Supporting Statement for a Request for OMB Review under

The Paperwork Reduction Act

1 IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection

Title: Asbestos-Containing Materials in Schools Rule and Revised Asbestos Model 

Accreditation Plan Rule

EPA ICR No.: 1365.09 OMB Control No.: 2070-0091

1(b) Short Characterization

This ICR addresses reporting and recordkeeping requirements found in the AsbestosContaining Materials in Schools Rule (“AHERA Rule”) and the Asbestos Model Accreditation 

Plan (MAP) Rule.

AHERA Rule: Under Section 203 of the Asbestos Hazard Emergency Response Act 

(AHERA, 15 U.S.C. 2641-2656) (see Attachment A), EPA was required to finalize the AsbestosContaining Materials in Schools Rule. This rule required Local Education Agencies (LEAs) to 

conduct inspections, develop management plans, and design or conduct response actions. 

Records must be maintained by all LEAs on inspections and response action activity, and current 

management plans must be provided upon request to EPA and State reviewers for examination.

MAP: Additionally, Section 206 of AHERA (see Attachment B) required that EPA issue 

a Model Accreditation Plan (MAP) for persons who inspect for asbestos, develop management 

plans, and design or conduct response actions. States are required to adopt an accreditation plan 

at least as stringent as the EPA model. In 1990, EPA was required to make certain changes in its 

original MAP. Accreditation of laboratories that analyze asbestos bulk samples and asbestos air 

samples is also required by AHERA. AHERA required the National Institute of Standards and 

Technology (NIST) to establish the bulk sampling accreditation program, and the air sampling 

program.

This information collection activity will assure that LEAs continue to inspect for asbestos 

and update management plans with accredited personnel to protect all school building occupants 

from exposure to asbestos. This collection will also assure that persons who inspect for asbestos, 

develop management plans, and design or conduct response actions are properly accredited, and 

that states will adopt appropriate accreditation programs.
2

2 NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

AHERA Rule and MAP: The reporting and recordkeeping requirements covered by this 

ICR are required by the Asbestos-Containing Materials in Schools Rule (40 CFR 763, Subpart E) 

and the Model Accreditation Plan (40 CFR 763, Subpart E, Appendix C); see Attachments C and 

D, respectively.

2(b) Use/Users of the Data

AHERA Rule: The activities pertaining to the use of this information collection activity

help assure that LEAs continue to inspect for asbestos and update their management plans using 

accredited personnel. This is intended to ensure the protection of all school building occupants 

from exposure to asbestos fibers. All public and private elementary and secondary schools 

(unless exempt under provision of the rule) were required to conduct inspections for asbestoscontaining building materials (ACBM) and develop management plans that describe necessary

actions to be undertaken. Reinspections by accredited persons must take place every three years 

unless all ACBM has been removed. Records retention as part of an updated asbestos 

management plan is necessary in order to document specific response action activities and 

periodic surveillance/3-year reinspection reports, and for an LEA to demonstrate compliance 

with the regulations. Beneficiaries of the collection activities include the LEA’s asbestos 

program manager and staff, accredited professionals who may be called upon to perform 

response actions at a school, and Federal and State enforcement agencies.

MAP: This collection will enable EPA, as well as State regulators, to determine initial 

compliance and to monitor continued compliance with the revised MAP standards. Lacking both 

the application submissions and other recordkeeping requirements, regulators would have no 

meaningful way of measuring the implementation of the MAP’s statutory mandates. Other 

beneficiaries of the collection activities include 1) individuals who may desire to obtain asbestos 

training meeting at least prescribed minimum quality standards for accreditation and subsequent 

employment purposes; 2) LEAs and other building owners and managers seeking to procure the 

services of qualified and accredited asbestos consultants and contractors; and 3) enforcement 

agencies at the Federal and State level.

3 NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-Duplication

AHERA Rule: EPA has tried to identify alternate sources of the information requested to 

implement and enforce this recordkeeping, and was not successful. This activity does not 

duplicate information already required to be reported by another agency or EPA program office.
3

MAP: All of the training and accreditation information collected pursuant to this ICR is 

specific to the MAP and does not duplicate any other collection. There is no other model 

accreditation plan for States other than the MAP, and there is no procedure for the accreditation 

of asbestos training programs under the Asbestos School Hazard Abatement Reauthorization Act 

(ASHARA) other than what is specifically provided for in the MAP.

3(b) Public Notice Required Prior to ICR Submission to OMB

Prior to submission to OMB, this ICR will be made available to the public for comment 

through a Federal Register notice. The public will have 60 days to provide comments. Any 

comments received will be given consideration when completing the supporting statement that is 

submitted to OMB.

3(c) Consultations

AHERA Rule: The Asbestos-Containing Materials in Schools Rule was 

developed through the regulatory negotiation process. Participants included representatives of 

national educational organizations, labor unions, asbestos product manufacturers, the 

environmental community, asbestos abatement contractor groups, professional associations of 

architects, consulting engineers, industrial hygienists, and EPA.

In December 2003 and January 2004, EPA consulted with the Agency regional asbestos 

coordinators and State regulatory agencies to determine if the creation of charter schools in 

recent years has led to additional respondents or respondent burden due to AHERA 

requirements. At this time insufficient information is available to demonstrate that any

additional reporting burden currently exists beyond that already identified for public schools 

(which include charter schools) in Section 6 of this ICR.

MAP: Consultations occurred with various respondents since development work on the 

MAP Rule revision began several years ago. Exploratory meetings were held with labor unions 

(May 1991) and States (June 1991) to learn of their interests and concerns. EPA published its 

proposed changes to the MAP in the Federal Register on May 13, 1992, and formally invited 

public comment. A public hearing was held June 8, 1992. An additional hearing, with the 

cooperation of the National Conference on State Legislatures (NCSL), occurred on June 9, 1992. 

Collection activities were discussed with State participants at that time. They continued to 

express support for EPA’s MAP proposals.

EPA consulted extensively with labor unions, the States, and other interested parties 

during the development of the 1994 Interim Final MAP. 

