Salary (Step 1) |
Work Hours Per Year Factor |
Benefits Factor |
Loaded Hourly Rate |
Management |
GS-14, $126,233 |
2,080 |
1.6 |
$ 97.10/hr |
Technical |
GS-12, $89,834 |
2,080 |
1.6 |
$ 69.10/hr |
Clerical |
GS-9, $61,947 |
2,080 |
1.6 |
$47.65/hr |
In summary, the estimated EPA burden per respondent to complete activities related to the burial at sea general permit is 0.11 hours with a labor cost per respondent of $6.90. The estimated EPA burden per respondent to complete activities related to the vessel disposal general permit is 9.0 hours with a labor cost per respondent of $666.37. The estimated EPA burden per respondent to complete activities related to disposal of marine mammal carcasses at sea is 2.0 hours with a labor cost per respondent of $125.51. Annualized burden and costs are based on the number of permits expected per year. This analysis is shown in Tables 26, 27, 28 and 29.
Table 26. Burial at Sea General Permit Agency (EPA) Burden and Cost [40 CFR 229.1]
Information Collection Activity
|
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/ hour |
Technical $ 69.10/ hour |
Clerical $47.65/ hour |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($)* |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. 1. Respondent conducts Burial at Sea and submits information to EPA |
|
|
|
|
|
|
|
|
|
a. Review recorded information as submitted and verify the information for accuracy and completeness |
0.00 |
.10 |
0.00 |
0.10 |
$6.91 |
$0.10 |
2475.7 |
247.57 |
$17,355.21 |
b. Organize and maintain submissions |
0.00 |
.01 |
0.00 |
0.01 |
$0.69 |
$0.10 |
2475.7 |
24.76 |
$1,958.33 |
Subtotal (hours and costs) |
0.00 |
.11 |
0.00 |
0.11 |
$7.60 |
$0.20 |
2475.7 |
272.32 |
$19,313.54 |
Table 27. Vessel Disposal General Permit Agency (EPA) Burden and Cost under 40 CFR 229.3(a)(1)-(a)(8)
Information Collection Activity |
Total Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/ hour |
Technical $ 69.10/ hour |
Clerical $47.65/ hour |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($) |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year |
|
1. EPA receives notice no later than 1 month prior to vessel disposal date, recording and reviewing the required information |
0.50 |
1.00 |
0.00 |
1.50 |
$117.65 |
$5.00 |
2.67 |
4.01 |
$327.49 |
2. No later than 10 days prior to the proposed disposal date under 40 CFR 229.3(a)(4), EPA receives notification that the vessel has been cleaned and is available for inspection |
1.00 |
1.00 |
0.00 |
2.00 |
$166.21 |
$5.00 |
2.67 |
5.34 |
$457.12 |
3. EPA reviews the information provided, coordinating with Coast Guard, in determining whether the requirements of 40 CFR 229.3(a)(3) are met |
1.00 |
1.00 |
0.00 |
2.00 |
$166.21 |
$5.00 |
2.67 |
5.34 |
$457.12 |
3. 4. Under 40 CFR 229.3(a)(8), EPA receives notification no later than 48 hours prior to the proposed disposal date |
0.50 |
0.00 |
0.00 |
0.50 |
$48.55 |
$5.00 |
2.67 |
1.34 |
$142.98 |
. 5. Under 40 CFR 229.3(a)(8), EPA receives telephonic notification at least 12 hours in advance of the vessel’s departure from port, recording and reviewing the information required |
1.00 |
2.00 |
0.00 |
3.00 |
$235.31 |
$10.00 |
2.67 |
8.01 |
$654.97 |
Subtotal (hours and costs) |
4.00 |
5.00 |
0.00 |
9.00 |
$733.92 |
$30.00 |
2.67 |
24.03 |
$2,039.68 |
Table 28. Disposal of Marine Mammal Carcasses General Permit Agency (EPA) Burden and Cost under 40 CFR 220.4
Information Collection Activity
|
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/ hour |
Technical $ 69.10/ hour |
Clerical $47.65/ hour |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($)* |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. 1. Respondent conducts marine mammal disposal and submits information to EPA |
|
|
|
|
|
|
|
|
|
a. Review recorded information as submitted and verify the information for accuracy and completeness |
0 |
1 |
0 |
1 |
$69.10 |
$0.00 |
9.00 |
9.00 |
$621.93 |
b. Organize and maintain . submissions |
0 |
1 |
0 |
1 |
$69.10 |
$0.00 |
9.00 |
9.00 |
$621.93 |
Subtotal (hours and costs) |
0.00 |
2.00 |
0.00 |
2.00 |
$138.21 |
$0.00 |
9.00 |
18.00 |
$1,243.86 |
Table 29. Disposal of Marine Mammal Carcasses for Alaskan Native Engaged in Subsistence Uses General Permit Agency (EPA) Burden and Cost under 40 CFR 220.4
