SUPPORTING STATEMENT FOR

EPA INFORMATION COLLECTION REQUEST NUMBER 2002.06

“CROSS-MEDIA ELECTRONIC REPORTING RULE” 

October 17, 2014

Office of Environmental Information

U.S. Environmental Protection Agency

Washington, D.C. 20460
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION.......................................................1

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION ......................................1

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION.....................................1

2. NEED FOR AND USE OF THE COLLECTION ..............................................................................3

2(a) NEED AND AUTHORITY FOR THE COLLECTION...........................................................3

2(b) PRACTICAL UTILITY AND USERS OF THE DATA ..........................................................4

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA................6

3(a) NONDUPLICATION ...............................................................................................................6

3(b) PUBLIC NOTICE .....................................................................................................................6

3(c) CONSULTATIONS..................................................................................................................6

3(d) EFFECTS OF LESS FREQUENT COLLECTION ..................................................................7

3(e) GENERAL GUIDELINES........................................................................................................8

3(f) CONFIDENTIALITY...............................................................................................................8

3(g) SENSITIVE QUESTIONS........................................................................................................8

4. THE RESPONDENTS AND THE INFORMATION REQUESTED ................................................9

4(a) RESPONDENTS AND NAICS CODES ..................................................................................9

4(b) INFORMATION REQUESTED...............................................................................................9

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT ......................................................16

5(a) AGENCY ACTIVITIES .........................................................................................................16

5(b) COLLECTION METHODOLOGY AND MANAGEMENT ................................................17

5(c) SMALL ENTITY FLEXIBILITY...........................................................................................17

5(d) COLLECTION SCHEDULE..................................................................................................17

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION ..............................19

6(a) ESTIMATING RESPONDENT BURDEN HOURS..............................................................19

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN ....................................................22

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND

COST BURDEN .....................................................................................................................22

6(e) BOTTOM LINE HOUR AND COST BURDEN ...................................................................32

6(f) REASONS FOR CHANGE IN BURDEN..............................................................................33

6(g) PUBLIC BURDEN STATEMENT.........................................................................................36
1

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) TITLE AND NUMBER OF THE INFORMATION COLLECTION

This Information Collection Request (ICR) is entitled “Cross-Media Electronic Reporting

Rule,” EPA ICR Number 2002.06, OMB Control Number 2025-0003.

1(b) CHARACTERIZATION OF THE INFORMATION COLLECTION

The U.S. Environmental Protection Agency (EPA) allows regulated entities to report 

electronically to EPA by allowing the use of electronic document receiving systems to receive 

electronic documents in satisfaction of certain document submission requirements in EPA’s 

regulations.1 The Cross-Media Electronic Reporting Rule (CROMERR) also allows State, 

Tribal, and local governments to seek EPA approval, as provided under 40 Code of Federal 

Regulations (CFR) 3.1000, to accept electronic documents to satisfy reporting requirements 

under authorized or delegated environmental programs that they administer. In seeking EPA 

approval, these State, Tribal, and local governments must upgrade existing electronic document 

receiving systems or develop new electronic document receiving systems to satisfy the criteria 

laid out at 40 CFR 3.2000. Regulated entities that use an electronic signature device in 

submitting electronic documents to the EPA or a State, Tribal, or local government receiving 

system must comply with identity proofing requirements, as applicable. In the remainder of this 

document, we refer to State, Tribal, and local governments as “States/Locals” because, at the 

current time, EPA is not aware of any Tribal governments that have electronic document 

receiving systems or are planning to develop such systems during the next three years.

CROMERR does not require any regulated entity to report electronically to EPA or 

States/Locals. CROMERR establishes requirements for utilizing electronic reporting as an 

alternative to paper-based reporting. It does not require States/Locals to implement electronic 

reporting; rather, it establishes the framework for implementing the electronic reporting 

alternative for Federal laws that they administer. In this regard, regulated entities are affected 

only as follows:

 Entities that report electronically to EPA have to register with EPA’s electronic 

document receiving system (e.g., log on to the EPA Web site and enter requested 

information), comply with the identity proofing provisions, and then commence 

electronic reporting. In this document, we refer to these entities as “direct reporters.”

 States/Locals must upgrade existing electronic document receiving systems or 

develop new electronic document receiving systems to meet 40 CFR 3.2000 

requirements. These States/Locals must apply for EPA program modification 

approval under 40 CFR 3.1000. They also must implement the identity proofing 

requirements at 40 CFR 3.2000(b)(5).

 

1

 In this document, EPA is using the term “electronic reporting” in a sense that excludes submission of a 

report via magnetic media, (i.e., via diskette, compact disc, or tape). EPA is also excluding transmission via hard 

copy facsimile. Likewise, EPA’s use of the term “electronic document” throughout this document refers exclusively 

to documents that are transmitted via a telecommunications network, excluding hard copy facsimile.
2

 Entities that report electronically to States/Locals must comply with the identity 

proofing requirements at 40 CFR 3.2000(b)(5). In this document, we refer to these 

entities as “indirect reporters.”

 Entities that opt to implement the local registration authority (LRA) alternative for 

identity proofing must identify an individual who will collect subscriber agreements 

from each individual that intends to use an electronic signature device in reporting 

electronically to a State/Local electronic document receiving system. In this 

document, we refer to these entities as “indirect reporting firms.”

 The LRA must collect and store subscriber agreements from individuals in his/her

indirect reporting firm. The LRA also must prepare an agreement collection 

certification and submit a certification of receipt and secure storage to the 

corresponding State/Local agency.

Sections 1 through 5 of this document describe the information collection requirements 

covered in this ICR (e.g., in regard to need and use of the information collected). Section 6 

estimates the annual burden to respondents. This ICR does not address the burden savings to 

respondents in reporting electronically under EPA programs. EPA’s programs will amend their 

program-specific ICRs to address these impacts. 

CROMERR establishes requirements applicable to electronic reporting and receiving 

systems, as specified. Many of the activities to be conducted by direct reporters will be 

determined by the instructions associated with EPA’s electronic document receiving system. 

Specifically, EPA has developed an Agency-wide receiving system, the Central Data Exchange 

(CDX), which guides direct reporters through the registration and reporting procedures. In 

developing this ICR, EPA referred to the regulatory text, as well as CDX, in describing direct 

reporters’ activities and associated burden.
3

2. NEED FOR AND USE OF THE COLLECTION

2(a) NEED AND AUTHORITY FOR THE COLLECTION

EPA established the CROMERR requirements to ensure compliance with the 

Government Paperwork Elimination Act (GPEA).2 GPEA requires that Federal agencies be 

prepared, by October 21, 2003, to allow persons who are required to maintain, submit, or 

disclose information, the option of doing so electronically, when practicable, as a substitute for 

paper; and to use electronic authentication (electronic signature) methods to verify the identity of 

the sender and the integrity of electronic content. GPEA specifically provides that electronic 

records, and their related electronic signatures, are not to be denied legal effect, validity, or 

enforceability merely because they are in electronic form.

(1) Registering with EPA Electronic Document Receiving System

Regulated entities must initially register with the EPA electronic document receiving 

system to establish a user account. EPA needs the registration information to identify the 

registrant, contact information, and registrant’s organization. Registrants also select a password 

and user name during registration. This information is needed to ensure that only the registrant 

has access to his/her account.

(2) Compliance with Identity Proofing Requirements

The identity proofing provisions in 40 CFR 3.2000(b)(5) are needed to strengthen the 

non-repudiation provisions of CROMERR. The electronic signature agreement, required in 

Section 3.2000(b)(5)(v), establishes that the signatory was informed of their obligation to keep 

the signature device from compromise, by ensuring that it is not made available to anyone else. 

These provisions are intended to ensure that the Federal laws regarding the falsification of 

information submitted to the government still apply to any and all electronic transactions, and 

that fraudulent electronic submissions will be prosecuted to the fullest extent of the law. In 

establishing clear requirements for electronic reporting systems, CROMERR helps to minimize 

fraud by assuring that the responsible individuals can be readily identified.

(3) Approval of State/Local Electronic Document Receiving System Applications

EPA needs information submitted by States/Locals in their program modification 

applications to evaluate the States/Locals’ upgraded or new electronic document receiving 

systems to ensure they satisfy the criteria at 40 CFR 3.2000. 

EPA also needs the information to evaluate whether the State/Local’s modified program 

has been satisfactorily revised or modified in regard to their electronic document receiving 

system. In particular, the application must include a certification that the State/Local has 

sufficient legal authority provided by lawfully enacted or promulgated statutes or regulations to 

implement the electronic reporting component of its authorized program covered by the 

 

2

 Title XVII of Pub. L. 105 277.
4

application; and to enforce the affected programs using electronic documents collected under 

these programs. The certification must be signed by the governmental official who is legally 

competent to certify with respect to legal authority on behalf of their government. In the case of 

a State, this official must be the Attorney General or designee. In the case of a Tribe or local 

government, this official must be the chief administrative official or officer or designee. As a 

legal matter, EPA’s position is that Attorneys General or their designees are the only officials 

capable of certifying with respect to their States’ legal authority. Where there are substantial 

administrative obstacles involving the Attorney General in such certifications, EPA urges the 

State Attorney General to provide for a legally competent designee who is available to 

participate in the submission of the State’s application. 

2(b) PRACTICAL UTILITY AND USERS OF THE DATA

(1) Registering with EPA Electronic Document Receiving System

Regulated entities must initially register with the EPA electronic document receiving 

system to establish a user account and create a password. EPA uses the information to identify 

the registrant (e.g., by name and/or organization), establish the account, and contact the registrant 

if needed. Regulated entities use the password to access their account and to protect it from 

unauthorized use.

(2) Compliance with Identity Proofing Requirements

EPA, States/Locals, and LRAs use the identity proofing information from registrants to 

determine each registrant’s identity and relationship to their regulated entity. The information 

may be used in an EPA or State/Local enforcement action to rebut a signatory’s attempt to 

repudiate their electronic signature and/or other elements of the document that was signed. 

When EPA or State/Local agency receives a subscriber agreement, certification of receipt 

and secure storage, or other identity-proofing information, the agency will review, process, and 

file the submittal. EPA or State/Local agency would then provide the registrant with access to 

the electronic document receiving system (e.g., open its account) so that it may begin using the 

electronic signature device in reporting electronically.

(3) Approval of State/Local Electronic Document Receiving System Applications

EPA uses the information submitted by States/Locals in their program modification 

applications to evaluate the States/Locals’ upgraded or new electronic document receiving 

systems against the criteria at 40 CFR 3.2000(b)(1)-(5). For example, EPA will review the 

application to determine if the systems are able to generate data as needed, and in a timely 

manner, including copy of record for each electronic document received, sufficient to prove that 

the electronic document was not altered without detection during transmission or at any time 

after receipt.
5

EPA also reviews the application to ensure that the State/Local has taken all necessary 

steps to modify its regulations and statutes, as needed, so that it has authority to implement 

electronic reporting and enforce the affected programs using electronic documents collected 

under its programs. This includes, among other things, an evaluation of the Attorney General’s 

certification under 40 CFR 3.1000(b)(1)(i).
6

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) NONDUPLICATION

CROMERR establishes uniform, Agency-wide criteria for electronic document receiving 

systems, thereby minimizing the potential for duplication or redundancy across EPA or 

State/Local programs. In addition, electronic reporting is voluntary, and will likely be used by 

facilities only if cost-effective and non-duplicative with their other compliance activities. 

CROMERR does not alter the reporting requirements under existing regulations and statutes, and 

does not affect whether a document must be created, submitted, or retained under the existing 

provisions 40 CFR.

3(b) PUBLIC NOTICE

In compliance with the Paperwork Reduction Act of 1995 (PRA), EPA issued a public 

notice in the Federal Register on [Insert date] ([Insert Federal Register citation]). The notice 

indicated that EPA was planning to submit an ICR, “Cross-Media Electronic Reporting Rule” 

(EPA ICR No. 2002.06, OMB Control No. 2025–0003), to the Office of Management and 

Budget (OMB) for review and approval in accordance with the PRA. The notice also requested 

comments on the information collection and burden estimates covered in the ICR. The public 

comment period extended through [Insert date]. 

[Insert summary of public comments received and a description of how the comments were 

considered in finalizing this supporting statement.] 

3(c) CONSULTATIONS

Most of the underlying assumptions in this ICR (e.g., hour and cost burden estimates) are 

based on EPA consultations with industry and States/Locals during the development of 

CROMERR and renewal of previous CROMERR ICRs. In developing this current ICR, EPA 

carefully reviewed all of the ICR’s data and assumptions and determined that a few should be 

strengthened based on additional consultations. 

Table 1 identifies the organizations contacted. 

Table 1

Organizations EPA Contacted during the Development of this ICR ([Insert month] 2014)

Organization Contact Name Phone Number
7

[Insert brief summary of consultation feedback.]

The above feedback is reflected in the burden assumptions of this ICR, as appropriate. 

Detailed information on EPA’s assumptions regarding these and other activities are fully 

discussed in Section 6 of this document. 

3(d) EFFECTS OF LESS FREQUENT COLLECTION

(1) Registering with EPA Electronic Document Receiving System

Facilities must initially register with the EPA electronic document receiving system to 

establish a user account. Registration information is collected at the time of registration (i.e., 

a one-time event) and updated if needed. Because it is a one-time activity, the information 

cannot be collected less frequently. If this information were not collected, EPA would not have a 

way to learn the identity of the registrant and establish its account.

(2) Compliance with Identity Proofing Requirements

Facilities must comply with the identity proofing provisions of CDX and 40 CFR 

3.2000(b)(5), as applicable. These provisions provide that, in the case of priority reports for 

which an electronic signature device was used to create an electronic signature, a determination 

of identity must be made before the electronic document is received. It is critical that registrants 

submit the identity proofing paperwork in advance of their priority reports so that the Agency 

can establish a link between each registrant and its electronic signature device to hold them 

accountable for their submittals. Facilities also must report any compromise or surrender of its 

electronic signature device to EPA or State/Local. 

LRAs must report any breach of storage of its subscriber agreements. These are asneeded submittals. If these reports were not collected, EPA and States/Locals would not have a 

way to learn about the signature compromise/surrender or storage breaches. Hence, they would 

not be in a position to take follow up action as needed (e.g., to temporarily prevent access to an 

account whose signature device has been compromised). This could result in the unauthorized 

use an electronic signature device.

(3) Approval of State/Local Electronic Document Receiving System Applications

CROMERR sets forth timeframes for EPA receipt, review, and approval of State/Local 

program modification applications to implement electronic document receiving systems. 

States/Locals that did not have an electronic document receiving system in use or substantially 

developed on or before October 13, 2005 must apply to EPA for program modification approval 

before receiving electronic documents (40 CFR 3.10000(a)(2)). If this frequency were not 

specified, EPA would not have assurance that States/Locals are developing and using electronic 

document receiving systems that comply with CROMERR’s provisions at 40 CFR 3.2000. 
8

3(e) GENERAL GUIDELINES

This ICR adheres to the guidelines stated in the PRA, OMB’s implementing regulations, 

applicable OMB guidance, and EPA’s ICR Handbook. 

EPA notes that subscriber agreements must be kept on file until five years after 

deactivation of the associated electronic signature device. A five-year retention period is 

necessary to ensure that such records are available in case of an EPA or State/Local enforcement 

action. EPA recognizes that a registrant may use an electronic signature device in signing a 

range of enforcement-sensitive reports. Certain reports may have relevance to an enforcement 

action long after it is submitted to EPA or State/Local. Because of this, EPA needed to establish 

a sufficiently long retention period for the subscriber agreements so that they would available for 

such enforcement actions.

3(f) CONFIDENTIALITY

If a confidentiality claim were asserted, EPA would treat the information in accordance 

with the confidentiality regulations at 40 CFR Part 2, Subpart B. EPA also would ensure that the 

information collection procedures comply with the Privacy Act of 1974 and the OMB Circular 

108.

3(g) SENSITIVE QUESTIONS

Persons registering with CDX are asked to provide knowledge-based information 

(e.g., date of birth) to ensure the security of their password, user name, and other information 

supplied. If the person loses his/her password or user name, or otherwise needs to confirm 

his/her identity to EPA, EPA could use the knowledge-based information to confirm his/her 

identity.
9

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) RESPONDENTS AND NAICS CODES

The information collection requirements covered in this ICR will likely have broad 

applicability across industries. Refer to Appendix A for a list of the North American Industry 

Classification System (NAICS) codes associated with industries most likely affected by these 

requirements.

4(b) INFORMATION REQUESTED

Following is a description of the data items and activities associated with the information 

collection requirements covered in this ICR. Refer to Section 1(b) for the types of respondents 

examined in this subsection.

(1) Registering with EPA Electronic Document Receiving System

Facilities must register their employees with CDX before reporting electronically to EPA. 

The employees must update their registration information if it changes.

(i) Data Items:

 An on-line registration application:

 Registrant name.