For the purposes of the current ICR renewal request, in January 2007, EPA conducted 

consultations on the ICR supporting statement with seven representatives of the regulated 

community affected by the ICR. These individuals included an asbestos MAP training provider 

listed under the National Directory of AHERA Accredited Courses (NDAAC), three AHERA 

designated persons for LEAs, a laboratory that performs asbestos testing, an LEA trade 

association, and a relevant asbestos worker trade association. 
4

NDAAC training providers are accredited by EPA or by a state that has developed an 

accreditation program. AHERA designated persons are responsible for implementing the 

requirements under the Asbestos-Containing Materials in Schools Rule (40 CFR 763 Subpart E) 

pursuant to AHERA for their respective local education agency (LEA). Laboratories that 

perform asbestos bulk or air tests also must comply with the requirements under the AsbestosContaining Materials in Schools Rule (40 CFR 763 Subpart E) and be properly accredited by the 

National Institute of Standards and Technology. 

Under 5 CFR 1320.8(d)(1) OMB requires agencies to consult with potential ICR 

respondents and data users about specific aspects of ICRs before submitting an original or 

renewal ICR to OMB for review and approval. In accordance with this regulation, EPA will 

pursue additional consultations with interested parties during the development of the renewal of 

this collection.

3(d) Effects of Less Frequent Collection

AHERA Rule: If information were collected less frequently, it would be difficult to 

determine whether an LEA properly inspected for asbestos-containing materials and developed 

an appropriate management plan, and kept these documents up-to-date including ongoing 

activities.

MAP: The revised MAP has no routine or repetitive reporting requirements. Training 

course self-certifications, training course approval applications and State Program approval 

applications are one-time submissions. Once approved, they do not expire. A less frequent 

collection schedule is not feasible. Recordkeeping requirements are tied directly to training 

courses and the issuance of accreditation certificates to students successfully completing those 

courses and passing the requisite exams. If training providers are inactive and not offering 

courses, no new record generation is required of them.

3(e) General Guidelines

Except as described in this section, the collection activities in this ICR adhere to the 

guidelines stated in the Paperwork Reduction Act, OMB’s implementing regulations, and 

applicable OMB and EPA guidance.

AHERA Rule: The rule requires that the asbestos management plans be maintained as a 

living document, necessary for as long as asbestos-containing building materials are present in 

the school building. When all asbestos materials have been removed from a homogeneous area, 

records pertaining to that homogeneous area must be retained for three years after the next 

reinspection date. As a result, such records may need to be maintained beyond the three year 

record retention period recommended in 5 CFR 1320.5(d)(2)(iv). EPA believes, however, that 

these retention requirements are necessary to satisfy the statutory mandates in AHERA, which 

specifically mandates the development and maintenance of asbestos management plans. In 

addition to ensuring that a management plan is available for public inspection as required by

AHERA, maintaining a current management plan is necessary and critical for ensuring the 
5

proper protection of human health, safety, and the environment as required by AHERA. 

Providing up-to-date information about the location and status of asbestos-containing building 

materials that remain present in the school building is also essential for ensuring that the material 

does not subsequently become unintentionally disturbed or damaged such that it may pose an 

unreasonable risk to school employees, children and other building occupants or users. In 

accordance with 5 CFR 1320.5(d)(2), the retention period beyond the recommended three year 

period is necessary and appropriate.

In approving the ICR in 1998, OMB stated the following: “This ICR is approved for 3 

years. As requested in previous terms of clearance- EPA will report on amendments to the 

School Rule as they relate to record retention periods and reinspection periods.” The previous 

terms of clearance referenced were from 1995 that stated, “This ICR is approved for three yearsas requested. EPA has done a good job updating labor rates for school employees. EPA shall 

report on the progress of the Region VII lead amendments to the Schools Rule as it relates to 

record retention periods -beyond 3 years- and reinspection periods -3 years-. EPA should 

continue to separate its MAP burden estimates for the schools estimates.”

As reflected in the 1995 statement, EPA had initiated an Agency workgroup in 1994 to 

evaluate the AHERA Rule for potential amendments related to enforcement, and this effort was 

subsequently expanded to include the consideration of potential amendments to the record 

retention and reinspection periods as OMB requested. This workgroup effort did not result in 

any proposed revisions to the AHERA Rule and has since been abandoned.

The Agency has concluded that the reinspection interval is necessary to satisfy the 

statutory mandates in AHERA, which specifically mandates the periodic surveillance and 

reinspection of asbestos-containing materials, and that the current interval is appropriate and 

necessary for ensuring that the asbestos-containing material does not subsequently become 

disturbed or damaged such that it is likely to become a potential hazard to school employees, 

children and other building occupants or users. The existing reinspection period is consistent 

with the provisions in 5 CFR 1320.5(d)(2).

MAP: There are no exceptions to note.

3(f) Confidentiality

This information collection does not include questions of a confidential nature.

3(g) Sensitive Questions

This information collection does not include questions of a sensitive nature.
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4 THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

AHERA Rule and MAP: There are three types of respondents for this information 

collection request. LEAs and States are involved in recordkeeping and reporting activities 

associated with the Schools Rule, while training providers and States are involved in 

recordkeeping and reporting activities related to the MAP Rule. The respondent activities are 

different for each respondent type and are discussed in turn. The respondents to this information 

collection activity are elementary and secondary school districts (NAICS code 61111), and all 

states (NAICS code 92311). Additionally, under ASHARA, the Model Accreditation Plan 

(MAP) affects training providers (NAICS code 61143), and State Asbestos Accreditation 

Programs (NAICS code 92312). These respondents are included because they are the providers 

and guarantors of accreditation, respectively.

4(b) Information Requested

(i) Data Items

AHERA Rule: There are no specific data collection instruments used to collect 

information for this activity. The AHERA Rule required management plans to be submitted to 

the States for review before October 12, 1988. LEAs must also submit management plans to the 

States for review for school buildings that have since come into operation after October 12, 

1988. The rule continues to require recordkeeping.

MAP: Training providers seeking re-approval for their existing training courses based 

upon the revised MAP standards, or initial approval for new training programs based upon the 

increased MAP standards, were required in 1994 to report the following data items:

- a self-certification letter for upgraded approval pursuant to Part IV.2 of the MAP; or

- an application for a new training course approval pursuant to Part III.a of the MAP.