Information Collection Activity
|
Hours and Costs Per Response |
Total Hours and Costs Per Year |
|||||||
Mgmt. $97.10/ hour |
Technical $ 69.10/ hour |
Clerical $47.65/ hour |
Total Hours/ Response |
Labor Cost/ Response |
O & M Cost ($)* |
Number Responses/ Year |
Total Hours/ Year |
Total Cost/ Year ($) |
|
1. Alaskan Native respondent conducts marine mammal disposal and submits information to EPA |
|
|
|
|
|
|
|
|
|
a. Review recorded information as submitted and verify the information for accuracy and completeness |
0 |
1 |
0 |
1 |
$69.10 |
$0.00 |
1.00 |
1.00 |
$69.10 |
b. Organize and maintain submissions |
0 |
1 |
0 |
1 |
$69.10 |
$0.00 |
1.00 |
1.00 |
$69.10 |
Subtotal (hours and costs) |
0.00 |
2.00 |
0.00 |
2.00 |
$138.21 |
$0.00 |
1.00 |
2.00 |
$138.21 |
The potential respondent universe for the burial at sea general permit is any person who disposes of human remains pursuant to the permit. The number of respondents was based on historical data. The number of respondents used for burial at sea is the average of the number of persons who have used this permit during a previous three-year time frame (2019-2021) in which data were available. EPA expects approximately 2,475.67 responses per year. The potential respondent universe for the transportation and disposal of vessels general permit is for all persons subject to title I of the MPRSA who dispose of the vessel pursuant to the permit. The number of respondents used for vessel disposals is the average number of vessels disposed of under this general permit during a previous three-year time frame (2019-2021) as reported in the Ocean Dumping Reports. EPA expects approximately 2.67 vessel disposals and 10.00 marine mammal carcass disposals per year.
The total estimated ocean dumping burdens and costs associated with Chapter 2 of the ICR are as follows:
1) Respondent
Respondents per year: 2,488.34
Total hours per year: 2,227.21
Total labor cost per year: $100,900.54
Total annual O&M costs: $5,278.25
Total annual cost: $106,178.79
1) Agency
Respondents per year: 2,488.34
Total hours per year: 316.35
Total labor cost per year: $22,160.05
Total annual O&M costs: $575.43
Total annual cost: $22,743.08
The total estimated ocean dumping burdens associated with Chapter 2 are summarized in Tables 30 and 31 for respondents and agencies, respectively.
Table 30. Total Burial at Sea, Vessel Disposal, and Disposal of Marine Mammal Carcasses General Permits Respondent Burden and Costs* under 40 CFR 229.3
Respondent Total |
Number of Respondents Per Year |
Total Number of Hours Per Year |
Total Labor Cost Per Year ($) |
Total Annual O&M Costs ($) |
Total Cost Burden ($)
|
Burial at Sea |
2475.67 |
2,054.80 |
$92,287.95 |
$4,951.33 |
$97,239.28 |
Vessel Disposal |
2.67 |
93.40 |
$4,550.00 |
$226.92 |
$4,776.92 |
Disposal of Marine Mammal Carcasses |
10.00 |
79.00 |
$4,062.59 |
$100.00 |
$4,162.59 |
TOTAL |
2,488.34 |
2,227.20 |
$100,900.54 |
$5,278.25 |
$106,178.79 |
* These data are from Tables 18 through 24.
Table 31. Total Burial at Sea, Vessel Disposal and Disposal of Marine Mammal Carcasses General Permit Agency (EPA) Burden and Costs* under 40 CFR 229.3
Agency Total |
Number of Respondents Per Year |
Total Number of Hours Per Year |
Total Labor Cost Per Year ($) |
Total Annual O&M Costs ($) |
Total Cost Burden ($)
|
Burial at Sea |
2,475.67 |
272.32 |
$18,818.41 |
$495.13 |
$19,313.54 |
Vessel Disposal |
2.67 |
24.03 |
$1,959.58 |
$80.10 |
$2,039.68 |
Disposal of Marine Mammal Carcasses |
10.00 |
20.00 |
$1,382.06 |
$0.00 |
$1,382.06 |
TOTAL |
2,488.34 |
316.35 |
$22,160.05 |
$575.23 |
$22,735.28 |
* These data are from Tables 25 through 29.
There is decrease in the burden for the permits covered in Chapter 2. When compared to the currently approved ICR, there is a decrease in the Total Hours from 2,426 to 2,227 and a decrease in the Total Annual Burden from $134,400.09 to $106,178.79. The reductions in the estimated Total Hours and Total Annual Burden are due to a reduction in the estimated number of general permit applications. This reduced estimate is based on a review of the actual average number of permits from the last 3 years and using that average to estimate future activity.