 Organization name.

 Address.

 Knowledge-based information (e.g., user-supplied secret question-andanswer pair).

(ii) Respondent Activities:

Facility employees must perform the following activities:

 Log on to receiving system site and enter requested information.

 Update the information, as needed.

(2) Compliance with Identity Proofing Requirements

Direct reporters, indirect reporters, indirect reporting firms, and LRAs must comply with 

the identity proofing provisions of CDX and CROMERR, as applicable. In addition, 

States/Locals that accept electronic documents to satisfy reporting requirements under authorized 

or delegated environmental programs that they administer must process, review, and approve the 

identity proofing information submitted by indirect reporters.
10

CDX and 40 CFR 3.2000(a)(2) require that any electronic document must bear the valid 

electronic signature of a signatory if that signatory would be required under the authorized 

program to sign the paper document for which the electronic document substitutes, except as 

otherwise specified. In the case of an electronic document that must bear electronic signatures of 

individuals as provided by CDX and 40 CFR 3.2000(a)(2), each signatory must sign either an 

electronic signature agreement, or a subscriber agreement with respect to the electronic signature 

device used to create their electronic signature on the electronic document.

CDX and 40 CFR 3.2000(b)(5)(vii) require that the identity of the individual uniquely 

entitled to use the device and their relation to any entity for which he or she will sign electronic 

documents must be determined with legal certainty by EPA or State/Local, as applicable. In the 

case of priority reports, this determination must be made before the electronic document is 

received, by means of:

 Identifiers or attributes that are verified by attestation of disinterested individuals to 

be uniquely true of the individual in whose name the application is submitted, based 

on information or objects of independent origin, at least one item of which is not 

subject to change without governmental action or authorization.

 A method of determining identity no less stringent than the one above.

 Collection of either a subscriber agreement or a certification from a LRA that such an 

agreement has been received and securely stored. 

The term “subscriber agreement” means an electronic signature agreement signed by an 

individual with a handwritten signature. The agreement must be signed by an individual with 

respect to an electronic signature device that the individual will use to create his/her electronic 

signature requiring such individual to protect the electronic signature device from compromise; 

to promptly report to the agency or agencies relying on the electronic signatures created any 

evidence discovered that the device has been compromised; and to be held as legally bound, 

obligated, or responsible by the electronic signatures created as by a handwritten signature. This 

agreement must be stored until five years after the associated electronic signature device has 

been deactivated.

The term “Local Registration Authority” means an individual who is authorized by a 

State/Local to issue an agreement collection certification, whose identity has been established by 

notarized affidavit, and who is authorized in writing by a regulated entity to issue agreement 

collection certifications on its behalf. Once approved by EPA or State/Local, the LRA would 

collect subscriber agreements from each individual in the regulated entity that intends to use an 

electronic signature device in reporting electronically to EPA or State/Local electronic document 

receiving system. The LRA would collect and store the subscriber agreements in a manner that 

prevents authorized or unauthorized access to these agreements by anyone other than the LRA. 

The LRA would prepare an agreement collection certification and submit a certification of 

receipt and secure storage to the EPA or State/Local.
11

(i) Data Items:

 Compliance with identity proofing requirements by means of identifiers, 

attributes, or alternative method:

 Identifiers or attributes that are verified by attestation of disinterested 

individuals to be uniquely true, as specified.

 Other information necessary to determine identity.

 Compliance with subscriber agreement provisions:

 Subscriber agreement.

 Report of compromised or surrendered electronic signature.

 Submission of subscriber agreement to LRA:

 Subscriber agreement.

 Report of breach of security.

 Report of compromised or surrendered electronic signature.

 Designation of LRA:

 Application to designate a LRA, including notarized affidavit and a 

written authorization from the regulated entity to issue collection 

agreement certifications on its behalf.

 Collection of subscriber agreements by LRA:

 Agreement collection certification. This is a signed statement by which a 

LRA certifies that a subscriber agreement has been received from a 

registrant; the agreement has been stored in a manner that prevents 

authorized or unauthorized access to these agreements by anyone other 

than the LRA; and the LRA has no basis to believe that any of the 

collected agreements have been tampered with or prematurely destroyed.

 Certification of receipt and secure storage. 

(ii) Respondent Activities:

Direct and indirect reporters must perform the following activities, as applicable:

 Comply with requirements for identifier, attribute, or alternative method:

 Prepare and submit information on identifiers, attributes, or other identityproofing information.

 Comply with subscriber agreement provisions:

 Prepare and submit a subscriber agreement.

 File subscriber agreement.

 Prepare and submit new subscriber agreement, for employee turnover.

 File new subscriber agreement, for employee turnover.
12

 Contact the Help Desk for technical support.

 Report compromised or surrendered electronic signature device and 

prepare/submit new subscriber agreement if necessary.

 Submit subscriber agreement to LRA:

 Prepare subscriber agreement and send to LRA.

 Prepare and submit new subscriber agreement to LRA, for employee 

turnover.

 Report breach of security or compromise/surrender of electronic signature 

device.

 Prepare and submit new subscriber agreement to LRA subsequent to 

breach of security or compromise of electronic signature device, if 

necessary.

 Conduct ongoing management:

 Identify and resolve problems.

Indirect reporting firms and LRAs must perform the following activities, as 

applicable:

 Designating a LRA:

 Develop a process or plan to implement the requirement, designate the 

LRA, and submit LRA application to agency.

 Register the LRA with the electronic document receiving system.

 Redesignate LRA, due to turnover, and send application materials.

 Register new LRA with electronic document receiving system.

 Collect subscriber agreements from reporters:

 Collect and securely store subscriber agreements

 Prepare agreement collection certification after securely storing subscriber 

agreements, and submit certification of receipt and secure storage.

 Collect and securely store subscriber agreements, for employee turnover.

 Prepare agreement collection certification after securely storing subscriber 

agreements, and submit certification of receipt and secure storage, for 

employee turnover.

 Collect and securely store subscriber agreements, for breach of 

security/compromise of electronic signature device.

 Prepare agreement collection certification after securely storing subscriber 

agreements, and submit certification of receipt and secure storage, for 

breach of security/compromise of electronic signature device.
13

State/Local agencies acting as regulators must perform the following activities:

 Collect identifiers, attributes, or alternative information:

 Receive, process, review, and approve identifier, attribute, or alternative 

information.

 Collect subscriber agreements:

 Receive, process, review, approve, and file new subscriber agreements.

 Receive, process, review, approve, and file new subscriber agreements, for 

employee turnover.

 Receive, process, review, and approve report of compromise or surrender 

of electronic signature device.

 Collect submittals from LRAs:

 Receive, process, review, and approve certification of receipt and secure 

storage.

 Receive, process, review and approve updated certification of receipt and 

secure storage, for employee turnover.

 Receive notification of breach of security or compromise/surrender of 

electronic signature and take action.

 Receive, process, review, and approve certification of receipt and secure 

storage, for breach of security or compromise/surrender of electronic 

signature device.

 Collect applications for designation of LRAs:

 Receive application to designate first-time LRA.

 Receive application to designate LRA, for LRA turnover.

 Conduct ongoing management:

 Identify and resolve problems.

 Respond to information requests.

(3) Approval of State/Local Electronic Document Receiving System Applications

To obtain EPA approval of authorized program revision or modification using procedures 

provided under 40 CFR 3.1000, a State /Local must submit an application for program revision 

to EPA that includes the elements specified in Sections 3.1000(b)(1)(i) through(iv).

A State/Local that revises or modifies more than one (1) authorized program for receipt 

of electronic documents, in lieu of paper documents, may submit a consolidated application 

covering more than one authorized program, provided the consolidated application complies with 

applicable requirements for each authorized program.
14

If the State/Local receives a notice from EPA that its application is incomplete or does 

not satisfy the requirements at 40 CFR 3.2000, the State/Local must submit an amendment to the 

original application that includes the missing information. 

A State/Local that accepts electronic documents in lieu of paper documents under an 

authorized program for which EPA has approved program revisions or modifications under the 

procedures provided in 40 CFR 3.2000(a)(1) must keep EPA apprised of those changes to laws, 

policies, or the electronic document receiving systems that have the potential to affect program 

conformance with Section 3.2000.

The State/Local program must satisfy the requirements at 40 CFR 3.2000. Pursuant to 

Section 3.2000, authorized programs that receive electronic documents, in lieu of paper 

documents, to satisfy requirements under such programs must use an acceptable electronic 

document receiving system as specified and require that any electronic document must bear valid 

electronic signatures to the same extent that the paper submission for which it substitutes would 

bear handwritten signatures under the authorized program, unless otherwise specified. An 

electronic document receiving system that receives electronic documents, submitted in lieu of 

paper documents, to satisfy requirements under an authorized program must be able to generate 

data with respect to any such electronic document, as needed and in a timely manner, including a 

copy of record for the electronic document, that meets the criteria specified at 

Sections 3.2000(b)(1) through (5).

(i) Data Items:

 An application (or application amendment) for program revision that includes 

the following elements:

 A certification that the State/Local has sufficient legal authority provided 

by lawfully enacted or promulgated statutes or regulations that are in full 

force and effect on the date of certification to implement the electronic 

reporting component of its authorized programs covered by the application 

in conformance with Section 3.2000 and to enforce the affected programs 

using electronic documents collected under these programs, together with 

copies of the relevant statutes and regulations, signed by the State 

Attorney General or designee, or in the case of an authorized Tribal or 

local government program, by the Chief Administrative Official or Officer 

of the governmental entity or designee.

 A listing of all State/Local electronic document receiving systems to 

accept the electronic documents being addressed by the program 

modification or revisions that are covered by the application, together with 

a description for each such system that specifies how the system meets the 

applicable criteria in Section 3.2000(b) with respect to those electronic 

documents.
15

 A schedule of upgrades for electronic document receiving systems that 

have the potential to affect the program’s continued conformance with 

Section 3.2000, if appropriate. 

 Other such information as the Administrator may request to fully evaluate 

the application.

 Appraisals to EPA of changes to laws, policies, or electronic document 

receiving systems.

(ii) Respondent Activities:

State/Local agencies that are regulated entities must perform the following 

activities:

 Upgrade existing electronic document receiving system or develop new 

electronic document receiving system to meet 40 CFR 3.2000 requirements 

and apply for EPA program modification approval under 40 CFR 3.1000.

 Submit amendment to original application for EPA program modification 

approval under 40 CFR 3.1000.

 Submit notification to EPA about changes to laws, policies, or electronic 

document receiving systems that have the potential to affect program 

conformance with 40 CFR 3.2000.
16

5. THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) AGENCY ACTIVITIES

(1) Registering with EPA Electronic Document Receiving System

EPA activities associated with facility reporting to EPA’s electronic document receiving 

system (i.e., CDX) include:

 Develop, operate, and maintain CDX.

(2) Compliance with Identity Proofing Requirements

EPA activities associated with the identity proofing requirements covered in this ICR 

include:

 Collect identifiers or attributes or other information:

 Receive, process, review, and approve identifier, attribute, or alternative 

information.

 Collect subscriber agreements:

 Receive, process, review, approve, and file new subscriber agreements.

 Receive, process, review, approve, and file new subscriber agreements, for 

employee turnover.

 Receive, process, review, and approve report of compromise or surrender of 

electronic signature device.

 Conduct ongoing management:

 Identify and resolve problems.

 Respond to information requests.

(3) Approval of State/Local Electronic Document Receiving System Applications

EPA activities associated with the approval of State/Local electronic document receiving 

systems include:

 Process and file applications submitted by States/Locals seeking to modify their 

programs, as required by 40 CFR 3.1000.

 Process and file amendments to program modification applications submitted by 

States/Locals.

 Process and file appraisals of changes to laws, policies, or electronic document 

receiving systems.
17

5(b) COLLECTION METHODOLOGY AND MANAGEMENT

CDX serves as EPA’s primary gateway for electronic documents received by EPA. CDX 

functions include:

 Access management allowing or denying an entity access to CDX.

 Data interchange accepting and returning data via various file transfer mechanisms.

 Signature/certification management providing devices and required scenarios for 

individuals to sign and certify what they submit.

 Submitter and data authentication assuring that electronic signatures are valid and 

data is uncorrupted.

 Transaction logging providing date, time, and source information for data received to 

establish “chain of custody.”

 Acknowledgment and provision of copy of record providing the submitter with 

confirmations of the data received.

 Archiving placing files received and transmission logs into secure, long term storage.

 Error checking flagging obvious errors in documents and document transactions, 

including duplicate documents and unauthorized submissions.

 Translating, forwarding, and converting submitted documents into formats that will 

load to EPA databases, and forwarding them to the appropriate systems. 

 Outreach providing education and other customer services to CDX users (e.g., user 

manuals, Help Desk).

5(c) SMALL ENTITY FLEXIBILITY

CROMERR allows electronic reporting by permitting the use of electronic document 

receiving systems to receive electronic documents in satisfaction of certain document submission 

requirements in EPA’s regulations. Electronic reporting under CROMERR is voluntary. These 

changes will reduce the burden on all affected entities, including small businesses. In addition, 

facilities will find that the initial set up process requires little expenditure of time and resources, 

and in the long run, this process will reduce the time spent on submissions each year.

5(d) COLLECTION SCHEDULE

The collection frequencies associated with CDX include the following:

 Registrants must initially register with the electronic document receiving system and 

obtain electronic signature certification, if applicable.

 Facilities must comply with requirements for determining the identity of individuals 

who use electronic signature devices (e.g., prepare/submit subscriber agreements or 

certification of receipt and secure storage), before submitting electronic reports using 

the associated device.

 Registrants must submit a notice of compromise or surrender of electronic signature 

device promptly, should this occur.
18

States/Locals that did not have an electronic document receiving system in use or 

substantially developed on or before October 13, 2005 must, using specified procedures, apply 

for and receive EPA approval of revisions or modifications to the authorized program before the 

program may receive electronic documents in lieu of paper documents to satisfy requirements of 

such program.

Within 75 calendar days of receiving an application for program revision or modification, 

the Administrator will respond with a letter that either notifies the State/Local that the 

application is complete or identifies deficiencies in the application that render the application 

incomplete. The State/Local receiving a notice of deficiencies may amend the application and 

resubmit it. Within 30 calendar days of receiving the amended application, the Administrator 

will respond with a letter that either notifies the applicant that the amended application is 

complete or identifies remaining deficiencies that render the application incomplete.

Except where an opportunity for public hearing is required, if the Administrator does not 

take any action on a specific request for revision or modification of a specific authorized 

program addressed by an application submitted within 180 calendar days of notifying the 

State/Local that the application is complete, the specific request for program revision or 

modification for the specific authorized program is considered automatically approved by EPA at 

the end of the 180 calendar days unless the review period is extended at the request of the 

State/Local submitting the application.

If a State/Local submits material to amend its application after the date that the 

Administrator sends notification that the application is complete, this new submission will 

constitute withdrawal of the pending application and submission of a new, amended application 

for program revision or modification, and the 180-day time period will begin again only when 

the Administrator makes a new determination and notifies the State/Local under that the 

amended application is complete.
19

6. ESTIMATING THE HOUR AND COST BURDEN OF THE COLLECTION

6(a) ESTIMATING RESPONDENT BURDEN HOURS

Exhibit 1 provides estimates of the respondent hourly burden associated with the 

information collection requirements covered in this ICR. The exhibit includes burden hours 

(total and by labor type) per respondent, as well as the overall burden hours for all respondents. 

The majority of the hour estimates in Exhibit 1 are based on the Agency’s technical background 

document, Cross Media Electronic Reporting Rule Cost Benefit Analysis, [and consultations with 

industry and States].

6(b) ESTIMATING RESPONDENT COSTS

Exhibit 1 provides estimates of the annual respondent costs associated with the 

information collection requirements covered in this ICR. These costs are based on the cost of 

labor, capital, and operation and maintenance (O&M). 

(1) Labor Costs

Using the total burden hours discussed in Section 6(a) and the hourly respondent labor 

costs outlined in this section, Exhibit 1 illustrates the labor costs associated with the information 

collection requirements covered in this ICR.

(a) Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and

Local Registration Authorities

EPA estimates an average hourly respondent labor cost (including fringe and overhead) 

of $61.63 for legal staff, $39.50 for managerial staff, $39.17 for technical staff, and $17.23 for 

clerical staff. These respondent labor costs were obtained from the previously approved 

CROMERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and updated to 2014

levels using Employment Cost Indexes developed by the Bureau of Labor Statistics.3

(b) State/Local Agencies

EPA estimates an average hourly respondent labor cost (including fringe and overhead) 

of $41.13 for legal staff, $41.13 for managerial staff, $31.15 for technical staff, and $14.78 for 

clerical staff. These respondent labor costs were obtained from the previously approved 

CROMERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and updated to 2014

levels using Employment Cost Indexes developed by the Bureau of Labor Statistics.4

 

3

 Bureau of Labor Statistics; “Table 4. Employment Cost Index for total compensation, for civilian 

workers, by occupational and industry;” Employment Cost Index, Historical Listing – Volume V, Continuous 

Occupational and Industry Series, September 1975 –June 2014;July 2014. Available online at: 

http://www.bls.gov/web/eci/ecicois.pdf, last accessed on October 8, 2014. Civilian Workers, All Workers, March 

2011=114.0 and June 2014= 121.4.