When a training provider offers approved training programs for accreditation purposes, 

certain records must be maintained for a three-year period in accordance with the MAP Part I.6. 

e.g.,

- copies of all instructional materials used;

- copies of all instructor resumes and approvals;

- copies of examinations and test scores; and

- records relating to accreditation certificates.

A State seeking re-approval of its existing accreditation program based upon the new 

MAP standards, or initial approval of its State accreditation program based on the new MAP 

standards, must report the following data item:

- an application for EPA approval pursuant to Part II of the MAP.
7

There are no recordkeeping requirements in the MAP that relate to State programs.

(ii) Respondent Activities 

MAP: Training and Accreditation

Under AHERA, LEAs shall use trained, accredited persons to perform asbestos-related 

tasks as defined by the revised MAP. Specifically, the MAP shall be used as a tool to accredit 

persons who:

- conduct inspections or reinspections for asbestos-containing material (ACM);

- prepare and/or update management plans for elementary and secondary schools; and

- design or carry out response actions with respect to ACM in those schools.

ASHARA extended that requirement to similar activities in public and commercial 

buildings as well (including residential buildings with 10 or more dwelling units), with 

the exception of the preparation of asbestos management plans.

Respondents who are training entities will need to perform certain collection activities:

- read the regulation;

- make any required changes to training programs;

- retain records/materials costs (usual business practice);

- provide reasonable access to records to EPA and/or the state, as requested.

Waiver for State Programs

The AHERA Rule provides a procedure to allow states to receive a waiver from some or 

all of the requirements of the rule if the state has established and is implementing, or intends to 

implement, a program of asbestos inspection and management at least as stringent as the 

requirements of the rule. The rule requires specific information to be included in the waiver 

request submitted to EPA. To date, 11 states have been granted this waiver under the AHERA 

Rule.

Respondents who are state accreditation programs will need to perform the following 

collection activities:

- read the regulation;

- compare state program authority and the minimum requirements of the regulation;

- develop state legislative analysis and adopt new legislation;

- develop state regulatory analysis and promulgate a new state regulation;

- prepare and submit to EPA an application for program approval; and

- implement a state accreditation program that is not less stringent than the regulation.

As of February 2007, 38 states are operating state accreditation programs under the MAP.

AHERA Rule:
8

Local Education Agencies: Local education agency (i.e., school or school district) 

reporting and recordkeeping under the Schools Rule may be divided into two main categories: 

those associated with the management plan, and those associated with operations and 

maintenance (O&M) activities. Most of the LEA recordkeeping burden involves the 

development and implementation of the management plan.

The management plan burden varies by school type as well as by the type of ACM found 

in a school. The management plan recordkeeping and reporting burden items include:

- Development and submission of the management plan; and

- Implementation of the management plan including:

-- Time spent by the program manager to do additional activity planning, create 

and gather new information, prepare written activity reports, and record and 

review that information;

-- Time spent by custodians and clerical personnel to gather, record, process and 

store asbestos-related information; and

-- Annual notification of parents and other interested parties of the presence of 

ACM in a school, as well as the availability of the management plan for public 

review.

The AHERA Rule required management plans to be submitted to the states for review 

before October 12, 1988. LEAs must also submit management plans to the states for review for 

school buildings that have since come into operation after October 12, 1988. The recordkeeping 

activities associated with the management plan implementation are on-going and are therefore 

included in burden estimates.

Recordkeeping Requirements: The recordkeeping burden associated with the 

development of an O&M activity plan was largely completed in the first year of AHERA Rule 

implementation. On an ongoing basis, however (AHERA regulations also require LEAs to keep 

known or assumed ACBM under periodic surveillance), the O&M plan may require updating. 

The original inspection report and any reinspection reports must be maintained in the 

management plan. Management planner recommendations and response actions with their air 

sampling clearance records are also to be kept. Records required by the rule also include those 

pertaining to fiber release episodes, periodic surveillance, training received by workers 

performing operation and maintenance activities, and cleaning activities that are part of an 

operations and maintenance program. The rule also requires LEAs to collect and retain various 

records that are not part of the information included in the management plan.

The rule requires LEAs to have accredited inspectors conduct reinspections at least once 

every three years after the management plan is in effect. Results of this reinspection shall be 

recorded in the school’s management plan, along with any necessary changes in response actions 

recommended or required.
9

The rule directs the LEA to select and implement in a timely manner appropriate 

response actions for ACBM that are assessed by the accredited inspector and management 

planner. The rule identifies five major response actions -- operations and maintenance (O&M), 

repair, encapsulation, enclosure, and removal -- and describes appropriate conditions under 

which they may be selected by the LEA. The rule also identifies the steps that shall be taken to 

properly conduct and complete the response actions.

After performing a thorough visual inspection of the area in which the response action 

was conducted, air testing is performed to determine whether a response action has been properly

completed. The rule as it is in effect at this time (2007) requires the use of transmission electron 

microscopy (TEM) for all removal, enclosure, encapsulation, or repair response actions 

involving more than 260 linear feet or more than 160 square feet of ACBM. The use of phase 

contrast microscopy (PCM) is allowed by the rule for final air sampling where the amounts of 

ACBM are less than the limits above and greater than for small projects of short duration.

Response actions that fail to meet prescribed air sampling standards by the stipulated 

sampling methods shall have the areas re-cleaned and re-sampled before being released for 

reoccupation. Records of response actions and subsequent air sampling clearance records must 

be maintained by the LEA.

The rule requires each LEA to maintain a copy of the management plan(s) in its 

administrative office, and each school is required to maintain a copy of its specific management 

plan in its administrative office. These plans are to be made available for inspection by the 

public without cost or restriction. LEAs must notify parent, teacher, and employee organizations 

of the availability of the management plans upon submission of the management plan to the State 

and at least once each school year.

States: States are involved in both the Schools Rule and the MAP Rule. In the first year 

of the Schools Rule, State governments were required to establish teams to review and approve 

management plans submitted by schools. This activity, however, is assumed to have been 

completed, and is therefore no longer included in burden estimates.