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 0.83 hours per response for Burial at Sea general permits, 35.0 hours per response for Vessel Disposal general permits, 8.5 hours for Section A Marine Mammal Carcass general permits, and 2.5 hours per response for Section B for Alaskan Natives engaged in subsistence use general permits. 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 Number EPA-HQ-OW-2015-0613, which is available for online viewing at www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. 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 Water Docket is (202) 566-2426. An electronic version of the public docket is available at www.regulations.gov. This site can be used 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. When 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, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OW-2015-0613 and OMB Control Number 2040-0008 in any correspondence.
1 For the purposes of this ICR, incineration at sea permits are included in the “research permit” category of MPRSA permits. Under 40 CFR 220.3(f), “permits for incineration of wastes at sea will be issued only as research permits until specific criteria to regulate this type of disposal are promulgated, except in those cases where studies on the waste, the incineration method and vessel, and the site have been conducted and the site has been designated for incineration at sea in accordance with the procedures of § 228.4(b) of this chapter. In all other respects the requirements of parts 220 through 228 apply.” The opportunity for research permits for incineration at sea excludes the incineration of industrial wastes, which may not be ocean dumped as a result of the Ocean Dumping Ban Act amendments to the MPRSA.
2 EPA may issue a general permit upon application by an interested person or may be issue without such an application. 40 CFR 220.3(a).
3 The BLS webpage is available on-line at: http://www.bls.gov/ncs/ect/.
4 For management labor costs, EPA used the website titled Occupational Employment and Wages, May 2021, available online at: http://www.bls.gov/oes/current/oes110000.htm.
5 For technical labor costs, EPA used the website titled Occupational Employment and Wages, May 2021, available online at: http://www.bls.gov/oes/current/oes192041.htm.
6 For office and administrative support occupations, EPA used the website titled Occupational Employment and Wages, May 2021, available online at: http://www.bls.gov/oes/current/oes430000.htm.
7 The above labor rate data are “fully burdened” or “hourly loaded” and include wages/salaries, and overhead and fringe benefits of the affected industry. EPA added 30 percent to the indicated average hourly wage to allow for overhead and fringe benefits. Only fully burdened BLS labor cost data are used in the analysis described in all chapters of the ICR.
8 http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2022/general-schedule/. The salary scales contained in Table 2 were effective January 2022; EPA used Step 1 of the General Schedule (GS) salaries for the ICR analysis. The 2022 GS Locality Pay Tables can be found at http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/22Tables/html/DCB.aspx. The annual GS salary rates were converted to hourly rates according to instructions in Section 6(c) if the EPA ICR Handbook (12/96 version). Total salaries were divided by 2,080, which represent the average number of hours work in a calendar year, and then multiplied by a factor of 1.6. The benefits factor “multiplier” represents the standard government benefits multiplication factor. The loaded hourly rate listed in Table 2 reflects the true cost to the federal government to employ a federal worker for one hour.
9 The BLS homepage is available on-line at: http://www.bls.gov/ncs/ect/.
10 For clerical hourly rates, EPA used the website titled Occupational Employment and Wages, May 2021, available online at: http://www.bls.gov/oes/current/oes430000.htm.
11 For management (funeral director) hourly rate, EPA used the website titles Occupational Employment and Wages, 11-9171 Funeral Service Manages, May 2021, available online at: http://www.bls.gov/oes/current/oes119061.htm.
12 For management hourly rate, EPA used the website titled Occupational Employment and Wages, 53-5021 Captains, Mates, and Pilots of Water Vessels, May 2021, available online at: http://www.bls.gov/oes/current/oes535021.htm.
13 For management hourly rate, EPA used the website titled Occupational Employment and Wages, 53-5021 Captains, Mates, and Pilots of Water Vessels, May 2021, available online at: http://www.bls.gov/oes/current/oes535021.htm.
14 For technical hourly rate, EPA used the website titled Occupational Employment and Wages, 13-1041 Compliance Officers, May 2021, available online at: http://www.bls.gov/oes/current/oes131041.htm.
15 For clerical hourly rate, EPA used the website titled Occupational Employment and Wages, May 2021, available online at: http://www.bls.gov/oes/current/oes430000.htm.
16 For management labor costs, EPA used the website titled Occupational Employment and Wages, May 2021, available online at: http://www.bls.gov/oes/current/oes110000.htm.
17 For technical hourly rate, EPA used the website titled Occupational Employment and Wages, 13-1041 Compliance Officers, May 2021, available online at: http://www.bls.gov/oes/current/oes131041.htm.
18 For clerical hourly rate, EPA used the website titled Occupational Employment and Wages, May 2021, available online at: http://www.bls.gov/oes/current/oes430000.htm.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | INFORMATION COLLECTION REQUEST (ICR) |
| Author | newuser |
| File Modified | 0000-00-00 |
| File Created | 2023-08-27 |