4

 Bureau of Labor Statistics, “Table 7. Employment Cost Index for total compensation, for State and local 

government workers, by occupational and industry,” Employment Cost Index, Historical Listing – Volume V, 
20

(2) Capital Costs

Capital costs usually include any produced physical good needed to provide the needed 

information, such as machinery, computers, and other equipment. 

(a) Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and

Local Registration Authorities

EPA does not anticipate that direct reporters, indirect reporters, indirect reporting firms, 

and LRAs will incur capital costs in carrying out the information collection requirements 

covered in this ICR.

(b) State/Local Agencies

EPA anticipates that State/Local agencies will incur capital costs in upgrading their 

existing electronic document receiving systems or developing new electronic document receiving 

systems to satisfy CROMERR standards at 40 CFR 3.2000 (e.g., copy of record, Secure Sockets 

Layer (SSL), e-mail notification, electronic signature, electronic signature agreement). In 

particular, EPA estimates that each State agency will incur a cost of $152,701 and that each 

Local agency will incur a cost of $57,996. These capital costs were obtained from the previously 

approved CROMERR ICR (i.e., EPA ICR Number 2002.05, dated June 22, 2011), and updated 

to 2014 levels using Consumer Price Indexes developed by the Bureau of Labor Statistics.5 The 

above capital costs are shown in Exhibit 1 for all applicable respondent activities. 

EPA notes that capital costs for Local agencies are estimated to be lower than the capital 

costs for State agencies because Local agencies are expected to have simpler electronic 

document receiving systems that cover fewer programs and fewer electronic reports than State 

systems. For example, EPA has received only one application from a Local agency under 

CROMERR, and that system only accepts reports under one authorized program.

(3) Operation and Maintenance Costs

O&M costs are those costs associated with an information collection requirement 

incurred continually over the life of the ICR. 

 

Continuous Occupational and Industry Series, September 1975 –June 2014;July 2014. Available online at: 

http://www.bls.gov/web/eci/ecicois.pdf, last accessed on October 8, 2014. State and Local Government Workers, 

All Workers, March 2011=116.6 and June 2014= 123.1.

5

 Bureau of Labor Statistics, “Table 24. Historical Consumer Price Index for All Urban Consumers (CPIU): U. S. city average, all items,” CPI Detailed Report for August 2014; August 2014. Available online at: 

http://www.bls.gov/cpi/cpid1408.pdf, last accessed on October 8, 2014. April 2011=224.906 and August 

2014=237.852.
21

(a) Direct Reporters, Indirect Reporters, Indirect Reporting Firms, and

Local Registration Authorities

O&M costs include:

 EPA estimates that employee registrants that submit subscriber agreements to EPA or 

States/Locals will incur a cost of $3.82 to mail a one-ounce letter by certified mail 

(i.e., $0.49 for first-class letter postage, $3.30 for the certified-mail fee, and $0.03 for 

standard business envelope).

6, 7, 8

 EPA estimates that employee registrants that submit subscriber agreements to their 

LRA will incur a cost of $0.52 to mail a one-ounce letter using first-class mail 

(i.e., $0.49 for first-class letter postage and $0.03 for standard business envelope).

9, 10

 EPA estimates that indirect reporting firms will incur a cost of $2.78 for obtaining a 

notarized affidavit to establish the identity of a LRA. This O&M cost was obtained 

from the previously approved CROMERR ICR (i.e., EPA ICR Number 2002.05, 

dated June 22, 2011), and updated to 2014 levels using Consumer Price Indexes 

developed by the Bureau of Labor Statistics.11

The above O&M costs are shown in Exhibit 1 for all applicable respondent activities. 

(b) State/Local Agencies

For State/Local agencies, O&M costs include mailing costs. In particular, EPA estimates 

that State/Local agencies submitting documentation to EPA (e.g., applications for program 

modification approval under 40 CFR 3.1000) will incur a cost of $6.09 to mail a nine-ounce 

large envelope by certified mail ($2.66 for first-class large envelope postage, $3.30 for the 

certified-mail fee, and $0.13 for catalog envelope).12, 13, 14 These O&M costs are shown in 

Exhibit 1 for all applicable respondent activities.

 

6

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: 

https://www.usps.com/2014/mailing/m-fcm-retail.xls, last accessed on October 8, 2014.

7

 U.S. Postal Service; “Extra Services Prices.” Available online at: 

https://www.usps.com/2014/mailing/m-dom-extra-services.xls, last accessed on October 8, 2014.

8

 Standard business envelope cost based on current market price, as of October 8, 2014 (i.e., box of 500 

standard business envelopes with gummed closure at $15.59). 

9

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: 

https://www.usps.com/2014/mailing/m-fcm-retail.xls, last accessed on October 8, 2014.

10

 Standard business envelope cost based on current market price, as of October 8, 2014 (i.e., box of 500 

standard business envelopes with gummed closure at $15.59). 

11

 Bureau of Labor Statistics, “Table 24. Historical Consumer Price Index for All Urban Consumers (CPIU): U. S. city average, all items,” CPI Detailed Report for August 2014; August 2014. Available online at: 

http://www.bls.gov/cpi/cpid1408.pdf, last accessed on October 8, 2014. April 2011=224.906 and August 

2014=237.852.

12

 U.S. Postal Service; “First-Class Mail Prices.” Available online at: 
22

6(c) ESTIMATING AGENCY HOUR AND COST BURDEN

EPA estimates the Agency hour and cost burden associated with the information 

collection requirements covered in this ICR in Exhibit 2. As shown in the exhibit, EPA 

estimates an average hourly labor cost of $65.58 for legal staff (GS-14, Step 5), $55.50 for 

managerial staff (GS-13, Step 1), $46.67 for technical staff (GS-12, Step 1), and $23.68 for

clerical staff (GS-06, Step 1). To derive these hourly estimates, EPA referred to the General

Schedule (GS) Salary Table 2014.

15

 This publication summarizes the unloaded (base) hourly 

rate for various labor categories in the Federal government. EPA then applied the standard 

government overhead factor of 1.6 to the unloaded rate to derive loaded hourly rates.

EPA estimates that, each year, the Agency will incur a capital cost of $173,600 in CDX 

development, operation, and maintenance activities.

16

 This capital cost is shown in Exhibit 2.

O&M costs include electronic transaction fees associated with the processing of

electronic subscriber agreements (ESA) by a third party vendor. In particular, EPA estimates 

that the Agency will incur an electronic transaction cost of $0.61 per subscriber agreement.17 

This O&M cost is shown in Exhibit 2 for all applicable activities.

6(d) ESTIMATING RESPONDENT UNIVERSE AND TOTAL HOUR AND 

COST BURDEN

In this section, EPA first describes the estimated respondent universe. EPA then 

estimates the annual burden to respondents under the information collection requirements 

covered in this ICR. 

EPA notes that, as used in this document, the term “respondent” includes:

 Direct reporters, indirect reporters, indirect reporting firms, and LRAs complying 

with the registration and identity proofing requirements covered in this ICR, as 

applicable. This includes:

 

https://www.usps.com/2014/mailing/m-fcm-retail.xls, last accessed on October 8, 2014.

13

 U.S. Postal Service; “Extra Services Prices.” Available online at: 

https://www.usps.com/2014/mailing/m-dom-extra-services.xls, last accessed on October 8, 2014.

14

 Catalog envelope cost based on current market price, as of October 8, 2014 (i.e., box of 100 6” x 9” 

brown kraft catalog envelopes with gummed closure at $13.29). 

15

 US Office of Personnel Management, “Base Hourly Rate,” 2014 General Schedule (Base), January 

2014. Available online at: http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/pdf/2014/GS_h.pdf, last accessed on October 8, 2014.

16

 Based on data current as of October 13, 2014.

17

 Based on data current as of September 10, 2014.
23

 Private sector entities; and

 State/Local agencies that are regulated entities18.

 State/Local agencies administering electronic document receiving systems subject to 

CROMERR19. In this document, we refer to these respondents as “State/Local

agencies acting as regulators.”

 State/Local agencies seeking EPA approval to allow electronic reporting under 

CROMERR20. In this document, we refer to these respondents as “State/Local 

agencies that are regulated entities.” 

(1) Respondent Universe

EPA estimates that, in total, 102,387 respondents will be subject to the information 

collection requirements covered in this ICR. This includes 77,482 direct reporters, 24,834

indirect reporters, 48 State/Local agencies acting as regulators, and 23 State/Local agencies that 

are regulated entities. The following paragraphs provide additional information on how these 

respondent universe estimates were derived.

(a) Direct Reporter Employees

EPA estimates that, each year, 77,482 direct reporters will be subject to the information 

collection requirements covered in this ICR. This includes 55,483 direct reporter employees 

expected to register with CDX and 21,999 direct reporters expected to submit subscriber 

agreements.

Table 2 presents information on the annual number of employee registrants expected to 

register with CDX during the three-year period covered by the ICR. As shown in the table, EPA 

estimates that, on average, 55,483 employees will register with CDX each year. 

Appendix B provides detailed information on the methodology used to estimate the 

average annual number of direct reporters expected to register with the CDX during the threeyear period covered by this ICR.

 

18

 Addressing State/Local agencies as “respondents” is consistent with EPA’s interpretation of the 

definition of respondent in the PRA.

19

 Ibid.

20

 Ibid.
24

Table 2

Annual Number of Direct Reporter Employees Expected to Register with

EPA’s CDX during the Three-Year Period Covered by the ICR

Respondent Universe Average Annual Number of 

New Employee Registrants a

Private Sector Entities 47,772

State/Local Agencies that are Regulated Entities 7,711

Total 55,483

a

 Federal government employees are not reflected in the table because they are exempt from ICR 

requirements.

Table 3 presents information on the estimated annual number of subscriber agreements to 

be submitted to EPA during the three-year period covered by the ICR. As shown in the table, 

direct reporters have various options for complying with the subscriber agreement requirements 

covered in this ICR:

 Paper subscriber agreement. Direct reporters have the option of preparing and 

mailing a paper subscriber agreement (i.e., a non-ESA).

 Electronic subscriber agreement (ESA). Direct reporters have the option of 

completing and submitting an ESA directly to CDX (i.e., without using a third party

vendor). This eliminates the requirement to prepare and mail new paper subscriber 

agreements.

 Reuse (Consolidated) ESA. Direct reporters now have the option of “reusing” an 

ESA. CDX has the ability to recognize when a registrant has already provided 

sufficient forensic evidence through wet-ink signature, organization information, and 

audit information tying forensic evidence to CDX credentials in order to allow reuse 

of the forensic evidence and accept a digitally signed (electronic) signature using the 

registrant’s existing CDX credential. This eliminates the requirement to prepare and 

mail new paper subscriber agreements.

 Third Party ESA. Direct reporters now have the option of completing and submitting 

an ESA through a third party vendor. CDX provides a voluntary method for real-time 

identity proofing using a third party vendor to validate government identification (ID)

and additional personal information in compliance with OMB Memorandum 

M-04-04, while retaining repeatable digital evidence of validation using 

cryptographic hash technology and not retaining the highly sensitive personally 

identifying information. The third party process validates both identity and business 

affiliation. This eliminates the requirement to prepare and mail new paper subscriber 

agreements.
25

Appendix B provides detailed information on the methodology used to estimate the 

average annual number of subscriber agreements to be submitted to EPA during the three-year 

period covered by this ICR.

Table 3

Annual Number of Subscriber Agreements to Be Submitted to EPA

during the Three-Year Period Covered by the ICR a

Type of Subscriber Agreement

Annual Number of

Subscriber Agreements b, c

Average

2015 2016 2017

Private Sector Entities

Non-ESA Registrants 1,696 1,867 1,856 1,806

ESA Registrants 8,701 9,693 9,792 9,395

Reuse (Consolidated) ESA Registrants 1,040 506 68 538

Third Party ESA Registrants 6,476 6,872 8,256 7,201

Subtotal 17,913 18,938 19,972 18,941

State/Local Agencies that Are Regulated Entities

Non-ESA Registrants 274 301 300 292

ESA Registrants 1,404 1,565 1,581 1,517

Reuse (Consolidated) ESA Registrants 168 82 11 87

Third Party ESA Registrants 1,045 1,109 1,333 1,162

Subtotal 2,891 3,057 3,225 3,058

Total

Non-ESA Registrants 1,970 2,168 2,156 2,098

ESA Registrants 10,105 11,258 11,373 10,912

Reuse (Consolidated) ESA Registrants 1,208 588 79 625

Third Party ESA Registrants 7,521 7,981 9,589 8,364

Total 20,804 21,995 23,197 21,999

a

 Table includes rounding error.

a

 Table contains data provided by EPA’s Office of Information Collection (OIC), and are current as of August 8, 2014.

c

 Federal government employees are not reflected in the table because they are exempt from ICR requirements.

(b) Indirect Reporter Employees

Table 4 presents information on the annual number of employee registrants expected to 

register and comply with identify proofing requirements of State/Local electronic document 

receiving systems during the three-year period covered by the ICR. As shown in the table, EPA 

estimates that, on average, 24,834 employees from indirect reporting facilities will register and 

comply with identify proofing requirements of State/Local electronic document receiving 

systems each year.

For indirect reporters, EPA assumes that only a portion of employee registrants from 

medium-size and large firms will use the LRA alternative. The remaining facility employees 

will comply with the subscriber agreement provisions. Thus, in order to perform the analysis, 

EPA categorized employee registrants based on the size of their firms (i.e., small firm or 
26

medium-size and large firm). Table 4 presents information on the annual number of employee 

registrants by type of firm.

As shown in Table 4, EPA estimates that, on average, 13,372 employees from small firms 

and 11,462 employees from medium-size and large firms will register and comply with identify 

proofing requirements of State/Local electronic document receiving systems each year. 

Appendix C provides detailed information on the methodology used to estimate the 

average annual number of indirect reporters for the three-year period covered by this ICR.

Table 4

Annual Number of Indirect Reporter Employees Expected to Register and Comply with

Identify Proofing Requirements during the Three-Year Period Covered by the ICR

Type of Firm Average Annual Number of 

Employee Registrants a

Private Sector Entities

Small Firms 11,514

Medium-Size and Large Firms 9,869

Subtotal 21,383

State/Local Agencies that are Regulated Entities

Small Firms 1,858

Medium-Size and Large Firms 1,593

Subtotal 3,451

Total

Small Firms 13,372

Medium-Size and Large Firms 11,462

Total 24,834

a

 Federal government employees are not reflected in the table because they are exempt from ICR 

requirements.

(c) Indirect Reporting Firms

As shown in Table 4, EPA estimates that, on average, 13,372 employees from small 

indirect reporting firms will register and comply with identify proofing requirements of 

State/Local electronic document receiving systems each year. Each small firm is expected to 

have an average of three employees21, for a total of 4,457 small firms (i.e., 13,372 employees 

÷ 3 employees/firm).

EPA also estimates that, on average, 11,462 employees from medium-size and large 

indirect reporting firms will register with State/Local electronic document receiving systems 

each year. Each medium-size and large firm is expected to have an average of 18 employees22, 

for a total of 637 medium-size and large firms (i.e., 11,462 employees ÷ 18 employees/firm).

 

21

 This assumption was taken from Cross-Media Electronic Reporting and Records Rule (CROMERRR) 

Cost Benefit Analysis, Final, dated November 17, 2004. 

22

 This assumption was taken from Cross-Media Electronic Reporting and Records Rule (CROMERRR) 
27

(d) State/Local Agencies Acting as Regulators

Based on data from EPA’s CROMERR Program and Stakeholder Management (PSM) 

System, EPA estimates that, currently, 48 State/Local agencies administer electronic document 

receiving systems subject to CROMERR.23 

(e) States/Locals Agencies That Are Regulated Entities

Based on information currently available to EPA on the submission and approval of 

program modification applications under 40 CFR 3.1000 (i.e., CROMERR applications), EPA 

estimates that, on average, four States/Locals (i.e., 3 States and 1 Local) will upgrade their 

existing electronic document receiving systems or develop new electronic document receiving 

systems and submit CROMERR applications each year. 

EPA also estimates that, on average, 15 States/Locals (i.e., 15 States and 0 Locals) will 

submit amendments to their original CROMERR applications each year.

In addition, EPA estimates that, on average, 4 States/Locals (i.e., 4 States and 0 Locals) 

will submit notifications to EPA about changes to laws, policies, or electronic document 

receiving systems each year. 

Based on the above information, EPA estimates that, each year, 23 State/Local agencies 

will be regulated entities during the three-year period covered by this ICR.