5 THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY AND INFORMATION MANAGEMENT

5(a) Agency Activities

AHERA Rule and MAP include the following:

- Distribute guidance to LEAs, state designees, and others on interpretation of 

AHERA;

- Audit training provider courses and records for compliance monitoring purposes;

- Review state program applications packages for approval/reapproval as they are 

received;
10

- Maintain and revise master database of approved training providers as required to 

be used as a resource for the public;

- Revise model criteria as appropriate and develop new curricula for new training 

disciplines as required;

- Provide technical assistance to LEAs and public on implementation and 

compliance with AHERA.

5(b) Collection Methodology and Management

AHERA Rule: No specific collection methodologies or management techniques are 

required.

MAP: The rule provides explicit instruction to training providers with preexisting 

approvals who wish to upgrade and continue offering asbestos training courses under the revised 

MAP standards. Providers were to submit a one-time self-certification in the form of a detailed 

letter to EPA describing changes made to their courses for the purpose of bringing them into 

compliance with the new MAP. This was required to be done within six months of the revised 

MAP taking effect. Only one letter was required from each training entity. EPA then compiled 

a listing of all self-certifications received by the deadline and entered them into the existing data 

base of approved training providers. After distribution to EPA Regional Offices and state 

program offices, compliance and program audits may be carried out. New training providers are 

to follow the same procedure.

The MAP Rule also prescribes the method by which states are to make application to 

EPA for accreditation program approval under the revised MAP. States wishing to obtain EPA 

program approval must make a one-time application to the appropriate EPA Regional Office, 

demonstrating how the state’s program is no less stringent than the MAP.

5(c) Small Entity Flexibility

The impact of the AHERA Rule and the MAP will primarily affect small asbestos 

abatement contracting firms or accredited consultants, and training providers that qualify for 

“small business” status. Small business training providers have a one-time only application 

process for training course approvals by MAP approved states that allows for flexibility in the 

way information is prepared and presented. A small business abatement contractor is required to 

keep and maintain records on the accreditation status of supervisors and abatement workers. 

Accreditation records are also kept and maintained by consultants, such as inspectors, 

management planners, and project designers. An advantage accruing from having those records 

is that of obtaining and retaining eligibility to qualify for work in asbestos control and abatement 

in schools and public and commercial buildings. With regard to worker protection, AHERA and 

the MAP impose no additional requirements beyond those that already exist in the OSHA 

asbestos standard or the EPA Worker Protection Rule.

5(d) Collection Schedule

Not applicable for AHERA Rule.
11

MAP: EPA’s receipt of a complete self-certification submission from a provider 

constituted immediate re-approval of the training courses. Where state legislatures convened in 

January 1994, a 180-day deadline was triggered for applying to EPA for new program approval, 

if needed. States not applying for new program approval by the end of the 180-day deadline 

forfeited their previous program approval, and they must then reapply in order to re-establish 

their state accreditation programs.

EPA-approved state programs may continue to receive new training course applications 

indefinitely into the future. EPA may continue to receive state program applications from 

unapproved states until all states, territories, and similar entities have ultimately obtained 

approval.

6 ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

The original ICR for the Asbestos-Containing Materials in Schools Rule (“Schools 

Rule”) based its burden estimates on a 30-year projection to reflect the estimated remaining life 

span of school buildings with Asbestos-Containing Materials (ACM). The previous Schools 

Rule ICR renewal (approved in 2007) updated values from the original ICR. This ICR renewal 

further updates values where noted in the sections below. Burden estimates based on the 

Asbestos Model Accreditation Plan (MAP) Rule were also included in the last ICR. Those 

values are also updated.

There are three types of respondents for this ICR: LEAs involved in recordkeeping and 

reporting activities associated with the Schools Rule, and training providers and States involved 

in recordkeeping and reporting activities related to the MAP Rule. The respondent activities are 

different for each type of respondent and are discussed in turn in the following section.

6(a) Estimating Respondent Burden

Local Education Agencies

Local education agency (i.e., school or school district) reporting and recordkeeping 

activities under the Schools Rule may be divided into two main categories: those associated with 

the management plan and those associated with operations and maintenance (O&M) activities. 

Schools with friable ACM incur burden for the management plan and O&M activities, while 

schools with nonfriable ACM (including newly constructed schools that are certified through an 

exclusionary statement not to have specified asbestos-containing building materials in 

construction) incur burden only for the management plan.

The management plan burden varies by school type as well as by the type of ACM found 

in a school. Appendix G of the Final Schools Rule Asbestos Hazard Emergency Response Act 

Regulatory Impact Analysis (EPA, 1987a) contains time and cost estimates for management and 

O&M plan development and implementation for schools with friable ACM or nonfriable ACM. 

Those activities incurring burden that were not completed during the initial 10 years of 

implementation are shown in Worksheet 1.
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Worksheet 1 indicates that the annual estimated recordkeeping burden for schools with 

friable ACM is approximately 35 hours for public primary schools and private schools, and 58 

hours for public secondary schools. For schools with nonfriable ACM only (including newly

constructed schools covered by exclusionary statements), the annual estimated recordkeeping 

burden is 15 hours for public primary schools and private schools, and 28 hours for public 

secondary schools. This approach may overstate the respondent burden for newly constructed 

schools covered by exclusionary statements because these schools will not incur a burden related 

to records of inspection, re-inspection, response actions and periodic surveillance. However, 

newly constructed schools covered by exclusionary statements still would need to keep certain 

information and records up-to-date. This includes name and training records for the AHERA 

Designated Person and dated copies of each year’s annual notification of the management plans 

availability to parents, teachers and employees, along with a description of the steps taken to 

provide the notification.