(2) Annual Respondent Burden (Exhibit 1)

(a) Registering with EPA Electronic Document Receiving System – Direct 

Reporters

EPA estimates that, on average, 55,483 employees of direct reporting facilities will 

register with EPA’s electronic document receiving system each year. EPA also estimates that, of 

the 55,483 employee registrants, approximately 10 percent (or5,548) will need to update their 

registration information each year. 

(b) Compliance with Identity Proofing Requirements – Direct Reporters

The following paragraphs discuss the assumptions associated with compliance with the 

identity proofing requirements by direct reporters.

 

Cost Benefit Analysis, Final, dated November 17, 2004. 

23

 PSM is a custom implementation of a Salesforce.com platform that integrates database records, online 

file storage, multiple distinct spreadsheets, and email logs, to support the reduction of Technical Review Committee 

(TRC) and EPA’s Office of Environmental Information (OEI) levels of effort in managing the application approval 

process. Data current as of October 9, 2014.
28

Comply with Requirements for Identifier, Attribute, or Alternative Method

EPA does not anticipate that direct reporters will prepare and submit information on 

identifiers or attributes, or other identity-proofing information.

Comply with Subscriber Agreement Provisions

EPA assumes that all direct reporters will comply with the subscriber agreement 

requirements. 

Non-ESA Registrants. EPA estimates that, on average, employee registrants from direct 

reporting facilities will prepare, submit, and file a total of 2,097 paper subscriber agreements

each year. EPA also estimates that, of the 2,097 paper subscriber agreements prepared each 

year, 89 percent (1,867) will be from new and existing employee registrants (e.g., employees 

registering for the first time with a data flow); 10 percent (209) will be associated with employee 

turnover, which requires the submittal of a new subscriber agreement by the employee 

replacement; and one percent (21) will be associated with a compromised electronic signature, 

which requires the submittal of a new subscriber agreement. EPA anticipates that all employee 

registrants preparing a paper subscriber agreement will contact the Help Desk for technical 

support. 

ESA Registrants. EPA estimates that, on average, employee registrants from direct 

reporting facilities will prepare, submit, and file a total of 10,912 ESAs each year. EPA also 

estimates that, of the 10,912 ESAs prepared each year, 89 percent (9,712) will be from new and 

existing employee registrants (e.g., employees registering for the first time with a data flow); 10 

percent (1,091) will be associated with employee turnover, which requires the submittal of a new 

subscriber agreement by the employee replacement; and one percent (109) will be associated 

with a compromised electronic signature, which requires the submittal of a new subscriber 

agreement. EPA anticipates that all employee registrants preparing an ESA will contact the Help 

Desk for technical support. 

Reuse (Consolidated) ESA Registrants. EPA estimates that, on average, 625 employee 

registrants from direct reporting facilities will reuse their ESA each year. EPA also estimates 

that, of the 625 reuse (consolidated) ESAs, 89 percent (556) will be from existing employee 

registrants (e.g., existing employee registrants registering for the first time with a data flow); 10 

percent (63) will be associated with employee turnover, which requires the submittal of a new 

subscriber agreement by the employee replacement; and one percent (6) will be associated with a 

compromised electronic signature, which requires the submittal of a new subscriber agreement. 

EPA anticipates that all employee registrants reusing an ESA will contact the Help Desk for 

technical support. 

Third Party ESA Registrants. EPA estimates that, on average, employee registrants from 

direct reporting facilities will prepare, submit, and file a total of 8,364 third party ESAs each 

year. EPA also estimates that, of the 8,364 third party ESAs prepared each year, 89 percent 

(7,444) will be from new and existing employee registrants (e.g., employees registering for the 

first time with a data flow); 10 percent (836) will be associated with employee turnover, which 
29

requires the submittal of a new subscriber agreement by the employee replacement; and one 

percent (84) will be associated with a compromised electronic signature, which requires the 

submittal of a new subscriber agreement. EPA anticipates that all employee registrants preparing 

a third party ESA will contact the Help Desk for technical support. 

Conduct On-Going Management 

EPA assumes that, of the 21,999 employee registrants from direct reporting facilities, 

three percent (660) will have to work with EPA to resolve problems involving their agreements 

or certifications each year. 

(c) Compliance with Identity Proofing Requirements – Indirect Reporters

The following paragraphs discuss the assumptions associated with compliance with the 

identity proofing requirements by indirect reporters.

Comply with Requirements for Identifier, Attribute, or Alternative Method

EPA does not anticipate that indirect reporters will prepare and submit information on 

identifiers or attributes, or other identity-proofing information.

Comply with Subscriber Agreement Provisions

For indirect reporters, EPA assumes that all employee registrants from small firms 

(13,372) and 98 percent of employee registrants from medium-size and large firms (11,462 x 

0.98 =11,233) will comply with the subscriber agreement requirements. In addition, EPA 

estimates that indirect reporters submit information to 1.3 State/Local electronic document 

receiving systems, on average; hence, their employees must submit subscriber agreements for 1.3 

receiving systems, on average.24 EPA assumes that all employee registrants from indirect 

reporting facilities will submit paper subscriber agreements.

Based on the above assumptions, EPA estimates that, on average, employee registrants

from indirect reporting facilities will prepare, submit, and file a total of 31,986 subscriber 

agreements each year (i.e., [13,372 small firm employees + 11,233 medium-size and large firm 

employees] x 1.3 subscriber agreements/employee).

EPA also estimates that, of the 31,986 subscriber agreements prepared each year, 

89 percent ( 28,468) will be from new and existing employee registrants (e.g., employees 

registering for the first time with a data flow); 10 percent25 ( 3,199) will be associated with 

employee turnover, which requires the submittal of a new subscriber agreement by the employee 

replacement; and one percent (320) will be associated with a compromised electronic signature, 

which requires the submittal of a new subscriber agreement

 

24

 Ibid.

25

 This assumption was taken from Section 2.3.4.2 (page 29) of Cross-Media Electronic Reporting and 

Records Rule (CROMERRR) Cost Benefit Analysis, Final, dated November 17, 2004.
30

EPA anticipates that all employee registrants preparing a subscriber agreement will 

contact the Help Desk for technical support. 

Submit Subscriber Agreements to Local Registration Authority

EPA assumes that two percent of medium-size and large firms will use the LRA 

alternative. EPA also assumes that indirect reporting firms submit information to 1.3 State/Local 

electronic document receiving systems, on average; hence, their employees must submit 

subscriber agreements for 1.3 receiving systems, on average.26 Based on these assumptions, 

EPA estimates that, on average, employees from indirect reporting firms will prepare and send to 

their LRA a total of 298 subscriber agreements each year (i.e., [11,462 medium-size and large 

firm employees x 0.02] x 1.3 subscriber agreements/employee).

EPA estimates that, of the 298 subscriber agreements prepared each year, 89 percent 

(265) will be from new employee registrants; 10 percent (30) will be associated with employee 

turnover, which requires the submittal of a new subscriber agreement by the employee 

replacement; and one percent (3) will be associated with a compromised electronic signature, 

which requires the submittal of a new subscriber agreement. 

Conduct On-Going Management 

EPA assumes that, of the 24,605 employee registrants from indirect reporting facilities 

(13,372 + 11,233 = 24,605), three percent (738) will have to work with States/Locals to resolve 

problems involving their agreements each year. 

(c) Implementation of Local Registration Authority Alternative – Indirect 

Reporting Firms and Local Registration Authorities

The following paragraphs discuss the assumptions associated with implementation of the 

LRA alternative by indirect reporting firms and LRAs.

Designating a Local Registration Authority

As stated above, EPA assumes that two percent of medium-size and large indirect 

reporting firms (637 x 0.02 =13) will use the LRA alternative. These firms will develop a 

process or plan to implement the LRA alternative, designate the LRA, submit the LRA 

application to the agency, and register the LRA with the electronic document receiving system.

Of the 13 medium-size and large indirect reporting firms that will use the LRA 

alternative, two percent (1) will need to redesignate the LRA annually due to turnover, which 

requires registration of the new LRA with the electronic document receiving system. 

 

26

 Ibid.
31

Collect Subscriber Agreements from Reporters

EPA estimates that, on average, LRAs will collect a total of 298 subscriber agreements 

each year. Of these 298 subscriber agreements, 265 will be from new employee registrants, 30 

will be associated with employee turnover, and 3 will be associated with a compromised 

electronic signature. For each of these subscriber agreements, LRAs will need to prepare an 

agreement collection certification after securely storing the subscriber agreements, and submit a 

certification of receipt and secure storage. 

(d) Compliance with Identity Proofing Requirements – State/Local Agencies 

Acting as Regulators

Collect Identifier, Attribute, or Alternative Information

EPA does not anticipate that indirect reporters will prepare and submit information on 

identifiers or attributes, or other identity-proofing information.

Collect Subscriber Agreements

EPA estimates that, on average, employee registrants from indirect reporting facilities 

will prepare, submit, and file a total of 31,987subscriber agreements each year. This includes 

28,468 subscriber agreements from new employee registrants, 3,199 subscriber agreements 

associated with employee turnover, and 320 subscriber agreements associated with a 

compromised electronic signature. State/Local agencies will receive, process, review, approve,

and file all these subscriber agreements.

Collect Submittals from Local Registration Authority 

EPA estimates that, each year, employee registrants from indirect reporting facilities will 

submit 298 subscriber agreements to their LRAs. This includes 265 subscriber agreements from 

new employee registrants, 30 subscriber agreements associated with employee turnover, and 3

subscriber agreements associated with a compromised electronic signature. State/Local agencies 

will need to receive, process, review, and approve the certification of receipt and secure storage

submitted by the LRAs.

Collect Applications for Designation of Local Registration Authority

EPA estimates that, each year, 13 indirect reporting firms will use the LRA alternative. 

EPA also estimates that, each year, one of these firms will need to redesignate the LRA due to 

turnover. State/Local agencies will need to receive and approve these LRA applications.

Conduct On-Going Management 

EPA estimates that, each year, State/Local agencies will have to work with 738 employee 

registrants to resolve problems involving their agreements or certifications, and respond to 

information requests. 
32

(e) Approval of State/Local Electronic Document Receiving System

Applications – State/Local Agencies that Are Regulated Entities

Read the Regulations

EPA estimates that, on average, 23 States/Locals will submit documentation to EPA 

associated with the approval of State/Local electronic document receiving systems each year. 

These States/Locals are expected to read the regulations at 40 CFR Part 3.

Submit Electronic Document Receiving System Application

EPA estimates that, on average, 4 States/Locals will upgrade their existing electronic 

document receiving systems or develop new electronic document receiving systems and submit a 

CROMERR application each year. This includes 3 States and 1 Local.

Submit Amendment to Original Application

EPA estimates that, on average, 15 States will submit amendments to their original 

CROMERR application each year. EPA does not anticipate that Locals will submit amendments 

to their original CROMERR applications during the three-year period covered by this ICR.

Submit Notification on Changes to Laws, Policies, or Electronic Document Receiving 

System

EPA estimates that, on average, 4 States will submit a notification about changes to laws, 

policies, or electronic document receiving systems that have the potential to affect program 

conformance with 40 CFR 3.2000. EPA does not anticipate that Locals will submit this 

notification during the three-year period covered by this ICR.

6(e) BOTTOM LINE HOUR AND COST BURDEN

(1) Respondent Tally

Exhibits 3 and 4 summarize the total annual respondent hour and cost burden associated 

with all the requirements covered in this ICR. Exhibit 3 presents information on the total 

estimated respondent hour and cost burden for all respondents. Exhibit 4 presents information 

on the total estimated respondent hour and cost burden, by type of respondent. As used in this 

document, the term “respondent” includes private sector and State/Local entities.27 As shown in 

the exhibits, EPA estimates the annual respondent burden to be 38,491 hours and $2,086,380. 

The bottom line burden to respondents over three years is estimated to be 115,473 hours and 

$6,259,140.

 

27

 Refer to Section 6(d) for additional clarification on the types of respondents examined in this ICR.
33

(2) Agency Tally

Exhibit 5 summarizes the total annual EPA hour and cost burden associated with all the 

requirements covered in this ICR. As shown in the exhibit, EPA estimates the annual agency 

burden to be 22,393 hours and $1,226,664. The bottom line burden to the agency over three

years is estimated to be 67,179 hours and $3,679,992.

6(f) REASONS FOR CHANGE IN BURDEN

The annual respondent burden estimate in the previously approved CROMERR ICR 

(EPA ICR Number 2002.05) was 39,763 hours. The annual respondent burden estimate for this 

ICR (EPA ICR Number 2002.06) is 38,491 hours. This represents a decrease of 1,272 hours.

This decrease occurred primarily because there was a decrease in the total annual number 

of employees complying with CROMERR’s identity proofing requirements, from 58,996

employees (i.e., 33,072 direct reporters + 25,924 indirect reporters) in the previously approved 

ICR to 46,833 employees (i.e., 21,999 direct reporters + 24,834 indirect reporters) in this ICR. 

In estimating the annual number of employees complying with the CROMERR’s identity 

proofing requirements for this ICR, EPA was able to take advantage of improvements in data 

software and hardware capabilities and thus, develop estimates based on actual data instead of 

the complex calculations used in the previously approved ICR. In particular, EPA was able to 

obtain actual numbers and growth rates for the annual number of subscriber agreements 

submitted to CDX over the past several years. These data were used to improve the estimate for 

the annual number of subscriber agreements submitted by direct reporters. EPA believes that the 

respondent estimates included in this ICR are a reasonable approximation of the actual 

respondent universe. 

Table 5 provides information on changes in burden. As shown in Table 5, all changes are 

considered “adjustments,” since they resulted from changes in the size of the respondent universe 

and refinements to the assumptions used in the development of the ICR.
34

Table 5

Reasons for Change in Respondent Burden Hours from EPA ICR Number 2002.05 to EPA ICR Number 2002.06

a

Changes in EPA ICR Number 2002.06 Type of Change

Burden Hours in 

EPA ICR Number 

2002.05

Burden Hours in 

EPA ICR Number 

2002.06

Change in Total 

Annual Burden 

Hours in EPA ICR 

Number 2002.06

Registering with EPA Electronic Document Receiving System - Direct Reporters

Increase in the number of employees that will register with EPA's 

electronic document receiving system (CDX) Adjustment 4,269 8,433 4,164

Compliance with Identity Proofing Requirements - Direct and Indirect Reporters

Comply with Subscriber Agreement Provisions

Decrease in the number of first-time subscriber agreements Adjustment 17,762 14,439 (3,323)

Decrease in the number of subscriber agreements, due to employee 

turnover Adjustment 1,996 1,622 (374)

Decrease in the number of subscriber agreements, due to compromised 

electronic signature Adjustment 53 43 (10)

Decrease in the number of employee registrants that contact the Help 

Desk for technical support Adjustment 3,988 3,239 (749)

Submit Subscriber Agreement to Local Registration Authority

Increase in the number of new employee registrants that prepare 

subscriber agreements Adjustment 70 87 17 

Increase in the number of subscriber agreements, due to employee 

turnover Adjustment 8 10 2 

Conduct On-Going Management

Decrease in the number of employee registrants that will have to work 

with EPA or State/Locals to resolve problems involving their agreements 

or certifications

Adjustment 1,763 1,398 (365)

Implementation of Local Registration Authority Alternative - Indirect Reporting Firms and Local Registration Authorities

Designating a Local Registration Authority

Decrease in the number of firms that opt to use the LRA alternative Adjustment 184 171 (13)

Collect Subscriber Agreements from Reporters

Increase in the number of new employee registrants that prepare 

subscriber agreements Adjustment 72 90 18 

Increase in the number of subscriber agreements, due to employee 

turnover Adjustment 8 10 2 
Table 5 (continued)

Reasons for Change in Respondent Burden Hours from EPA ICR Number 2002.05 to EPA ICR Number 2002.06

a

35

Changes in EPA ICR Number 2002.06 Type of Change

Burden Hours in 

EPA ICR Number 

2002.05

Burden Hours in 

EPA ICR Number 

2002.06

Change in Total 

Annual Burden 

Hours in EPA ICR 

Number 2002.06

Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators

Decrease in the number of first-time subscriber agreements Adjustment 5,676 5,438 (238)

Increase in the burden associated with the LRA alternative Adjustment 50 61 11 

Decrease in the number of employee registrants that will have to work 

with State/Locals to resolve problems involving their agreements or 

certifications

Adjustment 1,928 1,845 (83)

Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies as Regulated Entities

Decrease in the number of States/Locals reading the regulations Adjustment 36 35 (1)

Decrease in the number of States/Locals upgrading their existing 

electronic document receiving systems or developing new electronic 

document receiving systems and submitting CROMERR applications to 

EPA

Adjustment 1,534 1,203 (331)

Total Change in Burden Hours (1,272)

a

 Table includes rounding error.
36

6(g) PUBLIC BURDEN STATEMENT

(1) Registering with EPA Electronic Document Receiving System – Direct Reporters

The reporting burden is estimated to be 10 minutes for a facility employee to register 

with CDX. This includes time for preparing the on-line application and calling the CDX Help 

Desk. There are no recordkeeping requirements associated with registering with the CDX 

application. 

(2) Compliance with Identity Proofing Requirements – Direct and Indirect Reporters

The reporting burden is estimated to be 80 minutes for a facility employee to prepare and 

submit identifier, attribute, or alternative information. There are no recordkeeping requirements 

associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to range from 15 minutes to 20 minutes for a facility 

employee to prepare and submit a subscriber agreement. The recordkeeping burden for the 

facility employee is estimated to be 5 minutes to file an agreement on site. 

(3) Implementation of Local Registration Authority Alternative – Indirect Reporting 

Firms and Local Registration Authorities

The reporting burden is estimated to be 13 hours for a firm to develop a process or plan to 

use the LRA alternative, designate the LRA, submit the LRA application to the agency, and 

register the LRA with the electronic document receiving system. There are no recordkeeping 

requirements associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 1 hour for a firm to redesignate the LRA, due to 

turnover; send the LRA application to the agency; and register the new LRA with the electronic 

document receiving system. There are no recordkeeping requirements associated with this 

requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 10 minutes for a LRA to prepare and submit a 

certification of receipt and secure storage after receiving a subscriber agreement. The 

recordkeeping burden is estimated to be 10 minutes for a LRA to compile subscriber agreements 

from employee registrants within the LRA’s firm and place them in secure storage. 

(4) Compliance with Identity Proofing Requirements – State/Local Agencies Acting as 

Regulators

The reporting burden is estimated to be 30 minutes for a State/Local agency to receive, 

process, review, and approve identifier, attribute, or alternative information. There are no 

recordkeeping requirements associated with this requirement, and as such, there is no 

recordkeeping burden.
37

The reporting burden is estimated to be 10 minutes for a State/Local agency to receive, 

process, review, and approve subscriber agreements. There are no recordkeeping requirements 

associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 30 minutes for a State/Local agency to receive, 

process, review, and approve an LRA application. There are no recordkeeping requirements 

associated with this requirement, and as such, there is no recordkeeping burden.

The reporting burden is estimated to be 2.5 hours for a State/Local agency to resolve 

problems involving subscriber agreements or certifications, and respond to information requests. 

There are no recordkeeping requirements associated with this requirement, and as such, there is 

no recordkeeping burden.

(5) Approval of State/Local Electronic Document Receiving System

Applications – State/Local Agencies that Are Regulated Entities

The reporting burden is estimated to range from 210 hours to 331 hours for a State/Local

agency to prepare and submit the CROMERR application to EPA. The recordkeeping burden is 

estimated to be 90 minutes to read the regulations.

The reporting burden is estimated to be 24 hours for a State/Local agency to prepare and 

submit an amendment to its original CROMERR application to EPA. The recordkeeping burden 

is estimated to be 90 minutes to read the regulations.

The reporting burden is estimated to be 45 minutes for a State/Local agency to notify 

EPA about changes to laws, policies, or electronic document receiving systems that have the 

potential to affect program conformance with 40 CFR 3.2000. The recordkeeping burden is 

estimated to be 90 minutes to read the regulations.

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–OEI–2011–0096, which is available for online viewing at 
38

www.regulations.gov, or in person viewing at the Office of Environmental Information (OEI) 

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 OEI Docket is 

(202) 566-1752. 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–OEI–

2011–0096 and OMB Control Number 2025–0003 in any correspondence.
39

EXHIBIT 1

CROSS-MEDIA ELECTRONIC REPORTING RULE

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total

 $61.63/ $39.50/ $39.17/ $17.23/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year

Log on to the receiving system site and enter requested information 0.00 0.00 0.15 0.00 0.15 $5.88 $0.00 $0.00 55,483 8,322.45 $326,240.04

Update the information as needed 0.00 0.00 0.02 0.00 0.02 $0.78 $0.00 $0.00 5,548 110.96 $4,327.44

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 8,433.41 $330,567.48

Comply with Requirements for Identifier, Attribute, or Alternative Method

Prepare and submit requested information 0.00 0.25 1.00 0.10 1.35 $50.77 $0.00 $0.00 0 0.00 $0.00

Comply with Subscriber Agreement Provisions - Non-ESA Registrants

Prepare and submit a subscriber agreement 0.00 0.00 0.25 0.00 0.25 $9.79 $0.00 $3.82 1,867 466.75 $25,409.87

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 1,867 149.36 $5,843.71

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.25 0.00 0.25 $9.79 $0.00 $3.82 209 52.25 $2,844.49

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 209 16.72 $654.17

Report compromised or surrendered electronic signature device and prepare/submit 

new subscriber agreement if necessary 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $3.82 21 1.68 $145.95

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 2,097 125.82 $4,927.95

Comply with Subscriber Agreement Provisions - ESA Registrants

Prepare and submit a subscriber agreement 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 9,712 1,651.04 $64,681.92

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 9,712 776.96 $30,398.56

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 1,091 185.47 $7,266.06

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 1,091 87.28 $3,414.83

Report compromised or surrendered electronic signature device and prepare/submit 

new subscriber agreement if necessary 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 109 8.72 $341.17

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 10,912 654.72 $25,643.20

Prepare and submit a subscriber agreement 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 556 94.52 $3,702.96

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 556 44.48 $1,740.28

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 63 10.71 $419.58

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 63 5.04 $197.19

Report compromised or surrendered electronic signature device and prepare/submit 

new subscriber agreement if necessary 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 6 0.48 $18.78

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 625 37.50 $1,468.75

Prepare and submit a subscriber agreement 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 7,444 1,265.48 $49,577.04

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 7,444 595.52 $23,299.72

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 836 142.12 $5,567.76

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 836 66.88 $2,616.68

Report compromised or surrendered electronic signature device and prepare/submit 

new subscriber agreement if necessary 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 84 6.72 $262.92

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 8,364 501.84 $19,655.40

Conduct On-Going Management

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $39.17 $0.00 $0.00 660 660.00 $25,852.20

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 7,608.06 $305,951.14

a

 Exhibit includes rounding error.

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN a

Hours and Costs Per Respondent Per Activity

Registering with EPA Electronic Document Receiving System - Direct Reporters

Compliance with Identity Proofing Requirements - Direct Reporters

Total Hours and Costs

Comply with Subscriber Agreement Provisions - Third Party ESA Registrants

Comply with Subscriber Agreement Provisions - Reuse (Consolidated) ESA Registrants
40

EXHIBIT 1 (CONTINUED)

CROSS-MEDIA ELECTRONIC REPORTING RULE

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total

 $61.63/ $39.50/ $39.17/ $17.23/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year

Comply with Requirements for Identifier, Attribute, or Alternative Method

Prepare and submit requested information 0.00 0.25 1.00 0.10 1.35 $50.77 $0.00 $0.00 0 0.00 $0.00

Comply with Subscriber Agreement Provisions - Non-ESA Registrants

Prepare and submit a subscriber agreement 0.00 0.00 0.25 0.00 0.25 $9.79 $0.00 $3.82 28,468 7,117.00 $387,449.48

File subscriber agreement 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 28,468 2,277.44 $89,104.84

Prepare and submit a new subscriber agreement, for employee turnover 0.00 0.00 0.25 0.00 0.25 $9.79 $0.00 $3.82 3,199 799.75 $43,538.39

File new subscriber agreement, for employee turnover 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 3,199 255.92 $10,012.87

Report compromised or surrendered electronic signature device and prepare/submit 

new subscriber agreement if necessary 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $3.82 320 25.60 $2,224.00

Contact the Help Desk for technical support 0.00 0.00 0.06 0.00 0.06 $2.35 $0.00 $0.00 31,987 1,919.22 $75,169.45

Prepare subscriber agreement and send to LRA (non-ESA registrant) 0.00 0.00 0.33 0.00 0.33 $12.93 $0.00 $0.52 265 87.45 $3,564.25

Prepare new subscriber agreement and send to LRA, for employee turnover (nonESA registrant) 0.00 0.00 0.33 0.00 0.33 $12.93 $0.00 $0.52 30 9.90 $403.50

Report breach of security or comprimise/surrender of electronic signature device 0.00 0.00 0.08 0.00 0.08 $3.13 $0.00 $0.00 3 0.24 $9.39

Prepare new subscriber agreement and send to LRA subsequent to breach of 

security/compromise of electronic signature device (non-ESA registrant) 0.00 0.00 0.33 0.00 0.33 $12.93 $0.00 $0.52 3 0.99 $40.35

Conduct On-Going Management

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $39.17 $0.00 $0.00 738 738.00 $28,907.46

Develop a process or plan to implement the requirement, designate the LRA, and 

submit LRA application to agency 1.00 0.00 12.00 0.00 13.00 $531.67 $0.00 $6.60 13 169.00 $6,997.51

Register LRA with the electronic document receiving system 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 13 2.21 $86.58

Redesignate LRA, due to turnover, and send application materials 0.00 0.00 1.00 0.00 1.00 $39.17 $0.00 $6.60 1 1.00 $45.77

Register new LRA with electronic document receiving system 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 1 0.17 $6.66

Collect and securely store subscriber agreements 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 265 45.05 $1,764.90

Prepare agreement collection certification after securely storing subscriber agreements, 

and submit certification of receipt and secure storage 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $2.79 265 45.05 $2,504.25

Collect and securely store subscriber agreements, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 30 5.10 $199.80

Prepare agreement collection certification after securely storing subscriber agreements, 

and submit certification of receipt and secure storage, for employee turnover 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $2.79 30 5.10 $283.50

Collect and securely store subscriber agreements, for breach of security/compromise 

of electronic signature device 0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $0.00 3 0.51 $19.98

Prepare agreement collection certification after securely storing subscriber agreements, 

and submit certification of receipt and secure storage, for breach of 

security/compromise of electronic signature device

0.00 0.00 0.17 0.00 0.17 $6.66 $0.00 $2.79 3 0.51 $28.35

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 13,505.21 $652,361.28

a

 Exhibit includes rounding error.

Collect Subscriber Agreements from Reporters

Designating a Local Registration Authority

Submit Subscriber Agreement to Local Registration Authority

Implementation of Local Registration Authority Alternative - Indirect Reporting Firms and Local Registration Authorities

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Compliance with Identity Proofing Requirements - Indirect Reporters
41

EXHIBIT 1 (CONTINUED)

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total

 $41.13/ $41.13/ $31.15/ $14.78/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year

Receive, process, review and approve identifier, attribute, or alternative 

information 0.00 0.00 0.50 0.00 0.50 $15.58 $0.00 $0.00 0 0.00 $0.00

Receive, process, review, approve and file new subscriber agreements 0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 28,468 4,839.56 $150,880.40

Receive, process, review, approve and file new subscriber agreements, for 

employee turnover 0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 3,199 543.83 $16,954.70

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 320 54.40 $1,696.00

Receive, process, review, and approve certification of receipt and secure 

storage

0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 265 45.05 $1,404.50

Receive, process, review and approve updated certification of receipt and 

secure storage, for employee turnover 0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 30 5.10 $159.00

Receive notification of breach of security or compromise/surrender of 

electronic signature device and take action 0.00 0.00 1.00 0.00 1.00 $31.15 $0.00 $0.00 3 3.00 $93.45

Receive, process, review and approve certification of receipt and secure 

storage, for breach of security 0.00 0.00 0.17 0.00 0.17 $5.30 $0.00 $0.00 3 0.51 $15.90

Receive application to designate first-time LRA 0.00 0.00 0.50 0.00 0.50 $15.58 $0.00 $0.00 13 6.50 $202.54

Receive application to designate LRA, for LRA turnover 0.00 0.00 0.50 0.00 0.50 $15.58 $0.00 $0.00 1 0.50 $15.58

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $31.15 $0.00 $0.00 738 738.00 $22,988.70

Respond to information requests 0.00 0.00 1.50 0.00 1.50 $46.73 $0.00 $0.00 738 1,107.00 $34,486.74

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 7,343.45 $228,897.51

a

 Exhibit includes rounding error.

Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators

Collect Submittals from Local Registration Authority

Conduct On-Going Management

Collect Subscriber Agreements

Collect Applications for Designation of Local Registration Authority

CROSS-MEDIA ELECTRONIC REPORTING RULE

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Collect Identifer, Attribute, or Alternative Information
42

EXHIBIT 1 (CONTINUED)

CROSS-MEDIA ELECTRONIC REPORTING RULE

ESTIMATED ANNUAL RESPONDENT HOUR AND COST BURDEN

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total

 $41.13/ $41.13/ $31.15/ $14.78/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year

Read the regulations 0.00 0.75 0.75 0.00 1.50 $54.21 $0.00 $0.00 23 34.50 $1,246.83

Upgrade existing electronic document receiving system or develop new 

electronic document receiving system to meet 40 CFR 3.2000 and apply 

for EPA program modification approval under 40 CFR 3.1000 (States)

0.00 31.00 300.00 0.00 331.00 $10,620.03 $152,701.00 $6.09 3 993.00 $489,981.36

Upgrade existing electronic document receiving system or develop new 

electronic document receiving system to meet 40 CFR 3.2000 and apply 

for EPA program modification approval under 40 CFR 3.1000 (Locals)

0.00 20.00 190.00 0.00 210.00 $6,741.10 $57,996.00 $6.09 1 210.00 $64,743.19

Submit amendment to original application for EPA program modification 

approval under 40 CFR 3.1000 (States/Locals) 0.00 8.00 16.00 0.00 24.00 $827.44 $0.00 $6.09 15 360.00 $12,502.95

Submit notification to EPA about changes to laws, policies, or electronic 

document receiving systems that have the potential to affect program 

conformance with 40 CFR 3.2000 (States/Locals with approved 

applications)

0.00 0.25 0.50 0.00 0.75 $25.86 $0.00 $6.09 4 3.00 $127.80

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 1,600.50 $568,602.13

TOTAL Varies Varies Varies Varies Varies Varies Varies Varies Varies 38,490.63 $2,086,379.54

a

 Exhibit includes rounding error.

Submit Electronic Document Receiving System Application

Submit Notification on Changes to Laws, Policies, or Electronic Document Receiving System

Submit Amendment to Original Application

Read the Regulations

Hours and Costs Per Respondent Per Activity Total Hours and Costs

Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated Entities
43

EXHIBIT 2

ESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total

 $65.58/ $55.50/ $46.67/ $23.68/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year

Develop, operate, and maintain CDX 0.00 330.00 13,790.00 0.00 14,120.00 $661,894.30 $173,600.00 $0.00 1 14,120.00 $835,494.30

Subtotal 0.00 330.00 13,790.00 0.00 14,120.00 $661,894.30 $173,600.00 $0.00 1 14,120.00 $835,494.30

Receive, process, review and approve identifier, attribute, or alternative 

information 0.00 0.00 0.50 0.00 0.50 $23.34 $0.00 $0.00 0 0.00 $0.00

Receive, process, review, approve and file new subscriber agreements b 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 1,867 0.00 $0.00

Receive, process, review, approve and file new subscriber agreements, for 

employee turnover b 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 209 0.00 $0.00

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 21 3.57 $166.53

Receive, process, review, approve and file new subscriber agreements 0.00 0.00 0.52 0.00 0.52 $24.27 $0.00 $0.00 9,712 5,050.24 $235,710.24

Receive, process, review, approve and file new subscriber agreements, for 

employee turnover 0.00 0.00 0.52 0.00 0.52 $24.27 $0.00 $0.00 1,091 567.32 $26,478.57

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 109 18.53 $864.37

Receive, process, review, approve and file new subscriber agreements c 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 556 0.00 $0.00

Receive, process, review, approve and file new subscriber agreements, for 

employee turnover c 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.00 63 0.00 $0.00

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 6 1.02 $47.58

Receive, process, review, approve and file new subscriber agreements d 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.61 7,444 0.00 $4,540.84

Receive, process, review, approve and file new subscriber agreements, for 

employee turnover d 0.00 0.00 0.00 0.00 0.00 $0.00 $0.00 $0.61 836 0.00 $509.96

Receive, process, review, approve report compromise/surrender electronic 

signature device 0.00 0.00 0.17 0.00 0.17 $7.93 $0.00 $0.00 84 14.28 $666.12

Identify and resolve problems 0.00 0.00 1.00 0.00 1.00 $46.67 $0.00 $0.00 660 660.00 $30,802.20

Respond to information requests 0.00 0.00 1.50 0.00 1.50 $70.01 $0.00 $0.00 660 990.00 $46,206.60

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 7,304.96 $345,993.01

a

 Exhibit includes rounding error.