Worksheet 1: Annual Respondent Burden per Local Education Agency (Hours)

Burden Hour Elements

School Type

Public Primary or 

Private

Public 

Secondary

Schools With Friable Asbestos-Containing Materials

Implement Management Plan

Asbestos program manager - Activity planning, create 

and gather information, prepare activity reports, record 

and review information

10 15

Custodial - Gather, record, process and store 

information 4 8

Clerical - Gather, record, process and store information 16 30

Total Management Plan 30 53

Implement Operations and Maintenance (O&M) Plan

Asbestos program manager - Activity planning, create 

and gather information, prepare activity reports, record 

and review information

2 2

Custodial - Gather, record, process and store 

information 1 1

Clerical - Gather, record, process and store information 2 2

Total O&M Plan 5 5

Total recordkeeping burden per school with Friable 

ACM 35 58

Schools With Nonfriable Asbestos-Containing Materials Only

Implement Management Plan
13

Asbestos program manager - Activity planning, create 

and gather information, prepare activity reports, record 

and review information

5 8

Custodial - Gather, record, process and store 

information 4 8

Clerical - Gather, record, process and store information 6 12

Total recordkeeping burden per school with 

Nonfriable ACM 15 28

Source: EPA. 1987. AHERA Economic Impact Analysis; Table 11 and Appendix G: “Second 

Year Implementation Costs.” Nonfriable ACM does not require an O&M Plan. 

States

States are involved in both the Schools Rule and the MAP Rule. State activities related 

to the Schools Rule were completed during the first 10 years of program implementation. The 

MAP Rule went into effect in 1994, at which time states were to apply to EPA for new program 

approval. For the purposes of this analysis, all states are assumed to have completed 

accreditation program approval during previous ICR periods. Therefore, no burden for initial 

state activities is included in this ICR.

For all states with EPA-approved accreditation programs, an on-going burden associated 

with the MAP Rule is the implementation of state accreditation programs. Annual burden 

estimates from the MAP Rule are given in Worksheet 2. These estimates assume that all states 

have approved accreditation programs. In cases where a state does not have an approved 

program, the burden would be shifted to EPA. This assumption provides the most conservative 

estimates of state burdens.

Worksheet 2: Annual Respondent Burden per State or Territory (Hours)

Burden Hour Elements Labor Category Total 

Hours

ManagementTechnicalClerical

Annual activities

Implement a state accreditation program that is not 

less stringent than the regulation 8 23 109 140

Total annual activities 8 23 109 140

Source: EPA. 1993. Supplemental ICR for the Asbestos-Containing Materials in Schools Rule. 

(EPA ICR #1365).

Training Providers

Training providers were required to recertify under the revised MAP. Providing access to 

records is expected to take 5.5 hours per year per training provider, as indicated in Worksheet 3, 

while the retention of the records is considered a customary and usual business practice. 

Therefore, no additional burden is associated with this task.
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Worksheet 3: Annual Respondent Burden per Training Provider (Hours)

Burden Hour Elements Labor Category Freq/Year Total Hours Clerical

Annual activities

1. Retain records 0 N/A 0

2. Provide reasonable access to records to 

EPA or state 0.5 11 5.5

Total annual activities 0.5 11 5.5

6(b) Estimating Respondent Costs

The cost estimates addressed in this section are based on the burden estimates discussed 

above and additional non-wage costs discussed below. Wage rates (including benefits) have 

been updated from the values in the AHERA RIA (EPA, 1987a), the Supplemental ICR for the 

Asbestos-Containing Materials in Schools Rule (EPA, 1993), and the previous ICR (EPA, 2007) 

to reflect 2010 levels. Methods for updating hourly wage rates to 2010 levels are discussed for 

each respondent category.

Local Education Agencies

The implementation cost to LEAs of the Schools Rule includes the wages associated with 

the burden estimates in Section 6(a). Labor costs were updated to 2010 using mean hourly wage 

rates from the Bureau of Labor Statistics’ National Industry-Specific Occupational Employment 

and Wage Estimates, the Employment Cost Index for wages and salaries, and the Employer 

Costs for Employee Compensation, as follows:

 The school asbestos program manager, custodian, and clerical staff hourly

wages were $25.87, $14.06, and $15.69 for 2009, the most recent year for 

which data are available. They are based on the mean hourly wages for 

Occupational Health and Safety Specialists and Technicians1, Building and 

Grounds Cleaning and Maintenance Occupations, and Office and 

Administrative Support Occupations, respectively. These wage rates are 

specific to Elementary and Secondary Schools (NAICS 611100) and are based 

on data from both public and private schools (BLS, 2010c).

 According to the Employment Cost Index, wages and salaries rose by 1.7 

percent during the period of May 2009 to May 2010 for these workers, and 

wages and salaries used in this analysis have been increased by this amount 

(BLS, 2010a).

 

1 The wage figure used for Occupational Health and Safety Specialists and Technicians is a weighted average, by 

employment, of the wages for the separate groups of Specialists and Technicians, and is for Local Government 

specifically. 
15

 According to the Employer Costs for Employee Compensation, wages and 

salaries accounted for 65.9 percent of total compensation for school 

employees as of September 2006. Based on this information, a loading factor 

of 1.517 (1/0.659) was applied to the mean hourly wage rate to estimate total 

hourly compensation for school employees (BLS, 2010b).

 The updated, estimated 2006 total hourly compensation for school asbestos 

program manager, custodian, and clerical staff are $39.91, $21.69, and $24.21, 

respectively.

These values were used in Worksheet 4 to calculate current recordkeeping and reporting 

costs to schools with friable and/or nonfriable ACM, as shown below. In addition, schools are 

required to provide annual notification to parents and other interested parties of the presence of 

ACM, as well as the availability of the management plan for public review. The AHERA RIA

estimated the annual notification cost to be $56 per school (EPA, 1987a). This figure was 

updated to $93 in 2010 dollars using the implicit price deflator for the Gross Domestic Product 

(GDP) (Dept. of Commerce, 2010).

Worksheet 4 indicates that the annual reporting costs for schools range from $525 for 

public primary schools or private schools with only nonfriable ACM, to $1,649 for public 

secondary schools with friable ACM.