CROSS-MEDIA ELECTRONIC REPORTING RULE

Hours and Labor Costs Per Respondent Per Activity Total Hours and Costs

Registering with EPA Electronic Document Receiving System

Compliance with Identity Proofing Requirements

Collect Subscriber Agreements - ESA Registrants

Collect Subscriber Agreements - Non-ESA Registrants

Collect Identifer, Attribute, or Alternative Information

Collect Subscriber Agreements - Reuse (Consolidated) ESA Registrants

b

 Labor cost associated with the collection of subscriber agreements from non-ESA registrants is equal to $0.00 because it is included in the registration costs covered under "Reporting to EPA Electronic Document Receiving System."

c

 Labor cost associated with the collection of subscriber agreements from reuse (consolidated) ESA registrants is equal to $0.00 because, under this option, registrants can use their existing CDX credential. As a result, EPA does not need to 

receive, process, review, approve, and file new paper subscriber agreements from these registrants.

d

 Labor cost associated with the collection of subscriber agreements from third party ESA registrants is equal to $0.00 because, under this option, a third party vendor processes the subscriber agreements for an electronic transaction fee of 

$0.61 per subscriber agreement.

Collect Subscriber Agreements - Third Party ESA Registrants

Conduct On-Going Management
44

EXHIBIT 2 (CONTINUED)

ESTIMATED ANNUAL EPA HOUR AND COST BURDEN a

Leg. Mgr. Tech. Cler. Respon. Labor Capital/ Number of Total Total

 $65.58/ $55.50/ $46.67/ $23.68/ Hours/ Cost/ Startup O&M Respon. Hours/ Cost/

INFORMATION COLLECTION ACTIVITY Hour Hour Hour Hour Activity Activity Cost Cost Activities Year Year

Process and file receiving system documentation submitted by State/Local 

seeking to modify their programs, as required by 40 CFR 3.1000 (States) 0.00 0.00 160.00 0.00 160.00 $7,467.20 $0.00 $0.00 3 480.00 $22,401.60

Process and file receiving system documentation submitted by State/Local 

seeking to modify their programs, as required by 40 CFR 3.1000 (Locals) 0.00 0.00 80.00 0.00 80.00 $3,733.60 $0.00 $0.00 1 80.00 $3,733.60

Process and file amendment to original application for EPA program 

modification approval under 40 CFR 3.1000 (States/Locals) 0.00 0.00 24.00 0.00 24.00 $1,120.08 $0.00 $0.00 15 360.00 $16,801.20

Process and file notifications about changes to laws, policies, or electronic 

document receiving systems that have the potential to affect program 

conformance with 40 CFR 3.2000 (States/Locals with approved 

applications)

0.00 0.00 12.00 0.00 12.00 $560.04 $0.00 $0.00 4 48.00 $2,240.16

Subtotal Varies Varies Varies Varies Varies Varies Varies Varies Varies 968.00 $45,176.56

TOTAL 0.00 Varies Varies Varies Varies Varies Varies Varies Varies 22,392.96 $1,226,663.87

a

 Exhibit includes rounding error.

CROSS-MEDIA ELECTRONIC REPORTING RULE

Hours and Labor Costs Per Respondent Per Activity Total Hours and Costs

Approval of State/Local Electronic Document Receiving System Applications
45

EXHIBIT 3

CROSS-MEDIA ELECTRONIC REPORTING

TOTAL ESTIMATED RESPONDENT HOUR AND COST BURDEN SUMMARY a

Annual Burden 

Hours

Annual Labor 

Cost

Annual Capital/ 

Startup Cost

Annual O&M 

Cost

Total Annual 

Cost

Registering with EPA Electronic Document Receiving System - Direct Reporters 8,433.41 $330,567.48 $0.00 $0.00 $330,567.48

Compliance with Identity Proofing Requirements - Direct Reporters 7,608.06 $297,940.60 $0.00 $8,010.54 $305,951.14

Compliance with Identity Proofing Requirements - Indirect Reporters 13,505.21 $529,092.16 $0.00 $123,269.12 $652,361.28

Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators 7,343.45 $228,897.51 $0.00 $0.00 $228,897.51

Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated Entities 1,600.50 $52,363.06 $516,099.00 $140.07 $568,602.13

Total 38,491 $1,438,861 $516,099 $131,420 $2,086,380

3-year Total 115,473 $4,316,583 $1,548,297 $394,260 $6,259,140

a

 Exhibit includes rounding error.
46

EXHIBIT 4

CROSS-MEDIA ELECTRONIC REPORTING

TOTAL ESTIMATED RESPONDENT HOUR AND COST BURDEN SUMMARY, BY TYPE OF RESPONDENT a

Annual Burden 

Hours

Annual Labor 

Cost

Annual Capital/ 

Startup Cost

Annual O&M 

Cost

Total Annual 

Cost

Registering with EPA Electronic Document Receiving System - Direct Reporters 7,261.34 $284,625.42 $0.00 $0.00 $284,625.42

Compliance with Identity Proofing Requirements - Direct Reporters 6,552.07 $256,586.79 $0.00 $6,898.92 $263,485.71

Compliance with Identity Proofing Requirements - Indirect Reporters 11,626.85 $455,499.52 $0.00 $106,140.31 $561,639.83

Subtotal for Private Sector Respondents 25,440.26 $996,711.73 $0.00 $113,039.23 $1,109,750.96

Reporting to EPA Electronic Document Receiving System - Direct Reporters 1,172.07 $45,942.06 $0.00 $0.00 $45,942.06

Compliance with Identity Proofing Requirements - Direct Reporters 1,055.99 $41,353.81 $0.00 $1,111.62 $42,465.43

Compliance with Identity Proofing Requirements - Indirect Reporters 1,878.36 $73,592.64 $0.00 $17,128.81 $90,721.45

Compliance with Identity Proofing Requirements - State/Local Agencies Acting as Regulators 7,343.45 $228,897.51 $0.00 $0.00 $228,897.51

Approval of State/Local Electronic Document Receiving System Application - State/Local Agencies that Are Regulated Entities 1,600.50 $52,363.06 $516,099.00 $140.07 $568,602.13

Subtotal for State/Local Respondents 13,050.37 $442,149.08 $516,099.00 $18,380.50 $976,628.58

Total for All Respondents (i.e., Private Sector and State/Local) 38,491 $1,438,861 $516,099 $131,420 $2,086,380

a

 Exhibit includes rounding error.

Private Sector Respondents

State/Local Respondents
47

EXHIBIT 5

CROSS-MEDIA ELECTRONIC REPORTING

TOTAL ESTIMATED EPA HOUR AND COST BURDEN SUMMARY a

Annual Burden 

Hours

Annual Labor 

Cost

Annual Capital/ 

Startup Cost

Annual O&M 

Cost

Total Annual 

Cost

Registering with EPA Electronic Document Receiving System 14,120.00 $661,894.30 $173,600.00 $0.00 $835,494.30

Compliance with Identity Proofing Requirements 7,304.96 $340,942.21 $0.00 $5,050.80 $345,993.01

Approval of State/Local Electronic Document Receiving System Applications 968.00 $45,176.56 $0.00 $0.00 $45,176.56

Total 22,393 $1,048,013 $173,600 $5,051 $1,226,664

3-year Total 67,179 $3,144,039 $520,800 $15,153 $3,679,992

a

 Exhibit includes rounding error.
48

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A-1

Appendix A

List of North American Industry Classification System (NAICS)

Codes Associated with Industries Most Likely Affected by the

Information Collection Requirements Covered in this ICR

11 Agriculture, Forestry, Fishing and Hunting 

111 Crop Production 

112 Animal Production 

113 Forestry and Logging 

114 Fishing, Hunting and Trapping 

115 Support Activities for Agriculture and 

Forestry 

21 Mining

211 Oil and Gas Extraction 

212 Mining (except Oil and Gas) 

213 Support Activities for Mining 

22 Utilities

221 Utilities 

23 Construction 

233 Building, Developing, and General 

Contracting 

234 Heavy Construction 

235 Special Trade Contractors 

31 Manufacturing 

311 Food Manufacturing 

312 Beverage and Tobacco Product 

Manufacturing 

313 Textile Mills 

314 Textile Product Mills 

315 Apparel Manufacturing 

316 Leather and Allied Product Manufacturing 

321 Wood Product Manufacturing 

322 Paper Manufacturing 

323 Printing and Related Support Activities 

324 Petroleum and Coal Products Manufacturing 

325 Chemical Manufacturing 

326 Plastics and Rubber Products Manufacturing 

327 Nonmetallic Mineral Product Manufacturing 

331 Primary Metal Manufacturing 

332 Fabricated Metal Product Manufacturing 

333 Machinery Manufacturing 

334 Computer and Electronic Product 

Manufacturing 

335 Electrical Equipment, Appliance, and 

Component Manufacturing 

336 Transportation Equipment Manufacturing 

337 Furniture and Related Product 

Manufacturing 

339 Miscellaneous Manufacturing 

42 Wholesale Trade 

421 Wholesale Trade, Durable Goods 

422 Wholesale Trade, Nondurable Goods 

44-45 Retail Trade 

441 Motor Vehicle and Parts Dealers 

442 Furniture and Home Furnishings Stores 

443 Electronics and Appliance Stores 

444 Building Material and Garden Equipment 

and Supplies Dealers 

445 Food and Beverage Stores 

446 Health and Personal Care Stores 

447 Gasoline Stations 

448 Clothing and Clothing Accessories Stores 

451 Sporting Goods, Hobby, Book, and Music 

Stores 

452 General Merchandise Stores 

453 Miscellaneous Store Retailers 

454 Nonstore Retailers 

48-49 Transportation and Warehousing 

481 Air Transportation 

482 Rail Transportation 

483 Water Transportation 

484 Truck Transportation 

485 Transit and Ground Passenger 

Transportation 

486 Pipeline Transportation 

487 Scenic and Sightseeing Transportation 

488 Support Activities for Transportation 

491 Postal Service 

492 Couriers and Messengers 

493 Warehousing and Storage 

51 Information 

511 Publishing Industries 

512 Motion Picture and Sound Recording 

Industries 

513 Broadcasting and Telecommunications 

514 Information Services and Data Processing 

Services 

52 Finance and Insurance 

521 Monetary Authorities Central Bank 

522 Credit Intermediation and Related Activities 

523 Securities, Commodity Contracts, and Other 

Financial Investments and Related Activities

524 Insurance Carriers and Related Activities 

525 Funds, Trusts, and Other Financial Vehicles 
A-2

53 Real Estate and Rental and Leasing 

531 Real Estate 

532 Rental and Leasing Services 

533 Lessors of Nonfinancial Intangible Assets 

(except Copyrighted Works)

54 Professional, Scientific, and Technical 

Services 

541 Professional, Scientific, and Technical 

Services 

55 Management of Companies and Enterprises 

551 Management of Companies and Enterprises 

56 Administrative and Support and Waste 

Management and Remediation Services 

561 Administrative and Support Services 

562 Waste Management and Remediation 

Services 

61 Educational Services 

611 Educational Services 

62 Health Care and Social Assistance 

621 Ambulatory Health Care Services 

622 Hospitals 

623 Nursing and Residential Care Facilities 

624 Social Assistance 

71 Arts, Entertainment, and Recreation 

711 Performing Arts, Spectator Sports, and 

Related Industries 

712 Museums, Historical Sites, and Similar 

Institutions 

713 Amusement, Gambling, and Recreation 

Industries 

72 Accommodation and Food Services 

721 Accommodation 

722 Food Services and Drinking Places 

81 Other Services (except Public 

Administration) 

811 Repair and Maintenance 

812 Personal and Laundry Services 

813 Religious, Grantmaking, Civic, Professional, 

and Similar 

814 Private Households 

92 Public Administration 

921 Executive, Legislative, and Other General 

Government Support 

922 Justice, Public Order, and Safety Activities 

923 Administration of Human Resource 

Programs

924 Administration of Environmental Quality 

Programs 

925 Administration of Housing Programs, Urban 

Planning, and C 

926 Administration of Economic Programs 

927 Space Research and Technology 

928 National Security and International Affair
B-1

Appendix B

Methodology for Estimating the Annual Number of Facility Employees Expected

to Register and Comply with the Identity Proofing Requirements of EPA’s Electronic 

Document Receiving System during the Three-Year Period Covered by the ICR

This appendix describes the methodology for estimating the annual number of facility 

employees expected to register and comply with the identity proofing requirements of EPA’s 

electronic document receiving system (i.e., CDX) during the three-year period covered by the 

ICR. 

1. Annual Number of New Employee Registrants

This section describes the methodology for estimating the annual number of facility 

employees expected to register with CDX during the three-year period covered by the ICR

(i.e., new employee registrants). Section 1.1 provides an overview of the methodology, 

Section 1.2 provides a detailed discussion of the methodology, and Section 1.3 presents the 

results. 

1.1. Overview 

In estimating the annual number of facility employees expected to register with CDX, 

EPA first compiled historical information on the number of new employee registrants for years 

2011 through 2013. We then estimated the annual number of new employee registrants for the 

three-year period covered by the ICR (i.e., years 2015 through 2017). 

1.2. Detailed Discussion

EPA took the following steps to carry out the methodology.

A. Compile historical information on number of new employee registrants. EPA referred to 

CDX in order to compile historical information on the number of new registrants for 

years 2011 through 2013.

Year Number of New

Employee Registrants

2011 45,755

2012 83,701

2013 40,511

B. Estimate annual number of new employee registrants over the three-year period covered 

in the ICR. We estimated the annual number of new employee registrants over the threeyear period covered by the ICR (i.e., years 2015 through 2017) by averaging the number 

of new employee registrants for years 2011 through 2013. That is, we assumed that 

56,656 new registrants (i.e., (45,755 + 83,701 + 40,511) ÷ 3) will register with CDX each 

year.
B-2

C. Estimate annual number of new registrants by type of ownership (i.e., private sector vs. 

State/Local) and remove Federal government employee registrants from this analysis. 

We referred to data published by the Bureau of Labor Statistics on the number of 

employees in the U.S. These data indicate that 84.32 percent of U.S. employees work for 

the private sector, 13.61 percent of employees work for States/Locals, and 2.07 percent of 

employees work for the Federal government. We applied these percentages to the annual 

number of new employee registrants in Step B. We then excluded Federal Government 

employees from the analysis because they are exempt from ICR requirements.

1.3. Results

Exhibit B-1 presents information on the average annual number of facility employees 

expected to register with CDX.

Exhibit B-1

Annual Number of Facility Employees Expected to Register with

EPA’s CDX during the Three-Year Period Covered by the ICR

Respondent Universe Average Annual Number of

New Employee Registrants a

Private Sector 47,772

States/Locals 7,711

Total 55,483

a

 Federal government employees are not reflected in the table because they are 

exempt from ICR requirements.

2. Annual Number of Subscriber Agreements

This section describes the methodology for estimating the annual number of subscriber 

agreements submitted to EPA to comply with the identity proofing requirements of CDX during 

the three-year period covered by the ICR. Section 2.1 provides an overview of the methodology, 

Section 2.2 provides a detailed discussion of the methodology, and Section 2.3 presents the 

results. 

2.1. Overview 

In estimating the annual number of subscriber agreements submitted to CDX, EPA first 

compiled information on the number of ESAs for years 2012 through 2014. We then estimated 

the annual number of subscriber agreements (i.e., paper subscriber agreements, electronic 

subscriber agreements (ESAs), reuse (consolidated) ESAs, and third party ESAs) for the threeyear period covered by the ICR (i.e., years 2015 through 2017) based on analysis of growth rates 

and implementation rates.
B-3

2.2. Detailed Discussion

EPA took the following steps to carry out the methodology.

Non-Electronic Subscriber Agreements

A. Compile historical information on number of non-ESAs (i.e., paper subscriber 

agreements), by CROMERR data flow. Some of the CROMERR data flows do not 

support ESAs. For purposes of this analysis, the subscriber agreements associated with 

these data flows are categorized as “non-ESAs” or paper subscriber agreements. 

To estimate the number of non-ESAs or paper subscriber agreements for years 2015

through 2017, we referred to CDX in order to compile historical information on the 

number of non-ESAs, by CROMERR data flow, for years 2012 through 2014. 

CROMERR

Data Flow

Number of Non-ESAs or Paper Subscriber Agreements

2012 2013 2014 a

ARCS 3 26 9

CEDRI 23 314

CEDRI1 5 45

CSPP 10 46 36

eSIPS 11

LEAD 36 500 349

MYRCRAID 17 11

ODS 1 2 1

OTAQDCFUEL 46 176 58

SSTS 6 39

TRIMEweb 1 1,317 1,719

Total 102 2,158 2,547

a

 Number of paper subscriber agreements were available through July 2014. EPA projected the number of 

paper subscriber agreements for the entire year, based on available 2014 data.

B. Estimate total number of non-ESAs or paper subscriber agreements, by CROMERR data 

flow, for the three-year period covered in the ICR. We estimated the total number of 

non-ESAs or paper subscriber agreements, by CROMERR data flow, for years 2015

through 2017 by using the following equations: 

Number of

Non-ESAs

for Year Y

= ([3 x RegistrantsY-1] + [2 x RegistrantsY-2] + [RegistrantsY-3]) / 6
B-4

The table below shows the estimated number of non-ESAs or paper subscriber 

agreements, by CROMERR data flow, for years 2015 through 2017. 

CROMERR

Data Flow

Number of Paper Subscriber Agreements a

2015 2016 2017

ARCS 14 14 13

CEDRI 165 191 203

CEDRI1 16 16 13

CSPP 35 37 36

eSIPS 6 7 7

LEAD 347 373 360

MYRCRAID 11 12 12

ODS 1 1 1

OTAQDCFUEL 95 96 89

SSTS 22 25 26

TRIMEweb 1,299 1,442 1,441

Total 2,011 2,214 2,201

a

 Table includes rounding error.

Electronic Subscriber Agreements

C. Compile historical information on number of ESAs, by CROMERR data flow. EPA 

referred to CDX in order to compile historical information on the number of ESAs, by 

CROMERR data flow, for years 2012 through 2014. 

CROMERR Data Flow

Number of ESAs

2012 2013 2014 a

ARCS 2 1 0

CEDRI 32 1,731

CEDRI1 5 66 0

CSPP 30 66 35

eSIPS 21

LEAD 377 4,971 5,954

MYRCRAID 11 3

ODS 4 12

OTAQDCFUEL 3 2 110

SSTS 19 109

TRIMEweb 5 3,758 6,567

Total 422 8,930 14,542

a

 Number of paper subscriber agreements were available through July 2014. EPA projected the 

number of paper subscriber agreements for the entire year, based on available 2014 data.
B-5

D. Estimate number of ESAs, by CROMERR data flow, for the three-year period covered in 

the ICR. We estimated the number of ESAs, by CROMERR data flow, for years 2015

through 2017 by using the following equation: 

Number of 

ESAs

for Year Y

= ([3 x RegistrantsY-1] + [2 x RegistrantsY-2] + [RegistrantsY-3]) / 6

The table below shows the estimated number of ESAs, by CROMERR data flow, for

years 2015 through 2017. 

CROMERR Data Flow

Number of ESAs a

2015 2016 2017

ARCS 1 1 1

CEDRI 876 1,020 1,091

CEDRI1 23 23 19

CSPP 45 45 43

eSIPS 11 13 14

LEAD 4,697 5,162 5,139

MYRCRAID 5 5 5

ODS 7 8 8

OTAQDCFUEL 56 65 70

SSTS 61 70 74

TRIMEweb 4,537 5,084 5,149

Total 10,319 11,496 11,613

a

 Table includes rounding error.

E. Estimate number of reuse (consolidated) ESAs, by CROMERR data flow, for the threeyear period covered in the ICR. We estimated the number of reuse (consolidated) ESAs,

for participating data flows, by applying implementation rates derived from data provided 

by CDX to the number of ESAs obtained in Step D. The implementation rates are 

presented in the table below:

CROMERR Data Flow Implementation Rates for Reuse (Consolidated) ESAs

2012 2013 2014

ARCS 4%

CEDRI 49% 1%

CSPP 97% 18% 29%

LEAD 2% 0.3% 0.02%

MYRCRAID 6%

ODS 67% 50% 67%

OTAQDCFUEL 2% 2% 7%

SSTS 11% 2%

TRIMEweb 24% 1% 1%
B-6

The table below shows the estimated number of reuse (consolidated) ESAs, by 

CROMERR data flow, for years 2015 through 2017. 

CROMERR Data 

Flow

Number of Reuse (Consolidated) ESAs a

2015 2016 2017

ARCS 0

CEDRI 499 16

CSPP 44 8 13

LEAD 94 14 1

MYRCRAID 0

ODS 5 4 5

OTAQDCFUEL 1 1 5

SSTS 8 1

TRIMEweb 1,089 66 40

Total 1,233 600 81

a

 Table includes rounding error.

F. Estimate number of third party ESAs, by CROMERR data flow, for the three-year period 

covered in the ICR. We estimated the number of third party ESAs for participating data 

flows by applying implementation rates derived from data provided by CDX to the 

number of ESAs obtained in Step D. The implementation rates are provided in the table 

below:

CROMERR Data Flow Implementation Rates for Third Party ESAs

2012 2013 2014

CEDRI 81%

CEDRI1 50% 37%

CSPP 2% 46% 47%

eSIPS 56%

LEAD 90% 86% 93%

OTAQDCFUEL 2% 6% 50%

SSTS 56% 67%

TRIMEweb 76% 71% 78%

The table below shows the estimated number of third party ESAs, by CROMERR data 

flow, for years 2015 through 2017. 

CROMERR Data Flow Implementation Rates for Third Party ESAs a

2012 2013 2014

CEDRI 882

CEDRI1 12 8

CSPP 1 21 20

eSIPS 8

LEAD 4,227 4,456 4,801

OTAQDCFUEL 1 4 35
B-7

CROMERR Data Flow Implementation Rates for Third Party ESAs a

2012 2013 2014

SSTS 39 50

TRIMEweb 3,439 3,622 3,995

Total 7,680 8,150 9,791

a

 Table includes rounding error.

All Subscriber Agreements

G. Estimate annual number of subscriber agreements for the three-year period covered by 

the ICR. Using the number of subscriber agreements obtained in Steps B, D, E, and F, 

we estimated the annual number of subscriber agreements for the three-year period 

covered by the ICR. To do this, we averaged the number of subscriber agreements for 

years 2015 through 2017. The results are presented in the table below.

Type of Subscriber Agreement

Number of Subscriber Agreements a

Year 2015 Year 2016 Year 2017 Average

Non-ESAs (Paper Subscriber Agreements) 2,011 2,214 2,201 2,142

ESAs 10,319 11,496 11,613 11,143

Reuse (Consolidated) ESAs 1,233 600 81 638

Third Party ESAs 7,680 8,150 9,791 8,540

a

 Table includes rounding error.

H. Estimate number of subscriber agreements by type of ownership (i.e., private sector vs. 

State/Local) and remove subscriber agreements from Federal government employee 

registrants from this analysis. We referred to data published by the Bureau of Labor 

Statistics on the number of employees in the U.S. These data indicate that 84.32 percent 

of U.S. employees work for the private sector, 13.61 percent of employees work for 

States/Locals, and 2.07 percent of employees work for the Federal government. We 

applied these percentages to the number of ESAs obtained in Step G. We then excluded 

the subscriber agreements from Federal Government employees from the analysis

because Federal government employees are exempt from ICR requirements.

2.3. Results

Exhibit B-2 presents information on the average annual number of subscriber agreements

to be submitted to CDX during the three-year period covered by this ICR.
B-8

Exhibit B-2

Annual Number Subscriber Agreements to be Submitted to 

EPA’s CDX during the Three-Year Period Covered by the ICR a

Type of Subscriber Agreement Average Annual Number

of Subscriber Agreements b

Private Sector

Non-ESAs (Paper Subscriber Agreements) 1,806

ESAs 9,395

Reuse (Consolidated) ESAs 538

Third Party ESAs 7,201

Subtotal 18,941

States/Locals

Non-ESAs (Paper Subscriber Agreements) 292

ESAs 1,517

Reuse (Consolidated) ESAs 87

Third Party ESAs 1,162

Subtotal 3,058

All (Private Sector and States/Locals)

Non-ESAs (Paper Subscriber Agreements) 2,098

ESAs 10,912

Reuse (Consolidated) ESAs 625

Third Party ESAs 8,364

Total 21,999

a

 Exhibit includes rounding error.

b

 Federal government employees are exempt from ICR requirements. As a result, their subscriber 

agreements are not included in the exhibit.
C-1

Appendix C

Methodology for Estimating the Annual Number of Facility Employees Expected to 

Register and Comply with Identity Proofing Requirements of State/Local Electronic 

Document Receiving Systems during the Three-Year Period Covered by the ICR

This appendix describes the methodology for estimating the annual number of facility 

employees expected to register and comply with identity proofing requirements of State/Local 

electronic document receiving systems during the three-year period covered by the Information 

Collection Request (ICR). Section 1 provides an overview of the methodology, Section 2 

provides a detailed discussion of the methodology, and Section 3 presents the results.

1. Overview 

EPA estimated the number of facilities reporting to State/Local electronic document 

receiving systems by first identifying States with existing and new systems and compiling them 

into a table (referred to as the “Master Table” in this analysis).28, 29 We then referred to survey 

data compiled by EPA in 2002 from States that estimated the number of facilities subject to their 

respective receiving systems by environmental program. We updated these State estimates to 

current (2014) levels based on analysis of respondent universe growth rates in EPA program 

ICRs. We then extrapolated the updated survey data to the States in the Master Table to estimate 

their number of facilities. The extrapolation was performed by first finding the total number of 

commercial establishments in each State based on U.S. Census data, comparing the number of 

establishments in the survey States to the States in the Master Table, and using a scaling factor to 

extrapolate the number of facilities in the survey States to the States in the Master Table based 

on their respective number of commercial establishments. We performed this extrapolation by 

environmental program for all States in the Master Table. Finally, we estimated the number of 

employees based on the number of facilities.

 

28

 “Existing electronic document receiving system” means an electronic document receiving system that is 

being used to receive electronic documents in lieu of paper to satisfy requirements under an authorized program on 

October 13, 2005 or the system, if not in use, has been substantially developed on or before that date as evidenced 

by the establishment of system services or specifications by contract or other binding agreement (40 CFR 3.3). 

Pursuant to 40 CFR 3.1000(a)(3), States/Locals with an existing electronic document receiving system for an 

authorized program must submit an application to revise or modify such authorized program in compliance with 

40 CFR 3.1000(a)(1) no later than January 13, 2010.

29

 “New electronic document receiving system” refers to an electronic document receiving system that was 

not being used to receive electronic documents in lieu of paper to satisfy requirements under an authorized program 

on October 13, 2005 or the system, if not in use, that had not been substantially developed on or before that date. 

Pursuant to 40 CFR 3.1000(a)(2), States/Locals with new electronic document receiving systems must receive EPA 

approval of revisions or modifications to the authorized program before the program may receive electronic 

documents in lieu of paper documents to satisfy program requirements.
C-2

2. Detailed Discussion

EPA took the following steps to carry out the methodology.

Find the Number of States with Receiving Systems, by State Environmental Program

A. Identify States with existing and new electronic document receiving systems. To identify

States with existing and new electronic document receiving systems, we referred to

EPA’s CROMERR Program and Stakeholder Management (PSM) System. PSM is a 

custom implementation of a Salesforce.com platform that integrates database records, 

online file storage, multiple distinct spreadsheets, and email logs, to support the reduction 

of Technical Review Committee (TRC) and EPA’s Office of Environmental Information 

(OEI) levels of effort in managing the application approval process. 

For purposes of this analysis, EPA categorized systems based on the following criteria:

Existing Electronic

Document Receiving Systems

New Electronic

Document Receiving Systems

System Type System Stage System Type System Stage

 Existing

 New

 Approval Review

 Completeness Review

 Draft Received

 EPA Approved

 Incomplete

 TRC Approved

 New  Pending Receipt

 Scoping

EPA used data current as of October 9, 2014. 

B. Estimate the number of existing and new State receiving systems, by environmental 

program. Existing and new receiving systems were categorized into State environmental 

programs based on the statute associated with the authorized program (e.g., Clean Air Act 

(CAA), Clean Water Act (CWA)). Attachment C-1 presents a table of the States with 

existing and new receiving systems, by State environmental program. This table is called 

the “Master Table” in this appendix.

Estimate the Number of Facilities, by State Environmental Program

C. Estimate number of facilities by State environmental program, based on CROMERR costbenefit analysis (CBA) survey data. To obtain information on the number of facilities by 

State environmental program, we referred to “Table V-2. Existing State Receiving 

Systems” of Cross-Media Electronic Reporting and Records Rule (CROMERRR) Cost 

Benefit Analysis - Final; dated November 17, 2004. This table contains information on 

the number of facilities associated with State receiving systems reported in a survey 

conducted by EPA during the summer of 2002. Attachment C-2 shows the number of 

facilities by State environmental program based on CBA survey data.
C-3

D. Update CBA’s facility estimate for each State environmental program, based on ICR 

respondent data. The data on number of facilities developed under Step C are based on 

2002 data. In order to bring these numbers to the present (2014), we took the following 

steps:

 Obtained data on annual number of respondents in the ICRs listed in Attachment C-3. 

For each ICR, we obtained respondent universe estimates for at least two different 

years (e.g., 2003 and 2012) to enable us to estimate the annual percent change in the 

universe.

 Estimated the annual percent change in number of respondents for each ICR.

 Multiplied the annual percent change by 12 to estimate percent change over the 

2002-2014 period.

 Applied the 2002-2014 percent change to facility estimates in order to update the 

number of facilities for each environmental program.

Attachment C-4 shows the ICR data used to update the CBA’s facility estimates, by State 

environmental program.

Extrapolate Updated State Survey Data on Number of Facilities to All States in Master Table

E. Develop a scaling factor for use in extrapolation. We referred to U.S. Census Bureau 

data on number of establishments by employment size for States.30 Based on these data, 

which are presented in Attachment C-5, we obtained the following information for each 

environmental program: 

 Number of commercial establishments in the survey States for which respondent data 

were available; and

 Number of commercial establishments in States in the Master Table with existing 

and/or planned receiving systems. 

We then used these data to derive a scaling factor to be used in Step F. This scaling 

factor was derived using the following equation:

Scaling Factor = Number of establishments in States in Master Table

Number of establishments in survey States

F. Extrapolate the CBA’s updated facility estimates to States with existing and new

receiving systems. In deriving the total number of facilities in all States in the Master 

Table, we first estimated the total number of facilities associated with each environmental 

program. To do this, we multiplied the updated survey data (Step D) by the 

corresponding scaling factor derived in Step E. This gave us the total number of facilities 

reporting to the receiving systems of States in the Master Table, by environmental 

program. We then added up the total number of facilities in States in the Master Table

across all environmental programs. 

 

30

 U.S. Census Bureau, “Number of Firms, Number of Establishments, Employment, and Annual Payroll 

by Enterprise Employment Size for the United States and States, Totals: 2011,” December 2013. Available online 

at: http://www.census.gov/econ/susb/, last accessed on October 12, 2014. These are the latest Statistics of U.S. 

Businesses (SUSB) annual data.
C-4

G. Estimate annual number of facilities subject to the ICR requirements. In estimating the 

annual number of facilities subject to the ICR requirements, we made the following 

assumptions:

 Existing receiving systems: For purposes of this analysis, we assume that existing 

systems have been in operation since 2005. EPA estimates that 30 percent of 

facilities began to use the receiving system in the first year (i.e., 2005) and 10 percent 

in each subsequent year.

 New receiving systems: We assume that one third of facilities will begin reporting in 

each year of the three-year period covered by the ICR. In each year of the ICR, EPA 

estimates that 30 percent of facilities will begin to use the receiving system in the first 

year and 10 percent in each subsequent year. 

The above implementation rates for use of an electronic receiving system were taken 

from the CBA (Exhibit 2-5). 

H. Estimate average annual number of facilities subject to the ICR requirements, by 

employment size. In estimating the average annual number of facilities by employment 

size, we referred to the U.S. Census Bureau data presented in Attachment C-5. Based on 

these data, in the U.S., 70 percent of establishments have less than 20 employees and 

30 percent of establishments have 20 or more employees. We applied these percentages 

to the annual number of facilities in Step G. Once we estimated the annual number of 

facilities for each year from 2015 through 2017 (i.e., the three-year period covered by the 

ICR), we obtained the average over three years.

I. Estimate average annual number of facility employees subject to the ICR requirements. 

In estimating the average annual number of facility employees, we assumed that small 

firm facilities have three employees and that medium/large firm facilities have six 

employees. These estimates were taken from the CBA (Section 2.3.3, “Facilities;” 

page 26). 

J. Estimate average annual number of facility employees subject to the ICR requirements by 

type of ownership (i.e., private sector vs. State/Local) and remove Federal government 

facilities from this analysis. In estimating the average annual number of facility 

employees by type of ownership, we referred to data published by the Bureau of Labor 

Statistics on the number of employees in the U.S.31 These data indicate that 

84.32 percent of U.S. employees work for the private sector, 13.61 percent of employees 

work for States/Locals, and 2.07 percent of employees work for the Federal government. 

We applied these percentages to the annual number of facility employees in Step I. We 

then excluded Federal government employees from the analysis because they are exempt 

from ICR requirements.

 

31

 Bureau of Labor Statistics; Quarterly Census of Employment and Wages; Number of Employees (US 

Total, All Industries, All Establishment Sizes, All Employees); 2013 (Annual). Available online at: 

http://data.bls.gov/pdq/querytool.jsp?survey=en, last accessed on October 12, 2014. 
C-5

Attachments C-6 and C-7 present details on the application of the above methodology to 

existing and new receiving systems, respectively.

3. Results

Exhibit C-1 presents information on the average annual number of facility employees 

expected to register with existing and new State/Local receiving systems. 