Worksheet 4: Annual Cost per Local Education Agency (2010$)

Activities

School Type

Total Hourly 

Compensation

Public 

Primary and 

Private

Public 

Secondary

Schools With Friable Asbestos-Containing Materials

Implement Management Plan

Asbestos program manager - Activity planning, create 

and gather information, prepare activity reports, 

record and review information

$39.91 $399 $599

Custodial - Gather, record, process and store 

information $21.69 $87 $174

Clerical - Gather, record, process and store 

information $24.21 $387 $726

Total Management Plan $873 $1,499

Implement Operations and Maintenance (O&M) Plan

Asbestos program manager - Activity planning, create 

and gather information, prepare activity reports, 

record and review information

$39.91 $80 $80

Custodial - Gather, record, process and store 

information $21.69 $22 $22
16

Clerical - Gather, record, process and store 

information $24.21 $48 $48

Total O&M Plan $150 $150

Estimated Cost per School $1,116 $1,649

Schools With Nonfriable Asbestos-Containing Materials Only

Implement Management Plan

Asbestos program manager - Activity planning, create 

and gather information, prepare activity reports, 

record and review information

$39.91 $200 $319

Custodial - Gather, record, process and store 

information $21.69 $87 $174

Clerical - Gather, record, process and store

information $24.21 $145 $291

Estimated Cost per School $525 $877

Source: EPA. 1987. AHERA Economic Impact Analysis; Table 11 and Appendix G: "Second 

Year Implementation Costs." Nonfriable ACM does not require O&M. Cost per School includes 

$88 for Notification Costs.

States

As discussed in Section 6(a), states have no additional costs associated with the Schools 

Rule. Under the MAP Rule, state accreditation programs are required at least to meet the 

standards of the revised MAP. The burden estimates associated with the MAP Rule are given in 

Section 6(a). No additional costs for materials were given in the Supplemental ICR for the 

Asbestos-Containing Materials in Schools Rule (ICR #1365) (EPA, 1993). Worksheet 5 shows 

the estimated annual cost of state compliance with the MAP Rule is $4,436.

Wage rates were updated to 2010 using mean hourly wage rates from the Bureau of 

Labor Statistics’ National Industry-Specific Occupational Employment and Wage Estimates, the 

Employment Cost Index for wages and salaries, and the Employer Costs for Employee 

Compensation, as follows:

 The state managerial, technical, and clerical staff hourly wages for 2009, the most 

recent year for which data are available, were $37.74, $27.15, and $17.88, based 

on the mean hourly wages for Management Occupations, Environmental 

Scientists and Specialists, Including Health, Office and Administrative Support 

Occupations, respectively. These wage rates are specific to State Government 

(NAICS 999200) (BLS, 2010c).

 According to the Employment Cost Index, wages and salaries rose by 1.7 percent 

during the period of May 2009 to May 2010 for these workers, and wages and 

salaries were inflated by this amount (BLS, 2010a).
17

 According to the Employer Costs for Employee Compensation, wages and 

salaries accounted for 65.9 percent of total compensation for state employees as 

of December 2009. Based on this information, a loading factor of 1.517 

(1.0/0.659) was applied to the mean hourly wage rate to estimate total hourly 

compensation for school employees (BLS, 2010b).

 The updated estimated 2010 total hourly compensation for state managerial, 

technical, and clerical staff are $58.22, $41.89, and $27.59, respectively.

Worksheet 5 shows the estimated annual cost of State compliance with the MAP Rule is 

$4,436 per state.

Worksheet 5: Annual Cost per State/Territory (2010$)

Labor Categories

Activities Management Technical Clerical Total

$58.22/hour $41.89/hour $27.59/our

Implement a state accreditation 

program that is not less stringent 

than the regulation

$466 $963 $3,007

Estimated Cost per 

State/Territory $466 $963 $3,007 $4,436

Training Providers

The reporting and recordkeeping burden under the MAP Rule for asbestos training 

providers is described in Section 6(a). Providing access to records is expected to take 5.5 hours 

per year per training provider, and to be done by clerical staff. Wage rates were updated to 2010 

using mean hourly wage rates from the Bureau of Labor Statistics’ National Industry-Specific 

Occupational Employment and Wage Estimates, the Employment Cost Index for wages and 

salaries, and the Employer Costs for Employee Compensation, as follows: 

 The training provider clerical staff hourly wage for 2009, the most recent year for 

which data are available, was $16.48 based on the mean hourly wage for 

Administrative Support Occupations. This wage rates is specific to Business 

Schools and Computer and Management Training (NAICS 611400) (BLS, 

2010c).

 According to the Employment Cost Index, wages and salaries rose by 1.6 percent 

during the period of May 2009 to May 2010 for these workers, and wages and 

salaries were inflated by this amount (BLS, 2010a).

 According to the Employer Costs for Employee Compensation, wages and 

salaries accounted for 75.5 percent of total compensation for employees of service 

producing private industry as of December 2009. Based on this information, a 
18

loading factor of 1.325 (1.0/0.755) was applied to the mean hourly wage rate to 

estimate total hourly compensation for training provider staff (BLS, 2010b).
19

 The updated estimated 2010 total hourly compensation for training provider 

clerical staff is $22.19.

In addition, training providers are expected to incur materials costs associated with the 

annual recordkeeping requirements of the MAP Rule. Those costs were estimated to be $436 in 

the MAP Rule (EPA, 1993), which was updated to $591 in the previous ICR. This figure was 

again updated to $628 in 2010 dollars using the implicit price deflator for the Gross Domestic 

Product (GDP) (Dept. of Commerce, 2010).

Worksheet 6 shows the estimated annual cost of training provider compliance with the 

MAP Rule is $750 per training provider.

Worksheet 6: Annual Cost per Training Provider (2010$)

Labor Category

Clerical Freq/Year Total

$22.19/hour

Activities

1. Retain records N/A N/A $628

2. Provide reasonable access to 

records to EPA or State $11.10 11 $122

Estimated Cost per Provider $11.10 11 $750

6(c) Estimating Agency Burden and Cost

Agency burden and cost estimates are presented in Worksheets 7 and 8.

EPA Burden

EPA conducts implementation activities associated with the Schools Rule. In the 

AHERA RIA (EPA, 1987a), EPA estimated that Federal implementation of the Schools Rule 

would require the services of eight full-time equivalent (FTEs) employees in the first year, four 

FTEs in years two to four, and two FTEs in subsequent years. Because the rule is now past the 

initial four-year period, the remaining EPA burden from implementing the Schools Rule is two 

FTEs annually. This represents an annual burden of 4,160 hours.

In addition, an estimated 220 hours per year of management and technical labor are 

required to respond to questions about the MAP Rule. The annual burden from both rules 

combined is estimated to be 4,380 hours in subsequent years.

The EPA regional burden associated with auditing training provider courses and records 

is expected to be approximately 144 hours per year per regional office.

Worksheet 7: Annual Agency Burden Estimates for EPA Headquarters and Regional 

Offices (Hours)

Activity Labor Category Freq/ Total
20

Management Technical Year

EPA Headquarters

1. Perform recordkeeping tasks 

under the Schools Rule 0 4,160 N/A 4,160

2. Answer respondent questions 

about the MAP Rule 20 200 N/A 220

Total Headquarters 20 4,360 4,380

EPA Regional Offices

1. Audit training provider 

courses and records for 

compliance monitoring purposes

0 8 18 144

Total per Region 0 8 18 144

EPA Costs

Consistent with previous ICRs, technical tasks are expected to be completed by staff at 

the GS-13 level, and management tasks at the GS-15 level. The 2010 GS-13 level, step 5 hourly 

compensation was $77.36 for technical staff, while the 2006 GS-15 level, step 5 hourly

compensation was $107.54 for managerial staff (OPM, 2010). These hourly rates include the 

standard 60 percent loading factor for EPA personnel.

Estimates incorporating these hourly compensation rates and the burden hour estimates 

from the previous section are shown in Worksheet 8. Total annual costs for EPA Headquarters 

are estimated at $339,441. Total annual costs for EPA Regional Offices are estimated at $11,140 

per region, or $111,400 for all 10 regions.
21

Worksheet 8: Annual Agency Cost Estimates for EPA Headquarters and Regional Offices

(2010 $)

Activity Labor Category

Management Freq/Year Total

$107.54/hour

Technical

$77.36/hour

EPA Headquarters

1. Perform recordkeeping tasks 

under the Schools Rule $0 $321,818 N/A $321,818

2. Answer respondent questions 

about the MAP Rule $2,151 $15,472 N/A $17,623

Total Headquarters $2,151 $337,290 $339,441

EPA Regional Offices

1. Audit training provider 

courses and records for 

compliance monitoring purposes

$0 $619 18 $11,140

Total per Region $0 $619 18 $11,140

6(d) Bottom Line Burden Hours and Costs

Table 4 and Appendix G of the AHERA RIA (EPA, 1987a), and Figure 2, Addendum to 

ICR #2070-0091 Asbestos in Schools Rule (EPA, 1987b), estimate the change in number of 

schools with friable and nonfriable ACM over the implementation period of the rule. The intent 

of the Schools Rule is that all schools have a management plan, and that schools with friable 

ACM also have an O&M plan. The number of school respondents in this ICR renewal is based 

on the average number of affected schools of each type for years 23 through 25 of program 

implementation, which is an extension of the method used in the previous ICR. The total 

number of public and private schools is based on 2007-2008 data obtained from the U.S. 

Department of Education’s National Center for Education Statistics (Dept of Education, 2010).

As in previous ICRs, the total number of training providers is estimated using the latest 

National Directory of AHERA Accredited Courses, compiled by EPA. According to the most 

recent 2009 data available, there are currently 1,268 accredited training providers (EPA, 2009). 

This is a significant increase from the previous ICR, in which there were 636 accredited training 

providers listed. Based on the unit burden estimates from Section 6(a) and the unit cost

estimates from Section 6(b), estimated annual recordkeeping burden for all training providers is 

6,974 hours and the estimated annual cost is $951,000.

The MAP rule affects all 50 states, the District of Columbia, and the U.S. territories, for a 

total of 56 states and territories. Based on the unit burden estimates from Section 6(a) and the 

unit cost estimates from Section 6(b), estimated annual recordkeeping burden for all states and 

territories is 7,840 hours and the estimated annual cost is $248,416.

Based on these estimates of numbers of respondents, unit costs, and burdens, the total 

respondent and EPA tallies are shown in the following tables.
22

(i) The respondent tally

Average Annual Respondent Aggregation Table

Number of 

Entities

Unit 

Burden

Total Burden Unit Cost Total Cost

Local Education Agencies

Schools with Friable ACM

Public Primary 3,975 35 139,125 $1,116 $4,436,100

Public Secondary 2,341 58 135,778 $1,649 $3,860,309

Private 2,004 35 70,140 $1,116 $2,236,464

Schools with Nonfriable 

ACM

Public Primary 64,293 15 964,395 $525 $33,753,825

Public Secondary 28,307 28 792,596 $877 $24,825,239

Private 31,736 15 476,040 $525 $16,661,400

Subtotal 132,656 2,578,074 $85,773,337

Training Providers 1,268 5.5 6,974 $750 $951,000

States/Territories 56 140 7,840 $4,436 $248,416

Total 133,980 2,592,888 $86,972,753

(ii) The Agency tally

Average Annual Agency Aggregation Table

Number of 

Entities

Unit 

Burden

Total 

Burden

Unit Cost Total Cost

Headquarters 1 4,380 4,380 $339,441 $339,441

Regions 10 144 1,440 $11,140 $111,400

Total 5,820 $450,841

6(e) Reasons For Change in Burden

The average estimated number of schools of each type in the three years of this ICR 

renewal period (years 23 through 25 of the implementation period) is used with the unit burden 

estimates to derive an annual burden estimate. This ICR renewal follows the same methods of 

estimating numbers of schools with friable and nonfriable asbestos as the previous ICR renewal. 

The total burden estimate for respondents has increased since the most recently approved 

renewal of this ICR because of adjustments for Local Education Agencies and Training 

Providers. While the numbers of schools with friable ACM have declined, that decrease is less 

than the increase in the number of schools with nonfriable ACM, resulting in higher totals 

overall. The total annual burden for this information collection is currently estimated to be 

2,592,888 hours per year. This is a 2.3 percent increase above the annual burden of 2,530,600

hours in the most recently approved clearance of this information collection request. Most of this 

increase is associated with the increase in the number of schools with nonfriable ACM. The 
23

number of training providers has almost doubled since the previous ICR, but this has had only a 

small impact on the overall burden from this data collection. 