Exhibit C-1

Average Annual Number of Facility Employees Expected to

Register with Existing and New State/Local Receiving Systems

during the Three-Year Period Covered by the ICR a

Type of Firm

Average Annual Number of Facility Employees b

Existing Receiving Systems New Receiving System All Receiving Systems

(i.e., Existing and New)

Private Sector

Small Firms 6,769 4,988 11,757

Medium-Size and Large Firms 5,803 4,275 10,078

Subtotal 12,572 9,263 21,835

States/Locals

Small Firms 1,093 805 1,898

Medium-Size and Large Firms 937 690 1,627

Subtotal 2,030 1,495 3,525

All (Private Sector and States/Locals)

Small Firms 7,862 5,793 13,655

Medium-Size and Large Firms 6,740 4,965 11,705

Total 14,602 10,758 25,360

a

 Exhibit includes rounding error.

b

 Federal government employees are not reflected in the table because they are exempt from ICR requirements.
C-6

Attachment C-1

Number of Existing and New State/Local Electronic Document

Receiving Systems, by State Environmental Program

(also referred to as the “Master Table”)

State

Existing Systems New Systems

Air Water Waste Air Water Waste

Alabama X

Alaska X X

American Samoa

Arizona X X

Arkansas X X X

California X X X

Colorado X

Connecticut X X

Delaware X X X

District of Columbia X X X X

Florida X X X

Georgia X X

Guam

Hawaii X X

Idaho X

Illinois X X

Indiana X X X

Iowa X X

Kansas X X X

Kentucky X X X

Louisiana X

Maine X

Maryland X

Massachusetts X X X X

Michigan X X X

Minnesota X X X

Mississippi X X X

Missouri b X X X X

Montana X

Nebraska X X

Nevada X X

New Hampshire X

New Jersey X X X
C-7

Attachment C-1 (continued)

Number of Existing and New State/Local Electronic Document

Receiving Systems, by State Environmental Program

(also referred to as the “Master Table”)

State

Existing Systems New Systems

Air Water Waste Air Water Waste

New Mexico X

New York X X X

North Carolina X X X X

North Dakota X

Northern Mariana Islands

Ohio X X X

Oklahoma X X X

Oregon X

Pennsylvania

Puerto Rico

Rhode Island X

South Carolina X

South Dakota X X X

Tennessee X X

Texas X X X

U.S. Virgin Islands

Utah X

Vermont X X X

Virginia X X X

Washington X X X

West Virginia X

Wisconsin X X X

Wyoming X X X

Source: U.S. Environmental Protection Agency (USEPA), CROMERR Program and Stakeholder Management (PSM) System, 

data current as of October 9, 2014.
C-8

Attachment C-2

Number of Facilities Associated with Existing State Electronic Document Receiving Systems

in the CROMERR Cost-Benefit Analysis Survey, by State Environmental Program

(Data Current as of Summer 2002)

State

Air Water Waste, USTs, Emergency Planning

Air

(CEM)

Air

Permits

Air

(NEI)

Air

Title V

Emissions

Emission

Reports

(Non-Title V)

Air

Quality

PTO

Applications

Asbestos

Notification EDMR

Drinking/

Ground

Water

Wastewater UIC

HW

Annual

Report

UST Risk

Management

Florida 3

New Jersey 12 1,500 1,000

New Mexico 200

North Dakota 250

Ohio 200 780 2,400 780 5,700 1,550 480 500

Pennsylvania 125 6,000

Wisconsin 5,200 22 600

a

 For purposes of this analysis, data for Wisconsin’s “Consolidated (air, haz waste)” program was divided among the “Air” and “HW Annual Report” categories. Specifically, 90 percent of 

the facilities were allocated to the “Air” category and the remaining 10 percent were allocated to the “HW Annual Report” category. This allocation was based on Ohio’s data and available 

information on the number of hazardous waste handlers that reported to the 2007 Hazardous Waste Report.

Source: U.S. Environmental Protection Agency (USEPA), “Table V-2. Existing State Receiving Systems” of Cross-Media Electronic Reporting and Records Rule (CROMERRR) Cost 

Benefit Analysis, Final; November 17, 2004.

Acronyms

CEM Continuous Emissions Monitoring

EDMR Electronic Discharge Monitoring Report

HW Hazardous Waste

NEI National Emission Inventory

PTO Permit to Operate

UIC Underground Injection Control

UST Underground Storage Tank
C-9

Attachment C-3

List of ICRs Used in Analysis, by Environmental Program

ICR Numbers ICR Name

Air

1587.06

1587.12 State Operating Permit Regulations

111.10

111.13

NESHAP for Asbestos

1088.10

1088.13

NSPS for Industrial-Commercial-Institutional Steam Generating Units

Water

2.11

2.15

National Pretreatment Program

270.42

270.45

Public Water System Supervision Program

Waste, USTs, Emergency Planning

261.14 Notification of Regulated Waste Activity

976.11 2007 Hazardous Waste Report

976.16

2013 Hazardous Waste Report, Notification of Regulated Waste Activity, and Part A 

Hazardous Waste Permit Application and Modification

1380.07

1380.12

Underground Storage Tanks: Technical and Financial Requirements, and State Program 

Approval Procedures

Source: U.S. Environmental Protection Agency (USEPA), Information Collection Request, Review, and Approval System 

(ICRAS). Data obtained on August 13, 2014.
C-10

Attachment C-4a

ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA

Air Programs

State Operating Permit Regulations

EPA ICR Number 

1587.06

EPA ICR Number 

1587.12

2004 2011

Permitting Authorities and Sources Subject to Permitting under 40 CFR Part 70 17,738 16,052 -9.5% 7 -1.4% 0.59 -0.8% -0.6%

NESHAP for Asbestos

EPA ICR Number 

111.10

EPA ICR Number 

111.13

2003 2011

Respondents 9,848 9,517 -3.4% 8 -0.4% 0.35 -0.1%

NSPS for Industrial-Commercial-Institutional Steam Generating Units

EPA ICR Number 

1088.10

EPA ICR Number 

1088.13

2003 2012

Respondents 1,230 1,727 40.4% 9 4.5% 0.06 0.3%

Total Number Respondents for All ICRs 27,296

Weight

Weight

Weight

Average Annual 

Percent Change for 

Environmental 

Program

Weighted Annual 

Percent Change in 

Number of 

Respondents

Weighted Annual 

Percent Change in 

Number of 

Respondents

Weighted Annual 

Percent Change in 

Number of 

Respondents

Respondent Universe

Respondent Universe

Respondent Universe

Annual Number of Respondents

Annual Number of Respondents

Number 

of Years

Percent Change 

in Number of 

Respondents

Annual Percent 

Change in Number 

of Respondents

Number 

of Years

Number 

of Years

Annual Number of Respondents Percent Change 

in Number of 

Respondents

Annual Percent 

Change in Number 

of Respondents

Percent Change 

in Number of 

Respondents

Annual Percent 

Change in Number 

of Respondents
C-11

Attachment C-4b

ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA

Water Programs

National Pretreatment Program

EPA ICR Number 

2.11

EPA ICR Number 

2.15

2004 2011

Industrial users (IUs), POTWs, and States 28,285 24,411 -13.7% 7 -2.0% 0.14 -0.3% -0.8%

Public Water System Supervision Program

EPA ICR Number 

270.42

EPA ICR Number 

270.45

2004 2011

Existing PWSs, Primary Agencies, and Laboratories 161,682 154,938 -4.2% 7 -0.6% 0.86 -0.5%

Total Number Respondents for All ICRs 179,349

Average Annual 

Percent Change for 

Environmental 

Program

Percent Change 

in Number of 

Respondents

Annual Percent 

Change in Number 

of Respondents

Weight

Weighted Annual 

Percent Change in 

Number of 

Respondents

Respondent Universe

Annual Number of Respondents

Respondent Universe

Annual Number of Respondents

Weighted Annual 

Percent Change in 

Number of 

Respondents

Percent Change 

in Number of 

Respondents

Number 

of Years

Number 

of Years Weight

Annual Percent 

Change in Number 

of Respondents
C-12

Attachment C-4c

ICR Data Used to Update Number of Facilities Obtained from CROMERR CBA

Waste, USTs, Emergency Planning Programs

Notification of Regulated Waste Activity

EPA ICR Number 

261.14

EPA ICR Number 

976.16

2003 2012

Initial and Subsequent Notifications under RCRA Section 3010; 40 CFR Part 273, Subpart C; and 40 CFR Part 279 31,125 46,035 47.9% 9 5.3% 0.17 0.9% -1.0%

Hazardous Waste Report

EPA ICR Number 

976.11

EPA ICR Number 

976.16

2003 2012

Respondents to the Hazardous Waste Report 10,178 10,533 3.5% 9 0.4% 0.04 0.0%

Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures

EPA ICR Number 

1360.07

EPA ICR Number 

1360.12

2004 2011

Private and Governments 254,705 211,040 -17.1% 7 -2.4% 0.79 -1.9%

Total Number Respondents for All ICRs 267,608

Weight

Weighted Annual 

Percent Change in 

Number of 

Respondents

Number 

of Years

Annual Percent 

Change in Number 

of Respondents

Weight

Weighted Annual 

Percent Change in 

Number of 

Respondents

Annual Percent 

Change in Number 

of Respondents

Respondent Universe

Annual Number of Respondents

Respondent Universe

Annual Number of Respondents

Respondent Universe

Annual Number of Respondents

Note: The "Notification of Regulated Waste Activity," "Hazardous Waste Report," and "Part A Hazardous Waste Permit Application and Modification,” ICRs were consolidated into a single ICR. For purposes of this analysis, EPA reviewed the consolidated ICR and extracted 

information on the annual number of respondents associated with the notification and Hazardous Waste Report information collection requirements.

Percent Change 

in Number of 

Respondents

Average Annual 

Percent Change for 

Environmental 

Program

Percent Change 

in Number of 

Respondents

Percent Change 

in Number of 

Respondents

Number 

of Years

Annual Percent 

Change in Number 

of Respondents

Weight

Weighted Annual 

Percent Change in 

Number of 

Respondents

Number 

of Years
C-13

Attachment C-5

Number of Establishments (Facilities) by Employment Size, 2011

STATE Less than 20 Employees 20 or More Employees Total

United States 5,160,237 2,193,806 7,354,043

Alabama 63,531 34,212 97,743

Alaska 14,672 5,447 20,119

Arizona 87,427 42,878 130,305

Arkansas 43,523 20,948 64,471

California 620,726 228,590 849,316

Colorado 110,895 39,994 150,889

Connecticut 61,646 26,394 88,040

Delaware 15,928 8,204 24,132

District of Columbia 12,569 8,976 21,545

Florida 367,662 123,189 490,851

Georgia 146,828 67,807 214,635

Hawaii 21,295 10,177 31,472

Idaho 31,493 10,906 42,399

Illinois 221,285 91,152 312,437

Indiana 93,609 49,870 143,479

Iowa 54,344 25,769 80,113

Kansas 49,554 24,044 73,598

Kentucky 58,367 31,403 89,770

Louisiana 68,736 34,480 103,216

Maine 29,446 10,666 40,112

Maryland 91,698 41,550 133,248

Massachusetts 118,936 50,210 169,146

Michigan 151,473 65,871 217,344

Minnesota 101,406 43,200 144,606

Mississippi 38,705 19,887 58,592

Missouri 99,894 47,380 147,274

Montana 27,970 7,717 35,687

Nebraska 35,862 15,691 51,553

Nevada 39,689 19,088 58,777

New Hampshire 26,003 11,028 37,031

New Jersey 170,203 56,675 226,878

New Mexico 29,748 14,112 43,860

New York 404,335 117,202 521,537

North Carolina 145,815 69,298 215,113

North Dakota 15,765 6,605 22,370

Ohio 161,735 88,741 250,476

Oklahoma 62,095 27,654 89,749
C-14

Attachment C-5 (continued)

Number of Establishments (Facilities) by Employment Size, 2011

STATE Less than 20 Employees 20 or More Employees Total

Oregon 76,997 29,343 106,340

Pennsylvania 199,334 96,386 295,720

Rhode Island 20,622 7,559 28,181

South Carolina 66,893 33,588 100,481

South Dakota 18,501 6,993 25,494

Tennessee 81,870 47,619 129,489

Texas 346,994 178,426 525,420

Utah 50,110 18,637 68,747

Vermont 15,984 5,206 21,190

Virginia 127,999 63,064 191,063

Washington 126,548 46,963 173,511

West Virginia 24,565 13,585 38,150

Wisconsin 93,519 44,526 138,045

Wyoming 15,433 4,896 20,329

Source: U.S. Census Bureau, “Number of Firms, Number of Establishments, Employment, and Annual 

Payroll by Enterprise Employment Size for the United States and States, Totals: 2011,”

December 2013. Available online at: http://www.census.gov/econ/susb/, last accessed on

October 12, 2014. These are the latest Statistics of U.S. Businesses (SUSB) annual data.
C-15

Attachment C-6

Application of Methodology to Existing Receiving Systems

Environmental Program States with Facility 

Data in CBA

Total Number of 

Facilities in CBA

Average Annual 

Percent Change for 

Environmental 

Program

2002-2014 Percent 

Change for 

Environmental 

Program

Updated Total 

Number of 

Facilities in CBA

Air NJ, NM, OH, PA, WI 17,197 -0.6% -7.2% 15,959

Water FL, ND, OH, WI 7,525 -0.8% -9.6% 6,803

Waste, USTs, Emergency Planning NJ, OH, WI 2,580 -1.0% -12.0% 2,270

Environmental Program

Number of 

Establishments for 

States with Facility 

Data in CBA

Number of 

Establishments for 

States with Existing 

Receiving Systems

Scaling Factor

Air 954,979 5,415,429 5.67

Water 901,742 6,883,480 7.63

Waste, USTs, Emergency Planning 615,399 3,696,214 6.01

Environmental Program Updated Total Number 

of Facilties in CBA Scaling Factor

Total Number of 

Facilities for States 

with Existing 

Receiving Systems

Air 15,959 5.67 90,488

Water 6,803 7.63 51,907

Waste, USTs, Emergency Planning 2,270 6.01 13,643

Total Number of Facilities for All Environmental Programs 156,038
C-16

Attachment C-6 (continued)

Application of Methodology to Existing Receiving Systems

Year Number of Facilities

2005 46,811

2006 10,923

2007 9,830

2008 8,847

2009 7,963 Legend:

2010 7,166

2011 6,450

2012 5,805

2013 5,224

2014 4,702

2015 4,232

2016 3,809

2017 3,428

2018 3,085

2019 2,776

2020 2,499

Year 1 Year 2 Year 3

Small Firms 2,962 2,666 2,400 2,676 8,028

Medium-Size and Large Firms 1,270 1,143 1,028 1,147 6,882

Total 4,232 3,809 3,428 3,823 14,910

Type of Firm

Number of Facilities per Year Average Annual 

Number of 

Facilities

Average Annual 

Number of 

Facility 

Employees

Years Covered in the ICR
C-17

Attachment C-7

Application of Methodology to New Receiving Systems

Environmental Program States with Facility 

Data in CBA

Total Number of 

Facilities in CBA

Average Annual 

Percent Change for 

Environmental 

Program

2002-2014 Percent 

Change for 

Environmental 

Program

Updated Total 

Number of 

Facilities in CBA

Air NJ, NM, OH, PA, WI 17,197 -0.6% -7.2% 15,959

Water FL, ND, OH, WI 7,525 -0.8% -9.6% 6,803

Waste, USTs, Emergency Planning NJ, OH, WI 2,580 -1.0% -12.0% 2,270

Environmental Program

Number of 

Establishments for 

States with Facility 

Data in CBA

Number of 

Establishments for 

States with New 

Receiving Systems

Scaling Factor

Air 954,979 585,036 0.61

Water 901,742 1,573,831 1.75

Waste, USTs, Emergency Planning 615,399 360,209 0.59

Environmental Program Updated Total Number 

of Facilties in CBA Scaling Factor

Total Number of 

Facilities for States 

with New Receiving 

Systems

Air 15,959 0.61 9,735

Water 6,803 1.75 11,905

Waste, USTs, Emergency Planning 2,270 0.59 1,339

22,979

7,660

Year 1 Year 2 Year 3

Year 1 2,298 536 483

Year 2 0 2,298 536

Year 3 0 0 2,298

Total 2,298 2,834 3,317

Year 1 Year 2 Year 3

Small Firms 1,609 1,984 2,322 1,972 5,916

Medium-Size and Large Firms 689 850 995 845 5,070

Total 2,298 2,834 3,317 2,817 10,986

Annual Number of Facilities that Will Come Online

Total Number of Facilities for All Environmental Programs

Type of Firm

Number of Facilities per Year

Year System Will Come Online Number of Facilities per Year

Average Annual 

Number of 

Facilities

Average Annual 

Number of 

Facility 

Employees