Changes in Respondent Burden

Burden Hour Estimates Percent 

Change

Respondent Type Previous Current Difference

Local Education 

Agencies

2,519,262 2,578,074 58,812 2.3 %

Training Providers 3,498 6,974 3,476 99.4 %

States/Territories 7,840 7,840 0 0 %

Total 2,530,600 2,592,888 62,288 2.5 %

6(f) Burden Statement

The annual public burden for this collection of information, which is approved under 

OMB Control No. 2070-0091, is estimated to be 20.15 hours per response for schools, 140 hours 

per response for states, and 5.5 hours per response for training providers. According to the 

Paperwork Reduction Act, “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. For this collection it 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 number for this information collection appears above. The OMB control numbers 

for EPA’s regulations in title 40 of the CFR, after appearing in the Federal Register, are listed in 

40 CFR part 9 and included on the related collection instrument or form, if applicable.

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 No. EPA-HQ-OPPT-2010-0568. The docket is available for public viewing at the 

Pollution Prevention and Toxics Docket in the EPA Docket Center (EPA/DC). The EPA/DC 

Public Reading Room is located in the EPA West Building, Room 3334, 1301 Constitution Ave., 

NW., Washington, DC. The EPA/DC 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 EPA/DC 

Public Reading Room is (202) 566-1744, and the telephone number for the Pollution Prevention 

and Toxics Docket is (202) 566-0280. An electronic version of the public docket is available 

through the Federal Docket Management System (FDMS) at www.regulations.gov. Use FDMS 

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. Once in the 

system, select “search,” then key in the docket ID number identified above. Also, you can send 
24

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please 

include the EPA Docket ID No. EPA-HQ-OPPT-2010-0568 and OMB control number 2070-

0091 in any correspondence.
25

References

U.S. Bureau of Labor Statistics. 2010a. Employment Cost Index --- March 2010. News Release 

of April 30, 2010. Table 2. Employment Cost Index for wages and salaries, by occupational 

group and industry. Web site http://www.bls.gov/schedule/archives/eci_nr.htm. 

U.S. Bureau of Labor Statistics. 2010b. Employer Costs for Employee Compensation ---

December 2009. Table 3. Employer costs ... and costs as a percent of total compensation: State 

and local government workers .... Table 5. Employer costs ... and costs as a percent of total 

compensation: Private industry workers .... News Release of March 10, 2010. Web site 

http://www.bls.gov/schedule/archives/ecec_nr.htm. 

U.S. Bureau of Labor Statistics. 2010c. Occupational Employment Statistics: May 2009 National 

Industry-Specific Occupational Employment and Wage Estimates. Web site 

http://www.bls.gov/oes/2009/may/naics4_611400.htm for NAICS 611400 and SOCs 29-9011, 

37-0000, and 43-0000; http://www.bls.gov/oes/2009/may/naics4_611100.htm for NAICS 

611100 and SOCs 11-0000 and 43-0000; and 

http://www.bls.gov/oes/2009/may/naics4_999200.htm for NAICS 999200 and SOCs 11-0000, 

19-2041, and 43-0000. 

U.S. Department of Commerce. 2010. Bureau of Economic Analysis. Gross Domestic Product:

Implicit Price Deflator. Accessed through the Saint Louis Federal Reserve Bank at 

http://research.stlouisfed.org/fred2/series/GDPDEF/downloaddata?cid=21. Series ID GDPDEF, 

Gross Domestic Product Implicit Price Deflator. Index 2005=100. 

U.S. Department of Education. April 2010. National Center for Education Statistics. Digest of 

Education Statistics: 2009. Table 86: Number of public school districts and public and private 

elementary and secondary schools. Web site 

http://nces.ed.gov/programs/digest/d09/tables/dt09_086.asp 

U.S. EPA. 1987a. Office of Toxic Substances, Economics and Technology Division. Asbestos

Hazard Emergency Response Act Regulatory Impact Analysis. September, 1987.

U.S. EPA. 1987b. Office of Pesticides and Toxic Substances. Addendum to ICR #2070-0091 

Asbestos-In-Schools Rule. October, 1987.

U.S. EPA. 1991. ICR Renewal for the Asbestos Hazard Emergency Response Act (AHERA),

Title II of the Toxic Substances Control Act (TSCA) - Asbestos-Containing Materials in Schools 

Rule. OMB No. 2070-0091. EPA ICR #1365.

U.S. EPA. 1993. Supplemental ICR for the Asbestos-Containing Materials in Schools Rule. 

OMB No. 2070-0091. EPA ICR #1365.

U.S. EPA. 1994. Renewal ICR for the Asbestos-Containing Materials in Schools Rule. OMB No. 

2070-0091. EPA ICR #1365.
26

U.S. EPA. 1997. Renewal ICR for the Asbestos-Containing Materials in Schools Rule. OMB No.

2070-0091. EPA ICR #1365.

U.S. EPA. 2001. Renewal ICR for the Asbestos-Containing Materials in Schools Rule. OMB No.

2070-0091. EPA ICR #1365.

U.S. EPA. 2004. Renewal ICR for the Asbestos-Containing Materials in Schools Rule. OMB 

No. 2070-0091. EPA ICR #1365.

U.S. EPA. 2007. Renewal ICR for the Asbestos-Containing Materials in Schools Rule. OMB 

No. 2070-0091. EPA ICR #1365.

U.S. EPA. 2009. Office of Pollution Prevention and Toxics. . National Directory of AHERA 

Accredited Courses, Active Training Provider List. June 2009. Web site 

http://www.epa.gov/asbestos/pubs/provname.pdf.

U.S. Office of Personnel Management. 2010. Salary Table 2010-DCB. Web Site

http://www.opm.gov/oca/10tables/html/dcb_h.pdf.
27

ATTACHMENTS:

Attachment A Asbestos Hazard Emergency Response Act, Section 203

Attachment B Asbestos Hazard Emergency Response Act, Section 206

Attachment C Asbestos-Containing Materials in Schools Rule (40 CFR 763, Subpart E)

Attachment D Model Accreditation Plan (40 CFR 763, Subpart E, Appendix C)

Attachment E Worksheet A-1: Annual Recordkeeping Burden, by School Type and 

Asbestos Type, Revised for Years 20 through 22

Worksheet A-2: Annual Recordkeeping Cost, by School Type and 

Asbestos Type, Revised for Years 20 through 22

Attachment F Copies of Consultation Letters Sent and Received